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Interpretation Response #PI-76-038 ([Jackson, LA] [Honorable James M. Norsworthy, Jr.])

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

Interpretation Response Details

Response Publish Date:

Company Name: Jackson, LA

Individual Name: Honorable James M. Norsworthy, Jr.

Location State: LA Country: US

View the Interpretation Document

Response text:

July 16, 1976

Honorable James M. Norsworthy, Jr.
Mayor, Town of Jackson
Jackson, Louisiana 70748

Dear Mr. Mayor:

This refers to your request for a waiver from the requirements of 49 CFR 192.457(b) on behalf of the Town of Jackson, Louisiana, by letter dated June 23, 1976, which we have docketed as Pet. 76-10.

We have reviewed the information submitted and find for the following reasons that a waiver is not justified. Accordingly, the request is denied.

The main reason for the waiver appears to be the impending August 1, 1976, deadline and the consequent lack of time to complete an electrical survey and orderly plan of compliance. Without a showing of extreme circumstances, this reason cannot serve as the basis for a waiver because the deadline was established on June 21, 1971, to allow all operators at least 5 years to make the necessary arrangements for compliance. Also, we do not believe that the absence of underground facilities where gas might accumulate and the insulation of houses from the gas system are sufficient reasons for a waiver. There are many opportunities for fire or explosion due to a leaking gas system which would not be affected by those factors.

We note that the Town may choose to completely replace its gas system as an alternative to cathodically protecting the existing one. This course of action may provide sufficient grounds for a waiver from Section 192.457(b) if there is assurance that replacement is economically practicable for the Town and would begin and be completed within a reasonable period of time.

The enclosed statement of interpretations and enforcement policy may be helpful to you in reviewing your need for a waiver.

Sincerely,

Cesar DeLeon
Acting Director
Office of Pipeline
Safety Operations

Regulation Sections

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