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Interpretation Response #PI-76-052 ([M. J. Schiff and Associates] [M. J. Schiff])

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

Interpretation Response Details

Response Publish Date:

Company Name: M. J. Schiff and Associates

Individual Name: M. J. Schiff

Location State: CA Country: US

View the Interpretation Document

Response text:

September 2, 1976

Mr. M. J. Schiff
M. J. Schiff and Associates
1291 North Indian Hill
Claremont, California 91711

Dear Mr. Schiff:

This refers to your letter of July 26, 1976, asking whether this office is considering an extension of the deadline for corrosion control under §192.457(b) with respect to mobile home park
operators.

Your letter indicates that an extension is necessary because these operators did not have the five year lead time that most gas operators had and where only recently notified that they were subject to the regulations.

Section 192.457 was published in the Federal Register on June 30, 1971, and the five year lead time for compliance provided in the regulation itself applied to all gas pipeline operators,
including operators of systems in mobile home parks. Although it may be true that many mobile home park operators did not become aware of the regulation until recently, we do not feel that this would be sufficient reason to extend the deadline for compliance with respect to those operators. As a matter of policy, we will, of course, take into account all extenuating
circumstances in enforcing the August 1, 1976, deadline.

As you requested, we are forwarding copies of our Annual Reports.

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