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Interpretation Response #PI-76-055 ([City of Coalinga] [Kenneth H. Valley])

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

Interpretation Response Details

Response Publish Date:

Company Name: City of Coalinga

Individual Name: Kenneth H. Valley

Location State: CA Country: US

View the Interpretation Document

Response text:

September 10, 1976

Mr. Kenneth H. Valley
Director of Public Works
City of Coalinga
Coalinga, California 93210

Dear Mr. Valley:

This refers to your letter of July 30, 1976, requesting "an extension to December 1, 1977" to meet the corrosion control requirements of 49 CFR 192.457(b). Since 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 assigned the matter Docket No. Pet. 76-21W.

You have stated that you are unable to comply with Section 192.457(b) by the August 1, 1976, deadline because of "manpower shortages and economic considerations." We do not find that this assertion by itself is sufficient justification for granting a waiver. The August 1 deadline was established in 1971, allowing operators at least 5 years to make the necessary arrangements for compliance. Accordingly, your request is denied.

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 the City is 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.

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