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Interpretation Response #PI-93-050 ([Massachusetts Department of Public Utilities] [Chris Bourne])

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

Interpretation Response Details

Response Publish Date:

Company Name: Massachusetts Department of Public Utilities

Individual Name: Chris Bourne

Location State: MA Country: US

View the Interpretation Document

Response text:

August 17, 1993

Mr. Chris Bourne

Chairman, New England Pipeline Safety Representatives

Massachusetts Department of Public Utilities

Saltonstall Building

100 Cambridge Street

Boston, MA 02202

Dear Mr. Bourne:

Thank you for your letter of July 12, 1993, commenting on the applicability of 49 CFR Part 193 to mobile LNG plants. You asked us to reconsider our position that such plants are covered by Part 193, and to determine instead that they are subject to the operating and maintenance plan requirements of 49 CFR 192.605. You further asked us to comment on a set of draft guidelines intended either as instructions for enforcement of §192.605 or as conditions under state waivers of Part 193.

After reviewing the matter once more, we do not believe there is sufficient reason to change our position that mobile LNG plants are covered by 49 CFR Part 193 rather than 49 CFR Part 192. However, we believe the draft guidelines are appropriate to use as conditions under state waivers of Part 193. In fact, as you pointed out, one version of the suggested guidelines is already in effect under a waiver granted by New Hampshire. The guidelines could be used as conditions under a single waiver a state agency might grant all jurisdictional operators who apply for a waiver of Part 193 requirements.

Identical letter being sent to Richard Marini and Philip Sher.


Cesar De Leon

Director, Regulatory Programs

Office of Pipeline Safety

Regulation Sections

Section Subject
192.605 Procedural manual for operations, maintenance, and emergencies