City of Bay City — Pipeline Safety Interpretation

Page 1May 21, 1976 Ms. Mildred Nelsen Superintendent of Utilities City of Bay City Bay City, Texas 77414 Dear Ms. Nelsen: Your letter petition of April 7, 1976, requesting a waiver from compliance with the Federal gas pipeline safety standards concerning corrosion control is returned herewith. The petition should be presented to the Texas Railroad Commission which has authority under the Natural Gas Pipeline Safety Act of 1968 to enforce and grant waivers from compliance with the Federal standards for intrastate gas pipeline facilities in Texas. Should the Commission decide to grant the waiver, we will review that decision in accordance with Sec. 3(e) of the Act. Sincerely, Cesar DeLeon Acting Director Office of Pipeline Safety Operations Enclosure dal\192\457\76-05-21 1#

Page 2City of Bay City April 7, 1976 Office of Pipeline Safety Department of Transportation 400 7th Street, S.W. Washington, D.C. 20590 Re: Subpart I of Federal Safety Standards; Subject Corrosion control Dear Sir: Please accept this letter as a petition to seek a waiver for compliance of Subpart I of the Federal Safety Standards concerning corrosion control. At this time, the City of Bay City has only a few areas which have electrolysis and we have begun a program of changing out existing corroded lines with plastic pipe. This will eliminate need for electrodes in these areas. Since plastic pipe is more economical than steel pipe and does not have corrosive qualities, the public will be better served by the City using plastic pipe. The City of Bay City's gas lines are for the most part very old and we are today having the system completely checked for leaks. After the survey, we will determine which part of the system needs upgrading, and begin a systematic program of replacement. We have contacted people in the cathodic protection field and are beginning negotiations to put the required portion of the system under cathodic protection. We have just recently (1975) changed department heads and the present department heads are studying the necessary requirements and all safety acts will be complied with at the earliest opportunity. dal\192\457\76-05-21 2#

Page 3We respectfully request a waiver from the time period of August 1, 1976 until August 1, 1981, which will give the company time to comply with regulations. Sincerely, Mildred Nelsen Supt. of Utilities dal\192\457\76-05-21 3#