{"operation":"document","citation":"PI-76-052","title":"M. J. Schiff and Associates — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1976-09-02","effective_on":null,"summary":"PI-76-052 response to M. J. Schiff and Associates concerning 192.457.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-052.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-052.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-052","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1976/PI76052.pdf","body":"<<<PAGE 1>>>\n\nSeptember 2, 1976\nMr. M. J. Schiff\nM. J. Schiff and Associates\n1291 North Indian Hill\nClaremont, California 91711\nDear Mr. Schiff:\nThis refers to your letter of July 26, 1976, asking whether this office is considering an extension\nof the deadline for corrosion control under §192.457(b) with respect to mobile home park\noperators.\nYour letter indicates that an extension is necessary because these operators did not have the five\nyear lead time that most gas operators had and where only recently notified that they were subject\nto the regulations.\nSection 192.457 was published in the Federal Register on June 30, 1971, and the five year lead\ntime for compliance provided in the regulation itself applied to all gas pipeline operators,\nincluding operators of systems in mobile home parks. Although it may be true that many mobile\nhome park operators did not become aware of the regulation until recently, we do not feel that\nthis would be sufficient reason to extend the deadline for compliance with respect to those\noperators. As a matter of policy, we will, of course, take into account all extenuating\ncircumstances in enforcing the August 1, 1976, deadline.\nAs you requested, we are forwarding copies of our Annual Reports.\nSincerely,\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\ndal\\192\\457\\76-09-02\n1\n\n<<<PAGE 2>>>\n\nM. J. SCHIFF & ASSOCIATES\nJuly 26, 1976\nOffice of Pipeline Safety Operations\nDepartment of Transportation\nWashington, D.C. 20590\nGentlemen:\nThank you for Advisory Bulletin No. 76-7. It has answered a number of questions which I had\npreviously written about. It also may relieve the minds of some very small mobile home park\noperators who may not be able to meet the August 1, 1976 deadline.\nIs consideration being given to extension of this deadline for mobile home parks since they did not\nhave the same five year lead time that most gas operators had? I believe mobile home park\noperators were notified that they were covered by the act only within the last couple of years.\nWe would appreciate a copy of the Eight Annual Report as well as any previous copies that may\nstill be available. We do not have any annual reports in our files at this time.\nThank you.\nVery truly yours,\nM. J. Schiff\nM. J. Schiff and Associates\nConsulting Corrosion Engineers\ndal\\192\\457\\76-09-02\n2","truncated":false,"body_characters":2333}