{"operation":"document","citation":"PI-76-055","title":"City of Coalinga — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1976-09-10","effective_on":null,"summary":"PI-76-055 response to City of Coalinga concerning 192.457.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-055.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-055.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-055","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1976/PI76055.pdf","body":"<<<PAGE 1>>>\n\nSeptember 10, 1976\nMr. Kenneth H. Valley\nDirector of Public Works\nCity of Coalinga\nCoalinga, California 93210\nDear Mr. Valley:\nThis refers to your letter of July 30, 1976, requesting \"an extension to December 1, 1977\" to meet\nthe corrosion control requirements of 49 CFR 192.457(b). Since compliance with your request\nwould involve the granting of a \"waiver\" within the meaning of Sec. 3(e) of the Natural Gas\nPipeline Safety Act of 1968 (49 USC 1672(e)), we have assigned the matter Docket No. Pet. 76-\n21W.\nYou have stated that you are unable to comply with Section 192.457(b) by the August 1, 1976,\ndeadline because of \"manpower shortages and economic considerations.\" We do not find that this\nassertion by itself is sufficient justification for granting a waiver. The August 1 deadline was\nestablished in 1971, allowing operators at least 5 years to make the necessary arrangements for\ncompliance. Accordingly, your request is denied.\nIt is our policy not to grant waivers except upon a showing of cogent reasons why a general\nsafety standard should not be followed in a particular situation or an alternative standard is more\nappropriate. In contrast, it appears from your letter that the City is taking steps to achieve\ncompliance as soon as possible.\nWe have enclosed a copy of our recently published notice on corrosion control which may be\nhelpful to you in complying with the requirements.\nSincerely,\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\ndal/192.457\n76-09-10.3\n1\n\n<<<PAGE 2>>>\n\nCity of Coalinga\nJuly 30, 1976\nSecretary Department of Transportation\nOffice of Pipeline Safety\nWashington, D.C. 20590\nGentlemen\nWe, the City of Coalinga, Coalinga, Calif. request an extension be granted in regard to the\nAugust 1, 1976 deadline for Cathodic Protection under the provisions of Department of\nTransportation, OPS, Title 49, CFR Part 1, Subpart 192.455 and 192.457.\nOur lack of compliance is the direct result of manpower shortages and economic\nconsiderations.\nOur Cathodic Protection program to date follows:\n1. 2. 3. 4. We have employed the services of a professional consulting firm for compliance\n(November, 1975).\nWe had determined areas of active corrosion by a leak survey and electrical survey;\nthese areas will be Cathodically protected (-.850 volts) as soon as insulators and\nanodes can be installed.\nAll new services installed are plastic; the steel riser has an anode attached by\nmanufacture design.\nA comprehensive gas leak survey, using flame inization [sic] over the entire\nsystems, is conducted annually the commercial area is checked semi-annually and\nall \"B\" and \"C\" leaks are rechecked several months after repair to determine\neffectiveness of repair. Therefore, in areas where active corrosion is not found,\nleakage surveys monitor changes in the corrosive condition of the pipeline.\nElectrically surveys also compliment our leakage surveys.\nWe have established the following time table:\n1. In areas of active corrosion, Cathodic Protection shall be established by August 1,\n1977. Anode installation has begun, along with insulators.\ndal/192.457\n76-09-10.3\n2\n\n<<<PAGE 3>>>\n\n2. 3. 4. Annually leakage surveys over the entire system shall continue, along with our\nrecheck program.\nComplimentary electric survey with leakage on an annual basis.\nOur gas distribution system shall be in compliance with the federal regulations by\nDecember 1, 1977.\nWe therefore request an extension to December 1, 1977, be granted in lieu of our above\nstated purpose.\nSincerely,\nKenneth H. Valley\nDirector of Public Works\ndal/192.457\n76-09-10.3\n3","truncated":false,"body_characters":3588}