{"operation":"document","citation":"PI-84-004","title":"Memo: Internal — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1984-07-11","effective_on":null,"summary":"PI-84-004 response to Memo: Internal concerning 192.3.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-84-004.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-84-004.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-84-004","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1984/PI84004.pdf","body":"<<<PAGE 1>>>\n\nJuly 11, 1984\nACTION: February 8, 1983.\nWaiver Granted by Wisconsin Public Service Commission to Wisconsin Gas Company\nRichard L. Beam\nAssociate Director for Pipeline Safety Regulation, DMT-30\nRobert L. Paullin\nAssociate Director for Operations and Enforcement, DMT-10\nIn response to the request on your routing slip of July 3, 1984, forwarding a copy of the May 31,\n1984, memo with attachments from the Chief, Central Region, we have reviewed both the memo\nand the Wisconsin Public Service Commission (PSC) waiver with the supporting staff\nrecommendation.\nWe see several problems with the action taken by the PSC in this matter. As pointed out by the\nChief, Central Region, the required 60 days notice to the Secretary was not provided and the\nattempt to change the definition of the word \"main\" has made applicable regulations less stringent.\nThe effect of the subject waiver was to relieve Wisconsin Gas Company of the construction,\noperating, and maintenance requirements that are applicable to mains for those short sections of\nmain that are similar to service lines but supply gas to two or more customers. However, the\nwaiver does not specifically address each section of the regulations involved. If we were\nrequested to make a detailed review of a similar waiver, we would need to know why the\nregulations involved are inappropriate for these pipelines and why the waiver would not be\ndetrimental to public safety.\nIt is suggested that during the annual monitoring visit to Wisconsin in August 1984 that this\nproblem should be pointed out and that it be explained that the waiver granted February 8, 1983,\nto Wisconsin Gas Company has no legal effect because the PSC has failed to notify MTB as\nrequired by Section 3(d) of the\nNGPSA.\n#\ndal\\192.3\\3\\84-07-11\n1","truncated":false,"body_characters":1781}