# The Commonwealth of Massachusetts Department of Public Utilities — Pipeline Safety Interpretation

- **operation:** document
- **citation:** PI-93-005
- **title:** The Commonwealth of Massachusetts Department of Public Utilities — Pipeline Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 1993-02-05
- **effective on:** Not available
- **summary:** PI-93-005 response to The Commonwealth of Massachusetts Department of Public Utilities concerning 193.2001.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-005.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-005.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-005
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1993/PI93005.pdf
**body:**

<<<PAGE 1>>>

February 5, 1993
Mr. Chris Bourne
The Commonwealth of Massachusetts
Department of Public Utilities
Leverett Saltonstall Building
Government Center
100 Cambridge Street
Boston, MA 02202
Dear Mr. Bourne:
This responds to your letter of January 22, 1993. As we discussed
over the phone on January 12, 1993, if a state waiver regarding an
LNG mobile facility is granted, it should be granted to the
operator using the LNG mobile facility. The waiver should identify
the distribution systems where the LNG mobile facilities will be
used; state conditions that may be placed on the use of these LNG
mobile facilities; and indicate why the waiver will not compromise
pipeline safety.
A waiver request by an interstate pipeline would have to be made to
our office, and, if we are disposed to granting the waiver, we
would publish the waiver request in the Federal Register and
request and evaluate comments before granting the waiver. This
process takes a few months.
As we discussed, by the Natural Gas Pipeline Safety Act allows this
office 60 days to object to a state agency waiver, but we intend to
act expeditiously and plan to make a decision on the waiver within
three days. Accordingly, the state agency waiver should be made
effective in 60 days unless approved at an earlier time.
The following respond specifically to your questions in the order
enumerated in your letter:
1. Yes, if the LNG mobile pipeline unit is connected to pipi ng
owned by an intrastate operator, the unit is under the
jurisdiction of the State agency. If it is connected to
piping owned by an interstate operator, it is under the
jurisdiction of RSPA.
2. Yes, a State agency may grant waivers that are not a site o r
unit specific, but must identify the operator.
3. A state agency may grant a waiver for an unlimited period, if
appropriate conditions are placed on the use of the LNG
facility.
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4. The state agency should place appropriate conditions, such as
fire protection, security, personnel qualification, site
requirements, etc., on the use of these LNG mobile facilities.
5. Yes, while RSPA has 60 days to approve or deny a waiver, RSPA
will approve or deny a waiver regarding LNG mobile facilities
within 3 days.
In the meantime, a State agency should exercise judgment in
enforcing the regulations when a mobile LNG facility is being used
in an emergency to provide gas service.
Sincerely,
Cesar DeLeon
Directory Regulatory Programs
Office of Pipeline Safety
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