# City of Palo Alto Utilities Department — Pipeline Safety Interpretation

- **operation:** document
- **citation:** PI-96-012
- **title:** City of Palo Alto Utilities Department — Pipeline Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 1996-07-09
- **effective on:** Not available
- **summary:** PI-96-012 response to City of Palo Alto Utilities Department concerning 192.375.
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- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-96-012
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1996/PI96012.pdf
**body:**

<<<PAGE 1>>>

07/09/96
Mr. Greg Scoby, P.E.
Senior Engineer
City of Palo Alto Utilities Department
P.O. Box, 10250
Palo Alto, CA 94303
Dear Mr. Scoby:
We are responding to your letter requesting waivers for the Palo Alto municipal gas system
pursuant to our authority under Section 60106(a) Agreement (1). The waiver requests apply to
49 CFR §§ 192.375 and 192.3.
Section 192.375 - The request is to allow an anodeless riser, connected at the end of an
underground plastic gas supply line, to make an aboveground transition to metallic piping that
runs up the outside building wall.
This installation appears typical for an anodeless riser. While inside the riser casing, the
aboveground segment of plastic pipe is protected from deterioration and external damage as
required by § 192.375(a)(1). As long as the encased plastic pipe is not supporting external
loads in violation of § 192.375(a)(2), there is no conflict with this section.
Section 192.3 - The request is to allow a main on private property that transports gas from
another main (located in a public street or in a utility easement) to a privately-owned manifold
with multiple customer meters, to be treated and operated as a service line.
The installation appears similar to an approval for a waiver we issued to the Kansas
Corporation Commission on July 3, 1995. However, in the near future, your municipal gas
system is expected to come under the authority of the California Public Utilities Commission.
Subsequent to that change of authority, we feel it would be more appropriate to submit this
matter to Mr. Harry Strahl at the California Public Utilities Commission.
Sincerely,
Richard B. Felder
Associate Administrator
for Pipeline Safety
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