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March 24, 1987 <br />ci q Of VOW 9 iew <br />RAMSEY COUNTY. MINNESOTA <br />2401 HIGHWAY 10 <br />MOUNDS VIEW. MINN. 55112 <br />784.0055 <br />ROUGH DRAFT <br />Dockets Unit <br />Office of Hazardous Materials Transportation <br />Research and Special Programs Administration <br />U.S. Department of Transportation <br />400 Seventh Street• Southwest <br />Washington, U.C. 20590 <br />RE: Docket No. PS-93; Notice 1 <br />To Whom It May Concern: <br />The referenced Advance Notice of Proposed Rulemaking invites <br />public comment on the need for new or amended safety standards <br />for gas or hazardous liquid pipeline. The City of Mounds View <br />wishes to afford itself of this opportunity to once again state <br />our position, in a clear and concise manner, that current Federal <br />standards are wholly inadequate and require substantial modifica- <br />tion. <br />Our position is based on the premise that current regulations <br />were first put in place to protect public health, safety and <br />welfare and to preserve the environment. Evidence introduced <br />during the National Transportation Safety Board's (NTSB) in- <br />vestigation of the July 8, 1986 Williams Pipe Line Company (WPL) <br />incident in Mounds View as well as testimony given during the <br />NTSB's Board of Inquiry Hearing clearly shows the inadequacy of <br />current Federal regulations and the Office of Pipeline Safety's <br />(OPS) inspection program. The record further indicates that, at <br />least at it applies to WPL, there is a general lack of <br />compliance by the pipeline industry with both the intent and <br />the letter of Federal regulations. <br />It has also become apparent to the City that the general attitude <br />of the UPS is to regulate the pipeline industry in a manner which <br />leads one to believe the UPS has a predisposition to regulate in <br />favor of the industry. <br />The City is convinced that the only.way to correct the current <br />unacceptable level of pipeline regulation and inspection is to <br />® legislatively mandate those standards necessary to assure the <br />safe operation of interstate gas and hazardous liquid pipelines. <br />We will, however, continue to encourage any effort undertaken to <br />instigate and implement increased safety standards based upon <br />current regulations and wish to offer our comments regarding the <br />proposals identified in the referenced notice. <br />