Small Operators: There are two types of small gas systems:
· Mobilehome parks that take natural gas service through a master meter and then distribute it to park residents through their own system of underground pipes (MHP).
· Systems where liquefied petroleum gas (LPG) is distributed from a master tank through underground pipes to multiple customers (Propane Master Tank).
Regulations: Title 49 of the Code of Federal Regulations, Parts 190, 191, 192, 193, and 199. CPUC General Order No. 112-E.
Public Utilities Code, Sections 4351 through 4360 gives the California Public Utilities Commission (Commission) jurisdiction over the safety of master-metered natural gas systems in mobilehome parks. In January 1995 the Commission also assumed jurisdiction over the safety of propane master tank distribution systems. Assembly Bill 766 (Hauser) adopted Public Utilities Code, Sections 4451 through 4465 giving the Commission jurisdiction over Propane Master Tank systems serving 10 or more customers not in a mobilehome park or two or more customers inside a mobilehome park. The Gas Safety and Reliability Branch (GSRB) of the Commission enforces Federal Pipeline Safety Regulations through audits of jurisdictional MHP and Propane Master Tank systems. Audits consist of reviewing operation and maintenance records, evaluating emergency procedures, and performing field inspections of the gas distribution facilities. If violations are found, the operator is given an inspection form requesting that corrective measures be taken within a specified time. If the operator complies and reports the corrective actions to the inspector, the inspection is closed. If the operator fails to comply, a citation and fine may result.
In resolution SU-24, dated 12/17/1993 the Commission delegated authority to GSRB to cite and fine MHP operators for failure to comply with pipeline safety regulations. Resolution USRB-001 dated July 31, 2008 delegated similar authority for operators of propane master tanks. These fines are not to exceed $1,000 per day and $200,000 per violation. In levying fines, GSRB considers a number of factors including the gravity of the offense and the operator's history of compliance. There is an appeal process.
Public Utilities Code Section 2791 put a stop to the construction of master metered mobilehome parks. It requires that residents of mobilehome parks built after January 1, 1997 be directly served by the gas and electric utilities serving in that area. Sections 2791 through 2799 outline a process by which existing master metered mobilehome parks can be converted to direct utility service. GSRB encourages such conversions. Because the serving utilities are exclusively in the business of providing gas and electric service, a consistently high standard of maintenance and safety is assured. Benefits to operators of master metered parks include relief from complying with increasingly complex and demanding federal pipeline safety regulations and equally complex requirements for rendering bills for service.
The GSRB is required by Section 4353(b) to audit the gas facilities of MHP's at least once every seven years pursuant to a risk-based inspection schedule. Over 2,800 MHP's are currently under the jurisdiction of the Commission. Section 4453(b) requires GSRB to audit Propane Master Tank Systems once every seven years pursuant to a risk-based inspection schedule. Over 600 propane operators are currently contained in the Commission's database.
Assistance: To help small utilities and operators, the U.S. Department of Transportation - Pipeline and Hazardous Materials Safety Administration publishes guidance manuals for operators of small natural gas and propane systems.
Each year, the GSRB presents seminars to operators of small gas systems on how to comply with the federal regulations.
The Western Manufactured Housing Communities Association (WMA) represents the interests of owners of mobilehome parks
The Western Propane Gas Association (WPGA) represents the interests of marketers of propane
The Golden State Manufactured-Home Owners League (GSMOL) represents the interests of people who live in mobilehomes
User fees: The Commission is a user-funded agency and it collects fees based on the number of customers served by the master metered MHP or propane system. These fees are included in the master meter bill for natural gas customers and may be passed through to the submetered customers. The GSRB bills propane master tank systems annually at the time it mails the annual report
Annual Reports: Small operators are required to submit annual reports to the Commission giving a description of their system, the number of customers and the dates of most recent leak surveys and cathodic protection surveys. The due dates of the Annual reports are staggered to coincide with the time when license renewal is due.
Blank MHP-1 Form
How to prepare Operations and Maintenance (O&M) plan: Title 49 CFR 192, Section 192.605 requires each operator to prepare a manual of written procedures for conducting operations, maintenance, and emergency activities. GSRB has prepared a sample Guidance Manual to help small operators prepare their own Operation, Maintenance and Emergency (OM&E) Plan, Operator Qualification (OQ) Program, and Distribution Integrity Management Program (DIMP). This guide provides information on what is required to be included in your plans. Many outside vendors also can help you prepare the OM&E Plan, OQ Program, and DIMP.
2012 Guidelines for Preparing OM&E Plans, OQ Plan, & DIMP for MHP Gas Systems
2012 Guidelines for Preparing OM&E Plans, OQ Plan, & DIMP for Propane Gas Systems