BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                  AB 1694
                                                                  Page  1

          Date of Hearing:   April 9, 2012

                    ASSEMBLY COMMITTEE ON UTILITIES AND COMMERCE
                               Steven Bradford, Chair
                   AB 1694 (Fuentes) - As Amended:  March 21, 2012
           
          SUBJECT  :   Gas pipeline safety inspections.

           SUMMARY  :   Allows the California Public Utilities Commission 
          (PUC) to employ a risk-based approach in determining the 
          frequency of inspections for master-metered natural gas and 
          propane systems.  Specifically,  this bill  :

          1)A risk-based inspection schedule adopted by the PUC requires 
            that if the natural gas or propane operator demonstrates 
            compliance with the initial inspection, additional inspections 
            would be made pursuant to at least once every 10 years.

           EXISTING LAW:   

          1)Requires the PUC to undertake a gas safety inspection and 
            enforcement program for mobile home parks with distribution 
            systems to ensure compliance with the federal pipeline 
            standards, as defined, by propane operators within the state.  
            It also requires that the PUC conduct an initial inspection, 
            and, if the operator demonstrates compliance, to inspect the 
            system every 5 years.

          2)Requires the PUC to undertake a propane safety inspection and 
            enforcement program for propane distribution systems to ensure 
            compliance with the federal pipeline standards, as defined, by 
            propane operators within the state.  It also requires the PUC 
            to conduct an initial inspection, and if the operator 
            demonstrates compliance, inspect the system as specified by 
            law.

           FISCAL EFFECT  :  Unknown.

           COMMENTS  :  According to the author, AB 1694 provides the PUC 
          with resource flexibility so that it can better respond to 
          public safety needs.

           1)Background  : Approximately 3,476 mobile home master-metered 
            natural gas systems and 618 propane systems across the state.  
            The PUC must physically inspect mobile home park 








                                                                  AB 1694
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            master-metered natural gas distribution systems at least once 
            every five years.  There is a more stringent inspection 
            frequency for propane systems.  The PUC must inspect propane 
            distribution systems once every five years for systems with 
            less than 100 customers, once every three years for systems 
            with 100 or more but less than 200 customers, and once every 
            two years for systems with 200 or more customers.  

            On September 24, 2010, the PUC formed its own The Independent 
            Review Panel (Panel) to investigate the September 9, 2010 
            explosion of a Pacific Gas and Electric Company (PG&E) 
            pipeline in San Bruno.  In June 2011, the Panel issued its 
            report with recommendations for PG&E and the PUC.  The Panel 
            recommended that the PUC pursue legislation to replace the 
            mandatory minimum audit requirements with a risk-based regime 
            that would provide the PUC's Consumer Protection and Safety 
            Division (CPSD) with the flexibility in how it allocates 
            inspection resources.


           1)Risk-based inspection program  : The PUC's currently conducts 
            audits of master-metered natural gas and propane mobile home 
            park 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. 
          2)This bill would allow the PUC to employ a risk-based approach 
            in determining the frequency of inspections for master-metered 
            natural gas and propane systems.  According to the PUC, 
            substituting a risk-based inspection schedule would enable the 
            PUC to allocate its inspection resources more effectively to 
            focus on the mobile home parks and propane systems it 
            determines are at the highest priority for inspection.

            CPSD's risk-based inspection process would be designed to 
            ensure that only operators who consistently demonstrate an 
            understanding of the regulations, cooperate with CPSD 
            inspections, and comply with the most important aspects of 
            regulations would be placed on a maximum 10-year inspection 
            interval.  While the risk-based inspection plans would not be 








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            reviewed or approved by the US Department of Transportation 
            Pipeline and Hazardous Materials Safety Administration 
            (PHMSA), the PUC would receive PHMSA guidance on a risk-based 
            approached in developing and implementing this new regime.  
            CPSD would consider criteria such as recordkeeping of 
            operating plans, system maps used to prevent excavation 
            damage, responding to emergencies, hiring of qualified 
            personnel to perform job duties, and providing public 
            awareness literature to all customers served by the system. 

            CPSD performed an analysis, using data from previous 
            inspections, to determine how many operators would have 
            inspection frequencies extended, or decreased, compared to 
            current requirements.  The analysis concluded that 
            approximately 50% of natural gas master-metered system 
            operators would be candidates for an extended cycle; of that 
            amount an estimated 51% would have inspection intervals 
            extended up to 10 years; approximately 43% would remain on 
            current inspection frequency, and 7% of operators would have 
            inspection frequencies increased to less than 5 years.  For 
            propane system operators, approximately 66% operators would be 
            candidates for any extended cycle; of that amount an estimated 
            58% would have inspection interval extended to up to 10 years; 
            24% will remain on current inspection frequency, and 10% would 
            have inspection frequencies increased below current 
            requirements.

             The author may wish to consider reducing the time between 
            inspections from 10 years to 7 years to ensure that operators 
            who have been candidates for extended cycle inspections are 
            maintaining safe operations. 
          
           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          California Pipe Trades Council
          California Public Utilities Commission (CPUC) (Sponsor)
          California State Association of Electrical Workers
          Coalition of California Utility Employees
          Division of Ratepayer Advocates (DRA) (if amended)
          Western Manufactured Housing Communities Association

           Opposition 
           








                                                                  AB 1694
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          None on file.
           
          Analysis Prepared by  :    DaVina Flemings / U. & C. / (916) 
          319-2083