The CPUC inspection revolves around three crucial points: the Emergency Plan; Preventative Maintenance Schedules; and Mapping of the Gas System. Strict adherence to my plan will ensure a successful and a brief inspection from the CPUC.

1. Emergency Plan

There is no "one size fits all" Emergency Plan. Each community, as well as each emergency, is different. However, there are common elements that every Emergency Plan is required to have:

A. Evacuation Plan - It must be in written form and posted in a diagrammatic form.

B. Emergency Notices - You must have at least two physical notices per home. One for the most used door and one for the gas riser.

C. Emergency Equipment and Provisions - This includes such items as a shut off valve wrench for the main gas valve and a bottle of soapy water to detect leaks. You are only required to have access to heavy equipment such as a power generator or air compressor. This can easily be achieved by indicating in your Emergency Plan the local equipment rental yard. First aid kits are a must, as well as flash lights, batteries, a portable radio and a communication device.

D. Emergency Call List and Governmental Report Forms - Your call list should start with the owner's or management company's name, onsite manager, local city or county fire department and police department, a local hospital, as well as the CPUC and the Department of Transportation. Please note that all local numbers should be the business phone numbers and not 1-800 numbers. Make sure you have a clean telephonic report form. This form needs to be completed within two hours of a major emergency.

E. Education and Training Reports - You need to review with all staff members the entire contents of your Emergency Plan and all your preventative maintenance procedures. Make sure there is written documentation, including your signature and date, that all staff members have completed this review. Once annually, you must circulate or post some pointers to your residents about natural gas. It should be called a "Public Education of Natural Gas."

2. Preventative Maintenance Schedules

A. Gas Leak Surveys and Cathodic Protection Reports - These are now generally done on an annual basis and all records must be maintained within your Operation and Maintenance Manual for a period of five years.

B. Quarterly Patrolling and Sniff Test - You are required to patrol the gas mains and laterals to observe any evidence of a gas leak. A sniff test is required to assure that the odor the serving gas company applies to your gas is present. Strict written documentation must be observed for these tests.

C. Exercising all Key Valves - A key valve is your master meter valve and any and all sectional valves including shut off valves found on regulator stations. This does not mean removing the valve from the riser and running five miles with it. Generally speaking, you are to close the valve slightly and then return it to its original position. You are required to do this annually, but because of the age of many of the communities, most managers are doing this every six months. As with every one of these points, you must document in writing exactly what you have done.

3. A Map of the Gas System

A. A detailed map of the gas system must be maintained within your Emergency Plan and Operation and Maintenance Manual. This map must include such items as: illustrating where your gas lines run through the community; what type of material are the gas lines; the size of gas main and lateral lines; cathodic protection systems installed; locations of master meter(s) and sectional valves; and locations of any part of the gas system that was replaced with a different material.

Finally, do not overlook the importance of the atheistic appeal of your above ground gas lines. You are required to paint or wrap the above ground gas lines once every three years. I have found that it is a great idea to do this just prior to the inspector meeting with you at your community. They love it and it looks great.

By following my plan, it will minimize the likelihood of an onerous CPUC inspection and it will keep you in very good standing with the State for at least another five years.