2. The Harbor City Submetered Gas System
Harbor City operates and maintains the System, which serves 192 spaces in an MHP in Harbor City, California, with SoCalGas providing the master meter gas service.2 The System is commonly trenched with other utilities. The depth of the trenches varies throughout the system, but was originally specified to be at a minimum depth of 18 inches, which is not in dispute.3 The system was originally specified to be constructed from polyethylene (PE) pipes,4 although whether this is the case was a matter of dispute at hearing.
Whether the System is built entirely of PE pipes or of a mixture of PE and metal was a contested issue in this proceeding. It is undisputed that the System does not contain cathodic protection, which is needed to arrest corrosion in metallic pipes. SoCalGas contends that the failure to provide such protection makes the System of questionable reliability.5
Harbor City contends that cathodic protection is not necessary, as the System is entirely PE.6 SoCalGas argues that there is no proof that the System does not contain metallic pipe, partly because necessary records were not maintained.7 Harbor City argues that this lack of records is not compelling, as the System was inspected by the governing agency at the time of construction and was found to be adequate.8
SoCalGas' argument was originally bolstered by certain inspection reports that referred to tests of the cathodic protection system. However, as explained below in Section 5, these reports were completed by an inspector, Ed Trzepacz, who did not actually perform the inspections and who falsified reports.
Absent these falsified reports, we find no credible reason to doubt that the System was constructed of PE pipes in accordance with the plans. As the system was inspected at the time of construction and was found to be compliant with established safety regulations, we also find that the System is PE and does not require cathodic protection.
2 Exhibit 1, pages 2-3.
3 See Exhibit 5-A, B and C. Harbor City's Schones excavated two random locations in the System, and determined the depths to be 19 inches and 30 inches of cover. Exhibit 16, page 3.
4 Exhibit 5-B.
5 Exhibit 12, pages 4-6.
6 Exhibit 3, page 5.
7 Exhibit 12, pages 9-11.
8 Exhibit 17, page 4. The agency responsible for oversight of construction of submetered gas systems in MHPs is the California Department of Housing and Community Development, as discussed in Sections 3.3.1 and 3.4 below.
