Hillsdale Mobile Home Park — Pipeline Safety Interpretation

Page 1July 12, 1976 Department of Transportation 831 Metten Road Burlingame, Ca. 94010 Attention: Bill Whiteman Dear Sir: I am enclosing the information you requested during our phone conversation of two days ago, regarding the gas line safety act, Title 49, Parts 191-192. I received your copy of the act today and will try to comply with the law as soon as possible. I would like to ask for an extension of 120 days from August 1, 1976 in order to complete this work in the best possible manner so as to prevent any future problems. I have a low pressure system to each mobile site and have had no leaks or corrosion problems. The Yacht Harbor Mobile Park is located at 1609 Morgan Lane, Redondo Beach, California. Sincerely, Sam McNeill, Owner 565 Esplanade, #215 Redondo Beach, CA 90277 dal\192\457\76-07-12 1#

Page 2September 10, 1976 Dr. Jules Larner Hillsdale Mobile Home Park 885-13 S. Orange Grove Boulevard Pasadena, California 91105 Dear Dr. Larner: This refers to your letter of July 9, 1976, requesting "an extension" to meet the corrosion control requirements of 49 CFR 192.457(b). Although compliance with your request would involve the granting of a "waiver" within the meaning of Sec. 3(e) of the Natural Gas Pipeline Safety Act of 1968 (49 USC 1672(e)), we have not accepted your letter as a petition for waiver since you have not stated why you are unable to comply with Section 192.457(b) by the August 1, 1976, deadline. The August 1 deadline was established in 1971, allowing operators at least 5 years to make the necessary arrangements for compliance. It is our policy not to grant waivers except upon a showing of cogent reasons why a general safety standard should not be followed in a particular situation or an alternative standard is more appropriate. In contrast, it appears from your letter that you are taking steps to achieve compliance as soon as possible. We have enclosed a copy of our recently published notice on corrosion control which may be helpful to you in complying with the requirements. Sincerely, Cesar DeLeon Acting Director Office of Pipeline Safety Operations dal\192\457\76-07-12 2#

Page 3Enclosure July 9, 1976 California Public Utilities Commission San Francisco, Calif. 94102 Attn: Mr. David La Hue With this letter, we are requesting an extension beyond the Aug. 1, 1976 date of compliance of the Natural Gas Pipeline Safety Act of 1968 as it pertains to the Hillsdale Mobile Home Park, 6300 Roseville Rd., Sacramento, Calif. 95842, of which we are the owners. We have already had a Soil Resistivity Test with the following findings: Soil Resistance Category % of Readings 1K--5K Low 85.8 5K--10K Medium 4.2 Insulating unions are in the process of being installed. A gas leak survey and the required installations will follow. We will appreciate your cooperation. JULES LARNER, M.D. dal\192\457\76-07-12 3#

Page 4dal\192\457\76-07-12#