The Electric and Communication Facility Safety Section (ECFSS) regularly audits the electric and communications systems of utilities. ECFSS staff reviews the maintenance and inspection programs for the overhead and underground facilities required by Rules 31.1 and 31.2 in GO 95 and 17.1 and 17.2 in GO 128, and for electric distribution utilities, their inspection program required by GO 165. If violations are found, citation letters listing the violations are issued asking the utilities involved to take corrective actions. Follow-up audits may be conducted to verify compliance.
NOTE: Rule 12.3 in both GO 95 and 128 provides that the rules contained in the general orders are not retroactive. Therefore in order to determine if a particular facility is in compliance with the rules, one must know the age of the facility and whether any reconstruction has taken place. Then the rules that were in effect at the time the facility was constructed are applied.
The goal of an electric audit is to ensure that an electric utility is following the construction, maintenance and inspection requirements outlined in GOs 95, 128 and 165. ESRB normally conduct audits of electric utilities or, in the case of large utilities, their operational units every three or four years. ESRB may increase the frequency of audits based on any significant problems found. A typical audit lasts three to five days, depending on the size of the utility or unit.
During an audit, ESRB engineers review utility records and perform field inspections of utility facilities. The primary focus of the records review is to check the utility for compliance with General Order requirements and to find systemic problems in the utility’s compliance procedures. The field inspection focuses on verifying the records looked at during the records review and on performing quality assurance on the work done by utility employees.
Within 30 days of the audit, ESRB issues an audit summary to the utility. The summary includes all violations noted during the audit and an explanation of why the USRB considers each violation valid. The letter may also suggest changes in utility procedures in order to improve the safety and reliability of their electric systems. Utilities typically have 30 days to respond to the audit summary with a plan to correct all noted violations.
ESRB audits CIPs separately from electric utilities. Unlike electric utilities, CIPs are not bound by the inspection requirements outlined in GO 165. Prior to 2009, CIP inspection procedures were largely based on GO 95 Rules 31.1 and 31.2, and GO 128 Rules 17.1 and 17.2. that required CIPs to inspect their facilities, but did not specify inspection intervals. On August 20, 2009, CPUC adopted D.09-08-029 which required CIPs to conduct visual inspections of their facilities in high and very high fire threat zones in Southern California by September 2010. D.09-08-029 additionally amended GO 95 to include Rule 18. Rule 18 in part requires CIPs to create a maintenance plan to correct problems discovered on their systems.
ESRB's goal is to ensure all communication providers comply with the construction and maintenance requirements of GOs 95 and 128. ESRB determines CIP audit cycles based on the severity of non-compliance issues found within a CIP. CIP audits typically last for two to three days. The CIP audit is similiar to an electric audit where ESRB engineers conduct a comprehensive records review, verify equipment conditions in the field, and look for systemic procedural problems. ESRB notifies the CIP of violation within 30 days of the audit and requires the CIP to respond with a corrective action plan.