General Order 165
III. Reporting and Recording Requirements
A Comments of the Parties
Edison, PG&E, and Sierra propose the first annual report
be submitted in July 1998 rather than July 1997 in order to provide adequate
time for the utilities to demonstrate compliance with the new standards.
SDG&E supports the annual reporting requirements proposed in D.96-11-021.
ORA recommends that the utilities be required to document all corrective
action scheduled and undertaken as a result of their inspections. It also
recommends that a proposed General Order on inspection cycles require the
utilities to rate the condition of facilities according to results of each
inspection. Along the same lines, CUE proposes that the General Order require
the utility to maintain a record of problems observed by the inspector, the
date of corrective action, and the identity of the person performing the
ORA comments that the Commission, perhaps inadvertently, proposed to require
30-day notice by Commission staff for reviewing utility records. ORA observes
that PU Code Section 314 ( a) provides that Commission staff may inspect
utility records "at any time."
CUE proposes the General Order include specific definitions for "patrol,"
"detailed," and "intrusive," consistent with the discussion in D.96-11-021.
As the utilities suggest, we will require the first annual
reports to be submitted in July, 1998. However, to assure that reports as
well as source records are clear and comprehensive, we direct utilities to
submit compliance plans as soon as possible, but before July 1, 1997. These
compliance plans will include the proposed forms for annual reports and source
records, as well as the utility's plans for the types of inspections and
equipment to be inspected during the coming year. For detailed and intrusive
inspections, schedules should be detailed enough (in terms of the month of
the inspection and the circuit, area, or equipment to be inspected) to allow
staff to confirm that scheduled inspections are proceeding as planned. Since
patrol inspections may be carried out in the course of other utility business,
schedules are not required in advance. However, utilities should explain
how all required facilities will be covered during the year.
The utilities are directed to update this schedule annually. We authorize
Energy Division to review these compliance plans and to prescribe changes
relating to data, definitions, formats, and forms when and as necessary.
D.96-11-021 required that utilities maintain various kinds of information
on inspections. We will also include in the General Order the requirement
that the utilities maintain a record of problems observed by the inspector,
the schedule and actual date of corrective action, and the identity of the
person performing the work. This type of information will promote follow-up
to inspections and serve as a foundation for determining the reasonableness
of utility actions if and when specific problems occur on the system. Finally,
for detailed and intrusive inspections, we adopt ORA's recommendation that
utilities rate and record the condition of inspected facilities.
We incorporate in to the General Order the descriptions of the terms "patrol,"
"detailed," and "intrusive" presented in D.96-11-021, as proposed by CUE.
We agree that Commission staff should not be required to provide 30-day notice
to inspect utility records and will modify our original proposal accordingly.