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Public Service Commission http://psc.ky.gov Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George W. Wakim, P.E.

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Page 1: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Manager

Water & Sewer BranchDivision of Engineering

Public Service Commission

PSC INSPECTION REPORT

George W. Wakim, P.E.

Page 2: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

• Highlights the results of a periodic inspection.

PSC Inspection Report

• The purpose of an inspection is to document that a utility has a system in place that demonstrates its compliance with the Public Service Commission’s Statutes and Regulations.

Page 3: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Statutes & Regulations• KRS 278, 74• 807 KAR 5:006, 011, & 066• Ensure utilities provide customers with safe, adequate, and reliable service at fair, just, and reasonable rates

Page 4: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Elements of Inspection Program

Report

Pre-Inspection

Follow-Up

Inspection

Enforcement

Page 5: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Pre-Inspection

Page 6: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

The Inspector Cometh . . .

The Inspector is the eyes and ears of the

Public Service Commission.

Page 7: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Periodic Inspection

Office Review (Office Manager)• Posted tariffs, rules, regulations, &

statutes• Office personnel security and safety• Office records (new special charges,

fees)• Number of customers• Billing cards & deposit data• Customer complaints & customer service

Page 8: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Periodic Inspection

Office Review (Utility Manager)• Upcoming construction projects• Rate issues (proposed increases)• Water purchase contracts• Water loss figures from previous year• New water sales to other utilities• Meter testing program• System map

Page 9: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Periodic Inspection

Office Review (Utility Manager)• Safety program• Inspection program and records• Maintenance program and records• Water quality• Valve program and records• Unaccounted-for water loss

(non-revenue water)

Page 10: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Periodic Inspection

Office Review (Utility Manager)• Flushing program and records• Fire protection• Water pressure and records• Water shortage response plan

Page 11: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Periodic Inspection

Record Keeping

Page 12: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Periodic Inspection

Field Review (Certified Operator)• Utility plant• Distribution system• Inspection and maintenance records• Photographs of water plant, storage tanks,

pump stations, deficient facilities• Customer surveys

Page 13: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Inspection Report• Inspection checklist used to draft report• Written report summarizes investigation, includes photographs• Sites new deficiencies and highlights any repeat deficiencies using Deficiency Tracking Report• Copies sent to utility & Division of Water • Utility has 30 days to respond to any deficiencies

Page 14: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Inspection Report

Page 15: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Inspection Report

Page 16: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

or This?This?

Inspection/Maintenance Related Findings

Page 17: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

or This?This?

Inspection/Maintenance Related Findings

Page 18: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

or This?This?

Inspection/Maintenance Related Findings

Page 19: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

or This?This?

Inspection/Maintenance Related Findings

Page 20: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Root Cause Analysis

Goal of this Method

By going to root cause and encouraging the utility to manage their compliance, we can

reduce the likelihood of a non-compliant utility.

Page 21: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

What Creates an Outcome?

Man MachineMethod

EnvironmentManagement

Outcome

Inputs

An outcome can be the results of a maintenance program, service reliability, failure to properly test customer meters, etc.

Material

Page 22: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Basic Problem Definition

Problem = Unexpected or Undesired Outcome– Outcomes are determined by inputs so a

problem indicates an inappropriate or missing input

– Therefore, to solve a problem you must analyze the inputs to the system

Page 23: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Defining The Problem

• The most important step to solving the problem is properly defining the problem.

• If the problem is defined wrong you will arrive at the wrong solution.

• Example: A water tank is noted to be rusted by an investigator. It is tempting to define the problem as the tank is rusting. The root cause of which would be a chemical reaction between the iron and atmospheric oxygen. This is the expected state of iron when exposed to oxygen. It is not actually a problem. A more appropriate problem definition would be the utility has allowed the tank to become rusty. The problem analysis would then concentrate on why the utility did not properly maintain the tank.

Page 24: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Typical Response• A typical response addresses the output

rather than the inputs. If the problem is a leaking tank, then the response is to fix the leak. This is actually fixing the output.

• This is ineffective because it does not address the cause of the problem. Therefore the problem will happen again.

Page 25: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Desired Response

Responses need to address the cause of the problem as well as correct the outcome.

Application to InspectionStart from the regulation, ask/look for how the utility plans to comply. Then look for evidence that the plan is working.

Page 26: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Regulatory Compliance

Man(Certified)

Machine(Lab)

Method(Training)

EnvironmentManagement(Is there a plan?

Is it being followed?)

METER TESTINGFREQUENCY

INPUTS

So, an inspection involving the meter testing practices of a utility may start with management’s plan and end with an inventory of the meters tested, rather that just

checking the meters tested.

Material

Page 27: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

• Why did the deficiency occur?• What was done to correct the deficiency?• What was done to prevent recurrence?• Who is responsible for correcting and/or preventing?• Evidence of corrective actions required.

Deficiency Tracking Report(DTR)

Page 28: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Deficiency Tracking Report(DTR)

Page 29: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Deficiency Tracking Report(DTR)

Page 30: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Deficiency Tracking Report(DTR)

Page 31: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Deficiency Tracking Report(DTR)

Page 32: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Deficiency Tracking Report(DTR)

Page 33: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Example Progress Report

Page 34: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Example Water Meter Testing/Replacement Program

Page 35: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Be Proactive, not Inactive or Reactive

• Read and understand the applicable parts of the Kentucky Revised Statutes 278 and 74 and 807 Kentucky Administrative Regulation

• Develop management practices to ensure compliance such as:

–Development and maintenance of an O&M Manual per 401 KAR 8:020 Section 2(13) that could contain, but not limited to:

Page 36: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Be Proactive, not Inactive or Reactive

Preventative Inspection/ Maintenance Program Proactive Meter Testing/Replacement Plan Water Loss Prevention/Leak Detection Program Asset Management/Replacement Program Training and Staff Development Program

Page 37: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Be Proactive, not Inactive or Reactive

• Promptly notify DOW, PSC, & customers of any BWA’s, NOV’s, etc., and report any corresponding major accidents.

• A record-keeping system• Provide PSC periodic updates regarding any

actions taken to control water loss, meter testing, asset management, etc.

Page 38: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Summary

– PSC Inspection Program– Statutes and Regulations– Inspection Report– Root Cause Analysis– Deficiency Tracking Report (DTR)– Recommendations

Page 39: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Questions?

Page 40: Public Service Commission  Manager Water & Sewer Branch Division of Engineering Public Service Commission PSC INSPECTION REPORT George

Public Service Commissionhttp://psc.ky.gov

Public Service Commission

Manager, Water & Sewer BranchDivision of Engineering

George W. Wakim, P.E.

211 Sower Blvd.

Frankfort, KY 40602

http://psc.ky.gov

Ph: (502) 564-3940 ext 409

Fax: (502) 564-1582

[email protected]