public service commission manager water & sewer branch division of engineering public service...
TRANSCRIPT
Public Service Commissionhttp://psc.ky.gov
Manager
Water & Sewer BranchDivision of Engineering
Public Service Commission
PSC INSPECTION REPORT
George W. Wakim, P.E.
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.
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
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Elements of Inspection Program
Report
Pre-Inspection
Follow-Up
Inspection
Enforcement
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Pre-Inspection
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The Inspector Cometh . . .
The Inspector is the eyes and ears of the
Public Service Commission.
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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
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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
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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)
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Periodic Inspection
Office Review (Utility Manager)• Flushing program and records• Fire protection• Water pressure and records• Water shortage response plan
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Periodic Inspection
Record Keeping
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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
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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
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Inspection Report
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Inspection Report
Public Service Commissionhttp://psc.ky.gov
or This?This?
Inspection/Maintenance Related Findings
Public Service Commissionhttp://psc.ky.gov
or This?This?
Inspection/Maintenance Related Findings
Public Service Commissionhttp://psc.ky.gov
or This?This?
Inspection/Maintenance Related Findings
Public Service Commissionhttp://psc.ky.gov
or This?This?
Inspection/Maintenance Related Findings
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.
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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
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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
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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.
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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.
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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.
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
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• 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)
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Deficiency Tracking Report(DTR)
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Deficiency Tracking Report(DTR)
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Deficiency Tracking Report(DTR)
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Deficiency Tracking Report(DTR)
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Deficiency Tracking Report(DTR)
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Example Progress Report
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Example Water Meter Testing/Replacement Program
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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:
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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
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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.
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Summary
– PSC Inspection Program– Statutes and Regulations– Inspection Report– Root Cause Analysis– Deficiency Tracking Report (DTR)– Recommendations
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Questions?
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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