PSC INSPECTION REPORT George W. Wakim, P.E. Manager Water & Sewer Branch Division of Engineering Public Service Commission

PSC Inspection Report Highlights the results of a periodic inspection. 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.

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

Elements of Inspection Program Pre-Inspection Inspection Enforcement Report Follow-Up

Pre-Inspection

The Inspector is the eyes and ears of the Public Service Commission. The Inspector Cometh . . . The Inspector is the eyes and ears of the Public Service Commission.

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

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

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)

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

Periodic Inspection Record Keeping

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

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

Inspection Report

Inspection Report

Inspection/Maintenance Related Findings This? or This?

Inspection/Maintenance Related Findings This? or This?

Inspection/Maintenance Related Findings This? or This?

Inspection/Maintenance Related Findings This? or This?

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.

What Creates an Outcome? An outcome can be the results of a maintenance program, service reliability, failure to properly test customer meters, etc. Inputs Man Method Machine Outcome Management Material Environment

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

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.

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.

Application to Inspection Desired Response Responses need to address the cause of the problem as well as correct the outcome. Application to Inspection Start from the regulation, ask/look for how the utility plans to comply. Then look for evidence that the plan is working.

Regulatory Compliance INPUTS Man (Certified) Method (Training) Machine (Lab) METER TESTING FREQUENCY Management (Is there a plan? Is it being followed?) Material Environment 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.

Deficiency Tracking Report (DTR) 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)

Deficiency Tracking Report (DTR)

Deficiency Tracking Report (DTR)

Deficiency Tracking Report (DTR)

Deficiency Tracking Report (DTR)

Example Progress Report

Example Water Meter Testing/Replacement Program

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:

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

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.

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

Questions?

Public Service Commission Manager, Water & Sewer Branch Division 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 GeorgeW.Wakim@ky.gov