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Electrical Distribution Safety
Auditor Debrief
November 4, 2013
Disclaimer
• The information in this presentation was prepared as discussion points for the auditor meeting. In some cases more information may be required to understand the issue fully as discussed during the meeting. For more information please contact [email protected] or [email protected]
Electrical Distribution Safety
Electrical Distribution Safety
AGENDA 1. Review of 2012 Audit results 2. 2013 Questions & Issues 3. Third Party Review of Audit Process 4. Auditor Feedback 5. Other Information
a) Bulletins b) Other Issues c) USF Standards
Electrical Distribution Safety
Summary of Audit Findings for 2012
• 34 LDCs - Full Compliance • 36 LDCs - Needs Improvement only • 21 LDCs with only one Needs Improvement
(’10-17;’11-27) and 6 LDCs with more than two Needs Improvements (’10-14;’11-11)
• 5 LDCs had 1 Non-compliance • 1 LDC had more than 1 Non-compliance
Electrical Distribution Safety
Summary of Audit Findings Life to Date
0 1
12 14
24
27 26
34
8.4
5.3 3.3 2.6 2.0 1.5 1.3 1.0
0
5
10
15
20
25
30
35
40
2005 2006 2007 2008 2009 2010 2011 2012
Total LDCs no Findings Avg # per LDC
Electrical Distribution Safety
Common audit findings Section 6 – Equipment Approvals • Process for approving equipment returned
from field or refurbished • No process documented for approving equipment for re-
use from field or refurbished/repaired. • Some equipment is returned to inventory without
approval/ approval records not documented • The documented procedures/policies should be updated
to reflect current practice • There is discussions underway regarding the Cam Tran
C2C Program and similar programs. • Approved equipment list
• Unapproved equipment used • Not maintained / updated • Controls to ensure that only approved equipment is
purchased • Legacy equipment in inventory not on approved list.
Electrical Distribution Safety
Common audit findings Section 7 – Design • Designs without certificates of approval • Plan changes not approved /approval
not recorded • Designs not reviewed / approved for re-
closer protection settings or no Certificate of Approval
Electrical Distribution Safety
Common audit findings Section 8 – Construction Inspection and sign-off • Maintenance schedules (section 4)
– Documentation incomplete; – Lack of verification that entire system is reviewed on 3 or 6 year
cycles. – No schedule for some equipment/ records unavailable
• Incomplete/missing Records of Inspection and/or Certificate
• Not all work being signed off – meter replacements; small repairs; Trouble calls
• Work energized in stages – Need Record of Inspection & Certificate at each stage of
energization • Missing Third Party attachment ROI/Certificates • Not following approved CVP / CVP not updated to reflect
new processes
Auditor Question
Q. From an LDC: If a developer hires an outside contractor to complete terminations on primary cables and secondary cables and we do a visual inspection prior to energizing the equipment who is responsible for signing the drawing?
A. Section 7 – An approved standard design or plan shall be met.
Section 8 – A qualified person (CVP), P.Eng or the Authority are required to sign-off on the construction. If the contractor is not a qualified person then one of the options above shall be used.
Auditor Question Q. From an LDC: If there was a cable fault due to poor
workmanship by the developer’s contractor would we be liable having signed off the drawing?
A. If the drawing has a Certificate of Approval, then Section 7 Regulation 22/04 requirements are met, however the LDC is still ultimately responsible for the installation if it owns the equipment, regardless of who built it.
Section 8 – If the worker signed off incorrectly that the standard was met, then a non-compliance exists. The LDC is expected to implement a corrective action. This is treated the same whether it is a full time employee or a contractor by the Regulator.
Auditor Question
Q. From an LDC: “During our last DDI, as a safety concern it was noted that a hand cover was missing on a street light.
A. The hand cover is subject to the OESC, not Regulation 22/04 requirements, however if a safety concern is identified during the course of the DDI, it will be noted. This concern would be included in the “Observation” section and a response is not required, as it is recognized that it is not a 22/04 compliance issue.
Auditor Question Q. Distributor Information Bulletin DIB-10/12 shows that an LDC review of
third party attachment plans need not include “re-engineering”. However the bulletin does go on to state: “The LDC shall review to ensure the plan or work instruction meets the requirements of Regulation 22/04 and the Certificate of Approval covers all the proposed construction.” OR 22/04 specifies that overhead lines must provide adequate spacing, energized parts barriered and structures sufficient loading strengths. Under the heading: “When Safety Standards Met”, the regulation also requires compliance with the CSA overhead standard or the Ontario Electrical Safety Code. When reviewing 3rd party plans, What is necessary to ensure compliance and that the third party’s Certificate of Approval covers all of the construction?
A.. What the bulletin is addressing is whether or not it appears that 3rd Party issuing the plan / work instruction has appeared to address the safety issues. If the 3rd Party appears to be missing a safety element, then the LDC reviewer should address the missing elements with the 3rd Party prior to granting permission.
Auditor Question Q. Follow up on requirements for inspection of equipment returned
from the field after refurbishment by an external company. A new nameplate and serial number may be attached to the equipment. One transformer refurbisher considers the equipment new even though the required testing has not been done. In some cases, the refurbisher rewinds transformer designed and built by other manufacturers. Is an inspection by the LDC required on receipt of refurbished equipment?
A.. This issue is currently being addressed with the LDCs. Further direction is expected shortly. Until that time, re-Use of major equipment. 2.7.6 is clear. Is the LDC ensuring that tests, that involve the possibility of affecting a piece of equipment to fail in a safe manner, being followed/passed/signed off by a P.Eng. Is it possible that the summer student is signing off the refurbished unit and the LDC is fine with it?
Auditor Question
Q. Follow up on requirement for a standard design for metering backboards?
A. The Recommendations are requirements to comply with the Regulation sections 6, 7 & 8. ESA does not inspect this equipment as it is embedded LDC equipment.
Auditor Question Q. Review status of P.Eng. seal as evidence that engineering plans meet OR
22/04 requirements.
A..The Auditors are to treat the P.Eng seal as evidence that engineering plans meet OR 22/04 requirements. ESA has no updates that can be provided as to the submitted change requests to the Regulation.
The Regulation requires a Certificate of approval to be compliant with
section 7. If a distributor does not have a Certificate but does have a P.Eng seal, it should be noted as an observation in the audit report so that ESA is aware.
Auditor Question Q. When someone is declared by LDC as qualified or competent
person; i. What criteria to be set to evaluate the qualified person?
The LDC will set the criteria for qualified personnel. ESA reviews and approves the CVP, including qualifications listed.
ii. Should a separate written declaration be completed by a supervisor and kept at HR office? No
iii. Who would be in position to declare this person as qualified person - supervisor or manager? It is deemed that Senior Management approves the CVP for submission to ESA. ESA reviews the CVP for the purpose of providing an approval.
iv. Is it good enough to list the position under the CVP list? Yes. Positions listed need to correspond with personnel
records in HR confirming individuals in the position(s).
Auditor Question Q. The ESA Bulletin DIB-02/13 re. Commercial / Industrial Metering
Installations. The material/equipment related to metering is not a major material. What will be required for Audit? - Approval and data sheet of PT, VT , wires...?.
• A. All equipment used in the distribution system must be approved by the distributor. Equipment (such as revenue billing meters, and instrument transformers) is deemed to be approved if it has a
• Measurements Canada Approval number. The LDC establishes the approval process for equipment used on the distribution system, within the parameters established in the Technical Guidelines. Section 2.1.2 in the Guideline for Equipment Approval states that non-major equipment must be approved as a minimum in accordance with Good Utility Practice, but processes for approval of non-major equipment based on major equipment approval processes is encouraged.
Auditor Question Q. How often should the training or refresher of Re. 22/04 be conducted by
LDC? 2 or 3 years apart? What would be the recommended.
A. LDCs need to determine what frequency of training is required for their staff to ensure compliance. Most LDCS have regular periodic training, new and refresher, for their staff on a number of different topics, which include Reg. 22/04 processes.
ESA expects that with any CVP revisions or addition of new staff (contractors, trainees, transfers from other LDCs, etc…) that workers are fully trained, in the requirements of Regulation 22/04, including the CVP in order to be deemed qualified and competent.
Bulletins published
• DSB-01-13 Revenue Metering Equipment and Natural Gas Meter (NEW)
• DIB-03-13 Approved Auditors (UPDATED) • DIB-02-13 Metering Standards for C-I
installations • DIB-01-13 LDC Attachments on 3rd Party
Poles
Other Issues Relevance of S250 in regards to the “reasonable
information” clause on locates? S250 is the CSA Standard for “Mapping of
underground utility infrastructure”. The standard addresses “Reliability and Accuracy of Mapping Records” and other topics. ESA will continue to use its judgment of reasonable information and will not necessarily use S250 as the definition for reasonable information.
Other Issues On behalf of the Ministry of Consumer Services
(MCS), ESA will be contacting our stakeholders to make them aware of a consultation MCS has begun on the proposal to add administrative monetary penalties (AMPs) to the tools available to enforce the ministry’s consumer protection and public safety statutes.
Electrical Distribution Safety
LDC Mergers
Mergers and Acquisitions • NO LDC mergers have occurred
Potential changes in the near future • Norfolk Power sold to Hydro One – waiting for OEB
approval • Woodstock Hydro may also be sold soon
Electrical Distribution Safety
USF Standards • The USF drawings are now under a
new Certificate issued by a P.Eng, Ron LaPier from AESI.
• All previous Certificates issued by ESA will be revoked on March 15, 2014.
Electrical Distribution Safety
USF Standards
• Lag between new Certificate date and revocation date to allow for work-in-progress to be finished
• Projects already planned and standards assembled but not started yet using previous standards are acceptable
• Project plans started after revocation date must use standards covered by new certificate
Electrical Distribution Safety
• Any Questions?
