CASE 04-M-0159 – Proceeding on Motion of the Commission to Examine the Safety of Electric Transmission and Distribution Systems.
RESPONSES TO QUESTIONS ON ELECTRIC SAFETY STANDARDS
On January 5, 2005, the Commission issued an Order in this proceeding that adopts safety standards applicable to all electric utilities. On January 20, 2005, Department of Public Service Staff conducted a technical conference in this matter to discuss questions the utilities and other interested parties may have regarding implementation of the safety standards. During that technical conference, requests were made to provide written responses to questions and issues raised.
The following is a recitation of general questions and answers that were discussed at the technical conference. They should only be used as a guide to help facilitate the implementation process. They should not be considered interpretations, clarifications, or modifications of the Order. Should any party seek a clarification or modification of the Order, it must file a petition with the Commission, pursuant to the Commission’s regulations.
As stated in the Order, in many instances, the Commission adopted general parameters and guidelines and gave the utilities discretion, without those parameters and guidelines, as to the specific manner in which to implement the safety standards. Therefore, to the extent detailed questions on compliance were raised, specific responses will not be provided. Also, although best practices have not been established, the Order encourages utilities to work together to develop best practices.
Q. WHAT ARE "PUBLICLY ACCESSIBLE" FACILITIES?
A. Publicly accessible facilities are those that are within the reach of a pedestrian. They include, but are not limited to, facilities located in public thoroughfares, parks, rear lots, and off-road. While substations are not considered publicly accessible, substation fencing is. Generally, utility facilities located within fencing on customer premises will not be considered publicly accessible (specific circumstances may lead to a different conclusion, so utilities must exercise good judgment in determining public accessibility). Signs, property lines, and other non-physical demarcations are not considered barriers to public access.
Q. WHAT IS EXCLUDED FROM STRAY VOLTAGE TESTING?
A. The following equipment need not be tested: company- and customer-owned meters, equipment located inside a substation, utility equipment enclosed by customer fencing subject to the caveat stated in the preceding answer, and customer owned equipment except when called in as part of shock complaints or as covered by the streetlight requirements.
Q. WHAT ABOUT TELECOMMUNICATIONS AND CABLE ATTACHMENTS?
A. The utilities need to exercise good judgment in determining which such equipment should be tested. For example, if such equipment is bonded, publicly accessible, and in close proximity to electric facilities (e.g., a cable amplifier attached to a utility pole and using the utility’s down ground), utilities should test it. The Order does not require testing or maintaining an inventory of phone booths, pedestals, and other telecommunications equipment that is not in close proximity to electric facilities.
Q. WHICH STREETLIGHTS SHOULD BE TESTED?
A. As specified in the Order, included are:
Utilities are not required to test streetlights in private parking lots or private parks.
- All company-owned streetlights
- All streetlights under a maintenance contract
- All streetlights on public thoroughfare no matter who owns it
- All streetlights to which the utility provides direct service
- All traffic signals
Q. HOW ARE TESTERS CERTIFIED?
A. A make/model must be certified by independent laboratory; in-house certification is not acceptable. Certification is not required for individual units; once a particular make/model has been certified by any utility, it may be used by every utility without additional certifications.
Q. WHAT STEPS ARE NEEDED FOR CORRECTIVE ACTION IF VOLTAGE FOUND?
A. When stray voltage is found, the utility is required to make the area safe irrespective of who owns the facility causing the stray voltage. Subject to the caveats set forth in the Order, permanent repairs to utility-owned facilities must be made in 45 days. If customer-owned equipment is at fault a utility must notify the customer of the problem. If the facilities that were energized by the customer equipment are publicly accessible, the utility is strongly encouraged to follow up with the customer after repairs are made to make sure the stray voltage condition is truly eliminated.
Q. DOES JOB SITE TESTING FACTOR INTO THE TESTING PROGRAMS?
A. Voltage testing results at job sites do not need to be part of testing program. The Order provides only that it be conducted on a daily basis and when the job is completed. If voltage is found, conditions must be made safe before utility personnel leave the site.
Q. WHAT IS INVOLVED WITH INSPECTIONS?
A. All utility-owned equipment needs to be inspected at least once every five years. Inspections include all utility facilities, not only those covered by the testing programs (e.g., conductors, substation equipment, nonconductive facilities such as fiberglass service boxes and wood poles). With respect to streetlights, utilities are required to inspect only their own facilities. Manholes, service boxes, and other underground structures must be opened regardless of their exterior condition. Any problematic or improper conditions that are found need to be repaired pursuant to the utility’s normal practices, unless stray voltage found. In that case, the 45 day rule applies. Each utility must develop its own definition of “hazardous” condition and its own practices and procedures for evaluating the condition of its facilities and determining the time frame to complete repairs of conditions founds.
Q. HOW DETAILED SHOULD A QUALITY ASSURANCE PROGRAM BE?
A. The Order left the details to each utility’s discretion. A program akin to a nuclear QA program is probably unnecessary, but a QA program limited to simple checks by a foreman is likely insufficient.
Q. WHAT SHOULD BE AVAILABLE FOR PUBLIC ACCESS?
A. The reports each utility files with the Commission should be readily accessible to the public. Other than typical requirements for entrance into utility facilities, no impediments to immediate public access are permitted. Underlying data and detailed inspection and testing reports need not be provided. It is expected that no utility will seek trade secret status for its public reports or otherwise declare any portion of them to be confidential. That is, the reports should be drafted in such a manner that they provide salient and usable information (e.g., summary statistics by borough or similar geographic area) but not details of findings at specific locations.
Q. HOW SHOULD THE DETAILED RECORDS BE KEPT?
A. The Order left the details to each utility’s discretion. The parameters for recordkeeping include that records must be kept in a manner which is easily searchable. Legacy systems that take months to program may not be considered easily searchable. All data needs to be accessible to Staff; confidentiality concerns, if any, will be addressed on a case-by-case basis.
Q. WHY IS THERE CERTIFICATION OF THE PROGRAMS?
A. Accountability. The certifications are a demonstration that the utility’s management is aware of and responsible for the condition of their systems and compliance with the safety standards.
Q. WHAT IS EXPECTED TO BE FILED IN THE ANNUAL REPORTS?
A. The Order left the details to each utility’s discretion. Staff expects that they will include some detail of voltage testing performed and results by geographic area, type of equipment (e.g., poles, manholes), and levels of voltage found. The reports should also include:
As noted above, it is expected that no utility will seek trade secret status for its public reports or otherwise declare any portion of them to be confidential.
- analyses of stray voltage data to show trends or common causes
- certification requirements
- discussion of performance mechanism, if applicable
- information resulting from inspection program
- changes to program implementation (e.g., steps added, lessons learned)
Q. WHAT IS NEW TO THE NOTIFICATION REPORTING CONCERNING SHOCKS?
A. Notification must be made for shock cases whether or not voltage is substantiated. The notification requirements apply to people and domestic animals, not squirrels or birds.
Q. HOW MANY TARGETS ARE IN THE PERFORMANCE MECHANISM?
A. Two targets per year—one for testing, one for inspections. In the 5th year of the inspection program, the target is 100% completion of all inspections.
Q. HOW DOES ADOPTING THE NESC AFFECT THE UTILITY?
A. New facilities constructed must follow NESC guidelines or a utility’s more stringent standards. Specific concerns about existing facilities meeting the NESC will be handled on a case-by-case basis and should be discussed with Staff.