[38 Pa.B. 5273]
[Saturday, September 27, 2008]
[Continued from previous Web Page] Overhead line inspections distribution--foot patrol annually and transmission aerially twice per year and foot patrol every 2 years.
The EAP claims inspection costs would increase by $12 million annually, due to the necessity of more frequent inspections. The distribution line inspection under the proposed regulation would cost $4.6 million above present practices, and the above chart roughly supports that assertion.
The EAP claims that the current inspection and maintenance programs on overhead distribution lines utilized by Pennsylvania EDCs work well to both find and fix the problems. They focus on identifying deterioration of facilities, encroachment on the lines by property owners and vegetation, and finding damage to equipment that has not resulted in a service outage. Most equipment or material-related failures are caused by internal deterioration that is not readily determined by visual means. Many equipment failures are caused by lightening strikes, high winds, or other severe weather events that cause flashovers or through-faults at the time of the event. These failures will not be decreased by increasing frequency of visual inspections. Therefore, the EDCs wish to retain their individual inspection cycles for distribution lines.
Duquesne Light commented that annual foot patrols are extremely time consuming, expensive and labor intensive. Duquesne has over 7,000 miles of lines traversing varying terrain, and that amount is very small in comparison with other utilities in the state. Annual foot patrols are not relevant to Duquesne. The PUC should encourage the use of intelligent automated distribution components that have self-diagnostic capabilities and can be monitored remotely. Duquesne agrees that 30 days from discovery is a reasonable length of time within which to repair a known problem found during an inspection that can affect the integrity of the system subject to certain conditions, i.e. scheduling line outages for repair work must be coordinated with PJM, and the like.
PECO commented that the Commission should not adopt the distribution line inspection requirement because PECO already maintains and inspects its distribution system in compliance with all requirements of the National Electric Safety Code and the Commission should defer to the Code. PECO uses a ground patrol every 2 years that includes visual and thermographic inspection of its system. The thermographic computer equipment determines where hot spots are on the distribution lines, transformers and electrical connections. PECO believes that more frequent measurements would not measurably improve the reliability of the systems.
Disposition
Upon consideration of these comments, we are persuaded to change the annual standard to a 1-2 year requirement because most of the EDCs do not inspect annually, and some only use thermography, instead of foot patrol. If critical maintenance problems are found that affect the integrity of the circuits, they shall be repaired or replaced no later than 30 days from discovery.
An inspection shall include checking for broken insulators, conditions that may affect operation of the overhead transformer, and other conditions that may affect operation of the overhead distribution line.
Proposed: 52 Pa. Code § 57.198(e)(3): Overhead line inspections. Transmission lines shall be inspected aerially twice per year in the spring and fall. Transmission lines shall be inspected on foot every 2 years. Distribution lines shall be inspected by foot patrol a minimum of once per year. If problems are found that affect the integrity of the circuits, they shall be repaired or replaced no later than 30 days from discovery. Overhead distribution transformers shall be visually inspected annually as part of the distribution line inspection. Aboveground pad-mounted transformers and below-ground transformers shall be inspected on a 2-year cycle. Reclosers shall be inspected and tested at least once per year. Since the bolded portion above seems to cause no immediate problems, it will remain in the regulation.
Company 1990 1995 2000 Current Incremental Cost Allegheny Hazardous conditions repaired as soon as possible; problems without near-term consequences scheduled within following budget cycle. Hazardous conditions repaired as soon as possible; problems without near-term consequences scheduled within following budget cycle. Hazardous conditions repaired as soon as possible; problems without near-term consequences scheduled within following budget cycle. Hazardous conditions repaired as soon as possible; problems without near-term consequences scheduled within following budget cycle. NA Duquesne Serious problems were corrected when funding and resources were available. Serious problems were corrected when funding and resources were available. Serious problems generally corrected within 6 months; no standard for timely action. Serious problems corrected within 30 days; no standard for timely action on lower priority issues. NA Met-Ed No response. No response. No response. No response. Unknown. Penelec No response. No response. No response. No response. Unknown. Penn Power No response. No response. No response. No response. Unknown. PECO No response. No response. No response. No response. NA PPL Critical problems immediately addressed; others combined with other work; transmission problem schedule based on severity. Critical problems immediately addressed; others combined with other work; transmission problem schedule based on severity. Critical problems immediately addressed; others combined with other work; transmission problem schedule based on severity. Critical problems immediately addressed; others combined with other work; transmission problem schedule based on severity. NA UGI No response. No response. No response. No response. See 'UGI' above. Citizens' No response. No response. No response. No response. NA Wellsboro No response. No response. No response. No response. NA Pike County No standard. No standard. No standard. No standard. NA
EAP claims that placing a 30 day limitation for repair will not improve reliability because it will not accelerate the repair of urgent problems; conversely, it will increase cost and decrease resource flexibility for work crews by placing artificially short time schedules on noncritical repairs. The EDCs should retain the ability to determine the urgency of repair and to schedule resources accordingly.
Disposition
If critical maintenance problems are found that affect the integrity of the circuits, they shall be repaired or replaced no later than 30 days from discovery. Therefore, the Commission will adopt some of the AFL-CIO's language and incorporate it into subsection (n)(5) because without some repair deadlines, the regulation has less meaning.
Proposed: 52 Pa. Code § 57.198(e)(3): Overhead line inspections. Transmission lines shall be inspected aerially twice per year in the spring and fall. Transmission lines shall be inspected on foot every 2 years. Distribution lines shall be inspected by foot patrol a minimum of once per year. If problems are found that affect the integrity of the circuits, they shall be repaired or replaced no later than 30 days from discovery. Overhead distribution transformers shall be visually inspected annually as part of the distribution line inspection. Aboveground pad-mounted transformers and below-ground transformers shall be inspected on a 2-year cycle. Reclosers shall be inspected and tested at least once per year.
Company 1990 1995 2000 Current Incremental Cost Allegheny Inspected in conjunction with circuit inspection. Inspected in conjunction with circuit inspection. Inspected in conjunction with circuit inspection. Inspected in conjunction with circuit inspection. Additional cost included in foot patrol. Duquesne No formal inspection program. No formal inspection program. Infrared inspection on a 5-year cycle. Infrared inspection on a 5-year cycle. NA Met-Ed Every 4 years. Every 4 years. Every 6 years. Every 6 years. Included in line inspection. Penelec Every 4 years. Every 4 years. Every 6 years. Every 6 years. Included in line inspection. Penn Power Every 4 years. Every 4 years. Every 6 years. Every 6 years. Included in line inspection. PECO Variable divisional programs with 1 year patrol target. Variable divisional programs with 1 year patrol target. Drivable portion patrolled every year. Inspected as part of 2 year distribution line inspection. NA PPL Uncertain. Uncertain. NA No fixed interval. NA UGI NA NA NA NA See 'UGI' above. Citizens' Annually. Annually. Annually. Annually. NA Wellsboro NA 5 years. 5 years. 5 years. Included in line inspection. Pike County Annual infrared inspection for 3-phase; 3 years for other lines. Annual infrared inspection for 3-phase; 3 years for other lines. Annual infrared inspection for 3-phase; 3 years for other lines. Annual infrared inspection for 3-phase; 3 years for other lines. $15,000
Inspection of overhead distribution transformers annually
The EAP opposes a uniform standard for the annual inspection of pole mounted distribution transformers. Increasing visual inspection of overhead distribution transformers will not increase customer service reliability according to the EAP. The EDCs' current inspection programs uncover few transformer problems. Overhead transformer failures typically affect only a few customers.
The EAP alleges that increasing the frequency of inspection will not produce significant additional reliability benefits but will greatly increase costs and divert resources that could be used for the EDCs' maintenance programs that yield greater reliability benefits. Many transformer failures result from causes that occur right before the failure, such as lightening, or storm-related faults on secondary/service conductors. Annual visual inspections will not decrease the number of these events and will increase costs by approximately $2.9 million annually. Therefore, EAP argues the EDCs should be allowed to continue to inspect overhead transformers using their current schedule.
Disposition
The Commission is not entirely persuaded by the EAP's argument. We believe it is a reasonable requirement that when the distribution lines are inspected every 1-2 years, that as part of that inspection, distribution pole transformers are also inspected. The incremental cost for this was already included in the line inspection estimates for most of the EDCs anyway. As we have decreased the minimum inspection standard from annually to biennially, the costs for the overhead transformer inspections diminish.
A visual inspection of distribution transformers shall include checking for rust, dents or other evidence of contact, leaking oil, and any other conditions that may affect operation of the transformer. This language as proposed by the AFL-CIO will be incorporated in Annex A under subsection (n)(6).
Proposed: 52 Pa. Code § 57.198(e)(3): Overhead line inspections. Transmission lines shall be inspected aerially twice per year in the spring and fall. Transmission lines shall be inspected on foot every 2 years. Distribution lines shall be inspected by foot patrol a minimum of once per year. If problems are found that affect the integrity of the circuits, they shall be repaired or replaced no later than 30 days from discovery. Overhead distribution transformers shall be visually inspected annually as part of the distribution line inspection. Aboveground pad-mounted transformers and below-ground transformers shall be inspected on a 2-year cycle. Reclosers shall be inspected and tested at least once per year.
Company 1990 1995 2000 Current Incremental Cost Allegheny Inspected every 6 years. Inspected every 4 years. Inspected every 5 years. Inspected every 5 years. $100,000 Duquesne Network underground transformers inspected semi-annually. Network underground transformers inspected semi-annually. Network underground transformers inspected annually. Network underground transformers inspected annually. $450,000 Met-Ed Every 4 years. Every 4 years. Every 6 years. Every 6 years. $1,200,000 for the 3 FE companies Penelec Every 4 years. Every 4 years. Every 6 years. Every 6 years. See above. Penn Power Every 4 years. Every 4 years. Every 6 years. Every 6 years. See above. PECO Inspected following report of unusual condition. Inspected following report of unusual condition. 5-year inspection cycle. 5-year inspection cycle. NA PPL Uncertain. Uncertain. NA No fixed interval for pad-mounted; vaults inspected every 6 months. NA UGI NA NA NA NA See 'UGI' above. Citizens' Annually. Annually. Annually. Every 4 years. $25,000 Wellsboro NA 5 years. 5 years. 5 years. $15,000 Pike County None. None. None. None. $10,000
Inspection of pad-mounted or below-grade transformers every 2 years.
The EAP opposes a standard for the inspection of pad-mounted and below-grade transformers every 2 years. Current inspection programs for this equipment are sufficient to maintain this equipment in a reliable fashion. Increasing the frequency of inspection of these devices will not significantly improve customer service reliability and will increase cost by approximately $4.0 million annually. The EAP argues the EDCs should retain the ability to establish inspection programs for pad-mounted and submersible equipment to optimize use of inspection resources and customer service reliability.
Duquesne Light commented that nothing can be determined by visually inspecting a transformer, other than an occasional oil leak. Almost all of Duquesne's transformer failures are the result of thermal overload, which cannot be detected by visual inspection. It is better to analyze transformer capacity when there is a change in service to customers, such as the addition of new load or during periods of high heat when there is more stress on the system. It is nearly impossible to inspect below-ground transformers according to Duquesne Light because they are submersible or in vaults and inspection problems surface regarding confined space rules and the availability of trained personnel.
PECO believes the Commission should not adopt the proposed regulation's 2-year inspection requirement for pad-mount and underground transformers. PECO states that they have an approximate failure rate of once every 100 years. PECO currently inspects pad-mount transformers every 5 years and underground transformers every 6 years. These cycles are more than sufficient to maintain transformer reliability. PECO suggests amending the proposed regulations to state: Aboveground pad-mounted transformers and below-ground transformers shall be inspected on a cycle of 8 years or less.
Disposition
The Commission recognizes that a pad-mounted transformer and below-ground transformer are generally less likely to be struck by lightening and malfunction than a pole transformer. Therefore, we will adopt in part PECO's suggestion. The standard for inspecting a pad-mounted transformer will be a minimum interval of every 5 years, and the standard for inspecting a below-ground transformer will be a minimum interval of every 8 years or less.
Equipment failure is a major cause of outages, and the benefit to the customers in having these pad-mounted and underground transformers inspected every 5 or 8 years is of great value as we believe it will lead to fewer outages and less duration of average outages. If the EDC wants to exceed the standard, it my request so in writing with its plan and explain why that type of interval should be allowed and submit a cost/benefit analysis to support its claim. Otherwise, above-ground pad-mounted transformers and below-ground transformers shall be inspected on a 5-year and 8-year cycle respectively.
An inspection shall include checking for: 1) rust, dents or other evidence of contact; 2) leaking oil; 3) installation of fences or shrubbery that could affect access to and operation of the transformer; and 4) unauthorized excavation or changes in grade near the transformer.
Proposed: 52 Pa. Code § 57.198(e)(3): Overhead line inspections. Transmission lines shall be inspected aerially twice per year in the spring and fall. Transmission lines shall be inspected on foot every 2 years. Distribution lines shall be inspected by foot patrol a minimum of once per year. If problems are found that affect the integrity of the circuits, they shall be repaired or replaced no later than 30 days from discovery. Overhead distribution transformers shall be visually inspected annually as part of the distribution line inspection. Aboveground pad-mounted transformers and below-ground transformers shall be inspected on a 2-year cycle. Reclosers shall be inspected and tested at least once per year.
Company 1990 1995 2000 Current Incremental Cost Allegheny Inspected every 3 years. Inspected every 3 years. Inspected every 5 years. Inspected every 5 years. $2,000,000 + $2,000,000 startup Duquesne Condition-based maintenance on 23 kV Reclosers on 1-year cycle; single phase 4 kV reclosers not tested. Condition-based maintenance on 23 kV Reclosers on 1-year cycle; single phase 4 kV reclosers not tested. Condition-based maintenance on 23 kV reclosers on 1-year cycle; single phase 4 kV reclosers not tested. 23 kV reclosers w/o self-monitoring systems inspected on 1-year cycle; no planned maintenance for modern reclosers; single phase 4 kV reclosers not tested. $85,000 Met-Ed Oil reclosers--oil test on 5-year cycle; overhaul on 9-year cycle. Oil reclosers--oil test on 5-year cycle; overhaul on 9-year cycle. Oil reclosers--oil test on 5-year cycle; overhaul on 9-year cycle. Oil reclosers--oil test on 5-year cycle; overhaul on 9-year cycle. $1,600,000 for the 3 FE companies Penelec NA NA Visual and battery test inspection on 4 year cycle. Visual and battery test inspection on 4 year cycle. See above. Penn Power Annual field inspection and complete shop inspection performed based on number of fault operations. Annual field inspection and complete shop inspection performed based on number of fault operations. Annual field inspection and complete shop inspection performed based on number of fault operations. Annual field inspection and complete shop inspection performed based on number of fault operations. See above. PECO Variable divisional programs with 1 year target. Variable divisional programs with 1 year target. 2-year inspection cycle. Inspection cycles range from 1 to 4 years, depending on type. NA PPL 6-year replacement cycle. 8-year replacement cycle. NA 10-year replacement cycle. NA UGI 5 years/100 operations. 5 years/100 operations. 5 years/100 operations. 5 years/100 operations. See 'UGI' above. Citizens' Manufacturer's recommendations. Manufacturer's recommendations. Manufacturer's recommendations. Manufacturer's recommendations. $15,000 Wellsboro NA 6 years. 6 years. 5 years. $35,000 + $140,000 for purchase of add. OCRs. Pike County Visual inspection quarterly; tested semi-annually. Visual inspection quarterly; tested semi-annually. Visual inspection quarterly; tested semi-annually. Visual inspection quarterly; tested semi-annually. NA
Inspection and testing of reclosers once per year
The EAP agrees with the need for individual programs for inspection and testing of reclosers, but it does not agree with the proposed regulation mandating this work be done on all reclosers on a 1 year cycle. The EAP claims that improvements in technologies and communications are resulting in the development of intelligent reclosers that specifically do not require time-based inspections. Some EDCs are also adopting condition based maintenance practices for their equipment, that are based on operating cycles and other ''wear and tear'' independent of the time in-service.
The amount of wear that a recloser experiences is related to the frequency of operation and ambient weather conditions rather than to the duration of installation. A newly installed recloser will have a trip frequency based on the number of faults on the line that it protects, rather than on the length of time that the recloser is installed. During the course of a year, due to changes in severe weather and other external causes, this recloser may not trip at all, or it may trip several times. Reclosers that meet their manufacturer's recommended fault duty in 1 year are extremely rare. Initiating a 1-year testing standard would cause the EDCs to routinely spend resources inspecting and testing reclosers that are in new or nearly new condition. According to the EAP, the additional cost of recloser inspection and testing to the EDC is estimated to be approximately $14.0 million annually.
Duquesne Light states that the 4 kV hydraulic reclosers cannot be inspected and tested without their complete removal from the distribution system and their transportation to the utility shop for inspection and testing. There is no portable test available to confirm function with the reclosers in place. This proposed annual testing would be very expensive. If the proposed recloser inspection and testing standard were to be adopted, Duquesne believes many utilities would use fuses instead of reclosers due to the cost of removal for inspection and testing. Fusing would decrease reliability and would be an unintended outcome.
Citizen's and Wellsboro question the need for standards regarding reclosers as well. Each company tailors its plan to the equipment and needs of the specific territory. Even for two EDCs of similar size, the maintenance practices differ due to other factors such as age and type of equipment, terrain, and weather variations. Further, because the number of reclosers operations that occur is small between testing intervals, some reclosers may not need retesting on an annual basis as per the manufacturer's specifications regarding testing and maintenance.
PECO does not support annual testing of all reclosers because they are not manufactured equally. There are different types and each has a different industry standard/best practices inspection and testing schedule. PECO tests oil-insulated reclosers every 2 years and solid-dielectric-insulated reclosers every 4 years consistent with the industry practice for these reclosers. To test all reclosers once per year would be a waste of resources, especially single phase reclosers, which are simple, self-contained devices mounted high on poles in the zone of the primary wires. Manufacturers do not recommend frequent testing of single-phase reclosers. PECO recommends amending the subsection as follows:
Three-phase reclosers shall be inspected on a cycle of 8 years or less. Single-phase reclosers shall be inspected as part of the EDC's individual distribution line inspection plan.Disposition
Upon consideration of these comments, we are persuaded by the EDC commenters to amend this section in the interest of not wasting resources. Three-phase reclosers shall be inspected on a cycle of 8 years or less. Single-phase reclosers shall be inspected as part of the EDC's individual distribution line inspection plan. This requirement will be incorporated under subsection (n)(7).
Proposed: 52 Pa. Code § 57.198(e)(4): Substation inspections. Substation equipment, structures and hardware shall be inspected monthly.
Company 1990 1995 2000 2005 Incremental Cost Allegheny Monthly for EHV substations; quarterly for others. Monthly for EHV substations; quarterly for others. Monthly for EHV substations; quarterly for others. Monthly for EHV substations; quarterly for others. $900,000 Duquesne Monthly inspections. Monthly inspections. Monthly inspections. Monthly inspections. NA Met-Ed Monthly inspections. Monthly inspections. Monthly inspections. Monthly inspections. NA Penelec Monthly inspections. Monthly inspections. Monthly inspections. Monthly inspections. NA Penn Power Monthly inspections. Monthly inspections. Monthly inspections. Monthly inspections. NA PECO Monthly inspections. Monthly inspections. Monthly inspections. Every 5 weeks. NA PPL Critical--weekly; non-critical--
monthly.Critical--weekly; non-critical--
quarterly.NA Critical--weekly; non-critical--
monthly.$2,200,000 UGI 230 kV--semi-
monthly; 69 kV--semi-
monthly.230 kV--semi-
monthly; 69 kV--monthly.230 kV--semi-
monthly; 69 kV--monthly.230 kV--semi-
monthly; 69 kV--monthly.See 'UGI' above. Citizens' Monthly inspections. Monthly inspections. Monthly inspections. Monthly inspections. NA Wellsboro NA Bi-monthly. Monthly. Monthly. NA Pike County Monthly. Monthly. Monthly. Monthly. NA
Substation equipment, structures and hardware shall be inspected monthly.
The EAP disagrees with a requirement for monthly substation inspections and claims that this new requirement would add about $3.3 million annually in EDC operating cost on a Statewide basis. Current inspection programs are claimed to be sufficient to provide reliable substation operation. The EDCs have studied results of more frequent inspections and have found little benefit in inspecting stations more frequently. All EDCs have routine cycles for inspecting substation equipment. These inspections are more rigorous than a visual inspection. Very few customer outage incidents occur because of substation equipment failure that would have been detectable prior to their occurrence by a routine visual inspection.
However, Duquesne Light agrees and supports the requirement that substation equipment structures and hardware be inspected monthly because of its potential impact on reliability and safety, should be inspected monthly.
Allegheny Power claims its substation-related outages have very little impact on customer reliability, historically approximately 1% of all outages. Allegheny Power claims frequent inspections were not producing reliability benefits, and the proposed standard would cost an additional $900,000 each year. Allegheny claims the AFL-CIO and OCA proposals add additional annual costs of $3.9 million and $5.4 million, respectively and that their plans offer insignificant opportunity for increased customer reliability and deter the use of advanced tools that can reduce the need for inspection. Allegheny believes rigid repair standards and time frames will increase the costs or possibly decrease reliability.
AFL-CIO agrees with the EDCs that it is neither feasible nor required to test substation breakers on a monthly basis, but AFL-CIO requests the regulations establish a reasonable inspection, maintenance and testing cycle for these facilities.
PECO commented that it inspects its substation equipment every 5 weeks and that this is sufficient. Shortening the period to 4 weeks, while minor, would significantly increase PECO's inspection costs without any measurable increase in reliability. Accordingly PECO recommends it be amended as follows:
§ 57.198(e)(4) Substation inspections. Substation equipment, structures and hardware shall be inspected on a cycle of 5 weeks or less.
AFL-CIO proposes 52 Pa. Code § 57.198(e)(4) should be revised to state:
(4) Substation inspections. Substation equipment, structures and hardware shall be inspected monthly. Substation circuit breakers shall undergo operational testing at least once per year, diagnostic testing at least once every 4 years and comprehensive inspection and maintenance on a 4-year cycle.Disposition
Based on our consideration of the comments and current industry practices we will allow for a range of 5 weeks as the standard interval. Thus, we will adopt PECO's suggested language in Annex A, at 52 Pa. Code § 57.198(n)(8). Also, we note that PPL failed to explain why their alleged incremental cost would be $2.2 million when they state they do critical substation inspections weekly and noncritical monthly inspections already.
AFL-CIO's new proposal for other inspection requirements.
The AFL-CIO proposes a new § 57.198(5) to state:
(5) Other inspection requirements.(i) Group-operated line switches shall be inspected and tested annually.(ii) Relays shall be inspected and tested every 2 years.(iii) Sectionalizers shall be inspected and tested every 2 years.(iv) vacuum switches shall be inspected and tested every 2 years.(v) underground vaults with larger connections (750 Mcm or larger) shall be visually inspected and thermo-vision tested for hot spots annually. In addition, vaults of any size that serve schools, hospitals, public buildings, or residences shall be visually inspected and cleaned once per year.Each of these provisions was recommended by AFL-CIO in response to the Advance Notice of Proposed Rulemaking. The Commission did not include them in the NOPR and did not discuss reasons for their exclusion. AFL-CIO submits that these additional inspection, maintenance, and testing requirements are necessary to ensure the safety and reliability of electric service.
Disposition
Upon consideration of this proposal, we are not persuaded this level of detail is required at this time in order to ensure service reliability does not deteriorate. The EDCs can explain to this level of detail, but it is not required.
Automatic penalties
Finally, AFL-CIO requests automatic penalties when an EDC fails to repair or replace critical or dangerous facilities within a stated period of time. Failing to repair dangerous conditions or replace dangerous and defective equipment poses a danger to utility workers and the public. AFL-CIO recommends civil penalties of $1,000 per day for each day that the violation continues after the mandated repair interval, as authorized by 66 Pa.C.S. § 3301. AFL-CIO recommends, therefore, the addition of a new subsection to § 57.198 to state penalties for noncompliance are such that if an EDC fails to repair or replace defective poles, transmission circuits or distribution circuits within a certain time frame, the EDC shall be subject to automatic penalty of $1,000 per day for each day the violation continues.
Disposition
Upon consideration of this proposal, we decline to impose automatic fines and penalties for failure to comply with the final regulations because the Commission wants to retain flexibility in assessing fines for noncompliance, to consider the reasons for noncompliance, and to consider whether the EDC is also violating reliability standards and the number of customer complaints. There are factors beyond the control of the EDCs which influence an EDCs ability to have reliable service and meet its inspection, maintenance and repair intervals, such as off-right-of-way vegetation problems and weather-related outages and the Commission needs flexibility in determining whether an excuse is in good faith or not and whether the problem can be remedied by corrective action plans, before fines and penalties are pursued.
PPL's Pilot Program Suggestion
PPL's General Manager of Transmission/Distribution commented at the technical conference held on January 22, 2007, that if the Commission were to implement standards, they ought to be done on a pilot basis first in a controlled experiment to see if the standards do, in fact, improve reliability. PPL suggested targeting the worst performing circuit areas. PPL offered a graph depicting the effect of the proposed standards on effective management of the company in its comments. Figure 1, p. 8. PPL stated that the tradeoffs between alternatives, costs and results change over time, are driven by advancements in technology and work methods, and changes to the specific makeup and age distribution of an EDC's assets. At any given time, a cost/benefit analysis will produce different results at different EDCs due to differences in labor costs, design standards, equipment and material specifications, asset retirement and replacement schedules, asset upgrading programs, facility operating procedures, and inspection and maintenance programs.
Thus, PPL recommends the most effective way to proceed is for the Commission to establish individual inspection and maintenance standards for each EDC, which recognize the unique characteristics, performance and environment of each EDC and which can be adapted to changing technology, work methods, costs and system composition. Uniform labor-intensive standards will not necessarily lead to improvements in reliability and will likely result in substantial additional costs to the EDCs totaling approximately $75 million per year.
Disposition
PPL's pilot program suggestion is interesting but no other party recommended the same. The final-form regulation set forth today will allow for flexibility in reacting to technological advancements in inspection, maintenance, replacement and repair work, as well as encouraging better performance in uniquely different EDC service territories.
III. Conclusion
The Commission finds that the establishment of I & M standards for EDCs, as set forth in Annex A, is in the public interest because these standards are required by law, 66 Pa.C.S. § 2802(20), and because these standards will enhance the reliability of the electric service provided to ratepayers in this form. In addition, we have given consideration to the industry's claim that rigid I & M standards may not be appropriate for all EDCs by allowing individual EDCs to justify, by unique circumstances or a cost/benefit analysis, the use of an alternative approach to a given I & M standard.
Accordingly, under authority in section 501 of the Public Utility Code, 66 Pa.C.S. § 501, 66 Pa.C.S. Chapter 28 and the regulations promulgated thereunder in §§ 57.191--57.197; and sections 201 and 202 of the act of July 31, 1968 (P. L. 769, No. 240) (45 P. S. §§ 1201 and 1202) and the regulations promulgated thereunder in 1 Pa.Code §§ 7.1, 7.2 and 7.5; section 204(b) of the Commonwealth Attorneys Act (71 P. S. § 745.5)); section 5 of the Regulatory Review Act (71 P. S. § 732.204(b)); and section 612 of The Administrative Code of 1929 (71 P. S. § 232) and the regulations promulgated thereunder in 4 Pa.Code §§ 7.251--7.235, we adopt the regulations set forth in Annex A; Therefore,
It Is Ordered That:
1. The regulations of the Commission, 52 Pa. Code Chapter 57, are amended by the addition of § 57.198 to read as set forth in Annex A.
(Editor's Note: The proposal to amend § 57.192, included in the proposed rulemaking at 36 Pa.B. 6097, has been withdrawn by the Commission.)
2. The Secretary submit this final rulemaking order and Annex A for review and approval by the designated standing committees of both houses of the General Assembly, and for review and approval of IRRC.
3. The Secretary shall submit this order and Annex A to the Governor's Budget Office for review of fiscal impact.
4. The Secretary shall submit this order and Annex A to the Office of Attorney General for review as to legality.
5. The Secretary certify this order and Annex A and deposit them with the Legislative Reference Bureau to be published in the Pennsylvania Bulletin.
6. The amendments to Chapter 57 embodied in Annex A shall become effective upon final publication in the Pennsylvania Bulletin.
7. A copy of this order and Annex A be filed in the folder regarding benchmarks and standards at M-00991220.
8. The contact persons for this rulemaking are (technical) Blaine Loper, CEEP, (717) 787-3810 and (legal) Elizabeth H. Barnes, Law Bureau, (717) 772-5408.
9. A copy of this order and Annex A be served upon all EDCs operating in this Commonwealth, the Office of Consumer Advocate, the Office of Small Business Advocate, the Energy Association of Pennsylvania, Senator Robert M. Tomlinson, the Pennsylvania Utility Contractors Association, the IECPA, and the Pennsylvania AFL-CIO--Utility Caucus.
By the Commission
JAMES J. MCNULTY,
Secretary
State of Commissioner Kim Pizzingrilli In passing the Electricity Generation Customer Choice and Competition Act (the Act), the General Assembly emphasized that electric distribution companies should continue to ensure the safe and reliable provisions of electric service to all customers. 66 Pa.C.S. §§ 2802(12), 2804(1), 2807(d). To achieve this objective, the Commission was charged with establishing inspection, maintenance, repair and replacement standards via regulation for the electric transmisssion and distribution system. 66 Pa.C.S. § 2802(20).
The Commission has previously promulgated regulations to establish reliability benchmarks and reporting requirements. Rulemaking Re Amending Electric Service Reliability Regulations at 52 Pa. Code Chapter 57, Docket L-00030161 (Final Rulemaking Order entered May 7, 2004). However, we had not promulgated specific regulations on the inspection, repair and maintenance of facilities.
These rules are the result of a process in which many comments have been filed and where there has been an extensive dialogue between staff and stakeholders. I commend all those involved for their efforts. I believe thse rules reasonably balance the interests of all parties an serve the pbulic interest by fostering safe and reliable electric service.
KIM PIZZINGRILLI,
Commissioner(Editor's Note: For the text of the order of the Independent Regulatory Review Commission relating to this document, see 38 Pa.B. 4693 (August 23, 2008).)
Fiscal Note: Fiscal Note 57-248 remains valid for the final adoption of the subject regulation.
ATTACHMENT A
12-Month Average Electric Reliability Indices for 2006
ATTACHMENT B
Three-Year Average Electric Reliability Indices for 2004-06
Annex A
TITLE 52. PUBLIC UTILITIES
PART I. PUBLIC UTILITY COMMISSION
Subpart C. FIXED SERVICE UTILITIES
CHAPTER 57. ELECTRIC SERVICE
Subchapter N. ELECTRIC RELIABILITY STANDARDS § 57.198. Inspection and maintenance standards.
(a) Filing date and plan components. Every 2 years, by October 1, an EDC shall prepare and file with the Commission a biennial plan for the periodic inspection, maintenance, repair and replacement of its facilities that is designed to meet its performance benchmarks and standards under this subchapter. EDCs in Compliance Group 1, as determined by the Commission, shall file their initial plans on October 1, 2009. EDCs in Compliance Group 2, as determined by the Commission, shall file their initial plans on October 1, 2010. Each EDC's biennial plan must cover the 2 calendar years beginning 15 months after filing, be implemented 15 months after filing, and must remain in effect for 2 calendar years thereafter. In preparing this plan, the following facilities are critical to maintaining system reliability:
(1) Poles.
(2) Overhead conductors and cables.
(3) Transformers.
(4) Switching devices.
(5) Protective devices.
(6) Regulators.
(7) Capacitors.
(8) Substations.
(b) Plan consistency. The plan must be consistent with the National Electrical Safety Code, Codes and Practices of the Institute of Electrical and Electronic Engineers, Federal Energy Regulatory Commission Regulations and the provisions of the American National Standards Institute, Inc.
(c) Time frames. The plan must comply with the inspection and maintenance standards in subsection (n). A justification for the inspection and maintenance time frames selected shall be provided, even if the time frame falls within the intervals prescribed in subsection (n). However, an EDC may propose a plan that, for a given standard, uses intervals outside the Commission standard, provided that the deviation can be justified by the EDC's unique circumstances or a cost/benefit analysis to support an alternative approach that will still support the level of reliability required by law.
(d) Routine inspection and maintenance. The plan must specify for the standards in subsection (n) the routine inspection and maintenance requirements, and emergency maintenance plans and procedures.
(e) Reduction of risk of outages. The plan shall be designed to reduce the risk of outages by accounting for age, condition, technology, design and performance of system components and by inspecting, maintaining, repairing, replacing and upgrading the system.
(f) Clearance of vegetation. The plan must include a program for the maintenance of clearances of vegetation from the EDC's overhead distribution facilities.
(g) Consistency with reliability reports. The plan must form the basis of, and be consistent with, the EDC's inspection and maintenance goals and objectives included in subsequent annual and quarterly reliability reports filed with the Commission under §§ 57.193(c) and 57.195 (relating to transmission system reliability; and reporting requirements).
(h) Review procedure. Within 90 days of receipt of the plan, the Commission or the Director of the Bureau of Conservation, Economics and Energy Planning (CEEP) will accept or reject the plan in writing.
(i) Deemed acceptance. Absent action by the Commission or the Director of CEEP to reject the plan within 90 days of the plan's submission to the Commission, the plan will be deemed accepted.
(j) Plan deficiencies. If the plan is rejected, in whole or in part, by the Commission or the Director of CEEP, the EDC will be notified of the plan's deficiencies and directed to submit one of the following:
(i) A revised plan, or pertinent parts of the plan, addressing the identified deficiencies.
(ii) An explanation why the EDC believes its plan is not deficient. The revised plan is deemed accepted absent any action by the Commission within 90 days of the filing.
(k) Appeal procedure. An EDC may appeal the Commission staff's determination under subsection (h) by filing an appeal under § 5.44 (relating to petitions for appeal from actions of the staff) within 20 days after service of notice of the action. A final Commission determination is appealable to the Commonwealth Court. Absent having a granted stay, the EDC is obligated to comply with the Commission's directives regarding its inspection, maintenance, repair and replacement plans.
(l) EDC updates. An EDC may request approval from the Commission for revising its approved plan. An EDC shall submit to the Commission, as an addendum to its quarterly reliability report under §§ 57.193(c) and 57.195, prospective and past revisions to its plan and a discussion of the reasons for the revisions. Within 60 days, the Commission or the Director of CEEP will accept or reject the revisions to the plan. The appeal procedure in subsection (k) applies to the appeal of a rejection of revisions to the plan.
(m) Recordkeeping. An EDC shall maintain records of its inspection and maintenance activities sufficient to demonstrate compliance with its distribution facilities inspection, maintenenance, repair and replacement programs as required by subsection (n). The records shall be made available to the Commission upon request within 30 days. Examples of sufficient records include:
(1) Date-stamped records signed by EDC staff who performed the tasks related to inspection.
(2) Maintenance, repair and replacement receipts from independent contractors showing when and what type of inspection, maintenance, repair or replacement work was done.
(n) Inspection and maintenance intervals. An EDC shall maintain the following inspection and maintenance plan intervals:
(1) Vegetation management. The Statewide minimum inspection and treatment cycle for vegetation management is between 4-8 years for distribution facilities. An EDC shall submit a condition-based plan for vegetation management for its distribution system facilities explaining its treatment cycle.
(2) Pole inspections. Distribution poles shall be inspected at least as often as every 10--12 years except for the new southern yellow pine creosoted utility poles which shall be initally inspected within 25 years, then within 12 years annually after the initial inspection. Pole inspections must include:
(i) Drill tests at and below ground level.
(ii) A shell test.
(iii) Visual inspection for holes or evidence of insect infestation.
(iv) Visual inspection for evidence of unauthorized backfilling or excavation near the pole.
(v) Visual inspection for signs of lightening strikes.
(vi) A load calculation.
(3) Pole inspection failure. If a pole fails the groundline inspection and shows dangerous conditions that are an immediate risk to public or employee safety or conditions affecting the integrity of the circuit, the pole shall be replaced within 30 days of the date of inspection.
(4) Distribution overhead line inspections. Distribution lines shall be inspected by ground patrol a minimum of once every 1-2 years. A visual inspection must include checking for:
(i) Broken insulators.
(ii) Conditions that may adversely affect operation of the overhead transformer.
(iii) Other conditions that may adversely affect operation of the overhead distribution line.
(5) Inspection failure. If critical maintenance problems are found that affect the integrity of the circuits, they shall be repaired or replaced no later than 30 days from discovery.
(6) Distribution transformer inspections. Overhead distribution transformers shall be visually inspected as part of the distribution line inspection every 1-2 years. Above-ground pad-mounted transformers shall be inspected at least as often as every 5 years and below-ground transformers shall be inspected at least as often as every 8 years. An inspection must include checking for:
(i) Rust, dents or other evidence of contact.
(ii) Leaking oil.
(iii) Installation of fences or shrubbery that could adversely affect access to and operation of the transformer.
(iv) Unauthorized excavation or changes in grade near the transformer.
(7) Recloser inspections. Three-phase reclosers shall be inspected on a cycle of 8 years or less. Single-phase reclosers shall be inspected as part of the EDC's individual distribution line inspection plan.
(8) Substation inspections. Substation equipment, structures and hardware shall be inspected on a cycle of 5 weeks or less.
[Pa.B. Doc. No. 08-1746. Filed for public inspection September 26, 2008, 9:00 a.m.]
No part of the information on this site may be reproduced for profit or sold for profit.This material has been drawn directly from the official Pennsylvania Bulletin full text database. Due to the limitations of HTML or differences in display capabilities of different browsers, this version may differ slightly from the official printed version.
