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

2. 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.

3. 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

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

5. Pre-Inspection

6. 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.

7. 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

8. 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

9. 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)

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

11. Periodic Inspection
Record Keeping

12. 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

13. 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

14. Inspection Report

15. Inspection Report

16. Inspection/Maintenance Related Findings
This?
or This?

17. Inspection/Maintenance Related Findings
This?
or This?

18. Inspection/Maintenance Related Findings
This?
or This?

19. Inspection/Maintenance Related Findings
This?
or This?

20. 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.

21. 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

22. 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

23. 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.

24. 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.

25. 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.

26. 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.

27. 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.

28. Deficiency Tracking Report (DTR)

29. Deficiency Tracking Report (DTR)

30. Deficiency Tracking Report (DTR)

31. Deficiency Tracking Report (DTR)

32. Deficiency Tracking Report (DTR)

33. Example Progress Report

34. Example Water Meter Testing/Replacement Program

35. 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:

36. 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

37. 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.

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

39. Questions?

40. Public Service Commission
Manager, Water & Sewer Branch Division of Engineering
George W. Wakim, P.E.
211 Sower Blvd.
Frankfort, KY 40602
Ph: (502) ext 409
Fax: (502)