Auditor Debrief 2014 - Electrical Safety Authority

Auditor Debrief
November 13, 2014
(web version)
Electrical Distribution Safety
• 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
Review of 2013 Audit results
2014 Questions & Issues
Focus of 2014 Audits
Auditor Feedback
Other Information
a) Bulletins
b) Other Issues
Electrical Distribution Safety
Summary of
Audit Findings for 2013
• 37 LDCs - Full Compliance
• 30 LDCs - Needs Improvement only
• 23 LDCs with only one Needs Improvement
(’10-17;’11-27,’12-21) and 3 LDCs with more
than two Needs Improvements (’10-14;’1111,’12-6)
• 5 LDCs had 1 Non-compliance
• 4 LDC had more than 1 Non-compliance
Electrical Distribution Safety
Summary of
Audit Findings Life to Date
2007 2008 2009 2010 2011 2012 2013
Audit - No Findings
DDI - Average Number of
Findings per Inspection
Common audit findings
Section 6 – Equipment Approvals
• Process for approving equipment returned
from field or refurbished
• No process documented for approving equipment for reuse 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
• Legacy equipment in inventory not on approved list.
Electrical Distribution Safety
Common audit findings
Section 7 – Design
• Plans signed by persons not P.Eng.
Must be registered with the PEO.
• Designs without certificates of approval
• Plan changes not approved /approval
not recorded
• Designs not reviewed / approved for recloser 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
– No schedule for some equipment/ records unavailable
• Incomplete/missing Records of Inspection and/or
• 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
• Missing Third Party attachment ROI/Certificates
• Not following approved CVP / CVP not updated to reflect
new processes
Electrical Distribution Safety
Auditor Question
Q. Does listing non-major equipment on the USF
equipment list provide sufficient evidence of
equipment approval by an LDC? Does this satisfy ESA
Technical Guideline 2.7.5 for “supporting
documentation” or must each LDC provide a record of
approval by its competent person?
A. No. The list is one in which other LDCs have approved
equipment and often there is the supporting
documentation in which they have done so. The LDC
is required to approve the equipment via one of the
options listed in the Guideline under 2.7.5.
USF Statement on the
“USF Equipment List”
• The USF website is a library of information,
including industry standards, and
manufacturers test reports.
• All of this information is available for use by
any USF Member in order to approve its
materials, using its internal process, by a
competent individual.
Auditor Question
Q. Is a person listed in the LDC’s CVP as competent, considered to be competent for
approving equipment for use and re-use? What if the LDC’s documented equipment
approval procedure shows that persons listed in the CVP as competent are also
considered competent to approve equipment?
No. The CVP is only for addressing Section 8 requirements and not
Section 6.
Some LDCs included equipment approvals within the CVPs,
however when this was done ESA encouraged its removal, and if
that was not accommodated ESA made it clear that ESA was not
approving the LDCs Section 6 practices.
The person may be competent to approve under Sections 6 and 8,
however the CVP is not the document which would state this.
Auditor Question
Q. Is a certificate of approval (or P.Eng. seal)
required for third party attachment plans
submitted by one LDC attaching to the pole line
of a neighbouring LDC? The plans could be based
on the standards of both LDC’s.
A. Yes a certificate of approval is required under
Section 7. ESA has stated it has the same
expectations of any 3rd Party Attacher, no matter
if they are another LDC, communication
company, or other.
Auditor Question
Q. Soil resistivity measurement is required for substation grounding
electrode design. Could a ground resistivity study by a consultant
that displays neither a certificate of approval nor a P.Eng. seal be
relied upon by an LDC for calculation of GPR, step and touch
potentials? Should auditors record this as a noncompliance, needs
improvement or an observation?
This information is used to create the ground grid for the station,
which is important to ensure a safe installation. The entire plan
must be covered under a Certificate of Approval. The plan can be
split up between P.Eng’s and/or ESA (the Authority).
If it can’t be demonstrated that the entire plan is covered this is a
Non-Compliance with 22/04.
Auditor Question
Q. What if the LDC designs the grounding electrode for a 44
kV substation without a soil resistivity study?
A. ESA is not aware of any LDC having standard design
drawings for 44kV installations. This is typically under a
B. Step and Touch shall be controlled, so this needs to be
addressed, and this is addressed through a soil resistivity
study. If this is not addressed this should be documented
as a Non-Compliance.
C. CSA 22.3 No.7
15.4.1 Pad-mounted supply equipment
Pad-mounted supply equipment (i.e. transformers and switchgear)
shall be grounded to control step and touch potentials.
Auditor Question
Q. Load-break switches are considered major equipment.
Should not in-line switches also be considered major
equipment since they can be operated without a loadbreaking tool?
• A. Section 2.1.1 of the Technical Guideline lists the
Major Equipment. At this time the following excerpt
– Load break switches, including single and three phase units
(air, SF6, oil, vacuum insulated, solid dielectric, etc).
• ESA will examine expanding this section to include
other switches, however at this time Auditors are
expected to use the existing list.
Auditor Question
Q. Do as-built plans provide sufficient evidence that a final
inspection has been done and deficiencies have been
corrected or is a certificate of inspection also required?
A. No. Regulation 22/04 requires that a Record of Inspection and
Certificate exist before putting a distribution system into use.
ESA expects these documents will be created, as per the LDCs
approved CVP. ESA has not approved as-built plans on their
own as representative of a Record of Inspection and/or
Auditor Question
Q. Is the signature of a P.Eng. on a document equivalent to a
P.Eng. seal?
Regulation 22/04 requires a Certificate of Approval to exist. ESA does not
approve the format of the Certificates of Approval nor regulates the
proper use of the P.Eng signature/seal. Sample Certificates of Approval
are provided in the Technical Guideline, however the wording should be
Certificate of Approval
The installation work covered by this document meets the safety
requirements of Section 4 of Regulation 22/04
Continued on Next Slide
Auditor Question
Q. Is the signature of a P.Eng. on a document equivalent to a
P.Eng. seal?
B. ESA sees this question as a PEO / PEA question. On the PEO’s website the
following can be found.
When do I need to use my seal?
Section 53 of Regulation 941 of the Professional Engineers Act states that
"[e]very holder of a licence, temporary licence or limited licence who
provides to the public a service that is within the practice of
professional engineering shall sign, date and affix the holder's seal to
every final drawing, specification, plan, report or other document
prepared or checked by the holder as part of the service before it is
Auditor Question
Q “In comparison to wood poles, there are many disadvantages and
concerns in using concrete poles, not the least of which is safety, as listed
– Safety: Concrete poles are electrically conductive and could pose an electrical
hazard if the energized electrical plant comes in contact with the pole.
– The safety issue is an overarching concern. In accordance with Regulation
22/04 “Electrical Distribution Safety”, we are bound to engineer, construct and
operate our system in the safest way possible.
In consideration of the above, I would like to know if ESA has any concerns
with using concrete poles. “
A. No concerns with using concrete poles. This equipment, like
all equipment, is to be approved. This should address the
safety aspect.
Focus of 2014 Audits
• Auditors are requested to focus on the LDC’s
maintenance results (compliance with the
Ontario Energy Board’s Distribution System
Code – Appendix C).
• In particular chambers (also known as vaults),
and similar underground infrastructure is
Bulletins published
• DB-05-14 Major Equipment Refurbishment
• DB-04-14 Installation Methods – Sags and
Tension Overhead Conductor
– Using Sag and Tension Tables to ensure conductors remain
in their expected zones
• DB-03-14 Installation Methods – Guy Anchors
– Importance of installing anchors correctly
Bulletins published
• DB-02-14 Process for Safety Concerns on Joint
Use Poles
– Regulator’s expectation that LDC infrastructure on 3rd
Party Poles will remain safe, due to the regular
inspections that will take place as per Appendix C of
the OEB DSC.
• DB-01-14 Barrier Support Structures and
Grounding Requirements
– Regulator’s expectation that no matter who owns the
barrier, the LDC has a responsibility to ensure their
infrastructure remains in a safe condition
Other Issues
ESA will be looking for Working Group
volunteers in order to create Best Practices
around the following items.
1. Major storm damage
2. Temporary Overvoltages
LDC Mergers
Mergers and Acquisitions
• NO LDC mergers have occurred
Potential changes in the near future
• Norfolk Power acquisition by Hydro One – approved (OEB
license still exists)
• Haldimand Country Hydro Inc acquisition by Hydro One –
waiting for OEB approval
• Woodstock Hydro acquisition by Hydro One – waiting for
OEB approval
• Brant County Power Inc acquisition by Cambridge & North
Dumfries Hydro Inc - (OEB license still exists)
Electrical Distribution Safety
• Any Questions?
Electrical Distribution Safety