IX. GO Violations
A. The 37 Violations Involving Accidents
The 37 violations involving accidents are described in detail in Appendix B.18 In seven of the cases, we find no GO violation as alleged by CPSD. In the remaining cases, we find GO violations and impose fines because of Edison's failures to correct serious violations in a timely fashion. Our specific reasons for reaching these conclusions are set out in the discussions of the individual cases.
B. Violations of GO 95 and 128
Edison did not contest CPSD's findings of nonconformances with GO 95 and 128 at the time CPSD made them; in fact, once notified, Edison repaired these problems as required by CPSD. We applaud Edison for timely addressing these problems. Nonetheless, we find, based on CPSD's inspection results, 4,044 violations of GO 95 and 677 violations of GO 128.
We address below Edison's further arguments on whether it is appropriate to penalize Edison for these violations.
18 The accidents are set forth according to Edison's categorization of them: (a) No Nonconformance; (b) Nonconformance But No Causation; (c) Nonconformance, Causation, But No Inspection Violation; and (d) Nonconformance, Causation, and a Failure to Detect/Remedy. In Appendix B, we discuss the accidents in detail and reach our own conclusion as to whether Edison violated the GOs as alleged by CPSD.
