V. VIOLATIONS OF GENERAL ORDER 165

CSD staff has found that SCE's maintenance program is in noncompliance with GO165 requirements. On November 30 through December 1, 2000, CSD staff conducted an audit of SCE's GO165 program. The following are the main deficiencies observed by CSD:

4. Identification of Unsafe Conditions

GO165, Section IV, requires each utility to conduct inspections of its facilities "to assure reliable, high quality, and safe operation." "Detailed inspections" conducted by SCE do not identify the majority of unsafe conditions. "Field inspections" conducted by CSD staff of overhead facilities that were previously inspected by SCE found that most unsafe conditions (GO95 violations) were not recorded. CSD staff conducted random inspections of overhead facilities on six different circuits:

_ Score Circuit: CSD found 15 GO95 violations on 8 poles. SCE's detailed inspection had found no violations on the same poles.

_ Trident Circuit: CSD found 19 GO95 violations on 9 poles. SCE's detailed inspection had found no violations on the same poles.

_ Eagle Circuit: CSD found 12 GO95 violations on 5 poles. SCE's detailed inspection had found no violations on the same poles.

_ Drum Circuit: CSD found 11 GO95 violations on 8 poles. SCE's detailed inspection had found one violation on the same poles.

_ JoJo Circuit: CSD found 13 GO95 violations on 6 poles. SCE's detailed inspection had found 2 violations on the same poles.

_ Polk Circuit: CSD found 24 GO95 violations on 10 poles. SCE's detailed inspection had found 9 violations on the same poles.

1. Period between Inspections

GO165, Section IV states that the period between inspections may in no case exceed the time specified in GO165, Appendix A. SCE's GO165 practices allow the period between inspections to exceed the time intervals specified in GO165 Appendix A.

For example, according to GO165, Appendix A, the maximum period between inspections for patrols of overhead conductors in urban areas is one year. However, according to SCE practices, if such a patrol was conducted on January 1, 2000, the next patrol can be conducted on December 31, 2001 allowing the period between inspections to exceed one year and extend up to two years. Similarly, the period between detailed overhead line inspections can extend up to six years and the period between detailed underground line inspections can extend up to four years.

5. Scheduling and Performance of Corrective Action

SCE has developed an Operation and Maintenance Policy and Procedure Manual that provides guidelines and examples to its staff on how to conduct inspections and prioritize findings. Section IM-2 of the manual describes a priority system to rate conditions found during patrols and detailed inspections. The priority system is based on a sequence of numbers where "1" is the lowest maintenance priority and "6" is the highest maintenance priority as follows:

Priority 1: "No action required."

Priority 2: "Opportunity maintenance." No separate work order is generated and maintenance is performed on an opportunity basis. There is no requirement to correct the condition within a specified time.

Priority 3: "Moderate degradation." Corrective action or re-inspection required before the next scheduled detailed inspection.

Priority 4: "Advanced degradation." Corrective action required within the detailed inspection cycle. The required time frame for corrective action depends on the type of facility and ranges from 18 months to three years.

Priority 5: "Urgent Corrective action is required." The required time frame for corrective action ranges from 60 days to one year.

Priority 6: "Immediate attention is required."

Most GO95 violations found by SCE during annual patrols and detailed inspections are assigned priorities 2 and 3. Therefore, most GO95 violations found during SCE's inspections are either corrected the next time SCE visits the facility to perform other work within no specified time period (priority 2), or corrected in five years (priority 3). A GO95 violation assigned priority 3 can also be re-inspected in five years causing the corrective action to be delayed even further. The following are examples of GO95 violations and the priorities assigned by SCE:

_ Bare service drops (violation of GO95, Rule 49.4C7) - Priority 3

_ Low service drops (violation of GO95, Rule 54.8) - Priority 3

_ Missing "High Voltage" signs (violation of GO95, Rule 51.6A) - Priority 2

_ Missing/damaged ground wires/moldings (violation of GO95, Rule 31.1) - Priority 2

_ Idle facilities (violation of GO95, Rule 31.6) - Priority 2

_ Inadequate pole depth (violation of GO95, Rule 49.1C) - Priority 2 or 3

_ Missing steps (violation of GO95, Rule 91.3A) - Priority 2

_ Overhead guys not taut (violation of GO95, Rule 56.2) - Priority 3

This report contains only summaries of the CSD's findings. Complete staff

investigation reports, including documentation, photographs and related

correspondence are maintained for each accident investigated and inspection/audit

conducted, and will be served on the respondent utility and are available for public

inspection at the CPUC. The CSD staff reserves the right to move facts and findings on

any subsequent violations into the record of this proceeding. (See Ordering paragraph 4, Order Instituting Investigation SCE maintenance practices.) .