VII. Example Initial Certification Report

The following is an example of an Initial Certification Report to the CPUC for a hypothetical Power Generation Plant. All of the document references, discussion and dates are purely fictional, but do represent the level of detail envisioned for the Certification Report.

Generating Asset Owner: Legal Name of Owner

Owners Address

Generating Asset: Name of Station or Unit

Address of Station or Unit

Certification:

I, (name of officer), being duly sworn, do hereby certify that I am an officer in (Legal Name of Owner), and have sufficient knowledge of the maintenance programs being employed at the (Name of Station or Unit), and also certify, that with exceptions noted in Enclosure 1, that the maintenance program currently being employed at the (Name of Station or Unit), meets the intent of each Generation Maintenance Performance Standard promulgated by the Generation Maintenance Program, Revision 0, dated ___________.

All records of the initial self-assessment providing a basis for this certification are maintained at the (Location of records).

(Legal Name of Owner)'s designated contact for information regarding the self-assessment or other information providing a basis for this certification is:

Name of Individual

Title of Individual

Address of Individual

Telephone number of Individual

Attested to this (date).

______(Signature of Officer_________

(Typed Name of officer and Title)

Legal Name of Owner

Encl: 1

Notarized by:

Enclosure 1, Certification Report for (Legal Name of Owner).

The following report summarizes the methods employed by (Legal Name of Owner) to achieve each Generation Maintenance Performance Standard promulgated in the Generation Maintenance Program, Revision 0, Dated ______________.

(Note - Fictional documentation and dates are used to show level of detail desired)

Performance Standard: I. A

No exceptions noted in the Self-Assessment dated July 29, 2001. Applicable documents include:

Legal Name of Owner Safety Manual, Revision 4, 2000

Legal Name of Owner Safety Performance Report, YTD, June 2001

Performance Standard: I. B

One exception noted. Assessment Guideline I.B.2.F.1, suggests administrative controls for infrequently performed test and evolutions. At the current time, (Legal Name of Owner) does not have such an administrative control approved. A procedure is currently being developed and will be approved prior to November 30, 2001. Applicable documents include:

Name of Station or Unit Organization and Accountabilities, Rev. 14, June 2001

Name of Station or Unit, Conduct of Maintenance, Rev. 03, November 2000

Name of Station or Unit, Development and Control of Procedures, Rev. 2, April 1999

Performance Standard: I. C

No exceptions noted in the Self-Assessment Dated July 29, 2001. Applicable documents include:

Name of Station or Unit Organization and Accountabilities, Rev. 14, June 2001

Name of Station or Unit, Conduct of Maintenance, Rev. 03, November 2000

Name of Station or Unit Monthly Performance Report, YTD, June 2001

Name of Station or Unit, Corrective Action Process, Rev. 0, January 2001

Performance Standard: I. D

One exception noted. Although Assessment Guideline I.D.2.A does not explicitly require an administrative procedure for conducting self-assessments, we feel such a procedure is necessary. It will be developed and fully implemented by April 2002. Applicable documents include:

Name of Station or Unit, Corrective Action Process, Rev. 0, January 2001

Name of Station or Unit Monthly Performance Report, YTD, June 2001

Performance Standard: II. A

No exceptions noted in the Self-Assessment Dated July 29, 2001. Applicable documents include:

Name of Station or Unit Organization and Accountabilities, Rev. 14, June 2001

Legal Name of Owner Performance Evaluation Process, Revision 2, 1999

Legal Name of Owner Succession Planning, Revision 0, 2000

Performance Standard: II. B

One exception noted. At the time of the self-assessment, no means or method was available or being used to assess the qualification of contractor personnel as recommended by Assessment Guideline II.B.2.I. A method will be developed, documented in Station Administrative Procedures and be fully implemented by April 2002. Applicable documents include:

Name of Station or Unit Training Manual, Rev. 4, July 2001

Performance Standard: III. A

No exceptions noted in the Self-Assessment Dated July 29, 2001. Applicable documents include:

Name of Station or Unit Organization and Accountabilities, Rev. 14, June 2001

Name of Station or Unit, Conduct of Maintenance, Rev. 03, November 2000

Name of Station or Unit, Work Management, Rev. 02, October 2000

Name of Station or Unit, Post Maintenance Testing Manual, Rev. 01, June 1998

Name of Station or Unit, PM Program Manual, Rev. 04, June 1998

Performance Standard: IV. A

One exception noted. At the time of the self-assessment, no written policy existed governing the use of procedures. We feel such a procedure is necessary. It will be developed and fully implemented by April 2002. Applicable documents include:

Name of Station or Unit, Conduct of Maintenance, Rev. 03, November 2000

Name of Station or Unit, Development and Control of Procedures, Rev. 2, April 1999

Name of Station or Unit, Corrective Action Process, Rev. 0, January 2001

Performance Standard: V. A

Two exceptions noted. At the time of the self-assessment, the extent of planning and scheduling to support corrective maintenance for work performed in-service or during outages definitely did not meet the intent of this standard. In addition, the material support for maintenance as suggested by Assessment Guideline V.A.2.D.2 is not being satisfied. Station management is developing an action plan to resolve these issues prior to the commencement of our planned major overhaul in the fall of 2002. Specifics are not available at this time.

Name of Station or Unit, Conduct of Maintenance, Rev. 03, November 2000

Name of Station or Unit, Work Management, Rev. 02, October 2000

Name of Station or Unit, Procurement of Parts and Supplies, Rev. 08, November 2000

Name of Station or Unit, Post Maintenance Testing Manual, Rev. 01, June 1998

Performance Standard: V. B

One exception noted. Station Management does not subscribe to the concept of independent verification. Our monitoring of the number of problems created by mis-positioned components supports the management position.

Name of Station or Unit, Conduct of Operations, Rev. 06, April 1998

Name of Station or Unit, Conduct of Maintenance, Rev. 03, November 2000

Name of Station or Unit, Work Management, Rev. 02, October 2000

Performance Standard: VI. A

This performance standard is clearly not being met at this time. As noted in the response to Performance Standard V.A, the material support for maintenance as suggested by Assessment Guideline V.A.2.D.2 and this Standard are not being satisfied. Station management is developing an action plan to resolve these issues prior to the commencement of our planned major overhaul in the fall of 2002. Specifics are not available at this time.

Name of Station or Unit, Procurement of Parts and Supplies, Rev. 08, November 2000

Name of Station or Unit, Conduct of Maintenance, Rev. 03, November 2000

Name of Station or Unit, Work Management, Rev. 02, October 2000

Performance Standard: VII. A

One specific exception was noted, and there is general area for improvement in the overall technical support of station maintenance. As noted in response to Performance Standard III.B, at the time of the self-assessment, no systematic approach was being used to assess the effectiveness of the PM Task. Station management is considering development of such a process, but has no definite plans at this time. Improvements in the technical support for maintenance are addressed in Performance Standard VII.C. Applicable documents include:

Name of Station or Unit, Conduct of Maintenance, Rev. 03, November 2000

Name of Station or Unit, Work Management, Rev. 02, October 2000

Name of Station or Unit, Post Maintenance Testing Manual, Rev. 01, June 1998

Name of Station or Unit, PM Program Manual, Rev. 04, June 1998

Performance Standard: VII. B

As noted in response to Performance Standard VII.A there is general area for improvement in the overall technical support of station maintenance. These areas of improvement are performance related, not insufficient program documents. At the time (Legal Name of Owner) acquired (Name of Station or Unit), many of the engineers in the Technical Support Department opted to take an early retirement option from the previous owner. Recruitment efforts for experienced degreed engineers have not yielded the desired results. As an alternative, Station Management, with full support of (Legal Name of Owner), is developing job descriptions for Technical Specialist who will be experienced operators or maintenance personnel, and perform many of the non-design functions of technical support. Such tasks would include, but not be limited to, monitoring equipment performance and trends, conducting in-service test program, and review of equipment history for potential areas of improvement in maintenance approach or required design changes. We expect to have this performance weakness corrected by the time of our first re-certification.

Applicable documents include:

Name of Station or Unit, Conduct of Maintenance, Rev. 03, November 2000

Name of Station or Unit, Work Management, Rev. 02, October 2000

Name of Station or Unit Organization and Accountabilities, Rev. 14, June 2001

Name of Station or Unit, Conduct of Engineering Services, Rev. 03, July 1999

Performance Standard: VII. C

At the time of the self-assessment, Station Management had instituted a significant improvement program for chemistry. We were not meeting the requirements of Performance Standard VII.C. The improvement program is an integrated program, with scheduled completion for September 2002. Applicable documents include:

Name of Station or Unit Organization and Accountabilities, Rev. 14, June 2001

Name of Station or Unit, Conduct of Operations, Rev. 06, April 1998

Name of Station or Unit, Conduct of Engineering Services, Rev. 03, July 1999

Performance Standard: VII. D

While there are many improvements to be made in the chemistry support for station operations, no exceptions were note to regulatory compliance. Applicable documents include:

Name of Station or Unit Organization and Accountabilities, Rev. 14, June 2001

Name of Station or Unit, Conduct of Operations, Rev. 06, April 1998

Performance Standard: VIII. A

One exception noted. At the time of the self-assessment, technical support required for performing the reviews of equipment history as recommended by Assessment Guideline VIII.A.2.C is insufficient. See the response to VII.B above. Applicable documents include:

Name of Station or Unit, Conduct of Maintenance, Rev. 03, November 2000

Name of Station or Unit, Work Management, Rev. 02, October 2000

Name of Station or Unit, Conduct of Engineering Services, Rev. 03, July 1999

Performance Standard: IX. A

No exception noted. Applicable documents include:

Name of Station or Unit, Conduct of Maintenance, Rev. 03, November 2000

Name of Station or Unit, Work Management, Rev. 02, October 2000

Prepared by:

____________________

(Name and Title of Individual Performing Assessment for Certification)

This may be the individual who lead the self-assessment, or someone using the output of the self-assessment to prepare the certification summary.