Reporting Procedures for Self-identified Potential Violations Reporting Process GSRB’s current process, gas corporations submit reports of self-identified violations to a shared email inbox at the Commission. In the report, the gas corporation explains the violation, when it occurred (if known), and when and how the gas corporation identified the violation; it also describes any planned or completed corrective actions. In the future SED may develop a methodology or other refinements to the process for reporting of gas and electric self-identified potential violations. However, at this time the current GSRB methodology and practice is adequate for ESRB. We do not believe that Commission guidance is needed in this respect. Correction of Self-identified Potential Violations SED recommends that reports of self-identified potential violations be required to include information about whether the potential violation has been corrected. If a potential violation has not been corrected before the report is submitted, the report should include a plan and schedule for correction. Reporting self-identified potential violations does not relieve the utility of its obligation to correct violations with any immediate safety hazard as soon as feasible. Reporting Period PG&E supports a 30-day self-reporting period for both electric and gas utilities, on the basis that the longer period would allow the utilities time to consult with SED and to develop a thoughtful and thorough solution to the problem. SoCalGas/SDG&E state that the current 10-day self-reporting period for gas is insufficient time for the utility to gather all the underlying facts and information necessary to analyze carefully the underlying violation and potential remedies, pointing out that a ten-calendar-day requirement might only be six business days, depending on when a violation was first identified. They add
Reporting Procedures for Self-identified Potential Violations Reporting Process GSRB’s current process, gas corporations submit reports of self-identified violations to a shared email inbox at the Commission. In the report, the gas corporation explains the violation, when it occurred (if known), and when and how the gas corporation identified the violation; it also describes any planned or completed corrective actions. In the future SED may develop a methodology or other refinements to the process for reporting of gas and electric self-identified potential violations. However, at this time the current GSRB methodology and practice is adequate for ESRB. We do not believe that Commission guidance is needed in this respect. Correction of Self-identified Potential Violations SED recommends that reports of self-identified potential violations be required to include information about whether the potential violation has been corrected. If a potential violation has not been corrected before the report is submitted, the report should include a plan and schedule for correction. Reporting self-identified potential violations does not relieve the utility of its obligation to correct violations with any immediate safety hazard as soon as feasible. Reporting Period PG&E supports a 30-day self-reporting period for both electric and gas utilities, on the basis that the longer period would allow the utilities time to consult with SED and to develop a thoughtful and thorough solution to the problem. SoCalGas/SDG&E state that the current 10-day self-reporting period for gas is insufficient time for the utility to gather all the underlying facts and information necessary to analyze carefully the underlying violation and potential remedies, pointing out that a ten-calendar-day requirement might only be six business days, depending on when a violation was first identified. They add
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