Compliance

We require all employees to take a training course on our environmental policy, to reinforce every employee’s role in supporting PG&E’s goal of environmental leadership.

Just as operational excellence is the foundation for meeting our customer commitments, environmental compliance is the bedrock of PG&E’s commitment to environmental leadership. In fact, our environmental policy begins with a commitment to “comply fully with the letter and spirit of all applicable environmental laws and regulations.”

Our environmental policy and governance practices are designed to promote compliance with environmental requirements, as well as to provide a platform from which we can take our performance beyond the legal and regulatory baselines.

Our Approach

Environmental Management System

PG&E’s operations are subject to extensive federal, state and local environmental laws and regulations. These requirements relate to a broad range of activities, including preventing the discharge of pollutants; safely transporting, handling and storing hazardous materials; properly managing hazardous wastes; protecting threatened and endangered species; and reporting and reducing carbon dioxide and other greenhouse gas emissions.

To ensure we meet these requirements, PG&E uses an Environmental Management System (EMS) modeled after the ISO 14001 environmental management standard and consistent with its “Plan, Do, Check, Act” model for continuous improvement.

The Vice President of Safety, Health and Environment for Pacific Gas and Electric Company oversees PG&E’s commitment to meet—and strive to exceed—safety and environmental requirements. An Environmental Officer Steering Committee meets quarterly to provide oversight on environmental issues across PG&E. Other technical forums serve as additional vehicles to discuss, prioritize and cross-check environmental issues across the business.

Compliance performance updates are reviewed monthly by PG&E’s officers. In addition, an annual environmental compliance summary is presented to the Public Policy Committee of the PG&E Corporation Board of Directors.

2013 Milestones

Planning

Our current system uses a series of work processes to manage regulatory compliance and environmental performance by each line of business. While we have not sought ISO 14001 certifications for our facilities, we performed an independent third-party gap analysis to support the development of an EMS consistent with the ISO 14001 methodology and principles.

In 2013, our lines of business worked to develop specific environmental goals and objectives based on risk assessments of compliance work processes. The results are driving improvements to our plans and procedures in areas with the largest potential impacts to the environment. This process is overseen by a group of environmental directors and the Vice President of Safety, Health and Environment.

Implementation and Operation

PG&E employs a variety of operational controls to help ensure that actions to meet our environmental compliance obligations are performed on time, on purpose and are repeatable. We are also continuously learning from our experience and integrating these lessons back into our work processes and staff development.

Key EMS initiatives in 2013 included:

  • Developing a new tool to track environmental compliance at our facilities
  • Incorporating environmental requirements into an SAP-based work management system
  • Deploying an automated tool that uses GIS spatial data to assess projects for potential environmental impacts
  • Continuing a multi-year effort to embed environmental procedures into the work standards and procedures of our operating lines of business
  • Developing and updating environmental standards and guidance to improve consistency and efficiency

Through an extensive program, PG&E trains employees to correctly perform environmental activities associated with their work. Each year, PG&E trains thousands of employees on various environmental compliance responsibilities. Additionally, we require all employees to take a training course on our environmental policy, to reinforce every employee’s role in supporting PG&E’s goal of environmental leadership.

Reviews and Corrective Actions

A robust environmental auditing program is critical to ensuring that we are effectively complying with the many environmental laws and regulations relating to our business. We review and audit environmental performance in three different ways—self-assessments, comprehensive reviews and internal audits:

  • Self-Assessments: Environmental personnel perform self-assessments on facilities or projects under their oversight. Each assessment evaluates a facility or project for compliance with environmental regulations.
  • Comprehensive Reviews: These reviews are performed by personnel from the Environmental department who are not responsible for compliance at the facility or project being inspected. Each comprehensive review involves evaluating all environmental compliance obligations associated with a facility’s or project’s operations.
  • Internal Audits: The Internal Audit department conducts systemic and programmatic controls-based audits to independently analyze the effectiveness of our environmental compliance management systems. The results of these audits are reported annually to the PG&E Corporation and Pacific Gas and Electric Company Audit Committees of the Boards of Directors.

During 2013, we performed 2,508 self-assessments, 29 comprehensive reviews and four internal audits of various environmental processes, facilities and projects. The number of self-assessments increased from the previous year largely driven by enhanced rigor around compliance management tracking.

We continuously improve our corrective action process by performing root-cause analyses on non-compliance issues identified through environmental agency inspections, and tracking detailed corrective action plans to resolution.

Measuring Progress

Operational Performance

PG&E tracks and reports a wide range of annual environmental compliance performance indicators. This section details our performance results for 2013.

Reported Releases and Permit Exceedances

We reported a total of 211 releases in 2013, an increase from 182 reported in 2012. A release is defined as an unintentional discharge of a regulated substance that exceeds a reporting threshold. We report releases that meet regulatory thresholds, as well as many smaller releases, in an effort to ensure operational transparency to local agencies. A large percentage of these releases involved small amounts of mineral oil used in transformers or other petroleum-based substances.

We reported seven permit exceedances in 2013, compared to six in 2012. An exceedance is defined as a discharge in excess of what is allowed by a permit.

Agency Inspections

In 2013, a total of 341 agency inspections were conducted at our facilities. The majority of these inspections were performed by Certified Unified Program Agencies, such as city and county environmental health departments and fire departments.

Environmental Sanctions

Starting in 2012, we refined our compliance performance measures to sharpen our focus on enforcement actions that have environmental impacts. We began categorizing all written enforcement actions issued by a regulatory agency as “Level 1” (those findings that resulted in an actual or potential environmental impact) or “Level 2” (findings that did not result in an actual or potential environmental impact). We also began tracking the percentage of agency inspections that do not result in a written enforcement action.

The number of Level 1 enforcement actions received during 2013 was six. Our rate of inspections without a written sanction was 90 percent, meeting our target of 90 percent.

Enforcement Penalties and Settlements

PG&E paid a total of $64,244 in settlements and penalties.

Compliance Data 2011 2012 2013
Level 1 Enforcement Actions N/A1 4 6
Percentage of Inspections Without a Written Enforcement Action N/A2 89% 90%
Releases/Exceedances 243 188 218
Penalties Paid $32,378 $3,770,360 $64,244
Agency Inspections 710 632 3413
Audits Performed (System Audits and Comprehensive Facility Reviews) 59 40 33
Self-Assessments Performed 750 1,694 2,5084
  • 1 In 2012, PG&E began categorizing all written enforcement actions issued by a regulatory agency as “Level 1” (those findings that resulted in an actual or potential environmental impact) or “Level 2” (findings that did not result in an actual or potential environmental impact).
  • 2 In 2012, PG&E began reporting the percentage of inspections by a regulatory agency that do not result in a written enforcement action.
  • 3 In 2013, PG&E adopted a new Environmental Compliance System and only tracked facility inspections, whereas previous years included project inspections.
  • 4 The number of self-assessments performed increased largely due to enhanced rigor around compliance management tracking.

Looking Ahead

We will maintain our commitment to continuous improvement as we work to enhance our environmental management system. Key focus areas in 2014 include expanding our facility compliance tool to construction projects, expanding use of our automated environmental assessment tool and continuing to embed environmental procedures into the work standards of our operating lines of business.

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