Compliance
Just as operational excellence serves as 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 and provide a platform from which we can take our performance beyond 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 system uses a series of compliance work processes that enable PG&E to manage regulatory compliance and our environmental impacts by each line of business.
The Vice President of Safety, Health and Environment for Pacific Gas and Electric Company oversees our commitment to meet safety and environmental requirements, with the goal of exceeding them. In addition, 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, and an annual environmental compliance summary is presented to the Compliance and Public Policy Committee of the PG&E Corporation Board of Directors.
2014 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.
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 also continuously learn from our experiences and integrate these lessons back into our work processes and staff development.
In 2014, we continued to leverage technology solutions to drive compliance and minimize impacts on the environment. Key EMS initiatives included:
- Implementing an SAP-based tool to track facility and project compliance.
- Deploying an automated tool that uses Geographic Information System spatial data to assess projects for potential environmental impacts.
- Continuing a multiyear effort to embed environmental procedures into the work standards and procedures of our operating lines of business.
PG&E conducts extensive training to ensure employees have the skills and knowledge 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 ensure 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 they oversee. 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 the operations of a facility or project.
- 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 2014, we performed a combination of 5,673 self-assessments, comprehensive reviews and internal audits of various environmental processes, facilities and projects.
To drive continuous improvement, we employ a rigorous corrective action process, which includes performing root-cause analyses on noncompliance 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 2014.
Reported Releases and Permit Exceedances
We reported a total of 134 releases in 2014, a decrease from 211 reported in 2013. 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.
We reported six permit exceedances in 2014, compared to seven in 2013. An exceedance is defined as a discharge in excess of what is allowed by a permit.
Agency Inspections
In 2014, a total of 571 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 and Penalties
To measure compliance performance, we categorize 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 track the percentage of agency inspections that do not result in a written enforcement action.
We received five Level 1 enforcement actions in 2014. Our rate of inspections without a written sanction was 93 percent, exceeding our target of 90 percent.
PG&E paid a total of $3,100 in penalties.
| 2012 | 2013 | 2014 | |
|---|---|---|---|
| Level 1 Enforcement Actions | 4 | 6 | 5 |
| Percentage of Inspections Without a Written Enforcement Action | 89% | 90% | 93% |
| Releases/Exceedances | 188 | 218 | 134 |
| Penalties Paid | $3,770,3601 | $64,244 | $3,100 |
| Agency Inspections | 632 | 3412 | 5712 |
| Audits Performed (System Audits and Comprehensive Facility Reviews) | 40 | 33 | 40 |
| Self-Assessments Performed | 1,694 | 2,508 | 5,6333 |
- 1This includes $3.6 million that PG&E paid to resolve an alleged violation of a 2008 Clean Up and Abatement Order issued by the Lahantan Regional Water Quality Control Board regarding the chromium plume in Hinkley. The alleged violation was resolved by a settlement under which $1.8 million was paid to the state and the remaining $1.8 million was put toward a supplemental environmental project in the Hinkley area.
- 2 In 2013, PG&E adopted a new Environmental Compliance System and only tracked facility inspections, whereas previous years included project inspections.
- 3 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. In 2015, we will continue to focus on expanding the use of technology to minimize environmental impacts as we perform gas and electric infrastructure improvements. We also remain focused on further embedding environmental considerations into our work procedures and construction project plans.