ML022350448
| ML022350448 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/05/2002 |
| From: | Kirkpatrick E Pacific Gas & Electric Co |
| To: | Office of Nuclear Reactor Regulation, US Federal Judiciary, Bankruptcy Court, Northern District of California |
| References | |
| 01-30923 DM, 94-0742640 | |
| Download: ML022350448 (6) | |
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14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 JAMES L. LOPES (No. 63678)
-JANET A. NEXON (No. 104747)
JULIE B. LANDAU (No. 162038)
HOWARD, RICE, NEMEROVSKI, CANADY, FALK & RABKIN A Professional Corporation
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Three Embarcadero Center, 7th Floor 3 -. 3 San Francisco, California 94111-4065 Telephone:
415/434-1600 Facsimile:
415/217-5910 Attorneys for Debtor and Debtor in Possession PACIFIC GAS AND ELECTRIC COMPANY UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF CALIFORNIA
-SAN FRANCISCO DIVISION In re Case No. 01-30923 DM PACIFIC GAS AND ELECTRIC Chapter 11 Case, COMPANY, a California corporation,
- Date:
September 4, 2002 Debtor.
Time:
9:30 a.m.
-Place:
235 Pine Street, 22nd Floor San Francisco, California Federal I.D. No. 94-0742640 DECLARATION OF ERIC G. KIRKPATRICK IN S UPPORT OF MOTION FOR AUTHORITY.TO INCUR MISCELLANEOUS IMPLEMENTATION EXPENSES I, Eric G. Kirkpatrick, declare..
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I am employed by/ Pacific-Gas and Electric Company ("PG&E"), the debtor and debtor-in-possessiofi in this Chapter il case. With the exception of a ten-'month'period during 2001, I have worked for PG&E since 1984 in various engineering and related suipervisory positions. '-I have obtained considerable expertise in gis tran-smiission'matters; for example, from March 2000 through February 2001, I was responsibleI f6r directinig and leading the maintenance arid on-site operations of gas transmissioi' pi~elire_, comhpressor stations, and underground storage facilities in the central and southern area of PG&E's service area. Since January 2002, 1 have been a manager for the California Gas Transmission Business Unit, and am responsible for planning and DECLARATION OF ERIC G. KIRKPATRICK
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implementation of gas transmission-related activities associated with PG&E's proposed Plan of 2
Reorganization (the "Plan"). In this position, I have had'a leading role in the planning for GTrans, 3
LLC ("GTrans"), the New Entity that will carry out thb gas transmission line of business, and have 4
also become familiar with the planning for ETrans, LLC ("ETrans"), the New Entity that will carry 5
out the electric transmission line of business.
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This declaration is submitted in support of PG&E's Motion for Authority to Incur 7
Miscellaneous Implementation Expenses (the "Motion"). Defined terms used herein shall have the 8
meanings set forth in the Motion. I make this declaration based on personal knowledge, except 9
where otherwise indicated; and if called as a witness, could ind would testify competently to the 10 matters set forth herein.
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By the Plan Effective Date, both ETrans and GTrans will need to have accurate 12 Tangible Property List ("TPL"): databases in place. The TPL databases contain ihe mileage, 13 location, and other information about gas and electric facilities'§uch as gas pipelines and elehtric RICE$
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14 wires located in or-along the public roads within local jurisdictions. Franchise payment calculations
&R'.ltONGN 15 are based on the miles of utility facilities in the local franchise area, and local jurisdictions are 16 entitled to audit the franchise mileage data for accuracy. Therefie*, as part of the Plan 17 implementation process, it is necessary for ETrans and GTrans to have separate6TPL databases 18 reflecting their respjective electric and gas facilities for purposes of calculating firnchise pa)ýments.
19 PG&E's existing TPL database provides only limited information differentiating between 20 transmission facilities (which will be transferred to GTrans and ETrans) and distribution facilities 4
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- (which will remain at PG&E). For many types of facilities, the differentiation between transmission 22 and distribution facilities is inadequate, since the database was set up for one company handling 23 both distribution and transmission. For example, when both electric transmission lines and electric 24 distribution lines exist together on the same utility pole, the TPL database simply lists the location 25 and mileage of overhead electric wires, without indicating whether these lines are related to 26 transmission or distribution. A consultant will be hired from Structural Integrity, an engineering and 27 consulting firm, to: (i) develop a method to determine the correct franchise footage data to be 28 transferred into new TPL databases for ETrans (for electric transmission assets) and GTrans (for gas DECLARATION OF ERIC G. KIRKPATRICK 1
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&RAtBCN I, _ 15 16 17 18 19 20 21 22 23 24 25 26 27 28 transmission assets), (ii) design a step-by-step work process-fotk ccurately updating the new'TPL databases, and (iii) develop a work process for ETrans and GTrans to handle "delineation-requests" from local government authorities for Public Woiks projects (i.e., requests that existinig transmission assets be identified and located so that the Public Works'projects will not interfere with them). The total estimated cost for this work is $40,000.
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Once the foregoing work is completed, PG&E will require additional services to separate the existing gas and electric TPL database into the separate portions -that will be needed for the new ETrans and GTrans TPL databases. An estimate for these services cannbt be developed until the preliminary work described above is completed; therefore, the additional services Will be the subject of a subsequent motion. The services to be performed by the Stnictural Integrity.
consultant, combinied with the additiofial database work to follow, could take up to four months to complete.
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PG&E ha's identified four piojects related to GTrans' business operations, as described below, that must be performed in-advan6e 6. f the Plan Effective Date.
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Emergency Plan Manual:+ PG&E currently has a number of local gas transmismion Emergency Plan Manuals-,'which cor~tain step by step guidelines, checklists, government agency contact ndmbers and other information for use during earthquakes, gas leaks, failures of gas.'
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regulators and other emergencies. After the Plah Effective Date, GTrans will require one statewide Emergency Plan Manual. The new GTrans Emergen*y Plan Manual ("Emergency Plan Manual")
will contain the information that is currenitly contained in local manuals, but will also provide uniform procedures, guidelines and checklists, and be-set up in accordance with the new GTrans organizational structure and facilities., For example,-under the Plan, over 2,000 District Gas I.
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Regulator Stations (the delivery points between GTrans' gas transmission facilities and PG&E's gas a+
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distribution system) will be transferred from PG&E to GTrans. The Emrh'gen'cy Plan Manual will Jl
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reflect emergency procedures to be followed for any emergency involving these Regulator Stations.
A consultant from Blue Flame (a consulting' firm specializing in gas transmission work) be hired to gather and review the existing manuals, and to create a new statewide Emergency Plan Manual as described above. For example, the consultant will ensure that the Emergency-Plan DECLARATION OF ERIC 1
Manual has all of the city, county and public agency contact names and telephone numbers that 2
GTrans will need, in the event of an emergency, as well as key contact information for PG&E and 3
other GTrans' customers. Finally, the consultant will review all aspects of the Emergency Plan 4
Manual to verify that all necessary updates have been made to reflect the separation between GTrans 5
and PG&E. The total estimated cost for this work is $15,000. This project is expected to take up to 6
three months. As this project requires a consultant with detailed knowledge of the requirements of 7-the Emergency Plan Manual, PG&E requests authority to begin this work now as PG&E has I'
8 identified a consultant with the necessary expertise and'current availability. Also, this work must be 9
completed in advance of the Plan Effective Date to allow for additional time to train employees to 10 implement the new Emergency Plan Manual.
11 (b)
Employee Training. A consultant from Grinstead & Associates (a consulting 12 firm specializing in gas transmission work) will be hired to identify and gather training materials H*W*RD 13 and develop a targeted program to train GTrans field employees who may not be familiar with 14 redefined job responsibilities and/or revised work protocols. These field employees will maintain 15 and operate the gas transmission pipelines and be responsible for emergency responses. PG&E must 16 ensure that the GTrans employees are familiar with any new or revised requirements of gas 17 transmission work. The estimated cost for this work is $50,000. After Grinstead completes its
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18 training program development, which could take up to two months, PG&E staff will implement 19 Grinstead's recommendations and set up an internal training program. PG&E estimates that it could 20 take up to three months to set up and implement the necessary training for GTrans employees. This 21 work must be completed in advance of the Plan Effective Date so that GTrans can provide safe, 22 reliable service on the first day that GTrans.begins business operations.
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Service and Interconnection Requests. The personnel at PG&E who handle
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,requests for new service and/or interconnections will not be transferred to GTrans as PG&E will still 25 perform these services. Upon the Plan Effective Date, GTrans personnel must be prepared to 26 respond to transmission service requests as part of day-to-day business operations. Therefore, a 27 consultant will be hired from Blue Flame to develop new business procedures for GTrans to handle 28 requests for new service and/or interconnections. This work will include: a review of current DECLARATION OF ERIC 1
business procedures at PG&E; a review of tariff requirements applicable to GTrans; designing new 2
forms to record necessary irformation and setting up internal business procedures to be followed by 3
GTrans for new transmission service and/or interconnection requests. The estimated cost for2 this 4-work is $30,000. PG&E expects that this work will take up to three months to complete, following 5
which PG&E requires additional time to determine and plan for the required staffing and 6
organizational structures that will be needed by GTrans to handle n~w service requests.
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Mapping. Two consultants will be hired from Corestafft6 assi'st PG&E staff in 8
the mapping of GTrans transmission facilities onto the Gas Transmission Graphic Information 9
System ("GTGIS"), a system of computer-generated maps to be used by GTrans. Many of PO&E's 4,
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o 10 thousands of existing maps exist only in hard copy and will need to be retained by PG&E for4 its 11 distribution business. Therefore, this project is necessary-to proVide GTrans with its own maps of 12 all gas transmission facilities, to be used for both operational and 6mergericy response purposes-,
13 including: (i) to enable GTrans" employees to maintain the transimissioh facilifies and'respond in
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A 14 cases of emergency; (ii) to establish correct rou'tmig of USA tickets (requests by' c6fitracf6rý and 4g..
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15 others to mark the locations of facilities in the field-so that the facilities ar6 not harmed during
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16 construction projects). Specifically, the consultants will ensire'that ill GTrans facilities, including 17 the District Gas Regulator Stations, are included in the GTGIS and that theGTGIS conitains 18 sufficient detail to meet GTrans' requirements. The estimated cost f6r these services is $115,000.
19 The mapiifig project is expected to take four months to complet'e: PG&E believes that the mapping 20 project must be comkleted in-advance of the Plan' Effective Date in bdei" for GTrans to'cbmmence 21 business operations and to be prepared for emergency responses.
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PG&E's standard contractual provisions in place With the" firms listed above 4
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2 23 (Structural Integrity, Blue Flame, Grinstead and Coresfaff) do'not guarantee any future work or.any 24 minimum amount of revenue. PG&E also maintains the right to terminate the work at any time 4
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26 costs reasonably incurred by the firms in terminating any work in progress.
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The above cost estimates are based on PG&E's initial scoping of the project 28 requirements and negotiations with the consultants who have been selected to perform the services.
DECLARATION OF ERIC 1
I declare under penalty of perjury of the laws of the United States that the 2
foregoing is tmue and correct, and that this declaration was executed at Walnut Creek, 3
California on August
, 2002.
5 Eric G. Kirkpatrick 6
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.18 19 20 21 22 23 24 25 26 27 28 DECLARATION OF ERIC G. KIR"ATRICK I.