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Category:Legal-Affidavit
MONTHYEARML24162A0792024-06-0707 June 2024 OEDO-24-00083 - 10 CFR 2.206 - Diablo Canyon Units 1 and 2 Seismic CDF - Supplemental Declaration 6-7-2024 - DCL-23-022, 2023 Annual Statement of Insurance for Pacific Gas and Electric Company’S Diablo Canyon Power Plant2023-03-29029 March 2023 2023 Annual Statement of Insurance for Pacific Gas and Electric Company’S Diablo Canyon Power Plant DCL-19-082, Submittal of Site-Specific Decommissioning Cost Estimate2019-12-0404 December 2019 Submittal of Site-Specific Decommissioning Cost Estimate DCL-18-100, License Amendment Request 18-02 - License Amendment Request to Revise Technical Specification 5.6.5b1 Core Operating Limits Report (COLR) for Full Spectrum Loss-of-Coolant Accident Methodology2018-12-26026 December 2018 License Amendment Request 18-02 - License Amendment Request to Revise Technical Specification 5.6.5b1 Core Operating Limits Report (COLR) for Full Spectrum Loss-of-Coolant Accident Methodology ML16061A4522016-02-11011 February 2016 Submittal of Tricon Phase 2 Documents for the License Amendment Request for Process Protection System Replacement DCL-16-020, Diablo Canyon, Units 1 and 2 - Submittal of Tricon Phase 2 Documents for the License Amendment Request for Process Protection System Replacement2016-02-11011 February 2016 Diablo Canyon, Units 1 and 2 - Submittal of Tricon Phase 2 Documents for the License Amendment Request for Process Protection System Replacement ML16026A3882016-01-0505 January 2016 Westinghouse Electric Company, LLC, Submittal of Proprietary Version of LTR-DCPPS-15-008 Response to NRC RAI 73 (Open Item 129). ML15090A2752015-03-26026 March 2015 Independent Spent Fuel Storage Installation - Consent and Hearing Waiver Form ML14171A2372014-06-11011 June 2014 Submittal of Supplemental Analysis for Inservice Inspection Program Relief Request SWOL-REP-1 U2 DCL-14-034, Affidavit No. 993754-AFF-104T, Dated 03/12/2014, Signed by Mark Herschthal2014-03-12012 March 2014 Affidavit No. 993754-AFF-104T, Dated 03/12/2014, Signed by Mark Herschthal ML14205A0352014-03-12012 March 2014 Affidavit No. 993754-AFF-104T, Dated 03/12/2014, Signed by Mark Herschthal DCL-13-061, CS Innovations - Application for Witholding Proprietary Information from Public Disclosure, Enclosure, Attachment 22013-04-25025 April 2013 CS Innovations - Application for Witholding Proprietary Information from Public Disclosure, Enclosure, Attachment 2 ML13078A2922013-03-0505 March 2013 Areva Affidavit for Areva Calculations #32-9199805-000, Diablo Canyon Power Plant Unit 2 Pzr Safety and Spray Nozzles Planar Flaw Analysis (Proprietary) and #32-9199937-000, DCPP Unit 2 - Evaluation of Laminar Indications in Pressurizer Noz DCL-13-021, Areva Affidavit for Areva Calculations 32-9199805-000, Diablo Canyon Power Plant Unit 2 Pzr Safety and Spray Nozzles Planar Flaw Analysis (Proprietary) and 32-9199937-000, DCPP Unit 2 - Evaluation of Laminar Indications in Pressurizer N2013-03-0505 March 2013 Areva Affidavit for Areva Calculations #32-9199805-000, Diablo Canyon Power Plant Unit 2 Pzr Safety and Spray Nozzles Planar Flaw Analysis (Proprietary) and #32-9199937-000, DCPP Unit 2 - Evaluation of Laminar Indications in Pressurizer Noz DCL-12-069, Diablo Canyon, Units 1 and 2 - Submittal of Attachment 1, Quality Assurance Plan and Revised Phase 1 Documents for the License Amendment Request for Digital Process Protection System Replacement and Attachment 8 Affidavit 993754-AFF-38T2012-08-0202 August 2012 Diablo Canyon, Units 1 and 2 - Submittal of Attachment 1, Quality Assurance Plan and Revised Phase 1 Documents for the License Amendment Request for Digital Process Protection System Replacement and Attachment 8 Affidavit 993754-AFF-38T ML12222A0942012-08-0202 August 2012 Submittal of Attachment 1, Quality Assurance Plan and Revised Phase 1 Documents for the License Amendment Request for Digital Process Protection System Replacement and Attachment 8 Affidavit 993754-AFF-38T ML12137A0242012-05-15015 May 2012 Diablo Canyon - May Hearing File Update ML11297A0562011-10-18018 October 2011 Diablo Canyon - October Hearing File Update ML0715501312007-05-23023 May 2007 SER Compliance with WCAP-16260-P-A the Spatially Corrected Inverse Count Rate (Scicr) Method for Subcritical Reactivity Measurement DCL-05-121, Correction of Information Contained in License Amendment Request 05-04. Revision to Technical Specification 5.3.1. 'Unit Staff Qualifications.'2005-12-23023 December 2005 Correction of Information Contained in License Amendment Request 05-04. Revision to Technical Specification 5.3.1. 'Unit Staff Qualifications.' DCL-05-018, License Amendment Request 05-01 Revision to Technical Specification 5.5.9, Steam Generator Tube Surveillance Program, and 5.6.10, Steam Generator Tube Inspection Report. to Allow Use of the W* Alternate Repair Criteria.2005-03-11011 March 2005 License Amendment Request 05-01 Revision to Technical Specification 5.5.9, Steam Generator Tube Surveillance Program, and 5.6.10, Steam Generator Tube Inspection Report. to Allow Use of the W* Alternate Repair Criteria. DCL-04-149, License Amendment Request 04-07, Revision to Technical Specifications 3.7.17 and 4.3 for Cycles 14-16 for a Cask Pit Spent Fuel Storage Rack2004-11-0303 November 2004 License Amendment Request 04-07, Revision to Technical Specifications 3.7.17 and 4.3 for Cycles 14-16 for a Cask Pit Spent Fuel Storage Rack DCL-04-123, License Amendment Request 04-06 Removal of Technical Specifications 5.6.1, Occupational Radiation Exposure Report, and 5.6.4, Monthly Operating Reports2004-11-0101 November 2004 License Amendment Request 04-06 Removal of Technical Specifications 5.6.1, Occupational Radiation Exposure Report, and 5.6.4, Monthly Operating Reports DCL-04-104, Response to NRC Request for Additional Information Regarding License Amendment Request 04-01, 'Revised Steam Generator Voltage-based Repair Criteria Probability of Detection Method for Plant.2004-08-18018 August 2004 Response to NRC Request for Additional Information Regarding License Amendment Request 04-01, 'Revised Steam Generator Voltage-based Repair Criteria Probability of Detection Method for Plant. DCL-04-089, Response to June 14 and July 6, 2004, NRC Request for Additional Information Re License Amendment Request 03-18, Revision to Technical Specifications 5.5.9, 'Steam Generator (SG) Tube Surveillance Program,' & 5.6.10.2004-07-30030 July 2004 Response to June 14 and July 6, 2004, NRC Request for Additional Information Re License Amendment Request 03-18, Revision to Technical Specifications 5.5.9, 'Steam Generator (SG) Tube Surveillance Program,' & 5.6.10. DCL-04-095, 60-Day Response to NRC Bulletin 2004-01, Inspection of Alloy 82/182/600 Materials Used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized Water Reactors2004-07-27027 July 2004 60-Day Response to NRC Bulletin 2004-01, Inspection of Alloy 82/182/600 Materials Used in the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized Water Reactors DCL-04-066, Response to NRC Request for Additional Information Regarding License Amendment Request 03-12, Revision to Technical Specifications 3.3.1, 'Rts Instrumentation,' and 3.3.2, 'Esfas Instrumentation.'2004-06-0404 June 2004 Response to NRC Request for Additional Information Regarding License Amendment Request 03-12, Revision to Technical Specifications 3.3.1, 'Rts Instrumentation,' and 3.3.2, 'Esfas Instrumentation.' ML0412804352004-04-30030 April 2004 Notice of Change of Address ML0409704212004-03-31031 March 2004 Saybrook Capital, LLC Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for February 1 Through February 29, 2004 ML0409805912004-03-18018 March 2004 Public Policy Advocates Llc'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expense for February 1, 2004 Through February 29, 2004 ML0406204532004-02-23023 February 2004 Declaration of Sandip Sen in Support of Debtor'S Motion for Authority to Establish Cash-collateralized Letter of Credit Program and Facility to Secure Gas Purchases, and to Incur Secured Debt Related Thereto (the Motion)' ML0403706042004-01-29029 January 2004 Declaration of Michael J. Donnelly in Support for Authority to Establish Cash-Collaterized Letter of Program and Facility to Secure Gas Purchases, and to Incur Secured Debt Related Thereto ML0403706012004-01-29029 January 2004 Declaration of Raymond X. Welch in Support of Motion for Authority to Establish Cash-Collateralized Letter of Credit Program and Facility to Secure Gas Purchases, and to Incur Secured Debt Related Thereto ML0400700982003-12-30030 December 2003 Howard, Rice Nemerovski, Canady, Falk & Rabkin Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for November, 2003 ML0400200602003-12-22022 December 2003 Declaration of Grant Guerra in Support of Motion for Order Authorizing the Debtor to Settle Claim No. 13377 Filed by the Presidio Trust ML0333810452003-11-26026 November 2003 Cooley Godward Llp'S Twenty-Ninth Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period October 1, 2003 - October 31, 2003 ML0331800932003-11-0606 November 2003 Proof of Service ML0331701792003-10-31031 October 2003 Declaration of Michael J. Donnelly in Support of Pg&E'S Application for Authority to Incur Plan Implementation Expenses in Connection with Certain Financings DCL-03-133, Full Compliance with Order for Compensatory Measures Related to Fitness-For-Duty Enhancements Applicable to Nuclear Facility Security Force Personnel, Dated 04/29/03 (EA-03-038)2003-10-28028 October 2003 Full Compliance with Order for Compensatory Measures Related to Fitness-For-Duty Enhancements Applicable to Nuclear Facility Security Force Personnel, Dated 04/29/03 (EA-03-038) ML0331800902003-10-23023 October 2003 Declaration of Jennifer A. Becker in Support of City of Oakland and Port of Oakland'S Motion for Relief from Automatic Stay ML0331800862003-10-23023 October 2003 Relief from Stay Cover Sheet ML0328703662003-09-29029 September 2003 Skadden, Arps, Slate, Meagher & Flom Llp'S Cover Sheet Application for Allowance and Payment of Interim Compensation and Reimbursement of Expenses for the Period August 1, 2003 Through August 31, 2003 ML0327312982003-09-24024 September 2003 (Reorganized) California Power Exchange Corporation'S Limited Objection to Motion for Order Authorizing Pacific Gas and Electric Company to Compromise Claims Against El Paso Natural Gas Company Et Alia and to Enter Into Agreements Resolving ML0327314402003-09-23023 September 2003 Fact Witness Disclosure of Satellite Senior Income Fund, Satellite Senior Income Fund II and Deutsche Bank Trust Company Americas to Objection to Confirmation of Plan of Reorganization Under Chapter 11 of the Bankruptcy Code for Pacific Gas ML0327313322003-09-22022 September 2003 Notice of Hearing on Interim Compensation Applications of Professionals and Final Expense Application of Creditors' Committee Members ML0326810702003-09-16016 September 2003 Declaration of Michael J. Donnelly in Support of Debtor'S Notice of Motion and Motion for Order Approving Debtor'S Execution and Performance Under the Amendment to First Amended and Restated Summary of Terms with Respect to Forbearance and ML0325412082003-09-11011 September 2003 Order Re Ex Parte Application of Pacific Gas and Electric Company Authorizing Settlement and Withdrawal of Claim of Laguna Irrigation District ML0325911092003-09-0505 September 2003 Declaration of Joshua Bar-Lev in Support of Debtor'S Motion for Order Authorizing Pacific Gas and Electric Company to Compromise Claims Against El Paso Natural Gas Company Et Alla and to Enter Into Agreements Resolving the Claims ML0325411442003-09-0404 September 2003 Relief from Stay Cover Sheet - Motion & Notice of Motion of Smud for Relief from Automatic Stay in Litigation ML0325213432003-08-29029 August 2003 Declaration of Joseph Sauvage in Support of Motion for Authority to Enter Into Certain Hedging Transactions in Connection with Financing Under Proposed Plan of Reorganization, and to Incur Secured Debt Related Thereto 2024-06-07
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1 JAMES L. LOPES 368(NO.-
JANET A. NEXON (No.-104747). 6 2 0 3 8) 2 JULIE B. LANDAU (No.1 HOWARD, RICE, NEMEROVSKI, CANADY, 3 FALK & RABKIN- .
A Professional Corporation 4 Three Embarcadero Center, 7th Floor San Francisco, California .94111-4065.
5 Telephone: 415/434-1600 Facsimile: , 415/217r5910,.
6 Attorneys for Debtor and Debtor in Possession 7 PACIFIC GAS AND ELECTRIC COMPANY 8
UNITED STATES BANKRUPTCY COURT 9 ... , . NORTHERN DISTRICT OF CALIFORNIA 10 SAN FRANCISCO DIVISION 11 In re Case No. 01-30923 DM 12 Chapter 11 Case PACIFICGAS AND ELECTRIC 13 COMPANY, a California corporation, -
Date: October 2, 2002 0 14 Debtor.' -Time: 9:30 a.m.' -
':"*"" ' -' '"*- ".: '- *:- *"San Place: Street,California:-
Francisco, 235 Pine 22nd Floor
&?PAWUN Sr ancisco, C..: o. ia:.
- 15 Federal I.D . No. 94-0742640 16 OF.MOTION FOR
17 "DECLARATIONOF MICHAEL MEKO IN SUPPORT "AUTHORITYTO INCUR ADDITIONAL "
EXPENSES .
18 MISCELLANEOUS IMPLEMENTATION 19 20 I, Mi"h"i 'elMeko, herebydeclare: ."
("PG&E")
21 1. I have been emplo'yed by Pacific Gas and Electric Company outages and maintenance 22 since 1986. My"responsibilities have included the management of the procurement manager at Diablo 23 at the Diablo Canfiy6ofPower Plant. in 2001, I-be&ime f6r rhanigifig the~development'of:
24 Canyon. Sinice May 2002, 1 have beefi resp6nisible with the -implementation of 25 procuremeit processes forithe New Entities in connection PG&E's proposed Plan of Reorganizatifi (the "Plan"). . '
26 Motion for Authority to 27 "2. This declaration is submnitted in support of PG&E's Expenses (the "Motion"). iDefined terms 28 "IncurAdditional Miscellaiiniieus Implementation DECLARATION OF MICHAEL MEKO
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I used herein shall have the meanings set forth in the Motion. I make this declaration based 2 on personal knowledge, except where otherwise indicated, and if 6alled as a witness, could 3 and would testify competently to the matters set forth herein'. ..
4 3. Procuring goods and services for a large compa-r' such' as PG&E is, a' 5 substantial arid complex task. Although the New Entities "iltriotbe as large as present day 6 PG&E, it is estimated that the New Entities collectively wills'pend'approximately $200 7 million per year on materials (including supplies arid eq6uiprhent) and $300 million per year 8 on services (including consulting services and technical assistance). In order for the New 9 Entities to be prepared to commence business operations by the Effective Date, it is'critical 10 to implement certain procurement processes in advance of the Effective Date. Without an 11 established system in place for the day-to-day management of procurement, the New Entities 12 will not be able to operate efficiently, and would face substantial confusion and delay in the 13 completion of important business tasks. For example, tleý" follw;ing key procufement RKE 14 functions will be needed by, e New Entities: materials planning and forecasting; 15- puichasing; contract negotiation and administration; warehousing; and distribution of 16 equipment and materials.
17 4. The process of creating, testing and implementing new procurement 18 procedures for the New Efntities may take up io six months., Therefore, PG&E believes that 19 the work must begin promptly. Significant portions of this project will be handled by PG&E 20 without the assistance of outside resources, including, for example, the configuration of the 21 new Materials Management System to be utilized by the New Entities. However, PG&E 22- will require the assistance of the following consultants in connection with this project and 23 also anticipates incurring certain printing costs as described below:
24 a.,, Project Management., Russell Harris of Source California Energyý Services 25 will provide project management services for this project, including the preparation of work 26 plans, tracking project status, preparing reports, and otherwise facilitating and managing the 27 lf6ject. PG&E estimates that the cost for these services will be approximately $135,000.
28 Mr. Harris has performed preliminary services on this project beginning in July 2002. In DECLARATION OF MICHAEL MEKO will provide project management
'fdditid~n, Stan Miyamoto of Stan Miyamoto Consulting with the related materials 2 support as well as oversee the coordination of this project approved pursuant to the Motion for 3 distribution center project, which was previously PG&E estimates that the'cost 4 Authority to Incur Miscellaneous Implementation Expenses.,
$25,000.
5 for Mr. Miyamoto's services will be approximately outside consultants will be 6 b. Consultants with Procurement Expertise. Three areas of warehouse managenent, 7 needed to provide expertise and recommendations in the PG&E has not yet selected the 8 paperless procurement and e-commerce technology.
$75,000 for these services, ba.sed on 9 consultants but estimates a total cost of approximately discussions to date with, 10o its past experience with similar consultants 'and preliminary 11 potential consultants.
it will incur approximately 12 c. Printing of Materials. PG&E estimates that and procedures manuals, and other:
SR13 $35,000 for printing of training manuals, policies a* 14 PG&E intends to' materials related to procurement procedures for use by the New Entities.
1FaK confirmation.
.* 15 incur these costs immediately after Plan PG&E's initial scoping of 16 5., The cost estimates set forth above are based on who have been selected to 17 the 'projectrequirements and negotiations with the consultants of the 18 perform the work (or preliminary discussions with the potential consultants). For each contractual provisions in place with 19 consulting firms described above, PG&E's standard hereafter) do not guarantee future 20 these firms (or to be included in contracts to be executed will also maintain the right to terminate 21 work or any minimum amount of revenue. PG&E PG&E is liable only for work perfoi-med 22 the work at any time without cause, in which case incurred by the consultant in terminating any 23 to the date of termination plus costs reasonably 24 work in progress.
the United States that the 25 I declare under penalty of perjury of the laws of San Francisco,
, 26 foregoing is true and correct, and that this declaration was executed at 27 California on September 11, 2002.
28 DECLARATION OF MICHAEL MEKO
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