ML022610315

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Declaration of Michael Meko in Support of Motion for Authority to Incur Additional Miscellaneous Implementation Expenses
ML022610315
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 09/11/2002
From: Meko M
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: ML022610315 (4)


Text

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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