PG&E - premeeting discussion with opposing counsel

I just spent about 40 minutes on the phone with my counterpart discussing the
upcoming meeting. The call was cordial. A couple of items that came up
worth passing on are as follows:

There is some expectation in PG&E to decon the compressors. They may not
wish to do so right now but maybe soon. There is also discussion of these
being out of service for up to a couple of months. I passed along the idea
that it is probably best to simply monitor the situation and the PCB matters
may well take care of themselves through routine maintenance activities and
continued operation. No official decon processes exist as far as were are
aware. There are no restrictions on their continued use exist at that
location. PG&E may be considering employee exposure or continued source of
contamination as issues why they want to decon. We should expect to this to
come up during the meeting. I do not think that this type of decon would
necessarily be in line with the standard for reimbursement under our
operating agreement - which is "reasonable action, measured in accordance
with commonly accepted standards of care and practice in the natural gas
pipeline industry in California." I'm not aware of SoCal engaging in any
such action even though their system was highly impacted by PCBs. I did not
bring this standard up but we should be aware of it and recommend monitoring
before any decisions are made. My counterpart did acknowledge that even when
the Long Term facilities eliminated the delivery problem, that we may well
have continued issues with respect to the PCBs in the station and the 15
miles of pipe downstream for some lengthy period of time. PG&E did not
appear to be contemplating any pigging or decon of this section of the system.

PG&E may be looking for some more comfort on the question of "source
control". We have said that this situation is relatively unique to the
Topock Lateral but we have had some minor hits elsewhere recently. We should
be in a position to explain why the remainder of the system is not a problem
and even if it should be why the Long term facilities should be able to
handle any concerns.