ML19305E130
| ML19305E130 | |
| Person / Time | |
|---|---|
| Site: | South Texas, Comanche Peak  |
| Issue date: | 04/10/1980 |
| From: | Borchelt M CAROLINA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML19305E128 | List: |
| References | |
| NUDOCS 8004230007 | |
| Download: ML19305E130 (10) | |
Text
.,
State of Texas
)
ss
)
County of Nueces
)
AFFIDAVIT I, Merle L. Borchelt, having been duly sworn, do depose and say that:
1.
I am Executive Vice-President of Central Power and Light Company, Corpus Christi, Texas, a wholly owned subsidiary of Central and South West Corporation ("CSW").
2.
Shortly before March 25, 1980, Mr. Durwood Chalker, Chairman and Chief Executive Officer of CSW, requested that I contact Mr. Robert E. Roundtree, General Manager of the Public Utilities Board of Brownsville, Texas ("Brownsville") to advise Mr. Roundtree of the current status of the discussions among CSW, Houston Lighting & Power Company ("HLP") and Texas Utilities l
Company ("TU") concerning the possible interconnection of the Texas Interconnected System (" TIS") with the Southwest Power Pool ("SWPP") by two direct current (de) transmission lines.
3.
Accordingly on March 25, 1980 I, along with Mr. Buddy Teague and Mr. Tyler Russell of CPL, met with Mr. Roundtree and Mr. Larry Gawlik, Brownsville's Manager of Engineering in Brownsville.
I advised Mr. Roundtree and Mr. Gawlik that CSW, HLP and TU had reached a preliminary agreement on the location and capacity of two de interconnections between TIS and the SWPP, and that the capacity indiciated for these two interconnections was tentative and could be the subject of additional studies.
I further P
l 8 0 0 4 2 3 0Cb 7
~
. r explained that one of the purposes of my visit was to obtain Brownsville's preliminary reaction to and comments if any on the de interconnection.
4.
Mr. Roundtree responded that Brownsville might be i
interested in paying for some capacity in a de interconnection and requested that Brownsville be permitted to participate in any subsequent studies addressing the de interconnection.
I replied that I thoudit that this was perfectly appropriate and that at least as far as CPL was concerned, Brownsville would be welcome to participate in these studies.
I had no reason to believe that any other party would have any objection to Brownsville's participation and no objection has been expressed to me.
I 5.
The meeting concluded on very amicable terms. On April 7,1980, I received a copy of the Opposition by Brownsville to Joint Motion for Extension of Time and Request for Prehearing Conference,(" Opposition").
I was very surprised to read the allegation in the Opposition that Brownsville "does not believe that the arrangements as proposed for the de interconnection will be in the larger public interest
" since at no time during m/ meeting with Mr. Roundtree and Mr. Gawlik did either of them state that in their view the de interconnection would not be in the " larger public interest" or otherwise express any objection to the de interconnection.
In fact, I had left that meeting with the impression that Brownsville would be willing to work with us on the dc interconnection.
6.
I would like to correct one statement attributed to me in Mr. Roundtree's March 27, 1980 Affidavit, Attachment B to the Opposition.
I did not, contrary to the allegations on page 2 of the Affidavit, state at the March 27, 1980 meeting, or at any other time, that all federal regulatory staffs had l
l been contacted and that the " reactions expressed were favorable."
I did state that the appropriate staffs had been or would be contacted, and that I was unaware of any objections to the de i
interconnection by any of the staffs which had been contacted.
M'5 A~ =
Merle L. Borchelt '
l Subscribed and Suorn to before me this it?/ day of /7/10, 1 9 4.
<i j [I
_cu<, IMELDA V. PEREZ Notary Public
/
My Commission expires
/ V/-#/
l l
l l
l P
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:
S S
HOUSTON LIGHTING & POWER S
NRC DOCKET NOS. 50-498A COMPANY, THE CITY OF SAN S
50-499A ANTONIO, THE CITY OF AUSTIN,5 and CENTRAL POWER AND LIGHT S COMPANY S
(South Texas Project, S
Unit Nos. 1 and 2)
S S
d TEXAS UTILITIES GENERATING S
NRC DOCKET NOS. 50-445A COMPANY, et al.
S 50-446A (Comanche Peak Steam S
Electric Station, S
Unit Nos. 1 and 2)
S CERTIFICATE OF SERVICE I,
David M. Stahl, hereby certify that copies of the foregoing Response of Central and South West Corporation to Opposition by Brownsville to Joint Motion for Extension of Time and Affidavit of Merle L. Borchelt were served upon the following listed persons either by hand delivery or by deposit in the United States mail, first class postage prepaid on this lith day of April, 1980.
/
^
David fi. Stahl
Afg).ING LIST Marshall E. Miller, Esq.
Roy P.
Lessy, Jr., Esq.
U.S.
Nuclear Regulatory Commission Michael B.
Blume, Esq.
Washington, D.C.
20555 U.S. Nuclear Regulatory Comm.
Washington, D.C.
20555 Michael L.
Glaser, Esq.
1150 17th Street, N. W.
William C. Price Washington, D. C.
20036 Chairman and Chief Executive Officer I
Sheldon J. Wolfe, Esq.
Central Power & Light Co.
U.S. Nuclear Regulatory Commission P.
O. Box 2121 Washington, D.C.
20555 Corpus Christi, Texas 78403 t
Atomic Safety and Licensing G. K.
Spruce, Gen. Manager Appeal Board Panel City Public Service Board U.S. Nuclear Regulatory Commission P. O. Box 1771 Washington, D. C.
20555 San Antonio, Texas 78203 Chase R. Stephens (20)
Mr. Perry G. Brittain Docketing and Service Section President U.S. Nuclear Regulatory Commission Texas Utilities Generating Co.
Washington, D. C.
20555 2001 Bryan Tower Dallas, Texas 75201 Jerome D.
Saltzman Chief, Antitrust and Indemnity Group R.
L. Hancock, Director U.S. Nuclear Regulatory Commission City of Austin Electric Utility Washington, D.C.
20555 P.
O. Box 1088 Austin, Texas 78767 J.
Irion Worsham, Esq.
Merlyn D.
Sampels, Esq.
G. W.
Oprea, Jr.
i Spencer C.
Relyea, Esq.
Executive Vice President Worsham, Forsythe & Sampels Houston Lighting & Power Co.
2001 Bryan Tower, Suite 2500 P.
O.
Box 1700 Dallas, Texas 75201 Houston, Texas 77001 Jon C. Wood, Esq.
Michael I. Miller, Esq.
W.
Roger Wilson, Esq.
James A. Carney, Esq.
Matthews) Nowlin, Macfarlane & Barrett Isham, Lincoln & Beale 1500 Alamo National Building One First National Plaza San Antonio, Texas 78205 Chicago, Illinois 60603 Morgan Hunter, Esq.
J. A. Bouknight, Esq.
Bill D.
St. Clair, Esq.
Bill Franklin, Esq.
McGinnin, Lockridge & Kilgore Lowenstein, Newman, Reis, Axelrad Fifth Floor, Texas State
& Toll Bank Building 1025 Connecticut Avenue, N. W.
900 Congress Avenue i
Washington,.D. C.
20036 Austin, Texas 78701 R. Gordon Gooch, Esq.
Don R.
Butler, Esq.
Baker & Botts 1225 Southwest Tower 1701 Pennsylvania Avenue, N. W.
Austin, Texas 78701 Washington, D.
C.
20006
i.
Jerry L. Harris, Esq.
Richard C. Balough, Esq.
W.S.
Robson South Texas Electric City of Austin a
i P. O. Box 1088 Cooperative, Inc.
Austin, Texas 78767 Sam Rayburn Power Plant Complex Post Office 151 Joseph B.
Knotts, Jr., Esq.
Nursery, Texas 77976 l
i l
Nicholas S. Reynolds, Esq.
Debevoise & Liberman Robert C. McDiarmid, Esq.
1200 17th Street, N. W.
Robert A.
Jablon, Esq.
l Washington, D. C.
20036 Marc R.
Poirier Speigel & McDiarmid l
Don H.
Davidson 2600 Virginia Avenue, N.W.
I City Manager Washington, D. C.
20036 l
City of Austin i
P.
O. Box 1088 Kevin B.
Pratt Austin, Texas 78767 Texas Attorney General's Office P.
O. Box 12548 Jay Galt, Esq.
Austin, Texas 78711 Looney, Nichols, Johnson & Hays 219 Couch Drive William H.
Burchette, Esq.
Oklahoma City, Oklahoma 73102 Frederic H.
Ritts, Esq.
Law Offices of Northcutt Ely
[
Knoland J.
Plucknett Watergate Building Executive Director Washington, D.
C.
20037 l
Committee on Power for the Southwest, Inc.
Wheatley & Wolleson i
5541 East Skelly Drive 1112 Watergate Office Bldg.
Tulsa, Oklahoma 74135 2600 Virginia Avenue, N.W.
Washington, D. C.
20037 John W.
Davidson, Esq.
Sawtelle, Goods, Davidson & Tiolo Joseph Rutberg, Esq.
1100 San Antonio Savings Building Antitrust Counsel San Antonio, Texas 78205 Counsel for NRC Staff
(
U.S. NRC Washington, D. C.
20555 f
Douglas F. John, Esq.
Linda L. Aaker, Esq.
I Akin, Gump, Hauer & Feld Asst. Attorney General l
i 1333 New Hampshire Avenue, N. W.
P. O. Box 12548 i
Suite 400 Capitol Station l
Washington, D.
C.
I W. N. Woolsey, Esq.
Robert M..Rader Dyer and Redford Conner, Moore & Corber i
1030 Petroleum Tower 1747 Pennsylvania Ave., N.W.
Corpus Christi, Texas 78474 Washington, D.C.
20006 Donald Clements Melvin G. Berger, Esq.
l_
Gulf States Utilities' Company Ronald Clark, Esq.
l l
P. O. Box 2951 Antitrust Division, Energy Beaumont, Texas 77704 Section e
F Room 8308
.i 414 llth Street, N.W.
Washington, D.C.
20530
J e
Charles G, Thrash, Jr., Esq.
Joseph J.
Saunders, Esq.
l E.
W.
Barnett, Esq.
Chief, Public Counsel &
Theodore F. Weiss, Esq.
Legislative Section J.
Gregory Copeland, Esq.
Antitrust Section Baker & Botts U.S.
Department of Justice 3000 One Shell Plaza P.
O.
Box 14141 Houston, TX 77002 Washington, D.C.
20044 Donald A.
Kaplan, Chief Robert E.
Bathen Robert Fabrikant, Asst. Chief R. W. Beck & Associates Energy Section P.
O. Box 6817 Antitrust Division Orlando, Florida 82853 U.S.
Department of Justice Washington, D.C.
20530 Mr. G.
Holman King West Texas Utilities Company l
Nancy Luque P.
O. Box 841 l
Susan B.
Cyphert Abilene, TX 79604 Ronald H. Clark Frederick H.
Parmenter John Carney, Esq.
Antitrust Division Weil, Gotshal & Manges Energy Section 767 Fifth Avenue i
U.
S.
Department of Justice New York, NY
.0022 Room 8413 414 lith Street, N.W.
Washington, D.C.
20530 P
l l
l
- _,.