ML20078R557

Notice of Appearance of Div of Consumer Counsel in Proceeding to Support Seacoast Anti-Pollution League Motion to Dismiss Unit 2 OL Application

ML20078R557
Person / Time
Site:	Seabrook
Issue date:	11/10/1983
From:	Zitser B CONNECTICUT, STATE OF
To:
References
ISSUANCES-OL, NUDOCS 8311150198
Download: ML20078R557 (4)

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!! UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of:  : Docket Nos. 50-443 OL

50-444 OL PUBLIC SERVICE COMPANY  :

OF NEW HAMPSHIRE, ET AL  :

(Seabrook Station;  :

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Units 1 and 2)  : November 10, 1983 APPEARANCE OF THE CONNECTICUT DIVISION OF CONSUMER COUNSEL F

-IN SUPPORT OF SAPL'S MOTION TO DISMISS i, ,

h The Connecticut Division of Consumer Counsel (DCC), a state I

N P agency which acts as the advocate for Connecticut utility-consumers, respectfully intervenes in this-proceeding in support of the September 26th Motion to Dismiss the Operating License 1:

Application for Seabrook Unit II by the Seacoast Anti-Pollution v

l League (SAPL). The DCC is authorized to intervene in federal t.

I administrative proceedings. See Section 16-2a of the Connecticut l'

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! 8311150198 831110 PDR ADOCK 0"000443 O PDR h

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General Statutes.

! I. Name, Address, Telephone and Representative .

All correspondence in this matter should be  !

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d forwarded to:

. Division of Consumer Counsel c/o Barry S. Zitser, Consumer Counsel One Central Park Plaza, Room 105

.New Britain, Connecticut 06051 (203) 827-2603 i-II. Nature of Interest The United Illuminating Company (UI), a regulated Connecticut electric utility, is the major outside owner of Saabrook Unit No. 2, with a 17.5% ownership interest. The Connecticut Light and Power Company (CL&P), a regulated Connecticut utility, is.the owner of an approximately 4.5%

, ownership interest in Seabrook Unit No. 2. The Connecticut Department of Public Utility Centrol (DPUC), with the urging and support of the DCC, has found that it is in the interests ;

p of Connecticut utility consumers for CL&P. and UI to withdraw l from participation in Seabrook Unit No. 2, or, if they are unable to withdraw, to work towards its cancellation. DPUC Docket No. 83-03-01. Both CL&P and UI have publicly announced that they will comply with the DPUC's directive, h III. Nature of Participation i

The DCC intends to submit written comments and l

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reserves the right to cross-examine witnesses at a duly noticed public hearing. The DCC, however, does not believe a public hearing will.be'necessary since it is likely that Seabrook 2 I Ij will be scrapped in the near future.

H i I IV. Initial Positions .

!; t The DCC_ adopts the positicn of SAPL, as expressed in 4 1

its September 26, 1983 Motion with the following exceptions:

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l. The DCC does not believe that Seabrook 2 is l'

ll 23.4% complete. The DCC's expert in DPUC Docket No. 83-03-01

[ estimated that Seabrook 2 was approximately 7% complete. The 23.4% is a crude and unreliable figure, based on the percentage i of total labor hour completion, and with a presumption of no new.

[ dasign or construction modifications between now and when Serb.Took 2 is completed.

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[ 2. The DCC does not agree with any inference in t-SAPL's Motion that might be interpreted as suggesting that f Seabrook 2 can or will be built. The major owners of Seabrook I

2 do not have the financial capability or regulatory and t

statutory support in order to complete Seabrook 2.

j- Respectfully submitted,

DIVISION OF CONSUMER COUNSEL l f

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! Barry S. Titser y i

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.I- hereby certify that copies of the foregoing Appearance of~.the' Connecticut Division of Consumer Counsel have been mailed i

j this 10th day of. November, 1983 to all parties of record. t 1,

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Barry S. Zitadr n/

. Commissioner of the Supe'rior Court L

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