ML20082N370

Forwards Data Requests of Ofc of Consumer Advocate for New Hampshire Yankee

ML20082N370
Person / Time
Site:	Seabrook
Issue date:	08/21/1991
From:	Holmes M NEW HAMPSHIRE, STATE OF
To:	Haffer E SHEEHAN, PHINNEY, BASS & GREEN, P.A.
References
NUDOCS 9109090131
Download: ML20082N370 (2)

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OFFICE OF Tile CONSUMElt ADVOCATE 8 OLD SUNCOOK 1:OAD CONCO!!D, NEW li AM P81til:M tu: kit alm mu r:: ti::

21 August 1991 Edward A. Haffer, Esq.

Sheehan Phinney Bass & Green, PA 1000 Elm Street P.O. Box 3701 Manchester, NH 03105-3701 RE: NDFC 91-1

Dear Mr. Haffer:

Attached you will find data requests of the Office of the Consumer Advocate in the above styled docket.

Thank you for your attention to this matter.

Sincerely, 4(h'{kYx(hbXhY$l%'

Michael W. Holmes, Esq.

Enclosures CC: Service List T

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lilip', .4 STATE OF NEW HAMPSHIRE PUBLIC UTILITIES COMMISSION Office of the Consumer Advocate Data Requests For New Hampshire Yankee:

1. Has there been a " test case" of a single asset entity such as New Hampshire Yankee going bankrupt upon cessation of operations? Who would bear the burden of funding decommissioning in that instance?

2. In New Hampshire Yankee's opinicn, would the corporate parent (s) of NHY hold the " deep pocket" for completion of decommissioning activities if the Decommissioning Trust Fund was not sufficient?

3. How much does NHY charge itself for low level waste storage?

4. What is New Hampshire Yankee's forecast of capital additions for each year of Seabrook's life.

For Mr. Thomas Lacuardia:

1. Has Mr. LaGuardia's contingency factor ever not been adopted by a regulatory authority in which he has testified? If so please specify the jurisdiction and provide the Order if possible.

For Attorney Dunn:

1. Please provide the I.R.S. definition of " level funding".

2. For every Joint Owner of Seabrook Station provide the last date on which the cost of Seabrook will be in-luded in rate base for ratemaking purposes.

3. How does the fact that Decommission funds are turned over to the State Treasurer impact the tax liability? Please explain.