ML20236Q125

Forwards New England Power Co'S Motion to Intervene Separately in Seabrook Nuclear Decommissioning Fund

ML20236Q125
Person / Time
Site:	Seabrook
Issue date:	07/13/1998
From:	Gavilondo C NEW ENGLAND POWER CO.
To:	Patch D NEW HAMPSHIRE, STATE OF
References
NUDOCS 9807200016
Download: ML20236Q125 (7)

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A New England Power Service carlos A. Gasilondo A NEES comparty Anorney

,,e July 13,1998 y 't t )

Douglas L. Patch, Chairman Nuclear Decommissioning Financing Committee N.H. Public Utilities Commission 8 Old Suncook Road Concord, NH 03301 Re: Docket No. NDFC 98-01-New England Power Company's Motion to Intervene Separately

Dear Chairman Patch:

Enclosed please find New England Power Company's Motion to Intervene Separately in the above-captioned proceeding. Copies of this filing have been served on all parties on the attached service list.

Thank you for your attention to this matter.

Sincerely, Carlos A. Gavilondo Enclosures cc: Service List Docket No. NDFC 98-01

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l A-3 iLi( :) 1 n 9807200016 980713 PDR ADOCK 05000443 P PDR ,

2?> Research Drise Westborough, MA 01i3824WJ Telephone: MNkO2875 Fax: NNm2463 gasiloWneesnet.com

STATE OF NEW HAMPSHIRE BEFORE THE NUCLEAR DECOMMISSIONING FINANCING COMMITTEE

)

In re Seabrook Nuclear Decommissioning )

Fund--1998 Update )

) Docket No. NDFC 98-1

)

New England Power Company's Motion to Intervene Separately New England Power Company ("NEP" or " Company") moves pursuant to RSA 541-A:32 for an order granting its separate intervention in the above-captioned proceeding. In support of this motion, NEP states as follows:

1.

NEP is a wholly-owned subsidiary of New England Electric System ("NEES"),

and has its principal place of business at 25 Research Drive, Westborough, Massachuutts,01582.

NEP is primarily engaged in the business of electric power generation and transmission.

2. NEP has a 9.95766 percent ownership interest in the Seabrook Nuclear Unit One Generating Station (Seabrook No.1), and is a signatory to the Agreement for Joint Ownership, Construction and Operation of New Hampshire Nuclear Units dated May 1,1973, as amended,

(" Joint Ownership Agreement"), governing the relationship among thejoint owners of Seabrook No.1. Although NEP is among thejoint owners of Seabrook No.1, the plant is operated by North Atlantic Energy Service Corporation (" North Atlantic"), a subsidiary ofNortheast Utilities.

F 3.

, By Order dated March 6,1998, the Nuclear Decommissioning Financing Committee ("NDFC") established a procedural schedule in this matter. Pursuant to that schedule, North Atlantic submitted written testimony on April 14,1998 relating to the decommissioning of Seabrook No.1.

4. As one of thejoint owners of Seabrook No.1, NEP has a direct interest in the '

decommissioning of Seabrook No.1, which is the subject matter of this proceeding. As a result, i

NEP's rights, duties, privileges, immunities or other interests may be affected by this proceeding.

5. The written testimony submitted by North Atlantic does not reflect the position of i

NEP with respect to some aspects of the decommissioning of Seabrook No.1. As one example,

the positions set forth in the North Atlantic testimony with respect to the methodology for i

decommissioning funding does not reflect NEP's views on this issue.

6. NEP's viewpoints with respect to the issues in this docket can only be adequately addressed by permitting separate intervention and an opportunity to submit separate testimony.

NEP's separate participation in this docket will provide for a more ;omplete record upon which to consider the issues, and would serve the interests ofjustice.

7. Since the hearing in this matter is not scheduled to begin until September 28,1998, permitting NEP to intervene and file separate testimony on July 20,1998 will not impair the orderly and prompt conduct of these proceedings.

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, 8. Accordingly, NEP respectfully requests that the NDFC allow NEP to intervene l l and confer upon the Company all rights associated with full intervention, including the right to submit testimony and present witnesses.

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Respectfully submitted, NEW ENGLAND POWER COMPANY By its attorney,

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- 4 Carlos A.Mlondo ' W -

25 Research Drive '

Westborough, MA 01582 (508)389-2575 July 13,1998 CERTIFICATE OF SERVICE I certify that copies of the foregoing document have been served this date by first class mail on all persons named on the attached service list.

Carlos A. Gavilondo

NDFC 98-01 SERVICE LIST  ;

Douglas L. Patch, Chairman NH Public Utilities Commission i 8 Old Suncook Road Concord, NH 03301 John Stephen, Asst. Commissioner Dept. Of Safety  !

10 Hazen Drive .

Concord, NH 03301  !

Georgie A. Thomas State Treasurer .

State House Annex, Room 121 Concord, NH 03301 Winslow Melvin / 1 88 Pleasant Street

. Concord, NH 03301 General Counsel NH Public Utilities Commission 8 Old Suncook Road Concord,NH 03301 Robert A. Backus, Esq.

Backus Meyer Solomon Rood PO Box 516 Manchester, NH 03105-0516 Seabrook Selectmen's Office Seabrook Town Offices Seabrook, NH 03874  !

Director of Nuclear Reactor Regulation Nuclear Regulatory Commission Washington, DC 20555 i Joshua L. Gordon, Esq.

j. 26 South Main Street, #175 Concord, NH 03301 Rep. Channing Brown Appropriations Committee Room 100 State House Concord, NH 03301

.. J:mes P. Fredym2, Asst. Commission:r  !

Health & Human Services 6 Hazen Drive

- Concord, NH 03301 Sen. Jack Barnes, Jr.

Room 302 State House I Concord, NH 03301 Wynn E. Arnold, Esq.

Assistant Attorney General Dept. Of Justice 33 Capitol Street Concord, NH 03301 Thomas B. Getz Executive Director / ,

NH Public Utilities Commission 8 Old Suncook Road Concord, NH 03301 l Edward A. Haffer SPhB+G

, 1000 Elm Street Manchester, NH 03105-3701 Mary K. Metcalf i

Seacoast Antipol League '

PO Box 1136 Portsmouth, NH 03802-1136 l Robert Cushing, Jr.

L 395 Winnacunnet Road j Hampton, NH 03842

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John Crosier NHBIA 122 N. Main Street Concord, NH 03301 l Lt. Col. Willard F. Boyle 463 New Zealand Road Seabrook, NH 03874 Michael Ablowich j Deputy State Treasurer Room 121 State House Annex j Concord, NH 03301 l l

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. Stsv:n V. Camerino, Esq.

McLane, Graf, Raulerson & Middleton 900 Elm Street PO Box 326 Manchester, NH 03105-0326 B. Dickinson Henry, Jr.

President Bellwether Solutions LLC 1 South Street Concord, NH 03301 Deborah Schachter, Director Governor's Office of Energy

& Community Services 57 Regional Drive, Suite 3 Concord, NH 03301-8519

./

Michael W. Holmes, Esq.

Office of Consumer Advocate 117 Manchester Street Concord, NH 03301-5141 Kenneth J. Aupperle Vice President Team Associates, Inc.  ;

5935 Buford Way, Suite 200  ;

Norcross, GA 30071 Rep. Jeb E. Bradley House Science Technology '

& Energy Committee Legislative Office Building, Room 304 Concord, NH 03301 Tracy Guyette New Hampshire Public Utilities Commission 8 Old Suncook Road Concord, NH 03301 Alexander Kalinski, Esq.

PO Box 1136 Manchester, NH 03105-1136 Kendall F. Wiggin State Librarian '

NH State Library 20 Park Street Concord, NH 033016303

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