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NUCOR Steel-Hertford's Petition to Intervene

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NUCOR Steel-Hertford's Petition to Intervene Velson Mullins NelsonMullin sRile y& Scarborough LLP Attorneys and Counselors at Law Joseph W. Bason 4140 Parklake Avenue / GlenLake One / Second Floor / Raleigh. North Carolina 27612 Tel: 919.877.3807 Tel: 919.877.3800 Fax: 919.877.3799 Fax: 919.877.3140 www.nelsonmullins.co m [email protected] April 28,201 0 VIA HAND DELIVERY Ms. Renne Vance APR282Dtt North Carolina Utilities Commission ' ClericsOftc * 430 N. Salisbury Street 5th Floor- Clerks Office Raleigh,N C 27699-4325 Re: Inth e Matter of Application of Virginia Electric and Power Company, d/b/a Dominion North Carolina Power, for Authority to Transfer Functional Control of Transmission Assets to PJM Interconnection, LLC (NCUC, Docket No. E-22, Sub 418) Our FileNo . 19128/01513 Dear Ms. Vance: r^ Enclosed for filing on behalf of Nucor Steel-Hertford ("Nucor") are an original and thirty (30) vUt/lCJ copies ofNucor' s Petition to Intervene relating to the above-referenced matter. 96 n/Tllflffi ^•^so enc^ose^ IS an additional copy of thedocumen t to bestampe d as "filed" and returned to me ' . ," viam y courier. ( V11lO J Thank you for your assistance in this,matter . With best regards, Ia m \)j0^-^ ' Very truly yours, h W. Eason 36rtC5> JWE:nwilmot <c>O^JPp^nc*0Sures 7^ \rv\ cc: A^ parties of record (w/enc.) /ADA -PlAUptlanta • ^s*011 *Charlesto n • Charlotte • Columbia • Greenville • Myrtle Beach • Raleigh • Washington, DC • Winston-Salem •aaiito STATE OF NORTH CAROLINA UTILITIES COMMISSION RALEIGH APR282M DOCKET NO. E-22,Su b 418 CteriteOffic e BEFORE THE NORTH CAROLINA UTILITIES COMMISSION ^UfiBiesCommission In the Matter of ) Application of Virginia Electric and ) NUCOR STEEL-HERTFORD'S Power Company, d/b/a Dominion North ) PETITION TO INTERVENE Carolina Power, for Authority to Transfer ) Functional Control ofTransmissio n ) Assets to PJM Interconnection, LLC ) Pursuant to Rules Rl-17 of the Rules of Practice and Procedure of the North Carolina Utilities Commission, Nucor Steel-Hertford, a division of Nucor Corporation ("Nucor"), hereby moves to intervene in the above-captioned proceeding. In support of its Petition to Intervene, Nucor states: 1. Nucor is a corporation organized pursuant to the laws of the State of Delaware with its corporate headquarters located at 2100 Rexford Road, Charlotte, North Carolina 28211. 2. Nucor owns and operates a steel recycling facility located in Hertford County, North Carolina, which produces steel plate. Virginia Electric and Power Company does business in North Carolina as Dominion North Carolina Power (hereinafter "NCP"). Nucor is a customer of NCP and takes service pursuant to a special contract for electric service, as amended, subject to thejurisdictio n ofth e North Carolina Utilities Commission. 3. As a current customer of NCP, Nucor has an interest that is directly affected by theoutcom e of this proceeding, and, in accordance with the Commission's Rule Rl-5,ha s a right to intervene inthis proceeding. 4. Nucors interest is not adequately represented by any other party and Nucor should not be consolidated with anypart y or group of parties. 5. All correspondence related to this proceeding should be addressed to: Joseph W. Eason Christopher J. Blake Nelson, Mullins,Rile y & Scarborough, LLP 4140 ParkLake Avenue, Suite 200 Post Office Box 30519 Raleigh, NC 27622-0519 Telephone: (919)877-3807 Facsimile: (919)877-3140 [email protected] [email protected] And to: Damon E.Xenopoulos, * Esq. Shaun C. Mohler, Esq. BRICKFIELD, BURCHETTE, RITTS, & STONE, P.C. 1025Thoma s Jefferson St., N.W. 8th Floor, West Tower Washington, D.C. 20007 Telephone: (202) 342-0800 Facsimile: (202) 342-0807 [email protected] [email protected] *Of Counsel WHEREFORE, Nucor respectfully requests that the commission allow it to intervene in this proceeding, and become a party thereto for all purposes. Respectfully submitted, this £o day of April,2010 . JostSph W. Ea&n GnristopnerJ . Blake Nbtatfi, Mullins, Riley & Scarborough, LLP 4140 ParkLake Avenue, Suite 200 Post Office Box 30519 Raleigh, NC 27622-0519 [email protected] [email protected] Of Counsel: Damon E.Xenopoulos * Brickfield, Burchette, Ritts &Stone , P.C. 1025 Thomas Jefferson St.,N.W . 8th Floor, West Tower Washington, D.C. 20007 [email protected] ATTORNEYS FOR NUCOR STEEL-HERTFORD VERIFICATION Joseph W. Eason, first being duly sworn, deposes and says that he is the attorney for Nucor; that he has read the foregoing Petition to Intervene and that the same is true of his personal knowledge,excep t ast oan ymatter san d thingstherei n stated oninformatio n andbelief , and as tothose ,h ebelieve s them to betrue ;an d that hei s authorized to sign this verification on behalfo fNucor . This ^J/*i da. yo fApril ,2010 . NORTHCAROLIN A WAKECOUNT Y Sworntoan d subscribed beforem e This$£ _ dayo f QUOAUJL 2010. vNotar y MblicO Print N^JaryPubli cNam e MyCommissio n Expires: 730/^01 CERTIFICATE OF SERVICE The undersigned attorney for Nucor- Hertford hereby certifies that he served the foregoing Petition to Intervene upon thepartie s of record via First Class Mail inthis proceeding as follows: Leonard G. Green Robert W. Kaylor, Esq. N.C. Department of Justice Law Office of Robert W. Kaylor, Esq. Post Office Box 629 3700 Glenwood Avenue, Suite 330 Raleigh, NC 27602-0629 Raleigh, NC 27612 Antoinette R. Wike Ralph (Bo) McDonald Public Staff'- N.C. Utilities Commission Bailey & Dixon, L.L.P 4326 Mail Service Center P.O. Box 1351 Raleigh, North Carolina 27699-4326 Raleigh,N C 27602-1351 Sharon Miller Robert Page Carolina Utility Customer Association, Inc. Crisp, PageCurri n Suite 210,Trawic k -Professiona l Center 4010 Barrett Drive, Suite 205 1708Trawic k Road Raleigh, N.C. 27609-6622 Raleigh, NC 27604 Karen L. Bell Lara Simmons Nichols Dominion Resources Services, Inc. Duke Energy Carolinas P.O. Box 26532 P.O.Boxl006/EC03T Richmond, VA 23261 Charlotte, NC 28201-1006 Pamela Johnson Walker Edward Flippen Dominion NC Power McGuire Woods LLP P.O. Box 26532 One James Center Richmond, VA 23261 901 East Gary Street Richmond, VA 23219-4030 Mr. Rick Feathers Kenneth Raber North Carolina Electric Membership N.C. Eastern Municipal Power Agency Corporation 1427 Meadowwood Boulevard Post Office Box 27306 Raleigh,N C 27604 Raleigh, NC 27611-7306 Craig Glazer Phillip T. Golden PJM Interconnection LLC PJM Interconnection LLC Suite 600 Valley ForgeCorporat e Center 1200G Street NW 955 Jefferson Avenue Washington, DC 20005 Norristown, PA 19403-2497 Michael S. Colo Mr. Len S. Anthony Poyner & Spruill LLP Deputy General Counsel P.O. Box 353 Progress Energy Carolinas Rocky Mount, NC 27802-0353 P.O.Box 1551 PEB 17A4 Raleigh, NC 27602-1551 Richard M. Price M.Gra y Styers, Jr. 11181 Highway 70 West Styers and Kemerait, PLLC P.O. Box 911 Suite 101 Clayton, NC 27520 1101 Haynes Street Raleigh, NC*2760 4 Jeffrey M.Trepe l Michael Regulinski Duke Energy Corporation Dominion, NC Power P.O.Box 1244 120Tredega r Street Charlotte, NC 28202-1904 Richmond, VA 23219 This the day of April, 2010. .
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