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Nucor Steel-Hertford's Petition to Intervene

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Nucor Steel-Hertford's Petition to Intervene FIL£D Nelson SEP2 8m Mullins NelsonMullin sRile y& Scarborough LLP Attorneys and Counselors at Law Joseph W. Eason 4140 Parklake Avenue / GlcnLake One / Second Floor / Raleigh, North Carolina 27612 Tel: 919.877.3807 Tel: 919.877.3800 Fax: 919.877.3799 Fax: 919.877.3140 www.ndsonmullins.co m [email protected] September 28, 2010 VIA HAND DELIVERY t-aa-^MfcH Ms. Renne Vance North Carolina Utilities Commission 430 N. Salisbury Street 5th Floor- Clerks Office Raleigh, NC 27699-4325 Re: In the Matter of Application of Virginia Electric and Power Company, d/b/a Dominion North Carolina Power, for Authority to Adjust its Electric Rates and Charges Pursuant toN.C.G.S . §62-133.9 and NCUC Rule R8-69 Our FileNo . 19128.01514 Dear Ms. Vance: Enclosed for filing on behalf ofNuco r Steel-Hertford ("Nucor") are an original and thirty (30) copies of a Petition to Intervene relating to the above-referenced matter. Also enclosed is an additional copy of the document to be stamped as "filed" and returned to me via my courier. Thank you for your assistance inthis matter. With best regards, Ia m Very truly yours, 6^ <r# Joseph W. Eason JWE/njw fif ^ Enclosures cc: All parties of record (w/enc, via electronic mail and U.S.Mail ) Atlanta • Boston • Charleston • Charlotte • Columbia • Greenville • Myrtle Beach • Raleigh • Washington. DC • Winston-Salem STATE OFNORT H CAROLINA UTILITIES COMMISSION FILED RALEIGH SEP 2 8 DOCKET NO.E-22 ,Su b46 4 vc uSSElgJj. ussion BEFORE THE NORTH CAROLINA UTILITIES COMMISSION Inth eMatte ro f ) Application ofVirgini a Electrican d ) NUCOR STEEL-HERTFORD' S PowerCompany ,d/b/ a DominionNort h ) PETITION TO INTERVENE Carolina Power,fo rAuthorit yt oAdjus t ) itsElectri cRate san dCharge s Pursuantt o ) N.C.G.S.§ 62-133. 9an dNCU C ) RuleR8-6 9 Pursuant to Rules R8-69 of the Rules of Practice and Procedure of the North Carolina Utilities Commission, Nucor Steel-Hertford, a division ofNuco r Corporation ("Nucor"), hereby moves to intervene in the above-captioned proceeding. In support of its Petition to Intervene, Nucorstates : 1. Nucor is a corporation organized pursuant to the laws of the State of Delaware with itscorporat eheadquarter s located at210 0Rexfor d Road,Charlotte ,Nort h Carolina28211 . 2. Nucor owns and operates a steel recycling facility located in Hertford County, NorthCarolina ,whic hproduce sstee l plate. Virginia Electrican d PowerCompan ydoe sbusines s inNort h Carolina asDominio n North Carolina Power(hereinafte r "NCP"). Nucori s acustome r ofNC P and takes servicepursuan t to aspecia l contract for electric service, asamended , subject toth ejurisdictio n ofth eNort h CarolinaUtilitie s Commission. 3. As a current customer of NCP, Nucor has an interest that is directly affected by theoutcom eo fthi sproceeding , and,i naccordanc ewit hth eCommission' s RuleRl-5 ,ha sa righ t tointerven ei nthi sproceeding . 4. Nucors interest is not adequately represented by any other party and Nucor should not be consolidated with any party or group of parties. 5. All correspondence related to this proceeding should be addressed to: Joseph W. Eason Christopher J. Blake Nelson, Mullins, Riley & Scarborough, LLP 4140 ParkLake Avenue, Suite 200 Post Office Box 30519 Raleigh, NC 27622-0519 Telephone: (919)877-3807 Facsimile: (919)877-3140 joe.eason@ne lsonmu l1 ins .co m [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 thisproceeding , and become a party thereto for all purposes. Respectfully submitted, this Z** day of September, 2010. kSSlJr Jogepn W. Eljson 'Christppher J. Blake ^Nelgem,Mullins ,Rile y & Scarborough, LLP 4140 ParkLake Avenue, Suite 200 Post Office Box 30519 Raleigh,N C 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 swom, deposes and says that he is the attorney for Nucor Steel-Hertford; that he has read the foregoing Petition to Intervene and that the same is trueo fhi spersona l knowledge,excep t ast oan ymatter san dthing s therein stated on information and belief, and as to those, he believes them to be true; and that he is authorized to sign this verification onbehal fo fNucor . Thiis €^0 Hdan yo fSeptember ,2010 . NORTHCAROLIN A WAKECOUNT Y Swomto^n d subscribed before me ^ This ft* dayof ^yVc^Wy.2016. jfe&i NotaryCPliblfi Print^otary PublicNam e MyCommissio nExpires ires: ! ifeojao" CERTIFICATE OF SERVICE Theundersigne d attorney for Nucor- Hertford hereby certifies that heserve d the foregoing Petition to Intervene upon the parties of record inthis proceeding by electronic mail and depositing copies in the United States mail, postage prepaid as follows: Horace P. Payne Robert W. Kaylor, Esq. Horace P. Payne Law Office of Robert W. Kaylor, Esq. Dominion Resources Services, Inc. 3700 Glenwood Avenue, Suite 330 120Tredega r Street Raleigh, NC 27612 Richmond, VA 23219 [email protected] [email protected] Antoinette Wike Ms. Antoinette Wike North Carolina Utilities Commission 4326 Mail Service Center Raleigh, NC 27699-4326 Antoinette.W ike@ncmai l.ne t This the 2^da yo f September, 2010. .
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