ML17209B148

Affidavit Re Info Requested by Atty General for Antitrust Review.All Util Resources Exhausted in Preparing Response

ML17209B148
Person / Time
Site:	Saint Lucie
Issue date:	05/13/1981
From:	Danese T FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML17209B147	List: ML17209B146 ML17209B148 ML17209B149 ML17209B150
References
NUDOCS 8106040373
Download: ML17209B148 (2)

Text

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AFFIDAVIT OF TRACY DANESE I pwe~steln Newman Rels Axel!'ad 8g Tp]l Tracy Danese, being first duly sworn, deposes and says:

1. My name is Tracy Danese. I am Vice President for Governmental Affairs for Florida Power & Light Company .("FPL")-

I have been employed at FPL since 1974, and I was elected an officer of the company on May 15, 1975. Prior to that I was Director of Public Affairs for FPL.

2. In 1975, as part of the overall responsibilitv which I then exercised over FPL's legal and governmental affairs, 1 assumed responsibility for preparing a document entitled "Information Requested by the Attorney General for Antitrust Review Facility License Application" (" Information" ). This document was prepared pursuant to 10 CFR Part 50, Appendix L, and was submitted to the Nuclear Regulatory Commission in Docket No. P-636A on July 14, 1975.

3. The information was submitted in anticipation of FPL's filing for a license to construct an undetermined number of nuclear generating units commonly -referred to as the South Dade project. Plans for the construction of the South Dade project have since been abandoned.

4. Michael Mills, an engineer in the employ of FPL, worked under my supervision to prepare the Information.

5. We conferred on many occasions while the Information was being prepared. I discussed with Mr. Mills the procedures which he followed in assembling the material for the

Information, furnished him with information about events of which I had direct personal knowledge, and thoroughly reviewed with him drafts of the Information at the time that it was being completed.

6. I have read the accompanying affidavit of Michael Mills dated May 7, 1981, and the statements contained there-in accord with my own recollections of those events.

7. I acted in 1975 with the understanding that all documents that contained information responsive to Questions 13 and 18 in 10 CFR Part 50, Appendix L, would be located in FPL's central file. I believed that by reviewing the docu-ments in the central file and by interviewing the people within FPL who were interviewed at the time that Mr. Mills had exhausted all the resources within FPL that could have reasonably been expected to possess information responsive to Questions 13 and 18.

8. My intent at all times was to respond fully and candidly to the questions in Appendix L. I instructed Mr.

Mills to perform his assignment, with this objective.

'I Tracy D nese Subscribed and sworn to before me this gg T~i < day of May, 1981.

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