FPL Group, Inc. & Subsidiaries - Page 34

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            contract identified the specifications and amount of nuclear fuel                           
            contracts.  Appendix A contains diagrams and design parameters.                             
                  We conclude that the specifications for the nuclear fuel                              
            assemblies contained in appendix A to the Exxon contract satisfy                            
            the “readily identifiable” requirement.  The appendix contains                              
            the number of fuel assemblies in the core, diagrams depicting a                             
            fuel assembly and fuel rod array, the number of fuel rods per                               
            assembly, the distance between assemblies, etc.  Mr. Villard                                
            testified that “All fuel fabrication contracts have detailed                                
            specifications on not only the quantity, but also on the                                    
            material, the size, manufacturing tolerances that needs to be                               
            supplied under that fuel fabrication contract.”  TRA section                                
            204(a)(3) and the conference report state that “related                                     
            documents” must be specific, although not exact; on the basis of                            
            Mr. Villard’s testimony and the contents of appendix A, we find                             
            that the spent fuel assembly property relating to the Exxon                                 
            contract is readily identifiable.                                                           
                  Petitioner also asserts that the A.B. Chance contract                                 
            readily identifies the specifications and amount of the LMS                                 
            property.  The “Base Bid Schedule,” dated September 9, 1985, an                             
            attachment to the A.B. Chance contract, lists the following                                 
            components of the LMS:  (1) Master station and USW hardware, (2)                            
            master station and USW software, (3) field equipment (excluding                             
            transponders), (4) engineering and services, (5) interim master                             





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