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Nuclear fuel must be replaced because it wastes over time
and from use. During the years at issue, FPL’s nuclear reactor
units used an 18-month reloading cycle; it replaced one-third of
the fuel assemblies in the reactor core with new fuel assemblies
every 18 months.5 In 1988, 1989, and 1990, petitioner
depreciated the nuclear fuel over 5 years for tax purposes.
The fabrication of fuel assemblies is a multistep process.
The first step in the process is the acquisition of uranium from
the mines. The second step is to convert the uranium to uranium
hexafluoride (UF6), a gaseous compound. The third step is the
enrichment process, which is accomplished by increasing the
amount of uranium 235 in the gas. The fourth step is to convert
the gas into U2, a uranium oxide powder. The uranium oxide
powder is pressed into pellets, which are then loaded into tubes
or rods. The rods are then bundled together to form a fuel
assembly. The design of the fuel assemblies is specific to the
type of reactor used.6
5 Mr. Villard testified that the reload took about 1 week to
complete, during which time the power plant was shut down.
6 For example, one of FPL’s nuclear power plants, the St.
Lucie Unit 1 reactor, is a 14 by 14 array of fuel rods, whereas
another of FPL’s nuclear power plants, Turkey Point Units 3 and
4, uses a 15 by 15 array.
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Last modified: May 25, 2011