FPL Group, Inc. & Subsidiaries - Page 111

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            however, petitioner failed to introduce any drawings detailing                              
            the “backfit” items.                                                                        
                  Because the construction plans for St. Lucie Units 1 and 2                            
            lacked the precise detail necessary to identify the “backfit”                               
            items, these plans fail to satisfy the requirements of the plant                            
            facility rule.  While TRA section 203(b)(1)(C) requires a                                   
            “specific” plan, petitioner’s plot plan neither specifically                                
            identifies any of the “backfit” items nor identifies the location                           
            of these items at St. Lucie nuclear plant.  Although Mr. Paduano                            
            testified that petitioner has specific drawings for these items,                            
            petitioner failed to introduce these drawings into evidence.                                
                  Absent written plans that precisely and unambiguously                                 
            identify the “backfit” items, we hold that petitioner’s plot plan                           
            lacks the specificity required by TRA section 203(b)(1)(C).  The                            
            underwater intrusion system, the condensate polisher tie line,                              
            and the instrument air system upgrade do not qualify as                                     
            transition property under TRA section 203(b)(1)(C).                                         
                  2.    “Wrap up” Work and “Enhancements and Deficiencies”                              
            Work at the SJRPP                                                                           
                  Petitioner contends that the SJRPP “wrap up” work and                                 
            “enhancements and deficiencies” work qualify for the plant                                  
            facility rule of TRA section 203(b)(1)(C).  This property was                               
            placed in service during the 1988, 1989, and 1990 taxable years                             
            with tax bases of $1,702,649, $2,376,238, and ($360,804),                                   
            respectively.  Respondent argues that the SJRPP items do not                                





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