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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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