FPL Group, Inc. & Subsidiaries - Page 166

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          was increased to $5.9 million.  The ER included a report of                 
          construction action prepared on May 9, 1984, which is associated            
          with ER No. 6475.  The report of construction action stated that            
          construction work started on May 1, 1984.56  Another report of              
          construction action prepared on February 27, 1987, stated that              
          the underwater intrusion detection was completed on February 25,            
          1987.                                                                       
               ER No. 4866, approved in late 1988/early 1989, authorized              
          $360,000 for the St. Lucie underwater intrusion detection system.           
          The ER stated in pertinent part:                                            
                    [FPL] is committed to the * * * [NRC] for the                     
               development of an underwater intrusion detection system                
               for the intake canal.  This is a security measure.                     
               * * *                                                                  
               This ER is necessary as the presently installed system                 
               does not satisfy the requirements of the [NRC].  This                  
               has caused an extensive effort in research and                         
               development of this specialty system.  This research                   
               has identified the need to:  Install an additional                     
               sonar head and a surface detection system.  These                      
               additional requirements have made it necessary to fund                 
               and perform these modifications.[57]                                   
               With respect to the modification and construction of the               
          underwater intrusion system, petitioner incurred capitalized                
          costs (tax basis) of $338,665 for equipment placed in service in            
          the 1990 taxable year.                                                      


               56 Mr. Paduano testified that the construction work on the             
          underwater intrusion system began before 1986.                              
               57 Mr. Paduano testified that this ER “added additional                
          detection capabilities.”                                                    




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