ML20094P602
| ML20094P602 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 04/25/1984 |
| From: | Sinclair M SINCLAIR, M.P. |
| To: | |
| Shared Package | |
| ML19258A087 | List:
|
| References | |
| CON-BX19-042, CON-BX19-42, FOIA-84-96 NUDOCS 8408170297 | |
| Download: ML20094P602 (10) | |
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Mr.ry Silcliir 5711 Summerset Drive Midland, MI 48640 Statement Before the U.S. Nuclear Regulatory Commission April 25,1984 On April 10, 1984, at their annual stockholders' meeting, Consumers Power Co. (CPCo) announced that Unit 2 of the Midland nuclear plant can be completed, licensed and placed in commercial operation by December,1986 Using this construction completion date, CPCo is applying pressure on Mich-igan state officials to increase rates substantially to pay for continuing construction since other sources of financing have dried up.
Those of us who are involved in this case as citizen intervenors, and who follow the documentation closely on what is happening at the Midland nuclear plant, have serious reservations about the accuracy of this construction comple-tion date.
We base our concerns on the many unforeseen serious problems that have developed at the site since the last Caseload Forecast Panel met to evaluate the construction schedule at Midland (April 19 -21, '83) all of which indicate the Decem-ber,1986, schedule given by CPCo cannot be met and even raise the question as to whether the plant will be licensable.
Among the problems are:
- 1) The discovery that the bearing capacity of the base soils for the underpinning is 1/2 that used in the original analysis (BN83-174).
- 2) The discovery of incorrect and unconservative calculations of differ-ential settlement between the auxtilary building and the control tower (BN83-174).
- 3) The continuation of repeated drilling incidents despite past controls and commitments intended to rectify this problem (BN83-155 Stop Work and 10/5/83 memo).
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- 4) Alert levels for cracking and possible movement have been exceeded and not properly reported to the Nuclear Regulatory Commission (NRC)
(Stone and Webster meeting, 11/10/83, and 10/5/83 memo).
84081{0297840718 E84 6
s e
s.
- 5) Water seepage
- hat thre atens the integrity of the concrete plers, despite installation of a freezewall intended to control water problems.
The estimates for completion of the soils underpinning work made in December, 1982, when it was started, was 18 months. The current estimate,made 16 months since that prediction, is that the soils work is now only 34% complete.
It should be noted that Mr. James Keppler,in a meeting with CPCo manage-ment in Jackson, stated that the soils work was so complex as to be equivalent to building a third reactor simultaneously (June 21, 1982).
Two NRC inspectors, Ron Cook and Dr. Ross Lansman, have testified that
'the workmanship is " shoddy" and represents a hazard to the public health and safety of the tri-county area of Midland, Saginaw and Bay City (TR 15117, April 28, 1983).
The special task force team formed to do an in-depth inspection of Midland was ready to recommend the project be shut down in November,1982, following the extensive findings of quality control deficiencies during the diesel generator building (DGB) inspection of October,1982 (TR 15071, April 28,1983).
In 1978, when CPCo deelded to preload the DGB as a ' solution to its sinking and cracking in poorly compacted soll, NRC's Midland project manager, Darl Hood, told the utility it was proceeding at its own risk and that the building would have to meet or exceed the FSAR requirements.to be licensable (Meeting notes 12/4/78).
In June,1983, the Congressional Committee investigating the Midland nuclear plant requested an independent review of the diesel generator building which Inspector Dr. Ross Landsman said was not adequate. The Brookhaven Task Force was chosen to review the work. They essentially agreed with the on site inspectors, and also noted that the DGB could not meet FSAR requirements.
Furthermore, in January,1984, a report (MCAR 78, January 6,1984) stated that Bechtel's engineering designs of the piping equipment, conduits,and pipe supports failed to allow for requirements for differential settlement between the DGB structure and DGB pedestals. These facts raise grave doubts about the licensability of this building.
I
o Given these extraordinary serious problems, there is now grave concern in Michigan on the part of CPCo's chief industrial customers, such as General Motors, Ford Motor Co., Chrysler Motor Co. and Great Lakes Steel, who in viewing these serious problems with their considerable management expertise, have questioned its viability as a safe and reliable source of power in the fore-seeable future.
These industrial leaders have joined with the Public Service Commission (PSC),
the Attorney General and Michigan Citizens' Lobby in questioning near term completion of this project.
Since the NRC has the expertise to evaluate plant completion forecasts, I have filed a motion before the Atomic Safety and Licensing Board to require a new Caseload Forecast at Midland to confirm or refute the December,1986, completion date set by CPCo.
Last year's Caseload Forecast Panel's results were suppressed and not made public because ofinternal disputes between the members of the Caseload Fore-cast Panel and NRR management. Thus, investors relying on CPCo forecasts were grossly misled about the actual construction completion timetable (See Wetland vs. CPCo filed November 18, 1983).
Therefore, I am asking that the Commission personally follow through on the work of the Caseload Forecast Panel and the expeditious publication of the results of their evaluation of the construction schedule at Midland.
m-,_
, member of
',ne KiWC55e2 L#
'w I(
DQ % @M Special team formed o
EXHIBIT a=^.r
.An alternate proposal, requiring specific educational proglams to be made available for trainable mentally to ins OC ion SI e education students was approvedTy*
Special Education Advisory Council Monday by a 54 vote.
I Coetlaued from page I happening at the site."
The proposal now will be taken to the Krppler said communications may be Cook left at the meeting's conclusion Board of ' Education of the Midland a big part of the problem. "We don't without commenting. But the man in Intermediate School District for ap-have the same difficulty communicating charge of QA for the Midland plant.
proval July 8. according to William J.
with the other utilities in the region. We Walter R. Bird, said Consumers needs to Leppien, chairman of the SEAC and also have failed to convince you there are
" sit down, think about it and come uP chairman of the Parent Advisory bigger problems on that site than you with the best positive plan of action to Committee, the group which drafted the fe:I there are, get it resolved, as Mr. Keppler said."
proposal.
"We feel you need to be less defensive The PAC is a group of parents of cbout things. Either convince us our KEPPLER HAD proposed another handicapped children from throughout c:necrns are wrong, or focus the meeting with Consumers after be talks Midland County.
nec:ssary attention te correct them." he to his inspectors. Keppler also said he The SEAC is made up of r9presen.
told Consumers, plans to talk to Harold Denton. NRC tatives from each of the fout school director of nuclear reactor regulation.
districts in the county, the PAC and the PRESSED BY REPORTERS after the about the Midland situation. It was MISD board. Its responsiblity is tc meeting to more fully define the Denton who recently convened a special review the proposed special educatfor probl:ms at Midland. Keppler said the meeting of nuclear esperts to study the services and programs each year for the larga amount of work underway at the soll problems.
county. and make recomendations to the pt:nt may be preventing Consumers Last summer,'dur)ng a federal MISD board.
from paying enough attention to quality. bearing on the soil problems, Keppler The SEAC approved the alternate l
Thz utility is struggling to finish the $3.30 testified that be believed future QA at proposal after rejecting 51, the origina billion plant in time to honor an Midland will be adequate to protect proposal Feb. 15 At that time end of.1984 steam contract with the Dow public safety despite the past problems.
representatives to the SEAC fron Ch:mical Co.
Because of the recent problems, various school districts in the count:
/ He said the entensive work to fix the Keppler said Monday he now feels "very said that the PAC proposal to require I soil problerns is the equivalent, in his uneasy" about that testimony and may specific programs for TMI students wa virw, of a third reactor being built on the have to return before an Atomic Safety al(eady covered by a full continuum o sits. "Maybe there's too much work and Licensing Board panel to clarify or programs already considered for eac!
gring on. It's the only site being ristored change his statement.
child.
to what it was intended to be. TWhre "I've led that hearing board (ASLB) to The new proposal is a much mor should be little left to second guessing as believe the remedial work is proceeding general guideline, addressing the spet to hn well the work is being deoe.
with the satisfact6on of the (NRC) staff.
trum of special education prograr "I don't feel they (Consumers) are. At the moment, that isn't so," Keppler options, accordi is to Jim Clark, direetc the estra yard right now,"
said.
of curriculum for MPS and a represes (g:ing K:ppler told reporters.
"k seems like every time we stick our tative to the SEAC.
He said the problem apparently does noes into an area (while inspecting), we TMI students generally have IQ les e not criginate with Cook, who be said has aren't happy," Keppler told Consumers, between 30 and 55, and are characteritt o " good attitude." But Keppler added, He later told reporters, "I'm almost as showing below average developme:
"It sounds like he's not getting the full. embarrassed to be sitting here with this intellectually, a lack of developme story from his people as to what's degree of discomfort about the project."
primarily in the cognitive (thinkini j
area and impairment of adaptli e
- behavior, t0 l9 0f00 County are served through Midlai Currently, TMI students in Midla:
Public Schools. Most of those studen set over Lake Huron
=ttend Ashman Scho a
prograsas for the educable mesta impaired (EMI), a higher. level spec d
A temporary avlation Military from June 3 through July 9. The average education program, la other buildiv>gs Operating Area (MOA) known as the use will be two days a week 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> a the schooldletrict.
Huron MOA, has been established over day. The military will notify Federal Currently there are not any,T' Aviation Administration Flight Service Lcke Huron northeast of Alpena, Michigan. This area is estab!!shed to at least twe bours beforo using the MOA,. Programs 6s settings other than provide separation between civil aircraft so altmen may determlae if the MOA la rean.
Cad military aircraft practicing high in use by centracting the nearest FAA What the proposal basically would speed tactical maneuvers below 10,000 Flight Service Station, is to require the Midland Public sche A corridor, known as the Gore Bay f,
,',Pm
$ch i' The purpose of the Huron MOA is to Corridor, has been established through
- -.o.
.. s a l a. Meewe for flehters o.. MnA hatween Aloena VORTAC and Those settir.gs would include placin
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EXHBIT 2 15117 I
2-3,934 5
1 April 27th, and I'm re'ading from Transcript Page 14433 i
f!
MS. BER::ABEI :
Excuse me, Mr. Paton, what 3
was that page?
MR. PATON:
14433.
]
BY MR. PATON:
i:
6p O'
Mr. Marshall is interrogating Dr. Landsman, i
l and he asks Dr. Landtran:
i 8
"Would you agree, sir, that, as a 9) member of your panel has already testified, to the re's work tha6's shoddy down there?
" WITNESS LANDNMAN:
I would agree with 12(
that.
i
'3 '
"O And don't you think that Midland )
is entitled'to somet'aing better than shodd; I"
j 15 work at a nuclear power plant?
I 16l "A
(WITNESS LANDSMAN)
Yes.
i, I
c h
17 *
"C And don't you think, sir, that it j
is liable to jeopardize the public health
'8 V
0 h
19 l and safety, the people of the City of Midia i
l
[.
20 l' "A
(WITNESS LANDSMAN)
Yes.
t 21 "O
And the surrounding counties?
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'T 22 "A
(WITNESS LANDSMAN)
Yes."
23 Do you agree with Dr. Landsman's statement 24 that the shoddy work at the plant is liable to 25 jeopardize the public health and safety?
l'
,imi %
l EXHIhllT 3 2463
.6. C//ead ts-c) 1' sites, to a much different degree, howevar.
2 C
But there have been, in dact, problems on other 3
nuclear ' sites with some thing as simple c.
soils, haven' t
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4 there?
I; I' -
[ h To a much. lesser extent.
5 9
The degree of.the 6
problem is what's important here.
The extent of what has th'e Midland facility is unpreceder.ted at an1 __
j 7
occurred it
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8 other facility.
b.
9 C
The point remains, however, that other people W;-
10 I
P.
have had some problems with something as simple as soils I
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, or 11 haven't they?
12 I
l A
Yes, of course.
i i
I l
13 I
0 In fact, a recent bulletin has been issued
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14 covering not only Midland but other plants as well, I
i t
is that i
15 right?
16 A
I wrote the bulletin..
I I
\\
17 O
So the answer is that,
.l yes, a recent bulletin 15 has been iss.ued with regard to soils for not only this pla t I
19' but others?
ll n,
20 A
Excuse me.
I It was a circular: Inspection and 21' Enforcement Circular.
l 22 O
.l To someone li.ke me, they're the same.
I'm
$3 :l sorry.
4 l
I g
l 24 l!
A It has a different regulatory posture.
- 25j, O
So your answer is.
i tt ves i - # - --
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15071 EXHIBIT 4 Daco cny ccabar of tho pcnol know chout 1
Q any opinions expressed at,that meeting,for t$e
- 2' 1
3!
reason to shut the plant down?
4 A
(WITNESS GARDNER)
That particular 5;
meeting?
I That particular meeting or thereaf ter.
6!
Q, A
(WITNESS GARDNER)
Personally, I would Shafer.said in that we had
's agree with what Mr.
already found substan'tial evidence of noncompliance.
9 I
- Previously in September we had considered 10 I
11 recommending shutdown, and only based on the fact that we did not hav.e sufficient evidence did we 4
12
,i i
13 decide not to.
Now we had evidence that ind'icated a 14 and I think about 15 fairly widespread noncompliance, 16 i
this time it was unanimous among the team that we i
had the evidehce that we did not have in September 17 and, therefore, we could recommend a shutdown.
is 19 -
Q Now, was that recommendation carried to i
20 Mr. Keppler?
21" A
(WITNESS' SHA,FER)
A. recommendation ~ a I don't believe Mr. Keppler was 22 that time?
No, 23 involved in that.
Wa"s a recommendation carried to anyone 24
.Q 25 else at or near that time?
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a Current Status of Construction Completion Plan Report by Nuclear Regulatory Commission Inspector April 23, 1984 The new Construction Completion Plan was approved on October 22, 1983.
However, almost simultaneously 9 Stop Work Orders were issued dealing with deficiencies in drawing and design control.
This had to do with correcting improper procedures for Field Change Notices (FCR's).
These Stop Work Orders affected almost all of the Quality Assurance and safety-re' lated activ-itles at the plant, including safety-related work by Zack, Babcock and Wilcox, Bechtel, Consumers Power Co. and the newly reorganized Midland Plant Quality Assurance Department (MPQAD).
Thus, work was shut down in most areas of the plant from October, 1983, to the end of February, 1984.
At this point, only 2% of the Quality Verification Pro-gram called for in the Construction Completion Plan, with newly trained quality control inspectors, has been com-pleted.
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EXHIBIT 5 -
e w
2 n
t l
OurOninions-
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' The Game Is Over s
"othing in the law says that Consum-A ers Power Co. must abandon the Shareholders wouldn't take the bath alone,
{ and accept the " survival proposal"it receivedMidland nuclear of course. Consumers also would pay higher electricity costa. Indeed, the rate ofincrease in Lansing last Friday. The company never.
for domestic customers would, for most do-i theless would be foolish to shrug off the mestic customers, outstrip the state income k
formidable group of sponsors who offered the tax hike that produced so much heat last year, I
proposal.
not to mention two suct.essful recall elections.
The company says it can best serve con.
This " passion play" (as Mr. Kelley charac.
y sumers'interesta by finishing the first Mid.
terized it) takes place against a backdrop of f
l land reactor, which is 85-percent complete. utility disasters elsewhere. In recent months
, That seems questionable, however. The pro-the Nuclear Regulatory Commission (NRC) i gram already has cost $4 billion more than has refused to grant an operating license for a 1
completed $3.3. billion Illinois nuclear plant; originally estimated and construction has fallen nine years behind schedule. Consumers Cincinnati Gas and Electric officials decided a
- Power officials guess that the total bill will to turn their $1.7-billion Zimmer reactor into D-a coal-burning facility, and two lndiana nuele.
come to $4.43 billion, but even that's tenta.
ar planta in which $2.5 billion has been sunk tive. Directors and shareholders will get a new l
f members of the Public Service Commissioncompletion estim Why? No utility has any assurance now (PSC) staff expect the number to reach $6 that it will get an operating license from the billion. If expenses get that high for a complex NRC after it finishes a reactor. The compa-4
),
that was supposed to cost $339 million (the nies invest billions in construction and do not 1972 estimate), the PSC may urder the com.
recover a dime until they produce power.
I pany to kill it and take the loss.
Consumers management has bet the company l
against this risk, and customers and the Indeed, Atty. Gen. Frank J. Kelley recently regulstors have rebelled; they think the odds wrote the company and demanded abandon.
ment. The company replied in statewide have become impossible.
advertising that this would be unthinkable, The arguments used to justify the project t
i I
Consumers President John B. Selby then met when it was proposed were sound and thel l
price was right. But the situation today is
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quietly in Lansing with Mr. Kelley, and they decided to ask the staffs of the company, the completely different. A serious recession and I t
attorney general's office, and the PSC to. conservation shaved the need for power and exchange views on the subject, federal regulators inflated costs by changing
[
After two sessions the company received a construction and certification rules. Finally, F
l survival plan endorsed by Atty. Gen. Kelley,' when the NRC denied an operating permit the PSC staff the Michigan Citizens' Lobby a completed plant, it delivered the coupe de F and a consor, tium of 22 large industries, grace to nuclear power in this country. No 8
including General Motors, Ford, Dow Chemi.
sane manager would undertake such a project cal Co., and Great Lakes Steel. The group now and face that kind of uncertainty.
the company abandon the What should Consumers do? It seerns to us proposed that plant. It also outlined a way to p~ay the debt the company has no other choice but to q
incurred during construction. The plar. would abandon the project and strike the best deal it
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can make with its customers and the regula.
not affect preferred stocks and bonds, but it tors. The decision should not be viewed as a t
would require suspension of dividends on referendum on nuclear power, which remains W
common stock for a three to-five-year period, a safe source of energy, but instead as an y
For that, the regulators would guarantee the admission that the costa of build company sufficient rates to maintain service, fend off bankruptcy, and return to normal permitting the Midland plant have become l
financial health in eight to 10 years.
prohibitively high. After a decade of steadily I
escalating prices, the Midland game is over.
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1 1982j ArrORNEY GENERAL V MPSC 385 2
38G 412 Ahcli M pati M2]
Arnmn.w GeitAi. v MPSC 387 Supteme Court granted Ic.ne t.epp.al prior to dne., ion by the Court of Apph and orde ed the three ca s ci,nsoh.l.ited for Pro
- ideo the only nic. ins of seiyuuy into the re.im.mableness of N110RNEY GENERAL v MI: liis;AM l'UDIlC SERVICE arc. ment.
plants durmg constructen is inaccur. ate Ongoinir construction COM.\\llSSION in art opinion by Justwe lean, joinc.1 by Chief Justice is q ua ns ute kanngs uWer N ekctMy h 5
Colem.m and Justres Km.inagh. Fitzgerald, and Nyan. the nus=*on *c 8pPmumately ymly, and. m ad&tbn, b utshty get yos. 67938. ti7944. and *>7915 Argued Octaher 15. Iwil Supreme Court hel.t can nquet that ensmction wwk in pnsgms be included in
'Ca!cndir Nos. 23. 24...nd 25) - th ei4 d J.muary 27 tw Ib ket % n7914. tial5 The Tktnnt til the rate base. Moreover the commisoon in the esercise of its C
5"P"'i""'y Powm, may conduct penonstructum nmw **b t
the..ppr.nal of the 51erhiun Publoc &rvice Commsuon for i
)
- ecuritms to obtain funds fter a lawful purpme of the utahty and out reg.ird to whether the utehty seeks to have the plant's cents the is.,uanie of SG25 matt.on in munties, part of which would does not estems to whether. to accernpl sh that purpoi.e. there fmance the continued cos4tructum of the Ennco Fermi 2 nu.
is a m ed for the proj.st to which the funds will be devoted The 4
e rt cannot sw ently ct eat N Mah p
.ar p mered gener:itmq pl.mt.md the Belle River cual fired s
wm t ay conclu e that ab nawn4Wnns d a u%
mquery se the need for the Ibn.ls, mat the med for the pnpt g.
O ner.atmg pLints, ed p ort..f which would retire m,etunng it may N we e. in tha era of multi hithon dn.lar power plant.
construction project shout.1 he noide the subject of a preron-
)
h se term and i..n; 9.i m s bt A year later. Edison
.uath thr the commewson to pin upm the necteity for any such stmctwn heanng he'M duw nudt conc % mat h i
.c.oroval of the i -u :nre of. n.uiditional $1 tJ96 bdhon an pLmt hetore cimnt rpi t ime tegens. ht.t the pokey quente. n puhhc mterest is better sersed by the present system which
%uritem. primardy to finance sontmued constructson of IE, whether approval by the comnnamion should be required before requires a utshty. its shareholde w and its bundholders to carry
.wmer planta and to retire reistinat short term and long term constructmn hegms is pros eely for the legislature, and not for the nsk insolved in dwidmg to construct additional generatang debt the Omrt, to hwule capacity, if they have made erroneous deciseons and %e cost of IM.t No. 679:18 Canumers l%wer Company mought the ap.
1 The statute requires th.st in the opinion of the comniiunon prmal of the &-hi.:an ruhhc &rvice Commisuon for the the use of the e,ipital to tw raswd by the issu.ince of secuntms wa ince of $'i64 unthon in wuntes pnmanly to 6 nance the is reasonably requued for the purpows of the utihty The largely unakW n ntmued construction of the mit.md nuclear powered genera.
intervenors argue that than means that the commis mn must The adm d the cornmsmn authorbing the hence d tmrt plant and to ref ue m.iturmg short term and long term nnd that the umlerlying projects are reasonably requued not secunties are a5rmed in all three cases-
'j only whether the funds are reasonahly requirist for the proj.
Justice Wdhams, joined by Justice Moody. writing sepa-
[,.
in. ell three cases, the Alto,ney t;eneral and the Mkhigan ects fiut two other u.ms of the word "purpusies" an the statut, retely, would hold that the intention of the legislature was
(
Cduens lobby mtervened at the commise. ion's hearmgs on the show that it me.m. "the acquisataan of property. the construe.
that there skuld be a complete feamabiht'y esamination both at l,
h 4*P e.*tions for.ipproval. They argued in each case that the tion, cumpletion. extension or unprovement of f.iceht res or * *
- the time of the origmal Snancing apphcation and at the time of p'mer plants under construstion were unnecessary dnd unrea-the impeovement or mainten mce of sernce or * *
- the du.
ratemaking, that in, when it is determined whether the plant
=mahly ca*ly, and that the cmnmission should not approve charge or lawful refunding of chhgatens. No one has argued should be included in the utdaty's rate base. At the time of a p
y i%uan e of the secuntes snanfar as the proceeds would be uned that construrtmn of additamal generating capacity is not a subwquent Snancing application a complete feasibility esami-jl [
3[
T, to fmance their consenection In each case the commission lawful utihty purpome. It is a separate question whether the naam is not nece=sary anJ the more limited detersnituation d
.'g ricchrmd to consider evidence relatmg to the need for the power "I'hty necils the addition el generating capacity.
1 as it is the necessity of the Gnancing is adequate Their opmian is pLmis, and authorned swuance of the necurities. While appeals whether the.i&htsanal capacity shoiJd be fa s! or nuclear.
be.ed tudh on the constructioni of the statute and on considera-g..
si y
by the intervenors were pending m the Court of Appeals, the fueh d or whether the propowd plant is costefficient or rea=on.
Lion of policy imphe.stions The Legedature, by requiring pres >
f able.
"* b "" *3 b "0"8 erty for which secunties were to be issued to be reasonably C
g g y.,g, 3, ur 2d Pubhc Snurities and Ohhgations 2 The act does not give the commision discretion to inquire required for the purposes of the utshty, intended two things 16 4
ggy y m
meu immaterial subjects m determming whether it shouhl that. the property be employed, in this use. **for the * *
- 68 Am Jur 24, Pubhc Utehties {l 225,264.
gr.mt the authority to issue the secuntees The Michigan ca es completion of facihties", and 2) that the property be reasonably Dl 64 Tm Jur 2d. Pishhc Secunles and t)l.hgations $ 96-H.e intervenors show that a secunties issue proceeding required for a utihty purpose with n the overall content of c
9 2 Am Jur 24. Admini3rrative I aw {l 213. 241,243 hnuted to a review of the 6nancial decisions of the utihty.
utility regulation, namely property that would adequately serse
[13 g.tj t;g Ani ja,3, p,Nic linblics { fle)..t and does not r.
y 4
go into the teammableness of the umlerlymg consumeru at a reason:dde rate and enke a rea!onable return proiccts The utilities statutes of other junadictions offer httie for the utdity The latter deterniination will be achiesed if the j
gualance m construmg the Shchigan act, some are too dissimi.
MPSC makes a complete feaubdity examination at the time of p
lar. and otters cunt.iin language given diverse interpretations.
the oridnal application for Snancing and later evaluates the iIi 3 The intervenor's ane.umptmn that the utihty secunties act costs of the project when the utdefy requests inclusion in the t
rate b.se. it was not the ie,isiative inient to aiiow a utdity n I
k s
.