# 2009 WI NG Program Evaluation - wi2009ngprogramevaluation (Wisconsin; Natural Gas State Program Evaluation)

- **operation:** document
- **citation:** PHMSA wi2009ngprogramevaluation
- **title:** 2009 WI NG Program Evaluation - wi2009ngprogramevaluation (Wisconsin; Natural Gas State Program Evaluation)
- **source type:** inspection
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2009-01-01
- **effective on:** Not available
- **summary:** 2009 PHMSA natural gas program evaluation for Wisconsin.
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- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/subdoc/121/wi2009ngprogramevaluation.pdf
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1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2009 Natural Gas State Program Evaluation for WISCONSIN PUBLIC SERVICE COMMISSION Document Legend PART: O -- Representative Date and Title Information A -- General Program Qualifications B -- Inspections and Compliance - Procedures/Records/Performance C -- Interstate Agent States D -- Incident Investigations E -- Damage Prevention Initiatives F -- Field Inspection G -- PHMSA Initiatives - Strategic Plan H -- Miscellaneous I -- Program Initiatives DUNS: 969115450 2009 Natural Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 1

2009 Natural Gas State Program Evaluation -- CY 2009 Natural Gas State Agency: Wisconsin Rating: Agency Status: Date of Visit: 09/13/2010 - 09/17/2010 Agency Representative: Thomas Stemrich, Pipeline Safety Program Manager PHMSA Representative: Glynn Blanton, DOT/PHMSA State Programs Commission Chairman to whom follow up letter is to be sent: Name/Title: Eric Callisto, Chairperson Agency: Wisconsin Public Service Commission Address: 610 North Whitney Way City/State/Zip: Madison, Wisconsin 53705 60105(a): Yes 60106(a): No Interstate Agent: No INSTRUCTIONS: Complete this evaluation in accordance with the Procedures for Evaluating State Pipeline Safety Program. The evaluation should generally reflect state program performance during CY 2009 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual certification/agreement attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART F): The field inspection form used will allow different areas of emphasis to be considered for each question. Question 13 is provided for scoring field observation areas. In completing PART F, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A General Program Qualifications 26 26 B Inspections and Compliance - Procedures/Records/Performance 23.5 22.5 C Interstate Agent States 0 0 D Incident Investigations 7 7 E Damage Prevention Initiatives 9 8 F Field Inspection 12 10 G PHMSA Initiatives - Strategic Plan 10 8 H Miscellaneous 3 3 I Program Initiatives 9 8.5 TOTALS 99.5 93 State Rating................................................................................................................................................... 93.5 DUNS: 969115450 2009 Natural Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 2

PART A - General Program Qualifications Points(MAX) Score 8 8 1 Did the state submit complete and accurate information on the attachments to its most current 60105(a) Certification/60106 (a) Agreement? (NOTE: PHMSA Representative to verify certification/agreement attachments by reviewing appropriate state documentation. Score a deficiency in any one area as "needs improvement". Attachment numbers appear in parenthesis) Previous Question A.1, Items a-h worth 1 point each Yes = 8 No = 0 Needs Minor Improvement = 3-7 Needs Major Improvement = 2 a. State Jurisdiction and agent status over gas facilities (1) b. Total state inspection activity (2) c. Gas facilities subject to state safety jurisdiction (3) d. Gas pipeline incidents (4) e. State compliance actions (5) f. State record maintenance and reporting (6) g. State employees directly involved in the gas pipeline safety program (7) h. State compliance with Federal requirements (8) SLR Notes: Yes. However, Wisconsin Public Service Commission (WIPSC) does not have jurisdictional authority over LPG operators and their state damage prevention law penalty amount only applies to pipeline operators. 2 Did the state have an adequate mechanism to receive operator reporting of incidents to ensure state compliance with 60105(a) Certification/60106(a) Agreement requirements (fatality, injury requiring hospitalization, property damage exceeding $50,000 - Mechanism should include receiving "after hours" reports)? (Chapter 6) Previous Question A.2 Yes = 1 No = 0 1 1 SLR Notes: Yes, WI PSC regulation 104.05 addresses this required information. Additionally, WI PSC provides in their annual written notification to all operators at the end of the calendar year who and how to notify the Commission regarding incidents. 3 Has the state held a pipeline safety TQ seminar(s) in the last 3 years? (NOTE: Indicate date of last seminar or if 2 2 state requested seminar, but T&Q could not provide, indicate date of state request for seminar. Seminars must be held at least once every 3 calendar years.) (Chapter 8.5) Previous Question A.4 Yes = 2 No = 0 SLR Notes: Yes, WIPSC conducted a pipeline safety seminar in January 26-30, 2009 at Wisconsin Dells, WI. They anticipate having the next scheduled seminar at the same location on February 14-19, 2011. The number of participants who attend the 2009 seminar was 170 individuals. 4 Were pipeline safety program files well-organized and accessible?(NOTE: This also includes electronic files) (Chapter 5) Previous Question A.5 Yes = 1 No = 0 1 1 SLR Notes: Yes, a review of WIPSC file folders and other relative documents found the pipeline safety program files accessible, accurate and well organized. They use the Electronic Regulatory Filing System (ERF) as a method to record all inspections performed and letters sent to operators pertaining to compliance with the pipeline safety regulations. 5 Did state records and discussions with the state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? (Chapter 4.1, Chapter 8.1) Previous Question A.6 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: Yes, Tom Stemrich has a good understanding of the pipeline safety regulations and knowledge in submission of certification and payment agreement documents pertaining to the pipeline safety grant award. 6 Did the state respond in writing within 60 days to the requested items in the Chairman's letter following the Region's last program evaluation? (No response is necessary if no items are requested in letter and mark "Yes") (Chapter 8.1) Previous Question A.8 Yes = 1 No = 0 1 1 SLR Notes: time period. Yes, Chairperson Eric Callisto response letter to Ivan Huntoon, PHMSA Central Region Director dated February 4, 2010 was within the 60 day requested DUNS: 969115450 2009 Natural Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 3

7 What actions, if necessary, did the State initiate as a result of issues raised in the Chairperson's letter from the 1 1 previous year? Did actions correct or address deficiencies from previous year's evaluation? (No response is necessary if no items are requested in letter and mark "Yes") (Chapter 8.1) Previous Question A.8/A.9 Yes = 1 No = 0 SLR Notes: Yes, Chairperson Calliston understood the need to take jurisdiction over LPG pipeline facilities in order to obtain full jurisdiction over all intrastate gas system operators and if the opportunity presents itself, the organization will attempt to gain jurisdiction during next year's legislative session. In regard to inspection data being more transparent to the public, Chairperson Calliston mentioned Wisconsin has an open records law and information is available from their Electronic Records Filing system. Consideration will be taken to include summary information on the number of miles of mains, services, and leakage by operators on their web site. Personnel and Qualifications 8 Has each inspector fulfilled the 3 year TQ training requirement? If No, has the state been granted a waiver regarding TQ courses by the Associate Administrator for Pipeline Safety? (NOTE: If the State has new inspectors who have not attended all TQ courses, but are in a program which will achieve the completion of all applicable courses within 3 years of taking first course (5 years to sucessfully complete), or if a waiver has been granted by the applicable Region Director for the state, please answer yes.) (Chapter 4.4) Previous Question A.10 Yes = 3 No = 0 3 3 SLR Notes: Yes, all pipeline safety individuals performing inspections on operators in their state have completed the TQ training requirements within the 3 year period. Dagmar Vanek has not completed the LNG course PL4253 but does not perform LNG inspections. 9 Brief Description of Non-TQ training Activities: Info Only = No Points For State Personnel: No activity. For Operators: On March 31 thur April 3, 2009, Tom Stemrich conducted a training course at Excel Energy Company for their employees on the pipeline safety regulations in New Richmond, WI. October 22 & 23, 2009, Tom attended the Utility Workers Consetntion and presentated information on the pipeline safety regulations and issues of concern on safety issues or best practices. For Non-Operator Entities/Parties, Information Dissemination, Public Meetings: No activity. Info Only Info Only SLR Notes: 10 Did the lead inspectors complete all required T&Q OQ courses and Computer Based Training (CBT) before conducting OQ Inspections? (Chapter 4.4.1) Previous Question A.12 Yes = 1 No = 0 1 1 SLR Notes: inspections were conducted. Yes, a review of the OQ database and training records, the inspectors assigned to lead OQ inspections have completed the required training prior to the time 11 Did the lead inspectors complete all required TQ Integrity Management (IMP) Courses/Seminars and CBT before conducting IMP Inspections? (Chapter 4.4.1) Previous Question A.13 Yes = 1 No = 0 1 1 SLR Notes: Yes, a review of the training records indicate the inspectors assigned to lead IMP inspections have completed the required training prior to the time inspections were conducted. The lead inspectors are Tom Stemrich and Jeff Murley. 12 Was the ratio acceptable of Total inspection Person-days to Total Person-days charged to the program by state inspectors? (Region Director may modify points for just cause) (Chapter 4.3) Previous Question B.12 Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 434.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 4.30 = 946.00 Ratio: A / B 434.00 / 946.00 = 0.46 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 DUNS: 969115450 2009 Natural Gas State Program Evaluation 5 5 Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 4

Points = 5 SLR Notes: Yes, WIPSC had 434 inspection person days during 2009. The WIPSC is assigned 4.30 person years to the natural gas program during 2009. The resulting ratio is 0.46 which exceeds the minimum ratio of 0.38, thus a 5 point score is awarded. 13 Have there been modifications or proposed changes to inspector-staffing levels? (If yes, describe) Previous Info Only Info Only Question B.13 Info Only = No Points SLR Notes: calendar year 2010. John Vogt, Pipeline Safety Engineer, retired on January 15, 2010 and action is being taken by the commission to hire a new individual before the end of 14 Part-A General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: Total points scored for this section: 26 Total possible points for this section: 26 DUNS: 969115450 2009 Natural Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 5

PART B - Inspections and Compliance - Procedures/Records/ Performance Points(MAX) Score Inspection Procedures 1 Does the State have a written inspection plan to complete the following? (all types of operators including LNG) 6.5 6 (Chapter 5.1) Previous Question B.1 + Chapter 5 Changes + Incorporate LNG Yes = 6.5 No = 0 Needs Improvement = 50% Deduction a Standard Inspections (Including LNG) (Max points = 2) b IMP Inspections (Including DIMP) (Max points = .5) c OQ Inspections (Max points = .5) d Damage Prevention (Max points = .5) e On-Site Operator Training (Max points = .5) f Construction Inspections (Max points = .5) g Incident/Accident Investigations (Max points = 1) h Compliance Follow-up (Max points = 1) Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement SLR Notes: Damage prevention was not listed or described in the written inspection plan. Therefore, a point reduction of .5 was assessed. Total point award for this section is 6 points. 2 Did the written Procedures for selecting operators adequately address key concerns? (Chapter 5.1) Previous 2 2 Question B.2, items a-d are worth .5 point each Yes = 2 No = 0 Needs Improvement = 50% Deduction a Length of time since last inspection Yes No Needs Improvement b History of Operator/unit and/or location (including leakage , incident and compliance history) Yes No Needs Improvement c Type of activity being undertaken by operator (construction etc) Yes No Needs Improvement d For large operators, rotation of locations inspected Yes No Needs Improvement SLR Notes: Yes, See Wisconsin Public Service Commission, Criteria for Inspecting Natural Gas Utilities document. a. Yes, page 4, section 4 b. Yes, page 4, section 4 c. Yes, page 3, section 11 d. Yes, page 5, section 3 Inspection Performance 3 Did the state inspect all types of operators and inspection units in accordance with time intervals established in its written procedures? (Chapter 5.1) Previous Question B.3 Yes = 2 No = 0 2 2 SLR Notes: Utilities. Yes, all operators and inspection units were inspected in accordance with the Wisconsin Public Service Commission, Criteria for Inspecting Natural Gas 4 Did the state inspection form cover all applicable code requirements addressed on the Federal Inspection forms? (Chapter 5.1 (3)) Previous Question B.4 Yes = 1 No = 0 1 1 SLR Notes: Yes. A review of the federal inspection form to their state forms has been verified. All questions in their database form are the same as the federal inspection questions. Consideration will be taken to design separate inspection forms for each type of inspection performed in the future. 5 Did state complete all applicable portions of inspection forms? (Chapter 5.1 (3)) Previous Question B.5 1 1 Yes = 1 No = 0 SLR Notes: reviewed were checked. Yes. A review of inspections performed on July 2-4, 2009 on Midwest Natural Gas indicated the forms were completed and all portions of the items DUNS: 969115450 2009 Natural Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 6

6 Did the state initiate appropriate follow-up actions to Safety Related Condition Reports? (Chapter 6.3) Previous Question B.6 Yes = .5 No = 0 .5 NA SLR Notes: NA. During calendar year 2009, there were no safety related condition reports submitted by intrastate natural gas operators located in the State of Wisconsin. 7 Did the state review operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Previous Question B.7 Yes = .5 No = 0 SLR Notes: The State of Wisconsin does not have cast-iron mains, service lines or pipelines located in their state. .5 NA 8 Did the state review operator procedures for surveillance of cast iron pipelines, including appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance) (NTSB) Previous Question B.8 Yes = .5 No = 0 SLR Notes: The State of Wisconsin does not have cast-iron mains, service lines or pipelines located in their state. .5 NA 9 Did the state review operator emergency response procedures for leaks caused by excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21? (NTSB) Previous Question B.9 Yes = .5 No = 0 SLR Notes: Yes. This item is reviewed during the standard inspection and when an incident occurs on a natural gas distribution system. .5 .5 10 Did the state review operator records of previous accidents and failures including reported third party damage and leak response to ensure appropriate operator response as required by 192.617? (NTSB) Previous Question B.10 Yes = 1 No = 0 SLR Notes: Yes, this information is covered in the standard inspection. 1 1 Compliance - 60105(a) States 11 Did the state adequately document sufficient information on probable violations? (Chapter 5.2) Previous 1 1 Question B.14 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: the operator. Yes, information located in the database indicates documentation is being used to monitor probable violations. This information, Violation Report, is sent to 12 Does the state have written procedures to identify the steps to be taken from the discovery to the resolution of a 1 1 probable violation as specified in the "Guidelines for State Participating in the Pipeline Safety Program"? (Chapter 5.1) Previous Question D(1).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes, Wisconsin Public Service Commission, Criteria for Inspecting Natural Gas Utilities, page 3, Notification & Follow-up Procedures addresses this item. 13 Does the state have written procedures to notify an operator when a noncompliance is identified as specified in the "Guidelines for States Participating in the Pipeline Safety Program"? (Chapter 5.1(4)) Previous Question D 1 1 (1).2 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes, Wisconsin Public Service Commission, Criteria for Inspecting Natural Gas Utilities, page 4, Notification & Follow-up Procedures addresses this item. DUNS: 969115450 2009 Natural Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 7

14 Does the state have a written procedure for routinely reviewing the progress of compliance actions to prevent delays or breakdowns of the enforcement process, as required by the "Guidelines for States Participating in the Pipeline Safety Program"? (Chapter 5.1(5)) Previous Question D(1).3 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: Yes, Wisconsin Public Service Commission, Criteria for Inspecting Natural Gas Utilities, page 4, Notification & Follow-up Procedures addresses this item. 15 Has the State issued compliance actions for all probable violations discovered? (Note : PHMSA representative 1 1 has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation) Previous Question D(1).4 Yes = 1 No = 0 SLR Notes: been corrected. Yes, a review in Electronic Regulatory Filing System (ERF) indicated all probable violations are issued and tracked for compliance until the violations have 16 Did the state follow its written procedures for reviewing compliance actions and follow-up to determine that 1 1 prompt corrective actions were taken by operators, within the time frames established by the procedures and compliance correspondence, as required by the "Guidelines for States Participating in the Pipeline Safety Program"? Previous Question D(1).5 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes, this is addressed in the Wisconsin Public Service Commission, Criteria for Inspecting Natural Gas Utilities, and Electronic Regulatory Filing System. 17 If compliance could not be established by other means, did state pipeline safety program staff request formal action, such as a "Show Cause Hearing" to correct pipeline safety violations? (check each states enforcement procedures) Previous Question D(1).6 No = 0 Yes = 1 SLR Notes: Yes, WIPSC has the authority under their commission rules to issue a show cause. 1 1 18 Did the state adequately document the resolution of probable violations? (Chapter 5.1 (6)) Previous Question D(1).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes, their written procedures and files indicate they adequately documented all probable violations. 1 1 19 Were compliance actions sent to a company officer? (manager or board member if municipal/government system) (Chapter 5.1(4)) Previous Question D(1).8 Yes = .5 No = 0 .5 0 SLR Notes: No. A review of their database showed this was not done in 2009. Also, this requirement is not in the Wisconsin Public Service Commission, Criteria for Inspecting Natural Gas Utilities manual. Recommend this item be added to their written procedures manual. 20 Did the compliance proceedings give reasonable due process to all parties? (check each states enforcement procedures) Previous Question D(1).9 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes, Wisconsin Public Service Commission rules 196.26 or 196.28 addresses this requirement. 1 1 Compliance - 60106(a) States 21 Did the state use the current federal inspection form(s)? Previous Question D(2).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: NA. 1 NA 22 DUNS: 969115450 2009 Natural Gas State Program Evaluation Are results adequately documented demonstrating inspection units were reviewed in accordance with state inspection plan? Previous Question D(2).2 Yes = 1 No = 0 Needs Improvement = .5 1 NA Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 8

SLR Notes: NA. 23 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Previous Question D(2).3 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: NA. 24 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Previous Question D(2).4 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: NA. 25 SLR Notes: NA. Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question D(2).5 Yes = 1 No = 0 Needs Improvement = .5 1 NA 26 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Previous Question D(2).6 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: NA. 27 Part B: General Comments/Regional Observations Info Only = No Points SLR Notes: See questions 1 e, and 19 pertaining to recommendations or loss of points. Info Only Info Only Total points scored for this section: 22.5 Total possible points for this section: 23.5 DUNS: 969115450 2009 Natural Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 9

PART C - Interstate Agent States Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Previous Question D(3).1 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: The Wisconsin Public Service Commission is not an Interstate Agent. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Previous Question D(3).2 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: The Wisconsin Public Service Commission is not an Interstate Agent. 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Previous Question D(3).3 Yes = 1 No = 0 SLR Notes: The Wisconsin Public Service Commission is not an Interstate Agent. 1 NA 4 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Previous Question D(3).4 Yes = 1 No = 0 SLR Notes: The Wisconsin Public Service Commission is not an Interstate Agent. 1 NA 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Previous Question D(3).5 Yes = 1 No = 0 Needs Improvement = .5 1 NA SLR Notes: The Wisconsin Public Service Commission is not an Interstate Agent. 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Previous Question D(3).6 Yes = 1 No = 0 SLR Notes: The Wisconsin Public Service Commission is not an Interstate Agent. 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Previous Question D(3).7 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: 1 NA The Wisconsin Public Service Commission is not an Interstate Agent. 8 Part C: General Comments/Regional Observations Info Only = No Points SLR Notes: The Wisconsin Public Service Commission is not an Interstate Agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 969115450 2009 Natural Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 10

PART D - Incident Investigations Points(MAX) Score 1 Are state personnel following the procedures for Federal/State cooperation in case of an incident? (See Appendix in "Guidelines for States Participating in the Pipeline Safety Program") (Chapter 6.1) Previous Question E.1 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: Gas Company. Yes. Procedures were followed for Federal/State cooperation during the incident that occurred on January 31, 2009 in Milwaukee, WI involving Wisconsin 2 Are state personnel familiar with the jurisdictional authority and Memorandum of Understanding between NTSB and PHMSA? (See Appendix in "Guidelines for States Participating in the Pipeline Safety Program") (Chapter 6 ? Appendix D) Previous Question E.2 Yes = .5 No = 0 .5 .5 SLR Notes: Yes. Consideration should be taken to include this memorandum of understanding between NTSB and PHMSA in the Wisconsin Public Service Commission, Criteria for Inspecting Natural Gas Utilities. 3 Did the state keep adequate records of incident notifications received? Previous Question E.3 Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: Yes, Wisconsin Public Service Commission keeps telephonic incident reports by year in a file folder and in an electronic data base program located on the commission's computer system. 4 If an onsite investigation of an incident was not made, did the state obtain sufficient information by other means to determine the facts and support the decision not to go on-site? Previous Question E.4 Yes = 1 No = 0 Needs Improvement = .5 SLR Notes: Yes. Wisconsin Public Service Commission policy is to response to all potential incidents. 1 1 5 Were investigations thorough and conclusions and recommendations documented in an acceptable manner? Previous Question E.5, comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 a. Observations and Document Review 2 2 b. Contributing Factors c. Recommendations to prevent recurrences where appropriate SLR Notes: Yes No Needs Improvement Yes No Needs Improvement Yes No Needs Improvement Yes, a review of the Wisconsin Gas Company incident in Milwaukee, WI on January 1, 2009 indicated the investigation was thorough and conclusions were made in an acceptable manner. The commission recommended the company accelerate the existing replacement PVC program from 15 years to 5 years. 6 Did the state initiate enforcement action for violations found during any incident investigation(s)? Previous Question E.6 Variation Yes = 1 No = 0 Needs Improvement = .5 1 1 SLR Notes: natural gas. Yes. It was suggested by the commission additional awareness programs be adopted by the company to keep individuals informed about the presence of 7 Did the state assist region office by taking appropriate follow-up actions related to the operator incident reports .5 0.5 to ensure accuracy and final report has been received by PHMSA? (validate annual report data from operators concerning incidents/accidents and investigate discrepancies) (Chapter 6) Previous Question E.7/E.8 Yes = .5 No = 0 SLR Notes: DOT Form 7100. Yes. Wisconsin Public Service Commission has been responding to the PHMSA Central Region within ten days of an accident or information pertaining to 8 Part D: General Comments/Regional Observations Info Only = No Points SLR Notes: DUNS: 969115450 2009 Natural Gas State Program Evaluation Info Only Info Only Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 11

Total points scored for this section: 7 Total possible points for this section: 7 DUNS: 969115450 2009 Natural Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 12

PART E - Damage Prevention Initiatives Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? Previous Question B.11 Yes = 2 No = 0 Needs Improvement = 1 2 2 SLR Notes: This requirement is reviewed by the inspector during a damage prevention review of the operator's O & M Plan. 2 Did the state inspector check to assure the pipeline operator is following its written procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? New 2008 Yes = 2 No = 0 SLR Notes: Yes, this is reviewed during the standard inspection being performed on all operators. 2 2 3 Did the state encourage and promote the adoption of the Common Ground Alliance Best Practices document to 2 2 its regulated companies as a means of reducing damages to all underground facilities? Previous Question A.7 Yes = 2 No = 0 Needs Improvement = 1 SLR Notes: Yes, Wisconsin Public Service Commission has been working with other organizations in promoting best practices through the Committee for Damage Prevention for the adoption of the Common Ground Alliance Best Practices Version 7 document. In the commission's proposed rules they will require all operators to report their damages via the DIRT program. 4 Has the agency or another organization within the state collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests? New 2008 Yes = 1 No = 0 1 0 SLR Notes: No. Consideration is being developed to have all operators report data and trends on the number of pipeline damages per 1,000 locate request into DIRT. This requirement will be in the form of a commission rule. 5 Did the state review operators' records of accidents and failures due to excavation damage to ensure causes of failure are addressed to minimize the possibility of recurrence as required by 192.617? Yes = 2 No = 0 2 2 SLR Notes: Yes, this item is reviewed on their standard inspection. 6 Part E: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: See question 4 pertaining to recommendations or loss of points. Total points scored for this section: 8 Total possible points for this section: 9 DUNS: 969115450 2009 Natural Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 13

PART F - Field Inspection Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only = No Points Info Only Info Only Name of Operator Inspected: Wisconsin Power and Light Company (Alliant Energy) Name of State Inspector(s) Observed: Tom Reisdorf, Pipeline Safety Engineer Location of Inspection: Mauston, Wisconsin Date of Inspection: September 15, 2010 Name of PHMSA Representative: Glynn Blanton, USDOT/PHMSA State Programs SLR Notes: Tom Stemrich, Pipeline Safety Program Manager, was present during the inspection visit. A construction and records review was performed in the Mauston office. A meeting was conducted in Alliant Energy's office with Ms. Rosanne Rogers, Gas Compliance and Operation Support Manager and Mr. Matthew Weir, Engineering Department. An overview of the construction project located in the Castle Rock area was reviewed. The proposed project consist of installation of 4 & 6 inch PE pipelines and service lines along 32nd Avenue in Castle Rock to serve the existing and new homeowners in Half Moon Bay, Bay view Estates, Three Rivers, O'Dells Bay and Pine Lake subdivisions. A review of the leakage survey performed by Alliant Energy in the Mauston, Tomah and Wisconsin Rapids was reviewed by Tom Reisdorf. No leaks were found in the areas during the surveys and the operator is required under the Wisconsin Public Service Commission rules to perform two leakage surveys within a seven and one half month period during the calendar year. 2 Was the operator or operator's representative notified and/or given the opportunity to be present during inspection? New 2008 Yes = 1 No = 0 1 1 SLR Notes: Yes, the operator Wisconsin Power and Light Company was notified by Tom Stemrich ten days prior to the inspection performed on September 15th. 3 Did the inspector use an acceptable inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Previous Question F.2 Yes = 2 No = 0 2 0 SLR Notes: No. The inspector did not use a guideline document to perform the office and field inspection. Notes were taken by the inspector on the items observed and found during the inspection. WI PSC does not use an established form for their inspections except for the standard inspection. 4 Did the inspector thoroughly document results of the inspection? Previous Question F.3 Yes = 2 No = 0 2 2 SLR Notes: Yes, Tom Reisdorf, Pipeline Safety Engineer was very thorough in the review of the operator's records and field activities being conducted by contractor personnel in the installation of the PE pipelines in Castle Rock, WI. 5 Did the inspector check to see if the operator had necessary equipment during inspection to conduct tasks viewed? (Maps, pyrometer, soap spray, CGI, etc.) New 2008 Yes = 1 No = 0 SLR Notes: Yes, the operator had all necessary equipment available at the construction site and during the office review records. 1 1 6 What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) New 2008 Info Only = No Points SLR Notes: Office review of leakage survey and new construction inspection was performed. Info Only Info Only 7 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) New 2008, comprehensive question worth 2 points total Yes = 2 No = 0 Needs Improvement = 1 2 2 DUNS: 969115450 2009 Natural Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 14

a. Procedures b. Records c. Field Activities/Facilities d. Other (Please Comment) SLR Notes: Yes. The inspector reviewed the operator's procedures, records and field activities. 8 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Liaison will document reasons if unacceptable) Previous Question F.8 Yes = 2 No = 0 2 2 SLR Notes: Yes, Tom Reisdorf demonstrated adequate knowledge about the pipeline safety regulations and items to review during the inspection performed on September 15th in Mauston, WI. 9 Did the inspector conduct an exit interview? (If inspection is not totally complete the interview should be based on areas covered during time of field evaluation) Previous Question F.10 Yes = 1 No = 0 1 1 SLR Notes: inspection was completed. Yes, an exit interview was performed by Tom Reisdorf with Rosanne Rogers, Alliant Energy Gas Compliance and Operations Support Manager, after the 10 During the exit interview, did the inspector identify probable violations found during the inspections? Previous 1 1 Question F.11 Yes = 1 No = 0 SLR Notes: Yes, the inspector did note and explain during the exit interview two areas of concern. The areas of concerns were notation of leakage survey dates on the leakage survey map and patrolling information on the bridge crossing located on North Union Street in Mauston, WI. 11 What did the inspector observe in the field? (Narrative description of field observations and how inspector Info Only Info Only performed) Info Only = No Points SLR Notes: Observed the installation of PE pipelines in the Castel Rock, WI areas by Alliant Energy contract construction crews. A records review was conducted in the Mauston, WI office on the leakage surveys performing in the last twelve months. 12 Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) Info Only Info Only = No Points SLR Notes: No best practices were found or observed that could be shared with other states during the field inspection. Info Only 13 Field Observation Areas Observed (check all that apply) Info Only = No Points a. Abandonment b. Abnormal Operations c. Break-Out Tanks d. Compressor or Pump Stations e. Change in Class Location f. Casings g. Cathodic Protection h. Cast-iron Replacement i. Damage Prevention j. Deactivation k. Emergency Procedures l. Inspection of Right-of-Way m. Line Markers n. Liaison with Public Officials DUNS: 969115450 2009 Natural Gas State Program Evaluation Info Only Info Only Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 15

o. Leak Surveys p. MOP q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs C. Tapping D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other SLR Notes: Plastic fusion & welder cards were checked and verified by inspector. Bridge crossing at North Union Street was checked for atmospheric corrosion. 14 Part F: General Comments/Regional Observations Info Only = No Points Info Only Info Only SLR Notes: See question 3 pertaining to recommendations or loss of points. Total points scored for this section: 10 Total possible points for this section: 12 DUNS: 969115450 2009 Natural Gas State Program Evaluation Wisconsin WISCONSIN PUBLIC SERVICE COMMISSION, Page: 16

PART G - PHMSA Initiatives - Strategic Plan Points(MAX) Score Risk base Inspections - Targeting High Risk Areas 1 Does state have process to identify high risk inspection units? Yes = 1.5 No = 0 1.5 1.5 Risk Factors (criteria) to consider may include: Miles of HCA's, Geographic area, Population Density Length of time since last inspection History of Individual Operator units (leakage, incident and compliance history, etc.) Threats - (Excavation Damage, Corrosion, Natural Forces, Other Outside Forces, Material or Welds, Equipment, Operations, Other) SLR Notes: Yes, Wisconsin Public Service Commission's Criteria for Inspecting Natural Gas Utilities address a few of these items on page 2, section 7. However, additional language or process needs to be developed that includes the following risk rank items of population density, geographic area, length of time since last inspected, history of individual operator units on leakage, incident and compliance history and threats. 2 Are inspection units broken down appropriately? (
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