Employees who use odorant and their supervisors should refer to the Odorant Use, Handling and Spill Training Guide, Appendix B.

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1 03/25/10 1 A. SCOPE This procedure covers procedures used to pre-plan for, prevent and respond to odorant spills. B. GENERAL INFORMATION As part of normal operations, liquid mercaptan is stored in various locations on We Energies property. (See appendix A ) In some cases, it is also transported between company properties on special trailers. Odorant storage may also require We Energies to provide basic chemical information on mercaptan to local Public Safety Agencies (PSA) to allow for proper response if there was a spill. Appendix A lists the PSA that would respond to any request for emergency service. Employees need to be aware of the physical properties of mercaptan and the importance of spill prevention and proper handling. The Material Safety Data Sheet (MSDS) for mercaptan provides the basic information for response to a spill. It should be followed to make sure that employees, emergency responders and the public are protected from any hazards. The Department of Transportation Emergency Response Guidebook, specifically guide number 130, can also be followed to assure proper spill response. Employees who use odorant and their supervisors should refer to the Odorant Use, Handling and Spill Training Guide, Appendix B. Odorant containers should be marked so that emergency responders are aware of the types of chemical hazards that may be present at our odorant tanks. Appendix B shows appropriate markings for fixed odorant containers and containers in transportation. C. REPORTING REQUIREMENTS The current supplier s MSDS sheets and the We Energies emergency response plan for mercaptan spills should be shared with the local authority having jurisdiction, usually the Fire Department. Emergency Planning and Community Right to Know Act (EPCRA) reporting shall be submitted by the Corporate Environmental group (414) xxx-xxxx (redacted). Locations for which Environmental reports are designated with a symbol in appendix A. D. FORM REFERENCE CORPORATE SAFETY PUBLIC SAFETY AGENCY CONTACT FORM MSDS FOR LIQUID ODORANT FROM WE ENERGIES CORPORATE SAFETY SITE; CHES.

2 03/25/10 2 E. OTHER REFERENCES Department of Transportation Hazardous Materials Response Guide, Guideline number 130. We Energies programs on Chemical Spill, Hazard Assessment Guideline, manufacturer's MSDS for liquid odorant. Corporate Hazardous Material Security Plan in compliance with 49CFRpart 172. F. NOTES None. PROCEDURE STEP 1. Gas engineering, working with Occupational Health and Safety (OH & S) and corporate Environmental Department, develops an We Energies Chemical Spill Plan for odorant 2. Spill plan is shared with company management and employees 3. Resources needed to implement the Chemical spill plan for odorant are obtained and stored locally in each area where needed. ADDITIONAL INFORMATION Final document approval for Odorant Preplanning is conducted to assure completeness and accuracy. Plan is shared at monthly safety meeting or special training, as needed. Gas Central Dispatch and Gas Control are made aware of plan and its contents Elements include all physical resources needed to control an odorant spill and retain any recovered odorant or contaminated soil or materials. these include: - PPE such as kevlar suits, booties, etc. - drums for storage of contaminated soil or other products - etc. (place here) 4. Area manager and supervisor assures gas operations employees and stores employees are trained in proper collection storage and disposal of contaminated materials. Training should be conducted by Gas Training and Development or supervisors that are knowledgeable in odorant spill procedures. Training should be conducted upon

3 03/25/10 3 assignment to work dealing with odorant and rosters should be recorded. See Appendix B for training guide on odorant 5. OH & S determines which PSA's have jurisdiction in locations where liquid odorant is stored or transported and a complete list be developed. 6. PSA's that may respond would be contacted by We Energies to assure that the odorant spill plan and the MSDS for odorant is shared with them 7. Odorant tanks are marked according to the Chemical spill plan for odorant. List (see Appendix A) shows odorant storage location and jurisdictions for PSA's (public safety agencies) that would respond to an odorant emergency. MSDS for odorant and the Chemical Spill plan for odorant spills should be shared with PSA's by local management. Gas Engineering provides standard signs and markings to assure compliance. 8. In the event of a spill, follow guidelines Reference Appendix B. contained in this document and the We Energies chemical spill plan for liquid odorant. END OF PROCEDURE STEPS

4 03/25/10 A-1 APPENDIX A -ODORANT STORAGE LOCATIONS AND CAPACITIES REDACTED Portable Trailer Mounted Containers: REDACTED Service centers where these portable trailer mounted containers are stored must implement a formal security plan as designated in the Corporate Hazardous Material Security Plan in compliance with 49CFRpart 172.

5 03/25/10 B-1 APPENDIX B Odorant Spill Prevention Training Guide Description and overview: A colorless liquid with a strong sulpher like odor. Liquid and vapor are extremely flammable. Vapor may cause flash fire. May cause skin irritation. Strong odor may result from small spill resulting in public safety issue relating to "gas odors". Prevent all spills by using extreme care when handling this product. See MSDS for complete chemical information. Liquid odorant properties are listed below: D.O.T. Technical name: t-butyl mercaptan, methyl ethyl sulfide We Energies locations: Gas operations gate stations where odorant is stored and / or transported. CHES Number: 1578 UN Number: 3336 Manufacturer: CHEVRON, INC. Flammable Liquid Vapor Pressure Extremely Strong Odor Flammable Range Flash Point <0 F F Gassy Smell 1.7% to 12% in air (est.) GENERAL RESPONSIBILITY It is the responsibility of the Manager - Gas Measurement to implement this plan through the appropriate field personnel. Gas Control should also be familiar with these procedures and assist by contacting appropriate employees as needed. Emphasis will be placed on avoiding odorant spills by all employees or others. Accomplish this through proper odorant handling techniques and procedures. Employees who work with odorant systems or deliver odorant will be trained according to these procedures, and will be provided adequate supervision to assure proper odorant spill handling. Liaison with local Emergency Government and Fire Departments will be provided for by Occupational Health and Safety and the EPCRA Coordinator of Environmental. Training Requirements: Employees who work or transport odorant should be trained upon assignment and periodically thereafter. Training should cover the complete odorant spill chemical spill plan and procedures and any Haz Mat endorsements needed for transporting odorant over the road. In addition, portable trailer mounted containers which exceed 119 gallons are considered bulk transport. Additional signage and security plans may need to be established where these trailers are kept.

6 03/25/10 B-2 Medical Requirements: Respiratory equipment use requires medical approval. Contact Corporate Medical Department for assistance in employee approvals for employees. Internal Notifications-Information Needed: The following information should be provided to Gas System Control when reporting an odorant spill. Gas Dispatch should also be made aware of the spill in case of customer calls about gas odors in the area. Supervisor s Name Department Name Name of person discovering Personnel involved in cleanup Name of chemical Spill site address and description of where spilled/released (to ground, waters, air, or within building) Date and time of spill Approximate amount of chemical Outside agencies notified Estimated time required to clean up Personal Protective Equipment Choices: Major: Primary hazard is due to the flammability of the vapors generated from a large spill. Considered practically non-toxic if inhaled or swallowed. No more than slightly toxic if absorbed through the skin and slightly irritating to the eyes. Wear eye protection in the form of chemical goggles, or faceshield where splash hazard is present. Wear appropriate chemical resistant clothing such as disposable coveralls or rubber apron, disposable boot covers and chemical resistant (neoprene) gloves. Rinse immediately if skin exposure occurs. Remove any exposed clothing as soon as possible and dispose with other recovered material. Avoid breathing vapor or mist. If engineering controls (ventilation) can not prevent breathing of vapors in work area, wear a full face piece supplied air respirator such as a SCBA or SAR with escape bottle. Primary respiratory hazard is due to the flammability of vapors from a large spill. Exposure levels of less that 20 parts per million (ppm) require no respiratory protection. Breathing zone levels from 20 ppm to 50ppm, organic vapor R-100 filter mask respirators can be worn. Minor: Considered practically non-toxic if inhaled or swallowed. No more than slightly toxic if absorbed through the skin and slightly irritating to the eyes. Wear eye protection in the form of chemical goggles, or face shield where splash hazard is present. Wear appropriate chemical resistant clothing such as disposable coveralls or rubber apron, disposable boot covers and chemical resistant (neoprene) gloves. Rinse immediately if skin exposure occurs. Exposure levels of less that 20 parts per million (ppm) require no respiratory protection. Breathing zone levels from 20 ppm to 50ppm, organic vapor R-100 filter mask respirators can be worn.

7 03/25/10 B-3 SPILL CONTROL - Preplanning Company Facilities where odorant is stored or trailers that transport odorant shall be marked to adequately warn emergency responders about the nature of the chemical. The following basic markings shall be installed where visible to emergency responders on trailers, tanks or on the outside of buildings where odorant is stored: D.O.T. Class 2 Flammable gas label with UN number Available through Brady sign. Brady stock number B946 SSV Numbers Brady stock Blue = 2, Red=3, Yellow = 0 NFPA 704 Hazard Warning Label with correct hazard members. Available through Brady. Lot number B946 Vinyl and 6 Quick Align Die cut letters. In addition, the capacity and the maximum fill quantity shall be posted on the storage tank. Tools and Equipment Needed for Spill Response: Areas that have odorant transport trailers and odorant storage at stations shall have available for use the following materials needed for spill control: 55 Gallon metal recovery drums with tight fitting tops, labeled "Odorant-non hazardous, non-regulated waste" CHES label number pounds of commercial absorbent material. Absorbent pigs or other suitable material 3 12' by 12' heavy (15 mil) plastic tarpaulins. Shovels and other hand tools. One gallon of household bleach and 5 gallons of water. (prevent freezing in cold weather) 1 roll high quality duct tape General Spill Considerations: KEEP UNAUTHORIZED PERSONNEL AWAY. IN CASE OF FIRE, EVACUATE AREA. CALL FIRE DEPARTMENT if needed.

8 03/25/10 B-4 IMMEDIATELY NOTIFY DUTY SUPERVISOR AND SYSTEM CONTROL AT XXX-XXXX (redacted) SPILL RESPONSE INSTRUCTIONS Wear appropriate protective equipment based on hazards present. Turn off all motors and engines. Ventilate the area and keep people and ignition sources away. Small spills can be absorbed in dry earth or sand and removed to a closed container for approved and controlled disposal. Large spills may present a flammable vapor hazard. Contain spill by building a dike using absorbent material. Consult with We Energies Environmental Department at 414-xxx-xxxx (redacted) and/or gas engineering to determine if neutralization should be attempted. Does not use strong bleach or other oxidizer for neutralization as fire or violent reaction can occur. Recovered liquid odorant, absorbents and soil can be placed in CHES marked metal 55 gallon drums for later disposal using recommendations from We Energies Environmental Department at xxx-xxxx (redacted). On Frozen Ground or Pavement: Use absorbent pigs or other barriers to keep spill from migrating away from the original spill area into sewers, basins or other natural openings Recover any contaminated snow or ice and place in metal recovery drum. Recover any liquid with absorbent material and place in recovery drum. Wash area with dilute bleach/water solution (20% bleach/80% water), repeat as needed, and recover liquid wash solution and place in recovery drum. Cover the area with a heavy tarpaulin or cover weighted down with crushed gravel or clay to prevent suppress any residual odors and prevent contact with rainwater and water run off. If poor weather prevents an efficient recovery, cover the area as described above and complete recovery and clean up as soon as possible. On Soil: Neutralize odorant contaminated soils using a dilute bleach solution (20% bleach/80%water). Do not use strong bleach or solid bleach as a violent reaction may occur. As an alternative, enzyme/bacterial treatment is acceptable based on site conditions and regulatory approvals. Recover the soil by excavating in a continuous, controlled manner minimizing fugitive odorant vapors. Cover the area with heavy plastic tarps if work is delayed. Place all soil recovered in metal drums and seal at once.

9 03/25/10 B-5 Fill metal drums leaving a 4 inch head space to allow for expansion. Personal Protective Equipment Cleaning Procedures/Tool Cleaning Dispose of any clothing or PPE that becomes contaminated with odorant in metal recovery drums with other recovered products. Tools that are contaminated can be cleaned with a dilute bleach/water solution (20% bleach/80% water). Storage and Inspection A follow-up inspection will be made at the spill site daily for one week to ensure that odorant vapors are not present in abnormal amounts. More frequent inspections may be required as the situation dictates or at the request of the Emergency Government, local agencies or the DNR. The filled or partially filled waste container will be inspected weekly for leaks, corrosion or deterioration until disposal. A written log will be kept of the inspections which will be attached to the permanent file record of the incident. On-site storage of waste materials will be limited to the following if the waste qualifies as a hazardous material (ignitability below 140 F): Amount of Material Up to 2 containers (55 gallon barrels) Greater than 2 containers (55 gallon barrels) or greater than 2205 pounds On-Site Storage Time 180 days 90 days Storage of waste materials on-site exceeding the above limits requires a license from the DNR. Non-hazardous waste requires no limitation on storage time but should be expeditiously handled and disposed of. Liquid odorant lost during handling operations but reclaimed by collection pans will be considered reclaimed and will be saved for its original intended purpose, the odorization of natural gas. Odorant lost during operations into the soil, gravel or pavement must be treated in such a way that the odor is neutralized. Waste Disposition: Container to be labeled: "Non-regulated Waste," Odorant CHES 1578, and date. Retain waste barrels. The Environmental Department (414)-xxx-xxxx and the Solid Waste Coordinator shall be contacted and are responsible for proper material disposal. Shipping: Use a DOT approved Hazardous Waste or Non-regulated Waste or Non-hazardous shipping label.

10 03/25/10 C-1 APPENDIX C Environmental Spill clean up suppliers: (From We Energies Environmental) This section contains a list of environmental release response contractors who are equipped to aid in the control and cleanup of oil or chemical releases. These services should be used if needed, in conjunction with We Energies internal capabilities. North Shore Environmental Construction N117 W18493 Fulton Drive Germantown, WI Phone: (262) We Energies Contract Number: xxxxxxxx, expiration: xx Veolia ES Special Services N104 W13275 Donges Bay Rd Germantown, WI Hour Phone number: We Energies Contract Number: xxxxxxx, expiration: currently expired Individual Emergency Work Orders may be created for each spill response. Veolia ES Special Services is a qualified Oil Release Response Organization (OSRO) with capability to respond to any oil release incident across our service territory at any time necessary. Clean Harbors Environmental Services, Inc N. Park Drive Butler, WI Hour Phone Number: (800) OIL TANK / (800) Secondary number (781) We Energies Contract Number: xxxxxxxxx, expiration: currently expired Clean Harbors Environmental Services is a qualified Oil Release Response Organization (OSRO) with capability to respond to any oil release incident across our service territory at any time necessary. TriMedia Consultants Robert M. Steede, P.E. rsteede@trimediaconsultants.com 300 South Front Street Marquette, MI Phone: (906) We Energies Contract Number: xxxxxxx, expiration: xx Contract is for spill response assistance mainly for PIPP.