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STATE OF MICHIGANBEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION*****In the matter of the application of WOLVERINE)PIPE LINE COMPANY for authority under 1929 PA 16)to construct, operate and maintain a pipe line for the)Case No. U-13225Transportation of liquid petroleum products.))DIRECT TESTIMONY AND EXHIBITS OFDONALD J. MAZUCHOWSKION BEHALF OF THEMICHIGAN PUBLIC SERVICE COMMISSION STAFFDate: February 15, 2002

PREPARED TESTIMONY OF DONALD J. MAZUCHOWSKICASE NO. U-13225PART I - QUALIFICATIONS1Q.Will you please state your name and business address.2A.My name is Donald J. Mazuchowski, 6545 Mercantile Way, Lansing, Michigan,348911.4Q.By whom are you employed and in what capacity?5A.I am employed as an Intrastate Pipeline Engineer Specialist on the Staff of the Michigan6Public Service Commission.7Q.Will you briefly describe your educational background and professional experience?8A.I was graduated from Michigan State University in June of 1977 with a Bachelor of9Science Degree in Biochemistry and a Bachelor of Science Degree in Chemical10Engineering in August of 1980. I was employed by Gearhart Industries in New York11from September of 1980 until June of 1981. I was put in charge of a well logging truck12and crew. I evaluated the gas reserves and productive possibilities of the gas and oil13wells in the western New York and northwestern Pennsylvania areas. Since January141982, I have been a Petroleum Engineer with the Staff of the Michigan Public Service15Commission. One of my principle duties with the Staff has been to make various16engineering studies related to the Commission's regulation of intrastate gas production,17proration and transmission. My responsibilities include well log analysis, geophysical18evaluation, drawing of isopach maps, evaluation of well tests and calculation of field19reserves. For pipeline applications, I have been responsible for field route reviews,20environmental reviews, economic feasibility studies, gas pipeline specifications and the21preparation and presentation of Staff cases for public hearing. My duties also involve

MAZUCHOWSKI - PART I1the issuance of Standard Well Connection Permits and Allowable Withdrawal Orders,2participation in intrastate gas purchase contract pricing cases, maintaining gas3production records and tabulating gas field proration balances.4Q.562Can you elaborate on what is involved in your environmental reviews of pipelineprojects?A.I analyze the potential environmental effects that a proposed pipeline project will have7on the state. This analysis includes an evaluation of the proposed route to minimize the8amount of new right-of-way utilized, minimize the amount of environmentally-sensitive9areas crossed by the pipeline and recommending the use of construction methods that10have the least impact on the environment. The projects are handled on a case-by-case11basis, with some requiring a more in-depth analysis than others.12Q.13Have you presented expert testimony before the Commission in the past onenvironmental issues and other areas of your responsibilities?14A.Yes, on numerous occasions.15Q.Have you participated in or attended any educational programs or seminars related to1617your work experience?A.I have completed engineering courses and seminars in Well Logging Fundamentals and18Applications; Reservoir Engineering; Petroleum Geology; Pressure Buildup and19Drawdown Analysis; Gas Supply; and, Natural Gas Engineering - Production and20Storage, among others. I have also completed the "Annual Regulatory Studies21Program" sponsored by the National Association of Regulatory Utility Commissioners

MAZUCHOWSKI - PART I1at Michigan State University and a Pipeline Safety Seminar sponsored by the U.S.2Department of Transportation.3Q.Are you a member of any professional societies or organizations?4A.Yes. I am a Registered Professional Engineer in the State of Michigan and a member5of the Michigan Section of the Society of Petroleum Engineers.3

DIRECT TESTIMONY OF DONALD J. MAZUCHOWSKICASE NO. U-13225PART I I1Q.Briefly describe Wolverine Pipe Line Company’s (Wolverine) proposal.2A.Wolverine proposes to construct the Spartan Pipeline from Meridian Road just south3of Okemos, Michigan to Marathon Ashland Petroleum’s Lansing Terminal near the4Lansing airport. The pipeline will consist of approximately 25 miles of 12-inch5diameter steel pipeline. 22 miles of the entire 25 mile route will be in the limited6access I-96 right-of-way, which is under the control of the Michigan Department of7Transportation (MDOT).8Q.Why is the Spartan Pipeline being proposed?9A.In March of 2000, Wolverine proposed its initial application to construct and operate10the Jackson to Lapaugh Pipeline, which began just north of Jackson, Michigan,11extends to Wolverine’s pump station near Stockbridge, and continues northwesterly12to the Lapaugh Station near St. Johns, Michigan. In the initial application and the one13filed in this matter, Wolverine stated the Mid-Michigan area is in need of more supply14of liquid petroleum products, due in part to the closure of the Total/UDS Alma15refinery in 1999. In Commission Order No. U-12334, issued on March 7, 2001, the16Commission found there is a need for the pipeline. However, the Commission only17approved the Southern portion of the Jackson to Lapaugh Pipeline because18Wolverine had withdrawn the northern portion of that application. On December 6,192001, Wolverine filed the Spartan Pipeline application, the subject matter in this case,20as a replacement to the northern portion withdrawn from their last application.

MAZUCHOWSKI - PART II21Construction of the Spartan Pipeline will enable Wolverine to take the pipeline2constructed in the late 1930's between Freedom Junction and its Lapaugh Station out3of service.4Q.5What type of liquid petroleum products are proposed to be transported byWolverine’s Spartan Pipeline?6A.Primarily, gasoline and fuel oil which are hazardous and flammable liquids.7Q.How are liquid petroleum products transported to market in the United States?8A.Pipelines are the most common mode of transportation. Pipelines transport9approximately 64% of the liquid product in the United States. Exhibit S-10(DJM-1) is a pie chart, which depicts the different modes of11transporting petroleum products for 1997. These numbers do not change much from12year to year.13Q.Why are pipelines the preferred way to transport liquid petroleum products?14A.Transportation by pipeline is the most feasible, economic and safest mode of15transportation. To replace the equivalent volume of product this pipeline would16deliver to the Mid-Michigan market, a fleet of trucks would be required to carry 27517loads per day, the equivalent of a tanker truck load about every 5 minutes each day.18The proposed pipeline will result in less congestion and safer roads in the entire Mid-19Michigan area. Transportation by pipeline is much less expensive than other20transportation modes. Pipelines are able to deliver a gallon of fuel from the producing

MAZUCHOWSKI - PART II31areas in the southern portion of the United States, to the major consuming areas of2the nation for a few cents a gallon. In addition, pipelines are inherently safer to3operate than other transportation modes and have a significantly lower accident rates.4Q.56Please compare the safety performance of liquid petroleum product transportation bypipeline with other transportation modes?A.Trucks have an extremely high rate of accidents when compared to pipelines. As7shown by Exhibit S- (DJM-2), trucks have an 87 times higher accident8rate than liquid pipelines. Fires or explosions are 35 times more likely with a truck9incident than a pipeline incident. In addition, the oil pipeline industry’s spill record has10been improved substantially over the last 30 years, with the number of spills11decreasing by nearly 40 percent and the volume of oil spill decreasing by about 6012percent. This can be attributed to technological advances in the design, construction,13operation and maintenance of pipelines, improved third party damage prevention14programs, as well as better and quicker response plans in the event of a leak.15Therefore, the safety performance of liquid petroleum product transportation by16pipeline is preferred over other transportation modes such as rail or truck.17Q.Have the environmental impacts of spills from pipelines changed recently?18A.Yes. The environmental impacts have been reduced because a large portion of the19barrels lost are later recovered through industry clean up efforts. Estimated direct20recovery from all liquid releases in the year 1998, from pipelines as well as tank farms

MAZUCHOWSKI - PART II41and pump stations, was nearly 80% of the liquid volume spilled. Wolverine2recovered 80% of the liquid volume in the Blackman Township spill in the year 2000.3Wolverine is assessing a plan for the remediation of the remaining contaminated soil.4Q.What is third party damage?5A.Damage that occurs to the outside of a pipeline, usually by parties other than the6pipeline operator, when power equipment is used during the excavation process.7Third party damage is one of the leading causes of pipeline incidents. Exhibit S-8(DJM-3) shows the petroleum product pipeline accidents by cause and9Exhibit S- (DJM-4) shows the volume released by cause for the period10from 1994-2000. As can be seen from Exhibit S- (DJM-4), accidents11from outside force damage which include third party damage is the leading cause of12petroleum product volume released. If you can minimize the chance of a third party13contact, the probability of a leak is significantly reduced.14Q.Would you please describe Staff’s review of the Wolverine’s proposal?15A.The Staff reviewed the proposal by reading the application and Wolverine’s prefiled16testimony and exhibits. Staff sent out discovery questions to Wolverine and examined17the answers. Staff met with representatives of Wolverine on several occasions. Staff18has also worked together with MDOT and Wolverine on the portion of pipeline19located in the I-96 corridor. We conducted a number of route reviews and examined20the impact to the public water wells in the vicinity of the pipeline. Staff also

MAZUCHOWSKI - PART II15investigated additional safety features for this pipeline.2Q.What is Staff’s position on Wolverine’s route selection for the pipeline?3A.Generally, Staff would prefer to locate the pipeline away from populated areas,4however we must consider overall feasibility, land ownership and terminal points.5Staff was not in favor of Wolverine’s proposal, in Case No. U-12334, which6traversed through the highly congested areas of Meridian Township and East Lansing.7However, after reviewing the proposed route in this case and the potential8alternatives, both in this case, and those presented in Case No. U-12334, the Staff9believes utilizing the I-96 corridor is the preferred route for the Mid-Michigan area.10Q.What are the benefits of the route of this pipeline?11A.The freeway corridor is isolated, fenced, has minimal easements and contractors have12to be permitted by MDOT before they are allowed to work inside the corridor. As13mentioned earlier, this corridor will minimize third party damage because of the14limited access provided by the highway and the regulation by the MDOT. The route15utilizes existing corridors almost the entire length, which in turn, minimizes the impacts16to the residents and their property and minimizes environmental damage. The route17has no residences within 50 feet of the pipeline and few residents within 150 feet from18the pipeline. In general, most residences are not located near the highway. Unlike19almost every other potential corridor, in the future, most residences will not build near20the edge of the freeway. The freeway corridor will act as a buffer area for safety.

MAZUCHOWSKI - PART II61Also, Wolverine has designed into this pipeline additional safeguards in addition to2what is required to meet the Federal Regulations.3Q.What additional safeguards have been designed into the pipeline?4A.Mr. Woodburn’s Exhibit A- (CSW-2), provides a comparison between5what is required by Federal Regulations and the additional safeguards Wolverine is6utilizing. Some of the more important safeguards are that: (1) Wolverine is adding7extra wall thickness for its pipe which will further minimize the potential for corrosion8leaks and make it more difficult to fail if there was a third party contact; (2) In the9sections of the pipeline to be directional-drilled, Wolverine will be utilizing additional10wall thickness and special coating for the pipe; (3) Redundant over-pressure11protection, experienced inspectors and extra coverage depths will be utilized; (4)12Wolverine will internally inspect (smart pig) each pipeline segment every 5 years; (5)13Wolverine will provide extra remotely operated mainline valves and hydrocarbon14detectors which will quickly shut down the pipeline in the event of a leak thus15minimizing the volume of any product lost; and (6) Aerial patrols will be scheduled16weekly.17Q.181920How does the route of the Spartan Pipeline compare to the route Wolverineproposed in Case No. U-12334 in Meridian Township and East Lansing?A.I compared the proposed Spartan Pipeline route with Wolverine’s original proposedroute through the highly congested area of Meridian Township and East Lansing. The

MAZUCHOWSKI - PART II71risk of third party damage is enormously reduced with the Spartan Pipeline route.2Utilizing the limited access I-96 corridor creates a distance buffer between the3businesses and residents. The previously proposed pipeline in Meridian Township4and East Lansing has 14 houses closer than 50 feet while the entire Spartan Pipeline5has none. The Michigan Gas Storage alternative, which was one of four Staff6recommended alternatives has more houses closer than 150 feet to the pipeline than7the Spartan proposal. The Michigan Gas Storage alternative was the most remote8location of the four alternatives. The previously proposed pipeline was very close to9the two schools, the water treatment facility, Meridian Mall, two retirement homes,10and it bisected apartment and condominium complexes. In the unlikely event of a11leak on the Spartan Pipeline, disruptions to the residents will be minimized because12the corridor is already isolated. Exhibit S- (DJM-5) lists these and13other differences.14Q.What is your opinion regarding the operation of the existing 8 inch pipeline in the15Meridian Township and East Lansing area versus the operation of the proposed16Spartan Pipeline?17A.Staff believes the Spartan Pipeline will be safer than the older existing Wolverine18pipeline that exists today in the Meridian Township and East Lansing area. The19Spartan Pipeline has more safeguards. The older existing pipeline has an increased20risk of failure which increases the threat of the groundwater aquifer becoming

MAZUCHOWSKI - PART II81contaminated. The older existing pipeline located in Meridian Township area,2operates over the Saginaw formation without the state of the art design features of the3Spartan Pipeline. The Saginaw formation contains the aquifer from which the Lansing4area draws its drinking water. The older existing pipeline, built in the late 1930's,5while still safe to operate, has a higher probability of a leak from third party damage6or other causes than a new state of the art Spartan Pipeline.7Q.89older existing Wolverine Pipeline in th Meridian Township area?A.1011Wolverine has stated upon completion of the Spartan Pipeline, they will remove theolder existing pipeline in the Meridian Township area from hydrocarbon service.Q.1213If the Spartan Pipeline is approved and placed in operation what will happen to theWhat has the Staff done to evaluate the potential effects the proposed pipeline mayhave on the drinking water supply in the area?A.In addition to meeting with our own geological engineers on this issue, Staff has met14with officials of the U.S. Geological Survey(USGS) and the Drinking Water and15Radiological Protection Division of the Michigan Department of Environmental16Quality(MDEQ). Staff met with these officials to discuss the potential impact of the17pipeline on the area’s groundwater, consequences of a spill, remediation methods and18contingency plans to minimize the risk. Most of the drinking water wells in this area19are covered with significant layers of impervious clay above the bedrock aquifer.20However, some wells do not have this protective layer and are at greater risk.

MAZUCHOWSKI - PART II91Currently the precise location of the areas without the impervious layers, that are2near water wells, are unknown but we believe the areas are small. The Staff agrees3with USGS and the MDEQ that it is difficult if not impractical in today’s society to4eliminate all new threats or risks to the area. That is the reason a state of the art5contingency and response plans would minimize any risk to these wells. Included in6the plan should be an aquifer vulnerability study near the pipeline attempting to locate7areas that do not contain the protective clay areas.8Q.What is the Wellhead Protection Program?9A.It is a state managed program developed by Municipalities, to protect public water10supply systems using groundwater, from potential sources of contamination.11Protection is provided by identifying the area contributing groundwater to public12water wells, identifying sources of contamination within the area, developing methods13to cooperatively manage the area, and developing a contingency plan for water14supply emergencies.15Q.Does Lansing have a Wellhead Protection Program?16A.Yes. Lansing had been involved with the MDEQ and the surrounding local1718communities in developing a plan for this area.Q.Mr. Pandy, in testimony for the City of Lansing submitted with its petition to intervene19in this case generally testified that the Mason Esker, which runs from DeWitt, through20Lansing, to Mason, is of concern because water moves very rapidly through the sand

MAZUCHOWSKI - PART II101and gravel of an esker. If contamination occurred in the Mason Esker, it would also2move very quickly and impact the drinking water. Do you agree with these3statements?4A.No. Most of the Lansing water wells are completed in the bedrock. In the unlikely5event of a leak, Wolverine’s contingency plan would contain the leak before it6reached the bedrock drinking aquifer. Currently in Lansing, many gasoline stations7have underground storage tanks which leaked and contaminated the ground with8gasoline, which is the main product transported in the Wolverine Pipeline. These9contaminated sites are in varying stages of remediation to remove the contamination10from the ground. I am not aware of any situation where a leak has affected Lansing’s11drinking water.12Q.1314the drinking water supply?A.1516Yes. Existing railroad and highway traffic, landfills, and other industrial sites cantransport or store potential hazardous liquids.Q.1718Are there existing facilities in the Lansing area that pose a similar or greater threat toIn your opinion, how does the Wolverine’s proposed Spartan Pipeline impact thelocal wellhead protection area?A.One of the main parts of a Wellhead Protection Plan is to address potential sources19or areas that could be a threat to the water supply. Once identified, contingency20plans are added to the plan to minimize threats to the water supply. The Lansing area

MAZUCHOWSKI - PART II111has a Wellhead Protection Program that has been in place since 1990, which has2adequately protected the local water supply and demonstrated Lansing is well3equipped to handle threats to their water supply. This same technology used to clean4up contaminates around underground storage tanks can be utilized to contain and5remove any potential contaminants from the Wolverine Pipeline. Wolverine should6work with the City of Lansing to develop a specific contingency plan to minimize any7impact to the area.8Q.910How do you know the contingency plan will be adequate to protect the local watersupply?A.The technology to clean up gasoline contamination is currently being utilized in the11Lansing area and to my knowledge gasoline has not contaminated the drinking water.12The unfortunate spill in Blackman Township, almost two years ago, of a larger13diameter higher pressure pipeline than proposed now by Wolverine, has shown with14proper planning and emergency procedures, significant damage to the environment15can be minimized. No water wells were contaminated and the spill posed minimal16permanent damage to the environment. Wolverine recovered 80% of the product17lost and has removed and replaced, as much as practical, the contaminated soil18around the site of the leak and nearby creek bank. Wolverine is monitoring the area19and continuing to work with the MDEQ. Wolverine has shown that with the help of20the Federal, State and Local officials, they can effectively contain a leak and protect

MAZUCHOWSKI - PART II121the public as well as their source of drinking water. Furthermore, as a last resort type2of protection, Lansing’s water supply can be gathered in a central location and3treated to remove any contaminant that may reach the water supply.4Q.What impact does abandoned water wells have on the proposed pipeline?5A.Abandoned wells that are not properly plugged are a potential threat to contaminate6the water supply system. Any type of contaminate spilled nearby that enters the7abandoned well bore could potentially pose a threat. Lansing is working on a 108year plan to plug these wells in the area.9Q.What should be done to reduce the threat of contamination along the pipeline route?10A.Lansing has identified 73 abandoned wells, approximately a half mile from the11pipeline. Even though Wolverine’s pipeline has the proper safeguards to operate12safely in this area, Wolverine’s contingency plan should address the location of the13abandoned wells to assure, in the unlikely event of a spill, that contaminants would14not get into these wells. In addition, Staff believes it would be prudent for Wolverine15and the City of Lansing to develop and implement a plan to properly plug the16abandoned wells in the near future. Plugging these wells would provide another layer17of protection near the pipeline as well as minimize threats to the Wellhead Protection18Area from a number of other sources.1920Q.What is your opinion regarding the environmental impact if the pipeline isconstructed?

MAZUCHOWSKI - PART II1A.13The pipeline follows or is in existing right-of-way for essentially its entire length.2These areas have previously been disturbed and have not damaged the environment.3Staff believes the pipeline will cause minimal impact to the environment if constructed4and operated as proposed in the Environmental Impact Report.5Q.Who is responsible for Pipeline Safety regulation of the proposed pipeline?6A.The Office of Pipeline Safety (OPS) of the U.S. Department of Transportation7regulates the safety of the pipeline. Exhibit S- (DJM-6) contains a letter8from OPS which explains the jurisdiction and the actions taken by OPS to date.9Exhibit S- (DJM-7) is the OPS data depicting the decrease in the10number of accidents and volume of each accident on a yearly basis.11Q.What is your opinion of the safety of the proposed pipeline?12A.Staff believes that the pipeline is designed in a manner that exceeds the Hazardous13Liquid Pipeline Safety Regulations administered by the OPS and can be operated in a14safe manner. However, additional safety features can add protection that would15further reduce the possibility of a leak and reduce the threat to Lansing area’s16drinking water.17Q.What additional safety features are you recommending?18A.Staff recommends Wolverine install at least two automatic-operated mainline valves19in the I-96 corridor, to provide for rapid shutdown of any failed pipeline segment.20These valves would remove the chance of human error if a larger leak occurred. In

MAZUCHOWSKI - PART II141the alternative, Wolverine could install a safety device that would automatically detect2leaks. In addition, Staff recommends Wolverine utilize pipe with a wall thickness of30.5 inches in the area underlain by the Mason Esker. The extra wall thickness will4provide an extra layer of protection against corrosion leaks or from third party5damage. Finally, Staff recommends the Commission require Wolverine to develop a6specific detailed Emergency Response Plan for this pipeline and work with State and7Local public safety officials to ensure the plan can be carried out.8Q.What is Staff’s recommendation regarding the application?9A.Staff recommends the Commission approve Wolverine’s request contingent on10Wolverine agreeing to the additional safety features mentioned above. Staff believes11the Spartan Pipeline as proposed by Wolverine together with the additional safety12features proposed by Staff can be operated in a manner that will minimize any safety13risk to the general public as well as to the groundwater.

Case No.:Witness:Exhibit No.:Date:Page:U-13225Mazuchowski, Donald J.s(DJM-2)February 15,2002loflRelative Occurrence of Transportation AccidentsPer Ton-Mile of Oil Transported, 1992-1997EventPipeline a -FatalitylnjwFire/ExplosionRail Tank ship1.01.01.02.72.68.64.00.71.2?he rates of occurrence are based on a value of 1 .O for pipeline.safety record.Source: Association of Oil Pipe Lines.fa.BargeTruck10.20.94.087.32.334.7Values of less than 1 .O indicate a better

Petroleum product pipeline accidents by cause for1994-2000EaIcn400; 3502 300! 250#200E 1502 100z 50330Office of Pipeline Safety Data

Petroleum product volume released by cause 0000500000Office of Pipeline Safety Data

Case No.:Witness:Exhibit No.:Date:Page:U-13225Mazuchowski, Donald J.s(DJM-5)February 15,20021 of1Route ComparisonMeridian Township/East Lansing & Spartan Pipeline RoutesMeridian Township/E.L.(U-12334)Spartan Pipeline(Current Case)Meridian Township/E.L.Meridian Road toLansing Terminal8 miles25 milesTotal lengthStockbridge - TerminusStockbridge - LaPaugh42 milesMeridian Rd.Lansing Terminal25 milesLimited access corridorNoYes - 22.5 milesSchool yards crossedEdgewood ElementaryDonley Elementary0Apartmentcomplexes crossedHamilton TraceMarquette Senior AptsCarriage Hills EastBrandywine Creek0Ember OaksSylvan GlenShaker HeightsBanyon ParkHeritage HillsTowar Gardens Area0Mall parking lots crossed10Number of housesless than 50 feet from pipeline140Number of apartment buildingsless than 50 feet from pipeline70Water treatment facilityless than 50 feet from pipeline10Retirement home adjacent to pipeline10YesYesPipeline segments comparedLength compared4’Subdivisions crossedMunicipal water wellslocated near pipeline

CentralU.S. Departmentof TransportslionRegionPipelins Safety901 Locus,Room 46264106-2641KansssCii.MOResearchandSpecial ProgamsAdminktrationCaseNo.:U-13225Witness:Exhibit No.:Date:Page:Mazuchowski,DonaldJ.s(DJM-6)February 15,2002lofl, CERTIFIED MAIL - RETURN RECEIPT REQUESTEDFebruary 14, 2002Mr. Mike KiddDirector - Gas DivisionMichigan Public Service6545 Mercantile WayP.O. Box 30221Lansing, MI 48909Dear Mr.CommissionKidd:This letter is in response to Mr. Proudfoot's letter datedJanuary 18, 2002, in reference to Wolverine Pipe Line Company'sfiling on December 6, 2001 with the Michigan Public ServiceCommission for an application to construct a 26 mile section ofits Spartan System, a liquid petroleum products pipeline, in theLansing, MI area. I am writing to confirm that the CentralRegion, Office of Pipeline Safety plans to inspect theconstruction of Wolverine Pipe Line Company's proposed Spartanproject and that jurisdiction for compliance with applicablepipeline safety regulations is the responsibility of the CentralRegion, Office of Pipeline Safety.The Central Region, Office of Pipeline Safety, has reviewed theWolverine Pipe Line Company's design plans and specificationsincluded with your letter and will further review itsconstruction standards in conjunction with our constructioninspections.The specifications submitted appear to besatisfactory.Our construction inspections will include reviewof more specific procedures and standards to ensure constructionof the pipeline in accordance with pipeline safety regulations.As you are aware, our responsibilities include ensuringcompliance with regulations that cover the design, construction,testing, operation, and maintenance of interstate and intrastatehazardous liquid pipeline facilities. The proposed pipeline mustcomply with these regulations. We normally initiate ourinspections in conjunction with the start of construction.I need to point out, however, that our regulations do not cover,. nor do we have the regulatory authority to address, siting orright-of-way concerns with regard to the installation ofpipelines.If I can be of additional assistance in this matter, please callme at (816) 329-3800.Sincerely,Ivan A. HuntoonDirector, Central RegionOffice of Pipeline Safetycc:Mr. Paul ProudfootSupervisor Gas Safety SectionGas DivisionMichigan Public Service Commission

r,Case No.:Witness:Exhibit No.:Date:Page:OFFICE OF PIPELINE SAFETYHAZARDOUS LIQUID PIPELINE OPERATORSACCIDENT SUMMARY STATISTICS BY YEARl/1/1986 - 1995199619971998199920002001TotalsNo. ofFatalities 1410903301436*242U-13225Mazuchowski, Donald J.(DJM-7)February 15,20021 of1s--PropertyDamage 16,077,846 13,140,434 32,414,912 8,813,604 15,720,422 37,788,944 39,146,062 28,873,651 62,166,058 32,518,689 81,083,269 42,810,659 62,864,796 43,108,560 115,703,745 20,893,539Gross Loss(Bbls)282,791395,854198,397201,758124,2

17 the answers. Staff met with representatives of Wolverine on several occasions. Staff 18 has also worked together with MDOT and Wolverine on the portion of pipeline 19 located in the I-96 corridor. We conducted a number of route reviews and examined 20 the impact to the public water

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