SAN FRANCISCO, CA 94102-3298

October 5, 1998

Dean Shauers, Project Manager
Pacific Pipeline System, Inc.
12201 E. Arapahoe Road, C10
Englewood, CO 80112

RE: Variance Request #101 - Extension of the project pipeline to serve the Edison Pipeline and Terminal Company (EPTC) (a distance of 250 feet), Los Angeles County, Segment 5.

Dear Mr. Shauers:

We have reviewed the above-referenced variance request and approve your request, based on the following factor:

Air Quality. As proposed, the requested extension would include an approximate 250 foot bore, pipeline tie-in, and delivery terminal construction. These activities would generate additional emissions to those initially considered for the project. However, since the extension construction activities would be completed within a one to two month period, no long-term significant air quality impacts would result. All mitigation measures recommended for the reduction of air quality impacts shall be implemented.

Biological Resources. The proposed extension route was examined by a PPSI biologist (R. Maddox) on July 30, 1998. The area examined extended approximately 100 feet on either side of the proposed centerline of the bore, including proposed work areas. The entire alignment consists of disturbed habitat. The majority of the surface at the proposed bore pits is gravel, with the SCE substation yard being a combination of gravel and pavement. No sensitive vegetation or wildlife species were encountered during the investigation. No significant impacts to biological resources are anticipated.

Cultural Resources. The proposed realignment was examined by a PPSI archaeologist (K. Lord) on July 30, 1998. The area examined extended approximately 100 feet on either side of the proposed centerline of the bore, including proposed work areas. No evidence of prehistoric or historic resources were identified. Since the entire area has been previously disturbed by railroad, street, and substation construction, it is unlikely that any intact cultural resources remain. The previous literature review of the approved route along the flood control channel provided no information on any known sites at the proposed extension location. PPSI proposes to have a Native American monitor and archaeologist present throughout the excavation phases of the proposed extension. No significant impacts to cultural resources would result with the implementation of the measure noted below.

Environmental Contamination. The area of the proposed extension was previously surveyed for potential contamination in the original PEA and SEIR/EIR (see Table C.5.4 Active Regulatory Agency Listed Hazardous Waste Sites within 500 Feet of Proposed Route). No contaminated sites were identified within the area of the proposed extension. All measures outlined in the Construction Contingency Plan shall be implemented. No significant environmental contamination impacts are anticipated.

Geotechnical. The proposed extension is not located in an area of active faults or an area subject to lateral spreading. No significant geotechnical impacts would result.

Hydrology. The proposed extension would be perpendicular to Compton Creek, but would not cross or parallel any hydrologic features. Refueling within the bore pits (less than 0.25 miles of Compton Creek) would be required. No significant hydrological impacts would result with the implementation of the measures noted below.

System Safety. For the EPTC connection, PPSI proposes to construct and operate a delivery system materially identical to the other approved delivery stations for the project (Lynwood, El Segundo, Wilmington, and Ultramar). All of the metering systems, safety devices and standards applied to the other delivery facilities would be incorporated at EPTC. The 250 foot extension to EPTC represents a 0.04% increase to the total project length. The risk of a leak or rupture along this new 250 foot extension is 3.31x10-5 spills per year and 1.42x10-5 spills per year, respectively. The failure rates calculated for the entire project as part of the SEIR/EIR for leaks and ruptures included 5.4x10-4 spills per pipeline-mile per year and 2.7x10-4 spills per pipeline-mile per year, respectively. No significant increase in the level of system safety impacts would result.

Traffic. No increased traffic impacts are anticipated since construction activities would occur within the PPSI right-of-way (Los Angeles Flood Control Channel right-of-way) and SCE substation.

Other Issue Areas. Since the 250 foot extension represents a 0.04% increase to the total project length and is located within an industrialized area, no increased impacts would result for the following issue areas if the project mitigation measures are implemented: socioeconomics, public utilities, visual resources, or minority-low income.

- All applicable mitigation measures for the project shall be implemented at the subject location.

- Prior to the commencement of construction, property owner approval shall be submitted to the CPUC Environmental Monitor upon receipt.

- All construction equipment and materials, including excavated soils, shall be restricted to the established right-of-way and work areas.

- As proposed, a qualified archaeologist and Native American monitor shall be present during excavation activities. If any signs of cultural resources are identified, work shall cease immediately, and the site shall be evaluated using the procedures in the Cultural Resources Management Plan.

- The following fueling kit shall be installed around each piece of equipment fueled within the 0.25 mile zone, even if natural or man-made barriers are in place. The kit shall consist of an 8 by 8-foot area of plastic sheeting placed underneath or adjacent to the vehicle and the refueling truck. A 3 by 3-foot by 6-inch deep pan shall be placed underneath the vehicle being refueled. Each refueling truck shall also be equipped with automatic shutoff nozzles to prevent spillage from overtopping. In addition, absorbent material shall be placed around the filler pipe and the fueler shall be present throughout the entire fueling operation.

- Each refueling truck shall contain a fully stocked spill containment kit which includes absorbent pads, shovels, and appropriate spill containers.

- Parking of refueling trucks at the subject sites shall be prohibited.

- All drips, leaks, and/or spills from vehicles and/or equipment shall be excavated immediately and disposed of in appropriate, labeled containers.

- The location shall not be used for fuel or hazardous material storage.

- No parking or storage of vehicles (including personnel vehicles), equipment, pipe, or any other project-related items shall be allowed on adjacent roadways.

- Adjacent streets and sidewalks shall be swept manually or with water sweepers at the end of each day if visible soil material is carried onto paved public roads (as required by Mitigation Measure A-8).

- Implementation of this variance in accordance with the provisions noted above shall be verified on a random basis by a CPUC/ANF Environmental Monitor.


Andrew Barnsdale
Project Manager
cc: R. Borden, ANF
H. Rastegar, Aspen

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