SAN FRANCISCO, CA 94102-3298

July 30, 1998

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

RE: Variance Request #104 - Reduce the refueling distance requirements (0.25 miles) stipulated by Mitigation Measure B-AQ-1)for stream courses along The Old Road and San Fernando Road, Segment 2B.

Dear Mr. Shauers:

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

• In order to refuel equipment in accordance with Mitigation Measure B-AQ-1 (greater than 0.25 miles from streams/creeks) construction equipment would need to be returned along the right-of-way to a location that meets the refueling criteria. Such an operation could delay construction and increase associated construction impacts (air quality, traffic, noise, safety).

• As proposed under Variance Request #104, refueling would occur within less than 0.25 miles of stream courses along The Old Road and San Fernando Road at numerous locations (see Table 1). Refueling would be conducted using established refueling procedures approved for several locations along Segment 1 (see Variance Requests #32, 43, 52, 64, and 66); several locations along Segment 3 (see Variance Requests #62 and 73); five directional drill locations (see Variance Requests #35 and 66); and at the Dominguez Channel, Compton Creek, and Towsley Canyon bores (see Variance Requests #56, 90, and 93). In addition, at each approved refueling location, the topography is such that a spill would flow away from the nearby watercourse and/or existing berming or curbing would prevent a spill from flowing into the watercourse. Finally, sand bag berms would be created to prevent a spill from migrating off of the refueling site (roadway surfaces) and to protect downstream storm drains.

• The measures noted below and in Table 1 shall be implemented:

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

- The following fueling kit shall be installed around each piece of equipment fueled within the 0.25 mile zone. 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.

- As proposed, a sand bag berm (12 sand bags long by 2 sand bags high) shall be placed perpendicular to each refueling area to block any spilled fuel. The refueling truck and the vehicle to be refueled shall be up-gradient of the sand bag berm

- As proposed, additional sand bag berms (3 bags long) shall be placed at the next down-gradient curb cut (drainage) and halfway between the fueling location and the down-gradient cut.

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

- This variance approval allows for refueling and routine maintenance only at the approved locations and only if the stipulated measures are implemented. Storage of fuel or other hazard materials, or vehicle/equipment repair shall not be allowed under the provisions of this variance.

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

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

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


Table 1 - Variance Request #104 Refueling Locations


Refueling Sites

Distance to Nearest Watercourse

Obstructions between Refueling Site and Watercourse


Additional Mitigation

The Old Road #1 near Edison Road (station #3708+94 to 3713+29)

100 feet north

Refueling site slopes away from watercourse. Existing berm. Approved - Protect (sandbag) storm drain on west side.
The Old Road #2 (station # 3738+59 to 3741+84)

200 feet south and east

Refueling site slopes away from watercourse. Existing berm. Approved
The Old Road #3 (station # 3755+83 to 3759+36)

200 feet north

Existing berm and concrete k-rail. Approved; refueling site restricted to station # 3755+83 to 3754+83 to avoid spill migration to storm drain on northern end.
The Old Road #4 (station # 3801+43 to 3804+93)

50 feet to drainage easement

Existing berm and curb. Approved - Protect (sandbag) storm drain and drainages (on east and west side).
The Old Road #5 near Hendron Trail (station # 3818+52 to 3822+02)

150 feet northwest

Refueling site slopes away from watercourse. Approved; refueling site restricted to station # 3818+52 to 3817+52 to avoid spill migration to off-site storm drain along eastern fence line.

Protect (sandbag) storm drains to the west.

The Old Road #6 near State Highway 14 overcrossing (station #3833+47 to 3837+47)

125 feet northeast

Refueling site slopes away from watercourse. Approved - Protect (sandbag) storm drain to the west and channel to the east.
San Fernando Road #1 (station # 3854+42 to 3858+42)

150 feet east

Existing berms, curb, and buildings. Approved - Protect (sandbag) storm drains to the east and west.
San Fernando Road #2 at I-5 overcrossing (station # 3870+68 to 3873+68)

100 feet north

Partial curbing. Approved - Protect (sandbag) curbing along eastern side of refueling site, subject to CPUC Environmental Monitor approval.
San Fernando Road #3 (station # 3889+65 to 3893+11)

200 feet north

Refueling site slopes away from watercourse. Existing berm and hillside. Approved


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

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