SAN FRANCISCO, CA 94102-3298

October 18, 1998

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

RE: Variance Request #109 - Extension of the project pipeline to serve the Huntway Refinery (a distance of approximately 1,600 feet), Carson, 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 installation of approximately 1,600 feet of pipe using standard trenching practices and pipeline tie-ins. 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 route centerline. The entire alignment consists of disturbed habitat. The majority of the surface surveyed was gravel and spoils piles from other construction activities. Vegetation consisted primarily of non-native weeds, grasses, and shrubs including castor bean and tree tobacco. No wildlife was observed. No sensitive vegetation or wildlife species were encountered during the investigation. No 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 route centerline. No evidence of prehistoric or historic resources were identified. Since the entire area has been previously disturbed by railroad construction, it is unlikely that any intact cultural resources remain. The previous literature review of the approved route along Alameda Street provided no information on any known sites at the proposed extension location. No significant impacts to cultural resources would occur 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 environmental contamination impacts are anticipated.

Geotechnical. The Pacific Pipeline and proposed extension traverse an area subject to lateral spreading. If the design parameters established for the main pipeline are followed for the proposed extension, this potential impact would be mitigated to a level of insignificance.

Hydrology. The proposed extension would not traverse any hydrologic features. Dominguez Channel is roughly 4,900 feet to the east. No increased impacts to hydrologic resources would occur.

System Safety. For the Huntway connection, PPSI proposes to utilize existing metering systems, safety devices, and standards designed into the PPSI Wilmington Pump Station. The 1,600 foot extension to Huntway represents a 0.23% increase to the total project length. The risk of a leak or rupture along this new 1,600 foot extension is 2.12x10-4 spills per year and 9.09x10-5 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 off of public roadways within the railroad right-of-way.

Other Issue Areas. Since the 1,600 foot extension represents a 0.23% 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.

- 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.

- Design and construction of the proposed extension shall be done in accordance with the design parameters established for the main pipeline for areas subject to lateral spreading.

- 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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