SAN FRANCISCO, CA 94102-3298

September 23, 1998

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

RE: Variance Request #112 - Install the project fiber optic conduit under the Santa Clara River via directional drill, Segment 2B.

Dear Mr. Shauers:

We have reviewed the above-referenced variance request, and our decision of approval is based on the following factors:

• The pipeline in this area was installed using a directional drill during the winter of 1997/98. However, given problems with the pipeline directional drill (continuous frac-outs into the Santa Clara River), the fiber optic conduit was not installed within the pipeline casing at that time.

• As proposed, the fiber optic conduit directional drill would be approximately 1,300 feet long. Extra work spaces would be used as exit and entry points for the directional drill operation approximately 200 feet north and 500 feet south of the Santa Clara River, respectively. Refueling of directional drill equipment is also proposed within the entry and exit point work spaces.

• An additional 1,250 feet of fiber optic conduit would be installed within the approved PPSI right-of-way using trenching to connect the conduit to the existing buried conduit to the north and south of the directional drill exit and entry points (the directional drill for the pipeline was approximately 2,500 feet long), respectively. Open cut trenching of Feed Mill Road (instead of boring) would be required. Feed Mill Road is a two-lane roadway that is used as a service road for Magic Mountain, including emergency services access. Magic Mountain is open from 10:00 a.m. to 6:00 p.m., seven days a week until October 1; after October 1 Magic Mountain is open on weekends only. The right-of-way width would not exceed 25 feet for the trenched installation of the conduit. The trench depth would be approximately four feet.

• A biological resources survey of the directional drill entry and exit point work spaces (all other proposed activities fall within the approved PPSI right-of-way) was conducted by a PPSI biologist (E. Berg) on August 28, 1998. The extra work space for the directional drill entry point (to the south of the river) is mainly bare ground or mowed weeds. The extra work space on the north side of the river (directional drill exit point) is highly disturbed, also comprised of mostly bare ground. Adjacent to the site are several large cottonwood trees and the riparian habitat along the river. As proposed, exclusion fencing would be installed to separate the trees and vegetation from the extra work space. No wildlife species were observed on either site. No sensitive plant or wildlife species are anticipated on either site given their disturbed state. No biological impacts are anticipated with the implementation of the measures noted below.

• A cultural resources survey of the directional drill entry and exit point work spaces was conducted by a PPSI archaeologist (A. Knight) on August 31, 1998. No surficial evidence of prehistoric or historic resources were observed at either the entry or exit point work space sites. As proposed, each site would be monitored by a Native American monitor during construction. No impact to cultural resources is anticipated with the implementation of the measure noted below.

• The following measures shall be implemented:

- All applicable mitigation measures for the project shall be implemented at the subject location, including dust abatement and traffic control.

- Prior to commencement of directional drill activities, written land owner approval for both the entry and exit point work spaces shall be provided to the CPUC Environmental Monitor.

- Prior to trenching of Feed Mill Road, written County and land owner approval shall be provided to the CPUC Environmental Monitor.

- The size of the directional drill entry and exit point work spaces shall be limited to the minimum space necessary to conduct drill activities, with the boundaries clearly flagged. As proposed, exclusion fencing shall be installed at the dripline of the trees and along the boundaries of the riparian habitat near the directional drill exit point extra work space.

- As proposed, the right-of-way for trenched fiber optic conduit installation shall be limited to 25 feet in width. Trenching activities shall follow elevational contours and not change the existing grade.

- A Native American monitor and archaeologist shall be present during all 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.

- Use of the directional drill entry and exit point work spaces as refueling sites shall be limited to the refueling of directional drill equipment.

- The following fueling kit shall be installed around each piece of equipment fueled within the subject site. 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.

- 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.

- Open cut trenching of Feed Mill Road shall be conducted after October 1, 1998, Monday through Friday, unless allowed otherwise by Magic Mountain (written verification required).

- 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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