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 #113 - Reduce the refueling distance requirements (0.25 miles) stipulated by Mitigation Measure B-AQ-1) at Grapevine Creek, Pacoima Wash, and Tujunga Wash, Segment 3.

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 #113, refueling would occur within less than 0.25 miles near Grapevine Creek, Pacoima Wash, and Tujunga Wash at designated 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); numerous locations along Segment 2B (see Variance Request #104), 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, each refueling zone is located a minimum of 200 feet from each subject waterway or natural topography or manmade berms would prevent a spill from migrating into the waterways. Sand bag berms would also be created to prevent a spill from migrating off of the refueling site or into downstream storm drains. Finally, A-frame fueling trucks, rather than full size trucks, are proposed to limit the potential amount of spillage.

• 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, 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.

- As proposed, A-frame fueling trucks shall be used instead of full size trucks.

- As proposed, sand bags shall be placed at culverts to prevent any accidental spill from entering the culvert system.

- 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 #113 Refueling Locations

Subject Waterway

Proposed Refueling Sites1

Distance and/or Obstructions between Refueling Site and Watercourse

Additional Mitigation

Grapevine Creek

North of Station #3936+79


South of Station #3940+00

North side: < 200', but railroad berm in place; topography level.

South side: 200'; slopes away from creek.

Install sandbag berms along both north and south sides to protect creek.
Pacoima Wash


North of Station #4149+87


South of Station #4153+87

North side: 200', slight topographic depression.

South side: 200', slopes away from wash.

Tujunga Wash


North of Station #4310+50


South of Station #4316+00

North side: >200', topography level.

South side: >200', slopes away from wash.

Install sandbag berm on north side to protect wash.

1. No refueling shall occur within the noted station numbers.


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

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