SAN FRANCISCO, CA 94102-3298

December 17, 1998

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

RE: Variance Request #115 (revised) - Modify the CPUC approval of Variance Request #115 which allowed the delay of the initial smart pig run from prior to operations (as required by Applicant-Proposed Measure SS-49**) to within 30 days of the commencement of operation.

Dear Mr. Shauers:

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

•      Variance Request #115 was approved by CPUC on September 23, 1998.

•    PPSI is now requesting that the initial smart pig run be allowed to take place within 120 days of "full operation," with contract execution with a smart pig company occurring within 30 days of full operation. PPSI defines "full operation" as the "first 7 consecutive days of delivering product." The delay has been requested to accommodate the typical backlog of smart pig companies.

•     The intent of the initial smart pig run is to establish the baseline condition of the pipeline so that the integrity of the pipeline can be monitored over time via an annual smart pig program (as required by Mitigation Measure SS-7). A couple month delay would have a nominal affect on the pipeline baseline condition.

•     The measures noted below shall be implemented:

- All applicable mitigation measures shall be implemented during project operation.

- The smart pig run shall take place within 120 days of the start of the start of line fill. Results of the smart pig run shall be provided to the California State Fire Marshal for their review and concurrence of accuracy. A copy shall also be submitted to CPUC.


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

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