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 #121 - Allow for 24-hour completion testing activities (scraper testing, geometry inspection, hydrotesting, etc.), seven days a week, at specific locations along Segments 4 and 5.

Dear Mr. Shauers:

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

• As proposed, Segments 4A, 4B, and 5 would be filled at the Lynwood Station for hydrostatic testing. The dewater points for hydrostatic testing of Segments 4A and 4B would be at Fernwood and Sante Fe Avenue, immediately adjacent to the Lynwood Station. Segment 5 would be dewatered in a storm drain at Anaheim and Henry Ford. The proposed fill and dewater locations would also be used for pig launches/receiving required for scraper testing and geometry inspection. In addition, scraper testing and geometry inspection of Segments 4A and 4B would be conducted at the El Segundo Station in the Chevron El Segundo Refinery and at the Cornfield Yards in Los Angeles.

• In accordance with Mitigation Measure N-1, pipeline construction activities shall occur between 7:00 a.m. and 7:00 p.m., Monday through Saturday (or for a shorter period if stipulated by applicable noise ordinance). Due to the volume of water required for hydrotesting, PPSI and its contractors estimate that water fill and dewater operations could take approximately 15 consecutive hours per pipeline segment, based on water flow availability or any unforeseen problems that could arise. Likewise, continuous scraper testing and geometry inspection is requested to facilitate the completion of these tests, especially if any unforeseen problems arise.

• With the exception of the Anaheim and Henry Ford location, all of the subject sites are located within industrial or light industrial areas. The Anaheim and Henry Ford site is located within a mixed industrial and commercial area. None of the subject test locations lie within a radius of 300 feet of any residential properties. No additional land use impacts are anticipated from conducting 24-hour testing activities, seven days a week.

• The measures noted below shall be implemented:

- All applicable mitigation measures shall be implemented during testing activities at each proposed location, including noise abatement.

- 24-hour testing activities, seven days a week, shall be limited to the specific test locations identified in Variance Request #121. If the test locations are changed or if additional test locations are added, these sites shall be located at minimum 300 feet from any sensitive receptors (residences, churches, schools, recreational sites, etc.), subject to the review and approval of the California Regional Water Quality Control Board (CRWQCB), applicable local agency, and CPUC/ANF Lead Environmental Monitor.

- Prior to the commencement of 24-hour testing activities, seven days a week, at each proposed location, applicable CRWQCB NPDES permit approval, local agency approval, and written landowner approval shall be provided to the CPUC Environmental Monitor.

- Any complaint from the public associated with extended hours shall be reported to Aspen within 24-hour in writing.

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

- Signs shall be posted at any construction areas within 300 feet of residences, informing them of the activities, the date and time and anticipated period of 24 hours construction.


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

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