SAN FRANCISCO, CA 94102-3298

March 19, 1998

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

RE: Variance Request #56 - Reduce the refueling distance requirements (0.25 miles) stipulated by Mitigation Measure B-AQ-1 at the Dominguez Channel bore (Segment 4).

Dear Mr. Shauers:

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

• Boring of the Dominguez Channel is to be conducted to avoid the significant construction impacts associated with using open-cut construction methods and potential operation impacts (crude oil spill) within the channel and downstream San Pedro Harbor.

• Mitigation Measure B-AQ-1 requires that equipment be refueled 0.25 miles beyond all designated streams along the project ROW. Since equipment requiring refueling within a bore pit would need to be disassembled and moved, additional construction time would be required, resulting in increased air quality, noise, and traffic impacts.

• The Dominguez Channel is concrete lined at the proposed bore location. Therefore, if a spill were to occur during refueling, it would not be able to migrate into the channel.

• The following measures 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. 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 request allows for refueling and routine maintenance within the Dominguez Channel bore pits only if the measures stipulated above are followed. 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.

- 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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