SAN FRANCISCO, CA 94102-3298

May 16, 1998

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

RE: Variance Requests #66 & #82 - Conducting a directional drill at the Cuddy Canyon Creek and Cuddy Canyon Tributary crossings:

• Variance Request #82 - Directional drill, instead of trench, Cuddy Canyon Creek and Cuddy Canyon Tributary.

• Variance Request #66 - Reduce the refueling distance requirements stipulated by Mitigation Measure B-AQ-1 at the Cuddy Canyon Creek and Cuddy Canyon Tributary directional drill, Segment 1.

Dear Mr. Shauers:

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

• Under Variance Request #82, a directional drill of Cuddy Canyon Creek and Cuddy Canyon Tributary has been requested to avoid the significant construction impacts associated with using open-cut construction methods and potential operation impacts (crude oil spill) at these sensitive aquatic locations. In addition, traffic impacts on County Road 1531 and Lebec Road would be significantly reduced. The directional drill would be approximately 2,190 feet long, at a depth ranging from 26 feet at Cuddy Canyon Creek to a maximum depth of 34 feet.

Entry Site. As proposed, the directional drill entry point would be located on an approximate 200 foot by 400 foot site on the east side of Lebec Road, about 250 feet north of the banks of Cuddy Canyon Creek. The site is down-gradient from Cuddy Canyon Creek by approximately nine feet.

- On April 3, 1998, the site was surveyed by a PPSI biologist (J. Duncan). The area is about 80% disturbed with no vegetation present (possibly part of an old parking lot). Most vegetation occurs on the northern third of the site and consists of shrubs, rabbitbrush, yerba santa, buckwheat, and sage. Potential wildlife could include the coastal western whiptail and coastal horned lizard. Neither species was observed during the April 3 survey. Side-blotched lizards are abundant along the dirt berms surrounding the site. No impacts to biological resources are anticipated with the implementation of the measures noted below.

- The site was examined for cultural resources on April 3, 1998, by two PPSI archaeologists (M. Carlton and Q. Shup). No prehistoric or historic resources were identified during the survey. In addition, no cultural resources were identified during the original records search of the area conducted for the project. No impacts to cultural resources are anticipated with the implementation of the measure noted below.

Exit Site. The directional drill exit point would be located within the existing Pacific Pipeline right-of-way between the north and south bound lanes of Peace Valley Road. This area is approximately 100 feet southeast of the banks of the Cuddy Canyon Tributary. The area is below grade of the roadway, but has a culvert that drains a portion of the median. The use of this portion of the right-of-way as a directional drill exit point would not generate any additional impacts, in comparison to trenching at this location.

• As proposed under Variance Request #66, equipment would be refueled at the directional drill entry and exit sites using established refueling procedures approved for several locations along Segment 1 (see Variance Request #32, 43, and 52), four directional drill locations (see Variance Request #35), at the Dominguez Channel bore (see Variance Request #56), and at the Los Angeles River (see Variance Request #73).

The entry site is approximately 250 feet north and down-gradient from Cuddy Canyon Creek. The exit site is about 100 feet southeast of Cuddy Canyon Tributary and below grade of the surrounding roadways (north and south bound lanes of Peace Valley Road). As proposed, a culvert within the median would be protected during refueling activities, but would not be permanently blocked to prevent any water overflow onto the roadway surfaces during precipitation.

In order to refuel equipment in accordance with Mitigation Measure B-AQ-1 (greater than 0.25 miles from streams/creeks), directional drill equipment would need to be disassembled and 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).

• The following measures shall be implemented:

- All applicable mitigation measures for the project shall be implemented at the subject locations.

- The boundaries of each area shall be clearly flagged before clearing and grading activities commence.

- Prior to initial brush clearing and grading, a qualified biologist shall walk the areas to be cleared to verify that there are no active bird nests. If an active bird nest is found, the activities shall stop and PPSI shall consult with the CPUC for further instructions. In the meantime, no clearing and grading shall be conducted.

- During initial brush clearing and grading, a qualified biologists shall walk alongside or in front of the clearing equipment to salvage and relocated any coastal western whiptails, coastal horned lizards, or any other sensitive species that are uncovered.

- During any grading activity, a qualified archaeologist shall be present to ensure that no cultural resources are impacted. 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.

- All vehicle parking shall be confined to defined work areas.

- Any commercial or residential use within a radius of 300 feet from either site shall be provided with 72 hour notice of the intended use of each site and the construction schedule (copies provided to the CPUC Lead Environmental Monitor).

- Use of the entry site is limited to the drilling operations as described above.

- Adequate supplies shall be stored on-site to control drilling mud spills.

- If installation of the fiber optic conduit cannot be conducted during the directional drill operation, the CPUC Lead Environmental Monitor shall be notified immediately. Directional drill activities shall cease until a plan for fiber optic conduit installation is approved by the CPUC.

- 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.

- The culvert at the directional drill exit site shall be protected with sand bags during refueling operations. Sand bags shall be removed after each refueling operation if precipitation is present or forecasted.

- Each refueling truck shall contain a fully stocked spill containment kit which includes absorbent pads, shovels, and appropriate spill containers.

- Refueling trucks shall only remain at the directional drill entry and exit sites long enough to refuel and maintain equipment; parking of refueling trucks shall be prohibited. All equipment repairs shall be made in accordance with the distance stipulations of Mitigation Measure B-AQ-1.

- This variance approval allows for refueling and routine maintenance at the subject directional drill entry and exit sites. 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.

- Adjacent streets shall be swept manually or with water sweepers at the end of each day if visible soil material is carried onto paved public roadways (as required by Mitigation Measure A-8).

- Noise reduction measures shall be implemented, if legitimate complaints are received from the public.

- Implementation of these variances 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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