SAN FRANCISCO, CA 94102-3298

May 1, 1998

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

RE: Variance Request #73- Reduce the refueling distance requirements (0.25 miles) stipulated by Mitigation Measure B-AQ-1 at the Los Angeles River, Segment 3.

Dear Mr. Shauers:

We have reviewed the above-referenced variance requests, and approve your requests 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).

• As proposed, equipment would be refueled between station numbers 5141+96 to 5171+78 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), and at the Dominguez Channel bore (see Variance Request #56).

• As proposed, refueling parallel to the Los Angeles River would only occur when the right-of-way is on the west side of the railroad tracks away from the river; the railroad ballast would serve as a barrier between refueling and the river.

• In addition, refueling would occur within bore pits proposed for station numbers 5140+46 and 5143+46. These bore pits would be located on the east side of the tracks, adjacent to the river. However, the bore pits, in conjunction with the proposed refueling procedures, would serve to contain any fuel spills.

• 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 approval allows for refueling and routine maintenance between station numbers 5141+96 to 5171+78, as proposed (e.g., on the west side of the railroad tracks and within the project right-of-way, or within designated bore pits). 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 shall be restricted to the west side of the railroad tracks, within the project right-of-way.

- Protective fencing shall be installed around the Live Oak (station number 5147+10) five feet beyond the dripline of the oak tree (before pruning), or 15 feet from the trunk, whichever is greater.

- 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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