SAN FRANCISCO, CA 94102-3298

July 30, 1998

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

RE: Variance Request #93 - Reduce the refueling distance requirements (0.25 miles) stipulated by Mitigation Measure B-AQ-1 at the Towsley Canyon bore (Stream Crossing #60), Segment 2B.

Dear Mr. Shauers:

We have reviewed the above-referenced variance request, and approve your request 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 required for the boring operation would need to be removed from the bore pits 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, safety).

• As proposed under Variance Request #94, refueling would occur within less than 0.25 miles of Towsley Canyon along the project right-of-way at station number 3649+81 and near station 3647+56 in an approved extra work space. Refueling would be conducted using established refueling procedures approved for five directional drill locations (see Variance Requests #35 and 66), and at the Dominguez Channel and Compton Creek bores (see Variance Requests #56 and #90). In addition, sand bag berms would be constructed to contain any spilled fuel outside of the bore pits. If a spill were to occur within a bore pit, it would be contained.

• The measures noted below 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.

- As proposed, a sand bag berm (12 sand bags long by 2 sand bags high) shall be placed perpendicular to each refueling area to block any spilled fuel. The refueling truck and the vehicle to be refueled shall be up-gradient of the sand bag berm

- As proposed, additional sand bag berms (3 bags long) shall be placed at the next down-gradient curb cut (drainage) and halfway between the fueling location and the down-gradient cut.

- 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 only at the approved locations and only if the stipulated measures are implemented. 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 at the subject sites shall be prohibited.

- 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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