STATE OF CALIFORNIA, PETE WILSON, GovernorFile Code 2720 Pacific Pipeline

Date: June 4, 1998

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

Via FAX 303-792-0227

RE: Variance Requests #83 & #84 - Reduce the refueling distance requirements (0.25 miles) stipulated by Mitigation Measure B-AQ-1 at the Los Angeles River, Segment 3B.

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 impact (air quality, traffic, noise).

• As proposed under Variance Request #83 (see Table 1), refueling would occur at designated locations near the Los Angeles River that are either more than 180 feet from the river or on the opposite side of the railroad tracks from the river; the railroad ballast would serve as a physical barrier.

• Under Variance Request #84 (see Table 1), two refueling locations have been requested that are less than 100 feet from the river and where there are no natural or man-made barriers separating the refueling locations from the river. However, at both of these locations, PPSI proposes to use only smaller A-frame refueling trucks rather than full size fueling trucks to limit the potential volume of spill, and both areas are concrete lined.

• As proposed, equipment would be refueled at designated locations near the Los Angeles River using established refueling procedures approved for several locations along Segment 1 (see Variance Request #32, 43, 52, 64, and 66); several locations along Segment 3 at the California Aqueduct, Verdugo Wash, and Los Angeles River (see Variance Requests #62 and 73); four directional drill locations (see Variance Request #35); and at the Dominguez Channel bore (see Variance Request #56).

• The measures noted below and within Table 1 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 only at the approved locations (see Table 1) 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.

- Any storm runoff drainages within the refueling area need to be protected (especially, during any storm event).

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

Table 1 - Approved Refueling Locations

Proposed Refueling Location
Distance to
Los Angeles River
Station Number (Alignment Sheet)
Additional Mitigation
VARIANCE REQUEST #83
From Glendale Freeway overpass to where river is next to private road.
180 feet to 500 feet
4997+67 to 5016+72
(394 thru 397)
None.
After crossing one set of MTA railroad tracks and between maintenance buildings.
300 feet, separated from river by railroad ballast and buildings.
5034+97 to 5068+00
(398 thru 401)
None.
Between multiple sets of railroad tracks.
300 feet, separated from river by railroad ballast.
5068+00 to 5074+26
(401)
None.
East side of MTA railroad tracks.
25 feet, separated from river by railroad ballast and roadway.
5108+93 to 5119+83
(404 thru 405)
1. Protect roadway culverts during refueling with sandbags and remove after refueling.
2. No refueling allowed during precipitation.
VARIANCE REQUEST #84
East side of river along frontage road.
75 to 100 feet, separated from river by roadway.
5119+83 to 5132+46
(405)
1. A-frame refueling trucks required.
2. No refueling allowed during precipitation.
West side of railroad tracks just north of MTA main yard.
15 to 25 feet, separated from river by roadway.
5074+26 to 5108+22
(401 thru 404)
1. Protect roadway culverts during refueling with sandbags and remove after refueling.
2. A-frame refueling trucks required.
3. No refueling allowed during precipitation.

Sincerely,

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

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