Project Memorandum - SFPP Carson to Norwalk Pipeline

Mitigation Monitoring, Compliance, and Reporting Program

The following constitutes the November/December 1998 Progress Report for the SFPP Carson to Norwalk Pipeline Project Mitigation Monitoring, Compliance, and Reporting Program (MMCRP) contract. It should be noted that daily and weekly reports have also been issued which summarize our monitoring activities.

PROJECT MEETINGS

The following meetings were held during November/December 1998:

­ November 12 - Contractor briefing meeting to discuss the project, safety issues, agencies involved, responsibilities of participants, communication channels and protocols, environmental compliance issues, compliance criteria and enforcement, and record-keeping procedures. Meeting was attended by representatives from Kinder Morgan and their subcontractors, ARB, and Aspen/CPUC representatives Kris Thorne and Christopher Meyer.

­ December 7 - Contractor briefing for field personnel and inspectors was held to discuss the project, safety issues, agencies involved, responsibilities of participants, communication channels and protocols, environmental compliance issues, compliance criteria and enforcement, and record-keeping procedures. Meeting was attended by representatives from Kinder Morgan and their subcontractors, ARB, and Aspen/CPUC representatives Kris Thorne and Christopher Meyer.

­ December 7 - A meeting was held to discuss air quality concerns regarding a proposal to begin a second construction spread (Variance #2). Participants were Dave Cornman, Ed Ferrer (Kinder Morgan); Charles Smith, David Marx, Craig Sakamoto (Woodward Clyde); and Vida Strong, Kris Thorne, Tom Murphy (Aspen for CPUC).

­ Weekly Status Meetings - Attendees: Ed Ferrer, Gerry Reed, Chuck Hughes (Kinder Morgan); Charles Smith, Jeff Reardon (Woodward Clyde); Chuck Wadell, Jim Lamont, Mike Elmore (Paragon Partners); Steve Hay, Steve Balkcom, Steve Highland (ARB); and Kris Thorne, Christopher Meyer (Aspen/CPUC).

- December 2: Discussed proposed schedule for start of mainline construction and expected rate of progress. Land agents are coordinating with local schools and cities.

- December 9: Clarified details of mitigation measures, contractor staffing, and procedures when contaminated soils located.

- December 16: Discussed draft forms, status of variance request regarding start of second spread. Contractor agreed to control dust from sweeper and removed delineators and equipment from ROW on time at end of the shift.

- December 23: Discussed proposed schedule for start of mainline construction and expected rate of progress. Land agents are coordinating with local schools and cities.

PRE-CONSTRUCTION COMPLIANCE DOCUMENTATION

Construction of the 14-mile SFPP Carson to Norwalk Pipeline Project will traverse the following jurisdictions (from west to east): City of Carson, County of Los Angeles, City of Long Beach, City of Paramount, City of Bellflower, City of Cerritos, City of Artesia, and City of Norwalk. As required by the terms of the mitigation measure and the permitting requirements of various other regulating agencies, SFPP is required to prepare numerous plans and obtain approval of these documents prior to construction. During the first half of November 1998, SFPP completed this pre-construction compliance review for the City of Long Beach. As of the end of December 1998, no pre-construction compliance documentation had been provided for the other applicable jurisdictions. Construction will not be allowed to commence in these other jurisdictions until pre-construction compliance documentation is reviewed and approved by the applicable agencies. Separate approval must also be granted prior to the start of construction of the station modification work at the SFPP facilities in Carson, Norwalk, Industry, and Colton.

City of Long Beach. Construction within the City of Long Beach commenced on November 16, 1998. Primary activities from November 16 through December 31 are presented in Table 1. Table 2 presents the non-compliance events that occurred during this time period.

Table 1 Construction Activities¹

1. Construction progress from November 16 through December 31.

Table 2 Non-Compliance Events¹

1. Non-compliance reports issued from November 16 through December 31.

 During November, preparation of the construction yard (staging area) at Cherry Avenue within the City of Long Beach occurred; this yard will be used for construction equipment and material storage, and construction management trailers. Potholing activities within the City of Long Beach were slowed because of mismarked and unmarked underground utilities. During the latter half of December, contaminated soil was encountered during trenching and was transported off site for disposal at an approved facility. Brittle cast iron water lines in the construction zone failed, causing flooding of the trench and interruption of local water service during the third week of December. The Long Beach Water Department was contacted and repairs were made. Construction in front of Bret Harte Elementary School occurred during the Christmas break to minimize construction impacts near this sensitive land use. A City of Long Beach inspector was on-site during November and December, and a representative from the California State Fire Marshall was on-site during the third week of December.

A general environmental training program was conducted for all project personnel on December 7. Topics discussed included cultural resources, air quality, the role of CPUC monitors, and the importance of abiding by the project mitigation measures.

VARIANCES, STAGING AREAS, TEWS, & OPSS

Between November 16 and December 31, the following variances, staging areas, temporary extra work spaces (TEWS), and overnight parking on street sites (OPSS) were approved/denied:

Table 3 Variances, Staging Areas, TEWS, & OPSS

1 Variance #1 for modification of the pipeline route through the City of Paramount was approved prior to the start of construction.

TEWS: Temporary Extra Work Space

OPSS: Overnight Parking on Street Sites (temporary).

CONSTRUCTION SCHEDULE

Table 4 presents the current construction schedule for the SFPP Carson to Norwalk Pipeline Project. As indicated in Table 4, Spread 1 is scheduled to construct in a sequential fashion traversing the first the City of Long Beach; then the Cities of Bellflower, Cerritos, Artesia; and finally the City of Norwalk. Spread 2 is scheduled to first complete construction simultaneously within the City of Carson and County of Los Angeles, and then move to the City of Paramount.

Table 4 Construction Schedule

1. Estimated construction schedule per SFPP, January 14, 1999.

2. Construction on Garfield Avenue only in the City of Paramount will be completed by Spread 1 immediately after completion of adjacent construction in the City of Long Beach (Cherry Avenue).

SFPP has been informed that delays and the addition of multiple crews/spreads per segment could cause additional costs due to increased monitor hours required. We will attempt to have the primary Environmental Monitor be responsible for both spreads, if at all possible. In some cases, the addition of multiple spreads requires the need for additional monitors.

PUBLIC ACCESS PROGRAM

• During December, the Newsletter describing the MMCRP for the SFPP Carson to Norwalk Project was finalized and sent to SFPP for January distribution. The Newsletter is expected to be mailed between January 20 and 27, 1999.

• During December, the web site for the project MMCRP was constructed; it is scheduled to be online in January. This web site provides updates on pipeline construction, daily/weekly/monthly reports, the Newsletter, and variance approvals/denials. It also includes a brief description of the project, a project schedule, and links to the EIR web site where the Final EIR can be viewed or downloaded. The web site may be viewed at http://www.AspenEG.com/SFPP-MMCRP/.

STATUS OF FIELD REPORTING

For November and December construction activities, Aspen has been receiving daily monitor field reports via modem from our Environmental Monitor(s). These daily reports are sent to the agencies via facsimile each day and posted on the web site. In addition, weekly reports are being distributed to the CPUC and all interested permitting agencies.

PLANNED ACTIVITIES AND UPCOMING DELIVERABLES

During the month of January 1999, SFPP is scheduled to complete construction in the City of Long Beach, with the Spread 1 construction crews then moving to the Garfield Avenue segment of the City of Paramount and then to the City of Bellflower. The Spread 2 construction crews are anticipated to be working within both the City of Carson and Los Angeles County throughout the month of January. Construction in the City of Cerritos is anticipated to begin on approximately February 10, 1999.