Docket No. 217
Connecticut Light & Power Company
Development and Management Plan
Section III – Trench work for a 345-kV Cross-link Polyethylene (XLPE) Cable
Bethel, Connecticut
Staff Report – October 26, 2004

On July 2, 2004, Connecticut Light Power Company (CL&P) submitted a segment of the Development and Management (D&M) Plan referred to as Section III – Trench work for a 345-kV Cross-link Polyethylene (XLPE) Cable in the Town of Bethel, Connecticut.

The D&M Plan and alignment maps of the route (at a scale of 1" = 40’) outline the installation of new underground 345-kV XLPE cable anchored at the Plumtrees Substation and following Walnut Hill Road, Plumtrees Road, Whittelsey Drive, Judd Ave, and Putnam Park Road (Route 58) for a distance approximately of 2.1 miles to the Hoyts Hill Transition Station in Bethel. Transition poles would be required to integrate the underground cables to overhead conductors previously approved by the Council on October 7, 2004. CL&P consulted with the Town of Bethel, and the State Department of Transportation (DOT).

The D&M Plan identifies the locations and types of facilities to be used for Section III of the project, and describes the general procedures for:

• Installation of facilities, construction schedule and methods, procedures for environmental inspection, project administration, and techniques for landowner and agency notifications and consultations;
• Restoration of work areas and areas disturbed by construction (e.g., contractor yard, staging areas, and areas associated with road, stream and wetland crossings);
• Traffic control; and
• Long term operation and maintenance of the right-of-way.

Project administration is overseen by CL&P. CL&P will use temporary construction offices in vicinity of the project. Similarly, CL&P’s construction contractor will establish a contractor’s yard for office trailers, staging of equipment, materials and supplies, and a parking area for construction workers. This contractor’s yard will be about two to four acres in size and located proximal to the project. General construction will involve the use of public road rights-of-way approximately 15 to 20 feet in width of workspace and be in compliance with DOT recommendations. CL&P will limit location of facilities in the paved area where possible and will use temporary steel plates over open trenches or restore any disturbed pavement surfaces, thus minimizing disruption to traffic. DOT requested that steel plates with skid resistance be used. CL&P intends to comply. No contractor’s yard or other staging areas have been identified in the D&M Plan. Council staff recommends that the contractor’s yard and staging areas be identified and approved by Council staff prior to use.

The facilities will consist of a duct bank with six cables in six ducts and two fiber optic conduits for communications within a two-foot deep by three-foot wide duct bank and encased within thermal fill. The duct bank would have three feet of cover as agreed by DOT. Approximately 10 splice vaults (30 feet long, 9-feet wide and 7-feet high) will be installed at approximately 1,800 to 2,000 foot intervals. Two sets of vaults are required, one for each set of three cables. These vaults would not be located within environmentally sensitive areas and be located outside paved roadways wherever possible.

Other ancillary facilities include a ground cable and a communication system consisting of two 4-inch conduits located in the trench and a temperature monitoring system in a one-inch conduit centered within the duct bank.

The D&M Plan specifically outlines the methods of construction and guidelines for clearing, temporary access roads, trenching/excavation, soil erosion and sedimentation control, dewatering, blasting, spoil placement, and restoration of trench and disturbed areas to pre-construction conditions.

Special procedure have been developed for traffic, stream and inland wetland crossings, electric utility crossings, other subsurface utility crossings (i.e., water, sewer, telephone, natural gas , and cable to include Call Before You Dig), noise sensitive receptors, fugitive particulate emissions, dust and mud control, management of solid and/or hazardous substances, protection of cultural and historic resources including an unanticipated discoveries plan, visual impact and residential mitigation plan, and worksite safety plan. Whittelsey Drive is the town’s educational roadway which is narrow, adjacent to five schools and senior housing. CL&P agreed with the Town of Bethel to construct during the summer when school is not session. This was scheduled for this past summer but was not possible. Council staff recommends CL&P honor its agreement with the Town of Bethel and construct this segment during summer 2005. Another location requires crossing East Swamp Brook at the intersection of Walnut Hill Road and Plumtrees Road. CL&P and DOT were to coordinate construction crossing the Plumtrees Road/East Swamp Brook but DOT’s schedule has slipped. Therefore, CL&P proposes jack and bore 160 feet under the brook and roadway reducing impacts to the environment and busy intersection. No archeological reconnaissance surveys have been provided and staff recommends that such surveys be submitted prior to commencement of construction.

Work days will be Monday through Saturday between the hours of 7:00 a.m. and 7:00 p.m. in roadways, consistent with the traffic control plan. Extensions of the workday and hours may occur on a temporary and case-by-case basis. The splicing process will be conducted on a 24-hour basis over a period up to one week in each splice vault. While construction would temporarily disrupt traffic, DOT is concerned about splicing operations which may cause lane closures and that traffic signal loop detectors would be out of service for an extended period of time. CL&P proposes to place splice vaults and position manholes as far off the travel lanes to minimize traffic disruption wherever possible. CL&P and DOT would address such matters within an Encroachment Permit. Council staff recommends that the Council be notified of workday and/or work hour extensions verbally, as soon as possible, documented in a construction progress report.

CL&P developed a soil erosion/sedimentation control and revegetation plan and procedures regarding access road development, erosion control and minimization of effects on natural systems incidental to construction. Also, CL&P developed a wetland vegetation monitoring and maintenance plan and invasive species control and management plan. Council staff recommends that these plans be equivalent in context with DOT guidelines and comply with the 2002 Connecticut Guidelines for Erosion and Sediment Control.

A Spill Prevention, Control, and Countermeasure Plan have been developed to address actions to prevent spills in addition to those actions to be taken should any spills occur, including emergency notification procedures. On-site Environmental Inspectors will be responsible for ensuring that contractors implement and maintain spill control measures. All oil and hazardous materials management will be in accordance with local, state and federal guidelines. Council staff recommends CL&P attach copies of spill reports with its construction progress report.

CL&P provided information on the operation and rights-of-way maintenance plan and post-construction electric and magnetic field monitoring plan. Council staff recommends no action on these items in the D&M plan. Such plans should be provided to the Council for review and approval prior to commencement of operations.

CL&P will notify landowners directly along the rights-of way or within 50 feet of the center line not less than 48 hours prior to the initiation of construction and/or blasting. A toll-free number,

staffed during working hours (and voicemail other hours) will be available specific to the project. All calls will be documented which will initiate a protocol of response. If, within 30 days an issue or concern cannot be resolved, CL&P will forward to the Council relevant information and summary of activities that were performed to attempt closure. Council staff recommends notification to landowners be done not less than 48 hours prior to construction and/or blasting in vicinity of landowners, and changing 30 days to 15 business days to be more responsive to constituent concerns.

CL&P and DOT are negotiating a co-location agreement (Encroachment Permit) to include cost allocation for future movement of the transmission line. Council staff recommends CL&P file a copy of the Encroachment Permit prior to the commencement of construction, and any resulting change to the D&M Plan shall be provided to the Council for review and approval.

CL&P proposed to begin construction of the 345-kV XLPE line in the summer of 2004 with a projected completion date of November 2005. This schedule has slipped up to as much as one year. CL&P contends full restoration work may require additional time into the spring of 2006. Council staff recommends CL&P provide two week advance notice prior to commencement of construction.

Prior to commencement of construction CL&P requires all personnel (CL&P and Contractor) involved in construction activities attend project specific safety and environmental training session. These training sessions summarize the D&M Plan and other permit/certificate requirements governing the project. The training will emphasize the importance of workplace safety and environmental compliance including disciplinary action. Furthermore, an environmental inspector, the BCS Group previously recognized by the Council in approving the D&M Plan for the Norwalk Substation, will be responsible for inspections and weekly reporting to verify that the construction is performed in accordance with environmental requirements.

CL&P proposes the following procedures to address deviations of the D&M Plan:

• For proposed deviations prior to the start of construction or well in advance of commencement of specified activity, CL&P will submit a request in writing for review and approval by the Council;
• For proposed deviations during construction based upon field conditions, conduct a telephone conference with Council staff to present the proposed modification and receive verbal approval from the Council’s Chairman with written specification of the deviation to be submitted within 24 hours after the request; and
• Implementation of deviations to the D&M Plan that are approved by the Council will be documented within the monthly monitoring reports to be submitted by the independent environmental inspector.

Council staff recommends that proposed deviations be authorized by the Chairman (or designee) with written specification of the deviation submitted within 24 hours after the request and all other changes require advance notification and Council approval or be subject to enforcement by the Attorney General.

To summarize, the Council staff recommends approval of the Section III D&M Plan with the following conditions:

That CL&P file a copy of the DOT Encroachment Permit prior to the commencement of construction.

That CL&P provide two weeks advance notice prior to commencement of construction.

That CL&P provide a bi-weekly activity report of construction, including a spill report.

That CL&P provide a weekly Environmental Inspector’s report.

That the location of the contractor’s yard and staging areas be identified and approved by the Council prior to use.

That CL&P notify the Council of workday and/or work hour extensions verbally and documented in a construction progress report.

That CL&P construct around the Bethel School complex during a summer period.

That CL&P notify landowners directly along the rights-of way or within 50 feet of the center line not less than 48 hours prior to construction and/or blasting activity in vicinity of landowners.

That the D&M plans for erosion and sediment control is equivalent in context with DOT guidelines and comply with the 2002 Connecticut Guidelines for Erosion and Sediment Control.

That archeological reconnaissance surveys have been submitted prior to commencement of construction.

That CL&P submit non-resolution of constituent concerns after 15 business days to the Council.

That proposed deviations are authorized by the Chairman (or designee) with written specification of the deviation submitted within 24 hours after the request and all other changes require advance notification and Council approval or be subject to enforcement by the Attorney General.

To postpone review and approval of the operation and rights-of-way maintenance plan and post-construction electric and magnetic field monitoring plan.