Docket No. 217
Connecticut Light & Power Company
Development and Management Plan
Section I – Trench work for a 345-kV High Pressure Fluid-Filled (HPFF) Transmission Line
Staff Report – May 19, 2004

On March 4, 2004, Connecticut Light Power Company (CL&P) submitted a segment of the Development and Management (D&M) Plan referred to as Section I – Trench work for a 345-kV High Pressure Fluid-Filled (HPFF) Transmission Line between transition sites located at Archers Lane in the Town of Redding and Norwalk Junction in Wilton, Connecticut.

The D&M Plan and alignment maps of the route (at a scale of 1" = 40’), outlines the installation of 9.7 miles of a new underground 345-kV HPFF transmission line. The new transmission line will be placed within public road rights-of-way (Archers Lane, Diamond Hill Road, Umpawaug Road, State Routes 107 and 7). CL&P consulted with the Town of Redding, Town of Wilton, and the State Department of Transportation (DOT). The D&M Plan does not contain site details for the transition stations for change from overhead to underground transmission facilities. These plans would be submitted at a later date.

The D&M Plan identifies the locations and types of facilities to be used for Section I 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 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 provided to the Council prior to use.

The facilities will consist of two parallel HPFF pipes each containing three cables within a five-foot deep by five-foot wide trench and encased within thermal fill. DOT initially recommended placing the proposed cables eight feet below grade; however, DOT agrees with the five foot depth with three feet of cover. Approximately 20 splice vaults (18 feet long, 10-feet wide and 9-feet high) will be installed at approximately 2,000 to 3,000 foot intervals. These vaults would not be located within environmentally sensitive areas and be located outside paved roadways wherever possible. In addition, CL&P acknowledges that work in municipal roads is done at CL&P’s expense and contends that the matter for funding such costs is addressed within the Connecticut General Statutes.

Each pipe will be filled with polybutene, an insulating dielectric fluid that is deemed non-hazardous by the Environmental Protection Agency. Approximately 1.5 gallons of fluid per foot of pipe or approximately 153,648 gallons is needed. Two pressurization plants with 15,000 gallon reservoirs will be located at the transition stations to maintain proper level and pressure of the dielectric fluid to a nominal pressure of 200 pounds per square inch.

Other ancillary facilities include a cathodic protection system that includes test stations every 2,500 feet, a communication system consisting of two 4-inch conduits located in the trench and a temperature monitoring system in a one-inch conduit strapped to the pipe all terminating at the transition stations.

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 procedures 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. While archeological reconnaissance surveys are being conducted none 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 two weeks 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. 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, and documented in the 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 has been developed to address actions used to prevent spills in addition to actions that shall be taken should any spills occur including emergency notification procedures. The on-site Environmental Inspectors are 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 that landowners directly along the rights-of way or within 50 feet of the center line be notified not less than 48 hours prior to the initiation of construction and/or blasting and changing 30 days to 15 days to be more responsive to constituent concerns.

On April 1, 2004 the DOT provided comprehensive comments on both Section I and Section II 115-kV Solid dielectric Transmission Line between the Plumtree Substation in Bethel and the Norwalk Substation, Norwalk. On April 30, and May 7, Chairman Katz and Council staff mediated issues between CL&P and DOT. Such issues were depth of cover, loop detectors, steel plates, vault locations, hazardous soil and co-location agreement (Encroachment Permit) to include cost allocation for future movement of the transmission line. The only issues unresolved are the treatment and liability of discovered hazardous soil and final co-location agreement. Furthermore, the DOT schedule to improve Route 7 in southwest Connecticut is slipping and may not engage with CL&P’s schedule, causing changes to the installation of the underground transmission line. CL&P is prepared to adapt the D&M plan subject to the DOT schedule. Council staff recommends that CL&P file a copy of the final co-location agreement including resolution of hazardous soil and cost allocation associated to future movement of the transmission line and that any change to the D&M Plan shall be provided to the Council for review and approval.

CL&P proposes to begin construction of the 345-kV HPFF line in the summer of 2004 with a projected completion date of November 2005. CL&P contends full restoration work may require additional time since November 2005 is considered outside the planting season and CL&P would need spring of 2006 to plant vegetation. Council staff recommends CL&P provide two weeks advance notice prior to commencement of construction for the 345-kV trench work.

Prior to commencement of construction CL&P requires that all personnel (CL&P and Contractor) involved in construction activities attend a 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 BSC 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, CL&P will conduct a telephone conference with Council staff to present the proposed modification and receive verbal approval from the Council 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 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 I D&M Plan as follows:

That CL&P file a copy of the final co-location agreement with DOT including resolution of the treatment and liability of hazardous soil and cost allocation associated with future movement of the transmission line.

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 provided to the Council prior to use.

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

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 the initiation of construction and/or blasting.

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 be submitted prior to commencement of construction.

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

That proposed deviations are authorized by the Chairman 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.