Mr. Bob Haslam July 14, 2009 Agency of Natural Resources Page 3 Waterbury, Vermont soundings indicate the maximum depth to bedrock under the pier locations is approximately 2½ feet and less than 1 foot at several locations so bedrock may dictate soil excavation depths in most, if not all, locations.

On May 19-20, 2009, The Johnson Company conducted a field investigation to assess potential impacts to soils and groundwater in the area near the existing penstock. The following is a bulleted summary of The Johnson Company findings from the May 2009 field investigation.

• The TPH fingerprinting results confirmed that the source of the impacted soils is likely to be creosote, which is believed to have been applied to the existing penstock most recently in the 1970s

• Waste characterization analyses of “worst case” soil samples indicated that soil that may need to be removed in the course of the penstock replacement is not classified as hazardous waste.

• PAHs were reported at concentrations exceeding EPA Region IX screening levels for industrial soils in soils under the length of the entire penstock

• Comparison of field screening with laboratory results indicated that some correlation exists between visual observations and PAH concentrations

• Groundwater results were not reported in excess of Vermont Groundwater Enforcement Standards.

2.0 SOIL MANAGEMENT PLAN

The purpose of the Soil Management Plan is to minimize the potential for impact to worker health/safety, the public and the environment, and to provide proper soil management techniques during the construction of the replacement penstock.

Soil Volume/Mass Estimation: 680 linear feet * 12’ wide excavation * 1’ depth = 8160 cu ft 8 support piers @ 2.5’ deep and 5’ x 13 = 1300 cu ft 1 thrust block at 2.5’ deep, 13’ x 10’ = 325 cu ft 9785 cu ft + 10% ~ 10,800 cu ft or ~ 400 yards 400 cu yards * 1.5 tons = 600 tons All soil removal and excavation will be conducted by the selected contractor, GW Tatro of

Jeffersonville, Vermont. Site activities will be conducted in accordance with PSNHs’ Soil Erosion and Sediment Control Plan (Attachment 1).

It is estimated that approximately 400 cubic yards, or 600 tons of soil will need to be

excavated and transported for off-site disposal. Dry soils will be placed directly into roll-off bins or trucks for instances of immediate transport. Saturated soil will be temporarily piled in its area of excavation, covered with poly sheeting and will be allowed to gravity dewater into the excavation such that it will be free of liquid and can be transported off site to the disposal location. If soil must be stockpiled outside the area of excavation it will be placed on a geotextile that adequately extends

ATTACHMENT 1 SOIL EROSION AND SEDIMENT CONTROL PLAN

Public Serviceof New Hampshire

CANAAN PROJECTFERC NO. 7528

CANAAN PENSTOCK REPLACEMENT

SOIL EROSION AND SEDIMENTATION CONTROL PLAN

MAY 15, 2009

Prepared by:

Public Serviceof New Hampshire

CANAAN PROJECTFERC NO. 7528

CANAAN PENSTOCK REPLACEMENT

SOIL EROSION AND SEDIMENTATION CONTROL PLAN

MAY 15, 2009

Prepared by:

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PUBLIC SERVICE OF NEW HAMPSHIREMANCHESTER, NEW HAMPSHIRE

CANAAN PROJECTFERC NO. 7528

CANAAN PENSTOCK REPLACEMENT

SOIL EROSION AND SEDIMENTATION CONTROL PLAN

TABLE OF CONTENTS

1.0 INTRODUCTION................................................................................................................1

2.0 SITE PREPARATION AND TEMPORARY EROSION CONTROL MEASURES .........22.1 Concrete Placement .................................................................................................3

3.0 ACCESS TO WORK SITE .................................................................................................3

4.0 DISPOSAL OF UNSUITABLE MATERIALS...................................................................4

5.0 INSPECTION AND MAINTENANCE...............................................................................4

6.0 PERMANENT EROSION CONTROL MEASURES.........................................................5

1203020.01 20 03J:\1203\020\Docs\Permitting\FERC Pre Construction Filing\001-ESCP - Canaan Penstock.doc

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PUBLIC SERVICE OF NEW HAMPSHIREMANCHESTER, NEW HAMPSHIRE

CANAAN PROJECTFERC NO. 7528

CANAAN PENSTOCK REPLACEMENT

SOIL EROSION AND SEDIMENTATION CONTROL PLAN

1.0 INTRODUCTION

The Canaan Project is located on the Connecticut River, in the Town of Canaan, County

of Essex, Vermont and the Town of West Stewartstown, NH. The proposed penstock

replacement work will be entirely within the Town of Canaan. The Project is owned, operated,

and licensed to PSNH by the Federal Energy Regulatory Commission (FERC) as Project No.

7528.

The Canaan Penstock consists of an approximately 1,373 foot long, 114 inch (9.5 ft)

inner diameter, wood stave penstock which has reached the end of its practical service life. The

proposed work consists of replacing the entire length of wood stave penstock with a 108 inch (9

ft) inner diameter steel penstock partly buried and partly supported on 9 ring girders. Two

sections totaling approximately 652 feet will be buried in the shallow trench of the existing

penstock near the intake and surge tanks. The middle 721 feet will be supported on concrete

footings and steel ring girders at approximately 80 foot spacing. The new steel penstock will be

grouted into the existing intake, surge tank, and powerhouse to transition from the existing 10’

outer diameter wood stave penstock to the proposed 9 ft diameter steel penstock.

The following sections describe the measures to be utilized during the work. The purpose

of this plan and the proposed soil erosion control measures is to minimize soil erosion and

sediment transport from the project site during and after construction. The Contractor is required

to be in compliance with the applicable standards found in the:

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Army Corps of Engineers Wetlands General permit for the State of Vermont

http://www.nae.usace.army.mil/reg/vtpgp.pdf

VT DEC Construction General Permit 3-9020 for low risk projects

http:/www.vtwaterquality.org/stormwater/docs/construction/sw_low_risk_site_ha

ndbook.pdf

The construction activities associated with the project will include the following major

items:

Surface disturbance for demolition of the existing penstock

Disposal of wood and potentially contaminated soils

Earthwork and rough grading of pipeline

Excavation and placement of concrete footings

Placement and welding of steel pipe

Bury and backfill sections of pipe

Seeding and site restoration

2.0 SITE PREPARATION AND TEMPORARY EROSION CONTROL MEASURES

The Contractor shall initiate the soil erosion and sediment control measures as described

in this plan. All areas potentially subjected to erosion shall be protected by temporary

containment measures (silt fences) and any other means deemed necessary prior to

commencement of any construction activities. Details for design, installation and maintenance of

erosion and sedimentation control measures will be provided on construction drawings and

technical specifications incorporated into the Contractor’s construction requirements.

During penstock replacement activities, the installation of a silt fence will serve to reduce

potential runoff velocities and direct the disposition of the transported sediment load. Silt

fencing will be installed on the down slope edges of the spoils area, as well as the laydown area

and sedimentation basin. The fences positioned as close to the disturbed area as possible, but at

least 10 feet from the toe of a slope to allow for maintenance and roll down. The fabric fences

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will stand approximately 36 inches from the ground elevation, and be supported by wood or steel

posts embedded into an 8 inch diameter trench at the bottom edge of the fence. Once the

disturbed area is permanently stabilized and no longer susceptible to erosion, the temporary

fences will be removed.

As applicable during construction, the Contractor shall minimize the area of disturbance

of existing ground coverage such as shrubs, trees, and grass so that the smallest practical area of

land is exposed at any one time during construction. At the earliest possible date, the Contractor

shall establish the permanent erosion and sediment controls described in Section 6.0. The

Contractor shall inspect and maintain the facilities or control measures until the Owner’s

acceptance of the completed project, whereupon the Owner will assume maintenance

responsibilities.

2.1 Concrete Placement

Installation of the new facilities will require placement of fresh concrete mix near

existing bodies of water. The Contractor shall avoid concrete paste from entering the

main water channel and migration of paste beyond the work area. Concrete wash water

shall be directed overland into stilling basins, hay bale dikes or similar systems to prevent

wash water and paste from entering the waterway.

3.0 ACCESS TO WORK SITE

Access to the work area is expected to be achieved by building temporary fill ramps from

the adjacent Power House Road down to the penstock center line. Access along the penstock

will be from inside the existing penstock trench. Vehicular and materials access to the contractor

laydown area will be via Power House Road.

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4.0 DISPOSAL OF UNSUITABLE MATERIALS

Unsuitable soil and demolition materials will be disposed of at the Contractor’s spoil

area. The Contractor shall comply with all permit conditions applicable to the operation of the

landfill’s facility.

5.0 INSPECTION AND MAINTENANCE

The Contractor will be required to seed and mulch disturbed ground (if any) in the project

area within 7 days of completion of construction activity. In no case will an area remain

unprotected for longer than 7 days.

The Contractor will be required to inspect each soil erosion and sediment control

structure (silt fences, turbidity curtains, dikes, hay bale berms, etc.) and newly seeded areas at

least once per week during construction and immediately following rain storms and other periods

of heavy runoff. The Owner will also periodically inspect the site to confirm that the erosion

and sediment control structures are being installed and maintained according to this plan. The

Owner will notify the Contractor of observed deficiencies or additional measures necessary to

maintain the sediment control structures. The Contractor, upon observing or receiving

notification of deficiencies, will correct such deficiencies within 24 hours. Failure to comply

with the soil erosion and sediment control plan may result in a stoppage of construction

activities. The Contractor will maintain a weekly log of the condition of the sediment control

measures, any sediment control problems, and additional measures or repair work necessary.

The Contractor will remove and properly dispose of all sediment collected at dikes,

ditches, or other areas. Sediment shall be removed from the sediment barriers when the reserve

storage capacity is reduced by 20%.

As conditions require, the Contractor will cut/mow grass areas and remove cuttings

before the grass reaches a height of 6 inches.

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This program of inspection and maintenance will be initiated upon commencement of

construction and will remain in effect until project completion; at such time, the Owner will

assume responsibility for maintenance of the permanent erosion and sediment control measures.

6.0 PERMANENT EROSION CONTROL MEASURES

Upon substantial completion of the project, the temporary soil erosion and sediment

control facilities will be removed as appropriate. The disturbed areas will be graded, loamed,

seeded, and mulched as necessary. Upon establishing the permanent erosion control measures,

and a sufficient “catch” of grass, the temporary erosion control measures will be removed and

disposed of in accordance with Local, State and Federal regulations. The Contractor shall re-

seed all washouts and stabilize the project area prior to project acceptance.

Vermont Department of Environmental Conservation Agency of Natural Resources

Dam Safety and Hydrology Section

103 South Main Street [phone] 802-241-3758

Waterbury, VT 05671-0511 [fax] 802-244-4516 http://www.anr.state.vt.us/dec/fed/dss.htm

To preserve, enhance, restore, and conserve Vermont's natural resources, and protect human health, for the benefit of this and future generations.

DISTRIBUTED ELECTRONICALLY

June 23, 2009

James J. Kearns

Project Manager – Hydro Relicensing

Public Service Company of New Hampshire

PO Box 330

Manchester, NH 03105-0330

RE: Canaan Hydroelectric Project – FERC Project No. 7528

Penstock Replacement Project

Water Quality Certification

Dear Mr. Kearns:

By letter dated May 27, 2009, you transmitted a copy of revised design drawings, construction

specifications, and an erosion prevention and sediment control plan for the proposed replacement of the

penstock at the Canaan Hydroelectric Project on the Connecticut River. By email of June 22, 2009,

Kleinschmidt Associates filed supplemental information specifying the limits of earth disturbance for

construction-related activities. The Canaan Hydroelectric Project is subject to the conditions of a water

quality certification issued by the Agency of Natural Resources on November 20, 2008, including a

condition requiring prior approval of maintenance and repair projects (Condition M). The Agency

hereby approves the proposed project under Condition M subject to the following conditions:

1. Removal of vegetation and earth disturbance shall be limited to the area within the limits of

disturbance as shown on plan sheets 2a and 2b, June 22, 2009 revision;

2. For each two calendar week of construction, a progress report shall be filed with the

Department of Environmental Conservation Hydrology Section no later than the following

Tuesday; said report shall include information on project status; erosion prevention and

sediment control measures in place; and any erosion or water quality problems encountered and

related corrective actions;

3. Turbid water, exceeding 10 NTUs, pumped or siphoned from the work area shall only be

discharged into a containment area where sediment can settle out or otherwise be treated; turbid

water, exceeding 10 NTUs, shall not be discharged into the river;

4. Flow management (run-of-river operations and minimum flows) downstream and in the

bypassed channels shall be consistent with the provisions of the water quality certification and

FERC license at all times;

James Kearns

June 23, 2009

Page 2

2

5. Every reasonable precaution is to be taken to prevent the discharge of petrochemicals, debris,

and wet concrete to State waters; machinery shall fueled away from State waters and shall be in

good mechanical condition in terms of integrity of hoses, seals, and gaskets; during concrete

pours, water shall not be displaced from forms into State waters; wash water from ready-mix

trucks shall not be discharged into State waters directly or indirectly via storm sewers;

6. The contractor shall be provided with a copy of this approval letter before the start of work; and

7. The Department of Environmental Conservation Hydrology Section shall be notified

immediately upon the completion of construction to arrange a joint site inspection.

The Agency, in granting this approval, accepts no legal responsibility for any damage direct or indirect

of whatever nature and by whomever suffered arising out of the project described.

This approval is only for the work described. Any additional work or changes in procedure must be

approved in advance by the Agency.

The Agency maintains continuing jurisdiction over the project to address water quality issues that may

arise and to assure compliance with Vermont Water Quality Standards.

Please contact me if you have any questions.

Very truly yours,

Jeffrey R. Cueto, P.E.

Chief Hydrologist

c Pete LaFlamme, Director, Water Quality Division

Jud Kratzer, Dept. of Fish and Wildlife

Barry Cahoon, P.E., Rivers Management

Shannon Morrison, Vermont Wetlands Office

Martha Abair, COE

Keith Martin, P.E., KA

Allison Murray, KA

ATTACHMENT 2 CASELLA COVERNTRY VERMONT LANDFILL SOIL ACCEPTANCE DOCUMENTATION

Joel Behrsing

From: Mike Viani [Mike.Viani@CASELLA.COM]Sent: Tuesday, July 07, 2009 8:54 AMTo: Joel BehrsingSubject: Fw: Canaan VT Penstock Replacement ProjectImportance: High

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7/7/2009

Joel--Attached below is the email from Dave DiDomenico from VT DEC (our landfill inspector), approving of the acceptance and use of these soils from the penstock project, in response to my submittal to him, of the information (report) that Mike Marotto supplied to me. I trust that this will satisfy the needs of PSNH and Tatro regarding acceptability of these materials at our landfill. Let me know if there is anything else you need. Michael Viani Vice President of Business Development 91 North State Street, Suite 202 Concord, NH 03301 toll free 800-883-8877 office 603-223-2376 cell 603-491-3956 fax 603-223-0985 email: mike.viani@casella.com The information contained in this communication is confidential, may constitute inside information, may be attorney-client privileged and is intended only for the use of the named recipient. If the reader of this e-mail message is not the intended recipient, or the employee or agent responsible for delivery of the message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is prohibited. If you have received this e-mail in error, please notify the sender immediately by telephone at 603-223-2376. **Quotations/Proposals provided via email are valid for not more than 30 days from date of email unless otherwise specified. ----- Forwarded by Mike Viani/CASELLA WASTE SYSTEMS INC/US on 07/07/2009 08:42 AM -----

Hi Mike, Based on the analysis provided, you are approved to take the Penstock soils to Waste USA and use them as ADC. Let me know if you have any questions, Dave DiDomenico

"DiDomenico, David" <David.DiDomenico@state.vt.us>

07/06/2009 09:29 AM

To'Mike Viani' <Mike.Viani@CASELLA.COM>cc

SubjectRE: Canaan VT Penstock Replacement Project

Solid Waste Program (802) 241-3465 david.didomenico@state.vt.us

From:Mike Viani [mailto:Mike.Viani@CASELLA.COM] Sent: Monday, June 29, 2009 1:49 PM To: Surwilo, James Cc: DiDomenico, David; Haslam, Bob Subject: CanaanVTPenstock Replacement Project We have been asked by the Johnson Company, on behalf of PSNH, to accept at our Waste USA Landfill, in Coventry, VT, certain soils expected to be encountered on the above-referenced project. We respectfully request your approval to use these soils as Alternate Daily Cover. Because PSNH has expressed an urgency in commencing the project, and because Dave DiDomenico is on vacation this week, I am making this submittal to you, for your consideration. This portion of the project involves the disposal of an estimated 500 +/- tons of non-hazardous contaminated soil, which lies below an old (weathered) wooden penstock, which was creosote coated many years ago. I have included an excerpt from the Soil Investigation Study performed by the Johnson Company, which includes a letter to Mr. Bob Haslam of ANR, dated June 23, 2009, which explains the soil sampling and soil analytical results, and copies of the laboratory analysis results. Mike Marotto of the Johnson Co. suggested I cc Bob Haslam in this request, since he is very familiar with this project. Please call me if you should have any questions. Sincerely, (See attached file: CanaanVTPenstock-JCO Soil Investigation excerpt-Part II-DEC pkt-06-29-09.txt.pdf)(See attached file: CanaanVTPenstock-JCO Soil Investigation excerpt-Part I-DEC pkt-06-29-09.txt.pdf) Michael Viani Vice President of Business Development 91 North State Street, Suite 202 Concord, NH03301 toll free 800-883-8877 office 603-223-2376 cell 603-491-3956

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fax 603-223-0985 email: mike.viani@casella.com The information contained in this communication is confidential, may constitute inside information, may be attorney-client privileged and is intended only for the use of the named recipient. If the reader of this e-mail message is not the intended recipient, or the employee or agent responsible for delivery of the message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is prohibited. If you have received this e-mail in error, please notify the sender immediately by telephone at 603-223-2376. **Quotations/Proposals provided via email are valid for not more than 30 days from date of email unless otherwise specified. ______________________________________________________________________ This e-mail has been scanned by MCI Managed Email Content Service, using Skeptic(tm) technology powered by MessageLabs. For more information on MCI's Managed Email Content Service, visit http://www.mci.com. ______________________________________________________________________

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