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NARRATIVE TO ACCOMPANY APPLICATION OF KKSH2 LLC TO TOWN OF
MONTVILLE PLANNING AND ZONING COMMISSION FOR THE INTERMODAL
USE OF PROPERTY LOCATED AT 125 DEPOT ROAD, MONTVILLE,
CONNECTICUT FOR THE RECEIVING, AMENDMENT AND TRANSPORT OF
DREDGED MATERIALS
The property located at 125 Depot Road, Montville, Connecticut (hereinafter the
“Property”), consisting of 11.92 acres, is owned of record by Uncasville, LLC and leased pursuant
to the terms and provisions of a Ground Lease to Gateway Montville LLC. Gateway Montville
LLC has entered into a sublease with KKSH2 LLC pursuant to which KKSH2 LLC will conduct
on the premises a manufacturing process pursuant to which dredged materials will be amended
through a cementitious process in order to (i) stabilize the same for transport by either truck or rail
from the site and (ii) render the dredged material suitable for land based applications either for
environmental remediation purposes or for structural construction purposes, each depending upon
market demand and the specific characteristics of the dredged material. The Property is located in
the Industrial Zoning District pursuant to the provisions of Section 13 of the Town of Montville
Zoning Regulations. Although not applicable to the instant application, the Property is also located
in the Route 32 Overlay Zone.
The use of the Property proposed in the instant application is governed by Sections 13.2.1
and 13.2.10 of the Montville Zoning Regulations. Section 13.2.1 authorizes properties in the
Industrial Zoning District to be utilized, inter alia, for “those fields of economic activity including
… manufacturing, transportation …”. The application submitted herewith is an application for a
manufacturing process pursuant to which, as hereinafter described, dredged materials will be
subjected to a manufacturing process pursuant to which the materials will be stabilized by the use
of a cementitious product in order to render the same sufficiently stable for over the highway and/or
rail transportation and to create a structural product that has both market viability and structural
suitability for on land use.
Section 13.2.10 of the Montville Zoning Regulations authorizes water dependent uses, with
site plan approval, in the Industrial Zoning District. The proposed use of the Property submitted
with this application is also a water dependent use. The dredging of the State’s waterways to render
the same suitable for marine transport of goods and products is a critical component of the State’s
economy. The channels in the State’s waterways and harbors require dredging at approximate
intervals of ten (10) years in order to render the same of sufficient depth to accommodate the
vessels utilizing the same for transport. Concomitant with the need to dredge the State’s waterways
is the need to make disposition of the dredged materials. Dredged materials fall into three (3)
categories: (i) dredged materials that can be disposed of at sea (ii) dredged materials that are not
eligible for disposition at sea, but which do not contain any hazardous materials but, pursuant to
State regulation, must be disposed of on land and (iii) dredged materials that contain hazardous
waste. The application which is being submitted herewith to the Town of Montville Planning and
Zoning Commission is only proposed to authorize the site for the handling and amendment of
dredged materials which fall into category (ii) above. The application does not seek permission to
introduce to the site any dredged materials that contain any amount of hazardous waste. In fact,
the authorization for the process which is the subject of the instant application granted by the State
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of Connecticut Department of Energy and Environmental Protection specifically prohibits the
introduction of any materials containing hazardous waste to the Property.
The application submitted herewith seeks site plan approval for the use of approximately
2 acres of the 11.92 acre parcel which is the subject of the application, with all activities occurring
on the concrete pad which was the former foundation for the AES Thames cogeneration facility.
Site improvements for this use have been previously completed in conjunction with the Phase 2
and Phase 3 approvals granted by the Town of Montville Planning and Zoning Commission. As
depicted on Sheet 5 of the site development plan, a Hydroworks HydroStorm 6 hydrodynamic
separator has been previously installed at Stormwater Outfall #2 at the northerly end of the
Property and a Hydroworks HydroStorm 10 hydrodynamic separator has been previously installed
at Stormwater Outfall #4 on the easterly side of the Property. In conjunction with the instant
application, the Applicant proposes the installation of an additional hydrodynamic separator at
Stormwater Outfall #3 in the northeasterly corner of the Property. Otherwise, no additional site
improvements are contemplated with this application.
All dredged materials will be required to be tested at the dredging site to insure that they
satisfy the requirements for disposition in the State of Connecticut in accordance with the terms
and provisions of the Department of Energy and Environmental Protection permit issued for this
project; i.e. that they are free from any contaminants which constitute hazardous waste. Testing of
the materials at the dredge site is required periodically in order to insure that contaminants
constituting hazardous waste may be identified throughout the course of the dredge operation.
Dredged material will be brought to the site for offloading by deck barges or hopper barges.
While these barges vary in size, they are typically 200 feet long and 40 feet wide. Dredged
materials will be offloaded from the barges with a clamshell bucket. The water content of material
received in the barges will vary significantly from “dry material” (primarily sands and gravels
which do not have significant capacity to hold water) to “wet material” which will require
amendment with a cementitious product prior to being transported offsite.
Spill plates will be installed from the dock to the staging area for trucks which will receive
the dredged materials in order to insure that dredged materials are not introduced to the Thames
River. There are three (3) alternatives for transferring the materials from the barge to secured lined
bins where amendment of the dredged materials will occur with cementitious products. The
alternatives are (i) watertight dump trucks (ii) mobile conveyor transport or (iii) direct pumping.
The alternative utilized will depend upon the nature of the material being transported and its water
content. These alternatives are highlighted on the “Artist Renderings of Site” incorporated into the
site development plan as Sheet 2.
If the dredged material contains excess water, water will be skimmed and pumped from the
barge to an onsite holding tank (frac tank) for use as makeup water in cement batch plant
operations. If the water realized from dredging operations exceeds the frac tank capacity, water
from the frac tank will be collected and disposed of at an approved offsite facility.
Regardless of which method of offloading (enumerated above) is utilized, offloaded
materials will be transported to the amendment bins as depicted on the site development plan. The
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amendment bins will be constructed of concrete blocks lined with an HDPE watertight liner. At all
times that the facility is in operation, a minimum freeboard of one foot will be maintained in the
watertight bins in order to alleviate the propensity that the bins will overtop and result in
uncontrolled discharge of stormwater to the Property during intense storm events.
If required, and based upon the constituency of the dredged material, dry Portland cement
will periodically be utilized to partially dry dredged material while still in the barge and prior to
offloading. Wet silts and clays will be conditioned and processed in the watertight bins with a
cementitious product using different mixing tools which will be determined by the condition of
the material received and the condition of the material required for its ultimate offsite use (i.e.
whether for capping environmentally contaminated areas or as structural fill in construction
projects). Where mixing is required in the watertight bins, it will be conducted either by (a)
utilizing a mixing head on an excavator (b) by the introduction of a pugmill operation or (c)
utilizing innovative technologies including the Pneumatic Flow Tube Mixing (PFTM) method.
Upon conclusion of the mixing/drying operations, typically at a rate of 4-8% by weight of
material, the amended material is placed in a curing bin for the cementitious binder to react and
stiffen. The amended “dry” material must first pass a paint filter test to determine that it does not
contain free liquid. Upon satisfying this requirement, the amended material will be loaded either
onto triaxle trucks or rail for transport from the site. Materials loaded onto triaxle trucks will be
weighed prior to leaving the Property.
The cement product utilized in the amendment process will be stored onsite in vertical silos
as depicted on Sheet 2 of the site development plan. Refueling operations for onsite equipment
will be performed from a fuel truck or by utilizing an onsite above ground storage tank. In the
event that an aboveground on-site storage tank is utilized, it will be installed with secondary
containment with a capacity equal to 125% of the capacity of the tank itself. An OSHA approved
spill kit will be maintained onsite at all times during operations.
State regulations only allow dredging operations to occur during the months of October to
February. Therefore, the operation of the portion of the site which is the subject of this site plan
and coastal site plan application will occur during the permitted operating months. The adjacent
property leased by Gateway Montville LLC located at 133 Depot Road, Montville, Connecticut
was previously approved by the Montville Planning and Zoning Commission for a salt storage
facility. That facility has been completely constructed and is currently in commercial operation. In
conjunction with the salt storage operation, Gateway Montville LLC retained the services of F.A.
Hesketh & Associates, Inc. to perform a traffic study in order to determine whether or not the
roadway network which will provide vehicular access to and from the Property has sufficient
capacity to accommodate the site generated traffic. In conjunction with the salt storage operation,
the traffic engineer projected that that operation would generate, on average, 148 truck trips per
day with peak truck trip generation of 448 truck trips per day during winter pre-storm events. Peak
hour truck trip generation from the salt storage facility would be 30 truck trips during the summer
months and 62 truck trips during winter pre-storm events.
The prior traffic report prepared by F.A. Hesketh & Associates, Inc. projected that the vast
majority of truck trips generated by the salt storage operation would utilize Depot Road to access
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Connecticut Route 163 and thereafter Interstate 395. The same traffic distribution pattern is
anticipated for the proposal which is the subject of the instant site plan and coastal site plan
applications.
It is noted that, due to the fact that dredging operations are limited in the State of
Connecticut to the months of October through February, there is the potential for peaking of site
generated truck traffic with the peaking that may occur on days prior to winter storm events. This
combined peaking possibility is addressed in the December 15, 2022 traffic analysis supplement
prepared by F.A. Hesketh & Associates in which the author projects a theoretical maximum of 688
truck trips per day with a peak hour volume of 92 truck trips on days prior to predicted storm
events. Based upon the analysis contained in the December 15, 2022 report supplement, Scott F.
Hesketh, P.E. has determined that the roadway network has sufficient capacity to accommodate
this increased traffic burden. Nevertheless, the Applicant is proposing, as an integral component
of this application, that the transport of dredged materials from the site not be authorized on days
immediately prior to predicted winter storm events. With this limitation, all site generated truck
traffic to and from the Property will be maintained at levels substantially less than those previously
found acceptable by the Montville Planning and Zoning Commission in approving the salt storage
facility.
In conjunction with the applications submitted herewith, the Applicant is proposing
operating hours of 7:00 a.m. to 6:00 p.m., with no night-time operation. Operations will occur from
Monday through Saturday. There will be no operations conducted in conjunction with this
application on Sundays or legal holidays. Since dredging operations are, by regulation, conducted
during winter months, activities will be occurring on the site during periods of darkness; i.e. from
7:00 a.m. to 7:15 a.m. and from 4:15 p.m. to 6:00 p.m. Therefore, as depicted on the site
development plan, portable lighting is being proposed onsite to provide illumination necessary to
satisfy safety protocol while operations are being conducted during periods of darkness. All site
lighting will be full cutoff lighting to prevent light migration off of the Property during periods of
darkness illumination.
As contemplated by the application, this proposal will occur in an industrial zoning district.
Pursuant to the provisions of Section 13 of the Montville Zoning Regulations, all permitted uses
in the industrial zone are uses permitted by site plan approval and do not require special permit
approval. Therefore, the special permit general evaluation criteria contained in Section 16.5 of the
Montville Zoning Regulations are inapplicable to this application. The Commission’s role in
evaluating a site plan application is to insure that the site plan requirements of Section 17 of the
Zoning Regulations have been satisfied. In evaluating a coastal site plan application, the
Commission’s role is to determine that the proposed use is consistent with coastal policies and
goals as enumerated in the Connecticut Coastal Area Management Act.
The Applicant submits that this application satisfies both of those requirements.