ML20069L043

Suppl to Petition Requesting Suspension/Revocation of CPs Per 10CFR2.202 & 2.206(a),until Environ Review of Point Pleasant Diversion Completed

ML20069L043
Person / Time
Site:	Limerick
Issue date:	11/08/1982
From:	Sugarman R DEL-AWARE UNLIMITED, INC., SUGARMAN & ASSOCIATES
To:	NRC COMMISSION (OCM)
Shared Package
ML20069K972	List: ML20069K969 ML20069L043 ML20069L051
References
ISSUANCES-CP, NUDOCS 8211160364
Download: ML20069L043 (237)

Text

{{#Wiki_filter:_-. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION IN RE PHILADELPHIA ELECTRIC CO. DOCKET NOS. 50-352 CP LIMERICK GENERATING STATION 50-353 CP Units 1 and 2 REQUEST FOR SUSPENSION OR REVOCATION OF CONSTRUCTION PERMITS PURSUANT TO 10 C.F.R. $$2.202 and. 2.206 (a) :- SUPPLEMENT TO PETITION I. INTRODUCTION Del-AWARE Unlimited, Inc., by a Petition entitled " Request for Suspension or Revocation of Construction Permits Pursuant to C.F.R. S2.202 and 2.206(a)", dated July 2, 1981, requested that the NRC, under 10 C.F.R., Sections 2.202 and 2.206, take action to prevent the Point Pleasant Diversion and related construction meant to provide supple-mental cooling water for the Limerick Generating Station; the purpose of that requested action is to allow proper comprehensive environmental evaluation of the PPD and construction connected with the PPD, and consideration of alternative means for supplying supplemental cooling water to Limerick in ways which would be environmentally superior to PPD. Del-AWARE now submits this Supplement to Petition for these purposes: 1. Answer arguments raised by the Comments of Phila-delphia Electric Co., the Licensee, (PECO) in response to Del-AWARE's Petition (Comments received September 7, 1982); 8211160364 821111 PDR ADOCK 05000352 O PDR

b.: 2. Supply. additional information to substantiate the-need for action as requested in the Petition. Del-AWARE - hereby _ requests that the ' NRC Staff. consider this Supplement to' Petition'in conjunction with its earlier-Petition-f and treat it as 'if-incorporated into the earlier Petition. Del-AWARE submits that to do so (1) is'in keeping, with - the flexibility inherent in the informal. procedures i associated...with 10 C.F.R. $2.206 petitions, and ( 2 ') will help to promote the policy _ inherent in - 10 C.F.R. 2.206 'of ' giving fullest possible consideration to legitimate concerns raised by-members of the public in relation to the construc-tion and operation of nuclear power plants. II. RESPONSE TO PECO'S ARGUMENT-The following is a. response to " Comments of.Philadel-phia Company on Del-AWARE Unlimited's-Request for Suspension or Revocation of Construction Permits Pursuant to 10 C.F.R. $2.202 and $2.206(a)" (Comments) : Said Comments were received in this office on September 7, 1982. 1. In the Comments, it is stated that "each of these project components underwent a full environmental review as required by NEPA and related environmental statutes." 1

Comments, 6.

However, the PPD components reviewed in connection with Limerick, even allowing the most generous possible weight to previous environmental evaluations, were i

f only those which directly feed water into Limerick. None of the components which.will be used by the Neshaminy Water Resources Authority (NWRA) solely for water supply purposes were reviewed in conjunction with the components used for PECO or jointly by PECO and NWRA. This creates a very high probability, ariping virtual 1N to a certainty, that cumula-- tive and synergistic effects have not been and will not be s ( considered in the decision to permit or not permi.t the Point Pleasant Diversicn and related Nork. More directly, in the DRBC EIS, the intake was located only generally. No note was made of shad' spawning, \\ blasting, the status of the Pennsylvania Canal as a National Historic Landmark, the nature and extent of construction and establishment of a 60-80 foot high pumphouse (including fill), and the blasting and clearing on the hill, thef ) archaeological sites, and the historic district. Considera-tion of these matters as in the 1980 EA was cursory or nonexistent, and did not comply with NEPA procedural requirements. Historical and aquatic matters were deferred / to the Corps of Engineers, and depletive use considerations were deferred to this Commission. Documents showing the substantiality of these concerns are attached as Exhibit A. Nor was consideration given to the.present demon-strable inadequacy of water resources in the Delaware River, since shown by DRBC's proposed new Management Plan and storage requirements; which constitute changes in circum-stances as contemplated in the NRC Regulations. i

2. Reliance on the Corps of Engineers permit is similarly misplaced. The " Environmental Assessment and Section 404 Analysis of Point Pleasant Diversion Project for U.S. Army Corps of Engineers" (January, 1981), submitted by o a Bet - Converse-Murdoch, Inc., states that, "The Corps of Engineers have review and permitting responsibilities for the intake on the Delaware River at Point Pleasant and the rechanneling of Pine Run at the North Branch Water Treatment Plant... The overall functioning of the Point Pleasant Diversion Project and the construction of other system components are beyond the jurisdiction of the Corps of Engineers." (Page 1) This indicates that the Corps of Engineers has, like NWRA and NRC, only considered a portion of the overall complex of construction associated with PPD. This report further calls for the studies of wetlands at the site of the water intake for PPD, which have not been studies as of the date of the report. Study was also seen to be required of the impact of rechanneling Pine Run. (Page 30). This further demonstrates the fragmentation of the environmental analyses which have been conducted to date, and which are seen by PECO, erroneously in the view of Del-AWARE, to be adequate for purposes of compliance with NEPA. 3. Del-AWARE respectfully but vigorously disagrees with the determination of the Atomic Safety and Licensing Board in its Special Pre-hearing Conference Order, June 1, 1982, that 'he water supply components of the overall PPD k )

plan, which are dependent upon the diversion and related works serving Limerick, need not be evaluated as part of the overall project. The water supply components cannot be built without the components serving Limerick. ~Therefore, the water supply components of the overall scheme must be seen as a _ direct result and impact of the components meant to. supply water to Limerick. A bifurcated environmental analysis could be justified only. if the. Limerick-serving components were already in place. This. manifestly is not the case. 4. PECO attached to its comments the Affidavit of Robert A. Flowers, Executive Director of NWRA, to the effect that the-PPD and sufficient facilities to allow the water supply projects of NWRA would be built regardless of the Limerick generating station. This Affidavit must be given small evidentary weight, since it is obviously self-serving and/or subjective wishful thinking.

Moreover, it is l

directly contradicted by the memo attached hereto as Exhibit A in which Mr. Ackerson.of PECO records that NWRA needs to know whether PECO will proceed. 5. It is asserted by PECO that the Delaware River Basin Commission has responsibility for licensing PPD, with j-the implication that such responsibility establishes exclu-sive authority. PECO cites no authority for this implica-tion. On the contrary, it is clear that NRC must also evaluate PPD and related construction under NEPA, since the PPD and related construction are, in effect, parts of the _ _ _ _ _ _ _ _ - _ _ _ _ - - _ - _ _

overall plant of the Limerick Generating Station. While the Staff, has been allowed to use primary technical and scien-tific data from DRBC and other agencies, the opinion made it clear that NRC has the responsibility of integrating such information into a comprehensive picture of the environmen-tal impacts and of applying its own significance ratings or weights and judgment to these data to arrive at a balanced environmental decision. Philadelphia Electric Company (Limerick ~ Generating Station, Units 1 and 2), ALAB-262, 1 NRC 163 (1975). 6. The Comments assert that the material in Del-AWARE's Petition of July 2, 1982, concerning the relation-ship between PECO and NWRA was irrelevant. On the contrary, this relationship, as shown in the contract between the two entities, is strong evidence of the dependence of NWRA's components of the overall oroject and scheme upon the components serving Limerick. Although this evidence is circumstantial, circumstantial evidence has long been ac-cepted at law, and this evidence is extremely convincing. 7. The Comments cite the " Final Environmental Impact Assessment for the Neshaminy Water Supply System", Delaware River Basin Commission, August, 1980, as a complete environ-mental analysis of the PPD and related works. On the

contrary, this document cites the diversion of water to supply the Limerick Generating Station as a peripheral matter which is outside the scope of that environmental analysis.

See pages IV-5. 8. In their Comments, PECO cites the " Memorandum and Order", July 14, 1982, of the Atomic Safety and Licensing Board, as the " law of the case" which excludes analysis of the environmental impacts of the PPD and related construc-tion from 2.206 review. (Comments, 24-25.) This is an incorrect interpretation of the Order of July 14, 1982. The passage from that Order which PECO quotes clearly affirms only the determination not to admit certain contentions to the Operating License Hearing. It in no way negatives the suggestion in the Special Pre-hearing Conference Order of June 1, 1982, that these matters be referred to the Staff under 10 C.F.R. S2.206. In the June 1 Order, the Board

stated,

" Presumably, consistent with

NEPA, under the condition in the Limerick CP, the Director of NRR can exercise his authority to stay a construction activity which. may cause significant adverse effects not previously evalua-ted, until the NRC staff can complete its evaluation of the changes.

...Accordingly, Del-AWARE's allega-tions that changes in construction impacts due to either changes in proposed construction or the changes in the recognition of historical values of areas which may be impacted by construction should be directed as a request for action to the Director of Nuclear Reactor Regulations pursu-ant to 10 C.F.R. S2.206(a)."

Order, 85-86.

The Board further stated that, "Accordingly, in order to avoid the risk of rendering the above portions of contentions substantially moot and/or requiring the applicant to undue costly (in time and money) construction work, we determine that every effort should be made to resolve ~ the above summarized issues prior to the construction of the Point Pleasant intake and associated pump station and the Bradshaw Reservoir. In conjunc-tion with our examination of these operational impacts we will compare the alternatives, e.g., designs and locations, under NEPA. For that purpose, we will look at the Staff's findings under condition 3.E(3) of the construction permit of request pursu-ant to 10 C.F.R. $2.206 concerning construction impacts." Order, 88. The Board could not have stated more clearly that 10 C.F.R. S2.206 provides an appropriate avenue for exploring those environmental issues which it rules to be beyond the scope of the hearings. Del-AWARE now avails itself of the opportunity and procedure urged upon it by the Board. 1/ III. STAFF COMMITMENT TO THOROUGH ENVIRONMENTAL EVALUATION 1. Del-AWARE draws to the Staff's attention the j letter of January 5, 1982, from Robert L. Tedesco, Isssistant Director for Licensing,- Division of Licensing, to Mr. Vincent Boyer, Senior Vice President, Nuclear Operations, PECO, in which it was stated that " Cooling water supply in the diversion of Delaware River water was discussed by several participants at the meet-ing. We recognize that the final design of the diversion project was not completed when the Final Environ-mental Statement was issued for your 1. Del-AWARE does not hereby relinquish any right to appeal the holdings of the board concerning the narrowing or exclusion of any of its contentions from the OL Hearing. _

Construction Permit. Therefore, the staff. will thoroughly review the environmental impact associated with the diversion of the Delaware River -water. This area should also be -thoroughly. discussed in your tendered application." 2. Del-AWARE further draws the attention of the staff-to'a letter from Stephen H.. Lewis,. Counsel for NRC staff, to Robert J. Sugarman, Esq., in which it.was stated: "The environmental site. visit and public meeting have since been defer-red until the late summer or or early fall of 1982. Since the Draft Environ-mental Statement (DES) 'is not sched-uled for issuance until May, 1982, a late summer or early fall meeting will afford the staff ample' opportunity to take into. account the comments.of members of the public offered at the meeting in preparing the DES." (amy 6, 1982) It is clear from the context of this letter that the referenced DES is for the operation of the Limerick Generat-ing Station. 3. The thorough environmental review promised in the letter of January 5, 1981, quoted above, and the DES refer-red to in-the letter of May 6, 1982, quoted above, are.not available at this time to assist the Staff. in determining whether the PPD and related construction.should go forward. However, the scheduled date for initiating construction of the PPD is December 15, 1982. Since this last date is practically upon us, unless the complete environmental evaluation promised in January, 1981 is to be released 7itiating construction practically instantly, the date for 3 of PPD must be delayed. Otherwise, there will be a commit-ment of economic resources which will seriously prejudice consideration of the environmental issues; moreover, with-drawal of permission to construct PPD after construction has started would cause economic waste which would needlessly. burden PECO and its customers. It is preferable to avoid start of construction until environmental

issues, and alternatives for supplying supplemental cooling water to Limerick Generating Station, can be considered in light of existing conditions and of thG revised design of PPD.

4. The construction period for PPD has been estab-lished as-540 days in the bid documents. PECO's documents establish that the water supply system is not needed until April, 1985, and, in any event, the Perkiomen portion of the supplemental cooling water system will not be available until the end of 1984 or the beginning of 1985. Simple arithmetic establishes that, in these circumstances, there is no need to commence construction of PPD until the middle of 1983. 5. The PECO claim that two winters in the river are needed is not sustainable.

Indeed, PECO's original construction phasing called for the construction in the river to be in Phase III, thus clearly implying no need for two winters' access to the river.

Moreover, before any serious work can be done in the river, an access road is required. By the time the access road is constructed, the winter could be substantially over in any event. This is true not only because of the time required for construction itself, but also because of the need for detailed procedures and plans in connection with constructing the access road across the National Historical Landmark, i.e., the Pennsyl-vania' Canal. Thus, there is no need for an immediate start to construction, even if PECO can demonstrate'the PPD is the most desirable means of supplying supplemental water _ for Limerick. 6. An'immediate start of construction by PECO would only prevent the-staff from exercising its responsibilities and prerogatives to perform a thorough environmental evalua-tion of the supplemental cooling water system. An early I i start to construction would have the effect of a preemptive move, preventing the staff from carrying out its responsi-bilities under NEPA. IV. SECONDARY IMPACTS OF PPD 1. NEPA and the CEQ guidelines promulgated thereunder require consideration of secondary impacts of any major Federal action affecting the human - environment. Suburban development is clearly such a secondary impact. 2. Secondary ~ impacts were considered in the " Environ-mental Report on the Neshamint,yWater Supply System", Nesha-miny Water Resources Authority, Bucks County,

February, 1979.

However, the consideration of secondary impacts was cursory at best, occupying only two double-spaced pages. i 4 I

The analysis characterized the water supply aspect of PPD as responding "to needs created by the inevitable population increase rather than vice versa. ...The construction is in direct response to pleas by municipalities and water agen-cies in these areas for water to supplement their ground water supplies which have proven to be inadequate during low rainfall years..." Page V-31 of foregoing report. The report further states that zoning, subdivision regulations and floodplain ordinances are sufficient to control growth and protect the environment of the affected municipalities. However, there is no evidence that this assertion is true. There is no analysis of ordinances or of local administra-tive machinery for forming or carrying out of growth-management policy. 3. Secondary impacts are similarly reviewed in the " Final Environmental Assessment for the Neshaminy Water e Supply System", Delaware River Basin Commission, August, 1980. This report states that "The forecast water demands to be met by the proposed project are based upon revised population projections. Bucks and Montgomery counties will likely continue to experience growth and development with or without the Neshaminy Water System." Aforementioned report, pages 2-47 and 2-48. This report further asserts that the local communities would, through zoning, be able to control growth and influence development patterns in a way which would be beneficial. The assertion is made without proof. - -

4. The " Environmental Assessment Report and Findings, Point Pleasant Water Supply ' Project", of the Pennsylvania Department of. Environmental Resources, August, 1982, similar-ly asserts that the PPD Water Supply elements are simply responding to demand, and also asserts without proof that the project would encourage a more desirable pattern of growth and development. In itself, in any event, 'this acknowledges an impact. 5. Thernfore, it can be seen that the so-called analysis of secondary effects consists of (1) A Fatalistic acceptance of demands'for water based upon suburban growth as compelling an increase in the probably water supply by means of a diversion from the Delaware River, and (2), an optimistic but unproved assertion that local zoning and related ordinances can insure that growth will occur in an environmentally desirable fashion. 6. These analyses completely fail to recognize, let along analyze, alternative means of coping with asserted shortages in existing sources of probable water (predomin-antly ground water extraction). Such alternatives could include water conservation, growth management to guide suburban development in the greater Philadelphia area into part of the metropolitan area where water supply is not a

problem, and building and construction requirements, by i

means of rdinance or other regulations, which would allow better recharge by rainwater absorption of the aquifer serving the affected market area. (Construction methods for _-

insuring better efficiency in recharge of an aquifer, even with suburban land development, are well developed and recognized by the civil engineering profession.) 7. The so-called analyses of secondary impacts are extremely optimistic concerning the ability of local com-munities to formulate and implement a growth management policy. Absent proof that the communities in the region-served by Neshaminy Water Resources Authority are exceptions to the general rule and experience, the common experience of urban and suburban communities with the free granting of variances and exception from zoning ordinances throughout the United States undermines 1.he basis for any such optim-ism. V. WATER QUALITY IMPACTS 1. Del-AWARE's Petition of July 2, 1982, pointed out many water quality problems which will be exacerbated by PPD. 2. The water quality problems of the Delaware River, which are directly attributable to diversion ~and the deple-tive use of Delaware River Water, have recently been recogn-i=ed by the four states which are members of the Delaware River Basin Commission (New York, New Jersey, Pennsylvania, Delaware) and New York City. These entities have recently entered into " good faith" negotiations to revise the 1954 U.S. Supreme Court allocation of Delaware River Water and/or _ _ _ _ _ _

E management practices and augment reservoirs to maintain . water quality int he Delaware River. 3. The new discovery of the difficult Delaware River water quality problems is evidenced by the DRAFT " Recommend-ations and Background Report Concerning Interstate Water Management, Recommendation of the Parties to the U.S. Supreme Court Decree of 1954 to the Delaware River Basin Commission Pursuant to Commission Resolution 78-20", July, 1982, prepared by the staff of the parties and the Delaware River Basin Commission. A copy of.this report, which speaks clearly to the point, is attached hereto and incorporated herein. 4. The diversion of 95 million gallons per day at

PPD, approximately half of which would be lost through consumption at Limerick and evaporation and leakage losses in transmission from the Delaware River Watershed, can only make salinity and other water quality problems more serious.

5. Therefore, in light of the information reflected in the attached report, the permit by DRBC to divert water at the PPD is contestable. Del-AWARE, accordingly, has submitted a Petition to DRBC to reopen permit proceedings for the PPD diversion. 6. The worsened anticipated conditions documented in the attached " Background Report" constitute new circumst-ances which would require a new environmental evaluation of PPD, regardless of any other facts advanced by Del-AWARE. VI. CONCLUSION Section 2.206 of 10 C.F.R. provides an informal proce-dure by which the public may alert the staff of NRC to adverse impacts of nuclear plant construction or operation. Section 2.206 permits the Staff, in response to a Petition, to issue a "Show Cause" order under Section 2.202 of the Regulations if this is seem to be necessary. Such Show Cause Order may be immediately effective when circumstances require. Del-AWARE is requesting that such an immediately effective Show case Order be issued. This Order obviously would not cause the shut-down of an operating nuclear plant. It is even doubtful whether it would delay the start-up date of the Limerick plant. Hearings under the. Show Cause order could be held and concluded with ample time for PECO to construct whatever supplemental cooling water system is ultimately approved. Thus, prompt and timely action by the Staff to halt construction of PPD would not significantly burden the applicant, PECO. The only burden would be the legal costs associated with hearings, and the cost of litigation is not an unreasonable burden where interests protected by NEPA are at issue. On the other hand, failure to delay construction could cause either the commitment of economic resources by PECO to a construction project which ultimately would have to be dismantled, or, more likely, a commitment of environmental.--

resources in a way which ' would be, for practical purposes, irreversible even if the environmental cost was later shown to be too high and unnecessary. Although many studies of the environmental impacts of PPD and related construction have been made, these studies individually and taken together present numerous short-comings. As shown in Del-AWARE's Petition, and this Supple-ment, they fail to consider the entire complex focused on PPD in a comprehensive fashion, so as to draw into consider-ation any cumulative and synergistic effects. In addition, there appears to be no adequate consideration of the second-ary effects, i.e. suburban growth impacts, of alternative means of meeting the probable water requirements of the service area dependent on NWRA, of the wetland impact of the intake structure for PPD and of the problems presented by the ever-increasing burdens placed upon the Delaware River and water quality in the river. Also slighted are the impacts of this construction upon historic resources. Moreover, the NRC staff has committed itself in the past to a thorough environmental review of PPD. This review has not yet been performed. The hour is late, and Staff review completed after the beginning of construction would be, for practical purposes, irrelevant to a decision con-cerning construction of PPD. Once economic resources are committed, it is very heard to turn back the clock and pursue environmentally superior alternatives. The Petition of Del-AWARE and this Supplement show, at a minimum, that serious issues of environmental concern.have not be adequately evaluated. Granting the relief requested in this Petition, i.e. an immediately effective Show Cause Order, will not materially burden PECO. Failure to grant this relief will lead to commitment of environmental and economic resources in a way which can be deleterious-and unnecessary. The Petition, the Supplement, and correspon-dence which has occurred in the interim between submission of the Petition and this Supplement, clearly demonstrate that serious issues of fact remain to be resolved. The Atomic Safety and Licensing Board, in the Special Pre-hearing Conference Order of June 1, 1982, has indicated that a Petition to the Staff under 10 C.F.R. 2.206 is an appropri-ate procedure for resolving these issues. For issuance of a Show Cause Order, it is not necessary for Del-AWARE to prove "its case". It is sufficient that we have demonstrated that there are issues which require resolution. The appropriate place for contesting these

issues, should PECO wish to do so, is an adjudication pursuant to Section 2.202 of the Regulations.

In the circumstances, where issuance of the requested Show Cause Order cannot materially burden any party, and failure to do so could have irreversible and serious nega-tive consequences, Del-AWARE submits that the only reason-able. course of action for the Staff is to issue the reques-ted Order. Respectful] submitted, ROBERT J. SUGARMAN Counsel for Del-AWARE Unlimited, Inc. Of Counsel: SUGARMAN& DENWORTH .- 121 South Broad Street Suite 510 - Philadelphia, PA 19107. (215) 546-0162 Dated: November 8, 1982 207 e 4 4 5.

r,a ,y 9 4. UNITED STATES OF AMERICA { NUCLEAR REGULATORY COMMISSION ^ Before the Atomic Safety and Licensing Board In the Matter of ) ) Philadelphia Electric Company ) Docket Nos. 50-352 4 ) 50-353 (Limerick Generating Station, ) Units 1 and 2) ) Brief clarifying testimony by the Intervenor's witnes.3, Mr. Jonathan Phillippe, concerning hydraulic, hydrologic and related issues based on cross-examination testimony, further e ntudy and information only newly available to the witness. Five topics are addressed, as follow: 1. Flow patterns in the proposed Point Pleasant Pumping Station Intake' Area, e.g. below the mouth of Tohickon I. I Creek and the Lumberville ning dam. 2. Time of travel, Point Pleasant to Trenton 3. Accuracy of Applicant's Rating Curve g, 4. Utility of velocity measurements 1 S. Horizontal positioning considerations. 10/2.3 / 8 7 I t d 1-

( ,s. 1. ?;.,.,:atterns in the proposed Pt. Pleasant Pumping Station y Intds g, Iilre 1 and Figure 2 can be used to summarize observations cen:gr. t.g flow patterns in the Pt. Pleasant area. The follow- "I D'/:ssion represents the educated observations and opinions "I D -

• . Phillippe based on information presently available.

U* # # G 1:w flow hydraulic control of the river is provided by the :,'# arville wing dam at approximately river mile 155.90. t A shal,n area of the river having a more pronounced channel gradi*'t exists upstream of the mouth of the Tohickon Creek in the./icinity of the cross-section,22.56, at approximately

• 1. uile 157.08, surveyed for the " Corps of Engineers Tocks slar.<1,9:ervoir Study" in 19 64.

This Section 22.56 corresponds " '14'.9ral "rif fle area" immediately above the mouth of Tohick<,0 Creek. Stream velocities are accelerated in the riffle C'embined flows from the Delaware and the Tohickon Creek "#90 j' int upstream from the bar at the mouth of Tohickon Creek. The b,tr,tets as a constriction in the river under low flow con-itionn.,ihich concentrates the river flows to a channel mor'e ~ """C than upstream or downstream channels. In fact, the river < bannel does not return to its general cross-sectional chape r,*c several hundred feet below the proposed PPPS Intake. UH'1 r low flow conditions, flows up to approximately 9 6000 + '8 Cn, the bar tends to produce a cross-current component fr m th" Pennslyvania to the New Jersey sides. The bar itself, Cs indi.24ted in Figure 2, continues on toward the base of the >B

g,2 e a _x ~?+ -f-w ,3, , l,. h[' i,, ,J' proposed intake structure. However, since the bar becomes lowar as one moves from Tohickon creek toward the proposed bass of the intake structure, the flow in the river can expand cnd cubstantial velocity components. angling diagonally across the proposed intake structure can be anticipated particularly in tha flow range of 4000-5500 cfs. These velocity components can be expected to be most pronounced in the uppermost flow layers and to be less pronounced lower in the water column b:cause of the continuing constraints of the residual bar. One can contemplate velocity components from the deep channel, upstream of the intake structures, up and over the bar as well. l The eddy, as observed, exists because of the Ce formed t ? ~ by the Tohickon Creek bar. This volume of water below the bar L ih, cxpands and contracts only a small amount because the bar it-v- Golf continues, slightly submerged, for almost another one hun-ytG h dred feet channelward from the depiction on Figure 2. Conse-j? quently a large, relatively quiescent, volume of water below ,;cr the bar constitutes the eddy lows up to approximately 6000 cfs. >h ny, As shown in Figure 2, at flows above 6000 cfs the bar is over-y topoed and the eddy becomes washed out. At lower flows the eddy . f ;" a ~ bic'omes accelerated by the transfer of momentum from the main lfi< my e-current to the eddy. This energy transfer apparently continues I from the point the flow passes the bar to several hundred feet balow the proposed intake. Under steady-state conditions the t,4 cddy accelerates up to the velocity equal to that at the edge nf Cf the " main channel." As the flow rises, vortices are noted f'

w i in the transition between the eddy and the " main channel." It should be noted, that the " main channel" velocity is achieved cs the Delaware River flow passes through the " riffle area" up-ctream of the Tohickon, is merged with the Tohickon flow, and is This constrained by the bar at the mouth of the Tohickon. cccelerated flow becomes damped out somewhat within the " pool" created by the Lumberville dam as the flow is allowed to " spread out" across the river. It should also be noted that rising river stages probably are the assisting mechanism for adding quatic biota to the eddy, that falling levels of flow encourage cut-migration, and that at " steady-state" the integrity of the cddy is essentially maintained. Within the eddy, one can observe both upstream flow near the shore 4=-J3 and, of course, a downstream flow toward the channel. Because of shallow water and attendant higher energy losses the' nearshore upstream velocities are lower, of course than the downstream flow adjacent to the " main channel." Some-where near the bar the upstream flows are turned toward the i main channel. It can be postulated that the returning flows cre contrained by the submerged bar and tend to follow the sub-Earged Hickory Creek " channel". It is anticipated that at lower levels in the water column definite currents can be anti-Swimmers cipated and these will be directed as. discussed above. in the area report such currents, however the magnitude of these currents has never been measured in terms of direction.

,y,i .nr 4 .p e. 'lS? c.

2.

Finally, it should be noted that the river channel returns . s to its " normal" shape some 300-500 feet downstream of the pro-posed intake. From the latter area to above the Lumberville wingdam the channel remains relatively uniform. At the C of E curveyed Section 22.0, the river is somewhat constricted but the constriction is gradual. It can be anticipated that flow direc-tions will be uniform in this area and that a relatively high river velocity can be maintained. Also, the " main channel" is closer to the Pennsylvania than the New Jersey side of the river at Section 22.0, as well. .a Il 4 4 k , A ..e e 2-s. .A. v$ - ,Q 4_c' ,t r y.c bh Mc> T ?} U it ( g -- %?

f r3 h, ht'~ '}v - [{ ) h 2. Travel Time to Trenton. f At issue is the time it takes for flow observed at the ypps area to appear at Trenton. The following discussion is ps:d on review of time-of-travel studies (three) performed rf the New Jersey office of the U.S. Geological Survey. These studies were done to characterize a low flow regime in the river. The three studies were performed over the flow range of approxi-

stely 3500-3900 cfs, 4000-4500 cfs, and 6000-7000 cfs as mea-sured at Trenton.

For the 3500-3900 cfs range, time-of-travel between PPPS and Trenton was observed to be approximately 22 hours, with }.. average instream velocities in the PPPS area of 1.63 fps. For the 4000-4500 cfs range, time-of-travel was likewise observed-I w. to be approximately 20 hours, with average instream flow velocities of 1.82 fps in the PPPS area. For the 6000-7000 cfs 4 range, the corresponding time of travel was observed to be 16.5 hours, and the corresponding average velocities in the q PPPS area were 2.25 fps. [ [$ For higher streamflow, the USGS reports an expected time- ?,1) -Cf-travel of approximately 12 hours between Nockamixon and 7; Trenton as a guide used in its monthly reports of provisional off . flow data. e~ V 'D y k 2 t I

5 f q ^ e i y 3. Accuracy of the Rating Curve Submitted by E.H. Bourguard cnd Associates to Roy Denmark by letter dated January 22, 1982. At issue is the accuracy of the rating curve, since this vdedHU curve is the basis of streamEAowagreported elsewhere. The rating curve is extremely ~hard to evaluate. It pur-ports to have good measurements in the flow range from 2850 cfs through 376,000 cfs. However, flows under 5000 cfs are variably offected by the hydraulic control provided by the Lumberville wing dam. At flows below roughly 3000 cfs the weir section of 6[F the dam controls, between 3000 cfs and 5000 cfs control is pro-t vided by both the weir and the broad crested wing dam. The dam controls elevations at PPPS. Probably somewhere between 5000 cfs and 8000 cfs the effects of the dam are dissipated. Consequently, the upper flow portions of the rating curve pro-bably are realistic. However, even though the weir at Lumber-ville controls elevations at PPPS up to the 3000-3500 cfs level, establishment of a rating curve is difficult because the weir l Rets as a par.tially submerged weir rather than a free-overflow i Wair. I have developed a reasonable relationship but it is limited because of the very limited number of comparison points. 1 l It is clear, however, that one cannot simply extend the proferred rcting curve down to 65 feet msl, as has been suggested. i l The channel-storage methodology may be useful for adjusting rapidly varying flows observed in the upper ranges of the rating curve. However, the channel-ctorage is based, apparently, on I i f i

~ n. r k s- -l8 - -i '~ Y t m Y' spling cross-section$ from topographic maps and/or charts de-A picting " normal" river levels. Unfortunately, " normal" river ley.1s and flows do not reflect the conditions of interest under 1;w flow conditions. Basically, line2hrityisassumedunderlow-a flows as well as high flow conditions in the calculations pro-ferred. It is suspected that other non-linerarities, such as th: Lumberville Dam, exist under low-flows. The USGS time-of travel studies may be useful in constructing a rating curve b;cause between PPPS and Trenton various channel aberrations have b:en integrated so that one may be able to progress from PPPS to irenton while ignoring conditions in between, y A further problem exists in the flow range between 3000 and 1000 cfs in that the few observed " good" sets of flow values and elevations are closely clustered and, in several instances, are Contradictory. One elevation at PPPS has been coordinated with a PPPS flow Talue. Cert'in deficiencies have been noted in the handling of a the Delaware and Raritan Canal diversion. One can also note that L ~ e. "lWough the USGS staff characterized the Lumbervi11e measuremen't as 90cd, that characterizkaion indicates a variation of up to Mus ..? or minus five percent. o + f. 4 I i l' -

1. 1 f

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7, 4, velocity Measurements. At issue is the worth of velocity measurements used to support the Applicant's submissions. It is accepted that the flow-meter device used is essen-tially a state-of-the-art device and is probably sensitive to ths range of velocities anticipated. What is lacking, however, is the direction of maximum flow referenced to the centerline of the proposed intake. Also important jefunderstand the flow dynamics about the intake are flow measurements, with direction, at transects upstream and down-stream from the intake under various flow conditions. These lb' 3.~ conditions range from 2000-2500 cfs up to 6000 cfs. Beyond 6000 cfs the river is expected to begin to behave like other lf i: cross-sections downstream; e.g., after the bar has been sub-j stantially overtopped. I !L 1.r4 o I 1L I y k .j; I q. P i t a ( 1 i ? 4 .. ~ i 1%

E I h L 5. Horizontal Positioning. h _f i At issue here is the actual location of the various velocity measurements proferred by the Applicants. Two methods of horizontal positioning were reported for 4 1 two velocity surveys. I j A rangefinder was used for horizontal distance measurement f and a visual range object (s) was used. ~ Rangefinders using split-j image are based on optical-parallax and are quite sensitive to 1 l zechanical alignment of the optics. Distances as graduated on f } rangefinder scales are notoriously mismarked. Errors in cali-i j bration of a reliable surveying instrument are expected to be systematic and of an uniformly increasing or decreasing nature. I W.en non-systematic deviations are found, they are often indi-cative of mechanical problems. Such non-systematic deviations i Wre observed in the rangefinder used. 8j Stadia method's were used to provide horizontal positioning for the second velocity survey along with a transit line to main-tain proper horizontal alignment. The stadia approach is in- 'j erently rather reliable when performed with the transit and the I leVal rod, both on firm surfaces and over short distances, and is j 23eful in topographic surveying and landscaping layout ) , etc. It IS i Well known that although a transit may be used effectively eor accurate horizontal alignment, or angular measurement up l to 600 feet, visual resolution of instrument cross-hairs and

• 411-targe% deteriorate over greater distances, particularly Mere heat waves may interfere.

on stationary surfaces one can .,~

o'7 \\ it L - 5, (continued) a" anticipate horizontal accuracy to at least the nearest foot over sh:rt, less than 300 feet, distances. When the level rod is us:d on a moving, or non-stationary surface, accuracy is affected because the gradations on the rod represent a moving t:rgnt across a fixed set of stadia hairs, both of which need to b: read simultaneously. Thus, if the location is only n :ded to plus c: minus a few feet, then the stadia approach, whilo not optimal, i s adequate. Also, with greater distances cross-hairs tend to block out rod gradations tending to elicit from the observer inaccurate readings of a random nature. For diis reason, other methods of horizontal positioning are recom-

nded, such as

a floating tag-line with transit for alignment; two transits (and an accurately measured baseline between them) obssrving simultaneously a target on a boat; a combined theodo-lito with distance-meter

• or other, presently common, state-of-I the-c.rt methods.

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[ i ( 5 i elk 9.rrn,-E o 27JAN 1981 !!r. Corald Hanslar Executive Director DcInvare River !?r. sin Cor:alemfon P. O. Dox 7160 Went Tronton, N.J. OM.20 I ~ Daar Hr. !!antle : 'rnic vill acknowledga your 28 tsugust IMO lotts.r to re concening Point Ple-cr.cnt utcr divernion project. Your letter imilcated t.h:t the Delcutro River Dasht 0:rdicsica vaGT fn a rocition to cerely nith the twvisions of the n-tic.s1 Mir. tor Policy Act of 1M4 ns it' my pertain to thin dothet. Ca now t.we pc.: nit upplications frem the rioject croneors fo: portf of the work vithin Corpa' jurir diction. In proconsing theOo appli? the c.,rpo vill cceply with the cited 7.ct f.n cccord with 33 C?n 325c 7.t4xadix Cs a eg,y of thin rc;v3r,t f o:t is irrefosco. Cir.ccroly, I 1 Inci 1 JM;"S 0. d'XI Ao utato3 coloaci, Corps of Engincers Dirtrf ct i':qinocr ne/n. a e f[V 6 he' / kI / g. / / 1

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OFFICE OF THE TELEPHONES BOROUGH MANAGER SECY. 295-8181 295-8182 295-8183 295-8184 BOROUGH OF MORRISVILLE p' ',m. n e,.., m ) INCORPORATED A. D.1804 MORRISVILLE, BUCKS COUNTY, PA.19067 OCTII 1982 QT-Statement of i,,] BOROUGH OF MORRISVILLE and POLLUTION CONTROL GROUP OF LOVER BUCKS COUNTY Before the DELAVARE RIVER BASIN COMMISSION Concerning INTERSTATE VATER MANAGEMENT RECOMMENDATIONS September 29, 1982 Mr. Chairman, Members of the Delaware River Basin Coumission and Staff, and Ladies and Gentl'ement My name is Gretchen Leahy. I have been Environmental Coordinator of the Borough of Morrisville and Secretary of the Pollution Control Group of Lower Bucks County since 1973, and I have been actively involved l in Delaware Basin water resources planning activities at local, county, state and regional levels for the past eleven years as indicated on the attached page (Attachment 1). i i My comments today are on behalf of both the Borough and the Pollu-tion Control Group. We appreciate the opportunity to address the Com-I mission concerning the Draft Report Interstate Water Management Recom-mendations and its accompanying Background Report. The reports deal with a number of critical issues and policies that we have been concerned about since the Pollution Control Group's formation fourteen years ago.

I DltHC: INTERSTATE !!ATER MANAGEMENT 1(ECOMMENDATION". 9/29/82 Statrasnt ef: Bercugh of M:rrisvillo and tha .. P. o l. l. u t i o. n. C e. n. t. r. o. l.. G r. o. u f. o. f.. L. :. w. o. r.. B. u. c. k. s.. C. o. u. n. t. 7............. For those of you who are new to the Commission and its Staff, we offer both a cordial welcome and an attached brief explanation of the Pollution Control Group of Lower Bucks County. (Attachment 2) Over the years we have made a number of recommendations concerning policies and procedures regarding conservation and re-use of our re-sources, flexibility in meeting future needs, and reduction of costs and bureaucratic structure. Although we are one of few if not the only such technical committee in the Basin, our technical findings and our recommendations remain to date largely ignored by the DRBC Staff and by the Commission itself. It should be noted, however, that the tech-nical basis of most of our past findings and testimonies of long stand-ing has been recognized only in recent years through various govern-ment reports and technical studies. We appreciate the opportunity to comment on the two documents, Interstate Vater Mananement, Recommendations of the Parties to the U. S. Supremem Court Decree of 1954 to the Delaware River Basin Com-mission Pursuant to Commission Resolution 78-20, and the accompanying Background Report. The first part of our comments is concerned pri-marily with Section II, " Diversions, Releases and Reservoir Management During Drought" and germane matters. The latter part of our comments cites examples of other areas of concern of long standing. In some instances we have noted the numbers of specific recommendations to which our comments pertain. Where no numbers appear, our comments pertain to all the recommendations since they refer to fundamental policies which are basic to all Commission activities and decisions whether such policier or programs have been formally or otherwise acted upon by DRBC. This is in keeping with the Parties' statement in Section VII,

DRBC: INTERSTATE VATElt MANAGEMENT 1(ECOMMENDATIONS 9/29/82 Statsuont of Barcugh of Morrisville end tha Pollution Contr .................. o. l.. G ro u p o f Lo va. r.. B u c. k s Co. u n. t. y..................... 3..... " Enforcement", that all the Recommendations be considered as a whole, with each Recommendation being considered material to the whole. We must be assured of an adequate supply of good quality water at a reasonable price as population and water demand in the Delaware Basin increase. To that end, physical structures such as dams will be needed to some extent, and drought conditions must be planned for. It is ap-propriate to discuss potential solutions to the problems created by drought conditions. Fundamental to the finding of sound solutions is clear and accur-ate problem identification. As long as causes and effects of the prob-lems we face are not clearly and fully identified and differentiated between, recommended and proposed solutions will continue to be inequi-table and unsound. What is before us today is really two problems: one is how to meet out-of-basin water supply demands; the other is how to meet in-basin needs. Unfortunately, the documents before us neither diff-erentiate between the problems of out-of-basin demand and in-basin needs nor discuss how the problem of meeting out-of-basin demands adds I to and compounds the problem of meeting in-basin needs. In addition, the Interstate Vater Management Recommendations documents focus only on the water resources of the Delaware Basin and do not include water resources available to those areas that demand waters from the Delaware. I i Without these distinctions and absent any alternatives, it is ob-vious that the solutions recommended here are solutions to solve out-of-basin problems at the expense of in-basin needs, both in terma of quantity and quality of waters as well as economically. Furthermore, i

1 DRBC: INTERSTATE WATER MANAGEMENT RECOMMENDATIONS 9/29/82 Statem2nt of Borough of Morrisvilla and the Pollution Control Grou .........................p of Lower Bucks County.................................................. the documents confirm precisely what the Commission has been doing in the past, for example, during the drought of the sixties. The major demand on the Delaware Basin is that of the New York City water supply system. While New York City has built dams to meet its own demand and also to provide for flow augmentation to the Middle and Lower Delaware Basin, it is clear that the design of the City's Delaware system has been grossly inadequate. It is clear from the documents themselves that New York City's problem is its inability to take its maximum allowable Delaware water diversion of 800 mgd as an annual average with the condition that it provide sufficient water to maintain a downstream flow of at least 1750 cfs at Montague as decreed in 1954 by the Supreme Court. It is clear, too, that the documents pose to the people of the Delaware Basin not only the problem of managing the remaining waters ~ visely, but also the problem of compromising our own needs and resources in order to help New York City meet its demands. Our point is that New York City's problem of meeting the mandated 1750 cfs flow at Montague is precisely that it is New York's problem, not ours. New York is a water-rich state. For us even to enter into negotiations for lesser flows at any time under any circumstances is for us to assume responsibility for New York's problem. I New York City has many alternatives which would permit mainten-ance of the required 1750 cfs flow at Montague, for examples further l development of the vast resources of the lhtdson River including turning on the pumps at Chelsea, New York, as was safely done during the 1960's i

.3 DRBC: INTERSTATE WATER MANAGFHENT RECOMMEADATIONS 9/29/82 Statemrnt of Borough of Morrisvillo an(. ths Pollution Control Grou .........................pof Lower Bucks County........................................... 5...... drought, agressively metering the City and repairing system leakage, and enlargement of Cannonsville Reservoir. It should be remembered that drought is not a recent problem but is one of long standing, and that New York City has done little if anything of signifigance to solve its own water supply problems. If New York were not a water-rich state, or if the City had made a genuine effort to conserve and develop other water supply sources, we would be s'ympathetic to its needs and villing to share available resources. As it is, we are not. Under no circumstances should we permit the mandated 1750 cfs flow at Montague to be violated. We know of nothing in the intent of the 1954 Supreme Court Decree that requires downstream water users to share the cost of compensating for the New York diversion either direct-ly or indirectly, then or in the future. ~ It is obvious, then, that adoption of the recommended reservoir release program and drought operation formulas should be opposed by all. The proposed action would formally involve the Basin Commission I in New York City's problem of providing the necessary water to meet l the Supreme Court-mandated flow of 1750 cfs at Montague, and would do this at the expense of the Basin's resources including its people. We point out that DRBC has no regulatory or administrative authority and consequently no control over the use and management of waters be-yond the Delaware Basin's borders it can only make recommendations to the receivers of exported waters. If we adopt the proposed reservoir management program and drought operation formulas now, can other changes which would adversely affect l

DRBC: INTERSTATE VATER MANAGEMENT RECOMMENDATIONS 9/29/82 Stntenant of: Borough of M:rricville and tha .....l.lution Control Group of L:wcr Bucks County Po the Basin's water quantity, quality and costs be far behind? We cannot seriously talk of drought programs, storage needs, con-servation or a depletive water use budget when, after twenty years of existence, this Commission still has not established any policies on interbasin transfer of water for the protection of the Basin's resour-ces and its people. It is hard to fathom why the Commonwealth of Pennsylvania would be party to recommending interstate policies on interbasin transfers of water in the Delaware Basin that are contradictory to its own adop-ted policies on transfers of water between basins in the rest of the state. Pennsylvania's self-contradiction is even harder to understand since the recommended Delaware Basin interstate policies are largely at the expense of the Commonwealth. The essence of Pennsylvania's 1975-adopted policies regarding interbasin transfers in the rest of the Commonwealth is as follows: "a. Vater within the [ requesting 7 basin shall be developed 'to the fullest economic, environmental and hydrologic l extent before transfers will be considered. b. Future needs of the basin of origin shall be protected. l c. No transfers will be allowed without proper compensation to the basin of origin.

• Nothing less than that which is fully consistent with the above should be adopted by any agency including DRBC.

Ve note that had such policies been in effect in the basin, the form of the recommendations under consideration and of a goodly number of related federally and otherwise funded studies would be radically different from their ex-

• Dept. of Environmental Resources, Commonwealth of Pennsylvania, State Vater Plan Planning Principles (SVP-1), Harrisburg, March, 1975, p. 4.

l

DRBC: INTERSTATE WATER MANAGEMENT RECOMMENDATIONS 9/29/82 Stotsmsnt of Borcugh of Morriaville end the Pollution Control Grou .........................pof Lower Bucks County........................................... 7...... isting form. Additional relevant concerns that we have raised over the years are repeated again upon reviewing the two documents before us today. Unfortunately, we find that more of our concerns are omitted than are included. For examples (A) We are concerned about the continuing absence of any control over New York City's present and future water use during normal, non-drought conditions. ... Failure to address this concern increases the frequency of imposing drought warning and drought conditions on the Middle and Lower Delaware Basin. (B) We are concerned over the continuing absence of a specific sched-ule for development of New York City's Hudson River resources and for implementation of agressive conservation measures such as con-trol of system leakage and metering including retroactively. ... Water used by the Delaware Basin's 7,000,000 people is already over 90% metered, but the 18,000,000 people outside the Basin who use our water are only about 25% metered. Furthermore, 1 according to Commissioner McArdle, in 1979 there were only three wet industries in New York City, and the City's water use was 160-190 gallons per capita per day (160-190 gped) as compared to 100-130 gped nationally. The latter figure includes industrial as well as municipal water uses actual domestic water use is about 50 gped. ...Given these inequities and the absence of any control over

DRBC: INTERSTATE WATER MANAGEMENT RECOMMENDATIONS 9/29/82 Statsmsnt of Borough of Marrievillo end ths Pollution Contr ..................ol Group of Lower Bucks County -8 the dity's normal use and over parallel development of the City's own available resources, we' find: a. Use of storage conditions in New York City's Upper Dela-ware reservoirs as a trigger for declaring a basin-wide drought emergency under the Compact and for initiation of emergency in-basin conservation measures is inequitable and unreasonable. (Rec. 10) b. Any drought-imposed " conservation objective" of reduced in-basin depletive use and contingency plans applied only to in-basin water use are inequitable and unreasonable. (Rec. 11 and 12) Ve emphasize that New York City's stringent, drought-c. imposed conservation measures are inefficient as long as the City's normal, non-drought, wasteful use remains unchecked and its own available resources remain undevel-oped. Similarly, like percentage reductions of out-of-l basin and in-basin non-consumptive and consumptive water use are inequitable and unreasonable. (C) We are concerned that DRBC still has no legally established mini-mum flow to the head of the Estuary at Trenton, nor has the Com-mission set any upper limit on the amount of water that can be removed from the Basin either by exportation or by evaporation. ... Sympathy for New York City's water supply problems should be rooted out in any form, particularly in view of the following finding of the hovel B Study:

I DRBC: INTERSTATE WATEk MANAGEMENT REC 0rfMENDATIONS 9/29/82 Statemant eft Borough of Morricvillo nnd ths Fallution Contr .................. ol G roup of Lowe. r Bucko County................. 9..... (T)he controlling factor in sea salt intrusion may prove to be the total annual flow, rather than the manipulation of the waters remaining after export and consumptive use in order to sustain minimum flows during the summer months. If this is the case, a major concern should be the reduction of total annual depletive uses, (consump-tive and export use) not just emergency measures applied to the " dry" summer months. (Sic) * (D) We have long recommended development of a Basin-wide depletive water use budget including all exportaions, but we are concerned about inconsistencies in the structure of the depletive water use budget as presently recommended. We are concerned for a number of reasons, for example ... Exemption of areas from control is inconsistent with conservation. ... Exemption of the New York City reservoir drainage area or the area above Montague from control is inequitable and inconsis-tent with the " pooled waters" concept. ...Under the Basin's " pooled waters" concept, adopted policy is that all the Basin's waters form a single pool. It should be understood by all, however, that DRBC's existing and proposed regulations contradict Commission policy by separating the freshwater supply into three distinct pools:

1) New York City's pool;

2) the remaining Upper Basin pool,which includes the large Lackavaxen drainage basin and other tributaries as well as the waters between New York City's reservoirs and Montague; and 3) the watershed below Montague.

... Inequities already exist because of the three pools created _'spresent administrative structure (for example, water by DRBC

• P. 4, Delaware River Basin Comprehensive (Level B) Study Draft Final Report, October, 1979.

DRDC: INTERSTATE VATER MANAGEMENT RECOMMENDATIONS 9/29/82 Statement ofa Borough of M=rriavillo and ths Pollution Control Group of Lower Bucks Count ...............................................y............................ charges regulations). The proposed changes protect and enlarge New York City % pool at the expense of the Lower Basin. ...For all the asin's waters to work as one pool, the Basin's waters should be allocated both in proportion to contributing watershed area within the respective states and in proportion to in-basin population served within respective states. With respect to New York City, that portion of the pool controlled by New York City shall be in accordance with the mandates of the 1954 Supreme Court Decree, and none of the costs of the City's meeting its mandate shall be assessed against downstream water users. (E) Ve are concerned that the documents make no effort to relate flows to water quality despite known interdependencies, and that flows are related only to salinity. (Rec. 1) ...Ve note that although it is recommended that New York City's l flow requirements at Montague be relaxed only part of the time, l chloride standards would be relaxed all of the time. Vater quality is not improved by lowering existing salinity standards. ... Relaxation of existing chloride standards is inappropriate in the absence of full public evaluation of water quality ramifications including those referenced in the Level B Report as unknown and in need of further study and evaluation. l ...The documents fail to recognizes a. need for flushing; b. seasonal water quality impacts of en altered flow regime; l l

DRBC: INTERSTATE WATER MANAGEMENT RECO.fiENDATIONS 9/29/82 I Stnteernt of: Barough of Morrisvillo cnd ths Pallutien Control Group of Lower Bucks County........................................................................... c. the value of water to the stream itself; and d. that the Delaware is a resource and a commodity of incal-culable value. (F) We are also concerned that it is not generally known either what the costs will be or who vill bear the costs of off-setting adverse water quality impacts in the River system caused by the proposed actions. We are concerned, too, that the documents fail to provide this basic information to the Basin's people. ...It is unconscionable that this Commission, charged with the responsibility of protecting the resources and people of the Delaware Basin, vould justify removing water from the River and Estuary by these documents, then turn around and tell the i Basin's people they must buy back presently existing flows of water. Yet this is precisely the assumption made by DRBC in its May, 1981, Final Level B Report regarding the cost of enlarging New York City's Cannonsville Reservoir for flow augmentation. DRBC would have the people of the Delaware Basin bear costs of this project, as per footnote 4, Table 23. (Attmt. 3) ...This type of information should be in the body of that report rather than in its footnotes. Also, DRBC is being less than forthright in omitting this information from the body of the documents under comment today as well. I i ...Again, it is New York's problem to supply the 1750 cfs flow at Montague and to bear all costs of doing so, not our problem. No action whatsoever should be taken to reduce flows below the presently mandated level at Montague, to lower existing salin-t

DRBC: INTERSTATE VATER MANAGEMENT RECOMMENDATIONS 9/29/82 Statsusnt of Borough of florrisvillo cud ths Pollutien Control Grou .........................pof Lower Bucks County........................................... 2 - 1 ity standards or to reduce the present 3000 cfs flow objective at Trentdjvithout full public knowledge of who vill bear the consequences and costs of recommended cources of action. (G) We are concerned about the inconsistency of DRBC's application of the Montana Method in setting minimum stream flows. ...The Montana Method which correlates stream flow with water quality is not used on the main stem of the Delaware, but is recommended by DRBC Staff for use elsewhere in the Basin, for example, on Little lierril'1 Creek. ...Ve note that improving water quality in the Delaware River and Estuary for fish, vildlife and recreation is a priority item in the Level B and other studies. (H) We are concerned that the documents fail to reveal what method or methods will be used to calculate flows at various control points in the Basin, and that it is therefor unclear whether measured flows vill be actual flows of real water usable by people, fish and other aquasic life, or vill be " equivalent flows" as set forth in DRBC's Level B Study. l ...An " equivalent flow" is an amount of water measured elsewhere and then calculated as if the water actually flowed by a con-trol point when in fact it has not. i ...Public attention was first called to the " equivalent flow" concept following DkBC's publication in October, 1979, of its Draft Final Level B lleport. l l t

DRBC: INTERSTATE WATER MANAGEf1ENT RECOMMENDATIO??S 9/29/82 Statensnt of Borough of Morrieville end ths Pollutien Control Grou -1 .........................p of Lower Bucks.. County.......................... 3..... ...On March 30, 1981, DRBC's Executive Director testified berore the U. S. Ilouse Subcommittee on Vater Resources that the " equivalent flow" concept had been dropped from the Level B Study. ...In May, 1981, DRBC published its Final Lavel B Report which included as well as the concept itself

1) a number et sections justifying its use;

2) a table showing how amounts of water diverted above Trenton are subtracted from the Trenton flow objective, how cmounts of water projected as being conserved below Trenton are subtracted from the Trenton flow objective, and how the Trenton flow objective has thus been reduced from 2690 cfs to 2340 cfs (i.e., to 20% of the average annual flow at Trenton);

3) a number of other tables using " equivalent flovs" as the basis for determining New York City diversions, flows at Montague, and projected impoundment costs and yields; and 4) in its Final Environmental Impact Statement Section the statement, "This concept is eliminated in the Final Report."

...Use of the" equivalent flow" concept is inconsistent with DRBC dockets which cite specific control point figures as triggers for compensating reservoir releases. (I) Last but not least, we are deeply concerned that wording regarding sustainable flow has been changed from " minimum sustainable flow" to " maximum sustainable flow". ...This as per the May, 1981, Final Level B Report notwithstanding the Executive Director's additional denial of this concept at the aforementioned Congressional IIcaring on March 30, 1981.

DRBC: INTERSTATE VATER ?!A?!AGEMENT REC 061ME?lDATIONS 9/29/82 Statem2nt of: Barcugh of Morrisvillo and the Pol.lu. tion.. Control Grc.up of Lower Bucks County......... ...For example, where ve once had 2700 cfs as minimum sustainable flow at Trenton, this change would permit DRBC to operate the Basin's water resources with 2340 cfs or less as the maximum sustainable flow at Trenton. In short, we find that the Interstate Water Hanagement Recommenda-tions of the Parties to the U. S. Supreme Court Decree of 1954 to the Delaware River Basin Commission are inconsistent with the charge of the Commission, that they adversely affect the Basin's Comprehensive Plan and that they should be rejected virtually in toto by all. If the Commission and its Staff persist in deceiving and mislead-ing the Basin's people by withholding critical information and misrep-resenting that which is presented for public review, we cannot survive as a viable River Basin. Respectfully submitted, ~ Ua Gretchen V. Leahy Environmental Coordinator, Borough of Morrisville Secretary, Pollution Control Group of Lower Bucks County i l

I Attachmsnt # 1, DRBC, 9/29/82, p.15 Gratshan V. Ioahy Wat^r R:courc:a Cr:dintinio - May 15, 1979 B. A., Smith Co11eBe, 1949 (All water resources activities have been on a voluntary, unremunerated basis.) Independent study in Water Fesources field 1971-Borough of Merrisvillehiorr$ sville }!unicipal Authority Environinental Coordinator 1973-Pollution Control Group of Lcwer Bucks County Co-representative 1973-Fxecutive Secretary 197h-Neshaminy Water Resources Authority Assistant Secretary /Trensurer; Secretary 1976-78 Fucks County ?! aster Plan for Water Supply Advisory Committee regularly attending voting member 1973-75 Pennsylvania State Water Plan Subconnittee on Water Resources regularly attending voting mcmber 1973-78 Pcnnsylvania Comprehensive Water Quality Management Plan (COWAFP/208) 1975-78 Municipal Dischargers Subcommittee regularly attending voting member Industrial Dischargers Jubcommittee regularly attending voting member Fun./Indil. Dischgrs. Joint Subcom. regularly attending voting member (succeeded previous committees) Study Advisory Committee (SAC) non-voting participating member Technical Advisory Committee (TAC) participating obstrver Policy Advisory Committee (PAC) non-participating observer; participant where pennitted by structure (e.g., joint connittee meetings) County Forums and related meetings e.g., Year 2000 Forums Special meetings with Staff and Consultants Delaware Tstuary Model Study 1976-Technical Advisory Committee non-participating observer Policy Advisory Connittee participating observer at certain joint meetings with Fstuary Model TAC Coastal Zone Panagement Plan County Forums regular attendee 1975-Study Steering Conmittee regular attendee 1975-76 regularly attending member 1976-(Lower Bucks County runicipal Governnents Fepresentative) Level B Cor.prehensive Study 2 Delaware River Fasin 1977-Invited Observer non-voting participant . tudy Advisory Cornittee participating member

F Attochmsnt

1. 2:

DRBC POLLUTION CONTROL GROUP OF LOWER BUCKS COUNTI 9/29/G2 The Pollution Control Group of Lower Ducks County is a voluntary, non-funded, non-partisan, technical advisory committee comprised of water quality control professionals who represent the major municipal and industrial water suppliers, users and dischargers located in the highly developed, heavily industrialized lover part of Bucks County, Pennsylvania. The area begins immediately north of Philadelphia and extends along the upper reach of the Delaware Estuary to the Estuary's headwaters at.Morrisville, Pennsylvania, directly across the River from Trenton, New Jersey. Together the municipalities and industries we represent employ about 8,000 people and provide more than 200,000 people in the Basin's economic henrtland with water supply, pollution abatement and vaste treatment services. The Pollution Control Group was formed in'1968 in response to DRBC's request that the~se municipalities and industries perform a technical evaluation of a then-proposed Upper Estuary facility. Since that time ve have continued to offer joint technical testimonies consisting of our findings based on publicly available government data and studies, and our recommendations. Our testimonica document our continuing concern over the ways in which various aspects of water resources planning and management may affect water quantity, quality and costs in the Delaware River Basin and in the Upper Estuary in particular since it is the most sensitive and thus the critical part of the system, and how such programs, projects l and policies or lack of same may affect the health, safety and welfare of th'e people of the Delaware Basin. l

] e Attschn nt ( M 38 DRBC TA8LE 23 9/29/82 COST AND AUCIENTED Y1 ELD OF PROPOSED IMPOUNDMENTS FOR FLOW AUCMENTATION W (4 A i n) Source: Delaware River Basin Compre-Allocated Capital Augmented Yield, cfs Capital Cost hensive (Level d) dtudy, final iteport Dnd Environmental Impact Statement, ugme t n n n Augm nte teld DHBC, May, 1981. 4 Comprehensive Plan Impoundments Aquashicola $ 70 million 100 $700,000 3 $330,000 Maiden Creek $101 million 310 Prompton (Mod.) $ 19 million 130 $150,000 Tocks Island $152 million 1790 $ 85,000 S 28 million 165 $170,000 Trexler Walter (Mod.) $ 46 million 290 $160,000 Impoundments Identified by URS/Madigan-Praeger FOOTNOTES TO TABLE 23 Cirard S 46 million 80 $570,000 $ 73 million 120 $610,000 gCosts fnt the on-stream impoundments (Comprehensive $ 45 million$ 130 $350,000 rian impoundments, those identified by URS/Madigan-Hawlev $261 million 740 $350,000 Praeger, and the cannonsville modification) are based itacke ttstown 80 $550,000 on October 1977 costs. Costs for off-stream in-Lackawaxen McMichael $ 44 million 80 $340,000 poundments based on the 3 percent higher June 1978 Shohola Falls $ 27 million $220,000 There is no need for further refinement - $ 77 million 350 costs. Tobyhanna costs and yields are approximate. Other (Cannonsville Mod.)_ bugmented yield estimated by dividing flow augmen-4 Cannonsville (Mod.) $ 1 million' 85 $ 12,000 tation storage by 120 day u assumes full to empty - storage uniform withdrawal for this period of time. Off-Stream impoundment's 3 ugmented yield at confluence of Schuylkill River A Cherry Creek $210 million 1800 $117,000 with Delaware River. Same method as Note 2 used $133 million 560 $240,000 for determining equivalent flows for salinity repulsion r.quinunk Flat Drook $125 million 1050 $120,000 W r m es. Little Martins Creek $ 96 million 370 $260,000 4 Assumes half of project cost and storage dedicated Merrill Creek $ 88 million 220 $400,000 for flow augmentation of Delaware River at Trenton. M11anv111e $115 million 550 $210,000 Pideock Creek $122 million 620 $200,000 5Cost discountcJ to 1977 dollars. No allocation Mill Creek $ 79 million 2703 $290,000 for future Water supply or recreation benefits. 3 Red Creek $ 81 million 340 $240,000 ath ; VT @ ** i w N n N r I @ t5 E _a NW c N@Ub l NOe 66 I $i ) 3

I s .;u t / 'jo er O Yg 5 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION lli 6TH AND WALNUT STREETS PHILADELPHI A. PENN5YLVANI A 19106 FEB 17198) \\- / Mr. Robert L. Tedesco Assistant Director for Licensing / Department of Licensing U.S. Nuclear Regulatory Commission Washington,.DC 20555 6ea'r Mr.'Tedesco: ~~ ~ ~ ' Philadelphia Electric Company's Limerick nuclear facility is a complex project that has been controversial for many years. We have recently been involved in numerous meetings with the Delaware River Basin Commission (DRBC) concerning plans to permit diversion of water from the Delaware River in part for supplemental cooling water supply *for the facility. / We are particularly concerned with the consumptive use of scarce water resources, the mechanisms for provision of the necessary storage, and the physical and / biological impacts on the natural streams which will convey the flows to ' Limerick. Therefore, we were pleased to hear from the DRBC, from Dr. Samworth at IRC in Washington, and from the article quoting you in the Philadelphia Inquirer (February 10, 1981) that NRC is planning to prepare Draft and Final Environ-[ ' mental Impact Statement supplements prior to issuance of an operating license for Limerick. We were also encouraged to n:ste that you will be including review of the impacts of the supplemental cooling water diversion..)(I DRBC has indicated that they would like to consult and coordinate with you on those portions of the EIS. Since, as required by the National Environmental. Policy Act, EPA will be reviewing the EISs, we would like to participate in the project scoping and meetings so as to address the concerns we have raised in the past provide for their resolution in a timely fashion during EIS preparation. We are looking forward to working with you. Sincerely, s j / George D. Pence, Jr., C.ief ~ Environmental Impact Branch 1 J

acuzw w v.3iu r

• I h'*=,_

..e,,, gy 8 / gr. [J pkhI. hk) BUCKS COUNTY CONSERVANCY Y !&.;d. id. W pty ~ CONSERVANCY 11 North Main Street, Doylestown, Pennsylvania 18901 1215) 345-7020 November 27, 1981 Mr. Ron Eller U. S. Army Corps of Engineers Philadelphia District U. S. Customs House 2nd & Chestnut Streets Phil adelphia, PA 19106

Dear Mr. Eller:

Pursuant to our telephone conversation of November 12, 1981 and previous correspondance to the Corps I am submitting comments to the Eligibility Determination Report prepared - by Ms. Elizabeth Mintz August 1981. This report is in reference to the historic resources located in the area of p# Point Pleasant, Bucks County, Pennsylvania which are being reviewed at this time with regard to the effects of the proposed pumping station. Please accept these comments and forward them to all agencies and individuals responsible for the review o f this proj ect. ? Thank you for the time extended to the Conservancy to prepare these comments. Sincerely, },b-t jk.I w l w Kathryn Ahn Auerbach Director, Historical Sites Survey Enclosure b l Ultif.f.lf)Iti William Arney

• f.fri. Eol,er1 filifdic Ill
• Bo!>crt C. EocHnc
• T. Stdney Ca dw allader. Dq. e Fionnan J. Dnntivp

) N str> rauf flack

• Kenneth W. Ccmmitt. I:sti.
• Wil!!am F. Herfncr, Dq
• tewis Itull
• VI'611 rauriman I.to,s d ll klaritin
• 1.loyd Lawrrnte
• F.frs. fred W. I.ittle
• 7.f rs. Rc ntan t tcInIn;;cr. Jr.
• William C. r.id e e Harley t. Stowtfl 6

stariin Sutton a ref er A. Clasr ott, F.ul., Solicitor

• Enfiert W. Picnon. Encurlie Dirrcror

11 Nor th Main Street, Doyicstown, Pennsylvania 1 Bt.'C.KS COUNTY CONSERVANCY o T \\. November 28, 1981 I do hereby a f firm tha t I am an authorized representa tive of the U. S. A rmy Corps of Engineers, Philadelphia Branch and have been instructed by Mr. Ron Eller to receive a packet of informa tion from the Bucks County Conservancy of the above address con ta ining comments on the Eligibility Determina tion Report prepared by Ms. Elizabeth Mintz regarding the area of Point Pleasant, Bucks County, PA. I have received such package and will deliver accordingly. A (U W E ll-2 6 - Sj i Sign d; v G Q *].0 Yl?Ath Print.ed ~ e T r e ) O S van.

11 North Main Street, Doylestown, Pcnnsylvania 18 BUCKS COUNTY CONSliRVANCY c \\ POINT PLEASANT IIISTORIC AND ARCIIAEOLOGICAL DISTRICT domments and Criticisms rega rding the Recuest for Determination of Eligibility prepared by Elizabeth Mintz for the Army Corps of Engineers August 1981 Prepared by Ka thryn Auerbach Director, Historical Sites Survey Bucks Coun ty Conservancy November 1981 l' s. + O e

11 North Main Strcet, Doylestown, Pennsylvania 185 BUGKS COUN1 Y CONSERVANCY o l. . POINT PLEASANT HISTORIC AND ARCHAEOLOGICAL DISTRICT Table of Contents: - General and Specific Comments 18 pages - Maps 3 pages - Informa tion prepared by the Bucks County Conservancy, March 1980 10 pages - Informa tion resea rched by Mrs. Helen Sirmay, April 1981 7 pages N. m O e e $s

11 North Main Succt, Doylestown, Pcnnsylvani BUCKS COUNTY CONSERVANCY o .e a POINT ' PLEASANT HISTORIC AND ARCHAEOLOGICAL DISTRICT General Comments Specific Comments 9 e O e

BUCKS COUNTY CONSE14VANCY 11 North Mdn Street, Doylestown, Pennsylvania IB o I. POINT PLEASANT HISTORIC AND ARCHNEOLdGICAL DISTRICT Comments and criticisms regarding the Request for Determination _of Eligibility prepared'by Elizabeth Mintz for the Army Corps of Engineers August 1981 General Comments _ In March 1980 the Bucks County Conservancy was apprised of the Point Pleasant Pumping Sta tion proposal and its loca tion with-in a potential historic and archaeological district. Although scheduled to conduct other survey and register work a t the time, the Conservancy recognized the threa t this project could pose to the historic village and worked quickly with local residents to gather enough informa tion so tha t s ta te and federa1 officials would recognize the historic and prehistoric resources and pro-vide the area with a proper review. Within one week the information was prepared and delivered on March 10, 1980 to Mrs. Brenda Barrett of the then Office of Historic Preservation of the Pennsylvania Historical and Museum Commission. While brief, and in some sections not fully devel-oped, the informa tion submitted clearly defined the extent of _ the district and the major developement trends throughout its history. The Conservancy encourag'ed volunteers to continue C..- the research 'and the ca taloguing of buildings which proceeded a t a slow but s teady ra te.. For purposes of environmental review, the Conservancy provided the National Register. of Historic Places with a copy of the g above prepa red informa tion. On November 7, 1980 the Conservancy submitted additional information to the Pennsylvania Historical and Museum Commission and on November 10, 1980 Point Pleasant . as listed as an historic district on the Pennsylvania Inventory. w l On December 18, 1980 the village was accept'ed to the Bucks County l Regis ter of. His toric Places. i l In April 1981 the Conservancy met with representatives of the Pennsylvania His torical and Museum Commission, the Army Corps of Engineers, the Neshaminy Wa ter Resources Authority (proposing the project) and the Philadelphia office of the Heritage, Con-serva tion and Recreation Service to discuss the effects of.the proposed pumping sta tion on the pre-historic and historic re-l sources and wha t documenta tion was necessary for further and complete review of.the project. l The conservancy commented tha t a cultural Resource S tudl pre-l pared,in 1978 by Edward Shortman' and Pa tricia Urban did not mention the existence of the Point Pleasant district and did not i N 1 l November 1981 Page 1- .l

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BUCKS COUNTY CONSERVANCY 11 North Main Street, Doylest wn, Pennsylvania 185 o POINT PLEASANT HISTORICAL AND ARCilAEOLOGICAL DISTRICT i comments and criticisms regarding the Request for Determination _of Eligibility prepared by Elizabeth Mintz for the Army Corps of Engineers August 1981 General Comment 3 (continued) s adequa tely loca te or analyze the ' Indian village site studied by Dr. Henry Mercer in the immediate vicinity of the proposed pumping sta tion. The HCRS commented tha t more in-depth informa-tion than had been officially presented by the Conservancy was needed on the historic and archaeological district and the Loundaries j u s ti fi ed. The Conservancy and the PHMC concurred and recommended further study by contract with the Army Corps. It was the Conservancy's intention in recommending this s tudy to have the opportunity to clarify the fa c ts tha t were vague, expand upon the information tha t was previously submitted and secure the proposed boundaries with sound geographical, archae-ological and historical jus tifica tion. The Conservancy was initially dismayed to hear the contract was s awarded to someone who had not had contact with the Conservancy nor had done much (if any) research in Bucks County. We were further ala rmed when we noted tha t the contractor, Ms. Elizabeth Mintz, did not contact our office for the informa tion 'we had on file (some of which was in addition to tha t which had been pre- { . viously submitted) nor for preciso items requiring in-icpth s research to clari fy certain historical beliefs and fa c ts. When the Conservancy received a copy of the Mintz report from the Army Corps on September 10, 1981, it became obvious that,she re-researched wha t the Conservancy had already done and.irew conclusions without the benefit of a basic knowledge ana under-s tanding of a rchitectural and developmental trends of the central por tion of Bucks Coun ty. Furthermore, and totally ' inexcusable, is the deletion of the Tinicum Township section of Point Pleasant in the definition of the district boundaries. The dis trict with boundaries including the Tinicum section was approved by both the Bucks County Regic- -ter of His toric Places and the Pennsylvania Inventory. While Ms. Mintz does comrent on the exis te.nce of historical resources i in Tinicum, she does not give any justifica tion as to why they I are not included in the dis trict. The result is an unbalanced presentation of the Historical and Archaeological Distcict of Point Pleasant and a report tha t supplied no new in forma tion. It is unfor tuna te that the exis ting informa tion in the Conser-vancy of fice was not used in the ~ prepa ra tion of the Mintz report _so tha t new and more accura te comments could be presented._ The Conserva ncy 's prima ry concern is to have Point Pleasant Historical and Archaeological Dis trict represented a t all levels of review as thoroughly and correctly as possible. We requested of the Army Corps the opportunity to submit comments and criti-November 1981 Page 2

BUCKS. COUNTY CONSERVANCY 11 North Main Sucet. Doylestown, Pennsylvania Ib' o t. POIliT PLEASANT HISTORICAL AND ARCHAEOLOGICAL DISTRICT Comments and criticisms regarding the Request for Determina tion _ of Eligibility prepared by Elizabeth Mintz for the Army Corps of Engineers August 1981 General, Comments _ (continued) cisms on the Mintz report in order that all records are a consistent and proper documenta tion of Point Pleastn t. On November 12, 1981 in a telephone conversa tion with Ms. Ka thryn Auerbach of the Conservancy Mr. Ron Eller requested that cominents on the inaccuracies of the Mintz report be as detailed and specific as possible. To this end the report has been reviewed section by section, paragraph by paragraph; In some cases the comments may not a f fect the review of the pumping s ta tion pro-ject or may appear pe tty, bu t they are made to be his torically accurate and consistent with other documenta tion of Point Pleasant. Some of Ms. Mintz ' mistakes are sloppy and not expected from a professional researcher. The deletion of the Tinicum Township section of the district alone would require the rewriting of the report. In addition, it is the opinion of the Conservancy historical staff tha t the village developed in response to na tural fea tures and transpor-r. ta tion routes and not pa r ticula rly to English community planning \\, concepts. Wha t can be said for thelatter theory is that English (and other na tional an. ethnic) community planning in rural Bucks Coun ty essen tially took the form of responding to the given na tional resources and practical use and development,of transpor ta tion rou tes. In that sense Point Pleasant does repre e cent community development although not conscious planning of a town system tha t interrela tes. Point Pleasant is very important in th'c study of Delaware River l towns and villages. It is also very valuable from the point of I view of archaeology, having such a complex variety of sites within one area. Despite her lack of contact with the Conservancy and limited knowledge of Bucks County, Ms. Mintz did stress the value of the archaeological sites and his torfc district that she defined and expressed most of the development trends important to the evolution of Point Pleasant. Point Pleasant is a valid and valuable historical and archac-ological district and we hope the Army Corps will accept our coraments with the sinceres t intentions. Ka thryn Ann Auerbach Director, Historical Sites Survey Bucks Coun ty Conservancy November 1981 Page 3

'.mt,hp LUL,N 1 i LU4M.)C.h \\' /W L Y 11 hea th hin du ed, uupa.vM. A umu ab ~ - o POINT PLEASANT HISTORIC AND ARCHAEOLOGICAL DISTRICT Comments and criticisms regarding the Request for Determination of Eligibility. prepared by Elizabeth Mintz for the Army Corps of Engineers August 1981 SPeci fi_C, ;comm_e n t_s_ Cover Page: PROPERTY NAME: The firs t recorded name for the Plums tead side of the area later to be named Point Pleasa nt was appa ren tly "Pearson's Ferry." However, a more common, and longer lived, historic name would be " Black's Eddy" or " Lower Black's Eddy" for the Swartz (Bla ck) family who owned considerable property, including the ferry and tavern during the developmental years of the village. Although the name " Black's Eddy" was supplanted in 1828 by " Point Pleasant" by the Post Of fice Depar tment, the name has been ma inta ined, in part, due to the naming of " Upper Black Eddy" village in Bridgeton Township in the nineteenth century, the name by which this Bridgeton village is known today. ( LOCATION: The researcher's assertion tha t the Point Pleasant District is located in Plums tead Township reveals a basic flaw in the documenta tion. Although the Army Corps of Engineers is specifically in teres ted in the portion of the proposed district which is s itua te in Plums tead (re the Point Plea-sant Pumping Sta tion), the proposed historic and archaeo-logical district is not wholly contained in Plumstead, but encompasses much in Tinicum Township as well, with substan-tial buildings and sites of significance in each. Any his-torically ~ and a rchaeologically adequa te represen ta tion of Point Pleasant must include the areas in both townships. The supposition tha t the Point Pleasant district lie.s to-tally in Plums tead Township leads to repeated defects in-the presen ta tion, -omitting impor tant aspects of the village's physical description dnd historic significance. The brief Verbal Boundary Description given here if mapped according to present day land forms and tax parcels does not connect in several places. CLASSIFICATION : ~ Historic and Archaeoloi ical Dis trict. Due to the diverse l and extensive prehistorical sites known to exist in this Novenber 1981 Page 4 1.

11 Nonh Main Sucet, Doylestown, Pennsylvania 10 BU.CKS COUNTY CONSERVANCY o l[ POINT PLEASANT llISTORIC AND ARCIIAEOI )GICAL DISTRICT Comments and criticisms regarding the Reques t for Determina tion of Eligiblity prepared by Elizabeth Mintz for the Army Corps of Engineers August 1981 Speci fic C_omm_en_t3 CIASSIFICATION : Cover page (continued) area (more extensive than in most areas of Bucks County) the Conservancy feels it is appropria te to classify the area it has defined as the village of Point Pleasant to also be an archaeological district. PREPRES ENTATION IN EXISTING SURVEYS: 1. Point Pleasan t IIIs toric Dis trict was lis ted on the Bucks County Register of Historic Places December 18, 1900. 2. Point Pleasant Historic District was listed on the Pennsylvania Inventory of Historic Places Nov. 10, 1980. Map: POINT PLEASANT, PENNSYINANIA, HISTORIC DISTRICT BOUNDARIES 8/81: As men tioned before, the entire section of Point Pleasant in Tinicum Township has been deleted from the dis trict with no justifica tion. In addition, the Conservancy feels C, that the properties on either side of Tohickon Hill Road up to and including #34-18-94 be included in the district as it is fel t the approxi ma to 300' eleya tion.line forms a na' ural and ef fective bounda ry dis tinction.. (See enclosed map of boundaries proposed by the Bucks County conservancy).? PHYSICAL DESCRIPTION: Page 1 1st Pa ragraph: The his toric dis trict should include Tinicum Township. l This above cited limited understanding of the proposed district makes the resea rcher's physical description I s ta tement incomplete. The dis trict is loca ted in the eenI ra1 pa rt of Bucks Coun ty " Centra 1" Bucks Coun ty is not an of ficial term; the "C" should not be capitalized. (S a also pages 9 and 16 of the Mintz repor t.) l 2n' Pa ragraph: "... developmental his tory of the 18th Cen tury English..." should read, "18th and 19 th Cen tury, English and German... " l 3rd Paragraph: The unity among the developmental trends representing different periods of growth is the control imposed by the surrounding na tural fea tures of the a rea and how a l November 1981 Page 5

DUCKS COUNTY C6NSERVANCY 11 North Main Stre;t, Dsylestcwn, Pennsylvanh 18 o i POINT PLEASANT HISTORIC AND ARCllAEOL' GICAL DISTRICT O Comments and criticisms rega rding the Request for Determina tion for Eligibility _ prepared by Elizabeth 14intz for the Army Corps of Engineers August 1981 Specif_ic Commen ts_ PHYSICAL DESCRIPTION: Page 1 3rd.Pa ragraph : (continued) the various transporta tion links enter into and cross ,this area. Early 18th century English settlement was not extensive enough to crea te a structure by which la ter development was inserted. The early settlement was controlled by the na tural terrain and access to resources. The village today does have a very rural, r_.nbling cha racter lacking sidewalks, straight roads, etc., which may be wha t 14s.14intz is referring to as 18th century English. 4th Paragraph: Ms. Mintz does not clearly define wha t she feels is the " village core". Since as early as 1800, and definitely by 1828 when the pos t of fice was moved, rein forced by the Point Pleasant Pike and Delaware bridge c.

1850,

-(- through to today, the village core is the bridge over the Tohickon Creek leading to the Point Picasant Hotel (Trading Pos t). The village core of the mid-18th cen tury was probably the area a t the foot of River, Hill (Old Ferry) Road. The Ferry Road was laid out c.1738 from Chalfont (Bu tler 's Mill, 11 miles southwest of Point Pleasal t) and was a point of access as impor-tant as River Road. Ms. Mintz' s ta tement, " Sense of. place and cohesiveness crea ted by the English..." is inadequate. Subs tantial settlement by. Germans and other ~ groups took place a f ter 1760. 5th Pa ragraph: l As mentioned before the Verbal Boundary Description needs to be rewritten and. the boundaries more justifi-ably defined (particularly to include the Tinicum Township portion of the village). The Pennsylvania-New Jersey border does not connect to the rear property line of the Stover Mill (4 4-3 2-2 ). 1 PHYSICAL DESCRIPTION: Page 2 1st paragraph: (con tinued from page 1) l Refer to previous c'omments regarding including Tinicum l, Township section of Point Pleasant. See enclosed map t 1. November 1981 Page 6 1

BUCKS COUNTY CONSERVANCY o 11 North Main Sircet, Doylestown, Pennsylvania IM POINT PLEASTN T HISTORIC AND ARCHAEOLOGICAL DISTRICT Comenents and criticisms regarding the Request for Determination _ of Eligibility prepared by Elizabeth Mintz for the Army Corps of Engineers August 1981. Specific Comments PlfYSICAL DESCRIPTION: Pag'e 2 1st Paragraph (continued) for the Conservancy's proposed boundaries which are de-fined by the elevation lines (approxima tely 300 ', ), the prehistoric and historic sites. Ms. Mintz mentions again the " core of thg/early village" being in Plumstead. The " Cave Bank" for which the Cave Bank Fishery (c.1748) was named was in Tinicum Township; the first mill (c.1740) in Point Pleasant was along the creek in Tinicum Township (44-32-2); and John VanFossen petitioned in 1792 for a house of public entertainment ner.r a ferry "to be erected" near or a t the present site of the Point Pleasant Hotel in Tinicum. (Two of the signers of the petition were George and John Geddes.) In addition, as part of the archaeological district, the Walter's Nursery property (44-33-11 & 11-1) is the site of a substantial Indian {~- settlement site and has produced unique and impor ta n t a r ti fa c ts. There is no sound justifica tion for ignoring the la ter and very important growth events and their physical ma nifes ta tion s. The 1868 Map by Thomas S. McNair of the e-Delaware Division Canal (PA S ta te Archives : RG# 6-4t2 7-Point Pleasa nt) shows a substantial village core around the hotel, store and church in Tinicum Township, with just a sca ttering

• of s tructures in the Lower Black's Eddy area.

While this map does not represent all the. structures in the village it is interesting tha t McNair seems to emphasize the Tinicum section of Point Pleasant the primary area of the town. Ms. Mintz, whil.e as validly recognizing the control na ture had over growth pa t terns in Poin t Plea san t, seems to misrepresent the amount of growth occuring before 1760 and overemphasizes its effect on la ter growth. Throughout the history of this village the na tural fea tures and transpor ta tion routes have defined the arrangement of s tructures more than any one ethnic group's e f for ts a t town planning. so November 1981 Page 7

11 North Main Sucet, Doylestown, Pennsylvania 1S9 .UCKS COUNTY CONSERVANCY o I POINT PLEASANT HISTORIC AND ARCHAEOLdGICAL DISTRICT Comments and criticisms regarding the Request for De te rmina tion, o_f Eligibility prepared by Elizabeth Mintz for the Army Corps of Engineers August 1981 Sy_ecific Comments PHYSICAL DESCRIPTION: Page 2 2nd Pa ragraph: Ms. Mintz has oversimplified the early development pa ttern. There were s tructures sea ttered throughout the Plumstead and Tinicum areas of this valley in the 18th century. At the ferry site (Plums tea d ) there was,. possibly a much more extensive collection of buildings than a t present. (Some remain along River Road at the junction of Old Ferry Road.) While we can comment on. the loca tion of the 18th century buildings which remain today, it is dangerous to make definite conclusion.s as to the original settlement pa tterns as some of the original buildings are gone. Much more detailed research is ' requ ired before a clear picture of wha t was there can be made. Page 3: e k. 2nd Paragraph: Ms. Mintz has presented a totally misrepresenta tive generaliza tion of Bucks Coun ty a rchitecture. In forma-tion from the conservancy's comprehensive historic, sites survey indicates tha t approxima tely 70% of

f,.

Bucks County's houses before the Civil War are 2 1/2 story, three bay, one pile (room) deep with a gable roof and only one door. While not uncommon, buildings with two f ront doors and/or two rooms.in depth are not the ' forms by which Bucks County a rchitecture is cha rac-i l terized. These are fea tures which appear in domestic architecture a f ter 1800 and in many cases a f ter 1820. l 3rd Parag raph: Mr. Glassie draws his base for generaliza tions on English Pennsylvania a rchitecture from a much wider. region than the central portion of Bucks County. L' Within the latter region fieldstone cons truction and one front entrance door is predominan t. The two examples given by Ms. Min tz appea r to have been built in the ea rly 19th century and a re not exclusively English in design--they could have also been built by Sco tch-Ir ish or Germans. November 1981 Page 8

11 North Main Street, Doylestown, Pennsylvanin IS: BUGKS COUNTY CONSERVANCY o I POINT PLEASANT HISTORIC AND ARCHAEOLOGICAL DISTRICT Comments and criticisms regarding the Request for Determina tion of Eligibilih prepared by Elizabeth Mintz for the Army Corps of Engineers Augus t 1981 Specific Comments PHYSICAL DESCRIPTION: Page 3 4th Paragraph: The s ta t.cmen t tha t "I" houses were built before 1760 is inaccurate; the house type described by Glassie took its form during the mid-18th century and was used extensively throughou t Bucks County until 1850 and in some cases later. Two room deep houses were built by Germans and other na tional and ethnic groups as well as English and, as s ta ted above, were an exception to the norm and usually built a f ter 1800. Comments on this section: Ms. Mintz' selective quotes from Glassie (p. 49 Pa ttern in the Ma terial Folk Culture of the Eas tern U.S.) give a different in terpre ta tion to his theory. The Conser-vancy's his Lorica 1 s ta ff has read Glassie's statements and find they concur with our comprehensive survey { findings and our above comments. It is interesting to note tha t Bucks Coun ty a rchitecture along the Delaware River presents a wide diversity of building s tyles, materials, etc. and cannot be ca tegor-p ized or generalized as easily as inl, nd rural architec-ture. It is impor ta n t to Bucks Coun ty by illus tra ting how exposure to a variety of cultural groups and trends and ideas in addition to a variety of building uses can a f fect s tyle in architecture. Page 4: 1st Paragraph: No footnote #3 to document the quote. 2nd Paragraph: Double pile houses, while not always purely 2/3 Georgian, are more. popula r.in Bucks County villages than in the countryside--a pa ttern most likely defined by building lots with limited road fron tage. 3rd Paragraph: Ms. Mintz does not give a tax parcel number for the Indian village site, does not mention the two locks November 1981 Page 9

11 North Main Sucet, Doylestown, Pennsylvania 15 BUCKS COUNTY CONSERVANCY o POINT PLEASANT 11ISTORIC AND ARCHAEOLO'GICAL DISTRICT Comments and criticisms regarding the Request for Determina tion of Eligibility prepared by Elizabeth Mintz for the Army Corps of Engineers August 1981 Specific _ Commen ts_ PHYSICAL DESCRIPTION: Page 4 3rd Paragraph (con tinued) on the canal in this section, gives the wrong tax parcel number for the Lock Tender's house (which is 34-20-63_, not 69) and has the ferry landing coming a f ter the Lock Tender's house ins tead of before. Moving up the River Road toward the center of the District she does, not; mention the intersections with River Hill (Old Ferry) Road or Fer ry Road, both very important in the develop-Inent of Poin t Pleasant. The firesta tion dates to-c.1925, not 1950. The village " core" as described by Ms. Mintz in this paragraph is different from the one seemin' gly described in Paragraph 1, Page 2. This second village " core" of converging waterways and roads concurs with tha t described by the Bucks County Conservancy, March 1980. The "Y" and "T" shapes described here are unclear and cumbersome. Even recognizing the Corps of Engineers interest in the Plumstead portion of Point Pleasant, Ms. Mintz gives a very cursory accounting of the Tinicum section of Point Pleasant, ignoring several important structures and sites such as the Solliday House (4 4 -3 0-3 ), Stover Mill (4 4-3 2-2 ), Stover House (4 4 -3 0-8-1 ),, the 'y Baptist Church (4 4-3 0-7 ), the 19th century Victorian houses and store, the intersection of Ca fferty Road, and the Walter's nursery with its substantial Indian village site. The iron bridge carries Point Pleasant Pike over the canal; the bridge across the-river (bt.lt c.1853) was destroyed by the 1955 flood. The cited " Park Ro'ad" is shown on maps as "Tohickon Hill Road". s. 4th Pa ragraph: Including the Tinicum Township section, there are approxima tely 190 buildings within the Dis trict, wi,th exampics of 18th and primarily early 19th century vernacula r s tyling. O Page 5: 1st Paragraph: Ms. Mintz' summary s ta tement is essen tially well-pre-sented although we feel it is dangerous to s ta te tha t Point Pleasant is a "proto-typical 18th century rural village" based on the informa tion presented. Individual k November 1981-Page 10

11 Noah Main Sucet, Doylcstown, Pcnnsylvania 1W BUCKS COUNTY CONSERVANCY o f POINT PLEASANT HISTORIC AND ARCllAEOL GICAI., DISTRICT Comments and criticisms regarding the Request for Determination _of Eligibility prepared by Elizabeth Mintz for the Army Corps of Engineers August 1981 , Specific, Comments PHYSICAL DESCRIPTION: Page 5 1st Pa ragraph: (con tinued) title searches and research would need to be conducted in order to da te structures which have characteristics we have found to be indica tive of the ea rly 19th century which Ms. Mintz da tes as 18 th cen tu ry. The question still remains of wha t was the extent of the 18th century developmen t, and was it suf ficient to define and influence la ter development, or does development in Point Pleasant contain common threads due to the influence of na ture and transporta tion routes? 34-18-166 Mountainside Inn (photographs #1 & #2) Seven bays best described as 3 bays plus 4 bays repre-senting two sections built a t different times. Ver doub t ful that the Inn da tes earlier than 1738. Signi-C ficant pa tronage from rafters from earliest times through 1880's. 34-20-50 (photograph #3) Simple boxed wood cornice with modillions, not dentils. This building has an appearance of 1850 or la ter, not 1830, a1though specific dating would need his torical in forma tion to justify. It was used as a lodge or meeting hall with the double doors leading to a wide set of stairs. First floor built into stone clif f and - possibly just used for s torage. 34-20-45 (photograph #4)' Ms. Mintz has confused her labeling. Photograph ~#4 is of s tructure 34-20-46 which was built of block c.1950. Structure 34'-20-45 Is pictured in photograph

1. 7 and da tes c.1800 or earlier with a second story door possibly for an earlier two story porch.

Possibly used as a hotel. Page 6: 34-20-43 (photograph #8) " Georgian Vernacular"--d6cs this mean two rooms deep? Or does it refer to detailing? November 1981 Page 11

P L UCKS COUNTY CONSERVANCY 11 North Main Strect, Doylestown, Pennsylvania 159 o ( POINT PLEASANT HISTORIC AND ARCHAEOLOGICAL DISTRICT Comments and criticisms regarding the Request for Determination of Eligibility prepared by Elizabeth Mintz for the Army Corps of Engineers August 1981 Sp_ecific Commen ts PHYSICAL DESCRIPTION: Page 6 34-20-39 (photograph #9) This house is better described as 2 1/2 story with an exposed basement. While probably dating to 1820, the porch, probably added, crea tes a la ter look influ-enced by the Greek Revival. 34-20-37 (photograph #10) The dormers are probably recent. This structure exhi-bits traits of a house of 1820-30, not 1760. 34-20-14 (photograph #12) "L" houses are not defined by Ms. Mintz. Again, cer ta in fea tures are more cha racteris tic of 1820, n o t 17 60. Page 7: Photograph #15 was not commen ted upon. It also falls in to k, the ca tegory Ms. Mintz terms " Georgian Vernacular". Photograph #19 is the Tohickon Creek Aqueduct for the canal, the longest in the Delawa re Canal Sys tem. 44-30-1 (photograph #20)' This property is in Tinicum Township, not in the boun-daries of the district proposed by Ms. Mintz.

Also, a former resident of this house states tha t it was.always used as_a house.

44-30-13 (photograph #21) Also in Tinicum Township. Possibly the VanFossen hotel. A hotel on or near this site burned and was rebuilt in 1812 34-20-64.1 (photographs #28 & 29) Rumored to have been a speakeasy and to have been rebuilt c.1912. 34-20-64 (photograph #30) More likely on tax parcel 34-20-63. 34-20-S8 (photograph #32) Possibly older than 1825. i November 1981 Page 12 m

- - - _. = l'1 North Main str eet, Doylestown, Pennsylvanin lS9 BUCKS COUNTY CONSERVANCY o ( POINT PLEASANT HISTORIC AND ARCHAEOLOGICAL DISTRICT Comments and criticisms regarding the Request for Determination _of Eligibility prepared by Elizabeth Mintz for the Army Corps of Engineers August 1981 Specific Comments _ PHYSICAL DESCRIPTION: Page 8 34-20-55 (photograph #34) Apple Jack's Tavern. Said to have been built by the Swartz family.c.1810-1812, possibly remodeled c.1850 34-20-70 (photograph #35) Possibly the kitchen for the house opposite which was marked as a hotel on the McNair map. A rchi tec tural description ina ccu ra te---2 story with assymetrical fenestration; "Georg ia n '.Ve rna cul a r " does not apply in the same sense as Ms. Mintz has used it previously. No basis for da ting the structure 1790. Comment on photographs: Ms. Mintz has described those bu'ildings which she feels "bes t characterize the intent and flavor of the district". She has neglected the buildings on Ferry Road and impor- { tant ones in Tinicum Township induding two schools, a church, an 18th century mill, fine houses, and places minimal emphasis on the canal, one of the most impor-tant development factors of the village.... liISTORICAL SIGNIFICANCE: SUleiARY: Page 9 1st Paragraph; The periods of development for Point Pleasan t may better be outlined as follows: -Indian Settlement ~in the Delaware Valley (Pre-history) -White Settlement, including English, German, Scotch-Irish in Plumstead and Tinicum Townships (c.173 0-182 0) -Opera tion of the Delaware Canal (1830-1931, prime before,10! -Tourism, commercial & limited industry (c.1820-present)'

• 2nd Pa ragraph:

As per previous commen ts, it is misleading to call Point Pleasant a " product of 18th century community development planning." Contrary to English 17th and 18th century towns such as Philadelphia, Williamsburg, or even Bristol Borough or even "New Town" in Bucks Coun ty, Point Pleasant never had a mapped: plan for development or an arrangement of buildings for style ra ther than practicality. q November 1981 Page 13 i L.

11 North Main Street, Doylestown, Pennsyh ania 15 ..,UCKS COUNTY CONSERVANCY o i POINT PLEASANT HISTORIC AND ARCHAEOLOGICAL DISTRICT Comments and criticismsregarding the Reauest for Determina tion _ _of Eligibility _ prepa red by Elizabe th Mintz for the Army Corps, of Engineers August 1981 Specific Comments HISTORICAL SIGNIFICANCE: INDIAN SETTLEMENT: Page 9 1s t Paragraph: Point Pleasant has an archaeological district with boundaries corresponding to those proposed by the Bucks County Conservancy. In Tinicum there is an extensive site a t Wal ter 's Nursery (44-33-11 and 11-1) and the boundary on Tohickon Hill Road abuts an unusual and as yet unexplained grouping of stone walls, towers, pedestals or pla tforms on property 44-18-91-1. This archaeological district represents possibly the most extensive and diverse Indian settlement site in Bucks County,' possibly serving as a central trade area with Indians of other regions. Ms. Mintz refers to Dr. Henry Mercer as an "ama teur a rcha eologis t". This cla ssifica tion unders ta tes Dr. Mercer's prominence in the field of archaeology for C his time. The Bucks Coun ty Pa rks e nd RecreCa tion Department's brochure on the Moravien Pottery and Tile Works stales tha t Dr. Mercer held th:. pi ofessional capacity of Cura tor of American and Prehis toric Archae-ology a t the University of Pennsylvania Museu'm. 4 th Paragraph: Mercer also gives a detailed accounting of his findings in Point Pleasant in the "An tiquity of Man". Page 10: 1st Pa ragraph: Ms. M5ntz mentions "as a side note" the area was re ferred to as " Lower Black Eddy". See our comments under PROPERTY NAME in this report.. Ms. Min tz makes no a ttempt to pinpoint tbc loca tio~n of the Indian village site s tudied by Dr. Mercer. This information is impor ta n t fo r the proper review of the pumping s ta tion proposed in the immediate vicinity. Page 11: 3rd Paragraph: There is no footnote for the Rivinus map. November 1981 Page 14 l

BUCKS COUNTY CONSERVANCY 11 North Main Strcet, Doylestown, Pennsylva o POINT PLEASANT HISTORIC AND ARCIIAEOL'OGICAL DISTRICT Comments and criticisms regarding the Request for Determination of Eligibility prepared by Elizabeth Mintz for the Army Corps of Engineers August 1981 Specific Comments HISTORICAL SIGNIFICANCE: INDIAN SETTLEMENT: Page 11 4th Paragraph: There is no footnote or reference for the Kollner wa tercolor of Point Pleasant. Sth Paragraph: Ms. Mintz does not document who has reported archac-ological findings in the area near the village site. Page 12: 1st Paragraph: Ms. Mintz's accounting of the Indian Walk is not 'en-tirely accura te. The Walk of 1737 was a resurvey of 1686 purchase of land in Bucks County north of a W righ ts town to extend as fa r ba ck in the woods as a man could walk in a day and a half. As viewed by the Indians this area lay south of Tinicum Township C.. (incorpora ted Ma rch 12, 1738). Ms. Mintz needs to document the source that states that the Indlan Walk did not take place. According to Josiah B. Smith's unpublished manuscript of the his tory of Newtown and Upper Makefield there were eyewitness accounts of this walk (John Knowles ' family history). "Sprin g fo rd " is most likely Springtown on Route 412 in Bucks County. "Solesbury" (also mentioned in para ~ graph

3) is a deriva tion of Solebury which appeared in a few early records.

The common and accepted for, Solebury (Township), has been used since 1720. ENGLIS11 SETTLEMENTS : Page 12: 3rd Paragraph: No documenta tion for the s ta tement tha t members of the " Society of Friends" began settling in the Point Pleasant area. Page'13: 1st Paragraph: l r The date for the Moun tainside Inn given here is 1869, possibly a typing error from the previous reference to 3689. Again, c.1738 is a sa fer da te. November 1981 Page 15

11 North Main Street, Doylestown, Pennsylvania lbf BUCKS COUNTY CONSERVANCY c. POINT PLEASANT HIS70RIC AND ARCHAEOLOGICAL DISTRICT Comments and criticisms regarding the Request for Determination o_f Eligibility prepared by Elizabeth Mintz for the Army Corps of Engineers August 1981 Specific Commen ts ENGLISH SETTLEMENTS: Page 13 lst Pa ragraph (continued) No reference has ever been given for a grist or saw mill on property 34-20-40 a t the point of River and River Hill Roads. The 1868 McNair Map shows a saw mill on parcel 34-20-62 or 63 near the canal lock. While possibly having investments in Plumstead Township, the Cave Bank Fishery from which the collective took its name was actually loca ted in Tinicum Township. 2nd Pa ragrip h: The name Black appears in 1769 when Michael Swartz purchased the ferry and surrounding land. The post o f fi ce wa s a t Lower Bla ck 's Eddy from 1821-1828 when it was removed to Point Pleacant. Tic map reference given by Ms. Mintz, Kennedy 1817, is actually the W. E. Morris map of 1850 (figure 3 is also mislabeled). 3rd Pa ragraph: In 1738 the Old Ferry Road was laid out from Butler's Mill- (Chalfon t) to Pearson's Ferry. The Point Pleasant Turnpike was not established un til the mid-19th century, e probably in anticipa tion of the completion of the ^ bridge over the Delaware in 1853. According to research conducted by Mrs. Helen Sirmay (see enclosed) the section of R Lver Road through Point Pleasant can be dated from 1736 Comments on "English Settlements": Ms. Min tz makes no mention of the growth of the area a f ter the settlement of other na tional and e thnic groups. Scotch-Irish names appear on ea rly maps and Germans migra ting through the Perkiomen Valley reached this area by the 1760's. Both groups made valid contribu-tions to the ea rly developmen t of the a rea. Also, no mention is made of one of the ea rlies t indust ies-- ra f ting, particularly to move logs, down the Delaware River. The Eddy near the ferry was a na tural spot to "put in" for the night and accounts record that the nearby inn would need to accomodate dozens of ra f ters in one night. This industry remained strong, although leaving no bla tan t physical evidence, until the 1880's. November 1981 Page 16

11 Nonh Main Strcet, Doylestown, l'cnnsylvania 16 BUC:KS COUNTY CONSliRVANCY o I POINT PLEASANT HISTORIC AND ARCHAEOL'OGICAL DISTRICT Comments and criticisms regarding the Request'for Determination of Eligibility prepared by Elizabeth Mintz for the Army Corps of Engineers August 1981 Specific _ Commen ts CANAL PERIOD: Page 13 1st Paragraph: The s ta tement, " Canal systems were long a popular transporta tion mode in other parts of the county..." is misleading.,, According,,,to,C,.,,P., Yoder in Delaware Canal Journal: A Definitive His tory, "But it was not until the Erie Cana1, across New York S ta te from Albany to Buffalo, was completed in 1825 that the real potential of this means of transporta tion was demonstra ted" (pa ge 13). The Delaware Canal, begun in 1827 was not far be-hind the popular trend. Page 14: 1s t, 2nd, and 3rd Pa ragraphs: Ms. Mintz does not s tress the importance of Poin t Pleasant as a mid-point in the canal system with many ( canal-associa ted s tructures--mule barns, lock keeper's \\,, house, tool house; and structures / businesses active due to t,he canal--hotels, brothels (repu tedly), stores, saw mills, and limekilns. The Delaware Canal perhaps prospered longer 'than other -.~ canals because the railroad lines could not follow the ~ same pa th or anywhere n~ car. Also,, judging from the record of toll charges for the Delaware Canal in 1849 (Yod e r,

p. 244) there was no charge ra te for coal, although 580',934 tons were shipped in that year (Yoder,

p. 241).

POST CANAL ERA: Page 14 1st Pa ragraph: The present core of the village has an appearance con temporary with the crea ti'on of the Point Pleasant Turnpike and the opening of the bridge over the . Delaware--c.1850-1855. I t wa s, a n impor tan t s top on crossing s tagecoach routes. 2nd Paragraph: Ms. Mintz has read the quoted Atlas of 1876 incorrectly-- the proposed railroad does not follow "along the path of the canal route" but enters the northern portion of Plumstead Township and follows closely along the Tohickon Creek to its mouth near the Delaware Bridge. November 1981 Page 17 4

11 North' Main Su cet, Doylestown, Pennsylvania 10 BL1CKS COUNTY CONSERVANCY o 1 POINT PLEASANT HISTORIC AND ARCHAEOL"OGICAL DISTRICT Comments and criticisms regarding the Request for Determination _ of Eligibility _ prepared by Elizabeth Mintz for the Army Corps of Engineers August 1981 Specific _ Comments _ POST CANAL ERA: Page 15: 1st Paragraph: Comments on tourism, commerce, quarrying and other smaller indus t:.ir s are totally undeveloped. Tourism was impor ta n t to Point Pleasant throughout the 19th and 20th centuries, not just "in Point Pleasant's more recent history". Especially popular for its na tura1 beauty and fishing, notable people frequented there. It is rumored the Point Pleasant Hotel accomoda ted U.S. presidents. George MacReynolds in his Place Names of Bucks County, (p. 254) mentions tha t President Grover Cleveland frequented a section of the Delaware River, several miles north of Point Pleasant. Specula tion suggests tha t he might have s topped a t Point Pleasant. The records for the Hotel were destroyed in a fire in recent. years. In the early 19th century the famous - Solliday clocks were made.in or near Point Pleasant as members of the family lived throughout the area. The stone quarried from Point Picasant was exported to New York and Philadelphia. HISTORICAL SIGNIFICANCE: A STATEMENT: Page 16 f 1st Paragraph: The information herein is basically well-presented although it is necessary to stress tha t the entire area of Point Pleasant (Plums tead and Tinicum sections) is impor tan t a s an archaeological district with various interrelated sites. Ms. Mintz needs to comment on the extensive a rchaeological findings a t Walter 's Nursery site. 3rd Paragraph: While white se ttlement was es tablished in the 18th. cen tury it wasn ' t until the la te 18th and ea rly 19th centuries that the town took its real form. Ms. Mintz' other general comments on pages 16 and 17 are basically sound. November 1981 Page 18

11 North Main Str cet, Doylestown, Pennsylvania IS BUCKS COUNTY CONSERVANCY o ( POINT PLEASANT HISTORIC AND ARCHAEOLOGICAL DISTRICT Map Index:' - Archaeological and Historic District boundaries proposed March 1980 by the Bucks County Conservancy. - Approxima to eleva tion lines in the area of the Point Pleasant Dis trict, Plumstead and Tinicum Townships. - "Plumstead Township, 1759" land ownership map. e 9 e 0 O e b e O

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' L3UL.lsb LUL;4N 1 Y CUlibislW Alw y 11 Nut th.1;.in dis cct, oo> scstew a. 4 ums).w..1.s a v o ( POIf4T PLEASA11T llISTORIC 7d1D ARCllAEOLOGICAL DISTRICT Informa tion prepa red by the Ducks County Conservancy and submitted to the Pennsylvania IIis torical and 14useum Commission 14 arch 1980 Later included in nomina tions to the Bucks County Regis ter of His toric Places Pennsylvania Inventory of Historic Sites e G e

BUCKS COUNTY CONSlilWANCY e 33 west coun succi, ooylcsown.irnnsywania : g m POINT PLEASANT HISTORIC DISTRICT Physical

Description:

c The village of Point Pleasant is loca ted along the Delawa re River in Ducks County a t the boundary between Plumstead and Tinicum Townships. It is visually bounded by the ridges (approxima tely 300 ' elevation) of the steep beautiful valleys +l formed by the confluence of the Tohickon Creek, Geddes Run and Delaware River. Most of the clus tered settlement is in or directly above the alluvial plain of the Tohickon 'or seb' againtit the steep cliffs along the creeks and river. The village center opens out from,the crowded approaches to reveal a " town common" of rushing wa ter, bridges and the buildings edging on the mouth of the Tohickon. i Moving throughout Point Pleasant one is ' cons ta n tly awa re,of the closeness of the natural setting, the steep slopes and wa ter. Only perhaps on the plain between the canal and the river north of the Tohickon does one sense any feeling of i mr,r.ed i a t e openness although the high diabase hills close off any distant vis ta. ( Geographic fea tures break t.he village up into small areas and limit the visual as well as physical accesas to the town. At the same time proximity t.o these fea tu res in addition to f a general uniformity of scale tends to unify the physical. elements. 7 TW'elve roadways and wa terways follow a 200' spoke-like pat-tern to approach the hub of Point Pleasant, the mouth of the Tohickon. All excepting River Road and the adjacent Delaware Division of the Penn:3ylvania Canal south of Point Pleasant follow 'i,e drop considerably in elevation coming into town, most ing the steep stream valleys. -t The Ceddes Run Valley parralleled by Point Pleasant Pike is the most brea thtaking. Lined with moun ta in laurel and hemlock i this valley according to George MacReyno supplies "some of Bucks County 's mos t a ttractive scenery".{ds,As one a pproa ches from the west the road begins to drop passing opera ting and abandoned qua rries on the right and cteep slopes on the left. As the road progresses into the valley, there are s teep slopes - on both s ides, with the stream down to the left. There are almost no structures until the center of town along thid ap-proach as the inclines are too grea t and the velocity of the i stream during flood season destructive.

1. George MacReynolds, Place Names In Bucks County.

Doylestown: The Eucks County Historical Society. 1942.p.185 March 1980 Page 1 s

' v v L,.y v L v v.N A 1 L V 4 W .sw,.. L 1 u v. m p v. s.. w., m. . i.. -... - s,- u ( POINT PLNASANT HISTORIC DISTRICT .,X ,..I ; I Physical, Description _ (con tinued) : of the above--mentioned qua rries

• Swagger Road traces the tops directly southeast of Point Pleasant Pike then bends down into.'

the Geddes valley passing two recessed intrusions then steep natural slopes until a vista of the town unfolds with the hotel-and bridges of f to the far Icf t (picture #8), summer cottages on ,s the right, and the Point Pleasant Pike below on the left. Swag. ger Road then intersects with Ferry Road which passes a few older homes and sheds until meeting with the River Road just South of GedGes Run. The third and oldest approach from the west is along top of the diabase hill filling the south corner of the intersection of Geddes,Run, the Tohickon and the Delaware. This road, Ferry Road, pa ra llels Ilickory Run name'd for the abundant, hickory, trees along its banks. Hickory Run does not flow through a valley dte to the extreme hardness of the rock but cascades over the ridge above River Road. (picture #1) Perry Road, likewise, follows along the pla teau with random cons truction adjacent. Approaching two 19th century frame houses on the right, Ferry Road turns { slightly and begins to drop. Suddenly a cluster of houses appear, Old Ferry Road (npw River Hill Road) bears off to the 7., 3 right closer to Hickory Run and Ferry Road bends to the left passing a two.s tory cupolaed schoolhouse. (picture #3) and ... ~ crowded 18th and 19th century 2 1/2 s tory s tone and frame, houses. At this point the road is dropping steeply, giving a view of Point Pleasant and bends to the right as it meets Swagger Road. It continues bhiefly until it dead-ends into River Road with the firehouse and an old 1 3/4 story frame house oppos ite. Old Ferry or River Hill Road as it bears off from Terry Road winds down a steep wooded-hill to River. Road l passing closely by a ' few 18th and 19th century houses and a contempora ry house set back. River Hill Road intersects with ] River Road just north of Hickory Creek adjacent to a striking, j 18th century 2 1/2 story stone house. (picture #2) ~ The approach from the south on Riveh Road although fairly level' ' passes by very steep and dramatic cliffs. Directly preceding the historic district the road barely fits between the cliffs and the canal with only a sliver of the towpath between the canal and the river. The road bends to reveal the bridge supports in the dis tance (the bridge itself destroyed in the 1955 flood) and a field wedged between the road and the, canal.. f, l p 1 i i parch 1980 Page 2 e a - es e

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( ,' hlt". - .~ POINT PLEASANT llISTORIC DISTRICT . y,h.. g f. , $.!,i.. Physical Description (con tinued) : .q.., r.o.m

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Split rail fencing surrounds the gradually widening field .J is s e t..,.yk)g graced with trees crea ting a very pleasing prospect. The stonef Mountainside Hotel, and early 18th century river inn, ,-;.,,2 -P 'g,,y against the clif fs on the left immedia tely followed by an interesting white frame Greek Revival structure. As one pro-, ' g,q ceeds through the Lo'wer Black Eddy Section of Point Pleasant -[,,h f./ there is a mixture of 18th and 19th century houses on either' , d side of the road, tall clif fs to the lef t and a broadening ~ plain to the right extending to the canal and river. A slightly overgrown field formerly the site of the ferry landing,, limekilns and possibly very early Indian settlement is on the. small bridge'over Hickory right before River Road crosses a Run. The. density of houses increases, mostly 2 1/2 story, set, fairly close to the road, predominantly 18th and 19th century. River Hill Road comes down the cliff and marks the visual widen. ' ing of the district to the left to include the houses on the, hill in the block bounded by River, River Hill and Ferry Roads. From River Hill Road to the town center the development is close yet casual, ea rly 20th century resort rela ted s tructures such as bungalows and a luncheonette are interspersed among - { small yet interesting old 2 1/2 story s tone and fra me houses. (pictures # 4 & 5) Approaching Ferry Road one passes on the right "ApplcJacks" ba r, a mid-19th century la rge stone build-ing, (picture #6), the late 19th-ca rly 20th century firehouse, an old frame house and blacksmith shop founda tions. River Road bends slightly to the lef t and intersects with Point 7: Pleasant Pike a t the Pos t Of fice. River Road joins with the Pike to cross the 1922 concrete bridge over the Tohickon with ~ the large Point Pleasant Hotel on a knoll directly facing. i The River Road approach from the north is somewha.t s imilai- . [y',.,- to tha t from the south with more of a drop in eleva tion. Coming from Smithrown the road is again squee:.ed between the" lb, cliffs and the canal. The road drops and the area widens '. 'f ' "- slightly to accomoda te older homes on the cliff side and newer ones on the River side. The plain between the road apd the river widens considerably by the beginning of the district marked by a small red frame store on the left. No buildings occur on the right or cliff side until well into the town. On the lef t is the flood plain with Indian sites, a nursery and the canal. .A 30-40 yea r old trailer and summer cottage park is loca ted a t the edge of the pla in along the Delaware and is totally obscured by trees having no visual impact on March 1980 Page 3 w

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(' ~ POINT PLEAS ANT HISTORIC DISTRICT ,,/~'.,jp. ', , y{,g g Physical _ Description (con tinued) : .g -[: [ tend. ,:y)l ,y. on the dis trict. 'Up higher along the road are a few newer homes, then a series of Victorian frame houses. These p to get larger and more interes ting as one approaches the town *% y center. The plain below is almcat totally obscured by these.:f.}f houses and their respective ba rns and plantings. ..g p? 'u. la rg e.I.,jQ{ the right and seti back *is The level ground widens on a 19th century house and ba rn. Cafferty Road, which passes .g. directly by these buildings, is coming down from the top of ' q:.,, g the hill on the right. Next is a newer home then a small parking lot separa ting it from the striking 1832 Baptist Church ~ ~ - and school on the point formed by Ca fferty and River Roads (picture itll). The series of Victorian homes on the left ends here succeeded by several small 20th century structures then a complex of low sheds behind the large Point Pleasant Hotel being approached from the rear. Facing River Road where . ; [. in on the right is a well-designed late ( '. Ca fferty Road blends frame.home with flanking one '.Q,;..:i Federal (1826) 2 1/2 story white story wings (picture iflO). ,' 7 6 Following close to the road is an old store and as the road bends down slightly to the left is . N *., ' ' three s tory brick building on the right directly be fore the,,* a C.~ bridge (picture fi9). River Road continues to the right over .,, g. ; the 1922 Tohickon Bridge. Should the road be followed < 'ound (j,ll.I,'s.'". to the lefi; in front of the hotel one passes a bungalow on

p{;41 the right then goes up over the canal on an 1877 iron bridge f.

(pictures if 23,24,25) to the fl ood pla in a r e a w ith 19 th c en tu ry..T.f t ,[. farm house and buildings on the le f t an4 a n ea rly 20th century.i.WQ,;, dance pavillion, now restaurant, and barns on the right. The Ed,]4 6: N road essentially dead ends a t the approach to the former Del-aware Bridge'and a dirt lane to the lef t goes' by the wooded. trailer and cottage lots. ..y; y.6, E ' 2I' ; *f. ! Ca fferty Road comes into Point Pleasant from the north para-lleling River Road and the Tohickon on top of the ridge sep-ara ting the two. The district begins with the ceme tery ?V (picture if15) at the top of the hill and follows on the To-hickon side of the ridge a f fording a, wooded view of the - valley. The road descends through the wooded hill with ran-dom s tone walls on the left until passing by a large stone barn and house and on the right a frame house and shed. The 18th century stone and frame grist mill is down the hill on the right (pictures ifl2,13 ). The road continues briefly past the church and school to River Road. March 1980 Page 4 . *_. -.. = =.. s =

EUCKS COUN 1 Y CONSERVANCY o 33 wesi coun sircewaylcsiown.Pcansyh anta 86 I' POINT PLEASANT HISTORIC DISTRICT Physical Description (con tinued ) : The Tohickon Hill approach also affords a splendid view of the Tohickon Valley. Beginning a t the top of the hill a ritone wall to the left marks the property line for a s triking 18th century fieldstone house set back from the road. Beginning the. descent through the wooded slope the road bends to the right between two houses set close to the road, the left one a 19th century frame and the right an 18th century stone'. The Valley now can be seen with the graveyard appearing on the top of the hill directly across. Tohickon Hill Road travels down the face of the slope in a gradual linear fashion passing one intrusion on the left, then a stretch of natural terrain before reaching a row of regularly spaced houses on the right. During the descent one catches glimpses of Point Pleasant through the trees, es-pecially the Baptis t Church. Two older homes, three early bungalows and three more homes bring one to the 1978 concrete Geddes Run Bridge and the intersection with Point Picasant Pike., The last house, a 2 1/2 story grey stone is pa rticula rly ha nd-some set against the backdrop of the Geddes Valley (picture #9). Experiencing Point Pleasant from the Delaware Division of the Pennsylva nia Canal gives one a much less crowded impression of, { the town. To canal goers Point Pleasant is an alluvial plain between two s tretches adjacent tall cliffs. The town is set up on a higher level away from the river with only a scatter-ing of structures near the canal. Coming from the south, one passes near the Mountainside Inn and a bridge to Lock #13, then along a short stretch of open fields to the Hickory Run m overflow and Lock #14 with the locktender's house adjacent. Progressing in to town the backs of lots on River Road fa ce the canal to the le f t a nd wha t is called Kings Island to the right. The mule barn is on the right a s well a s a white frame house formerly an inn with a small s tone kitchen adjacent. The canal crosses the Tohickon via a concrete aquaduct repla-cing the wooden one a fler a severe flood in the 1930's. The canal is then crossed by the 1877 iron bridge nea r the Point Pleasant Hotel and travels across the low plain now a nursery. After leaving the district it is crossed twice by wooden bridges and comes very close to River Road as the Delaware. presses against the hills. March 1980 Page 5

'UL ;sg L.U ss N 1 1 LU.%J L \\ v e u w I a % c:,1 u u n dis c c i, evy e w.. 6 4 c a.4.W. ~.. 7.-. ( POINT PIIAS7sNT HISTORIC DISTRICT , Physical _ Description (con tinu ed ) : Point Pleasant visually has two dis tinct a rchitectural sections supported hisLorica11y by the existance of two.sepa ra te villages now merged into one. The earlier section, Lower Black Eddy, is clustered around the two Ferry Roads down to the Mountain-side Inn. It has an 18th and early 19th century atmosphere, small to medium sized houses clustered closely against the hill-side above the floodpla in. Tliere a re rela tively no documented service structures in this section save the inn and the school. Point Pleasant proper is essentially adjacent to and north of Point Pleasant Pike and is a town of the mid-19th century. There is more spacing between and dramatic placement of s tructures in this part,.particularly with the hotel, church and a fine Vic-torian house between Swagger Road and Point Pleasant Pik e. There are more service buildings in this section: the Hotel, church, school, stores and grist and saw mill. There are approximately 190 s tructures within the suggested bounda' ries of 'the historic district with close to 85 pre-1900 houses and less than 25% intrusions. 8% of total, or 12 of the (_ intrusions are situa ted along the river and not visable. The architecturally and visually dominant buildings located throughout Foint Pleasant are as follows: 34-18-94 Large fieldstone house, top of Tohickon Hill 34-18-166 Moun ta in s id e Inn 34-19-6 Grey stone a t mouth of Geddes Run 34-20-2 White frame Victorian house overlooking town center 34-20-3 Dobron's Store, Victorian frame 34-20-15-1 2 story schoolhouse with cupola 34-20-45 colonla1 2 1/2 story white plastered stone house 34-20-54 Lato Victorian firchouse 34-20-55-1 Applejack's Tavern 44-30-3 1826 la te Federal white frame house-44-30-6,7 1832 Greek Revival Baptist Church & school 44-30-13 Point Pleasant notel n. 'f L.. I , March 1980 P5ge 6 w- .--y

3UCipS COUNTY CUNSidRVANCY 33 wesi coun succi.oorlesiown,ecnnsykanta m e I. s POINT PLEASANT HISTORIC DISTRICT Historical Sign i fica nce_: Very little history'has been written about the quiet river town of Point Plea sant'. The following has been compiled from' general Bucks County Histories and oral history. ( Archeology _ - Prehistoric: Probably the be'st' documented segment of Point Pleasant's past. is that about the extensive Indian settlement and activity in and around the site of the present town. Dr. Henry C. Mercer investigated sites throughout the Delaware Valley and made this sta tement on his findings in the Lower Black Eddy section of Point Pleasant: I discovered a f ter digging a deep Licench tha t there 1 was a lower village 1iyer below the well-kndwn sur-face village a t Lower Black Eddy. This underplaced village-site a t' Lower Black Eddy is the oldest human trace tha t I have been able 'to find in the Delaware Valley, and if I give up.the Trenton gravel specimens it is all I have left. Who inhabited it? Was the denizen a predecessor of the Indien, was he the Trenton f gravel man himself, or.was he' only the first Lenapq r immigrant? To these questions I can say tha t no ex-tinct animal bones were found to give date to the . Iower hearths. The lower village man made pottery i which the ice men were not supposed to be able to do. He used more argillite than jasper.' His arrows and spears were very narrcw -and long, but that does not seem evidence enough'to me to prove, as has been urged, tha t he.wa s Ian Eskimo. Until other ev-idence is in, the resonable supposition seems that he was the. first coming Lenape pioneer of the 15th century. Although this site was not precisely:spinpointed in the article the open field near Hickory Run (34-20-65,66) occasionally produces prehistoric a rtifacts on its sur fa ce, morta r and pes-tle arrowheads and pipes found recently. 1.Dr. Henry C. Mercer, " Red Man's Bucks County" in a Collectio'n_ of Papers Read Be fore the Bucks Countiy His torica l_ S_ociety, Vol. II, pp. 279, 280 I J! arch 1980 Page 7 -_1

_A.,u w w v.si i Lu a w t,3 ei o umi u v.ca.s. w n daud.' w nw ~ * -o v a /l POINT PLEASANT 11ISTORIC DISTRICT 1sistorical_ S ignificance : Another archaeologically significant site is along the Geddes Run Valley and is described by Dr. Mercer in the same article: The Valley has distinction in scientific circles from its Indian quarry on the s ou th s id e of the creek, a short distance above Point Plea sant where countless " Turtle Backs", fashioned out o{ local argillite by Lenape Indians could be found. Other Indian sites are a small village a top Ilickory Run, clay digging site between Ferry and Swagger Roads (34-18-142), set-tiements in the plain along River Road north of the Point Plea sant Ilotel (44-33-11). Adjacent to the presently proposed dis trict bounda ries is a most unusual grouping of stone walls and founda tions on the hill (34-18-91) overlook ing the Tohickon Creek. Included in these undocumented remains is a solid round stone tower about 8' high. Further i nyt.:s tiga tion should be conducted to determine its s ign i fica nce and inclusion in the district. A rchaeology, - IIis toric Pearson's Landing or Black's Ferry, es tablished 1739, was located in Lower Black Eddy, southeast of the intersection of River liill Road with River Road possibly on parcels 34-20-65, 66, 69. It ' opera ted continuously until the Delawa re Bridge upstream was constructed in 1853. Old pillings have been found on the site O-and some residents remember the location or a boa thouse there. ^ These parcels are also the loca tion of old limekilns, now in ruins. The a rea s adjacent the canal, pa rticula rly a t the locks, aquaduct, Inn and mule barn could produce archaeological infor - ma tion as. well a s the blacksmith shop ruins. (34'-20-52) 2George MacReynolds, Pla ce_ Names In.Bu cks Coun t_y, - Doyles town, Bucks Coun ty IIis torical Socie ty 194 2 p. 185-186 i l i O , March 1980 Page 8

BUCK 5 LUUN 1 Y CUNSl;.iWANCY a3 wcu coun succi, t>oylmiown.iton.syhanta ice \\ POINT PLEASANT HISTORIC DISTRICT Historical Significance (con tinued ) : t... Perry Road was opened in 1738 extending across Bucks County

• 11 miles from Chalfont to Point Pleasant then called Pearson's Landing to bring travelers to the only Delaware crossing for 5 miles either north or south.

When the Delaware Br.idge was opened in 1853 the Point Pleasant Pike became the important transporta tion route and the development empha sis switched" from Lower Black's Eddy to Point Pleasant. The Delawa re River was the ea rlies t transpor ta tion route - and continued to be used by rafters and loggers until 1900. The Mountainside Inn da tes back close to 1700 servicing the river travelers. River Road was an old Indian path and pro-vides the'only North-South route for 4 miles from the river. Its course was somewha t altered when the Delaware Canal was built in 1831-1832. The Delawa re Division of the Pennsylvania Canal is probably the most importan t route in Point Pleasant. Constructed in 1831-32, it was in opera tion until 1931 ca rrying coal, lumber, iron ore and other heavy and bulky items between Bristol and Easton. c.1876 a railroad was planned from the canal aquaduct along the west bank of the Tohickon Creek and up through Plum-stead Township to be called the Delaware River and Lancas ter Railroad. ~ commerce The canal, ferry and bridge traffic stimulated commerce in Point Pleasant through,out its history making it an important point of trans fer for many goods. Items produced from the qu a r ry', saw and grist mill, limekilns and local farms were shipped from Point Pleasant north and. south

Industry, One of,the first industries was the Cave Bank Fishery Company established in the early 1700's.

Al'though the company's base was Prahl's Island slightly north of the dis trict bounda ry', it had the fishing rights for 'mbe entire area. In 1748 the seven village residents compris ing the company bought the ferry from Enoch Pearson. One of the founders of the company, John White, built the grist and saw mill a round 1750. Fishing has remained important to Point Pleasant since the mid-19th century not as an industry in itself but by contributing , March 1980 Page 9

3UCK.S COUNTY CONSERVANCY a a3 west coun succi, ooylcsiown.rennsyNanta m (. POINT PLEASANT. HISTORIC DISTRICT Historical Significance (con tinued) to the tourist and vacation industry. MacReynolds cites Point Pleasant as one of the best fishing resorts on the river for rock-spring for suckers and shad.g, catfish and sunfish, several kinds of bas fish, white perch, and in the The quarries along Point Pleasant Pike and Geddes Run have been in opera tion a t least since the 19th century. George MacReynolds comments: On the southeast bank of the creek, not fa r from the old Indian quarry, is a famous "bluestone" quarry, operated for many years by the late Nicholas L.

Heaney, who supplied many thousands of feet of curbstone and for Doylestown's streets befor for supplanted by concrete.g stone flags tone tha t purpose was In addition to supplying Doylestown, building stone from the quarry has been used for construction in Philadelphia and New York.

The grist and saw mill da te from the mid-18th century servicing I; the area fa rmers. Other local-orien ted trades such as black-smithing were located in Point Pleasant. The vaca tion resort industry has left its physical mark from the mid-19th century onwa rd with hotels, bungalows, dance hall, bars, etc. Vacationers from Philadelphia and New York came to ~ the area for its natural beauty, hunting, fishing, boating and Other wa ter-rela ted activities. 3 Ibid., p. 246. 4 Ibid., p. 186 Ma rch 1980 Page 10

r 11 North Main Strect, Doylestown,l'ennsylvania ISEA BUCKS COUNTY CONSERVANCY o ~. POINT PLEASANT lilSTORIC AND ARCIIAEOLOGICAL DISTRICT Informa tion resea rched by Mrs. IIelen Sirmay and submitted to the Bucks County Conservancy April 1981 6 O e

11 North Main Sueet, Doylestown, Pennsylvania ISq BUCKS COUNTY CONSERVANCY o ( POINT _ PLEASANT _ HISTORIC DISTRICT In forma tion researched by Mrs. Helen Sirmay and submitted to the Conservancy April 26, 1981 Point Pleasant, Pa., is located on the Delaware River in Bucks County, between the towns of Lumberville and Erwinna. The River Road (Route 32) follows the river from Bristol in the lower part of the county to the junction with Route 611 a t Kintnersville, enroute to Easton. Tradi-tionally it was an Indian trail. The section which goes through Point Pleasant is dated from 1736. In the center of the town it is the point of termination of Point Pleasant Turnpike, River Hill, Old Ferry and Tohickdn Hill Roads. A short distance further along it is also the termina tion point of Ca f ferty Road. Originally the' town, which lies in Plumstead as well as in Tinicum Township was named Black's Eddy but it was changed to Point Pleasant when the post of fice was moved in 1828. The 300' cliff along which the River Road runs permitted the town to grow only in one direction - north and it also precludes much fa rming although there is a small fer tile plain be tween it and the river a t some poin ts. So far as transportation is concerned, the river was always more impor ta n t than the above-mentioned roads. In the earliest days the Durham boats came down the river, laden with flour and whiskey. At tha t time northeas t-ern Pennsylvania was heavily fores ted and the log raf ts, some of which were 100'-200' long and 16'-36' wide were floated down during the high water seasons. Be fore the white man came, the upper part of the proposed historic dis-trict was a flourishing Indian village and at times there were larger groups of Indians a t wha t is now Point Ileasant who came there because of the good fishing and to use the " Indian quarry" an undeveloped out-cropping of easily worked s tone used for arrow heads, tools and other implements. There is a]so some evidence, as determined by Dr. Henry Mercer the cura tor of the University of Pennsylvania Museum, of prc-his toric man along t)ie Delaware River at this Jocation. In the 1730's the original grants o'f land began to be divided. The Sc - velopment of the town commences with the awarding of ferry rights to Ma tthew Hughes and Enoch Pearson, whose adjoining lands bordered the river, in 1739, the year in which Poin t Pleasant Turnpike, the road to Butler's Mill (now chalfont) which was the primary rou te from this part of the Delaware River to Philadelphia and the wes tern section of the S ta te.2 Hughes' ferry seems to have been the first commercial estab-lishment in Point Pleasant. April 1981 Page 1

11 North Main Strcet, Doylcstown, Pennsy.onia 1m BUpKS COUNTY CONSERVANCY o ( POINT PLEASANT - Conservancy /Sirmay In 1740 Enoch Pearson sold 50 acres of land, including the ferry site, to Daniel Dawson of Philadephia who, in 1744, willed it to his son Daniel and his daughter Mary Thompson. John Thompson, Dawson's son-in-law, sold to John White, John Hart, Jane Hart, Hezekiah Rogers, Ezekiel Rogers, John Meyer, Elias Carey and Rolof Sebring, all nearby landholders, each one having a 1/8 interest. Although it does not ap-pear pn the 1759 map of Plums tead,3 or the Survey map of Tinicum Town-ship, Gen. Wm. W.H. Davis, who was p esident of the Bucks County His-torical Society, s ta tes in his History of Bucks County, Pa. tha t Isaac Swartz was an early landholder on the sou th side of Tinicum Creek, in-cluding lower Black's Eddy, and John Von Fossen was the firs t settler on the north side. He also sta tes tha t Von Fossen built the first tavern and established the Cavebank Fishery Company.5 However, the above-mentioned group of eight people organized a business, operating a fishing hotel and the ferry. Michael Swartz acquired Hezekiah Roger's share in 1769 and af ter the death of John White he bought out the others and operated the ferry as a sole proprietor. It descended to his children and grandchildren (the family anglicized the.ir name to Black about this time) and accordingly the town was known as Black's Eddy. (' Although there may have been a mill on the Tohickon Creek a t Point Pleasant at an earlier da te, the firs t one documen ted was opera ted by the above-mentioned John White who is described in the deed of 1748 for the ferry tract.as a miller. The mill tract was pa tented to John White and his brother Joseph in 1765, but John White owned the adjoining land a t an even ea rl'ier da te as shown on the1759mapofPlumsteadTownshig. These t.wo trac ts totaled over 360 acres, the " upper Hughes tract" and were divided in 1784 between Joseph White, Sr. and the heirs of his brother John. The upper Hughes tract, and part of the mill tract below Gaddes Run, went to Joseph who sold to John Van Fossen. It appears tha t it was at this time Van Fossen established the Cave Bank Fishery ~ with John N. Solliday, a prominent clock and watchmaker who owned a great deal of land around Point Pleasant, as well as the islands in the river. Joseph White sold 134 acres and the mill which, a f ter having had seve-ral owners, was acquired by Jacob S tauffer who trans ferred it 'to pis son Henry. La ter, it was transferred to another son Ralph Stover who was a member' of the S ta te legisla ture from 1783 to 1799 and served in many other official capacities in the community. Ralph Stover was a prominent business man. He is repu ted to have bought up land a t the mouth of every Creek in Tinicum Township and to have stipula ted in his will tha t his lands were not to be cut over again for 100 years. His mill was a t the bott.om of Caf fer ty Hill, on the wes t side, while his impressive home was on the eas t side of Ca f fer ty Hill Road, opposite the mill site. Origina]ly a gris t mill, he operated it as a saw mill April 1981 Page 2

11 North Main Street, Doylestown, Pennsylvania M ByCKS COUNTY CONSERVANC o l POINT PLEASANT Conservancy /Sirmay wood lumber for shipment to distant parts".jng large amounts of hard-with his son, as the record sta tes, "produc Belknap's 1832 Gazetter of Pennsylvania describes Black's Eddy as "a rapid of the Delaware River at Point Pleasant, at which a samll village of 6-8 dwellings a tavern, store and post of fice" are loca ted and Point Pleasant in Tini-cum Township as "a town on the lower road to Easton, 14 miles north-east of Doylestown, having 8-10 houses, a store and a tavern". Ac tual-ly, there has been only one town here, from the beginning. Beside the ferry, the hot'el, the Cave Bank Fishery and the mills, Point Pleasant also supported quarries only one of which, the " Indian quarry" an undeveloped outcropping of rock along Geddes Run which as mentioned seems to have been the source of rock for arrow heads and other Indian a r ti fa c ts, is, within the limits of the proposed historic district. Three streams empty into the Delaware River at Point Pleasant, Hickory Creek,9 into which Geddes Run empties, and the About the junction of Hickory Creek {ghickon Creek. und Geddes Run there is half a mile from a pool which the fa rmers used, in the 1800's, as a sheep dip. These swif tly running s treams made this a logical place for mills, and in the mid 1800's there were three or four saw mills in the town producing finished lumber from the hemlock and pine trees which grew profusely in { the Delaware Valley. By 1900, most of them had been destroyed by fire. In addition, along the river near the site of the ferry a lime kiln was opera ted, burning limes tone taken from the deposits fur ther down the ~ river. There has always been good fishing a t Point Pleasant. The first " fish-ing hotel". the Moun tainside Inn which is on the River Road across from, the site of the ferry and the limekiln s till stands, although it i's not being opera ted a t the present time. The original building with its 16' bar room with large fireplace seems to have been crected in the mid 1700's although some authorities date it to 1689. It has been enlarged from time to time (the second floor of the second section was formerly the Point Pleasant Ice House) but the s' tone front has always been care-fully matched. Since it contains only about 6 bedrooms, a frame house on the opposite side of the River Road was enlarged. The first floor was used for dances and other entertaii. men ts, while the second floor had a t 1cas t 12. bedrooms. In early 1900's this hotel was owned by Chris. Schneider, a New York man, who organized parties that came to the Mountainside for vaca tions and week-end fishing trips. An ardent member of the I.O.O.F he dona ted the land for the white frame Odd Fellows lodge which was built on the rocks beside the inn. Beside the Sa turday lodge meetings, here were held the' local entertainments and also the sessions of the weekly de-ba ting s.ociety. A more recent owner of the ' hotel said tha t a s recen tly April 1981 Page 3

BbCKS COUNTY CONSERVANCY 11 North Main Street, D2ylest:wn, Pennsylvania 189( o l POINT PLEASANT Conservancy /Sirmay as 1949 a group of 70 fishermen came to the inn on a Sa turday morning, and this was not an unusually large group to be accommodated there. There was another smaller hotel in the town, the Central Hotel, which is now called Apple Jack's. This is said to have been built to accom-modak the men working on the barges, as Point Pleasant was a conve-nient spot to tie up for the night. There was also an inn near the two mule barns on King's Island which is part of Point Pleasant. On the high point of land which juts out over the river in the center of the town, stands the " upper hotel" the Point Pleasant Inn which was built about 1786. The original building was destroyed by fire in 1812. It was rebuilt by Michael Weisel and it is still an imposing structure with its six supporting pillars and double-deck porch, and is now an antique store. The second floor has about 35 rooms and since the pre-sent owner has found 17 small s toves, and 17 keys to the separa te toi-lets in the yard behind the hotel, it is assumed this is the number of guests which could be comfortably accommodated over night. He sta tes tha t in the gues t book, which was des troyed when they had a fire in the barn in 1948, appeared the names of Grover Cleveland, William McKinley, Gov. Stokes of New Jersey,and many other prominent people including c members of the Whitney, As tor and Vanerbilt families, who came to Point (. Pleasant to enjoy the fishing. This structure is referred to as the "qua lity" hotel. Here the stage, coach stopped and here were held sales of lives tock. Behind the barnw. in the rear are small shops of ra ther recent date. Opposite the hotel, across the River Road,, is a handsome brick structure, also with a double decker porch, which was built to accommodate the servants of the hotel gu e s. ts. Further-down the point, in.back of the inn, stand the weigh s ta tion for the Pennsylvania Canal, and a building occupied by a coal and feed dealer. Crossing the canal, we find a large res taurant which has been conver ted from a roller ska' ting rink. Ea rly in 1800's, a f ter the Erie Canal became profitable, the idea of h building a network of canals in Pennsylv'ania became lopular. The Del-aware Division of the Pennsylvania Canal was authorized by the ~ state in 1827 and completed in 1832. It ran between the river and the Riv er Road from Bristol to Easton.ll It has 9 aqueducts, 110 overhead bridges, a guard lock a t Easton 'and a tide lock a t Bris tol, and a total of 23 lif t locks. In addition to the dam at Easton there was a wing dam in the river at New Hope. It was connected to the Morris Canal a t Phil-

lipsburg, N.J.

and to the Delawa re and Raritan Canal a t Trenton,N.J., and consequently served a large area. With the advent of the railroad the canal fell into disuse but in 1959 the Lehigh Coal & Navigation Co., the owners, transferred it to the State and as the Roosevelt Sta te Park it again serves the people of the community. April 1981 Page 4

o' 11 North Main Strcet, Doylestown, Pennsylvania lb5 BqCTJS COUNTY CONSERVANCY POINT PLFASANT Conservancy /Sirmay (, Point Pleasant was popular stopping spot on the canal. Dressed stone from the quarrien was shipped out, d es tined for the streets of Philadelphia as well as buildings there and in the city of New York. Lock ill2 and if14, which are only about 700' part, are situated oppo-site the Mountainside Inn.. The lock keeper's house was adjacent to Lock #14. The aqueduct, which is the longestone over the canal, spans the Tohickon Creek in back of the present fire house near the Point Pleasan' Hotel. The canal of course brought a lot of business to Point Pleasant which enjoyed its grea test prosperity about the time of the civil War. For several years thereaf ter it was one of the busiest places in Bucks Coun ty. It is said that dozens of raf ts of timber were unloaded each season when the river was high. The canal a t that time employed hun-dreds of men between Easton and the locks a t Point Pleasan t and Lum-bervi.lle. $ grea t deal of coal was shipped down the canal on barges. While most J them used mules, sometimes teams of oxen were used. In addition to the river and the canal, travelers pa tronized the Doy-les town and Poin t Pleasan t s tagecoach, which in 1884 was opera ted by Jacob Isentrager. The Delaware River bridge, which was built by Hood and Steel in 1853 connected Point Pleasant with the town of Byram,N.J. ( which was served by the Belvidere Railroad. This rail line (plans made to extend the service to Point Pleasant and other towns in Penn-sylvania never ma terialized) had a president Elias Morris, and secre-tary John Clemens, both o f whom lived in Point Pleasant. l The bridge over the Delaware at Point Pleasant was destroyed in the flood of 1862 While the freshets which brought high wa ter down the river were useful, the serious floods of 1841, 1862, 1869, 1936 and 1955 did a great deal of damage washing.out bridges, uprooting trees, destroying crops and farm buildings and' seriously damaging the canal which in some of the abcve mentioned years was out of service for sevc-ral months. The S tate of Pennsylvania passed a law fin 1834 establishing free schools, but it was not well received as men preferred to havd their children educa ted in their own languages and customs and consequently many schools were associa ted with the chuiches. In 1850 the little schoolhouse which stands a t the intersection of the River Road and Ca f ferty Road was opened. It was built by subscription, and it was to belong to the contributors for a period of ten years and then sold to the highest bidder. This school was built by a group of public spi-rited citizens but any child could a ttend. Ralph Stover, who was the largest contributor, gave $25 while there were many donations of 12-T 1/2d -this a t a time when a man's wage was perhaps only $1 a day. The building continued to be used as a school until 1918. From 1934 to 1954 it was the local library. In 1954 it was sold and later became a part of the Baptist Church which stands directly behind it on the $pril 1981 Page 5

'i w,sa t.vv4 sob L,U4 N a t i i V / u w 1 44.we">+ni-"~.-w"~"".*- + _a ,, I 6-Conservancy /Sirmry /, POINT PLEASANT River Road. There were other schools is the proposed historic district-- the River Hill School was built in 1849. It is a sturdy structure having 20" stone walls with stucco finish and is graced with a wooden cupola. The inside dimensions are 33'x22'. At first it was a one room building, with wainscotted walls, later a second floor, which still has the teacher 's pla tform, was added. There is also an old school house at the end of the proposed historic dis-trict at the intersection of Tohickon Hill and Sta te Park Roads. The Baptist Church, the only religious structure in the town, is located above the point on the River Road. It was started by a group of ministers headed by the Rev. Jeseph Mathias of the Baptist Church of Hilltown. They came to the area and preached to the resi-dents in groves, barns and other loca tions and, just before the Church was erected, held meetings at the old River Hill School building. The original membership, when it was organized in 1849, number 53 persons but revival meetings were held in the 1870's and the membership increased, 134 new members were added in one year, and 85 in another. The occupations of the townspeople changed con-s tan tly. The 1871 Directory of Bucks County lists many businessmen a t Point Pleasant, such as blacksmiths, boatsmen, carpenters, a horse trader, a lime burner, locktenders, masons, millers, store-keepers, a coal dealer and a shoemaker, also hotelkeepers, and about 4 30 fa rmers. In 1898 the Directory lists a wheelwright, a physician, s torekeepers, stone workers, a lumber and coal dealer, a drover, but only 4 farmers. By 1902 the Directory also lists a reporter, a barber and a telephone operator. In addition, the men of the Solli-day family were noted clock and watchmakers and Henry Troemner, who married Ralph Stover's daughter Elizabeth was a maker of fine scale ~2' and, according the tradition, he invented the Troy scale used by apothecaries. With the advent of Prohibition in 1920, the hotels ceased to flou-rish although it has been said the some sold illicit beverages, a'nd by 1928 the canal boats, many of which ca rried coal, discontinued service. With the introduction of clean and cheap oil hea t the coal dealers could no longer make a profit. e 9 4 April 1981 pa ge 6 ~ (

\\ BUCliS COUNTY CONSERVANCY 11 North Main Strcet, Doylesto'wn, Pennsylvania ISS\\ o / Conservancy /Sirmay \\ POINT PLEASANT -7 BUCKS COUNTY CONSERVANCY _* FOOTNOTES 1 Department of American and Prehistoric Archaeology. 2 Statement over emphasizes the importance of the Point Pleasant Tu rnpik e. 3 Source and da te of compila tion unknown. Map is a probably of twentieth cen tury re-crea tion of township. 4 Source unknown. 5 McReynolds Place Names in Bucks Coun ty_ s ta tes tha t the Cave Bank Fishery Company was organized in 1748. 6 Sentence should read " upper Ilughes tract" in Tinicum and C e " lower IIughes tract" in Plumstead were divided. 7 Anglicized version of S tauf fer. 8 Most area gris t mills in the region regularly combined grist and saw milling operations. 9 S entence should read "Tohickon Creek, into which Geddes Run empties, and the Hickory Creek". 10 Tohickon Creek. 11 In this part of the county. Further sou th it crosses under River Road in several places. ? ~ A., April 1981 Page 7

hl t i BRYN MAWR COI.LEGE (r BRYN MAWR, PtNNSYLVANIA ItotD y. DtrARTMENT OT AMTHROrotoCY DIS) 443 3030 8 April 1982 Cathy Auerbach Bucks County Conservancy 11 North Main Street Doylestown, PA 18901

Dear Ms. Auerbach:

Enclosed is our evaluation of the archaeological investi-gation's conducted in 1978 by Sb6rtman and Urban in conjunction with the pumping station, transmission corridors, and reservoirs in and around Point Picasant. Based on our own understanding of the local prehistory, we are highly critical of the'ir report. Note that we have no objections to your using this in any future discussions concerning this proposed construction project. Sincerely, } / - Oh Dr. Richard H. Jordan Associate Professor and v ~ Glenn W. Sheehan Ph.D. Candidate CC: Dr. Larry Tice Pennsylvania Historic and Museum Commission William Penn Memorial Museum Ha rrisb urg, PA 17120 and Kurt W. Carr Review Archaeologist Division of Planning and Protection' Eureau of Historic Preservation o William Penn Memorial Museum-harrisburg, PA 17120 h

(.,. D-2p Qro

na Bucko County Conservancy has asked us to precent a brief evaulation of the archaeological sensitivity and potential of the area around Point Picasant wh,ich is involved in the proposed diversion project. We have been doing independent research in the area for almost a year, including field research'to locate, prehistoric sites which are documented archivally, and surveys to discover new sites. The project has had the over-all goal of documenting outcrops of stone which were used as sources of raw materials for tools, rad of investigating the distribution of these materials af ter their-Initial quarrying. A seconda'ry goal has been to research the history of archaeoloEy in the area as exemplified by the work of Henry Mercer. Our archival research has extended to the collections of Mercer's field notes and correspondence at the Mercer Museum, at Font Hill, and at the University of Pennsylvania. This project, the South Mountain Lithics Project, is under the direction of Richard H. Jordan, associate professor of Anthropology at Bryn Mawr College. G.W. Sheehan, one of Jordan's doctoral students, serves as field supervisor. About a dozen other individuals have devoted considerabic time to t.he proj ect. Our initial interest in Point Picasant lay in Mercer's f work there before the' t. urn' of the century, and in the distribution,' nature and age of the historic Indian sites in the region. Hence w'c feel that we are in a somewhat special position to con =ent upon the archaeological work conducted In conjunction with the proposed roint Pleasant pumping station and the pipe line corridor. Schortman and Urban (1978) conducted the work at Point Picasant under contract with E.H. Bourquard Associates. Their work is summed in the Environ-oc6tal Report on Neshaminy Water Supply System (1979:III,104) as follows: "In the area of Point Pleasant, four archaeological sites were identif'ied by I

Henry Mercer in tha lato nineteenth century, from the late 188010 (sic) to ' the early 1890's. ' None of the sites lic within,or proximate to the right-of-way..." - And "There is no archaeological evidence that the construction of the project's components would harm or destroy any archaeologically valuable site (III-113). " These conclusions are almost without question incorrect. We believe that an examination of th'c effort by Sdiortman and Urban reveals areas in which their program did not meet generally accepted standards for cultural resource cangement projects.,and that these deficiencies account for the'ir failure to note the presence of even a single " archaeologically valuable" site in the. impact area. We address our remarks specifically to prehistoric remains, but it should be n.oted that they apply at Icast in part to the question of historic archaeological sites. The program failed to involve a thorough or significant literature and archival search. This resulted in an inability to find or judge the signifi-cance of sites which have already been documented by other archaeologists and collectors. This ' initial failing should have resulted in a more intensive field project, since the lac 1s of archival sources n. 3de the impact area a virtual terra'inc66nita to the investigators. Un fo:: tuna t ely, the field work was seriously flawed above and beyond the lack of archival documentation. Although the report is not explicit as to the exact width of the corridor, it was at leas.t 10.25 miles long. In this entire area, only four test pits and twenty highly localized rapid. shovel tests in four areas were made. Had the entire corridor been under the plow or othervise exposed, perhaps a small number of tests would have been sufficient. Accord-ing to the investigators, most of the ground surface was totally obscured

~ 3 dich in our opinion; vould. require more intensive sub-surface testing. Moreover, the investigators rigidly adhered to a self-imposed course of action which restricted them totally to the land _ inside the designated, but not always apparent, b'oundaries of the corridor itself. In mitigation 6 surveys it is necessary, eppecially where ground cover obscures the visibility ~ of surface materials, to consider the setting of the corridor by investigating ' adjacent areas, especially when these areas are plowed or sparsely covered, 'or where thef exhibit topographic-or other features that might indicate the possibility of sites. Failure to consider and examine areas adjacent to the , corridor leads to an inability to properly assess the geographic setting and site potential within tiie co'rridor itself. At the juncture of the combined transmission Ifne, cast branch and north brancN"[s* the Bradshaw Reservoir - a 25 acre impact area just northeast of the north branch of the Neshaminy Creek. We feel that since these efforts here consisted of a single test pit, that they are inadequate. The only reported time that the investigators strayed from the corridor was during an investiga- .a-. tion of a stratified village site trenched and reported upon by Mercer (1897 and ciscwhere). 'Although they report that this mounded area, the Lower, l j Black's Eddy site, is 350 feet from the pipeline running out of the pumping l station, a more accurate assessment is that it is at most a few tens of feet j from the pumping station impact area. Although they did find the general site l . that Mercer' investigated,Sdhortman and Urban failed, as did Mercer, to deline-ate the extent of the village site. In other words, activity areas associated 1 with the village 'could very well lie entirely within the impact area - no one knows. Within the direct impact area of the pumping station, an area of about l 3.9 acres, only two test pits were excavat ed. One test pit hit a rock at l t

36 en (14") co cxcavrtion was stepp:d. Tha secand eubsurfcca test by th2 investigators was carefully placed on the same contour interval as the known part of the village site. .It extended to 25 inch'es below the surface. Since Mercer states and illustrates in his publications, sketches, and notes, that the second and older stratum of the site is 'at least 25" below the depth reached by Shortman and Urban's test (Mercer, 1897), and since they stopped in a sand nubsoil which may be the same one reported by Mercer to overlay the lower stratum of cultural material, we can only conclude that there was a complete failure to test 'for this buried horizon. Although the investigators were aware that Mercer had found a lithic reduction station. (he called it a blade factory), they, as did Mercer, made no' attempt to discover its extent. Although our field work was not directed toward ascertaining locational. facts in relation to the proposed constructirn area, we have succeeded in detennining that both the village site and the lithic reduction station immediately to the. couth and. north of the pumping station impact area, are still valuable and viabic archaeological entities. In fact, both contain undisturbed in situ preh'istoric materials which make them ' ~~ particularly significant for archaeologists. The steep slope corridor up Hickory Run was not investigated at all by ( fibettan and Urban. See, for example, the enclosed Schaddinger 1890's map of H1'clory Run, indicating ten sites where Indian " relics" have been found (Mercer Museum Archi.ves). Without question Shortman and Urban were entirely unaware of this map..Moreover, local residents have stated that there are numerous caves along Hickory Run which may have been temporary occupation sites (Charles Chaney, personal communication - Chaney lived for years on the plateau adjacent to Hickory Run) and there is a distinct possibility that e 9

quarry work shapa era sizo present hera. Ma hav2 found that th2 steep clop 0 along Caddis Run were not a hindrance to aboriginal quarrying and are extreccly visible along the Danboro-Point Pleasant Pike. We thus feel that this area of the corridor should have been closely inspected. Our experience indicates that what, at first glance, often appears to be scree and loose rock in the Point Picasant area is in fact the remains of pre-v historic quarrying' and reduction activities. SincekhortmanandUrbanreport walking over loose rock, we suspect that some quarry or reduction sites lie within the impact area and were not recognized. Again, no archaeologist, including Mercer, has ever precisely delinear ed the extent of the iuarrying l acitivites. Although the Danboro-Point Plersant Pike is almost one continuous archaeological site for a digtance of about 0.4 mile west of Point Pleasant, l' with evidence of extraction and reduction activities everywhere, PJhortman and Urban make no mention of the fact.- We believe they were unaware of this, and were therefore not alerted to test for its possibic extensions within the icpact area. Our revlev of the work by Shortman and Urban reveals it to be unsatisfac _ tory for the reasons stat;cd above and summarized here: there was a totally inadequate archival' and literature search; there was an inadequate program of interviews with knowledgeable local people; there was a disunderst' nding about a the basic areal extent of concern for Investigation during the course of a ~ cultural resource management project, so t.1 at areas adjacent to the direct icpact area were ignored, both unnecessarily limiting the scope of work and limiting the possibilities for understanding the area within the corridor; and finally there was'a totally inadequate testing program. In short, the conclusion reached in the Environmental Report that "there is no archaeological e

~ 1 _evidsncithet tha conptructicn of tha project's components would here er destroy ny archaeologically valuabic site"(1978,111-113) is totally without scientific justification; there is no basis for such a determination.. .Ve have not" reviewed,the wor'k done by archaeologists other than i Mortman and Urban. ~ That is, we have not seen any r.eports on other impacted areas, such as the,transmisnio,n lines and water treatment plant in and around i f,, Chal font. "Nor have we seen any archaeological investigations at. Limrf ck or the pipeline corridor Icading from the Perkioinen to the Limrick Power. Plant site. References Cited MERCER,llENRY C. .in the Delaware Valley and 1897 Researches Upon the Antiquity _o'r Ifan the Eastern United States. Publications of the University of Pennsylvania series in Pliflology, Literature and Archaeology, VOL. VI., NESHAMINY WATER RESOURCES AUTHORITY 1979 Pnvironmental Report on Neshaminy Water SupplyJystem_. Doylestown, PA. i SCIDRTMAN,* EDWARD M. AND PATRICIA A. URBAN 1978 "A Survey of Cultural Resources in the Area of the Proposed Point Picasant Pumping Facilities, Combined Transmission Main, Bradshaw Rese rvoir, North Branch ifain and Perkf omen Main, Bucks County, Pennsylvania. " Report submit ted to E.H. Bourquard - Assocfates, lia r r isbu rg, PA. m

C65 G - ShNt i $T;" lit'CKS ColJNTY e ', .1%. 4' .~ d I;<: 9*j, g,. BUCKS COUNTY CONSERVANCY 1 p ,c; 2 C() NS I'.R VA NC Y 11 N rth Main Street, Doylestown, Pennsylvania 18901 1215) 345 7020 December 1, 1981 Mrs. Brenda Barrett Bureau of Historic Preserva tion-Pennsylvania and Museum Commission ,,,-['j.i,l'.,((j.,f-] I P.O. Box 1026 .I..,g;'ijl j.f.{.. Harrisburg, Pennsylvania 17120 RE: Poin t Plea san t His toric -& }.j'.-@,"jg Archaeological District.cd.l* S

• 1. +.'

.S L.4-Ii 2..:;.- ' Q:.. ' '. il. l

Dear Brenda :

s v .... ~.n.v r ega rd ing!.,. Enclosed a re the Conservancy's Comments and Criticisms prepa red by Ms.Elizabe th', -] the R_egues t De termina tion of Eligibility Mintz for the U.S. Army Corps of Engineers Augus t 1981 Throughs,.1 our. survey and register work of the pas t four years, we haveje 8j gained extensive knowledge and unders tanding of Bucks County's'-[fl".- resources and development trends. In seeing flaws in the docu-menta tion prepa red by Ms. Min tz we felt it our responsibility to,,,, contribute our in forma tion in order that Point Pleasant be,' prop- ' erly recorded. We request that our comments always be kept withy-the Mintz Report. ~ Thank you. ) .hJ. 05i. L.. e Ka thryn Ann Auerbach Director, Historical Sites Survey KAA/ut1 Enc. i 0 Yc IL k lEn e r.., s; tvilliam.\\mey 0 Mrs. Rober1 liitfiffe ill o Norrnan J. Drustrup e Mrs Paul rlack o Kenneth W. Ccmmill, r_q. u ittom i II.. Incr. by. e 1.cwls llull e Virgil Kauffman e l_foytl 11. Klafdio e I.loyt! 12wrrnce o Mrs. rred W. IJille, I'li.nles M Mrrvditti !!!

• Wif fiam (:. Bittgn e lifw. net (:. Rmvr o it,.rfcy I.. Stowell Peter A. Ciascott. I: q. N,ditifor e Robert W. l'icrson, i:,scruflie Dintfor D-40 Lc..-. C 2...

HUCKS COUNTY t. .u. n .m i 6,, hh ) }id BUCKS COUNTY CONSERVANCY j k L-i CONSERVANCY 11 North Main Street, Doylestown, Pennsylvania 18901 (215) 345 7020 October 19, 1981 Dr. Larry Tise, Executive Direptor Pennsylvania Historical and Museum Commission Post Office Box 1026, William Penn Museum Harrisburg, PA 17.120

Dear Dr. Tise:

I am writirig with regard to the review of the proposed Point Pleasant Pumping Station project by the Bureau of Historic Preservation. As was mentioned in our July 23 meeting, there is great concern about the impact of the project on the valu-abic cultural and historical sites in the immediate area, par-ticularly the Delaware Division of the Pennsylvania Canal and the prehistoric Lower Village Site investigated by Dr. Henry Mercer. I am enclosing a copy of Dr. Mercer's report on his findings in Point Pleasant with the village account beginning on page 70. I have also provided a copy of a letter from Del-AWARE, an organization of citizens concerned about the use of the Delaware River and its environs, to Rep. James Greenwood. This letter outlines the inadequacies of the Cultural Resources assessment prepared by Edward Shortman and Patricia Urban in 1978. The Conservancy is in agreement with Del-AWARE in seeing the need to re-review the impacts of this project on Point Pleasant's historical resources. I would appreciate knowing whether you have instituted an ad-ditional review based on the importance of the Mercer site and your awareness of the inadequacies of the Cultural Resources study available when initial reviews were made. Sincerely, [ ! yf Robert W. Pierson Executive Director Enclosures cc. Rep. James Greenwood Del-AWARE l Ollit.C107.S. Willia m Amey

• him. Robcn Eiddle 111
• Rot en C. Bodinc
• T. Sidney Cadwallader. Faq.
• Nor man J. Drustrup hits. Paul flack
• hnncth W. Cemmill. Esq.
• William F. IIcerner Esq
• 12wis lfull
• Vir6il Kauffman l

L!cyd H. 5: fat:1in

• t.foyd t awrence
• hin. Fred W. Little
• hits. Benton hicinin6er, Jr.
• William C. Rid e
• liar!cy L Stowell 6

Ntartin Sutton

• Peter A. 'Clmott Esq, SoUritbr
• Robert W. Pierson Enc urig e Dirrefor

\\ ~

a me. t3UCKS COUNTY CONSERVANCY 11 N:rth Main Street, Doylestown, Pennsylvanin 18900 o .I ARCHEOLOGICAL INVESTIGATIONS OF THE POINT PLEASANT AREA A Preliminary Report By: Samuel W. Landis in conjunction with Dr. Richard Jordan, et al Dept.' of Anthropology Bryn Mawr College Bryn Mawr, PA. August 23, 1982 I Cd; h { i _.m-

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BUCKS CbUNTY CONSERVANCY o 11 North Main Street, Doylestown, Pennsylv:nin 18901 Archeological Investigations / Point Pleasant: Preliminary Report ABSTRACT The vicinity hmnediately surrounding the Point Pleasant area in the middle Delaware Valley was identified nearly a century ago by IIenry C. Mercer as being an extremely importnat key to under-standing the Indian of southeastern Pennsylvania. It was here that the Indian not only lived for thousands of years but also obtained a type of lithic material, argillite, from which he fashioned his tools. The importance of any archeological site is, indeed, questionable due to what data it may have to offer. Clearly some sites are of far greater importance than others. Although any river flat will generally produce at least some evidence of pre-historic habitation, the area in and around Point Pleasant is indeed unique for a variety of reasons. 1. The entire river flat N & S of Tohickon Creek shows surface indication of continuous prehistoric occupation. ~ 2. The entry of the Tohickon Creek, a high order stream origi-nating in the Piedmont of upper Bucks County, into the Dela-ware River on the flood plain provided easy access to both the river and the Piedmont for prehistoric travelers. 3. This area of continuous occupation on the river flat is immediately adjacent to the lithic workshops and quarrying activities of the Indian, a scenario seldom seen anywhere. 4. From surface indication, there is a definite difference in lithics from the area south of the Tohickon on the flat and the area north of the Tohickon on the flat. Although it is entirely too early in preliminary investigations to make a conclusive statement regarding this fact, we can assume that . some definite travel patterns and/or settlement patterns should become evident, t 1 i

BUCKS COUNTY CONSERVANCY o 11 North Main Street, Doylestown, Pennsylvanis 18901 Archeological Investigations / Point Pleasant:- Preliminary Report 5. The area under preliminary investigation represents deep & well-stratified deposits. This fact, in itself, is of para-mount archeological importance when dealing with any site. This along with the other facts concerning the Point Pleasant vicinity, indec4 makes the area quite unique and possibly important even to the prehistory of the entire northeastern region of the United States. The purpose of this preliminary report is an attempt to deter-mine depth of deposits, area of occupation, age, chronological sequences, etc. as a result of some archeological testing on the river flat. IIowever, due to the time element involved, and the unexpected depth of stratification encountered, conclusive interpretive results are not possible at this thme. We merely state given facts and individual situations as encountered thus far. ~ h 2

. BUCKS COUNTY CONSERVANCY o 11 North Main Street, Doylest:wn, Pennsylvania 18901 Archeological Investigations / Point Picasant: Preliminary Report GEOLOGY The area under investigation includes the entire flood plain along the Delaware River both north and south of where the Tohickon Creek enters the river. However, for the purpose of this preliminary report, the area considered includes only that portion of the flood plain north of where the Tohickon Creek enters the Delaware River, and then only a small series of test squares on the Walter's Nurserj property recorded with the Pennsylvania Historical and Museum Commission as 36BU2. The most recent geological formation on the flood plain, a thin, plow-disturbed humus, is nearly entirely absent on the nursery property. Due to the fact that as recently as forty years ago much of the nursery property was bulldozed to sell the topsoil, and the continual disturbance thereafter from nursery activities creates to some degree an interpretation problem of the geology of the property. At any rate, the upper zone throughout the property is a relatively low organic content plow-turned sand. This cand is subject to continuous wind and' wash erosion, partic-ularly the third and ' fourth terraces above the river. Beneath 1 this zone lies an alluvial sand formation ranging from 0.5 to (unknown) in depth which probably represents intermittent flood deposition. There are some individual sand strata within this zone ranging from about 0.5 cm to 3.0 cm in thickness. At some places these are separated by red clay luminae which were probably 3

BUCKS COUNTY CONSERVANCY o 11 North Main Street, Doylestown, Pennsylvania 18901 Archeological Investigations / Point Pleasant: Preliminary Report GEOLOGY dropped from suspension during times when water velocities were low. Beneath the alluvial sand lie two distinct formations. The first encountered, Trenton gravel, is a course river-laid gravel of r glacial outwash. Beneath this gravel, particularly at points where it is cross-bedded, lies a strongly developed boulder bed. The courser deposits may represent the work of the early formed Delaware River during the Pleistocene when the valley was being cut to its present levels. In relatively recent years, such major floods as those occurring in 1903, 1936, and 1955, caused marked changes in the topography of the flood plain. This, along with the top-soil removal indf-cated earlier, caused much of the later evidence of occupation to be destroyed. This is especially true of the third and fourth terraces where there exists in most places only 1.5 m of alluvial sand above the Trenton gravels. There is no distinct occupation levels evident in this sand and for the most part it is completely devoid of any lithic material. Such is not the case, however, with the second terrace. It is considerably lower than the third and fourth and therefore was subject to an unusually large amount of 1 slopewash and erosion from the higher terraces. In most cases, there appears to be approximately 50.0 cm of disturbed sand above the last or uppermost level of occupation. Taking into consider-ation the prior removal of the topsoil from this terrace, a protected 4

BUCKS COUNTY CONSERVANCY o 11 North Mrin Street, Doylestown, Pennsylvania 18901 Archeological Investigations / Point Pleasant: Preliminary Report GEOLOGY overburden overlays this last occupation. Such a situation lended greatly to the fine protection of the cultural icvels below and affords a classic example of an exceptionally well stratified area. It is therefore this second stratified terrace which shall be the focus of this preliminary report. h 5

BUCKS COUNTY CONSERVANCY o 11 North Main Street, Doylestown, Pennsylvania 18901 Archeological Investigations / Point Pleasant: Preliminary' Report \\ EXCAVATION ) k A test square of two meters was dug on the second terrace adjacent to the private road which runs parallel to the summer homes between Walters Nursery and the Delaware River. The area has not been utilized for nursery activities for at least 10 years and was sub-ject to a slight undergrowth of grass and weeds. Approximately twenty trees viere left growing by tNe nursery ov6ers immediately above this terrace in an effort to decrease slopewash and crosion fromtheupperte[ races. This square was excavated in 10.0 cm levels and all soil 'creened through 0.25 in wire mesh. s All of the first four levels and a portion of the fifth icyc1 (52.0 cm) was ~ found to contain a minture of prehistoric materihl in addition to historic and modern refuse. Most of this accumu-lation was a result of slopewash and erosion from the upper terraces and the disturbance caused by nursery activities, j There were several fragments of firc-cr.scked stone recovered, as well as several flakes of Jasper, chert, and argillite. One untyped broken projectile point was recovered from this area at a depth of 34.5 cm. No pottery fragrnents whatsoever were recovered. At exactly 53.0 cm, an undisturbed icve.'14.0 cm in thickness of flood-deposited alluvial sand was encountered, beneath which lies the first intact level of occupation. This level is 6.0 cm in thickness and is very apparent from a vertical profile due to the dark color of the deposit. It is' found to exist throughout 6 1

BUCKS COUNTY CONSERVANCY o 11 North M:in Street, Doylestown, Pennsylvania 18901 Archeological Investigations / Point Pleasant: Preliminary Report EXCAVATION the entire square. It is intermixed with charcoal and fire-cracked rock and as a result of artifact recovery apparently represents a level of occupat).on from the Late Woodland Period. Although no features were exposed in this test square, the following diagnostic artifacts were associated with it. Late Woodland gottery fragments representing interior / exterior smoothed interior smoothed, exterior corded, and one sample of,Overpeck Incised. Two fragments of clay pipe bowls Two notched pebble netsinkers In addition to these artifacts, several hundred flakes of lithic material were recovered. Representative percentages are as follows : Chert 70% Jasper 20% Argillite 8% Chalcedony 1% Other 1% It is interesting to note that even given the proxi. of the argillite quarries, this Late Woodland level holds true to other such levels excavated elsewhere in that the Indians apparently preferred higher quality flints to the argillite. Beheath the Late Woodland deposit there exists another level of 7 e w.

BUCKS COUNT? CONSERVANCY o 11 North Main Street, Doylestown, Pennsylvania 18901 Archeological Investigations / Point Picasant: Preliminiary Report EXCAVATION alluvial sand of at least 35 cm in depth. The soil is inter-mixed with considerabic charcoal and occasional fragments of fire-cracked rock and lithic chippage. In this icvel at a total overall depth of 88 cm a small hearth was c< posed, evidenccd by an unusually large amount of charcoal, woodash, calcined bone fragments and some fire-cracked rock. No associated artifacts were found in association with this feature, although charcoal sampics were taken for dating purposes. Further excavation frou this point will continue, but as stated earlier, due to the time element involved, this is the extent of excavation thus far. L e 8

BUCKS COUNTY CONSERVANCY o 11 North Main Street, Doylestown, Pennsylvania 18901 Archeological Investigations / Point Pleasant: Preliminary Report PRELIMINARY ANALYSIS OF EXCAVATION The presence of a well stratified terrace has been demonstrated at least up to the present extent of our excavation. Based on past experience, it can be reasonably assumed that the site does in fact contain well stratified deposits to considerable depth. Due to the lack of diagnostic artifacts in association with features, and the limited amount of excavation thus far pro-hibits any definite analysis of our field work. I e e. 9 9 9

BUCKS COUNTY CONSERVANCY o 11 North Main Street, Doylestown, Pennsylvania 18901 Archeological Investigation / Point Pleasant: Preliminary Report SIM1ARY In addition to our limited test excavations on the Walter's Nursery property, we had the opportunity to examine a consid-erable number of artifacts in, the possession of the property i owners which were recovered as a result of nursery operations over a forty year period. Such material represents a time span of perhaps 6000 years of Indian occupation, including many artifact forms of the Archaic tradition. Grooved axes and spearthrower weights as well as a wide spectrum of other Archaic tool forms and projectile points are quite abundant. The area south of the Tohickon Creek, specifically an area to which Henry Mercer referred as the Lower Black Eddy site, is also a well stratified deposit. Mercer indicated in 1893 after his excavations, a distinct difference in tool forms I from different levels. Even today, as a result of bu11 dozing I operations in the area, well defined strata are visible along I i i with excessively large amount of lithic material and pottery I fragments being exposed from erosion. This site is clearly I I in danger of destruction not only from this natural action, but j i as a result of its recent discovery by several local collectors. Hopefully from further archeological field work in the area, the unique importance of the Point Pleasant area will be acknowledged. The entire area of this river flat, both north and south of the Tohickon Creek has the distinct potential of providing a vast 10

BUCKS COUNTY CONSERVANCY o 11 North Mrin Street, Doylestown, Pennsylvania 18901 Acheological Investigations / Point Pleasant: Preliminary Report

SUMMARY

amount of information in not only the middle Delaware Valley, but also by providing a key to solving problems concerning Pennsylvania's archeological heritage. 4 i 4 i 11

~ L; Ai 0 A) \\I \\l v g d G WATER QUALITY ANALYSES r AREA-SPECIFIC DILUTION STUDIES REGION III rd a l ~J Prepared For: g U.S. ENVIRONMENTAL PROTECTION AGENCY Lj Office of Water Planning and Standards Monitoring and Data Support Division F' Le I g .e I' Prepared By: SCS ENGINEERS I-11260 Roger Bacon Drive Reston, Virginia 22090 (703) 471-6150 r k 1008 140th Avenue, NE 2b6 800 January 1981 ik IE. D-70 Il

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hydrologic fea tures were used to i den ti fy reach boundaries (pol f-tic ~al boundaries and structures, such as b. ridges, were not used). All riser segments connec ting reaches receiving waste discharge were given a reach designation even if no discharge occurred with-in the segments. ~' PRIORITY POLLUTANT DISCHARGE CHARACTERISTICS c Since the priority pollutant discharge characteristics of the dis-charge pipes in the dilution study areas had rarely if ever, been directly determined, estimates were used. In all cases, estimates were derived f rom the SIC of the activity generating the wastewa- + ter discharged based on one of two methods. For some SIC categories, nationwide screening surveys had previ-ously been conducted by the EPA Ef fluent Guidelines Division (EGD) to iden ti fy the priority pollutants found in the dilution study J areas, these-data were used to describe the types of priority pol- [ l utants present in the respective SICS.. Where no screening data were available, estimates of the anticipated types of priority g pollutants discharged were obtained from EPA personnel. A matrix showing the priority pollutants present for all SICS represented the dilution study areas is provided as Appendix B. P r el imi n a ry screening data were available for only a few of the SICS in the dilution study areas. Al though the information con-tained in this report will incorporate the uncertainty introduced [L by this data deficiency, the automated analysis system dev el oped for the p roj ec t allows for easy revision of the calculations in the future when better data become available. Where priority pollutants were determined to be present by one of x- ~ the two methods described above, the discharge concentration of ,) each pollutant from industrial sources was assumed to be equal to j the estimated 30-day average discharge concentration achievable with the judicious application of "Best Available Treatment" (BAT) techniques (2,3 For POTWs (SIC 4952), the priority pollutant I. discharge concen,4). l l trations were assumed to equal the median of the L values obtained from the nationwide discharge screening program since discharge concentrations are typically below the BAT treata- [] b i l i ty estimates. Th e priority pollutant concentration values lj used for both industrial and municipal discharges are presented in Ta bl e 2-1. i. RIVER CONCENTRATION CALCULATIONS ^ Calculations o f. p riori ty pollutant concentrations in the rivers i and streams of each study area were performed. at selected loca-tions using the approach described below. " Calculation points" were located at the downstream end of each reach and immediately below the junc tion of two or more reaches. 't l { 2-4

~ i The basic operations which the system performed for each reach I were as follows: 1. The volume of average daily process discharge flows were summed by SIC classifications; 2. The total process flow (in cfs) from each SIC was mul ti-plied by the BAT concentration of each priority pollutant present to obtain a mass loading for each pollutant; 3. The mass loadings for all SICS were summed to give a total loading for each pollutant; and 4. Each mass loading was divided by the mean annual flow and the 7-day, 10-y e a r low flow (cfs) at the downstream end of the reach to obtain the estimated concentration of each pollutant under the two flow conditions. Since conservative transport (no degradation / transformation after discharge) of the priority pollutants through the study areas was assumed for c al cul a ti on

purposes, mass loadings from upstream reaches were added prior to dividing by the river flow.

An exam-ple of the relationships between reaches, river flows and calcula-tion po,ints is shown in Table 2-2. Ta bl e 2-2 indicates that the river concentrations at calculation point No. I were obtained by dividing the mass loadings resul ti ng from d i s c h a r g.e s in reach No. 1 by 194 c f s and 19 cfs to obtain values for mean annual and low flow conditions, r e s pec ti v ely. For c al c ul a ti on point No. 3, the sums of the mass loadings from reaches No. 1 and 2 were divided by 498 cfs and 42 cfs to obtain the mean annual and low flow concen-t ra ti on s. Assumptions required to perform the dilution study analysis tend ' to both over-estimate and under-estimate in s tream priori ty poll ut-ant concentra tions. Under-estimates tend to result from the fol-l owing assump tions: t water upstream of the dilution area was pristine; e e BAT treatability levels are met by all discharges; j s' no non-point source pollution (low flow); and e zero growth (no increase in discharge flows over time). Over-estimates tend to resul t from the assumptions that: e all plants in the.same SIC category discharged the same poll u tan ts e degradation and transformation of the priority pollutants was negligible; t 2-9 A

3 g e discharge level s were BAT treatability leve s, these may. E be much higher than trace amounts in some dischargers; e BAT trea tment levels were not zero discharge; and e some discharge flows were permit flows or design flows if actual flows were not available. AMBIENT WATER QUALITY CRITERIA ANALYSIS g Ambient water quality criteria for the 129 priority pollutants are c u r r e.n tly under development by the EPA. The water qu al i ty c ri te-ria published in the November 28, 1980 Federal Register were used W in the dilution study analysis and are shown in Tabl e 2-3. Where 2 criteria development has not been completed, threshold l ev el s for f r e.s hwa te r aquatic life and cancer risk l ev el s for human heal th effects were used as specified by EPA. Where calculated river concentrations of priority pollutants were found to exceed the 24 hr. average fresh water toxicity criteria v al u e s, upstream dis-charge sources were exa 'aed to determine the source (s) of the h v iol ations( s). Specific findings concerning criteria violations based on calcu-l a ted river concentrations are presented in the following indi- ], vidual dilution study area report sec tion s. ~ O 0 B l rL. T*. L. ne. 2-11 O

,d 1: 1 ,ti=L 10:1 CI2 E~:2 iE3 C:2 E li C:2 i ::.li C:2 m lupi tan r.am nam me. -4.' TABLE 2-3 (CONTINUED) Priority Pollutant (pp) Priority Pollutant 24-ilr. Average Fresh Ndme and Category Number Water Criteria }{uman lie'alth Criterial II. METALS AND INORGANICS (CONTINUED) Lead 30 C 50.0 Mercury 31 0.00057 Nickel

• 32 0

13.4 Sel enium 33 35 10.0 E++ 50 Silver 3tt Thallium 35 40 13 Zinc 35-47 III. PCB's AND RELATED COMPOUNOS 'f PCB-1016 37 0.014 0.00079* PCB-1221 38 0.014 0.00079* PCB-1232 39 0.014 0.00079* PCB-1242 40 0.014 0.00079* PCB-1248 41 0.014 0.00079* PCB-1254 42 0.014 0.00079* i PCB-1260 43 0 014 0.00079* 4 2-Chloronaphthal ene 44 1,600 + IV. IIALOGENATED ALIPilATICS Methane, bromo-45 1.9* Methane, chloro-46 1.9* Methane, dichloro 47 Methane, chlorodibromo 48 11,000++ Methane, dichlorobromo 49 1.9* Methane, tribromo 50 1.9* Methane, trichloro 51 1,240+ 1.9* Methane, tetrachloro 52 4.0* Methane, trichlorofluoro 53 1.9* Methane, dichlorodi fluoro 54 1.9* Ethane, chlom 55

/ TABLE 2-3 (CONTINdED) f riority Pollutant (pp) Priority Pollutant 24-ile. Average Fresh Name and Category Number Water Criteria iluman Health Criterial IV. IIALOGENATED ALIPilATICS (CONTINUED) Ethane, l',1-dichloro 56 Ethane,1,2-dichloro 57 20,000+ 9.4 Ethane, 1,1,1-trichloro 50 18,400 E thane, 1,1,2-tri chl oro 59 9,400+ 6.0 Ethane, 1,1,2,2-te trac hl oro 60 2,400+ 1.7 Ethane, hexachloro 61 540+ 19 Ethene, chloro 62 20 Ethene,1,1-dichloro 63 0.33 Ethene, trans-dichloro 64 11,600++ Ethene, trichloro 65 27 ro Ethene, ' te trachl oro 66 840+ 8 i Propane, 1,2-dichioro 67 5,700+ Propeae, 1,3-dichloro 68 224+. 87 Butadicne, hexachloro 69 9.3+ 4.47 Cyclopentadiene, hexachloro 70 5.2+ 206 V. ETilERS Ether, bis (chloromethyl) 71 0.000038* Ether, bis (2-chloroethyl) 72 0.3* Ether, his(2-chloraisopropyl) 73 34.7 Ether, 2-chloroethyl vinyl 74 Ether, 4-bromophenyl phenyl 75 122+ Ether, 4-chlorophenyl phenyl 76 122+ Dis (2-chloroethoxy) methane 77 122+ VI. MONOCYCLIC AROMATICS (EXCLUDING PilEN0LS, CRESOLS, PitTilALATES) Benzene 78 6.6* Benzene, chloro 79 0.0072* Denzene, 1,2-dichloro 80 763+ 400 Benzene, 1,3-dichl oro 81 763+ 400 I .-~

daf,:A 12::1 1::A Otc1 L:::1 tr.:k C3 1::Q T2li f/G C22 M M I".UH E:ZR EE2A Eak E n:. bT.;h TABLE 2-3 (CONTINUED) Priority Pollutant (pp) Priority Pollutant 24-ilr. Average Fresh-Name and Category Number Water Criteria iluman liealth Criterial VI. MONOCYCLIC AROMATICS (EXCLUDING Pi!ENOLS, CRESOLS, PilTilALATES) (CONTINUED) 3cnzene, 1,4-dichl oro 82 763+ 400 Denzene, 1,2,4-trichloro 83 0.0072* Benzene, hexachloro 84 0.00/2* Benzene, ethyl 85 1,400 Benzene, nitro 86 19,800 Toluene 87 14,300 Toluene, 2,4-dinitro 88 230+ 1.1* Toluenc, 2,6-dini tro 89 VII. PilEN0LS AND CRESOLS ~ 1 Phenol (s)## 90 2,560+ 3,500 Phenol, 2-chloro 91 2,000+ Phenol, 2,4-dichloro 92 365+ Phenol, 2,4,6-trichloro 93 970+ 12* Phenol, pentachloro# 94 3.2+ 1,010 Phenol, 2-nitro 95 150** Phenol, 4-nitro ,96 150** Phenol, 2,4-dinitro 97 70 Phenol, 2,4-dimethyi 98 2,120++. m-Cresol, p-chloro 99 o-Cresol, 4,6-dinitro 100 13.4 a i VIII. PilTilALATE ESTERS Phthal ate, di-n-methyl ## 101 3+ 313,000 Phthalate, di-n-ethyl ## 102 3+ 350,000 3++ 34,000 Phthalate, di-n-butyl ## 103 Phthalate, di-n-octyl ## 104 3+ Phthalate, bis (2-ethylhexyl)## 105 3 15,000 Phthalate, butyl benzi## 106 3+ i

TADLE,2-3 (CONTINUED) Priority Pollutant (pp) Priority Pollutant .24-ilr. Average Fresh Name and Category Number Water Criteria liuman lleal th Criterial IX. POLYCYCLIC AROMATICS HYDROCARBONS Acenaphthene 107 Acenaphthylene 520** 108 Anthracene 0.028* 109 Benzo (a) anthracene 110 0.028* Benzo (b) fluoranthenc 111 0.028* Benzo (k) fluoranthene 0.028* 112 Genzo (ght) perylene 0.028* 113 Benzo (a) pyrene 0.020* 114 Chrysene 0.028* 115 Dibenzo (a,n) anthracene 0.028* 116 7' Fluoranthene 0.028* 117 ~ Fluorene 42 118 Indeno (1,2,3-cd) pyrene 119 0.028* i Naphthalene 0.028* 120 620+ Phenanthrene 121 Pyrene 0.028* 122 0.028* X. NITROSAMINES AND OTilER NITROGEN-CONTAINING #0MPOUNDS Hitrosamine, dimethyl 123 Hitrosamine diphenyl 124 0.014* Hitrosamine, di-n-propyl 125 49* l Benzidine 126 Benzidine, 3,3-dichloro 127 0.0012* Ilydrazine,1,2-diphenyl 128 0.103* Acrylonitrile 0.422* 129 0.58* I i

C;L n=L ' 1st C1 C:2 C3 C Ei3 CD D G G M lii21 M M EiGi E22 ,C TABLE 2-3 (CONTINUED) Footnotes: A c(1.05 in (llardness) - 8.53) : Cd B e(1.08 in (llardness) + 3.48) : Cr C c(2.35 in (llardness) - 9.48). Pb D e(0.76 in (llardness) + 1.06). gj E c(1.72 in (llardness) - 6.52) : Ag

1. Exposure through ingestion of contaminated water and contaminated aquatlc organisms.
   1. The liuman Health Criteria value was used in the dilution study calculations in place of the lower 24-ilr.

N Average Fresh Water threshold value. 'd + Chronic threshold value. ++ Acute threshold value.

• Concentration which may result in a cancer risk of 10-5 over a lifetime.
  • Toxicity level to one species of algae.

9 1

16 Saucon Creek 17 Lehigh River between Saucon Creek and Delaware ~Ri ver ~

• Reaches include all tributaries, to the main stream described.

As shown in Fi gu re 3-2, 25 calculation points.were selected as locations for comparing calculated river concentrations,of the priority pollutants with the availabla ambient water quality cri-teria. The relationship between reaches and calculation points as well as relevant flow information is shown in Ta bl e 3-1. The dischargers located on Figure 3-1 are described in Table 3-2. As shown, a total of 88 discharges from 42 facilities in 27 SIC categories were included in the study. Facilities located in the area surveyed, but not included in the study because 1) the f acility is no longer a direct discharger; 2) no reliable data on discharge flow or f acility location is available; or 3) the NPDES permit is not currently ac ti ve, are shown in Tabl e 3-3. Calculated river concentrations of the priority pollutants thought to be discharged in the study area are shown in Table 3-4. Violations of the ambient water quality criteria are indicated in Table 3-4 by an asterisk, and summarized in Table 3-5. Note that the value for total hardness used to define the water quality cri-teria for cadmium, chromium, lead, nickel, and silver was 102 mg/l (mean total hardness from USGS station number 01452150 on the Le-high River from 1969 to 1970). As'shown, 52 of the priority pollutants were found to be dis __ charged in the study area. Draf t. water quality criteria were available for 48 of the pollutants, and 15 pollutants were found to violate the criteria in at least one location. Cal culated ri v-er concentrations exceeded the criteria for at least one constitu-ent at 20 calculation points for both low flow conditions and mean flow conditions except at calculation point Nos. 12, 13, 14, 16 and 17 where only low flow violations occurred. The violations shown in Table 3-5 are summarized as follows: Number of Violations Violation Cause Mean Flow Low Flow Industrial only ~,. F 40 60 Municipal only 7 31 Industrial or Municipal 31 47 Industrial plus Municipal 1 0 3-2

-~ ,Q-l-]. Thus, the. majority of violations for both mean and low flow condi- ~ j tions resul ted from i ndustrial only discharges. 1 i 8 p I i a i s 1 4 1 N r O 4 4

v.,

1 A s d E t Y

r-lw

2 i

I i i g-1 is 3-3 i .-__..~._ _ . ~ --... a

OW MOHggygg CREgg Q 6 REACH Q g 2 REACH @ 6D,upgascotA '"' " ~ G1 gEhCO LEGEND 3 h CALCULATION POINT h i { [ REACH NUMBER Q REACH 5 g t-- C

• r

1. cd*'

s d t@ v E poS'# Mg y a I I >g ~g j 9.,,, REACH @ h REACH @ h e n g% 1 2 REACH [h R g IC REACH 12 p' g g 3 h, O REACH h h @ ( i2 giver REACH @ yREACH@ f: LITTL$ LEUIgg G 6 REACHNo Q '] y REACH h I ($t6 nE l [ O REACH h p s3 g M L Figure 3-2. Allentown, PA diluti'on study area schematic. E $E 3-5

M M IC C M iC JG iM Q A C G M M Q Q C*&, M,% \\ IABLE 3-1. (CONTINUED) Reach Numbers Calculation Mean Flow Low Flow + Primary USGS Secondary USGS 12345678901234567 Point No. (cfs) (c fs) Gauging Sta. Gauging Sta. Resolution

• 017 240 40 01451500 01452000 M

XXXXX 018 2,410 350 01453000 01452500 M XXXXXXXXXXXX 019 2,419 355 01453000,' 01452500 A .XXXXXXXXXXXXX 020 52 12 01452500 A X 021 ,2,471 367 01453000 A XXXXXXXXXXXXXX 022 2,480 370 01453000 M XXXXXXXXXXXXXXX y 023 90 86 01454500 M X ~a 024 2,570 456 01453000 01454500 M XXXXXXXXXXXXXXXX 025 3,032 653 01454700 A XXXXXXXXXXXXXXXXX

• Flow Data Resolution:

A = Flow Equal to Nearby Station M = Flow Estimate from Adjacent Station (s) E = Flow Estimate from Model; Flow Unit Area, etc. + 7-day 10-year Low Flow 9 I

I e I 1 e e I k .Z. O e. Z ..l .O W 4 8 U l J<u E o g L1Z O. H <c: HZ W U 6 U e 3o .J A

• I oJ OZ O

N O O O O O O N O O O O O 0 O rd O P O O O O n O O O O O N O c: O O b e O O O O O O O O O O O O W W O O P3 N O O O M O O O 4 O O O O u 0 O O O O 43 n C3 O w O O O O O V C C b b b b b b k b E W u e o-e 43 v e*

• e

=

• e e a e e e e e e e e

o e e n OO OO 00 OO 00 OO OO OO OO OO 00 OO 00 co OO 00 .N 40 00 OO OO OO OO OO OO CO 00 40 CO 00 00 eO -N u O4 00 eO 00 00 OO 00 OO 00 oo ar O OO 00 00 Ov nn m JH .* C3 OW nn OO OO OO OO OO ar tD oO 43 0 -= d) O -= 0O rd 0-o rd .a <Z oO 20 on nw c o-O 60 oo 'v e en on en UC rd O CO OO "O dd dd dd ks o d-d 4d n' w' dd d4 && dd d4 dd Ad O' d dd a c. -4 o - is rd rd - ts -O r4 O C e 42 I Cou v g rO 9 r C V >Z 3 E L1 E O O cm I w< Z u r a W a 3 or =u

• = w O

J 3 O

== c Q c J

== c N C2 c: 3 E Z J

== E W 3 W Z uJ J 0.J J< W E O n. Z O u g tJ u I I: (J

• • J H

Li C O e tt g u= _J .J Z c3 O +- CO Z C W O W W d I W C. A 4 c3 O U U u J E Z U3 L9 N C. CE

== U

• • (J c'3 g

rd r3 o 4 S c3 ts O rd n e c 4 Ls g rd N N W rd rd rd n n r3 r3 O n r3 e w 3-23 ~

e s e e 1 e bZ O A 5 H d u U<u C W S. \\ 171 ZQ m H<cD -W = UZOu 3 OJ 16 3 OJ QZ O O O O O O O O O O O O O O O m O O O O O O O O O O N O O O O c O O O O O O .O O O O .5 O O O O W W O O O O O O O O O O O O O O O O H w O O O N O O O 43 O O O O O O c t: v 0 4

== N ED 4 O O O O. O O. W u O

== W O O O O O 1 w C3 v e O n O O (d n 60 no 00 nO C0 et No no e& ON -N 00 00 no 00 no .N n.0 n 0* n0 -a N 4 rd O.o bO 4 rd b rd = N. o d nn OO .O O n 0* OO n EP u n4 N -*

• O OO rd N OO ON N re a0 o r2 wO co N -*

OO rJ = m .J H O-O -= n4 OO O -= OO O -* O== b0 00 0O nn O4 0 -=== 0 0= y <Z 00 00 0 -* OO 00 00 00 00* 00 OQ C0 no On OO Ob 00 u se 00 00. 00. 00. 00. 00. 00. 00. 00. 0 -* Q* OO ON- 00. C8 O 00 00 .3 A C e 42 C W f I W O Z O O Z W u 5 tr c 8 O O -5 Z J V td 8 H I J J c td H Z I O td I ZO LJ O I I HZ W H O c 4 Z O w E E u u W4 O td tr O O U c H O O = = HZ c O O .J c N H A Y >Z tr .J tr tt i H O c J I O Z = O 3 H< O tJ H H rd W d_ O O td uW J to w W ZW c n .* H J u' i ta e ta .O J uw Z ~Z Z O Z -Z J O t-3 I <k -Z rd Z rJ c-u I <Z tg Cy uw .J w Cy O J OJ u tr Z .O u cr y e~ <w 3 eD 2 I (d -= J H F-

== I -=.J X HZ Z w2 xZ I .J .O _J td u d co c W tJ .H .H .I W c WH w .w to y H O .O I e EL A e >- E W a td -a u 2 H HW O -= c I cm W H NH A rd -a C3 g -= N O O -= n 4 O N e o N O p n n n n 4 4 4 4 h C o O O O P = e . S 3-24 )

e e e H .Z O' R. ZO eo k u I u tg W e A. (13 Z Q 1 b<c >= Z Wu .Z O u 3 O J 4 3 OJ Q Z O O O O O O O O O O O O O ea O O O O O O O O O O O O O c O O O O O O O O O O O cD 0 l 10 W O O O O O O O O O O O rd 0 1 O H O O O O O v O O O O O O O c ar$ N d d d d d d d d d d N W U 43 O N

== 0 0 0 0 N v j O O += 0 0 0 0 0 1 4

== N O O w n I n n O O > t I n nO NO S n 'O nO nO to N c3 N O rd OO OO OO .o CD -= b -= N - P. .N O C* -a== nn n? o D= v3 & N CP rd C= rd D* OO OO OO N== nn n9 O r3 J u rd -a rd O ON N -= N -= N -a -* n -O

== n D* O ON -= 0 0== 0 rd ON ON ^ JH O -* O -* OO O -= O -* 0 -a OO OO OO bo =0 0 5o oo OO OO OO 'O <Z OO OO OO OO OO OO OO OO OO 0== -- b N rd OO OO OO OO O O 0 b0 b bb bb b bb ' b bb 0 =< l 3 A l C .e 4J j I W m O O H I' U c W < J I O J B J l Z v Q J I O J =I I J l< J W W t.d cc I O Z 0J OO 1 1 JI Z J Z e O u c w I cc O c L1 'J J >H N W W - H J

• a O

Z O In H. W IW W >W >W I ZW I I I y >Z = c J n. W JW c J >- IH H >- > - > - >- c. W >- t-H 8 F- < u H I O r Ic Zu >< J< 3< u< W ca < = = Z

• • a-

.= J l J uJ c

== J uu== e

J

>J r2 J OJ I a J CL c. m-E3 OC -Q G <O H OO 4 i OO >- 4 I4 9 < t < rd J J< c OJ I Z .Z HZ 4 Z. I W% >- C Z; ZI >I Z Z O t4J

• • a vW vW ZW Z

vW cH 0H Eh WH I H aH C3 x F- - W W D I CC =I =Z W2 4 .I <W .C

== T -- % ** % ** ! * * *:J 3I U U J J z, a CL NA' rd c.

n. c.

rd rd o.

c. E eo O c.

O c. O c. O c,. c2 0

3 CL A

E N M v n C3 D* O -= rd O v n 0 5 c3 6 B' H D' D' D' D' D' D' O O O O. O O O. O O. -=. 3-25 \\ l.

b* .t to e u t. 't.t 'l.j ..,l 'D >4 is 4j i-t'< ? I 9 $,.b 'd lll 2 6 = 0 2 A /lD Z 0 e.e e k ( T N 1 U ls' g ~ L;, u 2 E g W d L g. s'. M I,- Z O y.

• d H

se c F: C r.. G IU U t'. g (l 0 U 3 O e . i m J l b. b ~ 3 O a V '1 O J Z O O O O

• =

0 0 0 O I. j c C3 O O O td W rd O N O t, a n O O O n $4 4 O. O O. m c: O U W U N p: 4 e ie' f I; n -* N Oe bo t .N n ("3 5 (M o rd n4 u oN -= C3 OO n 43 m .J H OO OO OO O== L <Z CO OO OO OO ( V U= g C O 00. 00. 00. 00. 3 L ') C t +J C~ O i U Id v J td M Z c: H td H V >- Z td .J g H< Z Z ~H ta Z td O O c' 3 c H Z .J O.J O Z W a-* J 3 c. c c w g s cO .J u -J

0. C.

h. Z L d I c O N b .=. s Cd Cd ee i 3-26 O

s m ~.. a a ( n n 6 a l i I I I 1 l L a i i I I I I i I m u I I 4 I I I 1 a lj l s^ a t 3 I I I 1 a l a 2 M M m 1 1 l l i l Y 1 1 I I I 1 a R z A a M M M M M M 0 i I / / M M M l I M M o I I / / 1 U S N m t M M M M N n / / / / O i 9 I I o I I I I I P T l n 2 A i 8 M M M M o 2 L t O a l I lu V c 7 i I l M M M 2 l / / / I a t l A C ll C R M M M E 6 i I i / / / I 1 I I T 2 I j{I M M M M R 5 i I / I I / I i C C I / M M / 1 A l l I M M M P 4 I I i / / / 3 I I 1 t N M W 3 I I M M / O l t G T N l C E 2 I I I / / M M M / 1 M M M M M M L l I I / L A l l;4 1 I I M M M T - L 5 w _ 2 3 l o w o w o w o w o w o w w w w w w w w w w w w w w w _ 1, E F l Fl o i o l o l o lo w o w o w o w o w o w o w o w o w o w

C F

l o o l o l o l o l o l o l o l o l o o m F F Fl F l F l F l F l F l F l F l e l F l F l F l F l l F L a n n n n n n n n n n n n n n n F F F F F F F F F F F F o a w a w a w a w a w a w a w a w a w o w a w a w a w a w a w B r o o o o o o o o o o o o o o o o o o o o o o o o o o o o o o u A t M L M L M L M L M L M L M L M L M L M L M L M L M L M L M L T S C. M. t o n a n a x o t o h ly u o l m n h l a u s m 8 t o o N c l m o y u 4 o h n U n ly i r

• d r

l r i 2 n o p o 2 P i i u y o m p i u e e l c z o o 1 o a r c A B C C C L M ic i h i C o 'gn n d c k v l . L. i r e a o y o o l a n G n o t t s r d p a a r , c N S T Z P D 'c A Fi lo e l ll M P 3 5 6 0 9 0 1 2 4 5 6 1 4 6 8 o 2 2 2 2 2 3 3 3 3 3 3 4 0 1 1 0 1 N M Y]

~.. l! 1 (l [! lI . i lI l 4 l l l l 'l I ~ ~. li l l 1 l l l l 1 m' i t l l l l ll b r P e l l l l l l l I t M M M 1 I 1 / / l / I I i I M M H o I I/ I I 1 / M n 5 I I 1 l / / I 2 1 P l lI l \\I Ii } l I a n M M Io 4 I I t l / / I M M M M M M M w t I I / l / i / / / 1 / i / I i 2 t f I I I I I a t l lI l u M M M M M M M M M M M M M M c 3 / I 1 I / / I I I I I / I 1 l 2 1 I / I / / / 1 I / / / / / 1 l 1 l / I a I C w l l I ll l l l l l( l } I l l l l! I I + 1 M M M M M {l \\ M M M 4 2 r 2 1 I t 1 / / / 1 / i / I I I M I I I / / / v l l l I l { } I ll ll \\l l l ll l M l M M 1 I 1 / / M M M I / M M l 2 I 8 / l r l 1 l l l l l l l l M M 0 / r 2 I I/ I i M M m l l l l l l M M M M l l r 9 I 1 / l M M M / l M M 1 I / / 4 a I ll l {!\\ { l M M l l l ll l ll M M n 8 I i m 1 / M M M / / M N / y I I l 1 { l l ll 1 l l l l ) l ( l l l ll 7 1 1 l f i 1 I lll l } l 1 l l I ll l 1 l 1 I l I l I I l l l l I w o w w w w w w w w w o w 1 o w n w o s w w w w w w F l o i o l o w o w m F Fi F io l o l o lo w o w o w o> o l o lo w o w o w o w o w y o F l F F l F l F l Fl o l o o r F F F F f F Fl F l F l Fl o l o l o l o l F l F l F l F l F l a n n n n n n n n n n n n n a w a w F F F F F F ) e a w a w a w a < n n a w a w a w a w a w a w o w a w a o o a o d r o o a o o o a o o o o o o o o o h l M L M L M l M L M L M l t M L M L M L M L M L M L M L M L o o o o o o o o o e S u t n i l lh [I ll l s ,m tn t o n o C a a n t x o i a u s h ( u o e l m m h y l o N i l u r d r t r l 2 n o p o n 8 t o c i m o y u 5 P 4 e h n n o y o ly l p i u e e l 1 o r a r a n d c k v i c z o n o t s r d p a a r 3 i r o a o y o o i i h i C o r A D C C C L M lc l a n D n lh c i o t E o t S T Z P B c A F L f r ] 3 5 6 8 9 0 1 2 4 5 6 B P A b 2 2 2 2 2 3 3 3 3 3 3 1 4 6 8 t 4 8 0 1 T 1 1 yN m

. - - - -... ~ _ -. -. - l l l j, E i i k '4 ~ i Legond I-Indicates criterla excoedod duo to Indtastrial dischargos M-Indicatos celteria excoodM duo io municipal (POTW) discharDos 1+H - Indicatos critoria excoodod the combined offect of Industrial and municipal discharges 1/M - indicates celtoria excooded by the suri of Industrial and mualcipal discharges. In addition, either Industrial or municipal dis-charges alone would excoed the criteria. O 9 9 e e 4 O 8 N Q / e e G G e e e-

a. d,, h SECTION 4 REFERENCES 8 1. U.S. Bureau of the Census. Water Use in Manufacturing, MC 72 (SR)-4. U.S. Government Printing Office, Washington, D.C., 1975. 2. U.S. Environmental Protection Agency, Water Quality Conditions in Major Toxic Chemical Production Areas, unpublished report. Washington, D.C., October 11,, 1977. di 3.

Strier, M.

P. Treatability of Organic P oll u ta n ts- -P a rt D: IQ The Pesticides-Their Estimated ( 30-day 'a vera ge) Treated Efflu-ent Concentration, unpublished report. U.S. Environmental Protection Agency, Washington, D.C., December 26, 1978. 9 p. 4.

Strier, M.

P. Hea vy Me tal s in Wastewater. Presented at the National Association of Corrosion Engineers Regional Meeting, h Newport, RI, October 2-4, 1978. 18 p. S.

Strier, M.

P. Treatability of~Grganic Priority Pollutants-- p.1 Part C: Their Estimated (30-day ~avera ge) Treated Ef fl uent U Concentrations-by means of a molecular engineering approach. U.S. En vironmen tal Protec tion ' Agency, Washington, D.C., July 4 11, 1978. 32 p. d E (- s e <0 p l' 4-1 ,c il e

i, I I I-t 4 i PLANNING AID REPORT 'Ihe Sensitivity of the Delaware Estuarine Ecosystem to Alteration of the Natural Cycle of Salinity Change J } t Prepared for i U.S. Army Corps of Engineers ? Philadelphia District u , Prepared by U.S. Department of the Interior Fish and Wildlife Service i July 1981 t Preparer: llichael T. Chezik Project Leader: Charles J. Kulp s ') D-58 CTlC '

11 s 1 E. Synopsis cLf Salinity Effects on the Ecosystem with Emphasis on the Oligo-mesobaline Reach I ' The infctmation we have reviewed shows that salinity exerts strong influence on the Delaware estuarine ecosystem. Briefly,-it influences the distribution of marsh plants, benthic invertebrates, fishes and certain wildlife. Rela-tively few aquatic species are tolerant of the entire salinity gradient from fresh, water to salt water. Most species occupy portions of the gradient beyond which survival is threatened. Salinity affects seed germination and growth of marsh plants; oyster drill predation and probably MSX disease in the oyster seed beds; movement of blue crab larvae; location of blue crab spawning, nursery and mating grounds; movement of fish eggs and larvae; location of spawning, nursery and feeding, grounds of fishes; muskrat produc-tion; and, waterfowl feeding and resting g' rounds. The overall effect of the salinity gradient is to create numerous niches, fostering wide ecologic diversity and high productivity. Literally hundreds of plant and animal species, some with populations numbering in the many thousands, utilize the Delaware estuary. The salinity gradient is broadest in the Jower river and upper bay or the-oligo-mesobaline zone (Daiber and Smith, '1972; Tchthyological Associates, 1980). The dynamic nature of salinity and other physiochemical factors in this 45 mile reach results in a variable and decanding environcent.

However, these f actors also create an abundance of food resources attractive to species tolerant of the salinity fluctuations.

Tidal f7"ctuations enhance productivity by supplying food, nutrients and oxygen. Additionally, vertical mixing recycles and traps nutrients, sediments, detritus and planktonic. organisms. The adjoining marshland also contributes to the food base (Ich thyological Associates, ~1980). This highly productive brackish reach is important to shellfish and fishery resources. Oysters thrive in it partly because of protection against preda-tion by oyster drills. Blue crabs mate there'and young, after a period of carly development in downbay areas, int,o' the. region to na ture. Atlantic move menhaden, weakfish, striped bass, white perch, bluefish, summer flounder, American cel, white catfish, carp, Atlantic silverside, bay anchovy, mummi-chog and spot use these waters for early growth. Resides offering food to these species, the regi'on also' offers protection from predators incapable of tolerating the salinity regime. Also, higher water tempera ture during spring and summer probably results in faster growth (Ichth951ogical Associates, 1980). Euryhaline organisms occupying this reach have a distinct advantage over stenohaline types. Not only can they tolerate wide salinity variation, but they use this ability to maintain their populations. In summary ? the salinity characteristics of th!sJreach favor an abundant food supply, prot,ection from predation and early growth. These functions are important in maintaining populations of valuable commercial and recreational species. s IV. Potential Ef fags of Altering the Salinity Regime on the Delaware E_cosystem As we have previously noted, the zones of salinity shown in Figure 1 are displaced in different directions depending mainly on freshwater outflow and

) ~i ~ 23 1 h \\ It may be possible to benefit from low flow augmentation without reducing spring flows. Our study did not uncover evidence indicating a salinity increase in winter would be harmful to the ecosystem. Perhaps sufficient volumes of water could be stored during winter to limit salinity intrusion. This report only addresses changes in the salinity regime. Water circulation, turbidity, water quality, temperature, sedimentation, scouring and nutrient loading may also be af fected by altering runoff patterns. These factors should be assessed in other sttdies. Uc would particularly like to see a study of circulation patterns and the effects of changes on fish and benthic invertebrate egg and larval movements. In view of these findings, the Service recommends that reducing freshwater outflow in spring be avoided, and if it can' t be avoided, be minimized to protect and maintain the health of the Delaware estuarine ecosystem. O t e N.

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U 2. W t r Qusltty Camdsn)araa. Ultimate standards of 6.0 sg/l end 5.0 cg/l q a. Prrbl m Strt m m t b The new water quality model for the Estuary is being used to Philadelphia, Camden and Trenton are major Estuary dischargers estimate the dissolved oxygen levels which can be achieved which have not met the treatment levels required under the under present and increased degrees of pollutant reduction. National Pollutant Discharge Elimination System and the The model will consider both dry-weather and storm conditions, Commission vaste load a!!ocations. No management options nitrogenous so well as carbonaceous oxygen demand, and the g are included for this problem statement, since the cases are ef fects of tributary wasteloads and accumulated sediment being handled on an_ individual basis. Compliance is expected deposits. 9 by the mid-1980's. Concurrent with the determination of a. feasible dissolved Dissolved oxygen standards in the central portion of the oxygen " target", the most cost-effective mix of measures Delaware Estuary do not aantatte the ff.sheries potential of must be determined to reduce oxygen-demanding wasteloads the Delaware River, af f ecting the Es tuary. These loads, as implied above. include municipal and industrial discharges, ccabined sewer increased coordination anung water quality planning programs overflows and other storm runof f, tributaries as well as the would improve their effectiveness. main stem Delaware River as it enters the cidal reaches, and bottom deposits. With decreased discharge loads because of There is increasing concern about the possible threat of the DRBC wasteload allocations program and the requirements j, toute substances in the surface and ground waters of the of the Clean Water Act, the non-point sources become relatively 8asin. more important. Treating (Nse sources may be less costly than increasing treatment levels for point source dischargers. b. Water Quality in the Delaware Estuary Mcwever, much detailed analysis remains to be done to determine c The dissolved oxygen standards chosen for Zones 3, 4, and best management practices for non-point pollution sources. part of 5 of the Delaware Estuary are less than. the usual Non-point source treatment will be compared to additional point source treatment before resorting to additional point criteria for " fishable" waters under the Clean Water Act. source treatment. These standards were accepted by EPA in 1973 as the highest ( feasible under treatment, requirements then considered y realistic. The development of a new, more sophisticated Figure 12 shows computed dissolved oxygen (DO) profiles along the tidal Delaware River f rom Trenton to Liston mathematical model for water quality in the Estuary provides Point, for low-water slack tide, under dif ferent levels of the opportunity to reexamine the existing standards, flow regulation. These D0 curves were determined witn the one-dimensional version of DU C's current water-quality This reexamination has several aspects. First, an ad hoc Task Force.to Evaluate Dissolved Oxygen Requirements of model of the Estuary. The model simulations indicate that Indigenous Estuary Fish was appointed by the DRSC. The Task increasing the Trenton flow from 2,000 cfs to 3,475 cfs Force was established to provide fisheries expertise and would cause a DO increase of 0.13 mg/l at river-mi.le 98, on the downelope of the DO " sag", and 0.08 mg/l at the bottom guidance to both Level 8 and to DRBC's program now under way of the sag. Seaward of the critical sag point, as water to reevaluate its current wasteload allocations. A deterninstion was needed of the amount of fisheries resource in the Estuary quality improves with distance. D0 levels tend to be slightly which would satisfy the " fishable" goal, and the dissolved lower at higher flows. Flow changes have a significant impact on DO in Zone 2. from Trenton to about mile 113 oxygen levels required to attain the goal. The Task Force where D0 increases of a ag/l or more may result. The effects five times between September 1978 and January 1979. The ~ met final recommendations' (DRBC, Ad-Huc, Task Force March 1979) shown should be taken as relative rather than absolute, of the Task Force included two sets of recomunended dissolved since the sensitivity of the model results to changes in oxygen standards. For insiediate consideration was a set of waste loads has not been fully tested. standards recosonending an Estuary-wide minimum dissolved naysen standard of not less than 5.0 mg/l except in the critical reach of the Estuary where a minimum of 4.0 mg/l was deemed acceptable. n e critical reach represents the area of greatest dissolved oxygen deficit in the Philadelphia- [ \\ 26 ~. i ~

C gy m ~- Other wat:r grlity isru;2 la ths Estuiry includz thirmal cuch isture era clos liksly to b2 csstly. In this esntsat 1 tads and thi thract of c2ntnin:tisn with taxic substencss. ETA,has bun sicw to specify B2st ManttemInt Practices to m Th2 cd hoc Tssk Forca, while 41rscting its ef fort to dissolvgd servs as guide 11nsa for local man:gezent. Yet in many areas. czygin, egrssd a th212portance of th2sa facters for an non-point rourcs probleas should be resolved before poinc u improved fishery in the Estuary. 'the new Estuary model vill source controls are impused. explore the reistionship between temperature and dissolved oxygen levels at critical periods. It is not designed to In urban areas, af ter currently required treatment levels ? q evaluate the problem of contamination of the Estuary waters have been schieved, trade-offs must be considered between with trace quantities of toxic substances. These are addressed higher degrees of waste treatment and treatment of combined later in this section. sewer overflows or storm flows. Such stormwater management measures may prove to be less costly for Philadelphie and 9 The new model will be used to investigste point and non-other metropolitan areas in the fiasin than tertiary sewage i point source controle for various dissolved oxygen criteria treatment for the same degree of stres s improvement, u for a range of low-flow conditions consistent with the various flow maintenance objectives at Trenton. In suburban and developing areas, facilities planning for the last decade has focused e i local or regional sewage In Zone 2, the upper portion of the Estuary, more detailed treatment facilities large enough to handle anticipated w investigations of water quality issues are needed (1) the increases in loads. At the same time, suburban growth has ef f ect of bottom deposits on water quality should be examined, proceeded on the implicit assumption nat sewers would (2) water quality characteristics of the River as it enters follow. In many cases. housinC patterns have been too dense { the zone should be monitored, and (3) the effects of flow to allow continued use of traditional onsite systems, and 0 . changes (which are sore significant here than for the lower 'too scattered to allow sewering at a reasonable cost. The Estuary mones) should be evaluated. Zone 2 is impacted by result has been an expensive network of sewers feeding a drainage from 60 percent of the Delaware River Basin. The regional plant, with Probicas of diminished streamflow and background carbonaceous and nitrogenous loads carried by the depleted ground water in the areas served. Delaware River as it enters the Istuary at Trenton are issnense. Studies have demonstrated that loads entering t6.a Several completed "20S" reports take such problems into Estuary f rom the non-tidal river are predominately from non-account. In particular, proposals have been made to achieve point sources of pollution, suggesting that a truly interstate conservation by maintenance of onsite systems wherever I impact is being thrust upon Zone 2. A proposed Study by possible, and to plan at a community level for land application If DRBC would deterulne practical methods of removing the of waste. Unjer the federal Clean Vater Act, land application ef fects of organic loads from the River and distributing the measures are to receive a high level of consiferation, cost of the solution equitably to the contributing areas. ~ P ~ ~ - ~" ~ ~ "~~ Ne~s A variety of state, county, and local ordinances apply to Other Water Quality Management Is c. sedtment and erosion control and storm runoff in developing areas, some with the goal of accelerating rather than pre-s The consequences of a lowered flow maintenance objective for venting runoff. Stormwater management policies or reguia-the River above Trenton may also need to be explored. A tions normally have consequences for flood control and 'p water-quality model is available for this analysis for thJs conservation as well as water quality, and planning must C section of the River. consider all these purposes together. d. Overall Water Quality Manastement and Improvement In rural areas. land treatment and other measures carried P out under the programs of the Soil Conservation Districts r Non-point source problems and the measures to mitigate them have been directed primarily at reducing erosion and sedimen-can t s conveniently divided according to the types of lanJ tation and improving farm productivity. uses involved: urban areas, subur. ban / developing arens, and rural or predominantly agricultural lands. To varying The West Branch of the Delaware River above Cannonsville l P degrees, for each of these categories only limited information Reservoir was chosen by the New York Department of Environmental L to available on specific causes of observed water-quality Conservation for analysis by the Soil Conservation Service. problems and the effectiveness of potential management Management practices were identified which appear both to be measures, which may be costly and difficult to enforce. The acceptable to landowners and to shuw.proenise in mittenting f detatied investigations which may be required to revolve water-quality problems. Implementation of many of these { r I i. 28 9 e k

Y d? r SUGA RM AN & DCNWO RTH t w ei t a c's A110R N EYS AT L AW ' Ft O!)[ R T J. 5UG AR M AN. s ue t t s eo. =ou t u Au g s.C AN postoews sicae sat aaeo JOANNC R.OCNWORTH 121 SOUTH DHOAD S1 HC ET PHILAOCLf'. ; A,PCN NSYLVANIA 89107 (215) L 4 G-0 0 62 ~ pouCRT RAYMCN D CLLIOli, P. C.* COUNSCL ...,....to..m August'3, 1982 Mr. Jordan Tannenbaum Advisory Council on Historic Preservation Chief, Eastern Division of Project Review 1522 K Street NW Washington, D.C. 20005

Dear Mr. Tannenbaum:

These comments are filed by Del-AWARE Unlimited on the proposed memorandum of agreement between the Advisory Council, NWRA, and Pennsylvania S IIP O, concerning the proposed construc-tion of the Point Pleasant intake, in and through the Pennsyl-vania Canal (Delaware Division), a National Historic Landmark, the Point Picasant eligible Historic District, and the very significant and critical archeological sites in the vicinity of both of_those designated or eligible places. The Del-AWARE also adopts and reaffirms the comments of the Bucks County conservancy, contained in their letter to you - dated July 21, 1982. The expertise and objective approach of the Bucks County Conservancy, in addition to its authoritative role as spokesman for conservation of major el'ements of his-toric value in Bucks County, is illustrated by the quality of its Icadership, including its chairman, the Honorable Hart Rufe, a Judge of the Bucks County Court of Common Pleas. The Conservance therefore speaks not only to the technical issues addressed in their comments, but also to the importance that they hold for the community. Del-AWARE wishes to address the interrelationship between the fish and wildlife issues, which have been raised and are under consideration by Fish and Wildlife Service and-the Pennsylvania Fish Commission, and the historic issues addressed in the Memorandum of Agreement, in terms of the impact of the project on the values thus represented. Point Pleasant is a extremely important site for the ancient Delaware River civilization. The Delaware River valley at Point Pleasant, was inhabited by prehistoric natives as long 1

r. c ago.as the time of Christ, and has been a center of human activity related to to river culture periodically since that time. In the fourteenth through eighteenth centuries, the historic age Indians centered at Point Pleasant as a fishing and trading location. The abundance of food and water suppor-ted an intensive industrial civilization related to the river, which produced blades and other trade items, and because of its access both by water and by land, Point Pleasant served as a trading conter as far west as Lancaster, Pennsylvania, and upstream and downstream along the Delaware River. The English settlers were not long in realizing the value of Point Pleasant, and succceded the Indians at an early time in English settlement. Among the first activities established by the English settlers was a commercial fishing venture, and among the early following activities was as ferry across the Delaware River. The construction of. Ferry Road along the old Indian trails to the west followed, and Point PJeasant as an English settlement succeeded the Indian settlement. However, the early settlers respected their Indian prede-cessors, and at least several Indian sites remain essentially

intact, having been explored by IIen ry Mercer in the late nineteenth century, but otherwise undisturbed until the present time.

Among the most inportant of these sites, if not the most important, is the area which is now the proposed location for the intake conduit for the proposed water diversion. As the English settlement grew, it quickly became a center for logging activity, because of the eddy. Thus, Black Eddy has served as a major historic center of human activity because of its abundance of fish, its lack of currents (making it suitable for fording), and its ponding characteristics, making it suitable as a resting place for loggers coming downstream. As a result of these converging factors, the Mountainside Inn was developed at Point Pleasant as a major center of river commercia1 activity. Likewisa, when the Pennsylvania Canal (Delaware Divisien) war constructed in the 1820's, Point Pleasant became a major stopping place along the canal, both because of its preexisting facilities, its convenience as a crossing of the river, and the locks which were naturally related to the eddy (the fall off in the river at Point Pleasant). Similarly, in its turn the canal gave rise to a further but limited growth of activities related to the canal and to the river as a commercial center. This kind of village activity related to the water and the land surrounding it, has been preserved throughout the twenti-eth century as a result of the passage of commercial activities 2 2

r~ e' e to other areas more suited to the large scale water and land activities of the twentieth century. For this reason, and because of the earlier prosperity associated with it, and of the quality of buildings and facilities constructed,. Point Pleasant has remained intact and represents a major National resource for appreciation of the periodic return of human civilization to river roots. Although some of the foregoing is reflected in the Memo-randum of Agreement and the underlying work, the underlying historic documentation prepared by consultants and the Corps' case report also reflects a systematic understatement of the significance of the historic elements and a total failure to interrelate these significant areas of importance, and there-fore ' completely fails to present the historic meaning and significance of Point Pleasant. Similarl the draft MOA and Case Reports show a ' clear failure to appreciate the harm that would be caused to the Landmark and the surrounding historic areas of significance by the proposed project. The project would unavoidably alter the present natural historical character of the - Landmark in the vicinity of the

project, destroy the visual and historic in'tegrity of the area surrounding the canal and especially related to the Mountainside Inn, which is part of the Landmark designation, and through its destruction of the hillside and the natural run of Hickory Run, as well as the natural charac-ter of the foliage on the hillside, unavoidable and permanently irreparably damage the overall ambience of the historic area.

The MOA does not reflect this, and indeed once admitting the project into the area, cannot reflect this. r .In these circumstances, it is most unfortunate and of greatest concern to Del-AWARE that despite the provisions of Section 110f of the National Historic Act Amendments of 1980, no effort has been made to plan or act to adopt practicable measures and actions to minimize injury to the-Landmark. Alternatives to the project are readily ava i l'able, and while they were rejected by the applicant, the Delaware River Basin Commission and by Philadelphia Electric Company prior to the Landmark and distinct determinations enactment of Section 110f, they have not been evaluated either in the light of the passage of Section 110f, which mandates a more rigid comparison of alternatives weighted to minimize harm to the Landmark, nor have they been evaluated in light of the significant changes in - the project proposal, including substantial increases in the amount of blasting, implemented in 1981 and

1982, and the resolution to terminate Unit 2

of the Limerick Generating Station, a major justification for the project, adppted in May, 1982 by the Pennsylvania Public Utility Commission. In this connection, Del-ANARE Unlimited has repeatedly 3

7..

A^ .i sought the opportunity t.o discuss some mitigation alternatives under Section 110f with the applicant and Philadelphia Electric Company, but -bas never been given the opportunity to do so. It is especially untimely that a mon be entered into at this time, in view of the recent ' decision by' the Nuclear Regulatory Commission to examine alternatives to Point Pleasant for the first time, in connection with their operating licence pro-ceeding for the Limerick Generation Station. (Previously, the Nuclear Regulatory Commission had assumed the construction of Point Picasant as a portion of NHRA activities, and therefore had not considered the existence or not of Point Pleasant as an option in evaluating Limerick, and had passed no judgment on it. The NRC will now, presumably, make a finding under Section 110f in connection with the operating licence proceeding, or a pending request by Del-AWAPE to reconsider and to amend the construction permits for Limerick in light of the present situation, in which the Point Pleasant pumping station would not be constructed without the-financial participation of Philadelphia Electric Company.) Enclosed are discussions of available alternatives presen-ted by NURA and PECo, respectively, in their 1979 Environmental Reports. As you can see, nowhere in these reports is there a statement that the utilization of these alternatives is not a practicable measure which will minimize harm to the Landmark. Therefore, Del-AWARE Unlimited requests that the MOA be revised to require that, prior to execution, the Corps conduct a full investigation of alternatives, in light of the signif-icanca of the area and the impact, as described above, and take every action possible to minimize harm to the Landmark, pursu-ant to.Section 110f of the National Historic Preservation d Amendments of 1980. Such action by the Corps should be then submitted to the Advisory Council for comment pursuant to Section 110f, and the Advisory Council given a full opportunity to comment on the Corps' proposed undertaking, as required by that section. We do understand that the Advisory Council is amending the proposed MOA to include a representation by the Corps that it has complied with Section 110f, and while we view this as a critical step forward,, in that it will require the Corps to

consider, itself, whether it has so complied, it does not discharge the Corps' responsibility under Section 110f, nor does it discharge the Council's responsibility to afford comment to the Corps on such compliance.

We look forward to the opportunity to cooperate with the Council in further development of its cooperation with the Corps, and we particularly welcome the Council's assurance that we will, at our request, be included inh meetings to be held with the Corps. 4 i

T~ ~ We further understand that the Department of Interior, National Park Service, _is being afforded an opportunity to comment on the draft MOA and the undertaking, and we look forward to - the opportunity-to consul,t with the Park Service before they have finalized their ' comments, and will be communicating with them in that regard. With renewed appreciation'for the opportunity to comment, Sincerely, f .i Robert J. S garman Encls. bec: Ms. Loretta Newman i Ms. Kathy Auerbach Ms. Virginia Forrest Ms. Virginia Ilutton d Mr. Paul Pritchard Aubra Anthony, Esquire Ms. Colleen Wells Mr. Val Sigstedt b l I o } I 5

'% )' --r,.D' BEFORE'THE DELAWARE RIVER BASIN COMMISSION ) IN RE: NES!!AMINY WATER RESOURCES ) Docket No. D-65-76-CP AUTilORITY AND PHILADELPHIA ) . ELECTRIC COMPANY'S WITHDRAWAL FROM ) Docket No. D-69-210-CP THE DELAWARE RIVER AT POINT ) PLEASANT. ) Docket No. D-79-52-CP ) AMENDED PETITION TO REOPEN AND FOR RECONSIDERATION AND, TO SET ASIDE PRIOR ORDERS, AND TO TAKE OTHER ACTION AS APPROPRIATE Del-AWARE, Unlimited, Inc., Val

Sigstedt, Honorable Rita

Banning, Limerick Ecology

Action, Delaware Water Emergency Group, Phyllis Zitzer, Richard McNutt, Mary Ellen.

Noble, C. J. Gilmore, Anne P. Carney, Judy Zipkin, Jane and Falton Gross, Lee'Goldberg, Carla Van Dyk and Michelle and Graham Kinsman, by their attorneys, petition this Honorable CorrJnission to reopen and set aside its Orders in the within proceedings, pursuant to sections 3.8, 13.1 and 15.1 (s) 1 of the Compact and Sections 2-1.4, 2-1.7, 2-4.16 of the Rules, and the Administrative Procedure Act, 5 U.S.C. $701 I et seq., and to further revise the Comprehensive. P]an pursuant to Section 13.1 thereof, and aver as the basis thereof the following: 1. On February 18,

1981, this Commission granted

" final" approval, under section 3.8 of the Compact and to the inclusion in the Comprehensive Plan, of the proposed J

ty.- Neshaminy Water Resources Authority ~ and Philadelphia E}cctric Company withdrawals, as ' modified, via an' intake at Point Pleasant, Pennsylvania, of-95.mgd, subject to certain L understandings, c~onditions, and limitations. 2. All or most-of ' the Petitioners were objectors regarding the foregoing Orders. 3. ~No construction has been initiated in reliance'on ~ the above-mentioned Orders. 4. Reconsideration, reopening, and recission is war-ranted and necessary in the public interest for the follow-ing reasons, all of which have come into existence and/or been newly recognized since February 18, 1981, and all of which represent significant adverse environmental impacts not previously considered. A. The Commission's acceptance of the Level B Study, and the issuance of - draf t Recommendations of the Parties w regarding Interstate -Basin Management, and

Background

Report, issued in July, 1982, reflect a recognition of.the l l inability of the Delaware River Basin to reliably sustain the proposed withdrawal without unacceptable adverse effects on the water quality and water use needs of the Basin. The ~ Level B Study and the Recommendations specifically acknow ' ledge that the proposed withdrawal will further expand depletive withdrawals beyond the capacity of Basin supplies to ' prevent salinity contamination, and to insure against-excessive dissolved oxygen sags in drought and severe drought conditions, in violation of the present-salinity and i l L-

dissolved oxygen standards, in the absence of substantial additional storage capacity.

Thus, when joined with existing uses, there is not adequate water to support the proposed use.

In these' circumstances,. Commission must rescind the above-mentioned Orders. B. There is no present or forseeable-likelihood that the new offsetting storage proposed in the Level B Study and Redommendations can and will be provided in full, or at' least, there is no commitment to do so, and prerequisite environmental reviews are not yet completed, thus legally precluding a present decision. Moreover, the Commission's . environmental studies of Merrill Creek show that withdrawals for storage would exacerbate present inability to reliably meet salinity standards. Other proposed storage projects have not been studied and/or present similar or other problems. Implementation of the proposed Point Pleasant withdrawals in the absence of a determination of ~ approvability and feasibility of the necessary replacement or additional storage, would practically preclude the no build option, which must be preserved in order to make meaningful environmental decisions regarding the proposed replacement and additional storage. C. The proposed depletive use for Limerick Unit 2 is not a beneficial use of the waters. The decision of the Pennsylvania Public Utility Commission at Docket flo. 180100431, on August 27,

1982, represents a decision by Pennsylvania that present or near-term construction of

is not in the public interest. This finding Limerick Unit requires recission or. suspension of the Order with regard to 23 mgd for Unit 1, and implementation of an alternative available to supply the needs for cooling Unit 1, which would not further harm the Delaware River, including (a) placing the already constructed cooling towers in series, ~ (b) providing alternative storage in the-Schuylkill River Basin, deemed less desirable.for two units, but more desir-able than Point Pleasant for one unit, and which might be directed by this Commission in the public interest, (c) utilizing storage available at the Blue Marsh Reservior, and (d) utilizing other potential local sources of supply in'the -schuylkill ' River Basin, directly or-indirectly under the control of this Commission. D. Relevant agencies have identified an adverse im-pact on a National Historic Landmark and on very significant .~ archeological sites, which might require, pursuant to pro-cedures set forth by the Advisory Council on Historic Pre-servation, in situ preservation of the archeological finds as a result of preproject test digging and studies or. entail loss of significant unique resources. E. Contrary to expectation, it is now clear that in its present location, the intake will adversely affect Lower Black's Eddy, a spawning and nursery area, and an important shore fishing area, through the creation of turbidity and through entrainment and impingment, thus destroying a 4_ J

i. t significant habitat for American shad, a major species, and other' species. ~V F. The National Marine Fisheries Service has idbnti- 'E fied the probable presence of a habitat for shortnose

sturgeon, an endangered

species, in the nursery and/or spawning. stages, rendering the

• subject to injury by the

~ project, and recommended further studies to determine such effects. While NMFS believed that the intake design would limit

exposure, its finding' was based in' part on the.

erroneous information supplied to it that the intake would A s not operate at maximum velocity when river flows are Icweg N 4~ ~. ~ than 3,000 cfs (Tre.. ton). J z G. Philadelphia Electric _ Company has identifie'd 4 w TCE's, and the Environmental Protection Agency has identi " fled significant amounts of other toxic faa crials, in the Delaware River from the Lehigh confluence ^do'ns'tream, and w including Point Pleasant, which would' adversely impact the 3 Perkiomen and Neshaminy Creeks, and cause toxicity in th'ose s u creeks and the groundwater aciuifers, since the Perkiomen is a recharge stream in some reaches. H. The NWRA use is not a beneficial use in that (1) Local suppliers in Warminster and Warrington no longer need Delaware River water because thewaterqualig Pennsylvania DER has determined that s in their local wells is suitable for human consumption as a result of treatment. i O r 5m a (2) Contrary to previous information, this Commission's ground water study has. established the availability of -adequate new groundwater. sources in local aquifers t to ' supply Bucks and Montgomery County needs. s_, A J3); Use of these resources would add to rather than deplete river flows, and thus aid in meeti69 water quality and use objectives. x (4) The. dedication of Lake Nockamixon for drought v flow augmentation in tlie River makes it no longer ubb Lake Nockimixon for drought flow detrimentalL: to 3 y augmentation of local water supply rather than of the v Delaware Riv< .itrary to the situation in 1980. 'I. The Merrill Creek draft EIS regards the Merrill Creek Project as a necessary element of the Point Pleasant b 4 diversion to offset th'c adverse effect' of PPD on salinity levels. n J. The approvals should be reopened and reconsidered 4;. s as a result of the individualrand cumulative impact of all' of these,f&ctors, which require a finding that the s withdrawal is not a'benebicial use of the water, x that there a N is not adequatei water available to permit them, and that 3 ~ i \\ less' consumptive alternatives are available in light of the s changing economic and water 'needs within tfie Delaware River ~ ,s } z Basin, and thi's Commission's concern over the cumulative effect of depletive withdrawals,in the Delaware River Basin. s s ,g ,_p. '. s + ll x

a. \\ o u 5. In its 1981 decisions, expressly and in subsequent correspondenco, this Commission made it clear that it was 3 caving resolution of matters relating to historic impacts and local offects of the intake on fish to the U.S. Army Corps of Engineers and NMPS.

Thus, the 1981 decisions themselves require reconsideration and reevaluation in light of the present ' state ~of the record on those matters, as described in paragraph 4.

6. In its 1981 PECO decisions, this Commission or.at least its federal member deferred final determination of the Limerick withdrawal, including determination of the environmental issues related

thereto, to the Nuclear Regulatory Commission.

The United States District Court expressed a similar expectation in DELWEG vs..HANSLER. In that the Point Pleasant diversion is no longer financially viabic without the Limerick sub r,id ie s, the Nuclear Regulatory Commission has recognized the need to evaluate certain environmental impacts of the diversion in more depth.

However, the NRC Board has held that this Commission's determination as to the environmental impacts of the allocation of Delaware River water to Limerick (as distinguished from the effects of specific aspects of the diversion) in February 1981 is final.

In that this Commis-sion or at least its federal member did not so iinally determine, it is necessary for this Commission to reconsider its prior determination in light of the significance now placed on it by the NRC, which is inconsistent with this

y ) 'o Commission's action as of February 1981. The present state of the record is that since neither Commission has accepted responsibility for setting forth and weighing all the environmental effects and full range of benefits and costs with respect to the Point Pleasant diversion, no such disclosure .or weighing pursuant to the National En ironmental Policy Act is or will have been made by any agency unless this Commission does so. 7. As a result of the toregoing, the decisions repre-sented and reflected in the above-mentioned dockets in February, 1981, are no longer in the public interest, are incompatible with the Compact and the Conenission 's Compre-hensive Plan, and must be reconsidered, revised, rescinded, and reopened. 8. In light of the foregoing, implementation of the project as approved will substantially and adversely affect the petitioners, their

members, the environment, and the interest of users of the river throughout the Delaware River Basin, and therefore cannot be permitted to stand, consis-tent with the Compact, the National Environmental Policy Act of 1969, the Historic Preservation Act Amendments of 1980, the Endangered Species Act, the Fish and Wildlife Coordina-tion Act, Section 404'of the Clean Water Act, Section 10 of the River and Harbors Act, and the Atomic Safety and Licen-sing Act, and the regulations thereunder, respectively.

a., 9. The impacts of the changes discussed herein have never been considered. in 'any Environmental Assessment. In view of the substantiallity of the

changes, and the significant adverse effects as a

result

thereof, an Environmental Impact Statement is necessary to evaluate them.

WifEREFORE, petitioners request that the Commission reopen and "suspe-d, and, after hearing, and compliance with all relevant statutes, including an updated Environmental Impact St tement, set aside, and rescind its Orders of February 1981 in these proceedings, and award such other relief as may be just and appropriate, including attorney's fees and costs. I s ROBERT J. SUGARMAN Attorney for Petitioners Of Counsel: SUGARMAN & DENWORTli Suite 510 121 South Broad Street Philadelphia, PA 19107 (215) 546-0162 IIAROLD A. LOdKWOOD, Jr Lockwood, Reid, Bolger & Keller .'2126 Land Title Building Philadelphia, PA 19110 September 13, 1982 73 we ,, ~, -, _}}