ML20069L051

Testimonies of RW Mccoy,Jt Phillippe,M Kaufmann,C Emery, P Lewis & Landis Re Aquatic Impacts & Results of NRC Site Visits.Prof Qualifications Encl

ML20069L051
Person / Time
Site:	Limerick
Issue date:	11/08/1982
From:	Emery C, Kaufmann M, Landis S, Lewis P, Mccoy R, Phillippe J DEL-AWARE UNLIMITED, INC.
To:
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ML20069K972	List: ML20069K969 ML20069L043 ML20069L051
References
ISSUANCES-OL, NUDOCS 8211160377
Download: ML20069L051 (66)

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\t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Thiladelphia Electric Power Company ) Docket No. 50-352-OL .

(Limerick Generating Station Units 1 and 2 ) 50-353-OL t

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DIRECT TESTIMONY OF RICHA n t.' w cnv ON BEHALF OF DEL-AWARE, INC. 8 IN THE MATTER 0 l THE OPERATING LICENSE FUd Linr.KicA NUCLEAR GENERATING STATION l

8211160377 821111 PDR ADOCK 05000352 0 PDR ..

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• DIRECT TESTIMONY OF RICHARD W. McCOY ,

Q: State your name and address.

A: My name is Richard W. McCoy, and my business address is 315 S. , Allen Street, Suite 322, State College, Pennsylvania 16801.

Q: With whom have you been employed and how long have you worked for them?

A: I am employed by the U.S. Fish and Wildlife Service and have worked for them for the past 8 years and 4 months. Prior to that I was a student receiving a B.S. degree in Biology from Ohio State University and a M.S.

degree in Fishery Biology from South Dakota State Unversity.

Q: What has been your involvement with the Point Pleasant Diversion Project?

A: In February 1980, I reviewed the Environmental Assessment prepered by the Delaware River Basin Commission (DRBC) for the proposed North Branch Water Treatment Plant in Bucks County, Pennsylvania. In preparing comments for that assessment, I reviewed the previous documents, feasi-bility studies and environmental impact statements for the Limerick Generating Station; the proposed Merrill Creek reservoir; and the proposed Point Pleasant Diversion Project. Since 1980, I also helped prepare ,

comments on the intake structure design for the Point Pleasant Diversion Proj ect; the public notices from the Philadelphia District U.S. Army Corps of Engineers for permits 'to construct intakes for the Point Pleasant and Merrill Creek projects; the Environmental Report - Operatin5 License Stage (and five revisions) for the Limerick Generating Station; and the draft environmental impact statement for the proposed Merrill Creek Project. I have made several field investigztions of 'the Poin.t' Picasant'

' Diversion Project, the proposed Merrill Creek project, and the Limerick Generating Station.

4 Q: What is the Fish and Wildlife Service's position in regard to consumptive withdrawals at the Poin't Pleasant Diversion and their importance to fishery resources in the Delaware River Basin?

. A: The Service is concerned that water has been allocated and groundwater and surface water withdrawals permitted in the Delaware River Basin with little regard for cumulative effects. Mr. Seymore Selzer of the DREC infor:ed me on July 1,1982, that the DRBC does not maintain a list of previcus allocat*ons and consumptive withdrawals. Each new application is handled independently based on historical flow records, when available.

There are also many users established prior to development of the DRBC compact for which no records are maintained. DRBC recognizes this problem and is now advocating the. implementation of a depletive water use budget ,by 1985. Also, as a result of studies by Chester-Betz Engineers ~

and Moody Associates for the Pennsylvania State Water Plan, in October 1980, DRBC designated all of Montgomery County and parts of four other counties as a groundwater protection area. This designation resulted from problers caused by over-pumping of groundwater in these areas.

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O Tocks Island Dam would have eliminated the water shortage dilemma in the basin by supplying 980 cubic feet per second (cfs) of make.-up water.

In 1975, . construction of the Tocks Island Dam was deferred by DRBC to the year 2000 and DRBC now faces the problem of manipulating the small amount of available water storage to meet low flow conditions in the Delaware River.

The Service's March 11, 1980, letter to Mr. Cerald M. Hansler, Executive Director of the DRBC, expressed concern about the adverse effects on aquatic resources which would result from the increased frequency of low flows and additional consumptive withdrawals at Point Pleasant. In the 1980 Level B Study, current consumptive water use was estimated to be 1,495 cfs. Between 1970 and11980, depletive water uses increased $30 cfs and are expected to double in the next 20 years. By the year 2020, depletive use is expected to be 2,503 cfs. New York City and northeastern New Jersey are authorized to divert another 1,395 cfs out of the basin'by virtue of a 1954 Supreme Court Decree. Af ter the drought of the 1960's and 1980-81, DRBC recognized that inadequate water storage capacity exists to meet the Supreme Court Decree and still maintain flows down-stream, and has entered into negotiations with New York City.

In January 1981, flows at Trenton, New Jersey, dropped to 1,900 cfs and the average flow .for the entire menth was only 2,539 cfc. The cumulative effect of all consumptive uithdrawals has contributed to 1) depressed dissolved oxygen levels in Zone II of the Delaware estuary, adversely .

impacting diadromous fish runs, and 2) increased salinity levels in upper Delaware Bay during low river flows.

( Q: Why does the Fish and Wildlife Service believe that the Point P16asant Diversion project should not be considered independent of other consumptive uses in the basin? ,

A: 'In letters to DRBC, the Philadelphia District Army Corps of Engineers and the Philadelphia Electric Company, the Service recommended that the total consumptive use in the basin should be considered when evaluatin'g the effects of red'uced flo"s on fish and wildlife resources. A single water user may have lit'tle .2ffect on water quality or river flow, but all users could have significant adverse impacts. The 143 cfs diverted from the Delaware River by the Point Pleasant Diversion Project would lower dissolved oxygen IcVels in Zone II of the Delauare River estuary by less than 0.1 parts per million (ppm). However, in the nodel run presented in the Level B Study and the total consumptive use in 1980 of 1,495 cfs, dissolved oxygen levels were reduced by more than 1 ppm. If oxygea levels in Zone II were already at 5 ppm, another 1 ppm decrease could prevent most fishes from surviving in that reach.

The DRBC has concluded from their dissolved oxygen model that large river flows are necessary to improve water quality conditions in Zones III and IV of the estupry due to high nutrient loading from wastewater discharges.

Philadelphia treatment plants discharge an estimated 90% of the fecal

coliform bacteria to the estuary. Three large treatment plants currently under construction will reduce by half the organic waste load into the estuary and allow dissolved oxygen levels to remain at 3 ppm or greater

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year round, in all parts of the estuary (Ref: Philadelphia's River Resources, 1982). Therefore, increased consumptive uses in the Delaware River basin in the future could significantly af fect water quality in the entire Delaware ' estuary. .

Even if there was enough storage in the basin to maintain a 3,000 efs flow at Trenton, consumptive uses would increase the frequency.of occur-rence of this minimum flow standard. The Level B Study concludes that increased frequency of the 3,000 cfs flow level at Trenton will continue to have negative ef fects on dissolved oxygen levels in the estuary.

o Q: Why is the Fish and Wildlife Service concerned about dissolved oxygen levels in the estuary?

A: The Service is concerned about declines in anadromous fish stocks in the Delaware River. American shad, river herring, American eels, shortnose sturgeon and White perch must migrate through the Delaware estuary to reach spawning or nursery areas in the Delaware River. Timing is critical to the survival of migratory runs in the river. If dissolved oxygen levels are not high enough shen migratory fish reach the estuary, the fish may not be able to find suitable spawning areas below the pollution block. This was evident in the 1960's When spring flows were very low and the American shad population plummeted. American shad landings began to sharply decline after 1965 in Delaware Bay and reached a record low in 1969. These figures would reflect the 4 to 5 year lag time for fish .

hatched during the 1960-65 drough t to return to the Delaware River'.

- Small return runs would account for the continued low numbers through 1974. If fish enter the estuary and dissolved oxygen levels cej: ease (which could happen if there was a sharp increase in consumptive demand coupled with a period of no rain), the fish would become trapped and massive die-offs would occur. Low dissolved oxygen levels have been -

blamed for numerous large juvenile shad kills in the Delaware estuary.

There is very little repeat spawning of American shad because most downrunning adults are not able to pass throuSn the estuary as a result of lower flows and poor water quality..

If the dissolved oxygen barrier becomes established early in the fall, the potential exists for high mortality among juvenile migratory fishes attempting to leave the river. They too must pass through the estuary on their way to the sea.

Mr. E. H. Bourquard, a co'nsultant for Keshaminy Water Resource Authority, in a May 23, 1980 meeting with the Service, agreed that the Neshaminy Water Resource Authority could purchase water from the Torresdale Water Treatment Plant which is several miles downstream of the mouth of Neshaminy Creek. This would, in effect, recirculate more water through

! - Zone II rather than bypass 18 miles of Zone II as proposed by operation

' of the Point Pleasant Diversion project. If the Keshaminy Water Resource Authority would use water from Torresdale, there would be a positive .

. impact to dissolved oxygen in Zone II rather than the negative effect from diverting water at Point Pleasant.

ry Q: Does the Fish and Wildlife Service believe that there is sufficient water storage in the basin now to meet minimum flow standards during low flous.

vithout the Point Picasant Diversion Project?

r A: No. DR3C initially set a flow standard of 3,000 cfs at Trenton to ensure that high salinity levels did not af fect major water purveyors in the estuary. The Service has noted in letters to the Philadelphia District Army Corps of Engineers that this flow is not enough to improve dissolved oxygen levels in Zones III and .IV for aquatic life. DRBC now ecognizes that even the 3,000 cfs flow is unrealistic to maintain during

. .t drought and is currently supporting a 2,500 cfs flow. The historical flow records at the Treaton gage show that this reduced standard of 2,500 cfs was not met in January 1981 when flows decreased to 1,900 cfs.

This occurred even with voluntary cutbacks by New York City from their authorized 1,238 cfs diversion to 800 cfs.

DR3C's plan to maintain flow's of 2,500 cfs at Trenton includes construction of three new storage reservoirs and enlargement of three others. Presently, only the Merrill Creek Project and the Francis E. Walters Dam are in the early design stage. If built, Merrill Creek would not be operational until 1986, (barring any unexpected delays). The Point Pleasant Diversion Project is expected to be operational by 1985.

The Level B Study identified 23 water purveyors with deficiencies in allocations, yield and adequate ctorage in 1970, 71 in 1980 and an esticated 125 by the year 2020. The State Water Plan identified 100 water purveyors deficien't in at least one of those categories. Recom-mended relief of these problems includes future water diversions- and increased surface water use. .

The large Raritan-Magothy-Potomac aquifer is currently being pumped at three times its recharge rate. DREC has recognized the need to protect all of one county and parts of four more counties in the basin from further over-withdrawal of groundwater. Lower water tables have created new recharge points in over 220 miles of streams fr'om these five counties .

alone, removing critical surface water during low flows (Chester-Betz Engineers and Moody Associates). Solutions to the groundwater problem range from injecting Delaware River water into wells, to increasing '

surface water withdrawals directly (1980 Level B Study).

One groundwater intrusior, point has been identified on the East Branc.. of Perkionen Creek just downstream from the proposed discharge from the Point ?leasant . Diversion project. Several other rechayge points have been documented downstream on Perkiomen Creek. The Service is concerned about how much water from the Point Pleasanc Diversion would be lost to l groundwater in Perkiomen Creek. More water than previously estimated may l need to be pumped from the Delaware River to compensate for this loss to groundwater, i y Q: What are the Fish and Wildlife Service's concerns about salinity in Delaware Bay relative to the' Point Pleasant Diversion?

l A: The Service has reviewed the historical flow records for the Delaware

, River and has noted low flow problems at Trenton in letters to DRBC and the Philadelphia District Army Corps of Engineers. On October 31, 1963, flows decreased to 1,180 cfs at Trenton, New Jersey. DREC estimates that the three New York City reservoirs provide 90% of the available make-up i

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water storage in the basin. Two of-the three New York City reservoirs were'in operation by 1963 and'Cannonsville-was nearing completion., With the : storage available at that time, it was still impossible .to prevent l

this low-flow event from occurring in the middle of the outmigration period for American-shad. Extreme low flows have o'ccurred in the Delaware River every month since completion of the three New York City _ reservoirs (Table 1). .

Consumptive water uses . in 1980 exceeded 1,495 fc' s and are expected to increase to 2,503 cfs by the year 2,'000. If flows could not be con' trolled with over 90% of the total storage capacity operational during the past 18 years, .the Service questions where the make-up water .for the -Neshaminy Water Resource Authority and other new consumptive users will come from in the future during low flow events.

Dr. Harold H. Haskin in 1972 completed a salinity study of five locations in Delaware Bay. In 41 years of recor'd, Dr. Haskin noted significant increases in salinity. levels with the same freshwater inflows at Trenton.

Dr. Haskin gave three possible reasons for the narked increases: 1) less-freshwater input below Trenton; 2) changes in river bottom topography from dredging for navigation; and, 3) risihg sea levels. The: Department of the Interior in 1970 identified diversions and impoundments;as major ,

contributing factors in raising salinity levels in Delaware Bay.. A DRBC staff _ paper (Apgar, July 24, 1979), using the Thatcher /Harleman salinity model, predicted that during dry years salinity greater than '15 parts per .

thousand'(ppt) would exist all year over the seed oyster beds. Even

, during a norma 3 flow year (1970,) salinity lower than 15 ppt would only persist over the seed oyster beds,in April and May. "Diis model run used current flow augmentation capacity, a 1,000 cfs consumptive = use#(in 1980 consumptive use was 1,495 cfs) and a 2,700-efs minimum flow at Trenton.'

The Apgar paper also predicted the need for an additi onal 340 cfs of freshwater flow into Delaware Bay by the year 2000 to offset the effect on salinity levels by a rising sea level.

In a separate run of the salinity model .using the year 2000 consumptive

, use and a minimum flow of 2,700 cfs at' Trenton, DRBC demonstrated that the 1,393 cfs diversion to. New York City and New Jersey would cause significant increases in salinity between Chester, Pennsylvania, and the Delaware Memorial Bridge. Salinities also increased in the upper bay over seed oyster beds. DRBC has recognized the potential impacts from a total diversion of 1,393 cfs decreed by the Supreme Court in 1954 (to

'date New York City and New Jersey have never used their total allotted amount). DRBC has entered into negotations with New York City to reduce their diversion during drought periods. .

All the studies and actions taken in the Delaware River basin point to

, the fact that salinity in Delaware Bay continues to increase, consumptive viter use continues to rise, and there is inadequate storage now to make up the. water deficit in the basin during low flows. The Service is .

concerned that all of the evidence is not being considered before new diversions and consumptive uses ar'e approved. The Point Pleasant Diversion by itself may have only minor effects on salinity levels in Delaware Day, but the cumulative effect of all water uses in the basin can be si nifi- 3

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.- periods een occur during any conth of the year and thus adversely impact fish spawning, migration of diadromous fishes, seed oyster production, and other fish and wildlife resources. -

S$ed oysters- are very susceptible to predation by the oyster drill and the protozoan MSX. These predators are intolerant of salinity levels- .

below 15 ppt. The seed oyster beds near Ben Davis Point are especially valuable because this strain of oyster is more resistant to the protozoan MSX &nd survives better when moved ' to the lower hay for final growth before harvesting. Only if.the 15 ppt isohaline line can be stabilized through adequate freshwater inflows for April, May and June will the oyster drill be unable to invade seed oyster beds north of Ben Davis

' Point. As noted in Table 1,, low flows can occur during those months.

Diversions and consumptive withdrawals during low flow events in those months could devastate seed oyster beds in the upper Delaware Bay. Even too much skimming of high flows for make-up water storare during April, May and June would be detrimental. to oyster production in the bay if this.

allowed. the 15 ppt isohaline to move up the bay over the seed oyster beds.

Salinity is the most importaat single factor in determining the distribution of vascular plants in the estuary. Freshwater plants grow faster than saltwater plants in less saline' waters but are relatively intolerant of high salinity IcVels (Walton and Patrick,1973).

The life cycle of the blue crab is dependent on salinity regimes'in the bay. Adults mate in the upper bay at low salinity levels. Young crabs -

hatch in 'the lower bay at much higher salinity levels.

Young weakfish grow in the less saline waters of the upper bay. , Reduced freshwater inflows from diversions and consumptive use will cause salinity levels to move up the bay and force the young weakfish to leave their traditional nurse ~ry areas. The fish would also be crowded into a smaller- -

. area for survival.

The Service contends that the cumulative impacts from reduced freshwater inflows into Delaware Bay have never been analyzed- thoroughly.- The

. Thatcher /Harleman salinity model provides only a rough estimate of actual conditions. Because of the Chesapeake and Delaware Canal, ' the salinity model is not accurate below Chester, Pennsylvania (personal communication, Bill Mueller, U.S. Army Corps of Engineers). The' subtle changes in water chemistry in Delaware Bay may have far greater impacts

,to fish and wildlife resources than the Service has been able to document to date. Further studies are needed to ensure protection of the resources in Delaware Bay.

3 Q: What is the Fish and Wildlife Service's position relateive to skimming reservcirs and the Point Pleasant Diversion?

A: Point Pleasant was originally designed and approved with the assumption that either the Beltzville Reservoir or the Tocks Island Dam would .

, supply adequate flows in the Delaware River during low flows when Point Pleasant would be pumping water. There was little concern in the- Point Pleasant Environmental Impact Statement (February 1973) that adequate

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=ake-up water would not be available during low flows. After evaluating available storage in the basin, in 1977 DRBC required the, Philadelphia Electric Company to provide their own make-up water storage on the Delaware River to compensate for water withdrawals at Point Pleasant during low flows.

During 1975-77, studies of alternative sites for a make-up water reservoir led to the selection of the Merrill Creek Project on a' tributary to the Delaware River. Merrill Creek, if built, would destroy habitat for several State-listed endangered species, inundate 712 acres of exce31ent sildlife hab'itat and eliminare 1.7 miles of naturally reproducing brook trout stream in New Jersey. The Draf t Environmental Impact Statement for the Merrill Creek project states that the Red Creek reservoir alternative

,on the Schuylkill River would ,be less environmentally damaging than Merrill Creek.

Of the ten electric generating stations which would use make-up water from MErrill Creek, eight power plants are either on the Schuylkill River or downstream of its confluence with the Delaware River. Only 27 cfs of the projected 203 cfs supplied by Merrill Creek would be used on the Delaware River above the confluence of the Schuylkill River.

If the Red Creek reservoir site were used, there would be no need to build the Point Pleasant Diversion or the more environmentally damaging Merrill Creek Reservoir. Part of the justification for selecting the .

Merrill Creek. site was the need to satisfy the water withdrawals at Point Pleasant. Over 27%..of the water discharged from Merrill Creek would be withdrawn at Point Pleasant for the Limerick Generating Station. The Service believes that it-is not in the public interest to allow tonstruc-tion of the Point Pleasant Diversion with its potential adverse impacts to fish and wildlife resources and in turn create the need for the . -

construction of a make-up reservoir on the Delaware River-at Merrill Creek when far less environmentally damaging alternatives are feasible to meet the water supply needs of Limerick and other electric generating stations downstream. ~

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• t The Service has pointed out in letters to DRBC and the Philadelphia .

District Army Corps of Engineers the need to consider environmental i impacts from skimaing reservoirs. Wildlife habitat, wetlands and stream habitat are destroyed and replaced by large reservoirs'with extreme water

! level fluctuations. Evaporative losses and seepage to grcundwater l reduce surface water flows. Skimming during April, May and June may I create adverse impacts to salinity regimes in Delaware Bay during dry l years. Because the Point Pleasant Diversion project creates a need for construction of a skimming reservoir upstream, these impacts must be

, considered as a part of the overall project.

1 In a September 14, 1982, letter to the Philadelphia District nrmy Corps of Engineers, the Service pointed out that if Unit 2 of the Limerick Nuclear'Generaiing Station is not built, the need for make-up cooling

' water could be reduced by about one-half. This would allow for develop-l ment of several options 'or make-up water during low flows. The use of 30 cfs from the Philadelphia Treattent Plant discharge could reduce adverse environmental iapacts from the Point Pleasant Diversion and the need for construction of a skitming reservoir. Perhaps the smaller volume of l

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water could be purchased from' one of the existing reservoirs on the Schuylkill River. The possibility also exists for increasing the storage capacity of an existing reservoir on the Schuylkill River.' -

The Service believes that a skimming reservoir on the Schuylkill River would have a positive effect on water quality and quantity in the river -

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during low flov periods. A COWAMP/208 study in 1976 revealed that during a 7-Q-10 low flow event, 43% of the water in the lower Schuylkill River comes directly from vastewater discharges. At various times of the year, the dissolved _ oxygen levels in the Schuylkill River drop below 5 mg/1.

Extreme depressions in dissolved oxygen levels frequently occur between Norristown and Fairmont Dam. Augmentation of flows during dry weather would greatly improve water quality. Improved water quality would also enhance the Pennsylvania Fish Commission's ef forts to testore American shad to the Schuylkill River. Also, the Point Pleasant Diversion projre, would result in the loss of an undetermined amount of surface water to groundwater.in Perkiomen Creek. This loss could be avoided with a skimmin~g reservoir on the Schuylkill . River.

p Q: Does the Service feel that the Point Picasant Diversion project will have a negativo effect on the fish and wildlife. resources in the East Eranch of Perkiomen Creek and North Branch of Neshaminy Creek?

A: Yes. Since the 1970 draf t EIS for the Limerick Cenerating Stati,on, the -

Service has expressed concern about physical and water quality changes in '

both creeks. The maximum discharge into both creeks will equal approxi-mately the one-year. flood event. Both streams are very small headwater, first-order tributaries.. The North Branch of Neshaminy Creek is dry during low flow periods. Higher flows will scour the'streambedsand increase sediment and turbidity downstream. Water carried underground 17.5 miles to the East Branch could be much colder than the receiving ~.

stream. A rapid drop in water tenperature or increased turbidity in the'

spring would disrupt smallmouth bass spawning in the lower reaches of the East Branch of Perkiomen Creek.

Because of its proximity to the mouth of Tohickon Creek, some' Tohickon Creek water may be withdrawn at Point Pleasant and discharged into both s treams . This creates the' possibility of transporting poor quality water via the Point Pleasant Diversion to both the East Branch of Perkiomen Creek and the North Branch of Neshaminy Creek. In a letter dated March 18, 1980, the Environmental Protection Agency pointed out .that lead l

-concentrations sometimes exceed water quality standards in the Delaware River near the Point Pleasant Diversion. Heavy industry upstream of the Point Pleasant Diversion also discharges other metals and pollutants into the river. These pollutants could be transported to both streams through

! the Point Pleasant Diversion.

Q: Has the Service expressed concern,about wetlands impacted from the Point Pleasant Diversion? ..

l A:- Yes. In review of the Point Pleasant Diversion Project, the Service had determined that one acre of forested wetland would be impacted and 0.3 acre permanently lost. No compensation for this wetland loss is currently planned. The Service has pointed out that wetland impacts could be avoided by moving the project site further downstream.

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Q: Does the Service believe that intake structures in the Delaware River at Point Pleasant will cause adverse impacts to aquatic resou'rces?

A: Yes. DRBC approvals for water withdrawals at Point Pleasant do not stipulate that pumping must be conducted at flow levels greater than 3,000 cfs at Trenton. In fact, DRBC is attempting to set a lower minimum flow at Trenton since storage does not exist to maintain the 3,000 cfs flow during dry conditions. During July, August, September and October flows decrease below 3,000 cfs more than 20% of the time and at the Rieglesville gauge 35% of the time (Gyk and Associates, Inc. , August 9, 1982). As noted in Table 1, flows have decreased below 3,000 cfs in every month except March, April and May at Trenton, NJ.

Paul Harmon in a report on the " Biological Evaluation of the Proposed Water Intake In the Delaware River at Point Pleasant, Pennsylvania" (November 1980) pointed out that, for flows greater than 3,000 cfs,.

velocities at the proposed intake would be 1 fps. No measurements were taken at flows less than 3000 cfs.

It is the op' inion of the Service that there would be greater potential for entrainment or impingement of eggs and larval fishes if the intake is in the back eddy formed below Tochickon Creek at flows less than 3,000 cfs.

At the minimum flow of 1,180 cfs recorded on October 31, 1963, the intake would have withdrawn over 12% of the Delaware Rivet flow. The magnitude

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of entrainment and impingement losses are partially dependent upon the degree of influence. the intakes have on velocities away from the screens.

Mr. E. H. Bourguard, consultant for the Neshaminy Water Resource Authority, has estimated that positive pull towards the screens would not gy: tend beyond 10 feet from the intake. Therefore, fish eggs and larvae would be expected to be drawn to'the intake from approximately 0.1 acre of the ,,

back eddy and river. As the water circulates around the eddy, different '

water and more eggs and larval fishes would be continually exposed to the intake and increase mortality rates even more. The Service believes that entrainment and impingement losses would be greatly reduced if the intake were located where river velocities would always exceed 1 foot per second (fps) under all flow conditions in the river. ,

If debris clogging becomes a problem, velocities at the screen.would exceed the 0.5 fps design velocity and possibly impinge more larval fishes. Because of the behavior of young American eels, they would be entrained and impinged more than other species.

It is the opinion of the Service that regardless how small these entrainment and impingement losses are, they could be avoided altogether if a make-up water source for Limerick were constructed in the Schuylkill River basin and Neshaminy Water Resource Authority chose an alternate vater source. The Service recomme.nds that the Nuclear Regulatory Commission not allow this mortalit'y to occur when less environmentally damagin'g alterhatives exist other than the Point Pleasant Diversion project.

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k- Q: Dora tha S2rvice believ3 that intiks structuras in th2 Deltvara Rivar et Point Pleasant will cause adverse impacts to aquatic resources?'

A: Yes. DRBC approvals for water withdrawals at Point Pleasant do not stipulate that pumping must be conducted at flow levels greater than

. 3,000 cfs at Trenton. In fact, DRBC is attempting to set a lower minimum flow at Trenton since storage does not exist to maintain the 3,000 cfs flow during dry conditions. During July, August, September and October flows decrease below 3,000 cfs more than 20% of the -time and at the Rieglesville gauge 35% of the time (Gyk and Associates, Inc., August 9, 1982). As noted in -Table 1, flows have decreased below 3,000 cfs in every month except March, April and May at Trenton, NJ.

Paul Harmon in a report on the " Biological Evaluation of the Proposed Water Intake In the Delaware' River at Point Picasant, Pennsylvania" (November 1980) pointed out that, for flows greater than 3,000 cfs, velocities at the proposed intake would be 1 fps. No measurements were taken at flows less than 3000 cfs.

It is the opinion of the Service that there would be greater potential for entrainment or impingement of eggs and larval fishes if the intake is in the back eddy formed' below Tochickon Creek at flows less than 3,000 cfs.

At the minimum flow of 1,180 cfs recorded on October 31, 1963, the intake would have withdrawn over 12% of the Delaware River flow. The magnitude of entrainment and impingement losses are partially dependent upon the degree of influence the intakes have on velocities away from the screens.

Mr. E. H. Bourguard, consultant for the Neshaminy Water Resource Authority, .

has estimated that positive pull towards the screens would not extend beyond 10 feet from.the intake. Therefore, fish eggs and larvae would be expected to be drawn to'the intake from approximately 0.1 acre of the back eddy and river. As the water circulates around the eddy, different water and more eggs and larval fishes would be continually exposed to the intake and increase mortality rates even more. The Service believes that ,

entrainment and impingement losses would be greatly reduced if the intake were located where river velocities would always exceed 1 foot per second (fps) under all flow conditions in the river.

If debris clogging becomes a problem, velocities at the screen would exceed the 0.5 fps design velocity and possibly impinge more larval fishes. Because of the behavior oZ young American cels, they would be entrained and impinged more than other species.

It is the op'nion of the Service that regardless how small thesc

entrainment and impingement losses are, they could be avoided altogether if a make-up water source for Limerick were constructed in the Schuylkill

] River basin and Neshaminy Water Resource Authority chose an alternate water source. The Service recommends that the Nuclear Regulatory Commission not allow this mortality to occur when less environmentally damaging alternatives exist other than the Point Pleasant Diversion

. project.

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e Table 1 Lovest Minimum Daily' Flow Each Month at the Trenton, NJ gage for the Past 30 Years of Record

• Month Flow (cis) Year January . 1,900

• 1981 February 2,200 1977 March 3,990 1969 April .

4,710 1968 May 3,160 1965 June 1,420 1965 July 1,240 1965 August 1,440 1965 September 1,520 1965 j October 1,180 1963 4

1,460

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. November 1965 t

December 1,930 1965

. NOTE: Over 90% of current make-up water storage capacity in the basin h'as been in operation since 1964.-

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September 20, 1982 Atomic Safety and I.icens,ing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ,

In the matter of Philadephia Electric Company (Limerick Generating Station Units I and II Docket.i 50-352

. 50-353 Testimony attached to trial brief of DelEWARE Unlimited e

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Ssptemb r 20, 1982 QUESTIONS CONCERMING J.T. PljILLIPPE LETTER OF 11AY 10, 1982 Q. What was the purpose of the letter addressed to Del-AWARE, May 10, 1982?

A. The purpose of the letter was to summarize findings and suggestions concerning issues regarding the hydrology and hydraulics of the Ppint Pleasant Pumping Station for the use of the citizens of Del-AWARE Unlimited and their counsel.

Q. Was the letter the result of a lengthy review of project documents?

A. No. The . letter w'as the result of a brief review of very-limited project documentation and river flow records in the public domain. The letter reflected the concerns of an engineer looking' at possible environmental consequences of a very complicated project.

• Q. What kinds of environmental consequences were of concern?

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A. Of concern are the ef fects of diversion of water from the -

freshwater portion of the Delaware River, transfer of that water to a sub-basin of the Delaware (the Perkiomen Creek-Schuylkill River), and return to the Delaware Estuary by-passing the uppe'. Delaware Estuary. Also of concern is the effect of operation of the Point Pleasant Pumping Station on aquatic life in the immediate vicinity of the Pumping Station.-

Other concerns relate to the public safety with respect to the operation of the various components of the conveyance and storage' system.

Q. What was the purpose of the reference'to fire department pumper trucks? -

A. Since the letter was addressed to the citizen's group, Del-AWARE Unlimited, the use of t'he visualization of fire depart-ment pumper trucks was one to which I felt most citizens can relate. The number of equivalen't pumper trucks provided a point of. reference to which a layman could relate the magni-tude of pumping.

Q. Why did you suggest the use of mathematical models for charac-terization of the Point Pleasant Pumping Station pumping environment?

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A. The flow, velocity and eddy patterns at the Point Pleasant site are at present ill defined. The NWRA and PECO have provided very limited flow, velocity and eddy pattern field measurements. They have provided none at the low flow levels at which disruptions to the existing low flow velocity and oddy patterns may become significant. That is low flows substantially below 3000 cfs. Mathematical models' allow incorporation of geomorphologic factors into a computerized calculating and " bookkeeping" scheme that can keep track of changes to velocity and eddy patterns under a variety of flow conditions. Such model?s, for which the physics of the situ- -

ation are properly represented would allow the engineer to examine the sensitivity of the velocity and eddy patterns ,

to various river flow flow and pumping operation variations.

At the present time, only qualitative judgments can be made.

Decisions for,or ,against a project, should not be made on the

' basis,of qualitative judgments when better tools are available from which to make quantitative assessments.

Q. In your letter, yous analyzed flow records at Trenton for 'the period 1963-1979. The Merrill Creek Owners' Group used flow records beginni,ng in 1920 through 1979. Which set of flow records is more appropriate to use? -

A. The historic flow record for the entire period of record is more appropriate to use.

Q. Nith reference to Exhibit 2 of your letter of May 10, 1982, what are the corresponding low flow expectations when the period of record through 1979 is used for the Trenton flow gage? ,

A. The attached exhibit gives the low flow expectations for the historic period of record through 1979.

Q. How do the low flow expectations for the historic period of I

record differ from those presented in your letter of May 10, 1982 for the more recent 17 years of record? ~

A. The' low flow expectations produced from the complete period of record (as released by the USGS) are much lower than those calculated from the more recent 17 years of record.

Q. Why were the flow flow expectations produced from the more recent 17 years of published record biased on the high side

! when compared to the entire, published, historic. record?

Wasn't the severe drought of the 1960's included in the 17 years of recent record that was analyzed?

A. Although the extreme drought of 1966 was included, the very

" wet" years of the 1970's were also included. Hurricane Agnes occurred in 1972. Review of the entire published period of record shows several other significant drought periods on the j Delaware. Relatively severe droughts were observed in 1915, 1923-24, 1931-33, 1942, 1955, as well a7 the 1960's drought.

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EXHIBIT -

TRENTON GAGE (USGS No. 01463500)

SUMMARY

OF LOW FLOW EXPECTATIONS *

(Log Pearson Type III Analysis)

Flow Period Flow Values, cfs, for Recurrence Interval 2-year 5-year 10-year

. 1--day low flow 2184 1632 1411 3-day 1ow flow 2311 1717 1480 7-day low flow 2460.. .

1821 1566 14-da.y low flow 2605 1916 1647 .

30-day low flow - 2893 2106 1799 60-day low flow 3342 2393 2041 90-day low flow 3832 2686 2255 120-day low flow ** '4425 3047 2527

• Flow record, 1913-1979.

• Ma::imum sustained Merrill Creek Reservoir Relea se purported to be 200 cfs for 115 days. -

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Q. In your letter of May 10, 1982, Exhibit 3 showed the percent of time that the flow in the Delaware at Trenton was less than 3000 cfs for the 17 years of recent record analyzed on a monthly basis. How do those percentages compare using the entire published historic flow record for the Trenton gage?

A. The data used in Exhibit 3 was partitioned in 500 cfs incre-ments. The percentage shown as less than 3000 cfs should ,

have been shown as less than 3500 cfs. However, using the entir'e published historic period of daily flow values and

• partitioning in 100 cfs increments, flows less than 3050 cfs for Trenton can be expected for each of the twelve months as follows: .

Month

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Percent of flow less than 3050 cfs January - -

3.1 '

February .

1.5 l

March '

O.2 April --

0.0 May -

0.0 June ,

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2.9 July 19.4 August 29.5 September 34.3 October 30.3 -

November 14 7 December

, 5.1 O.

Can you provide similar monthly estimates of low flows less than 2500 cfs and 2000 cfs, respectively?

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Using the same partitioning scheme for historic published daily flow mates values can be at the' Trenton gage, the following esti-provided:

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Percent of Flow Percent of Flow Month Less Than 2550 cfs Less Than 2000 cfs January 1.4 0.1 February 0.5 0.0 March 0.0 0.0 April 0.0 0.0 May 0.0 0.0 June .

1.0 8 0.5 .

July +

10.2 3.9 August 19.2 e .. .. .

8.3 September 24.2 10.4 October 18.9 11.4 November

• 9.6 5.2 .

December -

2.8 0.9 Q. Given that the Merrill Creek Reservoir is built and is fully, operational for low flow augirantation, and that the Point

, Pleasant Pumping' Station benefit from such low flow augmen-tation using a " river-following" approach, do you anticipate pumping to be permitted at flows below 2500 cfs?

A. Yes.

Q. At flows less than 2000 cfs? '?

A. Yes.

Q. Questions have been raised concerning the, water surface ele-vation at the propsoed Point Pleasant Pumping Station intake.

Are you aware of water surface elevation measurements in'the low flow vicinity of 20,00 cfs?

A. Yes. Pickering, Corts & Summerson, Inc. obtained a water surface elevation of 69.4 feet above sea level for Channel Section 22.0 in a study of the proposed Tocks Island Dam and Reservoir.. This cross-section is located approximately 1/3 mile below the proposed intake and is in the pool created by the Lumberville weir and dam. The elevation was obtained on September 26, 1964 at which time the flows observed at the l

Trenton gage were approximately 2000 cfs.

( Q. What effect does the Lumberville dam have on flows below 3000 cfs?

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A. With incomplete data available, only'a qualitative answer should be given at this time. The Lumberville weir and dam, built, in part, to provide a pool from which water could be drawn into the Delaware-Raritan Canal, also creates a pool extending back to channel Section 22.0 and back to the proposed intake location. At 2000 cfs, given the cross-sectional areas surveyed on September 26, 1964, an average velocity of less than 0.6 fps could be calculated.

!!owever , the exact velocity distribution cannot be given based on data presently'available. Qualitatively, one can expect the instream velocities to drop as the flow drops below 3000 cfs because of the effects of the pooling oc-curring behind the Lumberville dam.

0. What do you know *ab'out the channel in .the Delaware River in

the vic'inity of the proposed Point Pleasant Pumping Station?

A. My knowledge is limited to the general nature of the bar at the mouth of the Tohickon Creek, the bend of the river-at Point Pleasant, the cross-sections obtained'for the ~

Corps of Engineers once proposed Tocks Island Dam and Reser-voir and information provided in E.H. Bourquard documents or from observations reported by divers and survey' ors hired by ,

Del-AWARE Unlimited or its counsel. In summary,,as the river is traversed in an' upstream to downstream direction, the main channel is found closer to the New Jersey shore in the vicinity of Tohickon Creek approximately two-tenths of a mile above,the proposed intake. The principal channel continues past the proposed intake with the main channel apparently further toward the New Jersey sho.re than the proposed intake location. Ap -

proximately, one-third mile below the proposed intake the main channel is found approximately mid-river with the Pennsyl-vania side of the river generally deeper than the New Jers.ey side. Generally, the stronger currents can be found in the main channel with the " eddy" primarily located toward the Pennsylvania side of the main channel and below Tohickon Creek.

Q. Will Point Pleasant intake water be derived primarily from the main channel of the Delawar'e River or from the " eddy" area under low flow (less than 3000 cfs) conditions? -

A. I don't know. Data for such low flow conditions is extremely meager. If the intake is, in fact, located in the main channel, then one might assume a larger proportion of the intake water to be drawn from the main channel. If, in fact, the intake is to be located at some distance from the main channel, one might anticipate a larger proportion of' the water to be taken from the " eddy" area. Again, the data is extremely meager, and there exist no models of the situation, to my knowledge, either physical or mathematical.

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OTHER QUESTIONS .

Q. Are you familar with the details of the proposed Bradshaw ,

Reservoir? .

3 A. I have briefly reviewed documents concerning the Bradshaw -

Re'servoir prepare,d by E.H. Bourquard and Associates, Inc.

Q. Do you agree that the plans and analyses are acceptable?

A. In general, I found the work to be thorough.

s Q. The question has beed" raised concerning th'e stability of

• embankments under proposed operating conditions. Do you "

consider the s'tability analyses and the embankment designs b; . - to be adequate?

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A. Given the type of soils to be used (although plasticit'y indices are generally low), the engineer has specified within reservoir's16 pes of one vertical to three horizontal ,

, and downstream slopes of one vertical to two and one-half horizontal. For the materials proposed, these'embankmpnts and slopes correspond to recommended practice by the Bureau of Reclamation, the Corps of Engineers and others. Stability analyses have been performed for these embankment situations '

including sudden-draw d own. One section of the embankment '

within the reservoir is proposed to have slopes of one verif- .

cal to two horizontal. A stability analysis under sudden-drawdown conditions was not found in materials available for review. No reason,was,found for such an omission.

Q. Materials available for review often indicate a general plan of operations under average conditions. What does " average" mean and what effect might significant deviations from

" average" entail?

l A. I cannot answer the question. In many planning projects r a sensitivity analysis is performed in which the significant deviations from the "av'erage"'are analysed in order to antici-pate effort on the project, or public safety, or oc'onomic

• lesses resulting from such devia tions from " average" con-

! . ditions. Those type of analyses are generally lacking in documents available for review for this project.

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hESUME*- JONATH$N T. PHILLIPPE, P.E.

Education: ,

B.S. - Civil Engineering (Cum Laude), Virginia Poly-technic Institute and State University, 1962 M.S. - Civil Engineering (hydraulics and hydrology),

Virginia Polytechnic Institute and State Uni-versity, 1968 Continuing Education:

Course work has been completed and language, requirements fulfilled toward a Ph.D. degree in Civil Enginceping at Vir-ginia Polytechnic Institute and State University; (Course -

work included the equivalent of a Master's degree in Environ-mental. Engineering and additional work in soils and geology).

GKY and Associates (1975 to present) : , ,

Mr. Phillippe is chief engineer of GKY and Associates. He serves as Vice President of the corporation. His philosophy is' to tailor the tools used to the requirements of the client. To the extent possible,-his philosophy includes drawing these tools from the public domain in order to maximize the supporting user community and to minimize the cost' to the client. Projects have .

been performed using client mainframe computers; down-loading mainframe run programs to minicomputers in order to hold costs ,

constant; and specification and procurement of sophisticated micro-computer based systems to enable cost-effective management and de-velopment of major data bases.

Project manager- experience has covered a wide range of activi '-

ties. These activities have included responsibility for a PL92-500, I

Section 303 (e). basin planning effort in the State of West Virginia,

.resulting in a basin plan for the principal river basin in the state l and in the development of procedures for the orderly accomplishment of basin planning for the remaining river systems in the state. Mr.

.Phillippe also organized a field sampling program and performed wasteload allocation modeling in three southern Alabama basins in support of PL92-500, Section 303 (e) planning. Nonpoint source

questions were addressed and available water quality data was j assessed.

Mr. Phillippe was a lead participant in water quality reviews

! of Advanced Wastewater Treatment project reviews for EPA in its first round of advanced treatment project reviews. As well as performing water quality reviews, Mr. Phillippe also participated ir screening incoming projects for adequacy of materials submitted I for review. This screening included facilities, population, economic

! as well as the water quality considerations of water quality data and attempted water quality simulations. Mr. Phillippe coordinated individual reviews with both EPA and the prime contractor, who was in charge of facilities reviews. More than 60 reviews were made in less than one year with the bulk of the review occuring within a six-month period.

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Ho hnc carv d no principal icvaatigator fort n two-yOcr EPA

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proj0ct on "Nonpoint Sourca Guidanca for 201 Facilitica", and for Bridgewater Commons EIS, heading a multidisciplinary team which assessed water quality impacts and hydrologic modifications to the environment induced by a shopping center in Bridgewater, New Jersey.

, The,Bridgewater Commons project.was supported directly by shopping center developer, Ernest W. Hahn, Inc. for Bridgewater Township.

Project manager experience also included the generation of reports and position papers for the Council on Environmental Quality, the U.S. Environmental Protection Agency and the U.S.

Water Resources Council. These papers included assessments of

. national data bases of water ' quality and quantity. Included in this area of experience are papers relating to the 1975 National Water Assessment. Mr. Phillippe provided waterfg ality sampling ,,

and analysis and hydraulic and hydrologi,c analyses with regard to an Environmental Impact Statement for a major expressway pro-posed through tidal wetlands. Expert testimony was provided in support of litigation both for the defendents and for the plain-tiffs in several' cases. Testimony was provided in the areas of water quality, hydraulics and. hydrology. Project manager experience also included the application of the computer programs, HEC-1 and HEC-2 to urban or urbanizing watersheds adjacent to major eastern .

cities. Mr. Phillip_pe has also engaged in hydrologic research'

. efforts for the National'W'eather Service. .

As a member of GKY study teams, Mr. Phillippe has engaged in'

. the review of and application of mathematical stream modeling in.cluding nonpoint source pollution simulation in both riverine and estuarine modeling efforts. He has been involved with the development of economic and statistical methodologies for use in the. assessment of stream gaging networks of national scope.

He has participated in the development of simplified methodologies ,

to assess urban stormwater impacts. He participat'ed in the develop-ment of a raw water interconnection optimization model for a major metropolitan area. He also participated in a series of projects evaluating the applicability of airborne lasers in hydrographic applications. -

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Private Practice 1974 - 1975): .

l Mr. Phillippe engaged in general civil engineering consulting l in Southwestern Virginia.

Wyt eville Community College (1968-1974):

While teaching at the community college, Mr. Phillippe served i as Chairman of the Division of Engineering Technology and Business l Sciences. He was responsible for the administration of a teaching l program involving fourteen full-time professionals and additional

! . part-time professionals and the requisite support staff. In his L .

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cap; city c3 Divicicn Chairman, ha also chnired a ctatswida c6m-munity college committee reviewing and recommending content of engineering technology curricula. He also served on a committee to establish a Master Plan for data processing for the community college system in Virginia. Teaching responsibilities as an a,ssociate professor of Civil Technology included a broad range of courses in mathematics, statistics, environmental engineering design and operation, a full range of surveying, soils, and engi-neering materials and structures. During this time, Mr. Phillippe also worked with the Appalachian Power Company on its Blue Ridge Project". This work included a surveying program of shoreline control and a soils sampling, testing and evaluation program with Drs. A. and L. Casagrande of Harvard University. Mr. Phillippe also developed and taught several short cours.es and training -

programs in the environmental technology fiela. -

Other Experience (1956 - 1962): '

Mr. -Phillippe attended Virginia Polytechnic Institute and State University as a 'co-op student. He co-oped with the U.S.

Coast and Geodetic . Survey in the areas of hydrographic surveying, photogrammetric interpretation, geodetic surveying and carto-graphy. Upon gr.aduation, Mr. Phillippe worked as'a junior engineer for the State of California on the southern terminus of the California Aqueduct. Other work included thorough ,

exposure to all aspects of residential construction. Mr. -

Phillippe's extensive travels have resulted in familiarity with most areas of. the continental United States and also of the sub-continent of India and other areas of southeast Asia.

1 Licenses and Professional Affiliations: s, Registered Land Surveyor - Virginia -

Registered Professional Engineer - Virginia Member, ' National Society of Professional Engineers

. Member, Virg, inia Society of Professional Engineers (has held elective o,ffices in a local chapter)

Member, 'American Society of Civil Engineers '

Member, American Geophysical Union ~

Tau Beta Pi, Phi Kappa Phi ~, Chi Epsilon, Sigma Xi Private Pilo t Other Skills:

l Accomplished semi-professional photographer.

Representative Publications:

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. Instantaneous Unit Hydrograph Response by Harmonic' Analysis,

. Bullet 15, Water Resources Research Center, Virginia Polytechnic

! Institute, March 1969. '

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s The Optimization of Rau Water Interconnections for the Wa s hing t on, D.C.~ Metropolitan Area: Phase III, Finai Report; Report to Baltimore District, Corps of Engineers, with G. K.

Young, R. A. Aspinwall and S. A. Daley, January, 1979.

The Optimization of Rau Water Interconnections for the Wa shing ton, D. C. Metropolitan Area: Phase I, Hydrologic and Hydraulic Data; Report to Baltimore District, Corps of Engineers, with R. Aspinwall and S. A. Daley, April, 1979.

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1 DIRECT TESTIMONY OF-MICHAEL KAUFMANN'AND CHARLES EMERY i

We are Michael Kaufmann and Charles E. Emery, III. We are empicydd. by the iPennsylvania

! ~ Fish Commission, respectively, 'as Area Fisheries Manager, Southeastern Pennsylvania, and Ffsheries Technician for the Fish Commission. Our resumes are attached.

Mr. Kaufmann, would you describe the importance.of the Delaware River shad fishery, and the factors related to Point Pleasant's operation which may affect the fishery in the River generally, which would not be true of operation of a Delaware River withdrawal facility located at Philadelphia Northeast Sewage Treatment Plant?

3. Importance of American Shad Delaware River American . shad stocks have ecological, recreational and commercial importance. Juvenile American-4 shad are believed to serve as forage fish for resident pescivorous fish species. This is especially important to i

resident species in the reach from Pdint Pleasant downstream to the Trenton falls since a 1982 Pennsylvania Fish Commission fisheries inventory revealed that densities of resident forage fish such as members of the minnow family-are sparse.

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The abundances of juvenile and adult shad in the river system in any one year reflect the health of the river during that particular year as well as the system's health 4-6 years ago. The_ size of the juvenile shad population is dependent upon the number of adults successfully ' entering the river system in spring, the quality of the river as.a spawning and nursery site, and the suitability of the Delaware River Estuary as an outmigration route. The number of adult American shad entering the Delaware River system each spring is greatly dependent upon the. timing of the annual formation of the " pollution block" (zone of oxygen concentration less than that suitable for the survival of American shad as well as other fish species) in the Delaware Estuary. Timing of tlie " pollution block" formation depends upon Delaware River flow rates, water temperature, and the e

amount of organic and inorganic wastes entering the Estuary.

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Generally, the earlier in spring that the " pollution block" forms the less adult American shad enter the Delaware River to spawn and the less adult American shad return to the ocean following spawning. The Point Pleasant Diversion will reduce flows in the Delaware River and extend the " pollution block" temporally and spacially. The water diverted for Limerick at Point Pleasant will constitute a total loss of clean fresh water in the area most affected by the pollution block - the upper Estuary. Water diverted for water supply purposes will be returned to the Delaware Estuary as sewage treated by Bucks and Montgomery County. Sewage treatment 5

s plants in this area are already organically or hydraulically overloaded with no forecast of upgraded treatment. Thus, additional volumes of water and wastes entering the plants as a - result of the Point Pleasant Divarsion and regional' population' growth stimulated by increased water supply will be poorly treated or untreated. The additional wastes being discharged to the Estuary will further contribute to the

" pollution block" formation, essentially replacing good quality _ water (from an organic loading standpoint) entering the Estuary. from the river with poor quality water entering the Estuary from its smaller tributaries.

Adult American shad support a commercial fishery in the 4

Delaware Bay and Delaware River and provide an excellent, heavily utilized sport fishery in the Delaware River. The popularity of the sport fishery appears to increase yearly as measured by the number of telephone inquiries received at Pennsylvania Fish Commission offices and by the number of anglers observed along the river. The fishery satisfies recreational need and is financially valuable to commercial interests, including motels, camp grounds, food chains, gasoline stations, and sporting goods stores.

Historically the American shad spawn in the Delaware River from the Philadelphia area, m ecially the wetland areas surrounding Philadelphia, upstream to the headwaters of the Delaware River (defined as the junction of the East Branch and the West Branch of the Delaware). In more recent 1

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years, or I should say in the industrial age and the age in which we saw Philadelphia and Camden grow in terms of industrial power as well as population density, pollution has greatly limited the ability of American shad to spawn in the lower Delaware. There is a process called Formation of the Delaware Estuary Pollution Block. This process involves a yearly formation of a zone that lacks suitable amounts'of dissolved oxygen for the passage of American shad through that zone a.nd sometimes even lacks enough oxygen to support any fish life. This forms as a result of warm water. temper-atures, high amount of organic material commonly called sewage entering the estuary, and high amounts-of inorganic material from industries entering the estuary and causing a-large dissolved oxygen lag. The pollution block sets up as early as May in some years and lasts as late as October in some years as well. During this time fish cannot pass through the Delaware Estuary. Getting back to the American shad if the pollution block sets up in May, even -right in the middle of the American shad run, shad who have come in earlier can continue up into the upper Delaware to spawn, but those that arrive in the Delaware River and the Delaware Estuary after the pollution block h'as set up, cannot migrate up river to spawn and must return to the ocean.

There are two theories regarding the absence of American shad spawning in recent years in the lower Delaware River. One concerns the juvenile american shad and the 7

other concerns the adult. Considering. the juvenile it is thought that possibly the juvenile American shad that had hatched in the lower Delaware River remain there until they proceed that the pollution block had disappeared in Fall.

Quite often, however, when they began their out migration the pollution block in fact had not disappeared from the river, it was only a temporary disappearance and closed in on the fish and resulted in a massive fish kill. It is possible that the genetic stock that spawn in the lower river was wiped out in this way.

Concerning the adults, the pollution block of ten sets up in May and limits the extent of the American shad run.

It is felt that possibly the adults that used to spawn in the lower Delaware River were late arrivers to the river and therefore would-have been eliminated from the lower Delaware River by the early formation of the pollution block. In the absence of adult spawning in the lower river over a number of years there is a probable ~ loss of the gentic stock of late arrivers. Another possibility is that the late arrivers are somehow different in their biological clocks, are not necessarily genetically attuned to the lower river but just arrive late an are still present in the ocean system but cannot make into the lower river to spawn, because the formation of the pollution block. At any rate the adults that would spawn there Pave not or do not make 8

into that area in years when the pollution block sets up in May and June.

With improved sewage treatment especially in the Philadelphia area, and especially-with the coming on line of upgraded sewage treatment plants by 1984 in Philadelphia, it is thought that the pollution block will be decreased in space and in time. This will allow late arriving adults to enter th,e lower rive \r and begin spawning again.

As a matter of fact in larger American shad runs that have occurred in 1980 and 1981, it is believed that the adult American shad have spawned down stream from the Delaware Water Gap further than they have in recent' memory.

This idea is supported by observations of waterways patrolmen in Northampton County who has noticed spawning activity by adult American shad in his portion of the*

Delaware River and also, by observations of biologists in New Jersey who have been sampling'the Delaware. River for a number of years for Juvenile American Shad. They have observed that the Juvenile American Shad have shown up much earlier in the Trenton area in 1982 than they have in years previously.

This-all suggests that the Point Pleasant area could become in the very near future an important spawning site for American shad. Furthermore, the importance of this area 9

may be - increased if the project goes through since the adults that are running upstream will thus be concentrated in the portion of the river below the Wing Forks dam. Even at this time such passage facilities are built along the dam since fish passage facilities at best are about 85 to 95%

efficient in passing adult American shad. If the lower river does become an important site for spawning of'American shad, especially in the Point Pleasanf' area, this could could Icad to greater and greater impingement and trainment of eggs and juvenile American shad or viable American shad

, by the Point Pleasant intake, which I wll disucss in more detail later.

Turning to more localized impacts, Mr. Kaufmann, how would you rate the Point Pleasant area as a fishing spot on the Delaware River?

The Point Pleasant area is one of the 6 best shore fishing spots from Trenton upstream to Easton at least with regards to shore fishing. Its probably the second best shore fishing spot for American shad and also l probably the second best fishing spot for walleye in l

l the lower Delaware River.

Why is that one of the better spots from the shore?

What makes it such a good shore fishing spot?

It is one of a few areas along the lower Delaware River where the public can park and gain access by foot I

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across the canal and directly to the river. Its also an area where American shad happen to'come close enough to the shore line that fisherman can - cast to the fish and capture them.

You talked about American shad, how about for other species in the Point Pleasant area?

In February and March the Point Pleasant area especially near the mouth of the Toohilkon Creek is particularly popular as a White Sucker Fishery and as a Walleye Fishery. We believe that after the ice goes out on the river that the Walleye congregate in the area near the mouth of Toohilkon Creek for the purpose of spawning. And in fact our waterways patrolmen have captured reproductively ripe female Walleye at that locatiori suggesting that it is a spawning site.

How would you rate approximately how many people are utilizing this area and the Point Pleasant area for Shad Fishing and maybe Walleye Fishing from February to May?

According to the local wdterways patrolmen Stan Pleavack who patrols that area and also fishes in that particular location, up to 25 fishermen may be seen on a weekday or on a weekend day in February and March trying for Walleye, Muskellunge and White Suckers in the Eddy and the mouth of Toohooken Creek. In April 11

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and May the same number of fishermen, and this is shore fishermen I am ' speaking of, may be seen on any given day.

Is this shore fishermen on the Pennsylvania side and the' Jersey side or just the Pennsylvania side?

These shore fishermen are those that are being counted only on the Pennsylvania side both for Shad and for the Walleye Fishery.

Could you tell us how many boat anglers are in this same area, during the same period fishing. for the same species.

Again, according to the waterways patrolmen both for the Walleye Fishery. and Muskellunge and for the ,

American Shad Fishery and that is the months of February through and including May, anywhere from 2 to 8 boats may be seen each containing up to anglers per day at that location, d:.tr'ing those months.

l What is the importance of the Point Pleasant site to l "

! Short Nosed Sturgeon?

It is possible 'this site is a spawning area for short l

l nosed sturgeon and if that is the case it is probable that larvae will be entrained by the Point Pleasant intake. If the zoo plankton samples could have been taken at this 12

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particular site that is the Point Pleasant site, however, to my knowledge know if the zoo plankton. Furthermore, sampling at the site to try to determine whether or not the site was being utilized by adults was done during months that according to the information and the short nosed sturgeon recovery plan by the National Marine Fishery Service are months that that the short nosed sturgeon would be least likely to be found at that type of location.

According to that plan short nosed sturgeon ascend the rivers in spring and may be present throughout the summer and descend the river in fall. The gill netting operation occurred from October through early December and is quite probable that even if short nosed sturgeon had been in the Point Pleasant area that they would have left that area by the time the gill netting survey began. (end of tape)

Why is Point Pleasant so important for shore fishing?

Due to accessibility.

What impact could the operation of the project have on the fishery?

The addition of the intake structure could very well destroy the Point Pleasant location as a shore fishing location for American shad. Shad often utilize a narrow line of travel while ascending a river, even through the entire river appears suitable for upstream migration. At 13

present, shad pass close enough to shore for anglers'to cast to the fish. With the addition of the intake the_ migration route ' may be distributed to the degree that the shad pass farther. from shore, making it impossible to reach the shad by casting from the shoreline. If this occurs one of the six shad shoreline fishing areas on the Delaware in Pennsylvania between Trenton and Easton will be lost.

What impact will Intake have on Fish in the immediate Intake Area?

The physical structure can and will probably a'ffect flow patterns in the River. This could have an effect on the resident fish population changing their utilization of said area.

The structure after construction and being 70 ft. by 10

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ft. roughly provides an excellent physical area for fish to congregate and/or spawn in or around. The smaller fish, eggs and larva could hence be su'sceptible to impingement or t

entrainment by t,he presence of the structure, especially with the anticipated on/off use of the pumps. A constant flow or water draw over the entire structure is more agreeable than a constant on/off period or limited use of portions of the structure. A constant withdrawal will condition fish to stay away from the structure. This appears not to be the case. Also, there is a seasonal or yearly effect in that fish could be drawn to the structure 14

over the winter and early spring because of its limited use and hence smaller larva eggs fish could be entrained or impinged. The structure will be likely to congregate fish.

If the structure is not located in the best possible flow condition i.e. flows greater 1.0 fs its potential to impinge fish is greater. It appears that_the structure is not located at the best possible location.

It appears that there is enough not seasonal of flow by month and year that a minimum 3,000 cfs cannot be. always assured hence the proposed maintenance of a minimum 70 ft.

water elevation aboard the structure can also not be met providing for a greater potential for relative flow velocities through the structure to be greater than one half of ambient velocities, increasing the probability of impinging fish.

O Summation of Facts The location of the structure at the Point Pl'asant e Pool not being in the best possible flow conditions (flows greater than 1.0 C..P.S.) i.e. not in channel, seasonal and yearly variation in flows in the river covering a drop of river water elevation to less than 70 ft. and an operational mode of on and off operation definitely increase the potential of impingement of larva, Walleyes, American Shad, and food organism utilizing by Walleyes and American Shad 15

)

and~other fishes. This could render this area useless as a successful spawning site and nursery.

Again the on/off use of the. screen operation especially in March could adversely impact Walleyes' spawning success in the Point Pleasant area due to the susceptibility of larva fish to inpingement. Walleye do congregate to spawn in the Point Pleasant area.

The physical size of the intake structure fand the rubble --created during construction will cause the area around this structure to congregate fish around the structure especially small fish _ seeking shelter from larger fish. These small fish may be impinged especially during this use of an on/off operation cycle.

All of this probably will decrease the effectiveness of this area as a successful spawning site for Walleye and American Shad due to the impingement of larva Walleye and

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American Shad and American Shad Eggs. There will also be a-loss of food organism utilized by the above species due to impingement and entrainment.

NOTES:

1. Shad at P.P. - the importance of P.P. pool area appear to be highly susceptible to anglers both from shore and boats, especially boats, heavily used in spring 16 i

t .

, e few areas along river-where both shore and access and boat access are available to public presently or near future an area of importance for spawning

' Effects of Construction

. - possible disturbance of run if work is done in spring due to blasting, ? general activity in river causing fish to head back down stream.

loss of use by angler's if done in spring Structure s

change of migration patterns affecting angler success due to the physical structure ,

operation of unit could cause disruption of migration patterns due to back flushing, on/off situation i

Eggs & Larva 17

F Possible entrainment more likely impingement 'especially , if operated at an off/on mode rubble created by the building of structure could catch eggs and/or larva.

Spring time the period.when on/off use of pumps will most frequently occur..

Juvenild physical structure of a screen could change P.P. Pool area or an already known nursery area for Juvenile Shad. Known area - by our work and Rel. Anadromous Fisheries Study -

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screen could impinge food organism of _

juvenal shad, walleye larva, etc.

es'pecially during low flows Point Pleasant - Fishing Spot

1. Very popular fishing spot from both shore and boats. Probably one of the best shore fishing spots between New Hope and Easton,

a. Walleye

b. Shad 18

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c. Suckers,~Smallmouth Bass, Sunfish

2. Intake structure will become a source for a loss of lures, hooks, monofilament, etc.

a. These lures, hooks, etc. will-gradually clog the intake structure thus increasing the potential velocity thru the intake. This material will not be removed via cach flushing.

b. The loss of the lures, hooks, etc

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will also become a very real threat to rafters or tubers who will come down over this ob;ect. Hooks could become embedded in the rafters er tubes.

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19

What

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Mr. Emery, techniques are proper to capture _

Juvenile American Shad at Point Pleasant?

The best time to sample for J. A. S. is at night in a pooled area along the shore. This takes advantage of the following J.A.S. habits coming out of the depths of the pool area to feed on diphtheria larva at night along shore are as well as other insects which more readily utilize still on calm water versus flowing area. If you sample 6.uring the day you are less likely to capture many or any A.S.

What techniques has R.M.C. used?

When sampling for fish we normally use night electrofishing employing a hand held electrode using DC voltage boat electrofishing units. Our electrofishing unit allows us to effectively fish all habitats whether shallow or deep and our choice of night work also allows us the greater potential to catch fish which are less wary at night and in the morning are out of deeper areas to shallow areas seeking' food. On September 7, we encountered a R.M.C. work crew at P.P. doing water samples. They indicated to us that they had been sampling lately for fish during the day using fixed boom D.C. voltage boat electrofishing units. R.M.C.

indicated they had only encountered a few A.S. during their sampling of the week of August 30, while we found quite a few fish. Fixed boom electrofishing units generally do not allow a boat to get very close to shore especially if the 1

w

e shore is shallow or strewn with debris or over hanging trees. Differences in techniques can and will yield different results.

Mr. Emery, have you had previous experience with RMC?

While reviewing I.A.(the former home of RMC) studies conducted at major water uses along the Delaware River (as part of E.P.A. 316-B studies) I noticed that their impingement rates were consistently lower than those collected by the Delaware River Anadromour Fisheries Study (whom I was working for at the time) of U.S.F. & W.S. at Rosemont, N.J. One day I ran into a sampling crew of I.A.'s at the Eddystone Power Plant which we were also going to be sampling. It was at this time that I found out the difference or the reason why our rates of impingement were different from those of IA's. It was based solely on

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sampling procedures. First, some background.

Traveling screens at Power Plants are operated by two

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methods, a pressure differential gauge (P.D.G.) or manual operation. The P.D.G. operates in such a manner that when a certain pressure is reached on the river side of the screen, the screen is rotated because it'has become clogged with debris or fish. Manual operation is based on a time period 3 hrs. or 4 hrs. the screens are then ran and cleaned.

Normal plant operations at all of the plants that I have ever been at has a shutdown time of generally 3 - 8 hrs.

depending on the time of year. During high leaf flows in 2

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the River some plants do run screen continuously; this is, however, very typical of plant operations. Screens are not run all of the time because of all the expected reasons,

- 1.e. increased maintenance, higher operational costs, increased ~ wear and tear etc. So again, normal plant operations of screens include long hours of shutdowns.

Longer hours of shutdowns does increase the amount of debris and fish collection, as this increases so does the velocity rate through the screen.

In this case, I.A. sampled all of its plants by rotating their screen, whereas our sampling consisted of set periods of non operated screens. Our impingement were higher than theirs. Both of us sampled the same plants over the same amount of time but utilizing dif ferent techniques coming up with different results.

Another -example: capture of Adult Shortnose Sturgoen can only be accomplished in Spring time, Brundage did his study in Fall.

l As you can see, you can sample and then again you can 1

i sample.

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NAME: Michael Lee Kaufmann AGE:- 30 ADDRESS: ~ Box 556 BIRTH DATE: May 12, 1952 Revere, PA 18953 HEIGHT: 6' l-1/2" TELEPHONE: (215) 847-2442- WEIGHT: 175 lbs.

8 am - 4 pm MARITAL STATUS: Single EDUCATION The Pennsylvania State University University Park, Pennsylvania Degree: B.S. - Biology - June 1, 1974 Emphasis: General Biology,_ Wildlife Management Aquatic Biology University of Pittsburgh~

Studied at Pymatuning Laboratory of Ecology, June 1974.

Course: Identification and'Ouantification of Aquatic Plants Clarion State College Clarion, Pennsylvania Degree: M.S. - Biology - May 22, 1977 Courses emphasizing aquatic ecology and environmental biology were taken at Clarion and at Pymatuning Laboratory of Ecology.

Cumulative Average: 3.79 Thesis

Title:

The Growth and Ecology of Stocked Largemouth Bass (Micropterus salmoides Lacepede) o-in Kahle Lake, Clarion-Venango Counties, Pennsylvania, Including a Comparison of Collecting Techniques. (abstract attached.)

WORK EXPERIENCE Pennsylvania Fish Commission Fisheries Management Section Area Fisheries Manager, Southeastern Pennsylvania April 21, 1980 to the pr'esent.

Fisheries Technician, Coldwater Unit August 15, 1979 to April 20, 1980 Semi-skilled laborer and labcrer, Coldwater Unit April 18, 1977 to August 14, 1979 Duties were the same as those of a Fisheries Technician. .

Laborer May'through September, 1976 .

Duties included coldwater and river inventory surveys.

Major duties with the Fish Commission have included supervising or participating in river, lake, or cold-water stream inventory surveys across the state; preparing resource inventory reports; critically reviewing coldrater inventory reports submitted by A.F.M.'s; participating in Coldwater Unit research projects, data analysis; promoting programs through the news media, public speaking; providing critical comment on the impact of proposed water projects; introducing smelt to selected waters; providing fisheries technical guidance to waterways patrolmen,

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representatives of other agencies', and private individuals; and managing fisheries in an urbanized environment.

Bear Creek Lutheran Camp Corp., Box 132, Bear Creek, Pennsylvania 18602 Camp counselor - Summer of 1973, 1972, 1971, 1970 and 1968.

Ford Heck Florists, 1133 N. Eth Street, Reading, Pennsylvania 19601 Clerk - Christmas vacations 1974, 1973, 1972.

PUBLIC SPEAKING Central Pennsylvania Chapt. A.F.S., Perkioman Chapt. T.U.,

Ironstone Chapt. T.U., Endless Mtn. Chapt. T.U., Freestone Chapt. T.U., Valley _ Forge Chapt. T.U., Berks Co. Chapt. T.U.,

Falling Spring Chapt. T.U., Williamsport Chapt. T.U. - Expo.,

Loyalsock Creek Watershed Assn., Blue Marsh Bassmasters,

Lancaster Bassmasters, P.S.U. Wildlife Society,_ P.S.U. E.R.M.

Club, P.S.U. classes, Lehigh Univ. class, Clarion State College Biology Dept., Ursinus College Class, Schuykill R. Symposium, State College Indian Guides, Springtown R&G Club, Hawk Mountain Sanctuary.

l PUBLICATIONS f

Mulfinger, Richard M. and Michael L. Kaufmann. 1980. Fish passage at the Fairmount Fishway in 1979 and 1980 with implica-tions for the Schuykill River through future fishway construc-

! tion. Schuykill River Symposium. The Academy of Natural Sciences of Philadelphia.

l Kaufmann, Michael L. 1979. A literature review of "special regulation" use in coldwater fisheries management. Pennsylvania Fish Commission, Harrisburgh, PA. (mimeo.)

I

e RESUME .

Charles E. Emery, III Office Address Home Address Pennsylvania Fish. Commission 154 S. Main Street P. O. Box 556 Quakertown, PA 18951 Revere, PA 18953 (215) 536-1426 (215) 847-2442 EDUCATION Admitted and graduated from Thiel College, Greenville, Pennsylvania with a Bachelor Degree in Biology in June, 1971.

Attended the 1972 Pennsylvania Fish Culturist School held at Fisherman's Paradise, Bellefonte, Pennsylvania. Completed the school with a final grade average of 93%. Attended Alliance College, Cambridge Springs, Pennsylvania. Water Quality Awareness Lab and Session, October and November of 1972 and April and May 1973.

WORK EXPERIENCE Joined the Pennsylvania Fish Commission, November 1, 1971 as a Fish culturist I, at the the Huntsdale Fish cultural Station, Huntsdale, Pennsylvania. Performed all the duties and responsi-bilities required of a Fish Culturist and was recommended for permanent civil service status.

, Transferred June 19 to July 22, 1972 to work with Mr. Jack ~.

Miller, Chief, Fisheries Environmental Services Branch of the Division of Engineering and Mr. Robert Hesser, Chief Fisheries Management Section Division of Fisheries at Pleasant Gap.

Assignment was for educational purposes through working with various- organizational levels with the Pennsylvania Fish Commission.

Transferred from Pleasant Gap to the Linesville Fish Cultural Station July 22, 1972 to assume the duties of the principal investigator for the sito projects (Projects No's l 3-110-R and 3-112-R) . These projects were funded under the Federal Commercial Fisheries Act. Promoted from Fish Culturist I to Fish Culturist II, January, 1973. Duties of the principal investigator include the following: data collection with various l types of equipment; daily caring for fish in the silos; performing various tasks related to the operation of the silos; administration work and report preparation as well as supervising other Fish culturists in the performance of tasks around the silos.

Promoted from Fish Culturist II to Fisheries Technician I, December, 1973.

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Transferred April 28, 1975, at the conclusion of the silo project, to the Delaware River Anadromous Fisheries Project under the direction of Joseph Miller, United States Fish and Wildlife Service, Rosemont,New Jersey. Field work included the entire Delaware River and Bay concentration on life history studies of the American Shad._ I specialized in the monitoring of major water users along the Delaware River for the impingement of fish.

Transferred February 1,. 1976 to the newly established South East Area Fisheries Management Office, Revere, Pennsylvania.

Duties included biological surveys of streams, rivers, lakes, ponds, and the estuary within the bain jurisdiction of the South East area office and the development of reports and management recommendations for the waters evaluated. Special projects within this area office include anadromous fish restoration efforts, fish rearing marsh development and tail race fisheries.

PERSONAL NTERESTS Activities include hiking, camping, fishing and wildflower identification. I have been involved with church youth groups and Boy and Girl Scout organizations over the last 20 years. I have also served in various community and civic organizations as well as the Girl Scout Board of Directors Freedom Valley Girl Scout Council Valley Forge, PA.

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, .,.& . h DIRECT TESTIMONY OF PROFESSOR PEIRCE LEWIS My name is Peirce Lewis. .I am Professor of-Geography at Pennsylvania-State University,. University Park, Pennsylvania. My curriculum vitae are attached. My specialty-is the study of vernacular human landscapes in the United States, a subject about which I have. written extensively for scholarly journals and about which I teach' undergraduate and graduate courses at Penn State.- I have been invited to

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i. lecture on these and related' subjects to academic and profes-i sional audiences throughout the United States and Canada.

.For more than twenty years, my studies have . focused particularly .

on vernacular-cultural landscapes of Pennsylvania, their historic origins and evolution, and their historic preservation.

I have been asked to review a number of documents ,

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including: (1) A Survey of Cultural Reso_urces_in the Area of the Proposed Point Pleasant Pumping Facilities, Combined

. . Transmission. Main, Bradshey Reservoi r, North Branch Main and

'Perkiomen Main, Bucks County, prepared by Edward E. Shortman 4

and Patricia Urban (1978) ; (2) Preliminary _ Case Report for Neshaminy Water Resources Authority,, Point Pleasant Diversion Project, Point Pleasant, Bucks County,,_ Pennsylvania, prepared by Elizabeth R. Mintz (1982); and (3) various reports, corre-spondence and testimony. submitted by the Bucks County ,

Conservancy to the U.S. Army Corps of Engineers and other I

agencies over the past few years, including a report entitled Point Pleasant IIistoric and Archeolo.gical District: Comments 4

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-on the Request for Determination of Eligibility by Ms. Mintz

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for the U.S. Army Corps of Engineers (1981). This testimony, which was written on September 19, 1982, is based on my reading of the above documents which include a description of the Point Pleasant Historic District and on a review of topographic maps of the area prepared by the U.S. Geological Survey and xeroxed copies of plans of the pumping facilities prepared by E.H. Bourquard Associates, Inc. for the Neshaminy Creek Water

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-Resources Development.P l an and. drawn to.the scale of about fifty feet to the inch. I have also seen documents to the effect that the U.S. Army Corps of Engineers, the Commonwealth of-Pennsylvania and the federal preservation authorities all agree that the Point Pleasant area is eligible for inclusion

- on the National Register of Historic Places.

As of the date of this testimony, I have not visited Point Pleasant , but I expect to do so before making formal oral testimony at the Hearing. It should be understood, however, that this testimony is based entirely on written and cartographic documentation, and not on firsthand experience.

On the basis of what I have read, there.seems to be general agreement that the village of Point Pleacant is a small but well preserved example of an early Nineteenth Century canal town whose basic form had taken shape before the end of

- the nineteenth century. Although there are many towns which owe their original prosperity to canal traf fic, most such towns have subsequently been greatly altered by railroad building and att endant industrial and commercial building.

p

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d The reason is obvious. Important canal. routes very often became important railroad routes, and railroads'not only wiped out the canals.themselves (often physically) they attracted industrial and comm'ercial growth which irreversibly changed the original character of the early canal' settlement.

That is what happened along the Erie Canal and along the main line of~the Pennsylvania Canal between Columbia and.Hollidaysburg

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In cases where railroads did not replace canals,those towns often fell into economic dcpression and then subsequently decayed beyond repair. That is commonly true in New England ,;

and-in upstate New York and in western Pennsylvania.where most buildings were made of wood and decay or change occured rapidly after the canal had gone into disuse.

Intact Nineteenth Century canal towns are relatively rare in the United States and there is consequently strong reason to pay special attention to preserving the ones that do_ exist.That is particularly true in places like nt Pleasant whose small-size makes them .particularly vulneruole to modern intrusions.

There is another reason why Point Pleasant appears to be especially important in historic terms. From my reading of available documents I gather that the village is a convunity

- with a strong vernacular flavor, not a place which is famous for its major historic monuments, but because it preserves the ordinary environment of the past and which continues to operate within the environment of the past. That environment is what

- preservationists have called in New Orleans the tout el.semble, y

more -than a single building, or tvio, sor. three, 'but 'rather the complete historic ambience. Such places are especially valuable because they~ help nourish " cultural memory" a-tangible...-

connection betwe.en contemporary Americans and ordinary people of the past. .The words " ordinary" and " vernacular" are crocial to historians and historical geographers like myself. By and large, our written history is written by and for famous people.- Ordinary people do not write history; instead, they build it. _

Thus, our knowledge of vernacular history necessarily depends on the presence of intact vernacular environments. ,

Unfortunately, however, Americans have rarely been very successful in preserving such ordinary environments.- But if they'have, as I gather they have done in Point Pleasant, the valne of such' places is particulary great. Significant changes >

in such environments should be undertaken only under the most pressing of circumstances.

Documents seem to suggest. that the pump station will be a fairly large scale affair, presumably much larger than-most of the buildings in Point Pleasant. It is easy to imagine this project could irreparably and irreversibly damage the histcrical ambience of such a small and fragile nineteenth century community simply because it is inconsistent with the nineteenth century scale and character of the town.

Experience shows that places like Point Pleasant of ten retain their historical charact er partly because their residents like their antique qualitie; and because they like the slower and quieter pace at which such communities go

_4_

about~their daily business.. It is-not hard to imagine that

' this: attitude'could~be changed markedly if local residents

' found noise from'the pump station to be objectionable, if

- they_found the coming'and. going-trucks, people and dredging equipment to be objectionable, if , in sum , they found_the arrival =of large scale twentieth cent'ury technology to be inconsistent with the nineteenth century environment which' 1

they have learned to enjoy and to. nourish. In short, the presence and operation of the pump station could easily undermine'the willingness 'of local inhabitants to work to maintain the antique qualities which have apparently combined to ,make Point Pleasant a desirable-place, partly as an outdoor

- museum of nineteenth century _ technology and life, but more -

importantly, as a functional link with an imp 6rtant time'in America's past.

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i July, 1982 Personal Vitae PEIRCE F. LEWIS Address: Department of Geography The Pennsylvania State University 307 Walker Building University Park, Pennsylvania 16802 Phone: (814) 865-6071 or 865-3433 Primary professional interest:

The American landscape--origins, morphology and symbolism Ancillary interests:

Historical geography of North American culture Regional geomorphology of North America Degrees earned:

Ph.D. (Geography), University of Michigan, Ann Arbor, 1958 M.A. (Geography), Univ 1rsity of Michigan, 1952 B.A. (Dual majors in Philosophy and History), Albion College, 1950 Post-doctoral study:

Geomorphology, University of Washington, Seattle, 1957-8, under J. Hoover Mackin, Department of Geology Quantitative methods in Geography, Northwestern University, N.S.F. summer inst it ut e, 1962 Primary academic positions:

Professor of Geography and member of the Graduate Faculty, Penn Ftate Uni-versity, University Park, Pennsylvania. 1962 to present.

Assistant Professor of Geography and associata mcmber of the Graduate Facul ty, Penn State University. 1958-196?.

Lecturer in Geography, University of Michigan extension. Summer, 1958.

National Science Foundation post-doctoral tellow in gecaorphology. Department of Geology, University of Washington, Seattle. 1957-58.

Metropolitan Community Fellow in urban political geography. Interdisciplinary program, University of Michigan, Ann Arbor. Academic Year, 1956-57.

Teaching fellow, Department of Geography, University of Michigan, Ann Arbor, 1955-56.

Geegrapher, Military Intelligence Branch, Far East Command, U.S. Army Forces, Tokyo, J. pan. (Research in the economic geography of continental Asia; civilian status). 1953-1955.

M.:p librar ian , Department of G.ography, University of Michigan, Ann Arbor, 1952-1953.

.11rsonal' Vitae, M 1R G F. LUGS--2

' Concurrent academic positions:

Visit ing. prof essor , Seminar s in American _Cul t ure, New York State Historical Association, Cooperstown, Summer, 1981 Visiting ~ professor, Department of; Geography, University of California,

' Eerkeley, aut umn 1976.

Visiting professor, Department of Geography, Concordia University, Montreal, summer, 1976.

Consultant and local author, Comparative Metropolitan Analysis Project (research program funded by the'N.S.F. and sponsored by the Associ-ation of American Geographers). Field and archival research on the historical urban geography of New Oricans. 1973-74.

Research associate, University of Montreal, with Prof. Pierre Dansereau.

Field research on the folk architecture of St. Lawrence estuary and Canadian Maritime Provinces. Summer, 1970.

Co-director (with Frederick I. Wernstedt), Experienced Teacher Fellowship Program in Geography, undec the auspices of the U.S. Office of Education, Penn State University. 1967-68.

National Science Foundation Fellow, Institute for the Study of Quantitative Methods in Geography, University of Chicago and Northwestern University.

Summer, 1962.

Honors:

Phi Beta Kappa, 1950 Oaicron Delta Kappa (Undergraduate men's leadership honorary, 1950),

Phi Kappa Phi, (Graduate academic honorary),1956.

5 First prize of $1,000 awarded by the Association of American Geographers for1 the best paper by a geographer under the age of 35; XIX International Geographical Congress, Stockholm, Sweden, 1960. _

Society of the Sigma Xi, 1962.

National Honors Award, Association of American Geographers, 1977, "for truly perceptive and eloquent studies of the evolving human scene in North America, for creative scholarship, advocacy, and teaching that have so greatly increased our sensitivity to the way in which habitat, history, society, and culture have interacted to mold the fascinating ever-changing landscape."

Christian R. and Mary F. Lindback Awa rd for distinguished t eaching, $1,000, Pennsylvania State University, 1981.

, Distinguished Teaching Award, National Council for Geographic Education (One of nine awards in North America),1982.

Awards and grant s:

Association of American Geographers grant for study of American verna-cular landscape, 1976-77.

Pennsylvania State University, Faculty Research Fund Crants, to support research on the following' t opics:

I Irages of Antrica's past vernacular landscapes: the pictorial

holdings of the Federal Governi.ent. 1979-61.

Evolution of physical and cultural landscapes of central and eastern Pennsylvania. 1978-79.

hersonalVitas,PEIRCEF. LEWIS--3

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Awards and grants continued:

Evolution of the landscape of New Oricans, 1973.

Rise and decline of Bellefonte, a small town in Pennsylvania.

1971-72.

Studies on the diffusion of folk architecture from New England through New York State in the 19th Century. 1968-69.

Studies on the origin and significance of the landscape divide between Pennsylvania and New York State. 1963-70.

Investigation of.the effect of Negro migration on the urban political-Ceography of Flint, Michigan, from 1932 to 1962. _1963.

Studies of the origin of various linear sand dune forms in the western United States. 1961-62.

Laborat,ory analysis of grain-size of loessial samples from the Palouse Hills, Washington-Oregon, 1960.

Association of American Geographers grant for support of studies on the diffusion of folk architecture from New England through New York State.

1968-69.

U.S. Office of Education grant to organize symposium of experienced high-setnol teachers, national meetings of the National Council for Geographic Education, Houston, Texas. 1969.

U.S. Office of Education grant'for Experienced Teacher Program in geog-raphy, Penn State University. 1967-68. (Co-recipient with Frederick L. Wernstedt).U.S.O.E. granted a subsidiary award in 1968 to support a symposium of the same teachers at Penn State for the purpose of re-evaluating the original program.

National Science Foundation Fellowship for attendance at Summer Institute for the Study of Quantitative Methods in Geography, University of Chicago and Northwestern University. Summer, 1962.

National Science Foundation grant for attendance at the International Geographical Congress, Stockholm, 1960. (Grant was refused because of simultaneous award from the Association of American Geographers; see " honors", above).

National Science foundation Post-doctoral Fellowship with Prof. J. Hoover Mackin, Department of Geology, University of Washington, for study and research in map interpretation and the geomorphology of the United States. 1957-58.

Horace H. Rackham School of Graduate Studies, University of Michigan, for cartographic work associated with research in urban political geography. 1956-57.

la u nal T o e, r L b c t F . ' L L i n- l.

Membership in professional organizations:

A .erican Studies Association Association of American Geographers

-Pioneer America Society i

National Trust for Historic Preservation The Cobblestone Society University services:

University Senate, Penn State University, 1962-1968.

University Faculty Affairs Committee, Penn State University, 1962-1968.

l The Dean's Committee for reorganization of the College of Mineral Industries, Penn State University, 1963-1965.

Faculty Advisor- and Resident Professor, Penn State University Study-Abroad Program, University of Salamanca, Salamanca, Spain, 1964.

President's committee for the Regional Planning Curriculum, Penn State l University, 1970.

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Committee for Promotion and Tenure, College of Earth & Mineral Sciences, Penn State, 1976-present. -

Chairman (elected), Geography Dept. Committee for Promotion and Tenure, Penn State, 1978-80.

Review Committee, Graduate Program in Architecture, Penn State University, 1980-81.

Search conmittee, Dean of the College of Arts and Architecture, 1981-82 Professional service:

Cocmit tee on the Teaching of Local Geography, High School Geography Project (A. A.C. /N. S.F. ). 1965-1970.

Representative of the Association of American Geographers to the U.S.

National Committee for the International Geographical Union. 1966-1970. -

Steering Committee, National High School Geography Project (Association of j American Geographers / National Science Foundation). 1966-1970.

Committee on the use of topographic maps to illustrate cultural geography, Commission'on College Geography, Association of American Geographers, 1967-1972. I Visiting scienti'st, Association of American Geographers / National Science I Poundation, 1969-71, 1981-Chairman and organizer of special session on Visual Blight in America. 1972 meetings of the A.A.G., Kansas City.

1 Research Committee, American Geographical Society, 1974. 1 l

Cont ributing Editor, Pioneer America, 1975-1978. I Chairnan, National Honors Committee [ elected), Association of American 1 ceographers, 1977-78 I National Councillor (elected at large by national membership), Association of American Ccographers, 1981-1984.

Editorint Roard, Journal of Hist orien1 Geograghv, 1932 -

Vice-Precid..nt (v1.cted), Association of American Ccographers, 1982-83.

Con unity service:

i State College (Pennsylvania) Borough Traf fic Cornission member, 1968-1970.

Co-author,

! State College (Pa.) sign-control ordinance, adopted into law, 1969.

Stat e College Borough Planning Commission mcaber, 1969-1976.

~ Beard of Directors, Pennsylvania Roadside Counciln_11 N "

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Personal vit ae, PEIRCE F.' LEWIS--S

. Courses regularly taught-(The' Pennsylvania State University)':

1 LANDFORMS OF TiiE WORLD.(Geog.'2) Elementary geomorphology for -non-

' specialists. The study of. landforms: .their geographic distribution, their origins, and their relationship to human activity. Exclusively-for undergraduates. Lecture and11aboratory.

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~ GEOGRAPHY OF INTERNATIONAL AFFAIRS (Geog. 28) ~ The~ geographic foundations of  ;

world politics, with' emphasis on international tand intranational con fli ct . Primarily undergraduate foreign service students.

. THE AMERICAN SCENE (Geog. 102) How Americans' converted wilderness . into .

-domesticated landscapes, and. how the American scene visibly reflects national.and regional cultures. Primarily for non-majors. Extensive

l. field work,- designed to teach students to " read" cultural meaning in ordinary landscapes created by ordinary Americans.

• TiiE AMERICAN SCENE II (Geog. 404) liow Americans created a modern national' .

landscape, while spreading the nationalidomain from.the Appalachians to the Pacific. An upperdivision course, aimed at undergrad,uate seniors and' graduate students. Emphasis on western landscapes of recent date.

l. Prerequisite: Geography.102,'which emphasizes castern landscapes created during colonial and early national times.

FIELD SEMINAR IN VERNACULAR LANDSCAPE STUDY (Geog. 525 ) . Advanced seminar for graduate students and exceptionally capable undergraduate students.

Intensive study of. regional landscapes in the eastern U.S. and eastern Canada,1 culminating in a 14-day field trip in late spring.

The ' purpose of the se:ainar is to apply the techniques of landscape-

. reading learned in classroom and local field work. Prerequisites:

4 Geography 102 and 404 -

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Geography 404, "The American Scene 1I", was first offered in the spring of 1982' l on an experimental basis. It is being proposed to the Pennsylvania State-j University Senate Committee on Curricular Affairs for permanent inclusion in

! the curriculum. It will be offerred annually.

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1 Personal ~ vitae, PEIkCE F. LEWIS--6 Invited lectures, 1978 to the present*

1978 Macalester College, St. Paul, Minnesota,(Keynote address, Symposium on Neighborhood ~

Conservation)

University of New Orleans (Sociology Department seminar)

Pennsylvania Council for Geographic Education (Keynote address, Clarion, Pennsylvania) ~

University of Northern Colorado, Greeley (University lecture)

Historic Deerfield, Massachusetts (Summer session lecture)

University of Southern Mississippi, llattiesburg (Conference on a Sense of Place .

and Public Policy in Mississippi)

United States Military /cademy, West Point ,

_197__9 Pennsylvania State Hi storic and Museum Commission, Harrisburg (Keynote address,

first statewide cenference on historic preservation in Pennsylvania)

Charleston Neighborhood Association, Charleston, South Carolinar#

University of South Carolina, Columbia (Department of History seminar and Department of Geography lecture) ,

Yale University (Department of the History of Art general lecture)

Indiana University of Pennsylvania Indiana State University, Terre Haute Ohio University, Athens (University lecture)

University of Tennessee 1980 University of British Columbia, Vancouver Sincn Fraser University, Burnaby, - Brit ish Columbia University of Vict oria, British Columbia East Carolina University, Greenville, North Carolina University of Maryland (Keynote address, Conference on landuse in noneetropolitan ,

America, sponsored by National Science Foundation and Association of American Geographers) -

Stetson University, DeLand, Florida (University lectare)

College of Charleston, South Carolina (Department of Fine Art conference on historic preservation)

Yale University (Department of the History of Art seminar on map interpretation) 198_1_

Florida State University, Tallahassee

. Qucen's Universi ty, Kingston, Ont ario University of Kentucky, Lexington (Ellen Churchill Semple Lecture)

State University College of New York at Onconta New York State Historical Association, Cooperstown (Week-long series of lectures)

- Frcnklin and Marshall College, Lancaster, Pennsylvania (Department of Art lecture)

Millersville State College, Pennsylvania York College of Pennsylvania (History Department and College lectures)

American Studies Association (Special session on material culture) 1982 (to date)

University of Marylar.d, College Park University of Miani, Coral Cables, Florida Shippensburg State College, Pennsyvlania (College symposium)

ass ichusett ts Institute of Technology (School of Architecture and Planning)

Cent ral Connecticut State College, New Britain Oklahoma State University, Stillwater (Society for the N. American Cultural Survey)

• Coonraphy Departnent invited lectures unless otherwise specified

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+

Publications A irce Levia,_The Pennsv1vania St a t e Ujtiy.e_r_sity) , p. 1

-1960 " Linear Topography in the Southwestern Palouse, Washington-Oregon," Annals of the Association of American_Ceographers 50 (2): 98-111. (Awarded first prize, $1,000, A. A. G. Participation Fellowships, 19th International ~Ceo-graphical Congress, Stockholm) _ _

Reprinted in Fred E. Dohrs and Lawrence M. Sommers, Physical Geography,

_ Selected Readings, Thomas Crowell, New York,1966: 92-102.

1961 "Dictiotomous Keys to the KUppen System," The Professional Geographer 13 (5): 25-31.

1963 " Questions Geographers Should Ask," The Pennsylvania Junior Geographer 2 (1): 23-29.

1965 " Impact of Negro Migration on the Electoral Geography of Flint,: Michigan, 1932-1962: A Cartographic Analysis," Annals of the Association of American Geographers 55 (1): 1-25.

Reprinted in Roger E. Kasperson and Julian Minghi-(eds.) The Structure ,

o_f Political Geography, Aldine, New York, 1969: 364-406.

1967 "The Vicinity of State College: .Being an Introduction to Divers Aspects of the Physical and Cultural Geography in a Certain Part of the Appalachian Mountain Region . . . ," prepared for.the Symposium of the Geography of Population Pressure upon Physical and Social Resources, University Park, Pa.

(Multilithed).

1968 "On Field Trips in Geography," in J. F. Hart - (ed.), _ Field Training _in Geograp1y,, Association of American Geographers, Washington, D.C.: 51-66.

2 1970a "The Geography of Old Houses," Earth and Mineral Sciences 39 (5): 1 'i .

1970b " Aesthetic Pollutita: When Cleanliness Is Not Enough," Public Management 52 (7): 8-11. .

1971 (with Kenneth Corey, et al.) The Local Community. Macmillan Company, New York.

1972 'tmall Town in Pennsylvania," Annals of the Association of American Geographys_ 62 (2): 323-351. Reprinted in J. F. Hart (ed.) R_egions of the United States, Harper and Row, New York: 323-351.

1973a (Ed.) Visual B_ light in America. Commission on College Geography Resource Paper, 23, Association of American Geographers, Washington.

1973b "The Geographer as Landscape Critic," in Visual Blight in America (see 1973a): 1-22.

1974 "The United States: the Natural Landscape." The Encyclopaedia Britannica, 15th Edition, Vol. 18, Chicago: 905-918, 945.

1975a "Cormon Houses, Cultural Spoor," Landscape,19 (2): 1-22.

. Publications (Peirce_,_ Lewis), p. 2 1975b "To revive urban downtowns,'show respect for the spirit of the v place," Smithsonian 6 (6): 32-41. (Originally titled "Cenius Loci and the Preservation of Place," a paper invited for ' pre-sentation at the American Association for the Advancement of Science meetings, New York, January, 1975.

'1975c "The Future of the Past: Our Clouded Vision of Historic V Preservation," Pioneer America 7'(2): 1-20.

1975d ers," and "A Map "TheLandofPenn'sWoods,""TheEarlySettpRobertSecoretal.

for Revolutionaries," in Pennsylvania 1776, (eds.), The Pennsylvania State University Press, University ,

Park and London, 17-31, 80-99.

1976a New Orleans: the Makings of an Urban Landscape. Ballinger Publishing Company'(Lippincott), Cambridge, Mass.

1976b " Axioms of the Landscape: Some Guides to the American Scene."

6-9. (Special Journal of Architectural Education 30 (1):

edition, edited by John B. Jackson).

1977 "La restauration du patrimoine aux ftats-Unis: evaluation critique et orientations," Cahiers de g6ogr_aphie de Quebec, 21 (53-54), 269-292.

1978a "The Architecture of Agribusiness -Reflections on Ambiguity in the Landscape," Pioneer America, 10 (1), 4-6.

1978b " Book, Tube, and Picture: Being an Appreciation of Peter Spier's Illustrated Books for Children." Pioneer America, 10 (2): 14-27. .

1979a " Axioms for Reading the Landscape: Some Guides to the American Scene." In The Interpretation of Ordinary Landscapes, Donald W. Meinig (ed.), Oxford University Press, New York and Oxford, 11-32. (Expanded version of 1976b, above).

1979b (With Ben Marsh) " Slices threugh Time: the Physical and /

Cultural Landscapes of Central and Eastern Pcnnsylvania. In The Philadelphia Region: Selected Essays and Field Trip, Itineraries, Roman A. Cybriwsky (ed.), Association of American Geographers, Washington: 1-50.

1979c "The Unprecedented City." In The American Land, A. Doster et al (eds.), Smithsonian Institution, Washington, and W. W.

Norton, New York: 184-193.

1979d " Defining a Sense of Place." The SouthenLDutrimly 17 (3 & 4):  !

24-46.

Reprinted in Peggy Prenshaw and Jesse McKee (eds.), Sense of Place: Mississippi, . University Press of Mississinpi, Jackson:

24-46.

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. Publications (Peirce,_ Lewis), p. 3" 1980 "When Ameries Was English."~ The Geographical Magazine-(London) 53 (5): 342-348.'

1981a' "The Urban Idea on America's' Western Frontier" (ReOfew article).

Journal of Historical Geography 7 (1): 95-100.

1981b "Cypsies at the Wheel." Landscape 25 (3): 37-38.

1982 " Facing Up to Ambiguity." Landscape 26 (1): 20-21. .(Modified from 1978a, above).- -

Short book reviews, abstracts, and unpublished field guides are omitted from this list.

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DIRECT TESTIMONY OF SAMUEL LANDIS The Point' Pleasant area north and south of the Tohickon Creek promises to be of great archeological significance for a variety of reasons. Because the area represents a river flat subject to periodic flood deposition, there exist well stratified cultural levels of prehistoric occupation. By studying such stratified sites, we, can piece together the archeology of an area as well as define 'and develop the chronology of an area.

In additi6n', charcoal samples which can be recovered from these stratigraphic profiles enable absolute dating for lithic materials

/ and artifacts. recovered from within the.' ame contexts.

Point Pleasant has also been well known for many years as the primary location from which the prehistoric inhabitants of n o the middle Delaware Valley quarried argillite had j metamorph'(sed s

/ shale fohynd in the upper beds of the Lockatong Shale Formation.

This lithic material was used extensively in the area by prehis- 7 toric inhabitants to manufacture and fashion projectile points and a variety of other tool forms. On the slopes adjacent to .Gaddis .

Run, a tributary of the Tohickon Creek, there remains substantial kr.. h&m evidence of quarrying activities. At these' lithic . production

- dCWitagC areas vast quantities of depotage, along with hammerstones, can bc zA l

found!bbtheriverflat, the site of extensive A htg.co. ,4 prehistoricoccupationp/ .hppearsi that ode can actually follow the course of the lithic! tool manufacturer from the quarries to the village site. This situation -- a well stratified village

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site immediately a'djacent to a prehistoric lithic material source,--

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is indeed unique in the Delaware Valley. g Detailed scientific s ,,a evaluationpfofjimportant and heretofore unknown facts can be s

utablishedI*such as cultural exchange patterns, settlement

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patterns, travel patterns and chro.nological sequences determined by radiometric dating procedures regarding the prehistoric inhabitants of the Delaware Valley. Additionally, and of paramount importance in the Point Pleasant area, is the site partially excavated by Dr. Henry Mercer, 1893. What motivated Mercer's investigations was the single but extremely difficult question: How long had prehistoric man lived in the New World? This question concerning the

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ve antiquity of man in the New World probably the central issue of Nineteenth Century archeology. One side of the debate on this issue was represented by Dr. Charles Abbott of Trenton, New Jersey.

Abbott believed that crude implements found in association with the. river gravels near Trenton,'U whqich closely resembled ancient _. -

tw t % ha specimens found in France,gwere-L, (llkowise~6ttributable-4 ,. q,i to. " glacial j t.d d -f fman". ' Abbottis belief was not without foundation, as the Old and-.New World specimens-did -look~alikeT hnd' the specimens froin

- both-sides -of~ the -Atlantic- came--from very similar geological u,.1 6 deposits. But Mercer, asfother archeologistsLofh.1<

g c. - mei q.14 t, his. day, had 4.t w' y, e ,,

doubts, about Abbott's- position. A Mercer-considered -how archeologists might determine-the-age-of finds. without any means of determining

( NclCt absolute chronology. Radio carbon dating techniques were not developed until 1950). Mercer was convinced that the problem of man's antiquity was not insoluble and ~ he set out on a careful research plan which was both simple and brilliant. One approach lS,' ri( ], () h, s < > .;> i; - (ll - f r le ,2-J. <If ,a t , , , il e l v.

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c was to study on a regional basis the distribution of these crude -

< forms and determine if they were associated with known " Indian N

relics". 'Phss second approach was to investigate sites where

. these crude tools were most common. Finally, he excavated numerous caves to determine whether any evidence of man could be found in association with remains of extinct animals. His cave explorations, as far away as Tennessee and the Yucatan, produced no evidence of man in association with extinct animals. His excavations along the South Mountain produced 2nany of these crude fokms at or near the Jasper Quarries. They _ were simply preforn s or imperfect a

rejects from quarrying activitie,s. Occasionally, an obvious u v uoteb

" Indian relic" was foundfassociat'eM. On.a regional basis, these crude forms were found only at or n' ear what Mercer correctly

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interpreted as Indian quarry sites, but it was at Point Pleasant in 1893 that Mercer made his most convincing case. Mercer located c',6 4 on the slopes adjacent to Gaddis Run a number of quarries reaching-thq crude forms and flaking debris but no finished " relics".

However, just to the east, on the banks of the Delaware, he

- excavated two distinct layers of Indian occupation, which provided a high percentage of finished tools, but only a few of the very crude forms. Mercer now correctly interpreted in his data .1hqt le crude forms were partially finished t'ools. The finer quality pieces were taken to the banks of the River, reduced into finished tools, and eventually lost of broken at the village site. Mercer then confidently stated that the crude artifacts were not evidence of extreme antiquity but were made by Indians of some uncertain age 0

and simply represented a stage of quarrying i:.-) g early tool

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, production. Point Pleasant, therefore, sealed the case for ,

A Mercer and a others who clgimed that man's antiquity in the New World was relatively recent. Abbott and his supporters were discredited. The site which Mercer partially excavated, and which supported his claim to the relatively recent arrival of Man in the New World, is still, in part , preserved. This site S t*

in itself, aside from the main river flgod discussed earlier, is clearlyofextremeimportanceduetothekeyrole[Iererplayedin establishing his sound basis for determining the antiquity of Man in the New World.

The most severe impact on the archeology of the area n.Uejw,a within and immediately adjacent to the impact area /; arising from the CL Point-Pleasant-diversion would ar-ise during construction, a\1d oper\ tion. Aside from the disturbance of the area by vehicles and machinery, the activities of which c1carly speak for themselves, 6 v.4 tl A q thehuman.factorfuldhave\(damagingresult5 Due to the fact that an incredible amount of public attention has been drawn to the archeology of the

• area by the press in dealing with the adjacent to the impact z diversions:Is and5 since the area immediately}y

,d  %'r area (:::%q Lower Black Eddy,g is physically rich in prehistoric material as a result of natural erosion, " curio collectin~g" and

" pot hunting" can be- w lk expected-to- take place. II suspect that this would not only be true of local collectors, but of construction ^*3 ou. ,s .w %,, vui 6 s O 'andImaintenance, workers 3-we1-1. Even if-these-persons had no true interest in prehistoric remains or archeology, human nature .

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being what it is from ' curiosity standpoint, they may_bemxpected'to

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" dig" around the-area for " arrowheads". '5he idea of not. only owning a few arrowheads but finding them on one's own as well has an' instant appeal to most people. Many examples of such activity can be cited from past experience, not only locally, but w.b*Y on a nation-wide basis. This isj, simply the way it is. People like to own curios, and in my judgement, more sites are ruined--;

cedef1M e

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at the hands of curio hunters than by direct efforts of ,

24 d' r2 F4 / "I' d construction.A Converting the area to "openspace"[exposesthearea to an even' greater degree of-harm-from~thiY c6u7X th'an-already

'exi-s t s~ g .

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