ML20054H531
| ML20054H531 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/21/1982 |
| From: | Sugarman R DEL-AWARE UNLIMITED, INC., SUGARMAN & ASSOCIATES |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8206240173 | |
| Download: ML20054H531 (50) | |
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UNITED STATES OF AMERICA.-
' 'q g gg NUCLEAR REGULATORY COMMISSION Nlf BEFORE THE ATOMIC SAFETY AND LICENSING-BOARD t J. ' b. E ~. i
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- M:n In the Matter of
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Docket Nos. 50-352 OL
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50-353 OL PHILADELPHIA ELECTRIC COMPANY
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(Limerick Generating Station
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Units 1 and 2)
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REQUEST OF DEL-AWARE LIMITED, INC.
FOR RECONSIDERATION OF ASPECTS OF SPECIAL PRE-HEARING CONFERENCE ORDER Del-Aware Unlimited, Inc.,
requests that the Board reconsider four aspects of its Pre-Hearing Order dated June 1, 1982, as follows:
I.
Request to Reconsider Order Precluding Consideration of Portions of Point Pleasant to be Utilized Solely by NWRA.
In its extensive and well-reasoned
- opinion, explaining the interrelationship of " segmented" projects and the impacts of segmentation, the Board determines that the NWRA portions pf the water system need not be analyzed because under-segmentation doctrines, it.is independently useful and has a distinctly different purpose. (Order, p. 78-79) e 1
{DR ADOCK 05000 hO 8206240173 820621
r It is the latter characterization, independently useful, which Del-Aware submits is crucial to the determination of the need for reconsideration.
Del-Aware's proferred contentions V-17 and V-18 state that the NWRA system would not
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and could not be built without the construction of the Limerick-financed Point Pleasant diversion.
In other words, even though NWRA might decide to place the facility at Point Pleasant to divert water for its purposes, without PECo's financial contribution it could not do so.
Apparently, although Del-Aware sought to make it clear that its argument was that Limerick is sine qua non to the NWRA system, e fact, the Board interpreted Del-Aware's argument as being that the two projects had been made compatible and might have cumulative effects.
Whatever the reasons, Del-Aware submits that it is inappropriate for the NRC to segment the NWRA-only portions of the system in a situation where the PECo portion is a sine qua non to the NWRA system.
Thus, it is crucial, as Del-Aware alleges, that NWRA could not and can not build a system without PECO, not that NWRA would have chosen to build a different system had PECo not joined them. The interdependent financial situation involved in this matter is equivalent to the lack of an independent physical utility involved in Indian Lookout Alliance v.
Volpe, 484 F. '2d 11, at 20, where the Court of Appeals held that a segment of.a proposed highway did not have 2
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"the requisite independent utility to be the appropriate segment to be covered by the Environmental Impact Statement".
II.
The Board Should Require Consideration of All Operating Effects of Portions of Point Pleasant Not Considered in the 1975 Appeal Board Decision and Accompanying FES, Not Only Those Arising from Changes from the Earlier ' Decision in FES.
Del-Aware agrees and concurs with the Board's determination that the common aspects of the Point Pleasant diversion must be considered, even though they may be construction activities, to the extent that their impacts are operating impacts, since they were not considered in 1975.
However, Del-Aware submits that this reasoning extends beyond
" changes" in the project design as it existed in 1975, since the " common" elements of the 1975 plan were never considered by the Licensing Board or the Appeal Board at that time.
The requirement that only changes be presented in the FES at the OL stage is predicated on the assumption that these environmental impacts were considered at the CP stage.
The Board directly points this out at page 55 of its present Order.
What is not clearly stated in the Order, however, is that even elements in the earlier plan which are unchanged must be presently considered with
- respect, at
- least, to their operating impacts, since they were never considered in the earlier ER or CP proceedinc}s.
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It should be noted that Del-Aware does not contend that this would necessarily be true in all cases; only in this situation, where the earlier decision and proceedings fail to consider those issues precisely because they were considered to be non-segmented attributes of the NWRA proposal, should they be addressed in the OL stage without regard to their~ newness in this proceeding.
Thus, for example, the impacts of construction under the historic canal and up the hillside should be considered de novo, not just because of the new designation of the landmark and determination of eligibility of the district, nor just because of the change of law, but also because they were never considered in the 1975 proceedings because it was assumed that these activities would take place
- anyway, even without Limerick.
At least, the operating impacts of all such elements of the intake in the Del-Aware River should be considered.
Thus, the concept of the joint project depleting the water in the River and depleting the spawning area should be considered without regard to the location of the intake, and not as dependent only on the comparison of the intake on the streambank as opposed to the intake in the pool.
Only in this way can the Board now supply the deficiency of the 1975 proceedings in failing to account for the impact of the project on the River.
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III. The DRBC Decision Should Not be Regarded as Binding Concerning the Environmental Effects of Taking from the Delaware River.
Although the DRBC decided Point Pleasant was consistent with the water use plan of the Delaware River, the DRBC did not make a
final decision on Point' Pleasant.
Recognizing the necessity for interplay between the question of water diversion'and the question of the public's need for the water, which in turn raised the question of the relative value of the Limerick
- facility, and recognizing that the latter question was outside of its statutory and technical competence, the DRBC expressly referred that question to this Commission.
In these circumstances, this Commission can hardly treat the DRBC Commission decision on that subject as definitive. At some point, obviously, the two agencies cannot continue to defer to each other in the question of making the balance between the competing potential uses of the water and competing potential means of providing electrical service.
This issue must be considered at this stage, since the DRBC has taken its final action and has deferred these questions to this Commission.
This arises not only from the NRC staff letter to the DRBC stating that all questions would be addressed in the OL prcceedin's, but also from the language of the DRBC Resolution.
g (Refer to previously sited DRBC Decision and December 24, 1980, letter from Mr'. Tedesco to'Mr..Hansler.)
For this Commission, 5
in these circumstances, to treat the DRBC decision as authoritative on the question of the diversion would in effect, ele' rate the DRbC decision to a standing which was abrogated by the DRBC.
IV.
The Commission Should Admit Del-Aware's Contention Regarding Toxic Contamination of the Neshaminy and Perkiomen.
b Del-Aware's contention regarding adverse effects of the proposed project on the water quality of the Neshaminy and Perkiomen were expressed in contention V-17.
This contention was not objected to specificity grounds, and Del-Aware has been conducting detailed investigations to determine the nature of the water that would be diverted to the Neshaminy and Perkiomen.
But with the most recent change of the intake location in January, 1982, after the close of the pre-hearing conference, the likely hydrology of the intake and the source of intake water has again shifted.
It now appears the diverted water will be some combination from the Delaware River and from Tohikon Creek.
In addition, Del-Aware has been acquiring data from EPA and NJDEP reflecting water quality studies of Delaware River water immediately upstream and downstream from Point Pleasant.
These studies are not readily available because of the difficulty of obtaining toxic data and its interpretation capability.
- However, it appears now that there would be significant transfers of t5xic. materials from the Del-Aware 6
~River into the Neshaminy and Perkiomen Creeks, information that has not been generally available and which Del-Aware has only, with difficulty, acquired over the last few months.
(Refer to attached March 8,
1982, letter and comments to DER Regional Planning Engineer and excerpts from the NJDEP Study, Dredging the Raritan and Delaware Canal..)
To reject the contention, in these circumstances, seems an unnecessary
- hardship, and contrary to the Commission's need to acquire true information.
This is particularly true in light of the EROL and staff inquiries into the water quality impacts on the Neshaminy and Tohikon in terms of toxic materials.
Del-Aware, therefore, requests reconsideration of the above specific aspects of this Board's determination.
Respectfully submitted, ObeA-MN %<c ROBERT J. SUGARMAN Counsel for Del-Aware Unlimited OF COUNSEL:
SUGARMAN & DENWORTH 121 South Broad Street Suite 510 Philadelphia, PA 19107 (215) 546-0162 g
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CERTIFICATE OF SERVICE
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$/Of I hereby certify that I have served copies-of} the [
foregoing Request of Del-Aware Limited, Inc. for ReconsId-eration of Aspects of Special Pre-Hearing Conference Order,
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by mailing the same at their respective addresses, as follows:
' Lawrence Brenner, Esq., Chairman Adminstrative Judge U.S. Nuclear Regulatory Commission Washington,'D.C. 20555 Dr. Richard F.
Cole Adminstrative Judge U.S.~ Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Peter A. Morris Adminstrative Judge U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Frank R.
Romano Air And Water Pollution Patrol 61 Forest Avenue Ambler, PA 19002 Judith A. Dorsey, Esq.
Limerick Ecology Action 1315 Walnut Street, Suite 1632 Philadelphia, PA 19107 Stephen H.
Lewis Esquire Counsel for NRC Staff U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Edward G.
Bauer, Jr.
Vice President & General Counsel Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 i
' Troy B. Conner, Jr., Esq.
Mark J. Wetterhahn, Esq.
Conner and Wetterhahn 1747 Pennsylvania Avenue, N.W.
Washington, D.C.
20006 Mr. Marvin I.
Lewis 6504 Bradford Terrace Philadelphia, PA 19149 James M. Neill, Esq.
' Associate Counsel for Del-Aware Box 511 Dublin, PA 18917 Joseph H. White III 11 South Merion Avenue Bryn Mawr, PA 19010 Environmental Coalition on Nuclear Power Dr. Judith H. Johnsrud, Co-Director 433 Orlando Avenue State College, PA 16801 Thomas Gerusky, Director Bureau of Radiation Protection Dept. of Environmental Resources 5th Floor, Fulton Bank Building Third and Locust Streets Harrisburg, PA 17120 Director Pennsylvania Emergency Management Agency Basement, Transportation & Safety Building Harrisburg, PA 17120 John Shniper Meeting House Law Building & Gallery Mennonite Church Road Schuylkill Road (Route 724)
Spring City, PA 19475 Robert L. An.thony Friends of the Earth of the Delaware Valley 103 Vernon Lane, Box 186 Moylan, PA'19065
Alan J.-Nogee The Keystone Alliance 3700 Chesnut Street Philadelphia, PA 19104 W. Wilson Goode Managing Director City of Philadelphia Philadelphia, PA 19107.
William A. Lochstet 119 E. Aaron Drive State College, PA 16801 Charles W.
Elliott, Esq.
123 N.
5th Street Suite 101 Allentown, PA 18102 Walter W. Cohen Consumer Advocate Office of Attorney General 1425 Strawberry Square Harrisburg, PA 17120 Robert W. Adler Assistant Counsel Commonwealth of Pennsylvania, DER 505 Executive House P.O. Box 2357 Harrisburg, PA 17120 Steven P. Hershey, Esq.
Law Center North Central Beury Building 3701 North Broad Street Philadelphia, PA 19140 Sugarman and Denworth i
Suite 510 North American Building 121 South Broad Street Philadelphia, PA 19107 l
_4 Donald S. Bronstein, Esq.
The National Lawyers Guild Third Floor 1425 Walnut Street Philadelphia, PA 19102 Atomic Safety & Licensing Board.
U.S. Nuclear Regulatory Commission Washington, D.C.
20555-
' Atomic Safety & Licensing Appeal Panel U.S. Nuclear Regulatory Commission ATTN: Chief, Docketing & Service Br.
Washington, D.C.
20555 f
4 Respectfully submitted, 1h1
$GAu~ %c Robert J.
Sugarman
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a Du p pg 44 D. South Main Street-New Hope, PA 18938 (215) 862-9862 March 8, 1982 Regional Planning Engineer 1875 New Hope Street Norristown, Pa. 19401 RE:
Neshaminy Water Resources Authority request for Water Quality Certi fication for portions of the proposed Point Pleasant Diversion Plan (1) Construction o f the intake on the Delaware River at Point Pleasant (2)
-Hechannelization of the Pine Run and North Branch Neshaminy Creeks.
Sirs:
Del-AWARE Unlimited submits the following documented evidence on impacts associated with the above captioned certificatio'n request.
We strongly urge the Department of Environmental Re-sources to hold public hearings and conduct a complete analysis of all pertinent aspects of the proposed Point Pleasant Diversion project.
Although department regulations are unclear as to the scope of review on such requests, we are assured by Article 1 Section 27 of the Pennsylvania State Constitution that the para-meters will be su f ficien tly broad.
The proposed diversion project has an almost interminably long history, having been conceived by the applicant and Phila-delphia Elec tric Company and approved "in concept" by the Depart-men t. many years ago through issuance of a water allocation permit.
In t erestingly, the present request for water quality c erti fica tion is the first opportunity for the State to review any substantive acpect of. the plan.
Although the project has been before various agencies at dif feren t times for approval of other aspects and ostensibly was approved by the DHRC, it is obvious that a compre-hensive and thorough analysis has yet to be done.
Surrounding circumstances such as projected need, the con-cept of proper utilization of natural resources, the political and economic climate, as well as the project design itself, have undergone major changes.
The project design is still undergoing change as recent as January 22, 1982.
It was necessary for the N'2RA to submit ' to the Corps of Engineers 'yet another ( the : fourth) location and design for the intake and its facilities on the Delaware River at Point Pleasant.
All former designs have been rejected as unacceptable environ-mentally and this one has never been assessed.
The proposed location of the intake is a highly sensitive part of the Delaware River. It is affected by the Tohickon Creek entering there, it is the location of an eddy forming a pool which is a fish spawning arca rod an area of sediment collection forming a benthis layer o f silt.
Approximately one mile south is
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a liscrcion LO 11cv! Jetu uy o r I; med.
1.n in Lahu al Toint Pleucan t. may wc3 3 a r rec t the Jien Je r::cy in t he !!ar.i tan Id ver Di vorcion.ir.4ali t.y o f v ater Lak en by Con:/idura tion i.iuct I.. fd v n I.o impucta of the divdenion projue t.ceriouc and 'cieni ri can the ro.11oviing. iccuac:
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- be uddruccing salinity in trusion, dovinstream estuarine quality, creepinc streamc and ground watcr.the int.ake loca tion, the receiving-In addition, inplications and adversothe 1)epartment must evaluate all of the errectn :213 Crunch !a ter Trca tmen t Plan t,t o Limeri ch."tation in Po of the nauter products of viatur trealment. including - the ul tiraate disposal aucarman,This comment is a supplement. to our attorney's (Robert 3
i' on February la,190P,Esq.) previoun correcpondence to the Department which brictly outlines our concerns.
Rcspectfully, YA h
Col 3 con Vielle Del-N.?ARE Unlimi ted, Inc.
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i COMMENTS AND OlkTECTIONS 1
k REGARDING TiiE NESilAMINY r/ATMR 1?MSOURCES AUT110RIT FOR WATER QUALITY CERTIFICATION FOR PORTIONS OF TIIP PR E
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POINT PLEASANT DIVERSION PLAN -
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Prepared for the Department of Environmental Resources
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By Del-AWARC Unlimited, Inc.
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'I'A111.R OF CONTI:NTT; 1.
Let t er o f in t ro du c ti on.............................
2.
Section I: Potentia] Impacto of Intake Operations on 'llater Quali ty in the Region..........
3 Ucction II:
T:n3 I ni ly I n c u rcion.....................
4 Section III:
Location of Intake-Impacts and t
Impli c a ti o n s.........................
4 5
Section IV:
- later Quality ?,f facts of the I?ccciving Streams from the Pro Pumping 3tation..... pocod Poin t Pleasant 6.
Section V:
'lloter Qual'i ty-O ther Arcac o f Impac t....
7 Section VI:
Impacts and Needed. Studies of 1.hc Poin t P3 casan t Di version Proj e t......
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Co n c l u si o n..................................
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A
t SECTION I Potential Impacts of Intake Operations on Water Quality in the Region The Proposed Point Pleasant Diversion Plan will have i
significant impact on water quality and present water policy as promulgated by the DRBC and the Pennsylvania State Water Plan. Therefore the lasues outlined below must be included in the Department's review.
Und er present Basin policy :
1.) there is no legally guaranteed minimum flow to th e estuary.
2.) there is no upper limit on the amount of water that can be removed from the Delaware River and the estuary either by evaporation or exportation out of the basin.
i 3.) the only obligation of the DRBC is to maintain k
the calt line. -
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Conservation within the Basin is meaningless as long as such policies are permitted to continue Although the presently. proposed maximum with-drawal for the year 2010 has been downscaled to 95 MGD from previous plans to divert 250 MGD, the proposed facilities are still designed to divert 250 HGD Since.
no formal action has been taken by Bucks County agencies to delete componants previously included in the Neshaminy Water Supply System, evaluation of 95 HGD as a maximum withdrawal is deceptive and unacceptable.
Whatever the amount of the water diverted at Point Pleasant, it is a 100% consumptive loss to downstream water users.
There has been no analysis of the impact of the removal of huge quantities of water from the Delaware and Estuary ~.
Since 1959, however,
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the USGS has been using an extrepely simple formulaknownasthejMontanaMethod" to evaluate water quality ' impacts relati've to average river flows..This method has been used successfully.
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f over a wide variety of rivers across the cou'ntry and can quite simply. determine what water _ quality will be, by expressing actual stream flow as a percentage of the n
average flow, and then referring to a simple chart tj that can be put on a 3x5 index card for resultant water quality (See Exhibit 3).
According to the chart a river h
flow of 30% of the averagd flow will result in fair ~ or
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degrading conditions during summer months.
A few numbers are needed to put the. Delaware Basin and Point Pleasant problems into perspective.
The average flow of the Delaware River at Trenton is 11,550 cubic feet per second (CFS).
For a number of years a flow of 3000 cfs at Trenton, or about. 25 % of the average flow was used as the so-called " minimum flow objective" for planning purposes, although necessary technical work had not been done to determine the actual flow regime necessary t'o protect water quality in the Estuary.
Despit'e the lack of these data and analyses, despite the failure to analyse the impacts of the removal of vast quantiples of water from the Estuary, and despite the ready availability'of the Montana Hethod, agencies responsible for Delaware e
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Basin water resources planning and management continue to base future. planning on the assumption that all flows in excess ~of, 3000 cfs at Trent6n can be withdrawn from the River (See Exhibit 4).
In other words, that all flows above 4
25% of the average flow can be diverted.
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Additionally, recent administrative actions of the DRBC indicate that the Commission, without going to 2
public hearing has changed from a policy of minimum sus-e tained flow to a policy of maximum sustained flow for is Basin streams (see Exhibit 5).
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Under such pclicies, Delaware Basin' water users s
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have no protection whatsoever from having riparian' waters taken away.
's The Point Pleasant Diversion sets policy in this regard.
As the initial project of a vastly larger water supply system, it is simply the tip of the iceberg.
It will set the standard for both planning and quality of review of 'similiar diversions which are now planned.
Its importance lies as much in its precedent setting aspects as in its diredt and indirect impacts (See Exhibit 6 & 7)
'b Use of imported water instead of developement E;
and use available water resources in area of need create fl artificial water shortages and water quality problems in
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Such " problems" may be then used by various agencies as justification for structural " sol
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"1, utions" which would otherwise be not needed.
ij And from which the agencies may profit; 1,
for example, reservoir con-struction for water supply or water quality augmentation
- purposes, f4 f.
The open-ended Point Pleasant Diversion per se will have a substantially underestimated impact on the Delaware River mainstem flows, particularly during seasonal s
low flow or drought conditions.
Downstream water users have testified repeatedly that they do not benefit from projects, policies, plans, or programs which remove their wat,er resources (see Exhibits 8 through 13).
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Additionally, more than ten years of. technical testimony exists documentin,g the active participation of downstream water users in Bucks County,in various s
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r aspects of water resources planning and management Extensive technical testimony has been incorporated i n both the Delaware River Basin Comprehensive (level B)
Study, and also COWAMP/208 Studies, including the devel' p-o ment of the new Delaware Estuary water quality models
,c (See Exhibit 13)'.
For example, just as background pollution loading from the proposed Point Pleasant Diversion to East Branch Perkiomen and North Branch N esh-
.aminy Creek is now being ignored in evaluating the Point Pleasant Diversion Project, so there exists (in COWAMP 208 and DRBC level B exhibits) a length of planning and management agencies ignoring background pollution loadings on the order of 650,000 pounds BODS per day from the Delaware River mainstem,into the upper Estuary at Tr enton.
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e SNCT10H H SALIH1TY I NCil'RS]ON The impacts o f the divercion a f v;oter at T*uint Pleacont.
coupled with the use of upctream reservoirs for low flow I
au5mentat. ion to hold the calinity incurcion in check has never been adequately addressed.
Evidence indicates that a not J nerease in fresh water outflow is necessary in incroacing quantities to hold back the salt line of the Atlantic Ocean.
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SEA LEVML EFFECTS I
We quote from coveral publi ca tions: "The Ocean's Rice" by Steacy D.
Hichu from the National Ocean and t.tmospheric Archives, April 197P, vol.
P,P.
"nince that t.ime (196P), the sea along the coast from Maine through Virginia hac been rir;ing at a very rapid rate.
From 196fi to the precent (197P), cea I
IcVel in this coactal area hac ricen an average o f 3 inchec."
" Water Recourecc o r the belaware River \\\\acin" by Pai'ker, et al, " An incroace j n calini ty o f the Delaware ectuary, probably due to this recent rice is nea 1evel, caused Chester, Penna. to abandon its local cupply in 1951 ancJ to obtain a care supply inland from the Sucquchanu River liacin."
I Journel of Geophyn)c 1 Reccarch, Vol. 83, //13, March 20, -
1978.
" An average coopotentiul nea Level Series for t.he IInited States" by Stacy D.111cks page 1379: "The trend (slope) ic 1 5 dynamic mm[yr., the riding.cea level (noted in the Tinal Environ nontal Accenument ) may be accumed.to continue, as the r
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continent tilto its east.crn edge into the oca."
It may be accumed the rising uea leve]c will continue oc 1
the continent ti3 t.s its eactern edge into the nea.
If stated
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t figures are correct, then to maintain the salinity incursion at its present location will require an additional 10 cubic feet per second of flow each year.
In 14 i years additional fresh water flo.ws equal to the maximum daily withdr w l s
Point Pleasant will be required just to maintain the aa at wedge at pre' 6nt levels.
s salini ty 2.
DELAWARE RIVER FLOWS
~~f It is apparent that the rationale for using high flow skim storage reservoirs to augment periods of low flow
' adequately addressed. replace water diverted and lost t and
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Although the Merrill Creek Reservoir is designed to repla water withdrawn at Point Pleasant, evidence indicatos th t th e
most important relationship may be the _ total annual flow to a
e the estuary that is the most si nificant determinant of 8
estuarine water quality rather than manipulations of upstr storage reservoirs during low flow conditions.(DRBC Level B eam Study 1980).
. Further indication of the sensitive relationship of fresh water outflow and saltwater inflow is found in th PLANNING AID REPORT:
e The Sensi tivity of the Delaware Estuarine Ecosystem to Alteration of the Natural Cycle of Salinity prepared by the U.S.
Chance Dept. of the Interior Fish and Wildlife Service for the Army Corps of Engineers July 1981 from the Summary and Conclusion We excerpt on the fo]1owing page:
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6 Summary:
H This report is an assessment of the sensitivity of the Delaware estuarine ecosystem to alteration of the natural cycle of salinity change.
ment is based on review of published and unpubliehed literature and personal The assess-interviews.
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[1 Freshwater outflow and saltwater inflow largely determine salinity concentrationa in the estuary.
during the low freshwater outflow period of summer, and lowest du
/Qdi high freshwater outflow period of winter and spring.
kid-increasing distance from the mouth' of the bat, reaching fresh water nearSalinitie E,
Philadelphia.
lower river and upper bay throughoutTide-induced mixing minimizen salinity s the year.
This is also the case in the
[j lower estuary except during winter and ' spring when the bay is strongly strati-fled.
The intrusion of heavier, saltier water from the ocean beneath fresher C
lighter water from the Delaware River sets up a transport mechanism importan in the life cycles of many estuarine fauna.
The DRBC proposes to' limit salinity intrusion in the Philadelphia area by storing water in reservoirs during winter or spring And augmenting summer flows.
As a result, salinity would be depressed below normal levels Icvels during the storage period. "
in summer, and increased above normal
.......c n Reducing freshwater outflow would lead to a reduction of low salinity environments and a reduction in the extent of the freshwater-saltwater mixing zone. This would restrict the availability of suitable habitat for low salinity dependent species.
Reducing freshwater outflow may alter bottom currents and interfere with transport of eggs and larvae up the estuary.
Changing runoff cycles, but not disrupt the salinity gradient at the total volume of water received, could causing a reduction in estuarine productivity.a critical time for plants and animals, Overall, reducing freshwater outflow would result in lowered estuarine productivity, the degree of decline dictated by the amount of reduction.
Not all.of the decline can be attri-buted to salinity change.
Loss of nutrien'ts and other changes may also contribute to the reduction in productivity.
b Reducing freshwater outflow in spring would allow benthic invertebrates t
associated with higher calinities to advance up'the bay.
benthic diversity while reducing habitat This would increase for brackish species.
Dyster drill predation would extend into oyster beds formerly protected by intermediate low salinity. MSX disease may al,so be extended.
Dyster losses would in-crease, damaging th'e oys ter industry. - Increasing salinity in spring may blue crab larvae and young. interfere with residual bottom currents, d perhaps reduced in size.
Nursery grounds may be shifted northward and mentat' ion would restrict Decreasing salinities in the sumr.cr via flow aug-and benefit brackis.h and freshwater types.the advance of salt-tolerant bentho It would also restrict the shrinkage of blue crab. nursery habitat which coincides with declining runoff 4
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Reducing spring flows may alter bottom cur 2ents n
transport of fish eggs and larvac.
, disrupting up-estuary Atlantic menhaden, American eel, summer flounders s
spot. (forage).
, striped bass, of estuarine fishes up the estuary. Reducing spring flows would s brought closer to the intakes of the Salem Nuclear GenEggs and larvae o sery grounds possibly increasing entrainment/ impingement erating Station, possibly increasing mortality. striped bass would be brought c losses.
a pollution zone, Reducing spring flows would reduce the extent of the low salinity zone, limiting valuable spawning and nursery habitat for Iow salinity dependent fishes.
Reducing salinity intrusion wouldMany commercial /r adversely affected.
minimize the shrinkage of the low salinity zoneshif t o limit the up-estuary It would also u Increasing salinity in spring via reduction of fre h affect the composition of waterfowl food plants s water outflow would not forcing waterfowl to forage over larger areas.
but would reduce productivity, would prevent brackish to saltwater marsh conversioReducing salinity in summer Huskrat production, of brackish carshes. limited by high salinity, would also benefitbenefiting waterfowl ns, increasing or decreasing salinity. " Wading birds and shorebirds would not y
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Conclusion:==
u The results of our work indicate that lower the productivity of the Delaware estuarine ecosystemincreasing salinit salinity intrusion in summer would benefit However, reducing the detriment and benefit the ecosystem.
The magnitude of the Service would not are dependent on the degree of change.
- Overall, reducing freshwater spring flows. encourage low flow augmentation to the detriment of would not appear to outweigh damages in spring.The benefits to the ecosystem
" This report only addresses changes in the salinity regim turbidity, water quality, temperature, sedimentation, scouring and nutriWater circu e.
loading may'also be affected by altering runoff patterns.
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These factors should be assessed in other studies.
We would particularly like to see a study of circulation patterns and the ' effects of changes on fish and -benthic
- invertebrate egg and larval movements. "
n In view of these findings, the Service recommends that reducing freshwater outflow in spring be avoided, and if it can' t be avoided', be minimized to protect and maintain the health of the_pelaware estuarine ecosystem."
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It 1o cicar that further investigation la needed to determine the risk to the delicate balance between fresh water outflow and salt water inflow that will be caused by storage of water at Merrill Creek d uring spring high flows and diversion of water at Point Pleasant during summer low flow.
Evidence indicates that the detrimental effect are not all known, and neither is a solution.
The Department therefore must gonsider other, non-con-
' sumptive alternatives, such that oownstream water quality is protected.
G q
m e
4
o SECTION III Location of Intake-Impacts and Implications The proposed intake location is influenced by many factors which have not been considered. The interrelation-ship of the Tohickon Creek, the main channel of the river, the pool and the eddy to the south have not been analyzed i
as to the effects of each on.the other nor the potential impacts of the introduction of the river structures. It is clear that documentation of that portion of the river is essential to determine the impacts, in all flow conditions, of this relationship, before the consideration or appro-val of the water quality certification.
It is evident that the Toh'ickon Creek is subject to influences which significantly effect the flows and loca-tion of the mouth. The factors tha~t precipitate these apparently rapid changes must be analyzed so that the future of the creek and its potential-impacts on the intake structure can be und erstood.
In Design Report 2(Bourquard 1972) it is noted that the intake
~
I should be situated as to avoid or minimize the hazards of blocking by ice; blocking by logs and heavy debris; I
blocking by siltation; and undermining of intake foun-dation by ri'ver currents.
The report goes on to say that the intake alignment would intercept the actual river channel and thus the main river current at about a right angle and about 800 feet downstream of the mouth of the Tohickon Creek.
At this point, Bourquard points t,he river, channel has about returned to its normal
- out,
~ ~ ~
cross-section after being restricted by the deposition below Tohickon Creek.
As the actual surveyed location is several hundred feet north of that discussed in the report as
~
acceptable, an e, valuation must be made as to the feasi-bility and soundness of the present location.
The river flow is significantly affected by the cross currents from both the Tohickon Creek and Hickory Creek which result in material deposition and some scouring of the west bank.
The effects of the intake structure o4 the evolution of the Tohickon Creek must be evaluated as to the potential changes in flow pa tterns, which may cause an increase in rates and volumes of sediment, rock, and debris deposition into the pool, the eddy and further downstream.
The effects of the intake s tructure c ot the l
creek movement and the water withdrawal less than 400 i
feet to the south is essential to an understanding of the soun'dness and permanence of this location.
The future flow pattern's of the creek (as affected by the intake) 43, will certainly aff'ect the flow patterms of the main jf/
channel of the river, and the hydrology of the pool and the eddy,'as well as the topography of the river bottom.
V The pool is subject to the hydrolics of the Tohickon Creek and to impacts due to changes in the channel and the eddy below, seasonal, manmade and other.
The po-tential for increased deposition of silt, rocks and debris in the pool is great.
The resultant need for mainte-nance dredging, and other mitigative measures and the associated adverse impacts of these must be determined.
The potential destruction of a sensitive environment for aquatic, life, the nature and deposition of the dredged material, as well as downstream and land use impacts must be considered.
-- ~~ ~ '" '
~
The intake structure design and location make the structure extremely vulnerable to destruction from rocks, sediment debris, ice damage or deposition, reducing j
. its officiency and endangering the structure itself as well as the aquatic environment in which it is located.
A map showing the river bottom topograph'y is needed to show the details and stability of the river bottom geology.
The rates and volumes of rock and 1
an cediment movement, d aring high flows and ice, must be determined. The effects of such movement on the intake struc-ture, as well as the effect of the structure on this deposi-tion', should be evaluated under all flow conditions. As the need fo' ' maintenance dredging and the resultant turbid-r ity will adversely effect the the water quality downstream and further allow the transfer of toxics and priority pollu-tants into Bradshaw Reservoir and the receiving _ streams.
9 1
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G S
POTWTT AT, PRP.SErlCM 07' Ton c Pol.T.IITAIJTS A study must be undertaken to determine the degree of contamination of transportable benthis and sediment deposits in the vicinity of the proposed intake location.
Specific analysis for heavy metals,as well as chemical determinations
'~
for hazardous organic residues that could be absorbed or entrained on or in the sediment. layer (s),should be executed to ascertain whether potential hazards exist from relocation of these deposits.
s Concerns exist when contaminated sediments are reloca as shown in studies funded by th'c U.S.
(1,2,3,4,5)
- and the U. S.
Army Corps of Ehgineers Environmental Agency (6)*.
Release of chemical contaminents can be facilitated when contaminated sediment encounters a different physiochemical environment (7,8,9)*.
Because released contaminents can enter the food chain (10 & 11)* and contaminate a previously unpolluted niche (10 & 11)*, the potential hazards as they relate to the intake on the Delaware must be addressed.
Of primary concern are sediments:1.which may be relocated through dredging and excavation operations or during constru ti and operations of the pumping facility, c
on P. the deposition of said sediments in the Bradshaw Reservoir and Lake Cal
.3 those sediments which will be removed in primary treatment at the North Branch Wa'ter Treatment Plant.
Given the degree of upstream industrialization on the Delaware River and its tributaries in the past and present and the potential for accumulation at the proposed intake zone a study should be carried out to determine the degree of contamination of transportable sediment and its ultimate deposition and disposal.
AJsurvey of upstream pollution sources should be executed to determine whether non-removable river pollutants may be encountered in the proposed water source.
Of primary concern here is the possible upstream pollutant spills which may render the surface water source non-potable even after treatment has been per, formed.
{
Finally, we would like to call to the Department's attention a report entitled " WATER QUALITY ANALYSIS AREA-Specific Dilution Studies Region III" and dated January 1981.
prepared for EPA This report provides a preliminary identification of areuc where water quality coals for toxic y
pollutants might not be attainable, even with the application of the best available technology, and indicates w'ith respect to the affected reach of the Delaware River a potential presence of 15 priority toxic pollutants above the draft
. water quality criteria of such pollutonts in the Lehigh
acenaphthylene and florine) would exceed criteria at the confluence with the Delaware River.
Although this study is based on discharges to be expected from the industries and municipalities upstream in the Lehigh River, it does not include dilution by Delaware River flows or pollutants added by the Delaware River.
Certainly, as a result of the above and the fact that best available technology has yet to be instilled by most industries, there is a substantial concern as to the water quality impacts on the Perkiomen and the Nechaminy, as well as ground water impacts at Bradshaw Reservoir and Lahc C:
All of which wi31 be discussed in Aona.
comment.
further sections of this Reference documents available up6n request G
t
SECTION IV WATER QUALITY EFFECTS OF THE RECEIVING STREAMS FROM THE PROPOSED POINT PLEASANT PUMPING STATION My concern is that the location of the intakes for the proposed Point Pleasant pumping station would be only 380 feet downstream from the mouth of the Tohickon. Creek.
Depending on exactly where and how the intakes function, they could well be pumping a majority of Tohickon Creek" water instead of Delaware River main stem water to the Neshaminy e
and Perkioman Creeks.
According to the C.0.W. A.M.P./ 208 Water Qu' lity Management Plan, a
i the water quality of the Tohickon Creek is indicated to be " seriously degraded".
This " seriously degraded" water in turn, if pumped into the Neshaminy or Perkionylh Creeks, would then violate water quality standards by several parameters including fecal coliform, ph, dissolved oxygen, phosphates, and possibly more.
According to the 208 Plan, the. water quality data indicates that
" water quality has improved in the Delaware Valley to some degree during the last half of the 70's decade.
However, both local areas with occasional problems and. widespread problem areas exBf a'nd will likely continue to exist into' the 1980's."
The Tohickon Creek appears to be one of those problem areas.
An excerpt from the 208 Water Quality Management Plan follows:
" Water quality data indicates that Tohickon Creek is seriously degraded in some upstream reaches especially in the Richland Township-Quakertrwn. area.
Upstream of.Quakertown, Tohickon Creek receives a e
(2) y
(,
significant nutrient load:
phosphorus averages 0.49 mg/l and nitrate as high as 2.39 mg/l has been observed.
Dissolved oxygen problems are also
'~
' indicated in this reach.
The mean DO concentration is 7.2 mg/l and has
.a 4.
approached 4.0 mg/1.* In two instances, the 4.0 mg/l DER stream criteria
[> ye has been v'iolated.
@N The Tohickon Creek also exhibits elevated fecal coliform levels
- E;.;.;y (violating DER stream criteria) and occasionally elevated chlorides
',]93[
(62.0 mg/1).
m.
]:((f Available data. indicates the Quakertown area exerts a major influence
.c e j r. g.-
on stream water quality in Tohickon Creek.
Comparison between upstream and downstream parameter levels shows very substantial increases in nitrate, total phosphorus and chloride loadings in the downstream samples.
Dissolved oxygen continues to be a problem in Tohickon Creek downstream of Quakertown.
Mean DO concentration is about 7 mg/l with occasional criteria violations.
Water quality monitoring data also indicate elevated coliforms (DER stream criteria violated), as well as high nitrates and extremely high phosphorus loadinns [(the mean concentration is 4.9 mg/l and a maximum of 27 mg/1)., which is a DER stream criteria violation The chloride concentration also becomes.very high in the reach with an averag concentration of 61.7 mg/1.
Water quality data for Tohickon Creek immediately upstream of Nockamixon Reservoir indicates that the reservoir is receiving a very large nutrient load.
The time trends indicate that the loadings for each of the individual constituents are variable.
The mean and maximum values reported were:
1.83 mg/l for nitrates (5.87 mg/l maximum); 41 mg/l and 120 mg/l for chlorides; 0.197 mg/l nad 3.6 mg/l for phosphates; and 0.76 and 1.10 mg/l for ammonia, respectively.
Water quality in the Tohickon downstream of the Nockamixon Reservoir exhibi,ts similar. problems to the upstream reaches.
Deep Run. Creek, a major
(3) tributary to the Lower Tohickon, has somewhat poor water qualityHigh i
in-stream coliform, nitrate, phosphate and organic loads ha ve been noted.
The DO in Deep Run Creek occasionally approaches 5.0 mg/l with highs i n
excess of 15 mg/l reported.
Elevated ph values (above 8.5) _in violation of stream criteria also indicate the presen'ce of a significant diurnal DO
' ~~
actuation due to aquatic growth, stimulated by high nutrient levels.
Tohickon Creek, below the confluence with Deep Run Creek, exhibits o and nutrient loadings.
The BOD averages about 2 mg/l but may periodically 5
achieve higher values.
The average DO is 11.4 mg/l with as low as 3.0 mg/l being' reported (DER stream criteria violated).
Septic systems are also indicate (
by. high suspended solid values and elevated chlorides and an extremely high mean fecal coliform concentration of 38,,572 MPN/100 ml. (this indicates a gross DER stream criteria violation, typically anything over 200 MPN/100 ml would be a DER stream criteria violation)
As in the case of Deep Run Creek, the Lower Tohickon Creek data also show a number of high ph values of >over ph 8.5."
(would violate Delaware River stream criteria)
So in view of the serious degraded water quality cf the Tohickon Creek how would it in turn effect the stream criteria fo the Perkiom/n and Neshamin L
Creeks?
If the pumps took a majority of Tohickon water, fecal coliform DER stream criteria of 200 MPN/100 ml would be violated in both streams.
Ph DER
. stream criteria of 6.0 - 9.0 would not be violated, but the upper limits are already being pushed (8.5) and in view of the ever present acid-rain problem the stream criteria for both streams minht be violated in the near future Chlorides, also while within the DER stream criteria, (no more th,an 150 mg/1) are pushing the upper limits ( 120 mg/I).
Phosphorus DER stream criteria would be violated in the Neshaminy (not more than 0.03 mg/1) and possibly the Perkiomen (not more than 0.1 mg/1) also as the Tohickon discharges approximately 0.197 m
(4)
Nitrates, which contributes to other stream problem are presently within acceptable limits.
Temperature violations (shock) could easily be violated as DER s~tream criteria allows only a 2 P. rise or fall per hour when ~ adding water to a stream.
Stream temperatures could easily vary that much from
~
one stream to another depending on the local amount of summer shading, influx of spring run-off vs reservoir runoff etc.
- {
Assuming that the majority of water to be pumped is Delaware River 4
main stem water, how would this affect the Neshaminy and Perkiomin Creeks?
Water quality data of the Delaware main stem at Point Pleasant appears to be lacking.
Typically, sample locations of the main stem are two to three miles downstream at the walking bridge at Lumberville or five miles upstream at Trenchtown.
The Lumberville data would be suspect because of th'e potential of mixing Tohickon Creek water with main stem water as they pass through the wing dam just upstream of the walking bridge at Lumberville, thus not giving true main stem characteristics at Point Pleasant.
Frenchtown data on the other hand,' being five miles upriver, could change significantly over its travel to Point Pleasant.
Truely, there is a need for more careful monitoring of the main stem at Point Pleasant.
Perhaps a robot monitor could be attached to one of the piers of the " broken bridge" opposite Pt. Pleasant Canoe Rentals, which is just upstream of the mouth of the Tohickon Creek.
This would be a much more accurate representation of the water quality of the main stem that would be potentially taken at the proposed intake 380 feet downstream of the mouth of the Tohickon Creek.
With limitations in mind, how would Delaware River from Lumb erville, Pa.
and Frenchtown N.J. respectively affect' the ecology of the Neshaminy and Perkiomin Creeks with respect to several water ' quality parameters?
Using the U.S. Geological Survey Water Data Report:
N.J. 80-2, DER stream criteria,for fecal coliform would be violated for both the Neshaminy
(5) and Perkiomin Creeks (2284 MPN/100 ml average Frenchtown and 2606 MPN/100 ml average kmberv111e).
Ph would be within limits, as would dissolved oxygen, chlorides, and nitrates.
Phosphates woul'd violate both the Neshaminy and Perkiomin Creeks (0.38 mg/l average Frenchtown and 0.27 mg/l average Lumberville).
Temperature shock analysis requires more consistent data as most of the different data sources seem to average the data over a year.
Fecal strep, while tested for do not appear to have a specific DER stream criteria.
Fecal strep however, are considered to verify fecal pollution from warm blooded animals.. Reported levels are high enough to warrant concern and furthur study.
STORET data for the Tohickon Creek indicates fecal strep counts of 1955 MPN/100 ml average.
STORET data for the Delaware River at kmberville Pa. indicate fecal strep counts of 288.6 MPN/100 ml average.
USGS data shows counts of 367 MPN/iOO ml average for Lumberville (alluding to another problem with the data base) counts of 383 MPN/1001 ml at Frenchtown.
From the COWAMP.208 Water Quality Management Plan the following concerns with the data base were noted:
" Problems With The Existinst Data Base An important lesson learned in this data inventory is that management of water quality information must have equal weight' with data collectior and analysis activities.
A data base with incomplete and erroneous nu ers is an invitation to problems.
The management system must also be capable of consolidating information gathered by governmental, private and academic groups.
Specific problems found in the data inventory and analysis were:
1)
Significant duplication among the many water quality monitoring stations.
Two or more agencies collecting data at a single site results in two limited data sets which can lead to conflicti.ng water quality interpretatio~ns.
Furthur, two samplings are more costly.
The preferable approach is a single sampling effort to meet the needs of both agencies.
(b) 2)
Many extranrous patameters are samples while othe r significant parameters are ignored due to oversight, Limited manpower, limited fiscal resources or other reasons.
in' stead of being specifically targeted to str aIn man e m reach.
lists oftem are not m'ade and long " laundry" lists Revisions to parameter of " pollution-sensitive" varibles result.
In particular, primary collection efforts have
" classic" sanitary engineering parameters such emphasized as nutrients, fecal coliform, and alkalinity, while slighting " newer" parametersof interest, such as toxic organics, heavy metals, and pesticides.
1 3)~
Sampling has reflected a lack of appreciation sampling frequency.
of the appropriate This is in part a result of the absence of specifi sampling objectives.
c frequencies are selected arbitrarily, for convenience, or because of manpower constraints.
Much of the existing water quality data from various sampling programs have not proved effi i c ent for trend or causal analysis.
The limited interpretive utility of existing data have been most acute on major tributaries other than the Schu lkill y
from nonpoint sources.
and for pollution In addition, the sampling frequencies encoutered in the data have proved inappropriate for assissi streams.
ng diurnal variations in most 4)
There are significant data naps caused by stream sampling sites _.
inappropriate location of Data were missing on important stream reaches with potential serious problems.
A number of sampling points were located on streams I
i with identified problems but 'either on reaches of th ose streams that manifest slight or no water quality effect of p~ llutants or that o
sample.
were more convient to 5)
Existing data fail to account adequately for~ the sea 1
sonal and reach-to-reach varibility in water quality that results fr om hydrologic phenomena.
(-
6)
There was a general scarcity of stream bottom sampli ng as compared e
4
~
(7) to the preponderance of data concerned with water column parameters.
7) 1he sampling data collected by various agencies were primarily determined by the needs of the agencies.
In particular, DER, DRBC, and EPA have systems that generate information primarily related to regulat'ory functions.
While this is appropriate for these agencies in their functions as regulatory agencies, the data possesses serious shortcomings as it relates to planning water resource and pollution management uses."
Even taking into consideration the drawbacks with data base, it appears
.that the location of the pumps at Point Pleasant is a poor one.
The potential of polluting both the Neshaminy and Perkiomin Creeks with a mix of Tohickon Cre'ek and Delaware River water seems very real.
In view of the fact that the Tohickon Creek is so " seriously degraded" it is ironic that it's water is being slated for possible future developement.
Potable water for future growth needs should not originate from such an obviously poor source.
A few other points still come to mind.
Given the need to manage Lake Galena with Delaware River water, the spring " fill up" of Lake Galena would possibly coincide with a major spawning of species of fish in the pool at Pt. Pleasant.
Typically, one sees a progression of walleye spawning, then shad, then herring, and then smallmouth bass.
By then it would be early June, so there is a need to know what is spawning in that pool at times of major projected withdrawls.
Which brings up the need for a detailed hydrologic /
ecological model of the pocl to determine 1) what % of Tohickon' Creek water will actually be taken up by the pumps and 2) how will the intermitent pumping affect aquatic life?
Also I am concerned about increased acidic runoff from snowmelt and spring " acid" rqins resulting in increased leaching of heavy metals (such as a.
cluminum) into tha watershed.
This could pussibly cause o seasonal pollution problem.
Tin' ally, any reduction in main stem flow will negatively effect downstream water quality in light, of Tohickon Creek's " seriously degraded" water quality.
However, it would be ultimately very ironic if the reverse happened.
That is 6.
if the pumps ended up taking mostly Tohickon Creek water instead of Delaware River main stem water.
Although the Neshaminy and Perkiomin Creeks would suffer, the downstream effect of the Delaware River itself would 'most likely be beneficial because of the elimination of the Tohickon Creek insult to the river.
Submitted by:
Norman Torkelson Box 22 Stockton, N.J. 08359 O
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SECTION V.
s, Water Quality: Other Areas of Impact e.c The following section is an excerpt from a document
' entitled, " Objections and Questions on Neshaminy Water
?
yJ< ;
Resources Authority Permit Applications NAPOP-80-534-3
[
ahd NAPOP-80-813-3, which was prepared by Del-AWARE Unlimited
-S.
and submitted to the U.
S.' Army Corps of Engineer ~s, July 6, 198'
- c.
"dF The permit applications referred to are: for construction
~}^
of the intake on' the Delaware River, and, rechannelization
,[
of Pine Run and North Branch Neshami ny Creeks.
These applications are pending the Corps' own review and consultation with other agencies, including the request presently befo're the Department. Referenced documents available<
Vater Quality : Bradshaw Reservoir /Perkiomen Discharge l
The size of the proposed 70 MG Bradshaw Reservoir has been in-creased from the 46 MG capacity proposed in 1973. Presently proposed storage allocations are: 18 MG for operating capacity 46 MG for emergency storage 6 MG for silt buildup 7U MG total No analysis is made of the rate of accumulation of the of the silt load, its impacts on water quality, the. frequency of sediment removal; nor of the location of a permanen't disposal site, presumable local'.
Bradshaw retention times will vary, depending on cooling water demand at Limerick, water d emand at the treatment plant, and whether water for the treatment plant passes into Brad-shaw or goes directly from the Combined Transmission Main via the by-pass into the North Branch Reservoir (Lake Galena)
Since there are, no publicly available analy,ses of data on the magnitud e of the pollutant loading to the East Branch Perkiomen Creek'from the discharge of Delaware River water, the estimates of the diversion's pollution loading to Lake Galena, although in themselves s ubs tantially und ere stimated.;
4
f4 offer o conservative indication of the impast of tha pollutant f
discharge into the Perkiomen's headwaters.
l This is suggested
~
because the average annual cooling water demand of 35 HGD at Limererick is comparable to the 33.6 MGD figure used by NWRA's j
consultant *as the annual average inflow from the Delaware'to Lake Galena for production of 40 MGD.
obviously, neithr water demand nor stream flows oc' cur in averages, and cyclical or seasonal loading should
- e. u;
,be evaluated for suspended solids, settleable solids, dis-solved solids, volatile and fixed solids, and heavy metals as well as nutrients.
Analysis should be made relative to ranges in temperature 'and retention time.
9 Water Quality Criteria and Effluent Standards'c
~
~
Antecedent Conditions.
It is noted that policies regarding stream quality and effluent loading are based on low flow conditions, not average conditions, and that pollution loading also varies with natural conditions such as temperature and cyclical or seasonal conditions.
Antecedent conditions also have been found to have a direct impact on Delaware River mainstream water quality, increasingly, deteriorating s tream quality as periods of dimin-ished flows lengthen.
(See Water jesources Engineers (WRE)
Reports to Delaware Estuary Model Technical. Advisory Committee and DRBC Level B Study Draf t Final Report.)
The quality of water diverted at Point Pleasant under summertime low flow or dro'ught conditions would be of lesser quality than water diverted under normal or average conditions.
Because of the known importance of antecedent conditions, 4
e b
OG 5 k
g t
f:v
=
1 D~
nnalyses of Delaware diversion impacts on the receiving stre Er ams and impoundments should be based on water sampling whi h 71.1, information on anteced c
carriee
~
ent conditions in the Delaware, e. g., prG cipitation, n;
temperature, Trenton flows, and actual flows at the
.. 7 P L, D Zf.
Pleasant intake site.
Antecedent conditions must also be
' t; ([
given for flows in the receiving stream *.
Ny It is also noted there appears to be no data on actu
~1 ral q,,
river. flows at Point Pleasant, and that percentages of water re-
?.~
.7, moved at Point Pleasant have been given as percentages of th flows at Trenton instead.
e Withdrawal percentages should be restated for actual flow at Point Pleasant and given also for low flow and drought conditions.
Operating Mode of North Branch Reservoir (Lake Galen a)
Because Lake Galena is already highly eutrophic and because this condition will.be worsened by accelerated pollution loading as the amount of, water from the Delaware increases, NWRA's consultant has recommended maintaining a hi h g
rate of flushing and has claimed that the more water pushed through Lake Galena, the more beneficial the diversion.
It is grossly irresponsible to ignore the impact passed on to' the receiving streams and the communities down stream from the reservoir.
This is of particular importance because of the anticipated diminished flows in North Branch
.t Neshaminy, Pine Run and Neshaminy mhinsten, and because these streams are-already water quality-limited stream segments Maintenance of a constant high water level in a reservoir for recrea tional purposes substantially reduces its utility 'for water supply purposes, and for this reason the 8
~
allocation for water supply in Lako Galenn wac cut by 50%.
Recreational benefits were then increased by this amount.
Although a ten month long, 20 foot drawdown is now the planned operating mode of Lake Galena no analysis has been mad e of how this wi11 affect recreational use of that fa cility.
(See
~
Exhibits C1 and.C2).
Such operational modes have been consi-
~
' dered " unacceptable at Nockamixon Reservoir and th
- e. proposed Evansburg Reservoir precisely for this reason and, further, because such a mode of operation would violate the cost allo-cation bene' fits used to justify construction.
If this mode of operation is used to purportedly. protect Lake Galena water quality while flushing the imposed, problem downs tre am, it appears that the Soil Conservation Service would be justified in assessing NWRA for the amount of lost recreational benefits.
Under-estimates of pollution loading to Lake Galena, J! orth Branch Neshaminy, and Neshaminy Creek:
Examples of
_ Inaccuracies in Dresnack Report. This report, " Impact of Delaware River Flow Augmentation on the Tro hi p
c State in Lake Galena" is appended as Exhibit B3 The consultant has estimated only poun'dage loadings of phosphorus.
Poundage leadings 'of other nutrients, e.g.,
- nitrogen, have not been estimated nor havy sediment loadings Ther'e are no estimates of suspended ' solids
, dissolved solids, volatile and fixed solids, heavy metals, or priority pollutants wh'ch include TCE 'and PCE.
i A simulated rather than an actual long-term average flow is used as the North Branch Neshaminy flow into Lake Galena The simulated average flow figure is questionable because it is
=
ralatcd to record:d flow dato at tha Langhorno gego en tha L
Neshaminy Creek.
Since
~
the Langhorne gage is downstream from several reservoirs, it is unlikely that it is indicative e
of flows which are not augmented or impounded.
,~
No figures are given for cyclical or seasonal pollu-tien loading to Lake Galena.
For example, no evaluation has been made of the impacts of spring and summer. overturns in
'+
p$'
^
either the Delaware River mainstem or in the receiving streams.
Vy The 1971-75 Delaware River samples contained sub-stantially higher levels for NO -N, NH
-N,. and total phosphorus 3
-m 3
s than most other data used for calculations in this report.
Al-though these samples were dismissed as being outdated, they were then favorabl /
commented upon by the author relative to the levels found in the North Branch Neshaminy.
The most recent sampling was taken at the Lumberville footbridge, 1.5 miles downstream from the proposed intake point.
The specific site is not' well described nor is there narrative or drawings to justify the author's claim that this site better simulates intake conditions.
Description of site and flow conditions are essential to evaluate validity of the data, particularly in view of the migration of the mouth of the Tohickon Creek and' River channel 'since completion of Nockamixon Reservoir in 19 73.
Filtered' samples were taken at -the i,umberville footbridgc-site.
Use of filtered s'amples is questioned because this filters out phytoplankton as we'll as inert solids.
Use of filtered Delaware River samples was justified by the author's assumption that, based on a 21 hour2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> retention time in' Bradshaw Reservoir, suspended material eroded from the River' bottom will settle out in Bradshaw.
We question this asstaption
in view of the proposed by-pass of the Reservoir and lack of set-tling time under maximum continuous pumping.
Present Violations of Stream Ouality Criteria in Stream) to Receive. Delaware River Water.
The following table was compilec r
from information in the cited figures in Ch, apter VI, " Existing Water Use and Quality", in PADER's Comprehensive Water Quality Management Plan (COWAMP/208), Lower Delaware and Schuylkill River' Basins, " Existing Water Uses and Quality", Draf t Chapter VI, June 1975.
Present Violations of Stream Quality Criteria of Streams to Receive Delaware River Water Discharged from Proposed Bradshaw Reservoir
.riteria Violation Stream Occurence Leg end Fig.No.
sissolved Oxygen Neshaminy Creek below Newtown Daily average VI-7 E.
Br. Perkiomen value violates cri teria during summer *
.E and Total N.
Br. Neshaminy, Pine Run, pH values periodi-VI-8
)issolved Solids Nesh aminy Crk., Perkiomen cally exceed 8.5 Crk.
otal Iron Neshaminy Crk, below Max. values VI-9 Warrington; Segments periodically exceed Perkiomen Crk.
1.5 mg/l
- opper Segments of Perkiomen Suspected max.
VI-l Creek values periodically exceed 0.1 mg/l S
Total soluble N..Ihr. Ne s h., - Pin e Run,.
Average values exceed VI-Phosphate Neshaminy Crk., & E.
Br.
criteria Perkiomen Crk.
Streams with high Neshaminy Crk, below High Values Reported VI acavy metals con-Doylestown for two heavy metals int.
Perkiomen Crk.
High Values Reported for three or more heavy metals
D-
~.:y
- Algco ccueco diurncl DO violctione may not dots ic usually collected during daylight hoursba shown because
.c The COWAMP/208 Draft Report N1 for Southeastern Pennsyl-w vania, DVRPC, April 1978, shows the mainstem Neshaminy Creek, East Branch Perkiomen and Perkiomen Creeks as Water Quality p.
ihl Lim,ited Stream Segments (p. 3-78, Fig. 3-17).
+%
yy
_ North Branch Water Treatment Plant Operating Mode
- n..
P(f.
Applicant projects NBWTP water pr,oduction as requiring the
[J initial installation of 10 HGD capacity, c
requiring increased filtration rates and installation of sludge dewatering fac-ilities to permit quadrupling production to 40MGD within four, to nine years from initial construction.
Objections raised relative to pollution loading to N.
Branch Neshaminy are applicable to Pine Run because during periods when the total flow of Pine Run is withdrawn for water supply purposes the only flows in Pine Run below the intake structure will be back flows from Lake Galena releases Design of NBWTP is presently unknown and it is not known whether it will include treatment for trihalomethane precursors, (one of which is algae),
as per EPA's recommenda-tions, or whether an exemption will be applied for. (See Exhibit C4)
Reduction of Neshaminy Ba' sin Stream Flows About 62%
of the mean daily flows of N. Brangh Neshaminy and 95% of the mean daily flow of Pine-Run will be withdrawn for C
water supply. during an average flow year.
Although' additional pumpages from Point Pleasant are required for partial replace-ment of the proposed water supply withdrawals, the replacement flows (Minimum releases)' below the intakes are expected to be O
losc than normal ficwa moat of tha tima and cdverac effect's on biota are anticipated.
~
Percentages of summertime low flows or of drought condition flows that will be withdrawn from the two s tre ams are not given, and although mainstem Neshaminy Creek flows
)
wi'll obviously be reduced by the taking of tributary inflows, similar percentages for withdrawals from the mainstem are also omitted.
t
- f.
In view of the underestimation of pollution loading including priority pollutsnts from Lake Galena to N. Branch Neshaminy, discretion would indicate that maximum precautions be taken in the design of the North Branch Water Treatment Plant.
Sedimentation at NBWTP Intake Damsites and Downstream Although the channel will be sloped downward as it approaches the intake structure, there is no evaluation of the of the volume or of the physical or chemical characteristics of the sediment which will accumulate either at these two sites or in the Neshaminy downstream.
Neither is there an identici-cation, description, or analysis of the disposal sit'e which will I
receive this accumulated sediment once it is dredged.
As water production increases, increased pumping at Point Pleasant and increased flushing rftes of Bradshaw and N. Brinch Reservoirs will increase sediment hecumulation at the intake dams and downstream, with increasingly severe but unevaluated water quality impacts.
Full evaluation of the cumulative physical and bio-chemical impacts above is essential before any further consi-deration of the permit applications.
f..
s-Considerations of n Dredging Proposal. Applicant O
states ( Application, p.5), "There is no present use of the i
i disposal site."
L Y. ;
~
The present Pine Run channel now provides e
m ecological, aesthetic and~ recreational uses of a natural
- ,c.;
stream bedt a
Treatment Plant site now serves as a flood plain n:.
. g. w and terrestial habitat.
h,,..-
Applicant states (Application, p.5) " Excavated materials are from alluvial deposits and will consist of a mis of clay, silt, sands and gravels.
While the bulk of this
, i, material will be sands and gravels, the clay and silt contente should be sufficient to permit compacting of the fills there-from to a relatively dense and impervious s tate. "
What are alternate plans if clay / silt content is insufficient to permit.
compacting the fills?
Applicant states (Application, p. 1) that excavation will remove apx. 18,770 and 6,280 cubic yards, respectively, from the Pine Run side and the N.
Br. Neshaminy side, and that after use to fill in and to reshape in the stream beds, the balance will serve to build up the plant site.
Since it seems doubtful that this remaining excavated material would be sufficient "to raise the plant site'by 4 feet (DRBC, EA, p. 1-9) what is the intended source of the remaining fill?
Will it 5
be suitable for placement in a floodplain?
How much additional fill will be required?[ -- -
Leachates to be produced; groundwater orotection plans <
Applicant states (Application, p.
- 6) "Not applicable" The same response is given to the question of " Chemical,composic tion of material" to be disposed of.
These answers are irres '
ponsible and unacceptab1'e.
Some leachate commonly occurs when
soile are compreosed.
In tha absence of.an data, the claim that there will be no leachate or concommitant water quality
,' impacts is unsubstantiated.
Data should be developed giving the chemical characteristics of alluvial deposits to be dredged, escavated materials, any supplemental fill needed, f
as well as the soils at the fill sites.
Such data for alluvial deposits should take into account upstream conditions such as abandoned lead mines (N. Br. Neshaminy) and industrial
,activ_i ti e s, for, e.xa.mple PFD Penn Color Inc.
on Pine Run Creek.
Additionally, there are no assurances that this site, long vacant, has not been used as a dump site, possibly for toxic wastes, whether legally or illegally.
There are no calculations on the additional compression of fill sites resulting from the added weight of dredged fill not from the installation of treatment plant facilities, including sludge lagoons.
The Corps (EA for Permit Application 80-0813-3, March 19, 1981, page 2, describes the soils at the site as "...nearly level, deep, poorly drained soils on flood plains.
They have a high water table, are wet most of the year, and are subject to flooding.
Permeability,,is moderate,or moderately, slow, and available water capacity is high.
Natural reaction is very strongly acid to' slightly acid."
Groundwater protection plans mdst take into account municipal well('s) operated by the Borough of'Chalfont located adjacent to the site.
6 G
e 6
e.o o o es, e
6
INDEX OF SECTION C EXHIBITS I
l.
Neshaminy Water Resources Authority, Significant Concerns at and af ter Public Hearing ~
Responses to of Environmental Report, flay 30, 1979, p.20, 11ain te-nance of Levels in Pa-617.
-4
~ r.;
2.
T Letter from Terry L.
Fought of E.H.
Bourquard, Asso-
'J, ciates, Inc., to Harold D. Sursa, Bucks County Water and L;.
Sewer Authority, concerning Reservoir PA-617 Storage Allocation, March 8, 1976
'i 3*
Dr. Robert Dresnack, for ?MRA, River Flow Augmentatica on the Trophic State in Lake" Impact of the D
' Galena, Nov. 1979.
4.
Bruce Stewart,- DRBC memo, April 13, 1978.
Trihalomethane precursors,'.
9 9.
S e
g?
4
' SECTION VI Impacts and needed studies of the Point Pleasant Diversion Project The Point Pleasant Diversion Project cannot be assessed in isolated: segments. The impacts to the environments down-stream and inland have not been evaluated.
j As substantial objections and questions have been raised in previous sections of this document as to the' location and
' operation of specific portdons of the Point Pleasant Diversion Project, and as these portions of the: project are defined as integral to.the successful and environmentally sound operation of the projectias a whole; Del-AWARE submits that
'th'e Departmente of Environmental Resources has the public
.re'sponsibility,to review all aspects
.9 of the project: con-struction, secondary and cumulative impacts, as part of the system, and the system in its entirety.
It is obvious that the environmental impacts of this
- e. project are far from minimum. This project is a large scale water diversi6n7that has far-reaching and serious impacts not limite, to. the Delaware River irt Point Pleasant, and the co'nfluence of the North Branch of the Neshaminy and Pine Run, but also,. that the physical, socioeconomic, and envir-onnental effects vill be felt throughout the region. -
" Comments to the DRBC have called for a complete and detailed financial plan to construct and operate the pro-
= -
{
tr.
jcet, including the cocial and economic cocto y,-
changes in tax structure, payments for liability and. mistakes relate.d to the generation of nuclear power. " (DRBC, 1980 B).
Such a financial plan and socio-economic evaluation of the Point Pleasa'nt Diversion Project is certainly nece ss,ary..
~
Del-AWARE requests that the Department of Environ-a.y
[
me,ntg1' Resources take its responsibility as representative
- 'i.
of the State and the public interest in this project to insure
~
~
that.each aspect of the project is adequately addressed. It seems>., unreasonable to expect that such an analysis can be made using presently availabl5 information, as previous documentation is incomplete, inacc urate, and discounts the many design and circumstantial. changes.
Del-AWARE also supports the conclusions reached in the ENVIRONMEljTAL ASSESSMENT AND SECTION 404 ANALYSIS THE POINT PLEASANT DIVERSION PROJECT (draft, Betz,
- Converse, Murdoch, Nov., 1980) Sections 4.1 through 4.4.2 as follows-
" 4.1 GENERAL t
In Ssction 3 of this i
tha t report, we have recommended further studies should be performed to adequately the environmental impacts of the Point Pleasant assess i
Diversion Project.
I address those significantThese studies are intended to adequate coverage in previous. studies. issues which have not been giv further work is recommended. to supplement the envi-Note that no ronmental inventory of the project area which is contained in previous documents.
Data gaps in the environmental inventory are not considered significant unless they impair the ability to adequately assess an environmental impact.
is included as part of the scope of work recommendedSome furth for studies of environmental impacts (e.g.,
identi-fying the project area wetlands).
However, no data collection for the sole purpose of environmental in-ventory is recommended.
NO 4
M a
)
Our recommendations The table references sectionsare summarized in Table 5.
data gaps are identified and where recommendationsof this report for further analysis are of fered.
tions describe the general purpose of each study The following sec-provide a preliminary study outline by task, and pre-sent an estimated study cost.
- 4.2 MODEL SYSTEM AND ESTABLISH OPERATION MODES 4.2.] Purpose of Study The purpose of ~this study is to use 'a mathe-matical model of the Point Pleasant Diversion Project system to simulate how the system will operate in low, average and high flow conditions.
be used to establish the need for and projected use The model will of any upstream reservoirs required to enable the system to operate.
From the model, an operating pro-cedure will be established to show what actions should be taken in response and service prioritiesto various weather conditions in the most environmentally sound marynerin order to operate
- basis, On this the quantities of water to be diverted and the in-stream flow rates projected in the' previous environmental references can be verified.
0
,_..I
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+-
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~
(continued )
I
/
W 4
G S
TABLE 5 RECOMMENDED STUDIES TYPE OF S.TUDY 9
Section of Report in which is Recommended or Noted
>=f n.,
Model system and establish 2.2.2 Modes of Operation *
,l,C operation modes and reliability 3.3.3 Surface Water Qualit
. a..
'?...
Quanity, and Biota Analyze population data and 3.3.6 Land Use*
.. secondary impacts of project 3.3.3 Surface Water QualiC.
Quantity, and Biota
- 3. 3. 4 '
Wildlife 3.3.5 Terrestrial Vegetati 3.3.7 Socioeconomics 3.3.8.1 Groundwa ter 3.3.9 History and Archaeol 3.3.10.1 Recreation 3.3.10.2 Aesthetics 3.3.11-Air Quality Evaluate financial plan and socioeconomic impact ov project 3.3.7 Socioeconomics*
, Evaluate environmental impacts of intakes on Neshaminy Creek and Pine Run 3.3.3 Surface Water Qualitz Quantity, and Biota
- Identify and evaluate impacts on wetlands 3.3.6 Land Use*
- These sections contain recommendations for conducting, needed studies.
The, remaining sections note some specifi'c purposes of the study.
Based on the results of' this' modeling effort, it will be possible to more accurately address issues such as the need for-additional reservoirs, the degree to which reservoirs will' be drawn down during low flows, the effect of the project on the salinity wedge in the Delaware River estuary, the degree of flow and velocity perturbations anticipated in the rivers and their ef fect on aquatic biota, the ability to reliably provide sufficient water to the nuclear power generating sta tion at Limerick,, t o a vo i,d,, an', pow e r,,,,,
t production curtailments, and the ability to reliably 4
l_
control the systcm to effectiv21y minimize advarsa environmental impacts.
4.2.2 Study Outline and Cost various models have been created and used to simulate conditions in the Delaware River Basin.
The DRBC used one such model in their Level B study (Delaware River Basin Commission, ] 9 79).
The Corps of
, Engineer,s is conducting a more detailed modeling e f fo rt.
However, nowhere in the references was such a-model described.
Therefore, the scope of work we are recommending assumes that no modeling has been
~
done.
A more appropriate scope of work and cost es-timate can be made a fter _ the modeling needs of this project are compared to the models which exist or are being developed.
With this provision, should be accomplished are listed below:the tasks which l.
Establish existing hydrographs for key points of water diversion system during low, flow years.
~
average and high These poin ts should include:
- Delaware River above Point Pleasant in'take
- Delaware River below Point Pleasant intake Delaware River at Trenton North Branch Neshaminy Creek below discharge of North Branch transmission main North Branch Neshaminy Creek below intake at North Branch treatment plant Main stem Neshaminy Creek below confluence with Norht Branch Neshaminy Creek East Branch Perkiomen below discharge of East Branch Perkiomen trasmission main Perkiomen Creek below intake
- Schuylkill River below intake 2.
Develop a computer model of the system operation.
Include all reservoirs needed to operate the system and all water courses af fected by the project.
3.
Establish the most beneficial mode of o;o$ rating the system and evaluate the ability to reliably control the system in this mode.
(Include in the evaluation consideration o.f who is responsible for operating the dif ferent components of the system.)
4.
Create hydrographs for low,.avera.t l
ge. and high flow conditions assuming that the system is operating.
5.
Eva lua te the expected environmental af fects of the modified strehm flows represented in the hydro-graphs.
The estimated' cost of this s tudy isS l'0 0,0 0 0 to S200,000; it is expected to take 12 to 18 months.
~-
- 4. 3 ANALY2E POPULATION DATA AND SECONDARY g.,
[
4.3.1 Purpose of Study
~~
The purpose of this study is to evaluate g,.b Diversion Project. secondary impacts associated with the Point Plea the
~~
c V-An analysis should be made of the most recent population and water use data and trends.
t.;'
~ the quantity and aerial extent of population gro Q;l. :
induced or accommodated by the project
'$P 196 relationship between the project The inter-and the operation of the nuclear power generating station at Limerick g_4 and its environmental impacts hould be described.
f, However, the environmental impacts
'- y; by referencethe nuclear power generating station should be included associated with
.0 to existing sources.
U19 4.3.2.
C Study Outline and Cost The following tasks should be accomplished.
as part of th'is study:
1.
Use current population estimates and trends to re-evalua te the population data used in de-signing the project.
2.
Re-evaluate water needs in the service areas based on population da ta and water consumption trends.
Include an evaluation of water conserva-tion.
3.
Evaluate the impact the project will' have on the quantity and aerial extent of population growth 4.
Evaluate the secondary impacts of projected service area development on climate, air quality, wildlife, vegetation, surface water quantity l
- and quality, aquatic biota, groundwa ter, aesthetics, i
recreation and cultural resources, and any addition-al. relevant factors.
5.
Describe the relationship between the operatica
~
of the nuclear power generating station at Limerick (and its attendant environmenta.1 impacts as previously assessed) and the Diversion Project.
Point P,leasant t
- 4. 4 EVALUATE THE SOCIOECONOMIC IMPACT OF THE PROJECT l
(.
t l
4
-,e
4.4.].
Purpose of Study The taskswhich should be performed as part of this study are:
1.
Obtain financial plan for project from PECO and the tWRA.
2.
Analyze distribution of project costs to project users 3.
Based on existing socioeconomic data for the affected area,
~
evaluate the primary and secondary socioeconomic impacts of the project Th'e estimated cost of this study is $6,000; it is expected to take 4 months.
~
Obviously the operation, efficiency and environmental im-9 pacts of the Diversion cannot be adequa tely addressed until the full scope of the diversions capabilities and planned increase in size is considered.
As noted in previous section, the facil-ities are capable of diverting up to 250 million gallons of water per day from th'e Delaware River. It.is misleading to evaluate the project. in terms.of the presently proposed 95 million gallon per day capacity, when plans call for vast expansion of the system.
The Neshaminy Water Resources Authority.! Trust Indenture calls for additional water withdrawal, and since there has been.
no attempt on the part 'of the County Commissioners or the A,uthor-ity to revise the figures contained in the indenture, and one commissioner (Elaine P. Zettick) has publicly acknowledged the h
I
plcnn2d c xpnnsion of the system, it is unfounded to evaluate the project on anything other than it s known maximum capabilities.
The construction of upstream reservoirs, particularly.
the Merrill Creek Project in Warren County New Jersey, shoud be r -
included in any evaluation of the project, as it seems that the L;~
.j projects successful operation especially in periods of low
- flow, m i'd
- is dependant on these reservoirs.
Therefore, need for the con-w-
struction of these reservoirs and the associated impacts should
.. =.
9 be assessed in conjunction with the water diversion project, as
"' [
they are, in ef fect, part of it.
Regional Impacts of the Poin t Pleasant Diversion The impacts of the Point Pleasant Diversion Project are many, and potentially serious with respect to the environments, communities and citizens in the region.
The effect of the changed flow regimes in the Delaware and Schuylkill Rivers, as well as the North Branch of the Neshaminy and the East Branch Perkiomen Creeks; The effects on water quality in the recieving streams; the impacts of operating the nuclear generating station at Limer-
~
ick, and the impacts on growth and development in Bucks and Mont-gome ry Coun ties ; and all associated impacts.- must. be addressed.
.t The effects of _ this project on population. growth and development in Bucks and fjontgomery will be substantial.
As a need is recognized' for the sensible and well planned growth of our communities, as well as the preservation of open space and n
farmlando, we cubmit that thic project will have an exag-gerated effect on the development of the counties. The effects of development are known to be increased costs for municipal services; changes in the tax structure and real estate values and a loss of aesthetic values integral to the preservation of the quality of life in the region. And in this case, create a dependence on an already oversubscribed surface water resource.
The Pennsylvania State Water Plan states that water should ' not be transferred from one basin to another wh'en the receiving area has not fully developed its own water resources. This inter-basin diversion is not in accordance with this prerequisite. It is evident that local water resources are available in adequate supply and at less expense to the communities which will receive the water.
Areas of Impact The diversion of water from the Delaware River at Point Pleasant, Pennsylvania, and the many components. of the system used to divert, carry, direct and distribute the water will all seriously af fect the people, water, aquatic and terres-trial life of all areas which are directly and indirectly touched i
l i
In previous documents prepared by tne Delaware Hiver Basin Commission (DRB C), the Neshaminy Water Resources kuthority (NWRA),
and the Philadelphia Electric Company (PECO), the im-pacts of this system have been inadequately studied, and must
(
be addressed by the DER some specific concerns not mentioned previously, are addressed below:
l
~
0 Combined Transmission Main to Bradshaw Reservoir The transmission main may leak, given the corrosive L
effects of the soils and the high operating pressures inherent in a head of water of three hundred and fifty feet Th e', impacts of raw river water leaking into the water table are nowhere con-n
~
sidered.
n c
~
]
Perkiomen Creek The Environmental Assessment prepared' for the Corps (Betz Converse & Murdoch, January 1980) states that i
the Philadelphia Electric Company no longer intends to utilize any of the natural flows of the Perkiomen Creek. ~Is this information correct?
If so, will the utility's demand for Delaware River water increase?
Will ~ the potential for 4
flooding on the East Branch Perkiomen increase?
Use of natural streambeds as open channel conveyances This method of transporting water saves money but wastes water and degrades streams.
Flooding is more likely.
Water evaporates enroute.
Bank erosion, streambed scour, turbidity, increased sedimentation, periodic dessication and increased pollutant loadings are among the impacts anticipa-ted.
Consideration must also be given ~to how mnch water the
^ * '
streams would be expected to carry when the system is enlarged In its Tinal Eviron' mental Assessment, August 1980, the DRBC states on page IV-63, "... doubling the velocity from
~
2 to 4 fps, the sediment increased 3 3 times... "
This means any e
e e
S
t increase is felt dramatically.
We suggest that the use of open stream beds for conveyance of water is environmentally unacceptable.
A full assessment of the use of stream beds for the transport of water, and their inclusion in the regional water supply system is necessary, in order to evaluate all of the en-vironmental as well as legal implications to the streams themselves and the resident water users that' reside along them.
We challenge the evaporative use 'of 46.2 million gallons
~
per day of water at the Limerick nuclear generating station, as unnecessary.and detrimental to the water sheds of the region.
- And, we submit, that the Philadelphia Electric company, as the single largest user of the water, will be subjecting the environment and.
thousands of people to unnecessary adverse impacts by obtaining it's water from a rela tively distant loca tion, especially unnec '
essary in light of the fact that more local sources of water are available for their developmen t.
e e
9
+
CONCLUSION
(
We have outlined some of the unstudied concerns and potential adverse effects that the diversion of water at Point Pleasant may cause to the water quality in the region In view of the considerable concern and opposition ex-pressed by members of the public and elected representa-tives, we strongly urge that there be a full evaluation by the Department, including public hearings held in the areas of impact.
Hearings should deal with the following:
-the adverse effects
-the problems on the State Water Plan of salinity in the Delaware River
-the potsntial impossibility of finding a safe and environmentally sound intake location in the Point s
Pleasant area.
-the impacts of d ff erent operating scenarios, both e
as to the effects on the Delaware River and the economic and environmental effects on the service area
-the impac~ts of transferring toxics from the Delaware River into the Neshaminy and Perkiomen watersheds
-the relationship to the Limerick project, to which it is an ad junct We expect a full technical review by the department, a thorough analysis of all evidence and a recognition of the interreBationships of the effects of the component parts and the project as a whole. such that the decision made the best interes.ts is in of the citizens of the region.
S k.
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, s TABLE 2.5a AflALYSES Oft WET SOLIDS Organochlorine Pesticides, Poly _ chlorinated Biphenyls and lierbicide Fraction (milligram / kilogram)
Compound Sample from Site.
D-2 D-4 D-6 D-8 D-ll D-13 Aroclor 1016 IID tid fl0 ND ND ND Aroclor 1242 Aroclor 1248 0.43 0 [46 0.43
- 0. 4,0 '
Aroclor 1254 tid ND ND ND n OllC y OllC (Lindane) y v
v (Y OllC 0.13 0.15 0.61 heptachlor ND ND ND aldrin heptachlor epoxide v
V v
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ilD - Not Detected 4
d
Y 8
TABLE 2.Sa (continued)
AtlALYSES Ott WET SOLIDS Organochlorine Pesticides, Polychlorinated Biphenyls and lierbicide Fraction (milligram / kilogram)
Compound Sample from Site D-2 D-4 D-6 D-8 D-11 D-13 y chlordane fiD fl0 fl0 fl0 tid fiD p,p' - DDE 0.033 0.021 0.054 fl0 dieldrin fl0 f1D endrin o,p' - DDT v
s7
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~.
mirex methoxychior V
V
't y
taxaphene sf sg
110 - flot detected 1
I TABLE 2.5b EP T0XICITY ANALYSES Oil WET SOLIDS Ileavy Metals (mi11igram/li ter)
Element Sample D-l D-2 0-4 D-5 D-6 D-7 D-8 D-9 D-10 0-11 D-12 Cd ND fl0 ND fiD fl0 fl0 t1D flD fl0 HD fl0 Cr Cu y
s.g V
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v v
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i TABLE 3.7 COMPARIS0N OF RULES AtlD REGULATI0 tis'FOR PCB DISPOSAL PCB Concentration Ranges milligrams / kilogram (ppm)
Regulation 0-10 10-50 50-500 50-1000
>l000 fl.Y. State (Ref.,3.13) minimize PCB minimize PCB incinerate or incinera te loss.for loss from chemical landfill ordinary spoil site spoil site USEPA (Ref. 3.6) plow into soil i
(Refs. 3.9, 3.10) less than incinerate or 50 ppm - no chemical
)
regulations landfill 1
({JDLP (REf. 3.7) 0.5 suggested upper limit for land spreading l
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