DECEMBER 21, 2012 SUPPLEMENTAL REPORT TO WRITTEN COMMENTS ( ) SUBMITTED BY THE SOUTH JERSEY BAYSHORE COALITION

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1 DECEMBER 21, 2012 EFFECTS OF THE SALEM COUNTY WATER QUALITY MANAGEMENT PLAN AMENDMENT ON THE STREAMS, GROUND WATER RESOURCES AND WATER SUPPLIES OF SALEM COUNTY SUPPLEMENTAL REPORT TO WRITTEN COMMENTS ( ) SUBMITTED BY THE SOUTH JERSEY BAYSHORE COALITION The South Jersey Bayshore Coalition (SJBC) has reviewed the proposed amendment to the Lower Delaware Water Quality Management Plan (WQMP) which would adopt a Future Wastewater Service Area (FWSA) map and a designated Sewer Service Area (FWSA) map for Salem County pursuant to P.L. 2011, Chapter 203 that purports to comply with the New Jersey of Department of Environmental Protection s (NJDEP) regulatory requirements of the 2008 Water Quality Management Planning Rule, N.J.A.C. 7:15 et seq. This amendment proposes significant expansion of FWSAs in Salem County. This expansion will be in conflict with several of New Jersey s environmental statutes and the NJDEP regulations and policies. Below is a description of each inconsistency as well as recommended means of mitigating the deficiency in the form of general and specific comments and recommendations. General Comments and Recommendations Issue - Inconsistent with the New Jersey Statewide Water Supply Plan N.J.A.C. 7: (f) specifies that the Department shall not adopt an amendment to a wastewater management plan if water supply needs associated with that plan are in conflict with the most current New Jersey State Water Supply Plan (NJSWSP). The most current plan is the 1996 NJSWSP which indicates that Salem County is in water supply planning area # 20 (Salem River) and #21 (Maurice River). According to the plan, the Maurice River planning area had a water supply deficit of 8.5 million gallons a day (MGD). Consequently, the amendment to the Salem County WQMP is in conflict with the most current NJSWSP, and requires the appropriate mitigation measures specified in WQMP regulations. None of these requirements is identified in the proposed amendment. Further, as discussed below, the NJDEP considered the 1996 NJSWSP to be a living document that was subject to updates of water availability as investigations were completed. The 1996 NJSWSP informed its readers (including decision makers at the NJDEP) that these updates should be utilized when evaluating proposals that can affect water resources (NJDEP, 1996, page 30). Several of these investigations have been completed since the 1996 NJSWSP was completed, but were not included in the amendment to the WQMP for Salem County.

2 Despite the NJDEP commitments over the last decade to release the next NJSWSP so that wastewater management planning agencies could adequately coordinate wastewater planning with water supply planning, and the legislature enacting a statute that required the NJDEP to complete the next NJSWSP by December 31, 2006 (N.J.S.A. 58:1A-13.3[a]), the NJDEP has yet to make this document available. In its absence, the SJBC conducted its own evaluation that utilized more recent and accurate demands while employing the same methodology purportedly used in the upcoming NJSWSP. That methodology includes a water supply availability threshold for depletive (water exportations) and consumptive (evaporative loss) withdrawals. Depletive and consumptive water uses in a watershed in excess of the threshold is concluded to degrade aquatic ecosystems. Its results show a significantly more severe water supply problem than that shown in the 1996 plan and are described in detail below. The SJBC analysis concluded that only one of the 10 watersheds that either are wholly or partially in Salem County were within the water supply availability threshold that is proposed to be used in the next New Jersey State Water Supply Plan. The watersheds ranged from currently using zero percent of the threshold to 1,189 percent of the threshold, averaging 292 percent of the threshold. As a whole, depletive and consumptive water withdrawals would need to collectively be less than 29 MGD in these watersheds in order to protect their natural resources. In contrast, 73.1 MGD is presently depletively or consumptively used. If all of the water withdrawals in these watersheds were allowed to increase demand to the full permit limits allocated by the Department, the watersheds ranged from using zero percent of the threshold to 1,756 percent of the threshold, averaging 510 percent of the threshold. At full allocation, depletive and consumptive water withdrawals in these watersheds are simultaneously estimated to be 112 MGD. As described above, no more than 29 MGD should be used if the aquatic resources are to be maintained and protected as required by the Water Quality Management Planning Act and its subsequent regulations. The NJDEP can readily review the draft NJSWSP to confirm these SJBC findings. The proposed amendment to the WQMP for Salem County will facilitate the above impacts as the sewer expansions increase dense development and water supply demands grow. As described below, the 1996 NJSWSP made several recommendations to conduct comprehensive investigations to better estimate water availability in the southeastern region of the state because that plan recognized that the water availability threshold that was employed was a simplified planning tool to only be relied upon in the absence of investigation that more accurately quantify water availability (NJDEP, 1996, Pages 25 37). The findings of these initiatives are discussed below in reference to the amendment to the WQMP for Salem County to expand sewer service. The United States Geological Survey (USGS, 2005, page 1) recently conducted a comprehensive investigation of the Upper Maurice River in Salem, Gloucester, Atlantic and Cumberland Counties upstream of Union Lake ((USGS, 2005, page 1). Eastern Salem County is located within

3 the Maurice River watershed (the Maurice River makes up its eastern political boundary), including major tributaries such as Muddy Run and Scotland Run. With regard to Salem County, this investigation concluded that baseflow reduction was nearly 62 percent at Scotland Run using withdrawals during a repetition of 1995 drought conditions. At maximum allocation, there would be no baseflow in the stream. At withdrawals, baseflow in Muddy Run would be reduced by 38 percent. At maximum allocation, there would be no baseflow in the stream under these conditions. Base flow in the Maurice River upstream of Union Lake was simulated in the USGS model to decrease by nearly 26 percent using withdrawals during a repetition of 1995 drought conditions. At maximum allocation, baseflow would be reduced by 93 percent. This more recent USGS investigation more than confirms the findings of the severe water supply situation in Salem County. Because of recommendations made in the 1996 NJSWSP and its subsequent action programs, the USGS also recently conducted a comprehensive investigation of the Potomac Raritan Magothy (PRM) confined aquifers of northern Salem and southern Gloucester Counties (USGS, 2011, pages 1 and 2). These aquifers provide the majority of potable water for both Counties. The USGS predicted that wells in these aquifers at maximum allocation will result in average simulated water level declines in the Upper, Middle, and Lower PRM aquifers of 156, 95, and 69 feet below sea level, respectively. Pursuant to NJDEP regulations, these declines are sufficient to declare an Area of Critical Water Supply Concern for this region. In addition, the USGS predicted at full allocation that local stream baseflow would be reduced by 29 percent, or 6.6 MGD compared to the streamflow reductions that would occur in the year With regard to saltwater intrusion, the USGS investigation pointed out that two areas in Salem County have already experienced acute problems with saline water in the PRM aquifer. Sodium and chloride concentrations in groundwater in these areas are near or above the secondary drinking water standard. Wells in Woodstown Borough are vulnerable to saltwater intrusion because of their close proximity to the saltfront in the aquifer. Elevated chloride concentrations found in wells in Oldmans Township are because of the proximity of these wells to the saltfront in this aquifer and their proximity to the brackish waters of Delaware River and its tributaries. While withdrawals south of Penns Grove were not analyzed in this investigation, these wells are thought to susceptible to saline water due to similar reasons. Increased demand due to expansions of the FWSAs along coastal Salem County is likely to accelerate these problems. Taken together, the 1996 NJSWSP and investigations that were recommended by the 1996 NJSWSP paint a picture of major water supply issues throughout Salem County. The proposed amendment to the Lower Delaware WQMP for Salem County is in conflict with the 1996 NJSWSP and the findings of its subsequent investigations that clearly demonstrate the ominous nature of the County s future water supply. The amendment will facilitate dense development as the proposed FWSAs reach build-out and further increase demand, thereby exacerbating the current water supply problems in Salem County. The likelihood of Salem County needing to

4 implement an expensive alternative water supply is formidable. The amendment did not address these conditions. Recommendation on Issue N.J.A.C. 7: (f)2 identifies several measures to mitigate a conflict with the NJSWSP when the existing water supply is insufficient to provide for the needs identified in the WQMP at buildout. These measures include conservation, reuse, obtaining a source with available capacity, and reducing the amount of water demand by reducing the amount or altering the type of planned future development. The SJBC recommends that these measures be evaluated and selected prior to approval of the amendment to the WQMP for Salem County. Inconsistent with the Surface Water Quality Standards The proposed amendment ignores that the increase in water supply demand accompanying the expansion of FWSAs would have adverse impacts upon the waters of Salem County pursuant to the Surface Water Quality Standards (N.J.A.C. 7:9B-1 et seq). More specifically, N.J.A.C. 7:9B- 1.5(a)6 stipulates existing uses shall be maintained and protected. Designated uses shall, as soon as technically and economically feasible, be attained wherever these uses are not precluded by natural conditions. In addition, N.J.A.C. 7:9B-1.5(a)9 states that the NJDEP use the Integrated Water Quality Monitoring and Assessment Methods developed pursuant to N.J.A.C. 7: to evaluate water quality data and identify waters where water quality does not meet the Surface Water Quality Standards at N.J.A.C. 7:9B as required by Section 303(d) and 305(b) of the Federal Clean Water Act. There was no evaluation of how the diminished flow in the watersheds of Salem could affect these uses or environmentally sensitive areas (ESA) if the expanded FWSAs were approved. As described further on, several of the watersheds are already not attaining their designated uses for numerous parameters. Approval of the amendment will exacerbate this condition. The SJBC conducted an additional supporting analysis to determine if withdrawals in the watersheds of Salem County are affecting the NJDEP s designated uses and environmentally sensitive areas. The SJBC estimated how the flows of the watersheds would be affected by current and allocated depletive and consumptive water withdrawals by analyzing 7Q10 flows (Appendix B). The 7Q10 is a natural drought flow that the Department employs to protect water quantity and quality, and maintain and protect the natural resources of a watershed. If depletive and/or consumptive withdrawals exceed the 7Q10 in a watershed, streamflow can be totally depleted in that watershed (i.e., they go dry), and the designated uses and ESAs of that watershed would be highly impaired. Ample supporting data and specific ESAs that are likely to be impacted are identified in detail below. The SJBC analysis found that current water withdrawals are reducing the 7Q10 from zero to 243 percent, averaging 92 percent. In other words, many of the watersheds of Salem County will be dried up during an extended future drought based on current demand. Most of the streams in Salem County are not attaining their designated uses for aquatic life. The SJBC believes that severe streamflow depletion is contributing to this impairment in many of these waterbodies. Aquatic life requires ample freshwater flows to survive. As the FWSAs expand and other development grows, and water demand increases toward full allocation, withdrawals are expected to reduce the 7Q10 from zero to 359 percent, averaging 182 percent. This means that

5 several watersheds in the County will be dried up during non-drought conditions. It is difficult to argue that the designated uses of the streams of Salem County can be attained or ESAs adequately protected within its watersheds if streams that do not flow any longer during low rainfall periods. These current and projected conditions have not been assessed in the WQMP amendment for Salem County. Recommendation on Issue The SJBA recommends that an evaluation be done of how expanding FWSAs in Salem County will affect the County s stream segments prior to approving the proposed WQMP amendment. Inconsistent with the Ground Water Quality Standards The Ground Water Quality Standards establish the designated uses of the State's ground waters, classify ground waters based on those uses, and specify the water quality criteria and other policies and provisions necessary to attain those designated uses. Designated uses are assigned as primary or secondary uses of ground water and include maintenance of special ecological resources, potable water, agricultural and industrial water supply. Excessive well withdrawals can impair the designated uses of ground water from both a quantity and quality perspective. For example, ESAs can be severely impacted if excessive well withdrawals dewater wetlands that are inhabited by these natural resources and are dependent upon them for specific hydrologic functions. Potable, agricultural and industrial water supplies can be lost if excessive well withdrawals result in saltwater intrusion. Freshwater wetlands along streams in the outcrop areas of confined aquifers can be converted to freshwater wetlands as confined aquifer wells increase pumpage. These withdrawals may also increase the concentrations of pollutants as freshwater dilution is reduced. The expansion of FWSAs in Salem County will in some watersheds increase the potential for these impacts. The amendment to the WQMP for Salem County has not addressed these impacts. The SJBC examined their potential impacts in detail the Watershed Analysis Section below. Recommendation on Issue The SJBA recommends that an evaluation be done of how the effects of expanding FWSAs in Salem County will affect the County s ground water resources prior to approving the proposed WQMP amendment. Absence of Holistic Assessments The wastewater management plan evaluations that were submitted to the NJDEP were not holistic. They focused on localized effects and ignored regional activities that may have significant environmental impacts. For example, much of Salem County relies on confined aquifers that cross county borders. The combined withdrawals from these aquifers are leading to saltwater intrusion in the wells closest to the saltfront. This was not evaluated. Alternatively, watersheds often cross county borders. Activities in watersheds upstream of the county border can lead to water quality degradation in the county undergoing an amendment to its WQMP. This too was ignored in the Salem County amendment to its WQMP. Recommendation on Issue

6 The SJBA recommends that an evaluation be conducted of the effects of regional resources be assessed prior to expanding FWSAs in Salem County. Absence of Wastewater Management Plans Some towns and agencies have not yet submitted updated wastewater proposals to Salem County, or that recent updates were not available for review at the NJDEP. This precluded the SJBC from conducting an adequate environmental review of the amendment to the Lower Delaware WQMP for Salem County. Recommendation on Issue The SJBC recommends that a determination on the proposed amendment to the Lower Delaware WQMP for Salem County not be made until all the required wastewater management plans are available for public review. Introduction/Background The County of Salem previously submitted a WQMP to the NJDEP and the County has recently proposed the Amendments to the FWSAs for these plans. The purpose of a WQMP is to establish policies, procedures, and standards which, wherever attainable, help to restore, enhance and maintain the chemical, physical and biological integrity of the waters of the State, including ground waters, and the public trust therein, to protect public health, to safeguard fish and aquatic life and scenic and ecological values, and to enhance the domestic, municipal, recreational, industrial and other uses of water. An increase in sewer service area requires an increase potable water to meet the demand of the residents and businesses that will occupy these generally densely developed areas. If the water supply source that will serve these new inhabitants is from a surface water supply or unconfined/semi-confined aquifer that is located in close proximity to the wastewater treatment plant that discharge to the same sources, and the new inhabitants conserve water, streamflow depletion or other undesirable effects are typically not a problem. Water is used and returned to the same source. These effects can be severe, however, when the water source is distant from the discharge as there can be losses in streamflow between the source and the discharge (i.e., a depletive use). The effects can also be precarious to the water source when excessive amounts of water are utilized for irrigation (i.e., a consumptive use). These depletive/consumptive uses are known to dewater streams and wetlands. In addition, excessive water withdrawals from a confined aquifer to meet the water supply needs of an expanded sewer service area can lead to saltwater intrusion and/or streamflow and wetland dewatering, especially in the recharge area of the subject confined aquifer. These effects are often over-looked when sewer service is being expanded, or are not properly analyzed when they are being evaluated. When this occurs, new water supply alternatives are frequently needed. For example, sewer systems were significantly expanded in Camden and Gloucester Counties during the 1970 s and early 1980s. This directly resulted in saltwater intrusion in Gloucester County. As a result, substantial cutbacks in use of the confined aquifer

7 were required and tens of millions of dollars in water supply infrastructure were required to compensate for the cutbacks and meet new demand. Another example is in Ocean County where regional sewering and excessive use of the unconfined aquifers have led to severe streamflow losses to the Barnegat Bay. Salem County obtains its water supplies for domestic, public, industrial, commercial and agricultural uses from sources that are totally in the County (e.g., an unconfined aquifer in a watershed that is located entirely in the county, or from water supplies it shares with other New Jersey counties (a confined aquifer such as the Potomac-Raritan-Magothy aquifer system) or even other states (e.g., the Delaware River). In the first case, all uses and their demand must be accounted for in order to conduct a proper assessment. In the latter two cases, an evaluation of the water supply must consider the uses and demands from within the County and the other users outside of the County. No such evaluations were made in the amendment of the Lower Delaware WQMP for Salem County. 1 Elmer 2 Woodstown 3 Salem

8 4 Penns Grove 5 Oldmans Township 6 Carneys Point Township 7 Pilesgrove Township 8 Mannington Township 9 Pennsville Township 10 Elsinboro Township 11 Lower Alloways Creek Township 12 Quinton Township 13 Alloway Township 14 Upper Pittsgrove Township 15 Pittsgrove Township

9 Objectives of the SJBC Analysis Project This project has three primary objectives. The first is to analyze the potential effects on streamflow of water demand increases from unconfined aquifers and direct surface water intakes that potentially may occur because of increases in sewer service areas in Salem County. More specifically, it will assess the current and future effects on drought flows in the ten HUC 11 watersheds partially or entirely within the County that result from the increase in withdrawals needed to meet the water supply needs of the expanded sewer service areas and other development in the Salem County WQMP. To ensure that the impacts of the expanded sewer service are evaluated holistically, this analysis will evaluate the cumulative effects of all withdrawals in Salem County, as well as those in bordering counties when watersheds flow into and out of Salem County. Drought flows are the most vulnerable of all flows with regard to deleterious impacts to aquatic resources, water quality and other users and uses of streams. Where appropriate, specific impacts will be evaluated including negative impacts to Category One Waters, water bodies that are inhabited by Threatened and Endangered Species, environmentally sensitive areas (ESAs), estuaries that may be affected by saltwater migrating upstream, streams where downstream wastewater discharges may be impacted, already impaired waters, saltwater intrusion along the coast, etc. Particular reaches of streams that will be negatively affected will be identified. Maps will be employed to illustrate negative impacts. In addition, an evaluation will be made to determine if any streamflow effects may be in conflict with NJDEP statutes and regulations. The second objective is to assess the potential for saltwater intrusion in the confined aquifers of Salem County that might occur as demand increases from these resources because of the proposed FWSA expansions and other forms of development. The majority of the County s drinking water supply is from these resources. As described in this report, wells in the confined aquifer of Salem County are vulnerable to saltwater intrusion as a result of its location in close proximity to the naturally occurring saltfront (the 250 PPM isochlor [drinking water standard]) and the fact that the recharge areas for these confined aquifers are either under the Delaware River or within the tidal reaches of the Delaware River. The third objective of this project is to assess the potential for contamination of the water supplies of Salem County by manmade substances. Unconfined aquifer wells are known to be often impacted by human activities. Salem County is unique in its potential for contamination of its confined aquifers. The majority of confined aquifer wells used for potable water is located near the recharge areas of these aquifers. Since much of the growth that will be facilitated by expansion of the FWSAs is atop these recharge areas, the possibility of contamination is significantly heightened. When all three of the above assessments are complete, this project will provide a holistic perspective of the state of the water supply of Salem County as new demand is placed on this supply due to expected increases in demand facilitated by the expansion of FWSAs and other demands in the County.

10 1996 New Jersey Statewide Water Supply Plan, Subsequent Action Plans, and Recommended Investigations As described above, the WQMP regulations stipulate that the NJDEP shall not adopt an amendment if water supply needs associated with that plan are in conflict with the most current NJSWSP. The most current plan is the 1996 NJSWSP. The next plan is expected to be released in The 1996 NJSWSP disaggregated the state into 23 large planning area watersheds (NJDEP, 1996). It employed a simplified planning methodology to estimate ground water availability in the planning areas. It utilized the concept inherent in the hydrologic cycle; that is inflow (or recharge) into a ground water system is equal to outflow (or discharge to streams or ground water flow at the saltwater interface), over time (NJDEP, 1996, pages 31 33). The more water removed from a ground water system in a planning area by depletive uses (e.g., exportation of water out of the area by sewering) and consumptive uses (e.g., evapo-transpiration losses that accompany irrigation), the greater reduction to streamflow and/or the greater the potential for saltwater intrusion. Based on previously conducted comprehensive geo-hydrological investigations, the NJDEP made the assumption that ten percent of recharge could be made available for depletive and consumptive water uses in the coastal planning areas of New Jersey without placing an unacceptable regional stress on its resources. The resulting values would serve as a surrogate for the resource s dependable yield, unless more comprehensive investigations concluded otherwise. Due to the size of the large planning areas, the plan did qualify that more localized stresses could occur when employing its planning thresholds. It also specified that the planning thresholds are for planning purposes only, and assumes that withdrawals are optimally located (i.e., spread out through the planning area, not located in close proximity to the naturally occurring saltfront [250 PPM isochlor or 50 PPM sodium line of equal concentration). The plan points out that wells that are not optimally located can accelerate saltwater intrusion. Other stipulations in the plan are described below. The 1996 NJSWSP placed Salem County in water supply planning area #20 (Salem River) and #21 (Maurice River). For planning purposes, the 1996 NJSWSP combined the two areas in Chapter Six based on the assumption that water supply problems in #21 may be potentially resolved by the water resources in #20 (NJDEP, 1996, pages 89 91). According to the plan, the Salem River planning area had a 1990 water supply surplus of 12 million gallons a day (MGD), while the Maurice River planning area had a water supply deficit of 9 MGD, for an overall surplus of 3 MGD. That plan projected that by the year 2010 the Salem River planning area had a water supply surplus of 9 million MGD, while the Maurice River planning area water supply deficit would grow to 18 MGD, for an overall deficit of 9 MGD. The plan also indicated that the confined aquifers in the Salem River planning area are subject to saltwater intrusion. The 1996 plan, however, placed a caveat on the possible use of surplus waters in #20 being used to address deficit conditions in #21. It indicated that these surplus supplies may not readily be available because of their location in Critical Water Supply Area #2, and their susceptibility to

11 saltwater intrusion. It is suggested that most water resource managers would agree today that the potential for conveying water supplies from #20 to #21 would provide little if any relief. According to the plan, the challenges facing planning area #20 are the protection and optimum use of its present resources. Current supplies should be carefully monitored to prevent demand from exceeding available water. Baseflow reductions could continue to be a test for the area because streams in southern New Jersey derive a large percentage (80 90 percent) of total flow from ground water discharge. The Plan also cautioned that surface water withdrawals in the planning area deserve further evaluation to determine their impacts during low flow periods. Further, water withdrawals by the PSE&G nuclear power plant from wells tapping the Wenonah- Mount Laurel aquifer have been documented with increased chloride levels, thereby limiting the aquifer as a potential water supply. According to the 1996 NJSWSP, the challenges facing planning area 21 will be to determine if ground water optimization schemes can resolve potential water supply problems. Ground water is available in the planning area, but it must be developed strategically. Depletive water uses associated with sewering and withdrawals without minimum passing flows could continue to be a problem in the planning area. Other issues affecting water availability could be the inclusion of the Maurice River in the Wild and Scenic River Program and significant ground water contamination sites. In recognition of the potential for water supply concerns in the two planning areas located in Salem County, the 1996 NJSWSP and its updates recommended a number of investigations be conducted. 1. Simulated Effects of Allocated and Projected 2025 Withdrawals from the Potomac- Raritan-Magothy Aquifer System, Gloucester and Northeastern Salem Counties, New Jersey The USGS recently completed this investigation of the Upper, Middle, and Lower Potomac- Raritan-Magothy (PRM) aquifers, which are the principal source of groundwater supply in northern Gloucester and northeastern Salem Counties. Water levels in these aquifers have declined in response to pumping. This investigation evaluated how increased population growth and demand from these aquifers over the next two decades ( ) will affect ground water levels, baseflow in streams, and the potential for streamflow depletion. The USGS predicted that wells in these aquifers at maximum allocation will result in average simulated water level declines in the Upper, Middle, and Lower PRM aquifers of 156, 95, and 69 feet below sea level, respectively, which are 79, 30, and 10 feet lower, respectively, than the estimated ground water levels predicted under year 2000 demands. In addition, the USGS predicted at full allocation that local stream baseflow would be reduced by 29 percent, or 6.6 MGD compared to the streamflow reductions that would occur in the year The exact amounts that would affect the specific HUC 11 watersheds of Salem County were not estimated, but it can readily be inferred that there are additional reductions over those discussed above.

12 With regard to saltwater intrusion, the USGS investigation pointed out that four areas in the study area have experienced acute problems with saline water in the PRM aquifer. Wells in Glassboro Borough and adjacent municipalities in southern Gloucester County are susceptible to saltwater intrusion, but are unlikely to be affected for hundreds of years due to the distance from the saltfront. However, Harrison Township in Gloucester County and Woodstown Borough in Salem County are in more immediate danger. The USGS has indicated that their wells are vulnerable to saltwater intrusion as a result of their close proximity to the saltfront in the aquifer. The elevated chloride concentrations found in wells screened in the PRM aquifer in Oldmans Township are because of the proximity of these wells to the saltfront in this aquifer and the orientation of the contributing flow path that directs recharge water through saline areas along the Delaware River and its tributaries. In all four areas, sodium and chloride concentrations in groundwater in wells in these areas are near or above the secondary drinking-water standard. Withdrawals south of Penns Grove were not analyzed in this investigation. However, these confined aquifer wells exhibit similar issues with regard to their location near the saltfront and thus their potential for saltwater intrusion. Based on the above, the eastern portion of coastal Salem County, which is where the majority if the County s population resides, has a significant water supply problem with regard to saltwater intrusion. One can argue that it is significant to the degree that it can be declared as part of an Area of Critical Water Supply Concern. According to the NJDEP s Water Supply Management Act Rule, N.J.A.C. 7: (Designation of areas of critical water supply concern): (a) The Commissioner shall, after notice and public hearing, designate as areas of critical water supply concern those areas in which the Department determines that adverse conditions exist, related to the ground or surface water, such that special measures are required to ensure the integrity and viability of the water supply source and to protect the public health, safety or welfare. The Department shall demonstrate that the designation is warranted through the use of a water supply availability study. The adverse conditions upon which the designation of an area of critical water supply concern is based shall include one or more of the following: 1. Shortage of surface water due to diversions from surface or ground water sources which leave insufficient surface water for permitted, certified, or registered diversions or for environmental protection purposes within a drainage area of at least ten square miles. 2. Shortage of ground water due to diversions exceeding the long- term, safe or dependable yield of an aquifer in an area of at least ten square miles. The Department may demonstrate such a shortage by a verified mathematical ground water model, or if such a model is unavailable, by one or more of the following: i. A progressive lowering of ground water to the extent that existing wells of 50 feet or more in depth are threatened by declining water levels or rendered inoperative; ii. ii. A reduction of the average potentiometric surface in a confined aquifer such that the 30 foot below mean sea level contour is within five miles of salt water or intersects the 250 part per million chloride isochlor; iii. iii. A reduction of the average potentiometric surface in an unconfined or semiconfined aquifer to the zero foot contour (mean sea level) or lower, such that the

13 contour line is either within five miles of salt water or intersects the 250 part per million chloride isochlor. As described above, nearly every regulatory provision for an Area of Critical Water Supply Concern is met for coastal Salem County. Expansion of FWSAs in this area will cause the above provisions to be exacerbated as demand grows because of the dense development that accompanies sewers. It is plausible that the above conditions will be even more severe as other new development in Salem County increases. As shown in the Watershed Analysis of these comments, streamflow depletion will worsen as Salem County grows. This will lead to more and more brackish water migrating up the tributaries of the Delaware River, especially during drought periods and as sea level rises. Since many of these tributaries are located in the outcrop areas of Salem County s confined aquifers, brackish water will be induced into these resources, further worsening the saltwater intrusion problem in coastal Salem County. As more confined aquifer wells are impacted, the probability of Salem County being required to implement an expensive regional water supply alternative will grow. No such analysis of these impacts was conducted as part of the amendment to the Lower Delaware WQMP for Salem County. Nor was an analysis done of the potential for human contamination of the confined aquifers of coastal Salem County. Much of the expansion of FWSAs in Salem County is in the outcrop (recharge) areas of the region s confined aquifers. These aquifers provide the majority of the potable water supply of Salem County. As development evolves within these outcrop areas, two phenomena can be expected. First, the natural recharge process will be changed; development is known to reduce aquifer recharge rates. Second, more contaminants from the increased development will be released into Salem County s drinking water supply. The end result is less water flowing into these important supplies accompanied by higher concentrations of pollutants. 2. Hydrogeology and Simulated Effects of Groundwater Withdrawals, Kirkwood-Cohansey Aquifer System, Upper Maurice River Basin Area, New Jersey 2005 While the above study focused on coastal Salem County, it is important to note that the western portion of freshwater Salem County has substantial water supply problems as well. The 1996 NJSWSP recommended that ground water investigations be conducted in water supply planning areas #20 and #21. One such study examined streamflow depletion in the Upper Maurice River watershed that was conducted by the USGS. This watershed encompasses southeastern Gloucester and Salem Counties, northern Cumberland County, and western Atlantic County (USGS, 2005, page 1). According to that investigation, a comparison of predevelopment conditions with postdevelopment ( ) conditions reveals considerable base-flow reduction in the headwaters area of Scotland Run as a result of withdrawals from nearby public-supply wells, especially during months of low recharge. Results of simulations indicate base-flow reduction was nearly 62 percent at Scotland Run near Williamstown, in August Agricultural withdrawals in the Muddy Run Basin affected base flow at Muddy Run at Centerton, reducing base flow by 38 percent during August Base-flow reduction near the southern boundary of the flow model,

14 corresponding to the location of the streamflow gauging station Maurice River at Norma, was due to the combined effect of public-supply, commercial, industrial, agricultural, and lowvolume institutional groundwater withdrawals in the Maurice River Basin. Base flow in the Maurice River at Norma decreased by nearly 26 percent during August 1995, between predevelopment and post-development conditions. Base flow was reduced by a comparable quantity at the same streamflow gauging stations during September 1996, even though higher recharge rates lead to higher base-flow values at this time of year. The future conditions scenario for this investigation used projections of groundwater demand by municipality for to simulate the effects of potential groundwater withdrawals in and Hydrologic conditions for 2010 and 2040 were simulated with below-average recharge and for years 2011 and 2041 with above-average recharge. Results indicate that base flow would cease at Scotland Run near Williamstown, and would decline to 4.32 cubic feet per second (ft3/s) at Muddy Run at Centerton, and ft3/s at Maurice River at Norma, during August Similar base-flow values were projected for Simulated base flow ceased at Scotland Run near Williamstown was 4.09 ft3/s at Muddy Run at Centerton, and ft3/s at Maurice River at Norma during August A scenario representing maximum allocation groundwater-withdrawal conditions was simulated using all wells in the study area that had been issued a water allocation permit by Groundwater withdrawal rates from each well were set to the maximum monthly and annual rates specified by the permit. Results of this simulation indicated considerable reductions in base flow in the Maurice River, particularly during periods of low recharge. When climatic conditions that occurred during were used, results indicated that during a dry year like 1995, simulated base flow would stop at Scotland Run near Williamstown, from June through September. Simulated base flow at Scotland Run at Franklinville, and at Muddy Run at Centerton, would stop during August A comparison of maximum-allocation conditions with predevelopment conditions indicated a reduction of simulated base flow by 93 percent during August 1995 and by 41 percent during September 1996 at Maurice River at Norma. Based on the above, this watershed also qualifies as an Area of Critical Water Supply Concern (i.e., N.J.A.C. 7:19-8.2(a)1 shortage of surface water due to diversions from surface or ground water sources which leave insufficient surface water for permitted, certified, or registered diversions or for environmental protection purposes within a drainage area of at least ten square miles. ). As described in the Designated Uses section of these comments, the above severe streamflow depletion problem will also play a crucial role in not allowing the NJDEP to meet the designated uses of the ground and surface water resources of the watershed. As shown in the Watershed Analysis of these comments, the watersheds of coastal Salem County are, or will in the future, experience similar streamflow depletion issues. The above discussion strongly infers that Salem County has major water supply issues. The water supply needs associated with the environmental build-out are demonstrated to be met with existing, new or expanded water supplies that will indeed conflict with the most current New Jersey State Water Supply Plan, its updates, and the investigations that were recommended in these documents.

15 Designated Uses The NJDEP is responsible for the development, adoption, and administration of New Jersey's Surface Water Quality Standards (N.J.A.C. 7:9B et seq.) and Ground Water Quality Standards (N.J.A.C 7:9C et seq.). Below is a discussion of each regulation and its relevance to the proposed amendment to the WQMP for Salem County. 1. Surface Water Quality Standards The NJDEP oversees the Surface Water Quality Standards. It is also responsible for conducting and coordinating water quality assessments of all waters of the State. These assessments are reported through the New Jersey Integrated Water Quality Monitoring and Assessment Report (Integrated Report). The Integrated Reports are intended to provide effective tools for maintaining high quality waters and improving the quality of waters that do not attain their designated uses (i.e., contain impaired waterbodies). The Integrated Reports describe attainment of the designated uses of surface waters of the State, as specified in the Surface Water Quality Standards, which for freshwaters include: aquatic life, recreation, drinking water, fish consumption, shellfish consumption, and industrial and agricultural water uses. In addition to identifying impaired waterbodies, the Integrated Reports identify sub-watersheds where there is no water quality impairment (i.e., all designated uses are attained). A major provision of the Surface Water Quality Standards is that all fresh waters be protected as potential sources of public water supply. Saline waters, for which there are many in Salem County, are also classified and have an array of designated uses. These include shellfish harvesting (for SE1 waters), maintenance, migration and propagation of the natural and established biota, migration of diadromous fish, maintenance of wildlife, and Secondary contact recreation. Without adequate freshwater flows in watersheds, the SJBC argues that the designated uses cannot be attained. Adequate freshwater flows are needed to ensure that aquatic life can be protected, drinking water supplies and other water uses are preserved, and water quality is sufficient for fish and shellfish consumption. Numerous waterbodies in Salem County are impaired or are in danger of being further impaired. There are also many environmentally sensitive areas (ESAs) in the watersheds of the County. The expansion of FWSAs in Salem County will obviously increase demand. In many cases, the increases in demand will result in additional streamflow depletion that will place more stresses on the streams of the watersheds of the County and the ESAs within these watersheds. The assessment in the Watershed Analysis Section below will evaluate these stresses and ESAs. These stresses and ESA impacts have not been assessed in the amendment to the WQMP for Salem County. 2. Ground Water Quality Standards The Ground Water Quality Standards establish the designated uses of the State's ground waters, classify ground waters based on those uses, and specify the water quality criteria and other policies and provisions necessary to attain those designated uses. The ground water quality criteria are numerical values assigned to each constituent (pollutant) discharged to ground waters of the State. The Ground Water Quality Standards also contain technical and general policies to ensure that the designated uses can be adequately protected. Included are policies on protecting ground water that flows (discharges) to freshwater. Also included are policies that specify that all fresh waters be protected as potential

16 sources of public water supply. characteristics and designated uses. Ground water is classified according to its hydrogeologic Designated uses are assigned as primary or secondary uses of ground water and include maintenance of special ecological resources, provision of and conversion to potable water, agricultural and industrial water supply, and other reasonable uses (other than potable use). For all ground waters of the State, the Ground Water Quality Standards assign designated uses of the ground water within each classification, and establish numerical water quality criteria to support those uses. The Ground Water Quality Standards also establish antidegradation policies, which are designed to protect the existing and designated uses of the State's ground waters. The designated uses of ground water can be impaired by excessive well withdrawals from both a quantity and quality perspective. For example, ESAs can be severely impacted if excessive well withdrawals dewater wetlands that are inhabited by these natural resources and dependent upon specific hydrologic functions. Potable, agricultural and industrial water supplies can be lost if excessive well withdrawals result in saltwater intrusion. These withdrawals may also increase the concentrations of pollutants as freshwater dilution is reduced. The expansion of FWSAs in Salem County will in some watersheds increase the potential for these impact. They have not been addressed in the amendment to the WQMP for Salem County. The SJBC examined their potential impacts in the Watershed Analysis Section below. Recent Development Trends in Salem County Prior to describing the impacts to watersheds, saltwater intrusion, and potential environmental resources impacts, it is worthwhile to discuss recent trends of development in Salem County. These trends are revealing in that they provide an overall snapshot of the reasons the individual watersheds and water supplies are being affected by human activities. One of the more significant landscape impacts attributable to urbanization is the creation of impervious surface (Hasse & Lathrop, 2010, pg. 15). In nature water is continually moving between the atmosphere, ground water aquifers, lakes and rivers. When land becomes developed, a portion of the parcel is necessarily covered with impervious surface such as asphalt and concrete. The creation of impervious surface changes the natural hydrologic cycle by impeding precipitation infiltration to groundwater while increasing the amount of surface runoff. Storm peaks are amplified in velocity and magnitude changing the load carrying and erosion characteristics of stream channels. These changes have significant environmental consequences including impacts to ground water recharge, frequency and magnitude of flooding, elevated nonpoint source pollutant levels and degraded biological activity (Kennen, 1998, pgs, 6; & Brabec, 2002, 16(4): ). Research has shown that the water quality and environmental condition of a watershed is demonstrably related to the amount of impervious surface within the watershed. A landmark paper by Arnold & Gibbons (1996, 62(2): ) described the relationship. Watersheds with less than ten percent impervious surface cover are generally considered un-impacted. At levels greater than ten percent impervious surface watersheds show signs of impact. As impervious surface reaches thirty percent and beyond, water quality has typically become seriously degraded.

17 Hasse and Lathrop (2001, pg. 15) compiled the degree of impervious cover in watersheds throughout the state. Interesting enough, two watersheds in Salem County are approaching the greater than ten percent impervious cover level where research has shown that water quality will show signs of impact. Much of the expansion of sewer service areas in Salem County are in the outcrop (recharge) areas of the region s confined aquifers. These aquifers provide the majority of the potable water supply of Salem County. As development evolves within these outcrop areas, two phenomena can be expected. First, the natural recharge process will be changed; development is known to reduce aquifer recharge rates. Second, more contaminants from the increased development will be released into Salem County s drinking water supply. The end result is less water accompanied by more pollutants entering the water supply of the residents of Salem County. To illustrate the transformation of natural previous cover to development s impervious cover in Salem County, Hasse and Lathrop compiled annualized land use changes from 2002 to During each of these years, urban/suburban development averaged increases of 524 acres, and agricultural land losses of 246 acres, forest land losses of 376 acres, and wetland losses of 13 acres. Between 1986 and 2007, Salem County has added 10,942 acres of urban/suburban development and an equivalent loss in agricultural, forest and wetlands, which averages to 521 acres a year. Continued extensions of sewer service areas will see continued losses of agricultural, forest and wetland, accompanied by additional impairment of water quality. Sewers facilitate this phenomenon. Growth and Development in Salem County According to the Salem County natural Resource Inventory, Salem County s role as an agricultural mainstay for the state of New Jersey has been threatened since the early 1990 s by rising developmental pressures spreading from nearby counties. Building permit data from N.J. Department of Labor (N.J. DOL) shows Salem County has experienced growth pressure since Most towns saw from half as many permits issued to triple the number of permits issued in the five years between 2000 and 2005 as were issued in the previous decade from (see Chart 4-1 and Table 4-2). Though the largest percentage increase in building permits issued from 2000 to 2005 occurred in areas the County has designated for growth (that is, within the Smart Growth Corridor west of Route 295 or in designated centers east of the Turnpike), the largest number of building permits were issued throughout the areas that are not designated for growth (Salem County, 2006, page 4-8). Description of Salem County Water Quality Management Planning Area Salem County has accepted the responsibility for preparing a Countywide Wastewater Management Plan (WMP) and has worked with local municipal officials to prepare the plan. The map below was recently developed by Salem County and these officials, and delineates future sewer service areas. It is noted that this map has been developed before preliminary Wastewater Management Plans have been available for comment by the public (Salem County, pages 4-7 and 4-8).

18 Map 1. Planned Sewer Service Area Expansions in Salem County.

19 It is also noted that some towns have not yet submitted updated wastewater proposals to Salem County, or that recent updates were not available for review by the ALS. In these cases, alternative sources were relied upon to estimate items such as build-out wastewater flows. In addition, it is important to mention that Salem County is considering participating with Gloucester County in a regional wastewater treatment plant where many, if not all, of Salem County s wastewater treatment plants would be abandoned, and the wastewater would be conveyed to the existing treatment facility located at the DuPont Chambers Works site in Deepwater for disposal (Salem County Board of Chosen Freeholders, 2009). This proposal has not been reviewed as part of this project. However, there have apparently been evaluations of wastewater flows at build-out that were conducted, but only summarized as part of the Salem County Resolution (Appendix A). Where these flows are larger than those indicated in the town s wastewater plans, the larger flows have been used in this report s analysis. Woodstown Sewerage Authority The planning area for the Woodstown Sewerage Authority includes all of Woodstown and small portions of Pilesgrove and Mannington. Woodstown is enveloped by Pilesgrove. The wastewater treatment plant has a design capacity of 0.53 MGD and discharges to a tributary (Salem Creek) of the Salem River. Salem Creek is classified as a FW-2 (Freshwater) NT (nontrout) stream. The water supply for Woodstown is provided by the Woodstown Water Department, which withdraws water from several wells in confined aquifers. A build-out analysis for the Woodstown Sewerage Authority was not available for review at the time of this report. Based on its 1995 WMP, the plant was discharging approximately 0.29 MGD serving populations of 3,334 in Woodstown (0.25 MGD), 143 in Pilesgrove (0.01 MGD), and 379 in Mannington (0.03 MGD) for a total 1995 population of 3,856. That plan projected that wastewater flows will increase to 0.53 MGD in 2015 due to increases in populations to 5,570 in Woodstown (0.4 MGD), 170 in Pilesgrove (0.03 MGD), and 1,334 in Mannington (0.1 MGD) for a total population of However, as discussed above in the Salem County Resolution, a build-out wastewater flows of 0.7 MGD is not estimated. This flow will be used in this report s analysis. Since the design flow for the plant is about 0.53 MGD, the plant will need to be upgraded and expanded. Map 1 show sewer expansions on the northern and western boundaries of Woodstown into neighboring Pilesgrove. Penns Grove Sewerage Authority The planning area for the Penns Grove Sewerage Authority includes all of the Borough of Penns Grove. Penns Grove is enveloped by Carneys Point. The wastewater treatment plant has a design capacity of 0.75 MGD and discharges to Delaware River. The purveyor that provides Penns Grove s water supply is the New Jersey American Water Penns Grove, which is a public community water system consisting of 7 wells that draw from the PRM Aquifer in Carneys Point and Logan (Gloucester County). (Saltwater threat?) This system may receive additional supply through an interconnection with New Jersey American - Logan System, which consists primarily of five Middle PRM wells, but may also include treated surface water from the Delaware River. (Check USGS reports) A build-out analysis for the Penns Grove Sewerage Authority was not available for review at the time of this report. An up-to-date WMP for the Penns Grove Sewerage Authority is not available. It is assumed that the majority of the Borough s 2010 population of 5,147 is served by

20 public sewers. Using NJDEP s 75 gallon per day per capita projection methodology, this population would generated approximately 0.4 MGD. In the absence of specific data, this report will employ the data from Salem County for maximum build-out wastewater flow, which is 0.82 MGD, a more than 100 percent increase. Information on the Penns Grove Sewerage Authority s wastewater treatment plant s capacity is unavailable, so no determination can be made on whether the plant will need to be expanded as demand grows in the future. Map 1 show substantial sewer expansions on the northern and western boundaries of Penns Grove in neighboring Carneys Point and Oldmans Township. This report assumes that the Carneys Point Sewerage Authority s sewer system will be expanded in these areas. Carneys Point Sewerage Authority The planning area for the Carneys Point Sewerage Authority includes all of Carneys Point Township and a relatively large section of Oldmans Township where the NJ Turnpike Service Area and Gateway Industrial Park are served. The wastewater treatment plant has a design capacity of 1.3 MGD and discharges to Helms Cove which is located adjacent to the Delaware River. The water supply for Carneys Point is provided by the New Jersey American Water Company which withdraws water from the confined Potomac-Raritan-Magothy aquifer in Carneys Point and Logan (Gloucester County). A build-out analysis for the Carneys Point Sewerage Authority was not available for review at the time of this report. The most up-to-date WMP for the Carneys Point Sewerage Authority is 1998 WMP, the plant was discharging approximately 0.66 MGD serving populations of 6,364 in Carneys Point (0.6 MGD), and receiving 0.06 MGD from the Turnpike facility. That plan projected that wastewater flows will increase to 1.19 MGD in 2018 due to increases in populations to 7,625 in Carneys Point (1.0 MGD), increases in flow from the Turnpike (0.06 MGD), and Salem County Industrial Park (0.12 MGD). However, as discussed above in the Salem County Resolution, a build-out wastewater flows of 1.24 MGD is now estimated. This flow will be used in this report s analysis. Since the design flow for the plant is about 1.3 MGD, the plant will not need to be upgraded and expanded. Map 1 shows substantial sewer expansions into the remaining portions of Carneys Point and into neighboring Oldmans Township. According to the Pennsville Sewerage Authority s WMP, the DuPont Chambers Work facilities and wastewater treatment plant were that were previously in the Pennsville Sewerage Authority s sewer service area, are now in the Carneys Point sewer service area (see below). From a total area perspective, this expansion appears to be the largest in all of Salem County. Pennsville Sewerage Authority The present sewer service planning area for the Pennsville Sewerage Authority includes a narrow strip of land in Pennsville Township adjacent to the Delaware River including the Glenside, Churchtown, Central Park, Penns Beach, and Mahoneyville sections, and a portion of Carneys Point to the northern boundary of the township. The latter includes some hotels, trailer parks, 600 single family homes, and a New Jersey Department of Transportation facility. The Pennsville Sewerage Authority wastewater treatment plant has a design capacity of MGD and discharges to the Delaware River. Within the Deepwater section of Pennsville, wastewater from the Deepwater Generating Station is conveyed to the DuPont Chambers Work Wastewater Treatment Plant (see below). The water supply for Pennsville is provided by the Pennsville

21 Water Department which withdraws water from eight wells in the confined Upper and Middle P- R-M aquifer within the township. The Pennsville Sewerage Authority recently completed its WMP in 2008 to reflect a recent major revision of the township master plan. The future sewer service area has been delineated to account for buffer requirements regarding wetlands, T & E Species, Riparian Corridors, and FW- 2 Waters. Lands outside of the future sewer service area will be continued to be served by individual septic systems. The township master plan and WMP have been coordinated in an attempt to ensure that total future wastewater flows do not exceed the current design capacity of the Pennsville Sewerage Authority s treatment plant (1.875 MGD). However, the township has indicated that it may request an additional expansion of the sewer service area, and upgrading and expansion of the plant in the future. The expanded Pennsville Sewerage Authority sewer service consists of substantial land areas in the northern section and south-central portion of the township. The Dupont facility has been removed from its sewer service area, and included in that for Carneys Point. The Pennsville Sewerage Authority plant is presently discharging approximately MGD serving the year 2008 sewered population of 10,744 in Pennsville (1.355 MGD), and 123 (0.011 MGD) from Carneys Point. The Pennsville Sewerage Authority WMP projected that build-out wastewater flows (estimated to occur around 2030) will increase to MGD due to increases in populations to 11,627 in Pennsville (1.638 MGD), and increases in flow from Carneys Point (0.015 MGD). However, as discussed above in the Salem County Resolution, a build-out wastewater flow of 1.5 MGD was also estimated. To be conservative, the larger Pennsville Sewerage Authority flow will be used in this report s analysis. Since the design flow for the plant is about MGD, the plant will not need to be upgraded and expanded. Salem City Wastewater Treatment Plant The planning area for the Salem City Wastewater Treatment Plant includes most of Salem City, and smaller sections of Elsinboro, Mannington, Alloway, and Quinton Townships. The wastewater treatment plant has a design capacity of 1.4 MGD and discharges to the Salem River. The Salem River is classified as a FW-2 (Freshwater) NT (non-trout) waterway. The water supply for Salem City is provided by the Salem Water Department which withdraws water from the confined Wenonah, Mount Laurel and Englishtown aquifers in and around Salem City (and a surface water withdrawal from Laurel Lake. A build-out analysis for the Salem City Wastewater Treatment Plant was not available for review at the time of this report. The most up-to-date WMP for the Salem City Wastewater Treatment Plant is its 2001 WMP, the plant was discharging approximately 0.69 MGD serving populations of 6,884 in Salem City (0.523 MGD), and receiving primarily residential wastewater flows from Elsinboro (0.002 MGD), Mannington (0.151 MGD), Alloway (0 MGD), and Quinton (0.014 MGD) Townships. That plan projected that wastewater flows will increase to MGD in 2021 due to increases in populations to 9,655 in Salem City (0.561 MGD), and increases in flow from Elsinboro (0.002 MGD), Mannington (0.186 MGD), Alloway (0.134 MGD), and Quinton (0.124 MGD) Townships. However, as discussed above in the Salem County Resolution, a build-out wastewater flows of MGD is now estimated. In consideration of the development potential of Salem City s bordering communities, this flow will be used in this report s analysis. Since the design flow for the plant is about 1.4 MGD, the plant will need to be

22 upgraded and expanded before it reaches full build-out. Map 1 shows substantial sewer expansions spidering out into neighboring townships. Other Wastewater Treatment Plants in Salem County There are two other small wastewater treatment plants in Salem County. This includes the Hancock s Bridge plant and Canton Village plant in Lower Alloways Creek Township. The Hancock s Bridge plant presently treats about 0.01 MGD and has a design capacity of 0.05 MGD, while the Canton Village plant treats about 0.02 MGD and has a design capacity of 0.05 MGD. Both plants discharge to the Alloway Creek. Their water supply is from confined aquifers. Description of Other Regional Facilities in the Salem County Area In addition to the above municipal sewerage authorities, there are numerous private facilities in the Salem County area that can contribute to streamflow depletion, confined and unconfined aquifer saltwater intrusion, increase salinity in the lower Delaware Bay estuary, thermal warming, the potential to impair natural resources, etc., via wastewater discharges and the depletive or consumptive use of water. The county WQMP regulatory process ignores the cumulative impact of these facilities in their assessments. While the Delaware River Basin Commission evaluates the macro effects of the many public and private facilities, there is no coordinated assessment of how these cumulative effects might affect local resources, especially when these local effects might be exaggerated by local activities such as those described in this report. Map 2 illustrates the larger facilities that can contribute to these impacts described above (USEPA, 2006, page B1-3). Those in Salem County are discussed below.

23 Map 2 Major Private Facilities in the Delaware Bay Estuary.

24 DuPont Chamber Works Intake and Wastewater Treatment Plant The DuPont Chambers Works plant is located in Pennsville in the vicinity of the Delaware Memorial Bridge. As described above, this plant has been recently included in the Carneys Point WMP. DuPont s Chambers Works facility has a dedicated intake structure co-located with the Deepwater Generating Station's offshore intakes in Delaware River at the Delaware Memorial Bridge. The intake consists of angled bar screens and two modified traveling screens. The screens are stainless steel wire mesh with 6.4 mm openings and lip troughs. Organisms removed by the low pressure spray are collected and returned to the river through a fiberglass fish sluice that is not submerged. Therefore, any surviving organisms returned to the surface waterbody via the return system would experience a drop in gravity prior to reaching the water surface. The operator can provide flow augmentation, as needed, to the fish sluice. The screens are rotated and cleaned once every 8 hours. The average intake flow is 37 MGD from the River (USEPA, 2006, Pg. B2-10). The design capacity of wastewater treatment plant at DuPont s Chambers Works facility is 47.8 MGD. The discharge is to the Delaware River. Dupont Chemical and Pigment Department Facility Intake The Dupont Chemical and Pigment Department facility has one cooling water intake structure that provides make-up for two non-contact, once through cooling systems as well as process water for facility operations. The intake is located 180 feet offshore in the Delaware River. The intake has vertical, conventional single entry/exit traveling screen and fish/debris conveyance trough. The design capacity of the intake is 33.8 MGD. The average intake flow is 7 MGD from the river (USEPA, 2006, Pg. B2-10). Deepwater Generating Plant The Deepwater Generating Station is an 82 megawatt natural gas-fired power station owned and operated by Pepco Holdings in Pennsville just north of the Delaware Memorial Bridge. The plant previously was coal-fired and switched to gas in 2010 to reduce air pollution. The facility began commercial service in Deepwater currently has three steam electric units: unit 1 is a natural gas unit of 96 MW, unit 4 is an oil unit of 53 MW, and unit 6 is a coal unit of 92 MW. Each unit has a separate cooling water intake (USEPA, 2006, Pg. B-2-11). All three intakes are located approximately 32 m (105 ft) offshore in the Delaware River (U.S. Department of Energy, 2001a). In a 2000 EPA questionnaire, the Deepwater Generating Station reported the design intake flow for units 1, 4, and 6 at 151 MGD; the average intake flow for these same units was MGD. In addition to the steam electric unit, Deepwater operates one gas turbine which does not require cooling water (USEPA, 2006, Pg. B1-5). Conectiv s Deepwater Generating Station obtains cooling water make-up from three intake bays in the Delaware River at the Delaware Memorial Bridge. The average intake flow at the facility is MGD from the river. The 3 intake bays supply water to Generating Units 1, 4, and 6. As noted above, Unit 4 was on cold standby as of 1999 with only minimal generation and intake requirements. Water is withdrawn through an intake structure (or intake crib) which is located approximately 75 feet off shore. Each intake is equipped with a single bay and trash racks. The intake water passes through submerged pipes that are located eight feet (bottom elevation) below mean low water on the shoreline bulkhead opposite the intake crib. The space between the face

25 of the bulkhead and the back of the intake crib forms a discharge canal that is parallel to the river and open at both ends. The intake water then passes through on-shore conventional traveling screens where there are two screens for each unit. The screens are not rotated on a continuous basis. The screens are equipped with a debris removal system and return sluice (USEPA, 2006, Pg. B2-9 & B2-10). Sanitary waste and process flow in the amount of about MGD from the Deepwater Generating Station is conveyed to the DuPont Chamber Works treatment plant. Salem Nuclear Generating Station The Salem Nuclear Generating Station is located on the Delaware Estuary in New Jersey, on an artificial peninsula known as Artificial Island in Lower Alloways Township. Artificial Island is the dividing line between the transitional and lower estuary zones in Delaware Bay. This section of the estuary is approximately 4 km (2.5 miles) wide, and is situated in the transition zone of the estuary. Tidal flow in this area is approximately 11,327 m3/s (400,000 cfs; NJDEP, 2000). Salem operates two large nuclear units of 1,170 MW each. Both units serve baseload demand. Unit 1 began operation in 1977, and is licensed to operate through June 30, Unit 2 began operation in 1981, and is licensed to operate through October 13, Each unit has a oncethrough cooling system with a design flow of 1,584 MGD. Estuary water is drawn in approximately 122 m (400 ft) north of the circulating water system, where it cools heat exchangers and other equipment before it is discharged back into the estuary (Correia et al., 1993). In addition to the two nuclear units, Salem operates one gas-fired generating unit, which does not require cooling water. Hope Creek Nuclear Generating Station The Hope Creek Nuclear Generating Station (Hope Creek) is less than half a mile northwest of the Salem Nuclear Generating Station, and thus has the same estuary characteristics as the Salem facility. Commercial operation at Hope Creek began in The facility has one boiling water nuclear reactor capable of generating 1,170 MW. Like Salem s units, the Hope Creek reactor is operated as a baseload unit. The design flow for the facility is MGD. The Hope Creek facility uses a closed-cycle circulating water system consisting of four circulating water pumps. The system holds 9 million gallons of water (USEPA, 2009, Pg. ). New Nuclear Generating Unit At Artificial Island, Lower Alloways Creek Public Service Electric & Gas (PSE&G) is working on the engineering required for the submission of an application to the US Nuclear Regulatory Commission (NRC) for a fourth reactor at the Salem-Hope Creek complex located on Artificial Island within the Delaware River in Lower Alloways Creek Township. An Early Site Permit for the complex is scheduled to be submitted in 2010 to the NRC. The NRC will then review the process and the construction, which could take up to 10 to 12 years to complete. Although this project has a long time frame to complete, the project has the potential to create significant employment opportunities at the project site and throughout other areas of the county. Watershed Analysis Methods

26 The United States Geological Survey (USGS) recently estimated the low flows of the 151 HUC 11 watersheds of the state under contract with the NJDEP (USGS, 2008, page 4). This initiative was conducted to provide streamflow statistics for the development of a threshold for how much water could be removed from a relatively small watershed without adversely affecting the stream ecology of that watershed. That threshold is to be employed by the NJDEP in its development of the next NJ Statewide Water Supply Plan, which is scheduled to be released in The NJDEP threshold employs an approach referred to as the low flow margin (LFM) to estimate the amount of water that can be removed from a watershed and not returned. The low flow that has been traditionally used by the NJDEP and many other states to quantify the yield of a surface water supply is the lowest total flow over seven consecutive days during a ten-year period, the 7Q10, has often been used to define an extreme low flow condition. A critical flow regime for aquatic ecology is the lowest monthly flow, which in New Jersey tends to occur in most years in September. The low flow margin is the difference between a watershed s September median and the 7Q10 flows. It is reported that the NJDEP will utilize 25 percent of this difference as the planning threshold for water availability from the States 151 HUC watersheds in the next NJ Statewide Water Supply Plan. To be consistent with the upcoming Statewide Water Supply Plan, this report will employ the above planning threshold as a trigger when unconfined aquifer and surface water withdrawals in the HUC 11 watersheds that are associated with the Salem County WQMP may be impacting, or will likely impact in the future, the natural resources of the County. While not all of Salem County and its watersheds are being proposed for sewering, the evaluation of withdrawals on streamflow will cover all of the County s watersheds so that readers can have a big picture of the cumulative effects of humans on the natural resources of the entire County. This report will evaluate the current and projected effects of withdrawals that are associated with the Salem County WQMP. It will do so by quantifying and illustrating water availability in each HUC 11 in Salem County as estimated by LFM threshold, and comparing that amount with the amount presently used and the projected amount to be used. Since some withdrawals are not associated with the WQMP, but will affect streamflow in the watershed, this report will also show what the effects would be if all the water in the watershed were fully used as currently allocated. To indicate the magnitude of these combined effects, streamflow depletion will be compared to the 7Q10 and LFM threshold in each watershed. The rationale is that the more water that is depleted from the 7Q10 and LFM threshold, the greater the impact to the watershed s ecological resources. The analysis will employ the water withdrawal/wastewater discharge data as a baseline for the above analysis (NJDEP, 2005). This older data was used because the report author did not have access to more recent comprehensive NJDEP water demand data. For larger withdrawals and discharges, the data was updated from the individual databases that the NJDEP collects, and from the Salem County WQMP.

27 It will also utilize the most recent WQMP, wastewater management plans, and amendments to project water demand at build-out. Where actual water demand was not projected, wastewater generation rates will be translated to water demand projections using NJDEP regulatory demand criteria. As described above, water supply withdrawals will be evaluated to estimate their effects on low streamflows. These flows are lowest, and most vulnerable to undesirable impacts, during hot dry conditions when demand is typically the greatest. Consequently, withdrawal demand projections will focus on the periods when hot, dry conditions prevail. As earlier described, all withdrawals in each watershed will be assessed with regard to their impact on streamflow and accompanying effects. These will include private domestic wells on residential lots served by septic systems in areas not planned for sewer systems. The approach used in this analysis will assume that well withdrawals from unconfined and semiconfined aquifers in a watershed reduce streamflow in that watershed on a 1:1 basis (i.e., each gallon of water withdrawn by the well will reduce streamflow by a gallon). If water is withdrawn from a well in the watershed, used in that watershed, and treated at a wastewater plant and discharged to that same watershed, the discharge will compensate for the loss in flow caused by the well. However, it is often the case that the wastewater treatment plant discharge is distant and downstream from the wells that provide water that inevitably comprises the discharge. In these cases, there could be significant reductions in streamflow between these two points. This approach will identify the portions of the watersheds that may be affected under these circumstances. In addition, it is often the case that water is withdrawn from one watershed, but discharged in an entirely different watershed. In those cases, all of the water withdrawn will proportionally reduce streamflow. Moreover, it is often the case that more water is withdrawn than discharged when wells and wastewater treatment plants are located in the same watersheds. This occurs when large amounts of water withdrawn from wells are used for irrigation purposes. This approach assumes that nearly all (90 percent) of water used for irrigation is lost via evapotranspiration. Last, most watersheds have additional withdrawals than those used in public sewer service areas. These include agricultural withdrawals, golf course withdrawals, etc. As described above, the majority of water used for these activities is lost to the watershed, and thus need to be factored in the accounting of water that must be factored in as streamflow depletion losses. The approach used in this analysis will also examine whether potential streamflow losses as described above may influence whether wastewater discharge effluent limits are being properly established. Effluent limits are based on the 7Q10. If there are substantial withdrawals upstream of the discharges, streamflows that are significantly less than the 7Q10 may occur in the future, and water quality impairment may result more frequently and for extended durations than originally planned. These circumstances will be identified in this report. Watershed Analysis This analysis assessed the potential for streamflow depletion, saltwater intrusion, water quality degradation, impacts to Environmentally Sensitive Areas, and non-attainment of surface and ground water resources in the watersheds of Salem County as a result of approval of the amendment to the Lower Delaware WQMP.

28 Oldmans Creek The Oldmans Creek watershed is 43.9 square mile stream that separates much of Salem and Gloucester counties before freely flowing to the Delaware Bay. Its headwaters are in the South Harrison - Upper Pittsgrove area. Portions of Oldmans, Piles Grove and Upper Pittstown in Salem County are in the watershed. Most of Oldmans Creek and it tributaries is categorized as a FW2 NT (Freshwater 2 Non-Trout) stream by the NJDEP. However, it is classified as FW2 NT C1 (Category 1) on the eastern boundary of the Harrisonville Lake Wildlife Management Area to Kings Highway by Porches Mill, including all tributaries. Beaver Creek is located within the watershed in Salem County. Map 3 depicts the watershed including surface water, unconfined and confined aquifer withdrawals, and surface and ground water wastewater discharges. The NJDEP estimates that there were approximately 5,997 people inhabiting the watershed in the year 2000 (in both Salem and Gloucester Counties), and that it grew to 7,889 by 2010, and is projected to increase to 13,114 by the year 2030 (NJDEP, 2005, WMA 18 - Oldmans Creek Watershed). In 1995, the watershed is comprised of primarily agricultural land (50%), wetlands (20%), forest (15%), and urban/suburban (12%) land uses. Between 1986 and 1995, approximately 4% of the watershed s land was converted from primarily agricultural land to urban/suburban. As indicated in the SJBC s comments that accompany these water supply comments, there are several environmentally sensitive and environmentally constrained land parcels in this watershed including some that are proposed for expansion of FWSAs or are in very close proximity to FWSAs (Gateway Industrial Park, Perkinstown area, Airport and Exit 7 Interchange, Kay Gardens Subdivision, Pedricktown Village area, Myers Run, and Oldmans Crossing).

29 Map 3. Surface water, unconfined and confined aquifer withdrawals, and surface and ground water wastewater discharges in the Oldmans Creek Watershed.

30 There are several stream reaches in the Oldmans Creek watershed that are not attaining their designated uses (NJDEP, 2012, pages ). Oldmans Creek above Commissioners Road is not attaining its designated uses for aquatic life, primary contact recreation, and public water supply. Oldmans Creek from Route 45 to Commissioners Road is not attaining its designated uses for aquatic life and fish consumption. Oldmans Creek from Kings Highway to Route 45 is not attaining its designated uses for aquatic life and primary contact recreation. Beavers Creek, a major tributary of Oldmans Creek, is not attaining its designated uses for fish consumption. Oldmans Creek from Center Square Road to Kings Highway is not attaining its designated uses for aquatic life, primary contact recreation, and fish consumption. Last, Oldmans Creek below Center Square Road is not attaining its designated uses for fish consumption. While many of these waterways are not attaining their designated uses due to direct water quality problems, streamflow depletion as described above will contribute to their impairment due to the loss of needed aquatic flows and loss of dilution. Presently, only a small section (Gateway Business Park) within the Oldmans Creek watershed is served by sewers connected to the Carneys Point Sewerage Authority, while a small sewage facility is located within an industrial park (previously the Army s Camp Pedricktown). The remainder of the watershed in Salem County utilizes private septic systems. According to Map 1, a relatively large section of existing FWSA in the watershed in Oldmans Township is proposed to be expanded and the wastewater conveyed to the Carneys Point Sewerage Authority. In addition, substantial sewer expansions are proposed in the Logan Township and Woolwich Township sewer service areas in Gloucester County within the Oldmans Creek watershed. If fully implemented, there appears to be significantly more growth and water supply demand in the watershed than the NJDEP projected as described above. As per Appendix B, the 7Q10 and September median flow at the outlet of the Oldmans Creek watershed are respectively estimated at 6.6 MGD and 16.0 MGD, which translates to a LFM of 9.4 MGD and an estimated water availability of 2.3 MGD. This watershed is presently stressed as total consumptive demand is estimated at 4.4 MGD, which is 191 percent of water availability and 67 percent of the 7Q10. During severe drought, this watershed will experience extreme low flows. Some stream and wetland reaches of the watershed may go totally dry. As illustrated in Map 1, there are significant agricultural Cohansey well withdrawals in the watershed s headwaters. Since headwaters are known to have the least flow in a watershed, this area is quite susceptible to stream and wetland depletion. This portion of the watershed is classified as C1 of which the NJDEP policy is to protect from measurable changes to water quality. Increases in demand will reduce dilution and consequently result in measurable changes to water quality. According to Appendix B, the majority of streamflow and wetland dewatering in the Oldmans Creek watershed is currently the result of agricultural withdrawals. Domestic withdrawals are substantial, but much of the water used is returned to the watershed via septic system returns. If all agricultural withdrawals in the Oldmans Creek watershed eventually withdrew as much water that is allowed in their NJDEP water allocations, it would result in a consumptive demand loss to the watershed of 22.5 MGD, which is 978 percent of water availability and 341 percent of the 7Q10. Under these conditions, Oldmans Creek and its tributaries would be totally dewatered

31 or at least partially dewatered during part of almost every year. It is obvious that agricultural water demand is over-allocated in the Oldmans Creek watershed. In addition, domestic demand from individual wells will play a greater role in streamflow depletion as the watershed continues to develop, especially if outdoor irrigation is not properly managed. The above estimated losses in streamflow do not account for additional losses that can be expected as confined aquifer withdrawals increase to meet the water supply needs of the population served by the proposed expansion of sewers in coastal Salem County (and southern Gloucester County since it also uses the regional confined aquifer system). As previously described, much of the land along the Delaware River is composed of the recharge area for the region s confined aquifers. The majority of water flowing to the wells is composed of water that originates in the recharge areas, especially where the wells are not too distant from the recharge areas. This is of concern for three reasons as wastewater infrastructure is further expanded into the Oldmans Creek watershed and water demand grows. First, the confined aquifer wells will induce ground water into the aquifer in its recharge areas. This, in turn, will reduce streamflow even more than estimated above. During future drought, streams and wetlands will be depleted more excessively and for longer durations as water supply demand from the confined aquifers that is generated by the expanded sewer service areas in the future, as well as by upstream agricultural withdrawals. Water-dependent resource impacts will be exacerbated, including those ESAs and impaired waters described above. Attainment of designated uses for surface water resources will be a challenge as freshwater flow will experience less dilution. Impairment of ground water designated uses is likely. Second, saline water from the Delaware River will travel further up the Oldmans Creek watershed as freshwater flow is replaced by brackish water. Where freshwater typically was recharged into the confined aquifers, more and more brackish water will be induced into the water supplies during drought periods. As sea level continues to rise, moreover, the concentrations in the brackish water will increase and migrate further upstream into the recharge areas of confined aquifer. Saltwater intrusion to the region s confined aquifers will become more severe. Third, not only will saltwater intrusion be worsened as demand grows in this region, contamination from increased human activity will become more problematic. The sewering of an area concentrates development which, in turn, concentrates pollutants. Since much of the expanded sewer service area in the Oldmans Creek watershed is in the recharge areas of the region s confined aquifers, the threat of pollutants entering the drinking water supply will grow. None of these impacts have been addressed in the amendment to the Lower Delaware WQMP for Salem County. Pennsville/Penns Grove Tributaries The Pennsville/Penns Grove Tributaries watershed is 22.7 square miles of uplands on a narrow strip in northwestern Salem County between the Delaware River and the Salem River watershed. It is the most highly developed section of Salem County and consists of western Oldmans Township, and the developed portions of Penns Grove, Carneys Point and Pennsville. Much of the County s industry lies in this watershed including the Deepwater Generating Station and DuPont s Chamber Works. The Delaware Memorial Bridge is in this watershed. The Deepwater

32 Canal, connecting the Delaware and Salem River, is located within the watershed as is Hendy Creek, Whooping John Creek, and Miles Creek. Most of the Pennsville/Penns Grove Tributaries watershed and its tributaries are categorized as a SE2 (Saline Waters of Estuaries) waters by the NJDEP. Map 4 depicts the watershed including surface water, unconfined and confined aquifer withdrawals, and surface and ground water wastewater discharges. As shown, there are numerous unconfined and unconfined aquifer wells in the watershed, as well as municipal and industrial discharges. The NJDEP estimates that there were approximately 14,247 people inhabiting the watershed in the year 2000, and that it would decrease to 14,199 by 2010, and is projected to further decrease to 13,743 by the year 2030 (NJDEP, 2005, WMA 17 - Pennsville/Penns Grove Watershed). In contrast, as described in the Description of Salem County Water Quality Management Planning Area section of this report, several wastewater management planning agencies in the watershed project significant growth in the decades ahead. In 1995, the watershed is comprised of primarily wetlands (40%), urban/suburban (29%), forest (11%), agricultural (10%), water (7%), and land uses. Between 1986 and 1995, approximately 1% of the watershed s land was converted from primarily agricultural land to urban/suburban, and forest land increased by 1%. The Pennsville/Penns Grove Watershed is the most developed of the watersheds in Salem County, including the most extensively sewered and served by public water. The Penns Grove, Carneys Point and Pennsville Sewerage Authorities operate three wastewater treatment plants. The New Jersey American Water Company serves Carneys Point and Penns Grove, while Pennsville has its own water department. The majority of public water is from the PRM aquifer system, while some is withdrawn from the Cohansey water table aquifer. There are numerous other confined wells in the watersheds immediately to the east. There are also several contaminated (ground water) sites that are undergoing remediation in the watershed. Salem County has identified much of the land area in this watershed as a planned growth corridor. As indicated in the Environmentally Sensitive and Environmentally Constrained Lands in Salem County comments, there are numerous land parcels containing threatened and endangered species or other important natural resources in this watershed including Whooping John Creek, the 200-acre DuPont Wildlife Habitat Preserve, Helms Cove, Oldmans Crossing (partially located in watershed), Kay Gardens Subdivision (partially located in watershed) Camp Pedricktown (partially located in the watershed), and Church Landing Woods.

33 Map 4. Surface water, unconfined and confined aquifer withdrawals, and surface and ground water wastewater discharges in the Pennsville/Penns Grove Watershed.

34 The NJDEP estimates that there were approximately 14,247 people inhabiting the watershed in the year 2000, and that it would decrease to 14,199 by 2010, and is projected to further decrease to 13,743 by the year 2030 (NJDEP, 2005, WMA 17 - Pennsville/Penns Grove Watershed). In contrast, as described in the Description of Salem County Water Quality Management Planning Area section of this report, several wastewater management planning agencies in the watershed project significant growth in the decades ahead. In 1995, the watershed is comprised of primarily wetlands (40%), urban/suburban (29%), forest (11%), agricultural (10%), water (7%), and land uses. Between 1986 and 1995, approximately 1% of the watershed s land was converted from primarily agricultural land to urban/suburban, and forest land increased by 1%. As indicated in the Environmentally Sensitive and Environmentally Constrained Lands in Salem County Report, there are numerous land parcels containing threatened and endangered species or other important natural resources in this watershed including Hendy Creek, Whooping John Creek, the 200-acre DuPont Wildlife Habitat Preserve, Helms Cove, and the actual geographic feature known as Carneys Point. According to Map 1, relatively large sections of the watershed in the Pennsville/Penns Grove Watershed are proposed to be sewered by the Penns Grove, Carneys Point, and Pennsville Sewerage Authorities, as well as in neighboring watersheds to the east and north. Included in the sewer service area are several environmentally sensitive and environmentally constrained lands. The residents and businesses within the watershed and neighboring watersheds served by these watersheds primarily rely on the PRM aquifer system. As described in the Withdrawal Effects on Confined Aquifers in the Salem County Area section below, several of the wells in this aquifer that provide the water supply for these residents and businesses have previously experienced problems with chlorides and/or sodium that exceed the drinking water standards. The wells are either barely confined or within the recharge areas of this aquifer system. Since the recharge areas are beneath the Delaware River or adjacent to the river, the potential for saltwater intrusion is quite high. As per Appendix B, the 7Q10 and September median flow at the outlet of the Pennsville/Penns Grove Watershed are respectively estimated at 2.1 MGD and 5.0 MGD, which translates to a LFM of 2.9 MGD and an estimated water availability of 0.7 MGD. This watershed is presently considered to be unstressed as total depletive and consumptive demand is less than water discharged into the watershed and this is resulting more overall water being available in it. At full allocation, even more water is expected to be discharged to, especially from industrial operations. Consequently, the watershed is anticipated to remain unstressed when the next NJSWSP is finally available. However, it is important to note a few important facts before concluding that the Pennsville/Penns Grove Watershed does not have any water supply issues. First, much of the water of the water being discharged into the watershed is discharged to streams that are located in close proximity to the Delaware River. As such, these inputs are only available for a short period of time before the streams flow into brackish water. It is not as if all the streams in the watershed have an ecologically abundant flow in them, or that there is a plentiful supply of freshwater available to recharge the confined aquifers and ward off saltwater intrusion.

35 Second, as Map 4 indicates, the unconfined wells and the discharges are often at two distinct locations. Consequently, some streams may enjoy a large freshwater input due to the discharge, but other streams that do receive a discharge may be subject to excessive losses in flow due to the influence of the unconfined aquifer withdrawal. Third, some of the water that comprises the discharges within the watershed are from confined aquifers outside of the watershed. The discharges in this watershed will do little to prevent saltwater from affecting these withdrawals. Fourth, the discharges in the watershed are within the outcrop areas of the confined aquifers that recharge them. It is questionable if the discharges mixed with streamflow meet the ground water standards. Fifth, all of the expanded FWSAs that are proposed are within the recharge areas of the confined aquifer wells that will provide water to the new development that will accompany the new sewers. The potential for drinking water issues will grow as these well pump more. The storm water facilities that serve these new developments are required to recharge the aquifers. Sixth, as shown on Map 4, all of the potable confined and unconfined aquifer wells are located in close proximity to the Delaware River and its tributaries. During drought, these waterbodies become brackish. Since many if not all of these withdrawals receive some of their recharge from these waterbodies, the threat of saltwater intrusion is likely to increase, especially as development from the FWSAs occurs over time and as sea level rises. Seventh, the streamflow depletion estimates in Appendix B does not consider the induced confined aquifer recharge that is likely to be occurring in the watershed. This outflow from the watershed s water budget may negate the discharge gain. Eighth, ESAs in the watershed may be impacted by the streamflow and wetland losses from the unconfined and confined wells that are not augmented by discharges. As demand grows, these impacts may worsen. The same applies to the designated uses of the surface and ground water resources in the watershed. Based on the above factors, the Pennsville/Penns Grove Watershed appears to have significant potential for future water supply problems if the amendment to the WQMP for Salem County is approved. None of these impacts have been addressed in the Salem County WQMP Upper Salem River The Upper Salem River watershed has a 23.5 square mile drainage area that flows into the Delaware River from its headwaters in Upper Pittsgrove. It is primarily agricultural and consists partially of the towns of Pilesgrove, Upper Pittsgrove, Woodstown and Mannington. Major tributaries include the Lower Salem River, Salem Creek, Nichomus Run, Norne Run, and Game Creek. Most of the Upper Salem River watershed and its tributaries are categorized as a FW2 waters by the NJDEP. Map 5 depicts the watershed including surface water, unconfined and confined aquifer withdrawals, and surface and ground water wastewater discharges. As shown, there are several public and agricultural confined aquifer wells in the watershed.

36 The NJDEP estimates that there were approximately 12,562 people inhabiting the watershed in the year 2000, and that it would increase to 12,978 by 2010, and is projected to further increase to 13,507 by the year 2030 (NJDEP, 2005, WMA 17 Upper Salem River Watershed). In 1995, the watershed was comprised of primarily agricultural (60%), wetlands (18%), urban/suburban (10%), forest (10%), and water (2%) and land uses. Between 1986 and 1995, approximately 2% of the watershed s land was converted from primarily agricultural land to urban/suburban land uses. As indicated in the SJBC s comments that accompany these water supply comments, there are four environmentally sensitive and environmentally constrained land parcels in this watershed including some that are proposed for expansion of FWSAs or be in very close proximity to FWSAs (Southeastern Carneys Point, Laytons Lake, Quillytown, and north of Woodstown). There are several stream reaches in the Upper Salem River Watershed that are not attaining their designated uses (NJDEP, 2012, pages ). The Salem River above Woodstown is not attaining its designated uses for aquatic life, fish consumption and primary contact recreation. Nichomus Run is not attaining its designated uses for aquatic life and primary contact recreation. The Salem River from Woodstown to County Home Road is not attaining its designated uses for aquatic life and primary contact recreation. The Salem River from County Home Road to Courses Landing is not attaining its designated uses for aquatic life, industrial supply, fish consumption, primary contact recreation, and public water supply. Game Creek above Route 48 is not attaining its designated uses for aquatic life and primary contact recreation. The Salem River from Courses Landing to the Salem Canal is not attaining its designated uses for aquatic life and primary contact recreation. Game Creek below Route 48 is not attaining its designated uses for aquatic life. Last, the Salem Canal is not attaining its designated uses for aquatic life and primary contact recreation. While many of these waterways are not attaining their designated uses due to direct water quality problems, streamflow depletion as described above will contribute to their impairment due to the loss of needed aquatic flows and loss of dilution.

37 Map 5. Surface water, unconfined and confined aquifer withdrawals, and surface and ground water wastewater discharges in the Upper Salem River Watershed. According to Map 1, relatively large sections of the watershed in the Upper Salem River Watershed are proposed to be sewered by the Carneys Point and Woodstown Sewerage

38 Authorities, as well as in neighboring watersheds to the east and north. Included in the sewer service area are several environmentally sensitive and environmentally constrained lands as described in the comments on this topic. The residents and businesses within the watershed and neighboring watersheds served by these watersheds primarily rely on the PRM aquifer system. As described in the Withdrawal Effects on Confined Aquifers in the Salem County Area section below, several of the wells in this aquifer that provide the water supply for these residents and businesses have previously experienced problems with chlorides and/or sodium that exceed the drinking water standards. This includes Woodstown. The wells are either barely confined or within the recharge areas of this aquifer system. Since the recharge areas are beneath the Delaware River or adjacent to the river, the potential for saltwater intrusion is quite high. As shown on Map 5, there are several other public wells that are either near the Delaware River or near the saltfront that is affecting Woodstown. If the FWSAs in this watershed are approved, these wells too are anticipated to be affected by saltwater intrusion as demand increases to accommodate development. As per Appendix B, the 7Q10 and September median flow at the outlet of the Upper Salem River Watershed are respectively estimated at 5.4 MGD and 12.9 MGD, which translates to an estimated water availability of 1.9 MGD. This watershed is presently considered to be significantly stressed as total depletive and consumptive demand is 5.9 MGD, which is 311 percent of availability. At full allocation, depletive and consumptive demand is projected to grow to 6.8 MGD, which is 360 percent of water availability. Regarding the 7Q10, total current depletive and consumptive demand will consume 109 percent of the 7Q10 drought low flow; at full allocation these demand would consume 126 percent of the 7Q10. This translates to a possible drying up of the watershed during future drought, and the potential for water quality issues as described below. Future increases in demand, including those that are expected as the FWSAs are expanded, will place a heavy strain on the natural resources, its ESAs, and the ability to attain the designated uses of the surface and ground water resources of the watershed. In addition, as previously described, streamflow losses might contribute to saltwater intrusion in the confined aquifers of this region of Salem County. The more reductions to streamflow in the Salem River, the more brackish water is induced upstream. This is the location of the PRM aquifer system s recharge area. As described earlier, the Salem City wastewater treatment plant discharges to the Salem River. The effluent limitations established by the NJDEP employed the 7Q10. Water quality in the Salem River is to be maintained at all flows in excess of the 7Q10. The 7Q10 has already been affected by current depletive and consumptive water uses, and is projected to be impacted even more as these uses increase toward full allocation. It is quite possible that the Salem plant will require expensive upgrades in the future as the drought flow continue to decline. Lower Salem River The Lower Salem River watershed has a 58.9 square mile drainage area that flows into the Delaware River from its headwaters near Yorktown. Salem City is located entirely in the watershed, and parts of Mannington, Pennsville, and Elsinboro occupy it. Major tributaries

39 include the Upper Salem River, Mannington Creek, and Fenwick Creek. Large wetland/lakes such as Pine Island Meadows and Mannington Meadows are on the Upper Salem River. Most of the Upper Salem River watershed and its tributaries are categorized as a FW2 waters by the NJDEP. Map 6 depicts the watershed including surface water, unconfined and confined aquifer withdrawals, and surface and ground water wastewater discharges. As shown, there are several public and agricultural confined aquifer wells in the watershed. The NJDEP estimates that there were approximately 14,909 people inhabiting the watershed in the year 2000, and that it would decrease to 14,774 by 2010, and is projected to further decrease to 14,377 by the year 2030 (NJDEP, 2005, WMA 17 Lower Salem River Watershed). In 1995, the watershed was comprised of primarily agricultural (39%), wetlands (29%), water (13%), urban/suburban (10%), forest (8%) land uses. Between 1986 and 1995, approximately 1% of the watershed s land was converted from primarily agricultural land to urban/suburban land uses. There are several stream reaches in the Lower Salem River Watershed that are not attaining their designated uses (NJDEP, 2012, pages ). Mannington Creek is not attaining its designated uses for aquatic life and primary contact recreation. Fenwick/Beavers Creek is not attaining its designated uses for fish consumption. The Salem River downstream of Fenwick Creek is also not attaining its designated uses for fish consumption. Last, the Salem River upstream of Fenwick Creek is not attaining its designated uses for fish consumption. As previously discussed, while many of these waterways are not attaining their designated uses due to direct water quality problems, streamflow depletion as described above will contribute to their impairment due to the loss of needed aquatic flows and loss of dilution. According to Map 1, relatively large sections of the watershed in the Lower Salem River Watershed are proposed to be sewered by the Pennsville and Salem City Sewerage Authorities, as well as in neighboring watersheds to the north. The residents and businesses within the watershed and neighboring watersheds primarily rely on the confined Wenonah-Mount Laurel aquifer and unconfined Cohansey aquifer. Salem City also withdraws surface water for Laurel Lake in Quinton Township, which is tributary to the Alloway Creek. As described in the Withdrawal Effects on Confined Aquifers in the Salem County Area section, wells in confined aquifer systems may be vulnerable to saltwater intrusion when their outcrop areas are in close proximity to brackish water. A great deal of attention has not been paid to Wenonah-Mount Laurel aquifer with respect to its potential in the Salem County area. However, wells using the aquifer in Salem County are within one to two miles of the aquifer s outcrop area located near the tidal Delaware River and its tributaries (USGS, 2003, page 27). Consequently, saltwater intrusion may be an issue as demand increases from this aquifer. In addition, surface water from reservoirs and lakes are susceptible to losses in safe yield (water availability) when upstream depletive and consumptive uses are substantial (see Alloways Creek analysis).

40 Map 6. Surface water, unconfined and confined aquifer withdrawals, and surface and ground water wastewater discharges in the Lower Salem River Watershed.

41 As per Appendix B, the 7Q10 and September median flow at the outlet of the Lower Salem River Watershed are respectively estimated at 3.14 MGD and 12.9 MGD, which translates to an estimated water availability of 2.1 MGD. This watershed is presently considered to be nearing a stressed condition as total depletive and consumptive demand is 2.2 MGD, which is 92 percent of availability. At full allocation, depletive and consumptive demand is projected to grow to 5.2 MGD, which is 217 percent of water availability. Future increases in demand, including those that are expected as the FWSAs are expanded, will thus place a heavy strain on the natural resources, its ESAs, and the ability to attain the designated uses of the surface and ground water resources of the watershed. In addition, as previously described, streamflow losses might contribute to saltwater intrusion in the confined aquifers of this region of Salem County. The more reductions to streamflow in the Salem River, the more brackish water is induced upstream. This is the location of the PRM aquifer system s recharge area. Alloway/Hope Creek The Alloway/Hope Creek Watershed has a 85.8 square mile drainage area that flows through Salem County into the Delaware Bay. Parts of Alloway, Lower Alloway, Quinton, and Elsinboro occupy the watershed. The major tributaries to Alloway Creek are Hope Creek and Slutts Branch, and Coopers Branch. In addition, Salem City s reservoir, Laurel Lake, is tributary to the Alloway Creek. Most of the Alloway/Hope Creek Watershed and its tributaries are categorized as a FW2 waters by the NJDEP. Map 7 depicts the watershed including surface water, unconfined and confined aquifer withdrawals, and surface and ground water wastewater discharges. As shown, there are several agricultural and mining operation unconfined aquifer wells in the watershed. The NJDEP estimates that there were approximately 5,735 people inhabiting this relatively slow developing watershed in the year 2000, and that it would increase to 5,858 by 2010, and is projected to further increase to 6,227 by the year 2030 (NJDEP, 2005, WMA 17 Alloway/Hope Creek Watershed). In 1995, the watershed was comprised of primarily wetlands (38%), agricultural (26%), forest (16%), water (14%) and urban/suburban (6%) land uses. Between 1986 and 1995, approximately 1% of the watershed s land was converted from primarily agricultural land to urban/suburban land uses. Several stream segments in the Alloway/Hope Creek Watershed are not attaining their designated uses. Alloway Creek above Alloway-Woodstown Road is not attaining its designated uses for aquatic life and industrial water supply (NJDEP, 2012, pages ). Cedar Brook/Carlisle Run is not attaining its designated uses for aquatic life. Alloway Creek between Quinton and Alloway-Woodstown Road is not attaining its designated uses for aquatic life and fish consumption. Alloway Creek between New Bridge to Quinton is not attaining its designated uses for fish consumption. Harmony Tributary is also not attaining its designated uses for fish consumption. Alloway Creek from Hancock Bridge to New Bridge, Alloway Creek from Hancock Bridge to the Salem River, and Hope Creek are not attaining its designated uses for fish consumption. While these stream reaches are not attaining their designated uses due probably to direct water quality problems, streamflow depletion as described above will exacerbate these problems due to the loss of needed aquatic flows and loss of dilution.

42 Map 7. Surface water, unconfined and confined aquifer withdrawals, and surface and ground water wastewater discharges in the Alloway/Hope Creek Watershed. According to Map 1, several sections of the Alloway/Hope Creek Watershed are being proposed to be sewered. The residents in the denser developments and industrial operations within the

43 watershed primarily rely on the confined aquifers, while rural residents and agricultural operations rely on the unconfined Cohansey aquifer. As per Appendix B, the 7Q10 flow and the September median flow at the outlet of the Alloway/Hope Creek Watershed are respectively estimated at 3.7 MGD and 20.6 MGD, which translates to an estimated water availability of 4.2 MGD. This watershed is presently considered to be in a non-stressed condition as total depletive and consumptive demand is 2.4 MGD, which is 57 percent of availability. At full allocation, however, depletive and consumptive demand is projected to grow to 5.4 MGD, which is 129 percent of water availability and when the watershed would be considered stressed under the next NJSWSP. Regarding drought flows, total current depletive and consumptive demand will consume 65 percent of the 7Q10 drought low flow; at full allocation these demand would consume 136 percent of the 7Q10. This translates to a possible drying up of the watershed during future drought. Future increases in demand in the Alloway/Hope Creek Watershed will thus place a heavy strain on the natural resources, its ESAs, and the ability to attain the designated uses of the surface and ground water resources of the watershed and to downstream watersheds. Stow Creek Much of the Stow Creek Watershed serves as the political boundary between Salem and Cumberland Counties. The Stow Creek Watershed has a 55.2 square mile drainage area that flows through southern Salem County into the Delaware Bay. Parts of Lower Alloway and Quinton occupy the watershed. Most of the Stow Creek Watershed and its tributaries are categorized as a FW2 waters by the NJDEP. Map 8 depicts the watershed including surface water, unconfined and confined aquifer withdrawals, and surface and ground water wastewater discharges. As shown, there are several agricultural unconfined aquifer wells in the watershed. The NJDEP estimates that there were approximately 3,503 people inhabiting this relatively slow developing watershed in the year 2000, and that it would increase to 3,699 by 2010, and is projected to further increase to 4,241 by the year 2030 (NJDEP, 2005, WMA 17 Stow Creek Watershed). In 1995, the watershed was comprised of primarily wetlands (42%), agricultural (28%), forest (20%), water (5%) and urban/suburban (5%) land uses. Between 1986 and 1995, there was very little change to the land uses of the watershed. Several stream segments in the Stow Creek Watershed are not attaining their designated uses. Stow Creek from Canton Road to Jericho Road is not attaining its designated uses for fish consumption (NJDEP, 2012, pages ). Raccoon Ditch is not attaining its designated uses for aquatic life, fish consumption and industrial water supply. Stow Creek below Canton Road is not attaining its designated uses for aquatic life and fish consumption. It is likely that these stream reaches are not attaining their designated uses as a result of direct water quality problems. Nonetheless, streamflow depletion can exacerbate these problems due to the loss of needed aquatic flows and loss of dilution.

44 Map 8. Surface water, unconfined and confined aquifer withdrawals, and surface and ground water wastewater discharges in the Stow Creek Watershed.

45 According to Map 1, several sections of the Stow Creek Watershed are being proposed to be sewered. The residents and agricultural operations rely on the unconfined Cohansey aquifer in this watershed. As such, streamflow depletion can be a concern if consumptive water use is excessive. As per Appendix B, the 7Q10 flow and the September median flow at the outlet of the Stow Creek Watershed are respectively estimated at 8.8 MGD and 24.5 MGD, which translates to an estimated water availability of 3.9 MGD. This watershed is presently considered to be in a nonstressed condition as total depletive and consumptive demand is 1.8 MGD, which is 46 percent of availability. At full allocation, however, depletive and consumptive demand is projected to grow to 3.6 MGD, which is 92 percent of water availability and when the watershed would be considered nearing a stressed state under the next NJSWSP. Regarding drought flows, total current depletive and consumptive demand will consume 20 percent of the 7Q10 drought low flow; at full allocation these demand would consume 41 percent of the 7Q10. This translates to a significant, but perhaps tolerable, impact to low flows in the watershed during future drought. Future increases in demand in the Stow Creek Watershed will thus need to be monitored to ensure that they do not place a heavy strain on the natural resources, its ESAs, and the ability to attain the designated uses of the surface and ground water resources of the watershed and to downstream watersheds. Still Run/Little Ease Run The Still Run/Little Ease Run watershed is 46.1 square mile headwater stream of the Maurice River that originates in Glassboro (Gloucester County) and runs parallel to Route 55. As it flows toward the Delaware Bay, a portion of its drainage area is also in western Salem County. It contains a few major impoundments including Silver Lake in Clayton and Willow Grove Lake near Newfield and then flows into Salem County in the Vineland area where it joins the Maurice River. In Salem County, it is located in the Landis Sewerage Authority sewer service area. It is categorized as a FW2 NT stream by the NJDEP. Map 5 depicts the watershed including surface water, unconfined and confined aquifer withdrawals, and surface and ground water wastewater discharges. The NJDEP estimates that there were approximately 23,921 people (primarily in Gloucester County) inhabiting the rapidly developing Still Run/Little Ease Run watershed in the year 2000, and that it would increase to 26,625 by 2010, and is projected to further increase to 34,000 by the year 2030 (NJDEP, 2005, WMA 17 Still Run/Little Ease Run Watershed). In 1995, the watershed was comprised of primarily forest (28%), agricultural (27%), wetlands (20%), urban/suburban (20%), water (1%), land uses. Between 1986 and 1995, approximately 3% of the watershed s land was converted from primarily agricultural land to urban/suburban land uses. There are several stream reaches in the Still Run/Little Ease Run Watershed that are not attaining their designated uses (NJDEP, 2012, pages ). Little Ease Run above Academy Road is not attaining its designated uses for aquatic life and primary contact recreation. Little Ease Run below Academy Road is not attaining its designated uses for aquatic life, primary contact recreation and public water supply. is not attaining its designated uses for fish consumption. Still Run above Silver Lake Road is also not attaining its designated uses for aquatic life. Reed Branch (Still Run) is not attaining its designated uses for aquatic life. Still Run Below Silver

46 Lake Road is also not attaining its designated uses for aquatic life. As previously discussed, while many of these waterways are not attaining their designated uses due to direct water quality problems, streamflow depletion as described above will contribute to their impairment due to the loss of needed aquatic flows and loss of dilution. According to Map 1, a relatively small section of the watershed in Still Run/Little Ease Run Watershed is proposed to be sewered east of Elmer. The residents and businesses within the watershed primarily rely on the unconfined Cohansey aquifer for their water supply in this section of Salem County. As per Appendix B, the 7Q10 and September median flow at the outlet of the Still Run/Little Ease Run Watershed are respectively estimated at 5.7 MGD and 14.9 MGD, which translates to an estimated water availability of 2.3 MGD. This watershed is presently considered to be significantly stressed as total depletive and consumptive demand is 4.9 MGD, which is 213 percent of availability. At full allocation, depletive and consumptive demand is projected to grow to 16.1 MGD, which is 700 percent of water availability. Presently, 85 percent of the 7Q10 is consumed by depletive and consumptive water uses; at full allocation, 282 percent of the 7Q10 would be used by these types of withdrawals. The watershed would essentially be dewatered during future drought, and summer flows will be substantially lower than they are today. Future increases in demand, including those that are expected as the FWSAs are expanded, will thus place a heavy strain on the natural resources, its ESAs, and the ability to attain the designated uses of the surface and ground water resources of the watershed. Downstream watersheds in the Maurice River watersheds will experience substantial impacts from these activities in the upstream river reaches.

47 Map 9. Surface water, unconfined and confined aquifer withdrawals, and surface and ground water wastewater discharges in the Still Run/Little Ease Run Watershed.

48 Upper Maurice River The Upper Maurice River forms the boundary of southern Salem County and northern Cumberland County. The Upper Maurice River watershed has a 58.8 square mile drainage area that eventually flows into the Delaware Bay from its headwaters near Yorktown. Parts of Pitts Grove in Salem County occupy it. The major tributary that exist in Salem County is the Green Branch. Most of the Upper Maurice River watershed and its tributaries are categorized as a FW2 waters by the NJDEP. Map 10 depicts the watershed including surface water, unconfined and confined aquifer withdrawals, and surface and ground water wastewater discharges. As shown, there are several public and agricultural confined aquifer wells in the watershed. The NJDEP estimates that there were approximately 31,363 people inhabiting this fast developing watershed in the year 2000, and that it would increase to 34,006 by 2010, and is projected to further increase to 40,185 by the year 2030 (NJDEP, 2005, WMA 17 Upper Maurice River watershed). The majority of this growth is likely to be in Newfield and Vineland, outside of Salem County. In 1995, the watershed was comprised of primarily forest (31%), urban/suburban (30%), agricultural (21%), wetlands (15%) land uses. Between 1986 and 1995, approximately 2% of the watershed s land was converted from primarily forest land to urban/suburban land uses. In Salem County, some stream reaches in the Upper Maurice River watershed are not attaining their designated uses (NJDEP, 2012, pages ). The Maurice River at Willow Grove Lake is not attaining its designated uses for aquatic life, fish consumption, primary contact recreation, and public water supply. Green Branch/Endless Branch is not attaining its designated uses for aquatic life, fish consumption primary contact recreation, and public water supply. While many of these waterways are not attaining their designated uses due to direct water quality problems, streamflow depletion as described above will exacerbate these problems due to the loss of needed aquatic flows and loss of dilution. According to Map 1, relatively small section of the watershed in the Upper Maurice River watershed is being proposed to be sewered (The Villages). The residents and businesses within the watershed and neighboring watersheds primarily rely on the unconfined Cohansey aquifer; however, there is a major public supply using an unidentified confined aquifer. Saltwater intrusion may be an issue for this wells since most of the confined aquifers in this region are salty. As per Appendix B, the 7Q10 and September median flow at the outlet of the Upper Maurice River watershed are respectively estimated at 15.5 MGD and 42.6 MGD, which translates to an estimated water availability of 6.8 MGD. This watershed is presently considered to be nearing a stressed condition as total depletive and consumptive demand is 17.2 MGD, which is 253 percent of availability. At full allocation, depletive and consumptive demand is projected to grow to 20.8 MGD, which is 306 percent of water availability.

49 Map 10. Surface water, unconfined and confined aquifer withdrawals, and surface and ground water wastewater discharges in the Upper Maurice River Watershed.

50 With respect to drought flows, total current depletive and consumptive demand will consume 111 percent of the 7Q10 low flow; at full allocation these demand would consume 134 percent of the 7Q10. This translates to a possible drying up of the watershed during future drought. Future increases in demand, including those that are expected as the FWSAs are expanded, will thus place a heavy strain on the natural resources, its ESAs, and the ability to attain the designated uses of the surface and ground water resources of the watershed. Moreover, as previously described, streamflow losses might contribute to saltwater intrusion in the confined aquifers of this region of Salem County. The more reductions to streamflow in the Salem River, the more brackish water is induced upstream. This is the location of the PRM aquifer system s recharge area. Muddy Run Nearly all of the Muddy Run Watershed is in Salem County. The Muddy Run Watershed has a 57.9 square mile drainage area that flows into the Maurice River from its headwaters in Upper Pitts Grove. Parts of Pitts Grove occupy it. The major tributaries that exist in Salem County are the Valentine Branch and Indian Run. Most of the Muddy Run Watershed and its tributaries are categorized as a FW2 waters by the NJDEP. Map 11 depicts the watershed including surface water, unconfined and confined aquifer withdrawals, and surface and ground water wastewater discharges. As shown, there are several public and agricultural confined aquifer wells in the watershed. The NJDEP estimates that there were approximately 10,458 people inhabiting this relatively fast developing watershed in the year 2000, and that it would increase to 11,003 by 2010, and is projected to further increase to 12,561 by the year 2030 (NJDEP, 2005, WMA 17 Muddy Run Watershed). In 1995, the watershed was comprised of primarily agricultural (47%), forest (22%), wetlands (18%), urban/suburban (11%), land uses. Between 1986 and 1995, approximately 2% of the watershed s land was converted from primarily agricultural land to urban/suburban land uses. Some stream reaches in the Muddy Run Watershed are not attaining their designated uses (NJDEP, 2012, pages ). Muddy Run below Elmer Lake is not attaining its designated uses for aquatic life. Palantine Branch (Muddy Run) is also not attaining its designated uses for aquatic life. Indian Run is not attaining its designated uses for aquatic life and public water supply. While these waterways are not attaining their designated uses due to direct water quality problems, streamflow depletion as described above will exacerbate these problems due to the loss of needed aquatic flows and loss of dilution. According to Map 1, five relatively small sections of the watershed in the Muddy Run Watershed are being proposed to be sewered. The residents and businesses within the watershed primarily rely on the unconfined Cohansey aquifer; however, there is two major public supply (unidentified) confined aquifer wells operated by Elmer Borough Water Department. Saltwater intrusion may be an issue for these wells since most of the confined aquifers in this region are salty.

51 Map 11. Surface water, unconfined and confined aquifer withdrawals, and surface and ground water wastewater discharges in the Muddy Run Watershed. As per Appendix B, the 7Q10 and September median flow at the outlet of the Muddy Run Watershed are respectively estimated at 10.1 MGD and 20.8 MGD, which translates to an

52 estimated water availability of 2.7 MGD. This watershed is presently considered to be in a severely stressed condition as total depletive and consumptive demand is 15.4 MGD, which is 570 percent of availability. At full allocation, depletive and consumptive demand is projected to grow to 23.2 MGD, which is 859 percent of water availability. Regarding drought flows, total current depletive and consumptive demand will consume 152 percent of the 7Q10 low flow; at full allocation these demand would consume 230 percent of the 7Q10. This translates to a possible drying up of the watershed during future drought. Future increases in demand, including those that are expected as the FWSAs are expanded, will thus place a heavy strain on the natural resources, its ESAs, and the ability to attain the designated uses of the surface and ground water resources of the watershed. Upper Cohansey River The headwaters of the Cohansey River Watershed are in Salem County near Aldine. The Upper Cohansey River Watershed has a 37.4 square mile drainage area that flows through Cumberland County into the Delaware Bay. Parts of Alloway Township occupy it. The major tributary that exist in Salem County is Clarks Branch. Most of the Upper Cohansey River Watershed and its tributaries are categorized as a FW2 waters by the NJDEP. Map 12 depicts the watershed including surface water, unconfined and confined aquifer withdrawals, and surface and ground water wastewater discharges. As shown, there are several agricultural and mining operation unconfined aquifer wells in the watershed. The NJDEP estimates that there were approximately 6,896 people inhabiting this relatively slow developing watershed in the year 2000, and that it would increase to 7,377 by 2010, and is projected to further increase to 8,665 by the year 2030 (NJDEP, 2005, WMA 17 Upper Cohansey River Watershed). In 1995, the watershed was comprised of primarily agricultural (68%), forest (12%), urban/suburban (10%), and wetlands (7%) land uses. Between 1986 and 1995, approximately 2% of the watershed s land was converted from primarily agricultural land to urban/suburban land uses. The Cohansey River upstream of Beals Mill in the Upper Cohansey River Watershed in Salem County is not attaining their designated uses for aquatic life and primary contact recreation (NJDEP, 2012, page 303). While this stream reach is not attaining its designated uses due probably to direct water quality problems, streamflow depletion as described above will exacerbate these problems due to the loss of needed aquatic flows and loss of dilution. According to Map 1, one small section of the watershed in the Upper Cohansey River Watershed is already sewered. The residents and agricultural operations within the watershed primarily rely on the unconfined Cohansey aquifer. Due to the fact that these residents and agricultural operations exist in the headwaters of the Cohansey River, streamflow depletion is quite possible as a result of consumptive water uses.

53 Map 12. Surface water, unconfined and confined aquifer withdrawals, and surface and ground water wastewater discharges in the Upper Cohansey River Watershed.