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February 15, 2016

:'vfary Anne Clausen, Chair
Board of Supervisors
Eldred Township
P.O. Box 600
490 Kunkletown Road
Kunkletown, PA 18058

RE:

Special Exception Zoning Application

Hanover Project ELD15-23

Dear Mary Anne:

We have conducted a preliminary review of the following geology documents, as received by
Hanover Engineering Associates, Inc. on January 12, 2016.

Report entitled "Special Exception Zoning Application for Deer Park - Chestnut Springs
Project", Volume 100 and 20f3.

We offer the following comments:

1. The report states variously that the overall proposed rate of withdrawal will be 138 gallons
per minute (gpm) and 200,000 gallons per day (gpd). While it is recognized that the
difference between these figures of 1,280 gpd may be the result of "rounding", we request
that the applicant cla.rify whether the intent is to pump both wells simultaneously for twentyfour (24) hours straight at the stated combined pumpage rate, or to pump the wells for a
shorter duration at a higher rate to achieve the same average withdrawal. If the latter, the
applicant should provide the maximum pumpage rate planned, and comment on the
adequacy of existing calculations to assess its impact.
2. The report states that the Unnamed Tributary did not act as a boundary, that the
downgradient capture limit falls substantially short of this feature, and that "no direct
recharge is induced from the Unnamed Tributary or from areas to the west of the Unnamed
Tributary."
The consultant has provided Pumping Test Drawdown Maps (Figures 8, 9, and 10) which
depict drawdown contours extending significantly west of the Unnamed Tributary, and West
of Chestnut Ridge Road for that matter. The consulta.nt should clarify this apparent
inconsistency.
3. The consultant has stated that the reduction in flow in the Unnamed Tributary during the
combined pumping test was 62 gpm, compared to the average daily flow of approximately
521 gpm. This is apparently due to a dimunition of flow from the Lower Spring (which feeds
the lower reach of theUnnarned Tributary), since the consultant has already established that
no flow of surface water from the channel of the tributary was induced during the pumping
tests.
The consultant has dismissed the reduction in flow in the Unnamed Tributary as minimal.
The reduction represents an almost twelve percent (12%) decrease in flow, which in our
opinion may be great enough to have an effect on the aquatic organisms living in the
tributary. The consultant has concluded that nearly half of the flow of the Unnamed
Tributary at its outlet to the Buchwha Creek "is corning from outside the topographically

252 Brodhead Road, Suite 100 Bethlehem, PA 18017-8944 610.691.5644 Fax 610.691.6968 www.hanovereng.com

Mary Anne Clausen

Eldred Township

February 15, 2016

delineated watershed". The implication is that the source water creating the flow of the
Unnamed Tributary is derived almost entirely from areas far outside of the project property
boundary and therefore cannot be protected or guaranteed by the applicant.
4. The consultant has provided "worst case" calculations of drawdown in various wells
assuming zero (0) recharge for one hundred eighty (180) days. The consultant should clarify
whether similar calculations were performed to assess the effect on the Lower Spring and
the flow of the Unnamed Tributary, and state how much the tributary flow will be
diminished under that scenario.
5. The report states that the withdrawallitnit/safe yield was determined to be 0.525 million
gallons per day (mgd) for the Unnamed Tributary, based on very conservative Delaware
River Basin Commission methods, and compares this to a withdrawal of 0.206 mgd for
current uses plus the proposed Project. From this comparison, the report concludes that
"the proposed withdrawal will not cause a reduction in groundwater quantity available to
other properties within the recharge area and that the proposed use is sustainable".
Simply based on the numbers presented, the proposed withdrawal in fact causes a thirty-nine
percent (39%) reduction in the groundwater quantity available within the recharge area. All
of this from a single eighty-acre (80 ac) property that occupies only twenty-one percent
(21 %) of the 0.57 square mile recharge area as calculated by the consultant. In our opinion,
this represents a disproportionately large usage of water ",-ithin this basin by a single user
which may eventually prevent other land owners within the basin from being able to utilize
their properties as they wish due to lack of groundwater availability. The sustainability of this
project may ultimately depend on controlling and curtailing the water usage of other
prospective users in the basin.
6. We request that the consultant clarify that the pumping water level in each production well
reached equilibrium (i.e. - drawdown stabilized), and at what elapsed time this occurred
during each of the three (3) pumping tests.
7. The applicant should clarify whether they propose to provide long-term monitoring to the
wells currently owned oy Cogan and Tanzosh, how this arrangement will be formalized with
the current owners, how it ",-ill be transferrable to potential new owners, and how it will be
executed and managed.
Please note that the review of this application is ongoing and is, therefore, subject to fw:ther
comment.
If you have any questions or comments regarding this information, please contact this office.

Respectfully,

~OVE~E;~rG ASSOCIATES, INC.

\Jk1Y- ~-

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Christopper A. Taylor, PGJ

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cc:

Attorney Paul Cohen

Eric Andreus