Water Works 11 - 3/19/03

Deficiencies of New Jersey Geologic Survey Aquifer Test Report

( Excerpts from Fellow Correspondent’s letter, continued. )

The original test plan for the QVF wells called for testing of QVF-2 and QVF-3. The first paragraph of the November 19, 1999 cover letter states that “Problems were experienced with monitoring drawdown in QVF-2 and there was no response in nearby observation wells.” No data for the QVF-2 test was presented. I was told on the day of the test that the well drew down too far, too fast and the yield of the well was lower than expected. Is this accurate? Why was QVF-2 never tested after that? Further, page 1 of the “Results of Aquifer Test at Quaker Valley Farms” (i) states that “an 8-hour drawdown and recovery test was conducted on well QVF-2.” Where is this data and why wasn’t it reported?

The NJGS November 19, 1999 report states that at 7.368 mgm “the analysis indicates that drawdown in the aquifer at this rate of use would be significant.” This is at least a partial answer to 7:20A-2.5(a)7(i). The impact analysis indicates that water level observation wells are needed to monitor water levels near Quaker Valley Farms. To date, these wells have not been installed.

Page 2 of the NJGS November, 1999 report states that at 16.254 mgm the effects on groundwater users “would be considerable.” The NJGS analysis uses the entire area of the Lockatong basin for their analysis. The use of the entire basin is not appropriate when all the allocations are in the headwaters of the basin. Why was no analysis of the headwaters conducted for this allocation? The 7Q10 low stream flow for Lockatong Creek (ii) has not been presented, and data on the impact of the 19 mgm total diversion on the 7Q10 was not discussed by the NJGS or found in the file at the BWA. This analysis should be conducted before further consideration is given to this application.

Also not included in the NJGS analysis of basin impact and groundwater recharge are the impervious coverage, soil compaction, and weed block fabrics on the GSG and QVF properties. Greenhouses and other impervious and nearly impervious surfaces cover large sections of the properties. Much of the nearly 160 acres has severely diminished recharge capacity. The NJGS did not include the loss of recharge due to impervious cover in their analysis of water use. The NJGS must include this in their analysis, as nearly 25% of a square mile of recharge area may have been lost. This analysis should be conducted before further consideration is given to this application.

The GSG and QVF properties not only demand high consumption of water, but cover the soil and prevent aquifer recharge over large areas, the double jeopardy of water resource management. Covering the soil also presents another serious concern that has not been addressed by the NJGS or the NJDEP. Typically, the soil zone will permit the recharge of rain water with some level of dissolved oxygen into the aquifer. However, when that soil is covered and dies, as under hoop houses and mum fields, organic matter in the soil will decay and use up significant amounts of dissolved oxygen. The potential exists to decrease the dissolved oxygen level of what little recharge water occurs and mobilize naturally occurring metals. Specifically, iron and manganese levels will be observed to increase. Arsenic and lead sulfide minerals may also begin to dissolve. Potential geochemistry impacts have to be evaluated when you have coverage of nearly 100 acres or more in concrete, greenhouses, weed block fabrics and hoop houses.

Page 2 of the NJGS report discusses well failures during drought that have been reported for wells in the Lockatong basin in the Quakertown area, in particular during the drought year 1998. As previously discussed, 1998 was not a drought year, especially due to the high rainfall that occurred early in 1998 during the primary period of aquifer recharge. An explanation as to why 1998 is considered a groundwater drought year is needed to support this assertion.