c. Proposed riprapping of the shoreline could further reduce wetland 



acreage. The applicant has faUed to demonstrate that there will not be an 

 adverse water quality and related habitat impaa resulting from riprapping. 



t Based upon information received by the Department, the applicant has 

 underestimated the total wetland acreage affected. 



2. The applicant has failed to demonstrate that there will be no adverse water 

 quality impacts from increased groundwater levels resulting from the project 

 The ground water model used by the applicant is not acceptable due to 

 erroneous assumptions and the lack of a sensitivity analysis. The applicant has 

 not provided sufBcient information concerning the impact of increased 

 groimdwater levels on existing sites of subsurface contamination, adequacy of 

 subsurface sewage system replacement areas and the impact of potential 

 increased surface flooding. Additionally, information was not provided to 

 adeqtiately assess the effect of raised groundwater on sewer system laterals, 

 effectiveness of sewer rehabilitation measures and potential for increased flows at 

 the Harrisbtirg wastewater plant 



3. The applicant has failed to demonstrate that there wiU not be a dissolved oxygen 

 problem as a result of the impoundment Present information indicates the 

 existing river system in the area is sensitive to diurnal, dissolved oxygen 

 fluctuatioiL Suffident information was not provided to allow the Department to 

 conclude that dissolved oxygen standards wfll be met in the pool area. 

 Additionally, the applicant failed to adequately address the issue of anticipated 

 dissolved oxygen levels below the dant 



4. The proposed impoundment will create a backwater on the lower three miles of 

 the Conodoguinet Creek. Water quality in the Creek is currently adversely 

 affected by nutrient problems. The applicant has failed to demonstrate that 

 there will not be water quality degradation as a result of the impoundment 



5. The applicant has failed to demonstrate that there will not be an adverse water 

 quali^ impact resulting from combined sewer overflows. 



6. The applicant has faOed to demonstrate that there wiU not be an adverse water 

 quality impact to the 150 acre area downstream of the proposed dam and 

 upstream from the existing Dock Street dam. 



7. The applicant has failed to demonstrate that the construction and operation of 

 the proposed dam will not have an adverse imp>act on the aquatic resoiirces 

 upstream from the proposed impoundment For example, the suitability of the 

 impoundment for smalimouth bass spawning relative to the frequency of turbid 



52 



