March 1, 2019 Via Federal Express Application Support ...

Application Support 1/2

Ramboll 1760 Market Street Suite 1000 Philadelphia, PA 19103 USA

T +1 215 523 5600 F +1 215 496 0164 www.ramboll.com

March 1, 2019

Via Federal Express

Application Support Department of Environmental Protection Division of Land Use Regulation 501 E. State Street, 2nd Floor Trenton, NJ 08609

RE: APPLICATION FOR WATERFRONT DEVELOPMENT INDIVIDUAL PERMIT PROJECT: DRP GIBBSTOWN LOGISTICS CENTER (DOCK 2) APPLICANT: DELAWARE RIVER PARTNERS LLC 200 NORTH REPAUNO AVENUE BLOCK 8, LOT 4 GREENWICH TOWNSHIP, GLOUCESTER COUNTY, NEW JERSEY

Dear Sir/Madam:

On behalf of the applicant, Delaware River Partners LLC (DRP), please find enclosed an application for a Waterfront Development Individual Permit to construct a two-berth dock at the above-referenced site. Laura George with Ramboll U.S. Corporation is serving as agent for this application.

To satisfy the requirements of the Coastal Zone Management Rules (N J.A.C. 7:7) the following items are enclosed, bound into two volumes:

Administrative Items (1 copy)

• Item 1: Completed WFD Application Checklist;

• Item 2: Completed DLUR Form, signed by the Applicant/Owner, Agent forthe Applicant/Owner, and Preparers of the site plan and supportingapplication documents; and

• Item 3: Proof of Public Notification, including:

• Proof of Mailing (FedEx Confirmation) and copy of the cover letter sent to theTownship of Greenwich Municipal Clerk transmitting one (1) copy of theentire joint FWA-FHACA application package;

• Template notice letter sent to property owners within 200 feet of theProperty and copies of notice letters sent to the Township of GreenwichEnvironmental Commission, Planning Board and Construction Official, andthe Gloucester County Planning Board;

• White USPS mail receipts for all notice letters sent;

• Certified list of property owners within 200 feet of the site, as provided bythe Township of Greenwich;

Application Support 2/2

• Copy of newspaper notice published in the South Jersey Times on February 20, 2019.

Compliance/Environmental Impact Statement (3 copies) • Written narrative to describe the site, existing site conditions, and the proposed project activities.

• Statement of Compliance with Coastal Zone Management Rules, meeting the requirements for the Environmental Impact Statement;

• Site location map on a USGS quadrangle;

• Site location street map;

• Site location on Greenwich Township tax parcels map;

• Site photographs;

• Additional documentation required to demonstrate compliance, including:

– Proof of Tidelands Ownership

– Copies of Application for Tidelands Licenses

– Alternatives Analysis

– Atlantic and Shortnose Sturgeon Impact Assessment

– Phase 1 Underwater Archaeological Investigation Report

– Submerged Aquatic Vegetation Survey Report

• Note that the Dredged Material Management Plan will be provided under separate cover.

SITE PLANS (3 copies) Three (3) sets of Site Plans signed and sealed by Thomas Shafer, Jr., P.E. of Moffatt & Nichol, a New Jersey-licensed Professional Engineer. Additional copies will be provided upon request.

An electronic version of the complete application is also provided on the enclosed CD.

Also enclosed is a check (No. 1826) in the amount of $30,000.00, made payable to Treasurer, State of New Jersey for the application fee.

Should you have any questions or require any additional information, please do not hesitate to contact me at [email protected] or 215-523-5603.

Sincerely, Laura George Principal Consultant

LNG:jap 1690000609-001, Task 105

Enclosures

cc: Gary Lewis, DRP (email) Jim Osman, DRP (email) David Miller, Gibbons PC (email) Thomas Shafer, Moffat & Nichol (email)

Prepared for:

Delaware River Partners LLC

Gibbstown, NJ Prepared By:

Ramboll US Corporation

Philadelphia, New Jersey Date

February 2019 Project Number

169000609

APPLICATION FOR WATERFRONT DEVELOPMENT INDIVIDUAL PERMIT ADMINISTRATIVE ITEMS DOCK 2 DRP GIBBSTOWN LOGISTICS CENTER GIBBSTOWN, GLOUCESTER COUNTY, NEW JERSEY

WATERFRONT DEVELOPMENT INDIVIDUAL PERMIT APPLICATIONS

Item Permit Application Requirement

1 Completed Application Checklist

2

3

Completed DLUR Application Form and Fee Calculation

Proof of Public Notice Requirements

-- Copy of Newspaper Public Notice

-- Letter to Municipal Clerk and Evidence of Mailing

-- Template Notice Letter to Property Owners Within 200’ of Site

and Notice Letters to Township and County Contacts

-- Certified Mail Receipts


ITEM 1

COMPLETED APPLICATION CHECKLIST

1

State of New Jersey Department of Environmental Protection

Revised: June 2018 Website: www.nj.gov/dep/landuse

COASTAL ZONE MANAGEMENT APPLICATION CHECKLIST Waterfront Development and/or Coastal Wetlands Individual Permit

To apply for a Waterfront Development and/or Coastal Wetlands Individual Permit, please submit the information below to:

Postal Mailing Address Street Address (Courier, Overnight & Hand Carry Only) NJ Department of Environmental ProtectionDivision of Land Use RegulationP.O. Box 420, Code 501-02ATrenton, New Jersey 08625-0420

Attn: Application Support

NJ Department of Environmental ProtectionDivision of Land Use Regulation501 East State StreetStation Plaza 5, 2nd FloorTrenton, New Jersey, 08609Attn: Application Support

1. Completed application form;

2. Documentation that notice of the application has been provided in accordance with N.J.A.C. 7:7-24, asfollows:

Notice to municipal clerk (N.J.A.C. 7:7-24.3(a))A copy of the entire application, as submitted to the Department, must be provided to the municipal clerk ineach municipality in which the site is located.

i. Documentation of compliance with this requirement shall consist of a copy of the certified United StatesPostal Service white mailing receipt, or other written receipt, for each copy of the application sent.

Notice to governmental entities and property owners (N.J.A.C. 7:7-24.3(b) and (c))A brief description of the proposed project, a legible copy of the site plan, and the form notice letter describedat N.J.A.C. 7:7-24.3(d)1iii must be sent to the following recipients:

A. The construction official of each municipality in which the site is located;B. The environmental commission, or other government agency with similar responsibilities, of each

municipality in which the site is located;C. The planning board of each municipality in which the site is located;D. The planning board of each county in which the site is located;E. The local Soil Conservation District if the regulated activity or project will disturb 5,000 square feet or

more of land; andF. Adjacent property owners:

If the application is for one of the following projects (listed at N.J.A.C 7:7-24.3(c)1-5), notice shall besent to all owners of real property, including easements, located within 200 feet of any proposed above-ground structure, except for any conveyance lines suspended above the ground or small utility supportstructures (e.g. telephone poles):

• A linear project of one-half mile or longer

• A shore protection development, including beach nourishment, beach and dunemaintenance, or dune creation of one-half mile or longer

• A public project on a site of 50 acres or more

CALL NJDEP AT (609) 777-0454 IF YOU HAVE ANY QUESTIONS

X

X

X

http://www.nj.gov/dep/landuse

2

• An industrial or commercial project on a site of 100 acres or more

• Maintenance dredging of a State navigation channel of one-half mile or longer

For any other project, notice shall be sent to all owners of real property, including easements, located within 200 feet of the site of the proposed regulated activity.

The owners of real property, including easements, shall be those on a list that was certified by the municipality, with a date of certification no more than one year prior to the date the application is submitted.

ii. Documentation of compliance with this requirement shall consist of:

A. A copy of the certified United States Postal Service white mailing receipt for each public notice that wasmailed, or other written receipt; and

B. A certified list of all owners of real property, including easements, located within 200 feet of the propertyboundary of the site (including name, mailing address, lot, and block) prepared by the municipality foreach municipality in which the project is located. The date of certification of the list shall be no earlierthan one year prior to the date the application is submitted to the Department.

iii. The form notice letter required under N.J.A.C. 7:7-24.3(d)1iii shall read as follows:

“This letter is to provide you with legal notification that an application for a <<waterfront development/coastal wetlands>> individual permit <<has been/will be>> submitted to the New Jersey Department of Environmental Protection, Division of Land Use Regulation for the development shown on the enclosed plan(s). A brief description of the proposed project follows: <<INSERT DESCRIPTION OF THE PROPOSED PROJECT& PROPOSED CHANGES>>

The complete permit application package can be reviewed at either the municipal clerk’s office in the municipality in which the site subject to the application is located, or by appointment at the Department’s Trenton Office. The Department of Environmental Protection welcomes comments and any information that you may provide concerning the proposed development and site. Please submit your written comments within 15 calendar days of receiving this letter to:

New Jersey Department of Environmental Protection Division of Land Use Regulation P.O. Box 420, Code 501-02A Trenton, New Jersey 08625 Attn: (Municipality in which the property is located) Supervisor”

Newspaper Notice (N.J.A.C. 7:13-19.4) Newspaper notice, in the form of a legal notice or display advertisement in the official newspaper of the municipality(ies) in which the project site is located, or if no official newspaper exists, in a newspaper with general circulation in the municipality(ies), is required for the following projects:

• A linear project of one-half mile or longer

• A shore protection development, including beach nourishment, beach and dunemaintenance, or dune creation of one-half mile or longer

• A public project on a site of 50 acres or more

• An industrial or commercial project on a site of 100 acres or more

• Maintenance dredging of a State navigation channel of one-half mile or longer

If your project is not one listed above, newspaper notice is not required.

i. Documentation of newspaper notice shall consist of:

A. A copy of the published newspaper notice; and

X

X

3

B. The date and name of the newspaper in which notice was published.

ii. The newspaper notice may be either a legal notice or display advertisement and must read asfollows:

“Take Notice that an application for an application for a <<waterfront development/coastal wetlands>> individual permit <<has been/will be>> submitted to the New Jersey Department of Environmental Protection, Division of Land Use Regulation for the development described below:

APPLICANT:

PROJECT NAME:

PROJECT & MODIFICATION DESCRIPTION:

PROJECT STREET ADDRESS:

BLOCK: LOT:

MUNICIPALITY: COUNTY:

The complete permit application package can be reviewed at either the municipal clerk’s office in the municipality in which the site subject to the application is located, or by appointment at the Department’s Trenton Office. The Department of Environmental Protection welcomes comments and any information that you may provide concerning the proposed development and site. Please submit your written comments within 15 calendar days of the date of this notice to:

New Jersey Department of Environmental Protection Division of Land Use Regulation P.O. Box 420, Code 501-02A 501 East State Street Trenton, New Jersey 08625 Attn: (Municipality in which the property is located) Supervisor”

Notice for projects located in the Pinelands Area

For a project in the Pinelands Area as designated by as designated under the Pinelands Protection Act at N.J.S.A. 13:18A-11(a), documentation showing that a copy of the entire application has been provided to the New Jersey Pinelands Commission.

Notice for installation of submarine cables or sand mining activities

An applicant applying for waterfront development individual permit to install a submarine cable in the ocean, or to perform sand mining in the ocean, must provide documentation that a copy of the completed application form and a copy of the NOAA nautical chart showing the proposed cable route or the limits of the proposed sand mining area submitted to the Department as part of this permit application were sent to the following entities:

1. Garden State Seafood Association;

2. National Fisheries Institute;

3. North Atlantic Clam Association;

4. Rutgers Cooperative Extension;

5. New Jersey Shellfisheries Council; and

6. New Jersey Marine Fisheries Council.

4

3. The appropriate application fee, as specified in N.J.A.C. 7:7-25.1, in the form of a check (personal, bank,certified, or attorney), money order, or government purchase order made payable to “Treasurer State ofNew Jersey.”

4. Three sets of site plans, certified in accordance with N.J.A.C. 7:7-23.2(j). Prior to issuance of any permit,the Department will require four to five sets of final site plans. The site plan shall be signed and sealed bya New Jersey licensed professional engineer, surveyor, or architect, as appropriate, pursuant to N.J.A.C.13:40-7.2 through 7.4. The site plans must include the scale of the site plan, a north arrow, the name of theperson who prepared the plan, date the site plan was prepared, and the applicant’s name and the block, lotand municipality in which the site is located. In addition, the site plan shall include the followinginformation, both on and adjacent to the site, in accordance with N.J.A.C. 7:7-23.4(a)4:

i. Existing features such as lot lines, structures, land coverage, vegetation, and location of themapped coastal wetlands line;

ii. All proposed regulated activities such as changes in lot lines; the size, location, and details of anyproposed structures, roads, or utilities; details of any clearing, grading, filling, and excavation; thelocation and area of any riparian zone vegetation that will be disturbed; cross-sections of regulatedwaters or water control structures being analyzed; and the anticipated limits of disturbance;

iii. Topography:A. Existing and proposed topography where necessary to demonstrate that the proposed

regulated activity or project meets the requirements of this chapter. All topography mustreference NGVD or include the appropriate conversion factor to NGVD.

iv. Tidelands:

A. The limits of any existing or proposed tidelands instrument;

v. Soil erosion and sediment control:

A. Details of any proposed soil erosion and sediment control measures.

vi. Water information:

A. For all applications, as applicable: The mean high, mean low, and spring high water lines of any

tidal waters, water depths, and location of navigation channels.

B. Where the regulated activity is the construction of a dock, pier, or mooring area, the site plan

must show the location and orientation of the proposed mooring area(s), the water depths at

mean low water within the mooring area(s), and cross sections of the dock including the height

and width of the structure over the water and crossing wetlands. Except for docks proposed

within lagoons, the site plan must also depict water depths at mean low water for a distance of

at least 100 feet waterward of the dock. The site plan must include the method, date, and time

of all soundings;

C. For dredging activities, the area to be dredged, existing and proposed water depths at mean

low water, the water depths at mean low water adjacent to the area to be dredged, the amount

of material to be dredged, the method of dredging, the location of the dredged material

dewatering and placement site, including the municipal block and lot, and the means of

containing the dredged material;

vii. The upper and lower limits of all special areas, as described at N.J.A.C. 7:7-9. For the purposes of

this requirement, “upper” refers to the upland or landward limit and “lower” refers to the waterward

limit of the special area;

viii. The location of any existing or proposed public access to lands and waters subject to public trust

rights as set forth at N.J.A.C. 7:7-9.48; and

NOTE: In accordance with N.J.A.C. 7:7-23.3(h), an applicant may elect to prepare his or her own plan if both of the following are true: (1) the applicant proposes an activity in a man-made lagoon, or the applicant proposes the construction of a single-family home or duplex or an accessory

X

X

5

development located landward of the mean high water line, such as a patio, garage, or shed on his or her own property for his or her own use, and (2) the proposed regulated activity or project is one for which no survey, topography, or calculations are necessary to demonstrate the requirements of this chapter are met.

5. State Plane coordinates in accordance with N.J.A.C. 7:7-23.4(a)5.

i. For a linear development or shore projection development of one-half mile or longer, include State planecoordinates at the endpoints of the project and State plane coordinates for points located at 1,000-footintervals along the entire length of the project;

ii. For a linear development or shore projection development of less than one-half mile in length, includeState plane coordinates at the endpoints of the project;

iii. For all other projects, State plane coordinates at the approximate center of the site (within 50 feet of theactual center)

6. Color photographs depicting the entire project area, mounted on 81/2 inch by 11 inch paper and

accompanied by a map showing the location and direction from which each photograph was taken. Copies

of photographs are acceptable provided they are color copies. Black and white photographs are not

acceptable.

7. Calculations and analyses:i. If the project is a major development as defined by N.J.A.C. 7:8-1.2, a demonstration of compliance withthe requirements of the Stormwater Management Rules, N.J.A.C. 7:8 is required. Seewww.njstormwater.org for more information.

8. A description of any anticipated impacts of the proposed activity or project, including any monitoring orreporting methods that will be used.

9. A copy of an NJDEP Office of Natural Lands Management Natural Heritage Database data requestresponse for endangered or threatened species of flora or fauna, including a Landscape Map report.

10. For an activity or project in the Pinelands Area as designated under the Pinelands Protection Act atN.J.S.A. 13:18A-11(a), a Certificate of Filing, a Certificate of Completeness, or a resolution approving anapplication for public development, issued by the NJ Pinelands Commission.

11. Three copies of an Environmental Impact Statement (EIS) that:i. Describes in narrative form:

A. The proposed development or activity;B. The characteristics of the site and the surrounding region; andC. The location of all proposed regulated activities, potential impacts from the construction

process, and, as applicable the operation of the development after completion;ii. Discusses the applicability of the Coastal Zone Management rules to the proposed development,

including a detailed statement of compliance with each rule applicable to the type of developmentproposed. Where the applicant believes a rule otherwise applicable to the type of developmentproposed does not apply, the applicant shall explain the reasons why the rule does not apply to theapplicant’s development;

iii. As necessary based on project-specific and site-specific circumstances, provides support byrelevant experts for the assessments, discussions, and statements made in the EIS; include thequalifications of the persons who prepared each part of the EIS; and provide references andcitations to all information, reports, or treatises that are mentioned in the EIS but not contained inthe EIS; and

X

X

NA

X

X

NA

X

See DLUR Form

See EIS

6

iv. Provides evidence that all tidelands instruments required for the proposed project are obtained ORthat the applicant has submitted a complete application to the Bureau of Tidelands.

12 For tidal dredging projects, in addition to the information required in items 1 through 10 above:

A copy of an executed Sediment Sampling and Analysis Plan (Form available athttp://www.nj.gov/dep/landuse/forms.html.)

Sediment sampling results obtained in compliance with the approved SedimentSampling and Analysis Plan including:

Data summary tables that provide a comparison of the bulk sedimentchemistry results to the Department’s Soil Remediation Standards andthe modified elutriate results to the New Jersey Surface Water QualityCriteria. The summary tables shall highlight all results that exceedapplicable criteria. Data packages shall be provided electronically alongwith one (1) hard copy of the data summary tables;

Sediment sample core profile/logs (full project depth);

Written consent from the proposed dredged material management site indicating thatthey have reviewed the available sampling results and consent to acceptance of thespecified volume of dredged material.

13. For an activity that requires mitigation in accordance with N.J.A.C. 7:7, the applicant may submit amitigation proposal as part of the application for the individual permit. If the applicant does not submit amitigation proposal with the application, the applicant must submit the mitigation proposal at least 90calendar days before the start of activities authorized by the permit, in accordance with N.J.A.C. 7:7-17.

14. An application for an individual permit for the construction of wind turbines for which, in accordance withthe energy facility use rule at N.J.A.C. 7:7-15.4, pre- and/or post-construction monitoring is required, mustinclude the proposed monitoring methodology (see Technical Manual for Evaluating Wildlife Impacts ofWind Turbines Requiring Coastal Permits available at http://www.nj.gov/dep/landuse/guidance.html).

15. One computer disk containing a copy of the entire application.

X

NA

X

NA

X

to be provided under separate cover

to be provided under separate cover

http://www.nj.gov/dep/landuse/guidance.html


ITEM 2

COMPLETED DLUR APPLICATION FORM AND FEE CALCULATION


Division of Land Use Regulation Application Form for Permit(s)/Authorization(s)

501 E. State Street Mail Code 501-02A P.O. Box 420 Trenton, NJ 08625-0420

Phone#: (609) 777-0454 Web: www.nj.gov/dep/landuse • Please print legibly or type the following: Complete all sections and pages unless otherwise noted. Is this project a NJDOT Priority 1 Repair Project? Yes D No 00

Is this project a NJDOT Priority 2 Repair Project? Yes D No 00

1. Applicant Name: Mr./Ms./Mrs Gary Lewis, President, Delaware River Partners LLC E-Mail: [email protected]

Address: 200 North Repauno Avenue Daytime Phone: 856-224-7063 Ext. _____ _

City/State: Gibbstown. NJ Zip Code _o_so_2_1 ___ Cell Phone:----------

2. Agent Name: Mr./Ms./Mrs Laura George

Firm Name: Ramboll U.S. Corporation E-Mail: [email protected]

Address: 1760 Market Street, Suite 100 Daytime Phone: 215-523-5603 Ext. _____ _

City/State: Philadelphia, PA Zip Code _1_s_10_3 ___ Cell Phone:----------

3. Property Owner: Mr./Ms./Mrs Delaware River Partners LLC E-mail: ___________________ _

Address: Same as #1 above Daytime Phone: __________ Ext. _____ _

City/State: Zip Code ______ Cell Phone: _________ _

4. Project Name: Dock 2 at DRP Gibbstown Logistics Center Address/Location: 200 N. Repauno Avenue

Municipality: Greenwich Township County: Gloucester Zip Code 08027

Block(s): 8 Lot(s): 2, 3, 4.01, 4.02 and portions of 1 and 4

N.A.D. 1983 State Plane Coordinates (feet) E (x): ~I,_9~~ __ N(y): _]~ .~~ _ _ Not Longitude/Latitude

Watershed: Cedar Swamp/Repauno Creek/Clonmell Creek Subwatershed: Nehonsey Bk/Clonmell Ck& Repaupo Ck/Cedar Swamp

Nearest Waterway: Delaware River

5. Project Description: This applicant is seeking a Waterfront Development Individual Permit for the development of Dock 2 at the

DRP Gibbstown Logistics Center. The dock is designed to accommodate two vessels and includes two loading platforms and necessary

breasting and mooring dolphins. To create the berths, approximately 655,000 cy of sediment will be dredged.

Provide if applicable: Previous LUR File# (s): _s_ee_A_tt_a_c_h_m_en_t_A ________ _ Waiver request ID# (s): --------------

A. SIGNATURE OF APPLICANT (required):

I certify under penalty of law that I have personally examined and am familiar with the information submitted in this document and all attachments and that. based on my inquiry of those individuals immediately responsible for obtaining and preparing the information, I believe that the information is true, accurate, and complete. I am aware that there are significant penalties for knowingly submitting false information, including the possibility of fine and imprisonment. If the applicant is an organization such as a corpor ·on, municipal entity, home-owners assocition etc., the party responsible for the application shall sign on behalf of the organization.

(/' / .

Signature of Applicant

Date ~ / Date

Gary Lewis Print Name Print Name

Page I Document ID: lur_021.doc, Last Revised: January 2019

B. PROPERTY OWNER'S CERTIFICATION

I hereby certify that the undersigned is the owner of the property upon which the proposed work is to be done. This endorsement is certification that the owner/ease.men! holder grants permission for the conduct of the proposed activity. In addition, written consent is hereby giver to allow access to the site by representatives or agents of the Department for the purpose of conducting a site inspection(s) or survey(s) of the property in question.

In addition, the undersigned property owner hereby certifies:

1. Whether any work is to be done within an easement? Yes D No 181 (If answer is 'Yes" - Signature/title of resonsible party is required below)

2. Whether any part of the entire project will be located within property belonging to the State of New Jersey? Yes D Nol!!l

Yes D No i;1g

Yes D No~

3. Whether any work is to be done on any property owned by any public agency that would be encumbered by Green Acres?

4. Whether this project requires a Section 106 (National Register of Historic Places) Determination as part of a federal approval?

d-1 ./ 4~;~C~

SignatufEf of ONner/, ;;J It 19

Date / 1

Signature of Owner/Easement Holder

Date Gary Lewis, President, Delaware River Partners, LLC

Print Name Print NamefTitle

C. APPLICANT'S AGENT

I Gary Lewis, President, Delaware River Partners LLC, the Applicant/Owner and ----~~_,,,..~-~------• co-Applicant/Owner authorize to act as my agent/representative in all matters pertaining to my application the following person:

Laura George Name of Agent

Principal Consultant Occupation/Profession of Agent

AGENT'S CERTIFICATION:

I agree to serve as agent for the above-referenced applicant:

;_>. l~.· •- ) I .:.J..1.:....w .. _ ----------Signature of Agent

D. STATEMENT OF PREPARER OF PLANS, SPECIFICATIONS,

SURVEYOR'S OR ENGINEER'S REPORT

I certify under penalty of law that I have personally examined and am familiar with the information submitted in this document and all attachments and that, based on my inquiry of those individuals immediately responsible for obtaining and preparing the information, I believe that the information is true, accurate, and complete. I am aware that there are significant penalties for knowingly submitting false information, including the possibility of fine and imprisonment.

SEE PAGE 28

Signature

Thomas Shafer Jr. P.E. Print Name

Vice President, Moffatt & Nichol Position & Name of Firm

24GE03910200 Professional License# Date

Page2A

sinatiJ're of Applicant/Owner

Signature of co-Applicant/Owner

Ramboll US Corporation Name of Firm

E. STATEMENT OF PREPARER OF APPLICATION, REPORTS AND/OR

SUPPORTING DOCUMENTS (other than engineering)


Signature

Laura George Print Name

Principal Consultant, Ramboll US Corporation Position & Name of Firm

Professional License # (If Applicable)

2/25/19 Date

B. PROPERTY OWNER'S CERTIFICATION

I hereby certify that the undersigned is the owner of the property upon which the proposed work is to be done. This endorsement is certification that the owner/easement holder grants permission for the conduct of the proposed activity. In addition, written consent is hereby giver to allow access to the site by representatives or agents of the Department for the purpose of conducting a site inspection(s) or sU1vey(s) of the property in question.

In addition, the undersigned property owner hereby certifies:

1. Whether any work is to be dooo within an easement? Yes D No 181 (If answer is "Yes" - Signature/title of resonsible party is required below)

2. Whether any part of the entire project will be located within property belonging to the State of New Jersey? Yes D No l1!l

Yes D No~

Yes 0 No 181

3. Whether any work is to be done on any property owned by any public agency that would be encumbered by Green Acres?

4. Whether this project requires a Section 106 (National Register of Historic Places) Determination as part of a federal approval?

SEEPAGE2A

Signature of Owner/Easement Holder

Date Date Gary Lewis, President, Delaware River Partners, LLC

Print Name Print Name/Tille

C. APPLICANT'S AGENT SEEPAGE2A I Gary Lewis, President Delaware River Partners LLC, the Applicant/Owner and ------------• co-ApplicanVOwner authorize to act as my agent/representative in all matters pertaining to my application the following person:

Laura Ge_()~~e ____________ _

Name of Agent

______ .;..P.;.;;rin;.;;.cip~-~nsu~_!l __ t _______ _

Occupation/Profession of Agent

AGENT'S CERTIFICATION:

I agree to serve as agent for the above-referenced applicant:

Signature of Agent

Signature of ApplicanVOwner-----------

Signature of co-ApplicanVOwner

Rambolt US Corporation

Name of Firm

-·-----·-·-·-·-·-·-·-·-·-·-·-·---·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-·-D. STATEMENT OF PREPARER OF PLANS, SPECIFICATIONS,

SURVEYOR'S OR ENGINEER'S REPORT


s~ ~---------- Thomas Shafer._J_r,,j'J;_,_ ____________ _

Print Name

Vice President, Moffatt & Nichol Position & Name of Firm

24GE0391020Q ____ _ 1> ... 125-1a V-~------L ______ _

Professional license# Date

E. STATEMENT OF PREPARER OF APPLICATION, REPORTS AND/OR

SUPPORTING DOCUMENTS (other than engineering)


Page2B

SEEPAGE2A Signature --- ----

Laura George Print Name

Princi)lal CongiltantB..aJ!!QQJLLI~-kQ!Jlorat1on Position & Name of Firm

Professional license# lllAppliooblo)

Date

FEE CALCULATION TIPS:

• Whenever the calcuation requires an acreage figure (including the Stormwater calculations), you will need to round UP to the nearest whole number, for example: 0.25 acres gets rounded up to one (1) acre or 2.61 acres gets rounded up to three (3) acres.

• The maximum fee for a CAFRA Individual permit, an Upland Waterfront Development permit, or an In-Water Waterfront Development permit is $30,000 per permit type. For example: if you are applying for both an upland and an in-water Waterfront Development the maximum fee is applied to each permit for a maximum total of $60,000 plus any applicable stromwater review fee.

• The stormwater review fee is applied only one time per project, maximum of $20,000, regardless of multiple applications.

APPLICATION(S) FOR: Please check each permit/authorization that you are applying for and fill in the calculated fee (for each) in the "Fee Paid" column

Coastal General Permits Fee Amount Fee Paid Coastal Individual Pennits Fee Amount Fee Paid D CZMGP1 Amusement Pier Expansion

$1,000.00 D CAFRA - IP SFH or Duplex $2,000

0 CZMGP2 Beach/Dune Activities $1,000.00 D CAFRA - IP Residential not SFH/duplex $3,000 x __ # of units

D CZMGP3 Voluntary Reconstruction Certain $1,000.00 Residential/Commercial Dev.

D CAFRA - IP Commercial, Industrial or $3,000 x __ acres of Public the site

D CZMGP4 Development of one or two SFH or $1,000.00 Dunlexes

D WO - IP SFH or Duplex (Upland/Landward of $2,000 MHWL)

D CZMGPS Expansion or Reconstruction $1,000.00 SFH/Duolex

D WO - IP Residential not SFH/duplex $3,000 x __ # of (Uplandll"1dw..-d of MHWL) units

D CZMGP6 New Bulkhead/Fill Lagoon $1,000.00 D WO - IP Commercial, Industrial or Public $3,000 x __ acres of Develooment IUt landllandw..-d of MHWL\ the site

D CZMGP7 Revetment at SFH/Duplex $1,000.00 D WD - IP SFH or Duplex (Wateiward of MHWL) $2,000

0 CZMGPS Gabions at SFH/Duplex $1,000.00 D WO - IP Residential not SFH/duplex $3,000 x __ acres of (Wateiward of MHWL) water area lmnacted

D CZMGP9 Support Facilities at a Marina $1,000.00 at WD - IP Commercial, Industrial or Public $3,000 x ...A.5._acres of 30,000 Development IWateiward of MHWLl water area imnacted

D CZMGP10 Reconstruction of Existing Bulkhead $1,000.00 D CSW - IP SFH or Duplex $2,000

D CZMGP11 Hazard Waste Clean-up $1,000.00 D CSW - IP All Development not SFH/duplex $3,000 x __ acres of wetlands disturbed

D CZMGP12 Landfall of Utilities $1,000.00

D CZMGP13 Recreation Facility at Public Park $1,000.00 Additional Coastal Authorizations Fee Amount Fee Paid

D CZMGP14 Bulkhead Construction & Fill $1,000.00 Placement

D Modiflcation of a Coastal GP $500

D CZMGP15 Construction of Piers/Docks/Ramps in $1,000.00 Lanoons

D Minor Technical Modification of a Coastal $500 x ___JI of items Wetland Permit to be revised

a CZMGP16 Minor Maintenance Dredging in $1,000.00 Laaoons

D Minor Technical Modification of a CAFRA $500 x ____#of items IP to be revised

D CZMGP17 Eroded Shoreline Stabilization $1,000.00 D Minor Technical Modification of a $500 x ___JI of Items Waterfront IP to be revised

D CZMGP18 Avian Nesting Structures $1,000.00 D Major Technical Modification of a Coastal 0.30 x __ original fee Wetland Penmit =Fee (Minimum $500\

D CZMGP19 Modification of Electrical Substations $1,000.00 D Major Technical Modification of a CAFRA 0.30 x __ original fee IP = Fee Minimum $500\

D CZMGP20 Legalization of the Filling of Tidelands $1,000.00 D Major Technical Modification of a 0.30 x __ original fee Waterfront IP = Fee (Minimum $500\

D CZMGP21 Construction of Telecommunication $1,000.00 Towers

D Zane Letter (Waterfront Development $500 Exemotion\

D CZMGP22 Construction of Tourism Structures $1,000.00 D CAFRA Exemption Request $500

a CZMGP23 Geotechnical Survey Borings $1,000.00 D CZM General Permit Extension $240 x __ #of GPs to be extended

D CZMGP24 Habitat Creation, Restoration, No Fee No Fee Enhancement Livina Shorelines D Waterfront Development Individual Permit 0.25 x __ original fee

- Extension (Waterward of MH\111..) = Fee !Maximum $3 000\

D CZMGP25 1 to 3 Turbines < 200 Feet $1,000.00 D Meadowlands District Water Quality $5,000 + ($2,500 x Certificate __ #acres regulated

area disturbed\

D CZMGP26 Wind Turbines< 250 Feet $1,000.00 D Individual Penmit Equivalency/CERCLA No Fee No Fee

D CZMGP27 Dredae Laaoon I oost storm eventl $1,000.00

D CZMGP28 Dredae cost Bulkhead Failure $1,000.00

D CZMGP29 Dredne Marina loost stonm event\ $1,000.00

D CZMGP30 Aauaculture Activities $1,000.00 Consistency Determination Fee Amount Fee Paid

D CZMGP31 Placement of Shell (shellfish areas) $1,000.00 D Water Quality Certificate $5,000 + ($2,500 x (NOTE: No fee required under the coastal __ # acres regulated oroaram\ area disturbed\

D CZMGP32 Application of Herbicide in Coastal $1,000.00 D Federal Consistency No Fee No Fee Wetlands

D CZM Permit-by-Certification !On-line ann/icalion ONL YJ

$1000.00

Page 3

APPLICATION($) FOR: Please check each permit/authorization that you are applying for and fill in the calculated fee (for each) in the "Fee Paid" column

Freshwater Wetlands Fee Amount Fee Paid Freshwater Individual Permits Fee Amount Fee Paid General Permits

D FWGP1 Main. & Repair Exist Feature $1,000.00 D FWW /P-SFH/Duplex-Wetlands $2,000

D FWGP2 Underground Utility Lines $1,000.00 D FWW IP-Wetlands (not SFH/Duplex) $5,000 + ($2,500 x __ #acres FWW disturbed\

D FWGP3 Discharge of Return Water $1,000.00 0 FWW IP-SFH/Duplex-Open Water $2,000

0 FWGP4 Hazard Site lnvesUCleanup $1,000.00 D FWW IP-Open Water (not SFH/Duplex) $5,000 + ($2,500 x ___#acres FWW dislurbedl

D FWGP5 Landfill Closures $1 000.00 D FWGP6 Filling of Non-Tributary Wetlands $1,000.00

0 FWGP6A TA Adj. to Non-Tributary Wetlands $1,000.00 Freshwater Wetlands Fee Amount Fee Paid Transition Area Waivers

0 FWGP7 Human-made Ditches/Swales in $1,000.00 Headwaters

D TAW Averaging Plan With valid LO/ $1,000 + ($100 x

D FWGP8 House Additions $1,000.00

0 FWGP9 Airport Sight-line Clearing $1,000.00 D TAW Hardshin Reduction

__ #acres TA disturbed)

D TAW Reduction oer N.J.A.C. 7:7A-8.1 fdl D FWGP10A Very Minor Road Crossings $1,000.00 0 TAW Soecial Activitv Individual Permit

D FWGP10B Minor Road Crossings $1,000.00

D FWGP11 Outfalls/ Intakes Structures $1,000.00

D T AW Soecial Aclivitv Linear Develooment WilhQ!/l vgjrf. LQJ $1000 + ($100 x

D TAW Sn<>cial Aclivitv Redeve/ooment __ acres TA

0 FWGP12 Surveying and Investigating $1,000.00 disturbed) + LOI Fee

0 TAW Snecial Activitv Stormwater

0 FWGP13 Lake Dredging $1,000.00

D FWGP14 Water Monitoring Devices $1,000.00 Letter of lnteroretation Fee Amount Fee Paid D FWGP15 Mosquito Control Activities

$1 000.00 0 LOI Presence Absence $1,000.00

D FWGP16 Creation/Restoration/Enhancement No Fee No Fee Habitat

D LOI Footprint of Disturbance (3 Maximum) $1,000.00 each

D FWGP17 Trails I Boardwalks $1 000.00 0 LOI Delineation < 1.00 Acres $1 000.00

D FWGP17A Non-Motorized Multi-Use Paths $1,000.00 D LOI Verification

$1,000 + ($100 x __ # of acres of the sit0\

D FWGP18 Dam Repairs $1,000.00 0 LOI Partial Site Verification $1,000 + ($100 x___#

of acres of the site subiect to LO/\

D FWGP19 Docks and Piers $1,000.00 D LOI Extension Presence/Absence,

$500 Footprint, Delineation < 1 acre (Re-lssuancei

D FWGP20 Bank Stabilization $1,000.00 0 LOI Extension Line Verification (Re- 0.50 x __ original fee Issuance\ <Minimum $500\

D FWGP21 Above Ground Utility Lines $1,000.00

D FWGP22 Expansion Cranberry Growing No Fee No Fee (Pinelands) Additional Freshwater Fee Amount Fee Paid

Wetlands Authorizations D FWGP23 Spring Developments $1 000.00 D FWGP Administrative Modification No fee No Fee

0 FWGP24 Malfunctioning Individual Septic Svstems No Fee No Fee D FWGP Minor technical modification $500.00

D FWGP25 Minor Channel I Stream Cleaning $1,000.00 D FWGP Maior technical modification $500.00

D FWGP26 Redevelop Previously Disturbed $1,000.00 Site

D Individual Permit Administrative No Fee No Fee Modification

D FWGP27 Application of herbicide in wetlands $1,000.00 D Individual Permit Minor Technical $500.00 Modification

0 Individual Permit Major Technical 0.30 x __ original fee Modification /Minimum $500\

Hiahlands Fee Amount Fee Paid D TAW Administrative Modification No Fee No Fee

D Pre-ann/ication Meetino $500.00 D TAW Minor Technical Modification $500.00

0 Resource Area Determination $500.00 Presence/Absence

0 T AW Major Technical Modification 0.30 x __ original fee <Minimum $5001

0 Resource Area Determination!: one acre $500.00 D FWGP Extension $500 x __ #of items to be extended

D Resource Area Determination > one acre $750 + ($100 x __ #of acres· of

D Individual PermiUOpen Water Permit 0.30 x __ original fee Extension (Minimum $500)

the sitel

D Resource Area Determinat'lon Extension 0.25 x __ original fee !Minimum $5001

D TAW Extension $500 x ___#of items to be extended

D HPAAGP 1/ Habitat Creation/Enhance No Fee No Fee 0 Freshwater Wetlands Exemntion $500.00

D HPAAGP 2 Bank Stabilization $500.00 0 T AW Exemotion $500.00

D Preservation Area Annroval IPAAl D Permit Enuivalencv/CERCLA No Fee No Fee

D PAA with Waiver ISMCifv tvoe below\

Waiver Tvoe:

D HPAA Extension $1,000 Page4

APPLICATION(S) FOR: Please check each permit/authorization that you are applying for and fill in the calculated fee (for each) in the "Fee Paid" column

Flood Hazard Area General Fee Amount Fee Paid Additional Flood Hazard Area Fee Amount Fee Paid Permits Authorizations

D FHAGP1 Channel Clean w/o Sediment Removal No Fee 0 FHA Hardship Exception ReQuest $4,000

0 FHAGP1 Channel Clean w/Sediment Removal No Fee D FHA GP Administrative Modification No Fee

No Fee

D FHAGP2 Mosquito Control $1,000.00 0 FHA GP Minor technical modification $500x __ #of

proejct elements to be revised

0 FHAGP3 Scour Protection Bridges/Culverts $1,000.00 0 FHA GP Major technical modification 0.30 x __ original fee

(Minimum $500)

0 FHAGP4 Creation/Restoration/Enhancement No Fee of Habitat and Water Quality Values and

D FHA Individual Permit Administrative No Fee No Fee Modification

Functions

D FHAGP5 Reconstruction and/or Elevation of No Fee Building in a Floodway

D FHA Individual Permit Minor Technical $500x __ #of Modification proejct elements to be

revised 0 FHAGP6 Construction of One SFH/Duplex and

$1,000.00 Drivewav 0 FHA Individual Permit Major Technical 0.30 x __ original fee

Modification (Minimum $5001 D FHAGP7 Relocation of Manmade Roadside

$1,000.00 Ditches for Public Roadway Improvements 0 FHA Verification Administrative No Fee No Fee Modification

0 FHAGPS Placement of Storage Tanks $1,000.00 0 FHA Verification Minor Technical $500 x __JI of

Modification proejct elements to be revised

0 FHAGP9 Construction/Reconstruction of $1,000.00 Bride/Culvert Across Water < 50 Acres

0 FHA Verification Major Technical 0.30 x __ original fee Modification (Minimum $500)

D FHAGP10 Construction/Reconstruction of $1,000.00 Bride/Culvert Across Water> 50 Acres

0 FHA GP Extension $240

0 FHAGP11 Stormwater Outfall Along Regulated $1,000.00 Water <50 Acres

0 FHA Individual Permit Extension 0.25 x __ original fee

D FHAGP12 Construction of Footbridges $1,000.00 0 FHA Verification Extension of Methods 1, $240

2 3 5 or Rinarian Zone Onlv 0 FHAGP13 Construction of Trails and $1,000.00 Boardwalks

0 FHA Verification Extension of Methods 4 0.25 x __ original fee or6

D FHAGP14 Application of herbicide in riparian $1,000.00 zone

0 FHA Individual Permit No Fee No Fee Eauivalencv/CERCLA

D FHA GP Administrative Modification No Fee No Fee

Flood Hazard Area Fee Amount Fee Paid Individual Permits

0 FHA - IP SFH and/or Accessory Structures $2,000 Stormwater Review Fee Fee Amount Fee Paid (Maximum Fee= $20,000) (Round UP to the nearest

whole number\

0 Individual Permit (Fee is calculated by adding $3,000 Base Fee o Stormwater Review ( Fee is calculated by $3,000 Base Fee

the base fee to the soecific elements belowl addina the base fee to the soec ific elements below\ FHA - IP Utility' +($1,000x __ # Review of Groundwater Calculations + $250 x__JI acres

of water crossings) disturbed --rnA·--1'Psarikictiiifinei(NCicaiciiia1iciri _______ +$1,000 --R;v;;;;.;eiiRunoircili-ari1it\.-caicuiaii0iis ___ + $250 x __ # acres _ .l'l..e_vJ~!YJ.~ _________________________________

FHA - IP Bank/Channel (With Calculation + ($4,000 + ($400 disturbed

--R0v;0;.;ei1waiiiiatia~1;c-aicliiatio~;;----- + $250 x __ # acres Review)• x_per100 impervious surface

linear ft.ll --------------------------------------------FHA - IP Bridge/CulverVFootbridge/Low Dam + ($1,000 x __ # Total Stormwater Review Fee

__ [~9.i:t?!~~l?Ji9Jl~'i!!YJL ___________________ of structures! FHA - IP Bridge/CulverVFootbridgellow Dam + ($4,000 x --#

__ [it/J!'1~~'9.!lJ~~9D.'3!lY!~'!l1_' __________________ of structures) FHA - Review of Flood Storage +$4,000

__ 9J~gL~e_~_nJ_(!l,!l_!J@_Q?!~~i?1Lo_l!i!.' ___________ Applicability Determination Fee Amount Fee Paid

Total IP Review Fee 0 Coastal Applicability Determination No Fee No Fee

0 Flood Hazard Applicability Determination No Fee No Fee

0 Highlands Jurisdictional Determination No Fee No Fee

Flood Hazard Area Verifications Fee Amount Fee Paid 0 Executive Order 215 No Fee No Fee

0 Verification-Delineation of Riparian Zone Only $1,000

0 Verification-Method 1 (DEP Delineation) • $1,000

D Verification-Method 2 (FEMA Tidal Method) • $1,000

D Verification-Method 3 (FEMA Fluvial Method)• $1,000

I TOTAL FEE:

CHECK NUMBER:

0 Verification-Method 4 (FEMA Hydraulic $4,000 + ($400 x Method) _per100

linear feetl

D Verification-Method 5 (Approximation Method) $1,000

D Verification-Method 6 (Calculation Method) $4,00lt($400 x ___per100 linearfeetl

'Fee not applicable to (1) SFH 'Fee not applicable to (1) SFH

Page 5

APPLICANT NAME: Delaware River Partners LLC FILE# (if known):

APPLICATION FORM -APPENDIX I

Section 1: Please provide the following information for the overall project site. All area measurements shall be recorded in acres to the nearest thousandth (0.001 acres).

PROPOSED: PRESERVED UNDISTURBED DISTURBED

RIPARIAN ZONE 0 0 0

CZMRA FORESTED 0 0 0 (CZMRA IP- Only)

E & THABITAT 0 0 0 Endangered and/or Threatened

FRESHWATER WETLANDS 0 0 0

Section 2: Please provide the following information for each permit/authorization requested pursuant to the Freshwater Wetlands Protection Act. All area measurements shall be recorded in acres to the nearest thousandth (0.001 acres). Use additional sheets if necessary

PERMIT TYPE

WETLAND TYPE Emergent, Forest, Shrub, Etc.

RESOURCE CLASSIFICATION Ordinary, Intermediate, Exceptional, EPA, Etc.

PROPOSED DISTURBANCE: WETLANDS TRANSITION AREA

FILLED

EXCAVATED ------t'llOT APPLICABLE

CLEARED

TEMPORARY DISTURBANCE --------

PERMIT

TYPE

WETLAND TYPE Emergent, Forest, Shrub, Etc.

PROPOSED DISTURBANCE: WETLANDS

FILLED

EXCAVATED

CLEARED

TEMPORARY DISTURBANCE

RESOURCE

CLASSIFICATION Ordinary, Intermediate,

-------- Exceptional, EPA, Etc.

TRANSITION AREA

NOT APPLICABLE

--------

Page 6

ATTACHMENT A

PREVIOUS DLUR NUMBERS FOR 200 N. REPAUNO AVENUE

-

LUR File No. Activity Number Description -0807-07-0002.1 FWW 070001 Freshwater Wetlands Letter of

FWW 120001 Interpretation .

0807-06-0002.1 FWW 130001 Freshwater Wetlands General Permit 4

0807-08-0001.1 FWW 080001 Coastal General Permit 15 CAF 080001 Freshwater Wetlands General Permit 4

0807-08-0001.3 FWW 090001 Coastal General Permit 27 CAF 090001 Freshwater Wetlands General Permit 12

0807-08-0001.3 FWW 140001 Coastal General Permit 15 CAF 080001 Freshwater Wetlands General Permit 14 CAF 140002

0807-02-0006.1 WFD 020001 Freshwater Wetlands General Permit 5 WFD 030001 Waterfront Development Individual Permit FWW 030001 Flood Hazard Act Stream Encroachment FWW 030002 FHA 030001

0807-06-0002.1 CZM160003 Coastal General Permit 11 Freshwater Wetlands General Permit 4

0807-16-0001.1 FWW160001 Freshwater Wetlands Letter of Interpretation

0807-06-0002 .1 CZM 160004 Coastal General Permit 23 CZM160005

FHA 160003 FHA Verification FHA 160004 FHA Individual Permit

0807-06-0002.1 FWW 160003 Freshwater Wetlands General Permit 7 FWW 160004 Freshwater Wetlands General Permit 106 FWW 160005 Freshwater Wetlands General Permit 11

FWW 160006 Transition Area TAW Averaging Plan

0807-16-0001.3 CZM 170001 Coastal General Permit for Avian Nesting Structures

WFD160001 Waterfront Development Individual Permit WFD160002 (In-water, Upland)

0807-16-0001.2 WFD170001 Flood Hazard Area Individual Permit FHA160001 Flood Hazard Area Verification FHA160002 Coastal Wetlands Individual Permit

CSW160001

0807-16-0001.2 FWW160001 Freshwater Wetlands Individual Permit

FWW160002 Transition Area Waiver (Special Activity)

0807-16-0001.1 TDI160001 Tidelands License (Dredging)

0807-16-0001.1 TDI170001 Tidelands License (Fixed Structure)


ITEM 3

PROOF OF PUBLIC NOTICE REQUIREMENTS


COPY OF NEWSPAPER PUBLIC NOTICE

PUBLIC NOTICE

Dated: Wednesday, February 20, 2019

TAKE NOTICE that an application for an individual water-front development permit will be submitted to the New JerseyDepartment of Environmental Protection, Division of Land UseRegulation for the development described below:

APPLICANT: Delaware River Partners LLCPROJECT NAME: DRP Gibbstown Logistics CenterPROJECT DESCRIPTION: Development of a second dock

at previously permitted deep-water marine terminal.PROJECT STREET ADDRESS: 200 North Repauno AvenueBLOCK: 8 LOTS: 1, 2, 3, 4, 4.01, 4.01 and 4.02MUNICIPALITY: Greenwich TownshipCOUNTY: Gloucester

A complete copy of the permit application package isavailable to be reviewed at either the Greenwich Townshipmunicipal clerk’s office or by appointment at the Departmen-t’s Trenton Office. The Department of Environmental Protec-tion welcomes comments and any information that you mayprovide concerning the proposed development and site.Please submit your written comments within 15 calendar daysof the date of this notice to:

New Jersey Department of Environmental ProtectionDivision of Land Use RegulationP.O. Box 420, Code 501-02A501 East State StreetTrenton, New Jersey 08625Attn: Greenwich Township Bureau Chief

The applicant’s name and mailing address are:Delaware River Partners LLC200 N. Repauno AvenueGibbstown, New Jersey 08027

Cost $64.36(9035494) 1t 2/20/19


LETTER TO MUNICIPAL CLERK AND EVIDENCE OF MAILING

G IBBONS I

VIA FEDERAL EXPRESS

Municipal Clerk Greenwich Township 420 Washington Street Gibbstown, NJ 08027

February 26, 2019

Re: Application submitted by:

Dear Clerk:

Delaware River Partners, LLC Regarding property at: 200 No. Repauno A venue, Block 8, Lot 4 Greenwich Township, Gloucester County

DAVID J. MILLER Associate

Gibbons P.C. One Gateway Center Newark, New Jersey 07102-5310 Direct (973) 596-4603 Fax: (973) 639-6286 dmil [email protected]

This letter is to provide you with legal notice that my client, Delaware River Partners LLC ("DRP"), is submitting the enclosed application to the New Jersey Department of Environmental Protection ("NJDEP"), Division of Land Use Management under the Coastal Zone Management rules, NJ.AC. 7:7.

DRP is applying for a Waterfront Development Permit for the development of a second dock ("Dock 2") at the DRP Gibbstown Logistics Center, which is designed to accommodate transloading operations for liquid products. Dock 2 would provide navigational access, mooring, and loading equipment for two vessels up to 173,400 cubic meters in capacity and would be located west (downriver) of the multi-purpose dock that is under construction. The addition of Dock 2 will allow transloading operations to be separated from the operations at the multi-purpose dock.

In accordance with NJ.AC. 7:7-24.3(a), DRP is required to file a complete copy of the application with your office, which should remain available for inspection by the public.

If you have any comments or questions regarding this application, please write to the Department at the following address and include a copy of the first page of the attached application form:

Newark New York Trenton Philadelphia Wilmington gibbonslaw.com

GIBBONS P.C.

Delaware River Partners, LLC 200 No. Repauno Avenue, Greenwich Twp. February 26, 2019 Page 2

New Jersey Department of Environmental Protection Division of Land Use Regulation

501 East State Street, P.O. Box 420 Mail Code 501-02A

Trenton, New Jersey 08625-0420 Attn: Gloucester County Supervisor

If you have any questions regarding this application, please do not hesitate to contact me at (973) 596-4603 or [email protected].

Sincerely,

A(;d :.:e~~~ Attorney for Applicant

Enclosures

cc: New Jersey Department of Environmental Protection

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FROM

Ramboll US CorporationLaura George

1760 Market StreetSuite 1000

Philadelphia, PA US 19103215 523-5603

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Greenwich TownshipMunicipal Clerk

420 Washington StreetGIBBSTOWN, NJ US 08027

215 523-5603

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TEMPLATE NOTICE LETTER TO PROPERTY OWNERS WITHIN 200’ OF SITE AND NOTICE LETTERS TO TOWNSHIP AND COUNTY CONTACTS

Notice to Property Owners within 200 Feet

GIBBONS SAMPLE NOTICE TO PROPERTY OWNERS WITHIN 200 FEET OF APPLICANT'S SITE AND GOVERNMENT ENTITIES

February 21, 2019

VIA REGULAR & CERTIFIED MAIL (R.R.R.)

ADDRESS

RE: Application submitted by: Delaware River Partners LLC Regarding property at: 200 N. Repauno Avenue Block 8, Lot 4 Greenwich Township, Gloucester County

Dear Interested Party:

DAVID J. MILLER Associate

Gibbons P.C. One Gateway Center Newall<, New Jersey 07102-5310 Direct: (973) 596-4603 Fax: (973) 639.0286 [email protected]

This letter is to provide you with legal notification that our client, Delaware River Partners LLC ("DRP"), will be submitting an application for an individual waterfront development permit to the New Jersey Department of Environmental Protection, Division of Land Use Regulation (the "Department" or "NJDEP") under the Coastal Zone Management rules, N.J.A.C. 7:7, for the development called the "Gibbstown Logistics Center" and shown on the enclosed plan. A brief description of the proposed development follows:

The DRP Gibbstown Logistics Center will be a multi-use, deep-water seaport and international logistics center at the site of the former DuPont Repauno Works in Gibbstown, New Jersey. This marine terminal is planned to include uses such as an automobile import and processing facility, bulk cargo handling, a bulk liquids storage and handling facility, logistics and associated warehousing. In addition to the multipurpose berth currently under development pursuant to previously issued permits, a second dock designed to accommodate transloading operations for liquid products ("Dock 2 ") is proposed Dock 2 would provide navigational access, mooring, and loading equipment for two vessels up to 173,400 cubic meters in capacity and would be located west (downriver) of the multi-purpose dock that is under construction. The addition of Dock 2 will allow transloading operations to be separated from the operations at the multi-purpose dock.

The complete permit application package can be reviewed at either the Greenwich Township Clerk's office or by appointment at the NJDEP's Trenton office. You can call the NJDEP at (609) 777-0454 to make an appointment to see DRP's application at NJDEP offices in Trenton during normal business hours.

'• gibbonslaw.com

GIBBONS P.C.

February 21 , 2019 Page2

The NJDEP welcomes comments and any information that you may provide concerning the proposed development and site. If you wish to comment on DRP's application, your comment should be submitted to the NJDEP in writing within fifteen (15) days of receiving this letter. The Department shall consider all written comments submitted within this time. The Department may, in its discretion, consider comments submitted after this date. Comments cannot be accepted by telephone.

Please submit any comments you may have in writing. along with a copy ofthis letter, to:

New Jersey Department of Environmental Protection Division of Land Use Regulation

501 East State Street, P .0. Box 420 Mail Code 50 l-02A

Trenton, New Jersey 08625-0420 Attn: Greenwich Township Supervisor

If you have questions about DRP's application, you can contact DRP or its agent, at the addresses below.

Sincerely,

David J. Miller Attorney for Applicant: Delaware River Partners LLC 200 N. Repauno A venue Gibbstown, NJ 08027

Applicant's Agent: Laura George Ramboll Environ US Corporation 1760 Market Street, Suite 1000 Philadelphia, PA 19103 Tel.: (215) 523-5603

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Notice Letters to Greenwich Township Construction Official; Greenwich Township Environmental Commission;

Greenwich Township Planning Board; Gloucester County Planning Board; and Gloucester County Soil Conservation District

DAVID J. MILLER Associate Gibbons P.C. One Gateway Center Newark, New Jersey 07102-5310 Direct: (973) 596-4603 Fax: (973) 639-6286 [email protected]


February 21, 2019


Robert DeAngelo

Construction Code Official, Greenwich Township

403 W Broad Street

Gibbstown, NJ 08027

RE: Application submitted by:


Regarding property at:

200 N. Repauno Avenue

Block 8, Lot 4

Greenwich Township, Gloucester County


This letter is to provide you with legal notification that our client, Delaware River

Partners LLC (“DRP”), will be submitting an application for an individual waterfront

development permit to the New Jersey Department of Environmental Protection, Division

of Land Use Regulation (the “Department” or “NJDEP”) under the Coastal Zone

Management rules, N.J.A.C. 7:7, for the development called the “Gibbstown Logistics

Center” and shown on the enclosed plan. A brief description of the proposed development

follows:

The DRP Gibbstown Logistics Center will be a multi-use, deep-water seaport and

international logistics center at the site of the former DuPont Repauno Works in

Gibbstown, New Jersey. This marine terminal is planned to include uses such as an

automobile import and processing facility, bulk cargo handling, a bulk liquids storage and

handling facility, logistics and associated warehousing. In addition to the multi-purpose

berth currently under development pursuant to previously issued permits, a second dock

designed to accommodate transloading operations for liquid products (“Dock 2”) is

proposed. Dock 2 would provide navigational access, mooring, and loading equipment for

two vessels up to 173,400 cubic meters in capacity and would be located west (downriver)

of the multi-purpose dock that is under construction. The addition of Dock 2 will allow

transloading operations to be separated from the operations at the multi-purpose dock.

The complete permit application package can be reviewed at either the Greenwich

Township Clerk’s office or by appointment at the NJDEP’s Trenton office. You can call

the NJDEP at (609) 777-0454 to make an appointment to see DRP’s application at NJDEP

offices in Trenton during normal business hours.

February 21, 2019

Page 2

The NJDEP welcomes comments and any information that you may provide

concerning the proposed development and site. If you wish to comment on DRP’s

application, your comment should be submitted to the NJDEP in writing within fifteen (15)

days of receiving this letter. The Department shall consider all written comments submitted

within this time. The Department may, in its discretion, consider comments submitted after

this date. Comments cannot be accepted by telephone.

Please submit any comments you may have in writing, along with a copy of this

letter, to:

New Jersey Department of Environmental Protection

Division of Land Use Regulation

501 East State Street, P.O. Box 420

Mail Code 501-02A

Trenton, New Jersey 08625-0420

Attn: Greenwich Township Supervisor

If you have questions about DRP’s application, you can contact DRP or its agent,

at the addresses below.

Sincerely,

David J. Miller

Attorney for Applicant:



Gibbstown, NJ 08027

Applicant’s Agent:

Laura George

Ramboll Environ US Corporation

1760 Market Street, Suite 1000

Philadelphia, PA 19103

Tel.: (215) 523-5603

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420 WASHINGTON STREET

GIBBSTOWN, NJ 08027





Block 8, Lot 4









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February 21, 2019

Page 2








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David J. Miller




Gibbstown, NJ 08027


Laura George




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February 21, 2019


Greenwich Township Planning and Zoning Board

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February 21, 2019

Page 2








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David J. Miller




Gibbstown, NJ 08027


Laura George




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GLOUCESTER COUNTY PLANNING BOARD

ATTN: CLERK

1200 N. DELSEA DRIVE

CLAYTON, NJ 08312





Block 8, Lot 4









follows:
















February 21, 2019

Page 2








letter, to:




Mail Code 501-02A





Sincerely,

David J. Miller




Gibbstown, NJ 08027


Laura George




Tel.: (215) 523-5603

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February 21, 2019


GLOUCESTER COUNTY

SOIL CONSERVATION DISTRICT

14 PARKE PLACE BLVD.

SUITE-B

SEWELL, NJ 08080





Block 8, Lot 4









follows:
















February 21, 2019

Page 2








letter, to:




Mail Code 501-02A





Sincerely,

David J. Miller




Gibbstown, NJ 08027


Laura George




Tel.: (215) 523-5603

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:••

Prepared for: Delaware River Partners LLC Gibbstown, New Jersey

Prepared By: Ramboll US Corporation Philadelphia, Pennsylvania

Date

February 2019 1690000609-001

COMPLIANCE STATEMENT IN SUPPORT OF WATERFRONT DEVELOPMENT INDIVIDUAL PERMIT APPLICATION DOCK 2 DRP GIBBSTOWN LOGISTICS CENTER GIBBSTOWN, GLOUCESTER COUNTY, NEW JERSEY

COMPLIANCE STATEMENT IN SUPPORT OF WFD INDIVIDUAL PERMIT APPLICATION DOCK 2 - DRP GIBBSTOWN LOGISTICS CENTER Page i

Contents Ramboll

CONTENTS

1. INTRODUCTION 1 General Project Description 1 Regulatory Jurisdiction 1 Purpose 1 Other Permits and Approvals 1

2. SITE DESCRIPTION 3 Site Location 3 Site History 3

3. SITE CHARACTERISTICS 4 Site Location 4 Regulated Wetlands and State Open Waters 4 Shoreline Characteristics 4 Stream Conditions 4 Submerged Aquatic Vegetation 4 Threatened and Endangered Species 5 Dredged Material Characteristics 5

4. PROJECT DESCRIPTION 7 Berth Construction 7 Dredging 9 Transportation Improvements 10 Vessel Traffic 10

5. PROJECT NEED 11 Statement of Water-Dependence 11

6. COMPLIANCE WITH COASTAL ZONE MANAGEMENT RULES 12 Compliance with Coastal Zone Management Rules on Special Areas 12 Compliance with Coastal Zone Management Rules on General Water Areas (N.J.A.C.

7:7-12) 22 Compliance with CZM Rules on Location (N.J.A.C. 7:7-14) 25 Compliance with CZM Use Rules (N.J.A.C. 7:7-15) 26 Compliance with CZM Resource Rules (N.J.A.C. 7:7- 16) 28

7. COMPLIANCE WITH FHA RULES 32 Regulated Activities in a Channel (N.J.A.C. 7:13-11.1) 32 Regulated Activities in a Riparian Zone (N.J.A.C. 7:13-11.2) 32 Requirements for a Regulated Activity in Floodway (N.J.A.C. 7:13-11.3) 33

8. SUMMARY AND CONCLUSIONS 34

COMPLIANCE STATEMENT IN SUPPORT OF WFD INDIVIDUAL PERMIT APPLICATION DOCK 2 - DRP GIBBSTOWN LOGISTICS CENTER Page ii

Contents Ramboll

TABLES

Table 1: Coastal Zone Management Rules Applicability Review

FIGURES

Figure 1: Site Location Map

Figure 3: Site Street Map

Figure 3: Municipal Tax Map

APPENDICES

Appendix A: Site Photographs

Appendix B: Natural Heritage Database Search and IPAC Search

Appendix C: Submerged Aquatic Vegetation Survey Report

Appendix D: Atlantic and Shortnose Sturgeon Impact Assessment

Appendix E: Alternatives Analysis

Appendix F: Phase I Underwater Archaeological Investigation Report

Appendix G: Phase IA Historical and Archaeological Survey

Appendix H: Property Deed and Proof of Tidelands Ownership

Appendix I: Tidelands License Applications

COMPLIANCE STATEMENT IN SUPPORT OF WFD INDIVIDUAL PERMIT APPLICATION DOCK 2 - DRP GIBBSTOWN LOGISTICS CENTER Page iii

Acronyms and Abbreviations Ramboll

ACRONYMS AND ABBREVIATIONS

BMP: Best Management Practices

CZM: Coastal Zone Management

DRP: Delaware River Partners LLC

EFH: Essential Fish Habitat

FHA: Flood Hazard Area

FHACA: Flood Hazard Area Control Act

FWPA: Freshwater Wetlands Protection Act

GLC: DRP Gibbstown Logistics Center

MHW: Mean High Water

MLW: Mean Lower Low Water

NAVD88: North American Vertical Datum of 1988

NJDEP: New Jersey Department of Environmental Protection

NMFS: National Marine Fisheries Service

NOAA: National Oceanic and Atmospheric Administration

PCB: Polychlorinated Biphenyls

SAV: Submerged Aquatic Vegetation

SCD: Soil Conservation District

SSAP: Sediment Sampling and Analysis

USACE: U.S. Army Corps of Engineers

USFWS U.S. Fish and Wildlife Service

COMPLIANCE STATEMENT IN SUPPORT OF WFD INDIVIDUAL PERMIT APPLICATION DOCK 2 - DRP GIBBSTOWN LOGISTICS CENTER Page 1

Introduction Ramboll

1. INTRODUCTION

On behalf of the applicant, Delaware River Partners LLC (“DRP”), Ramboll US Corporation has prepared this Compliance Statement to support an application for a Waterfront Development individual permit to construct a second dock (“Dock 2” or “Project”) at the DRP Gibbstown Logistics Center (“Site” or “GLC”). The Site is located along the Delaware River at 200 North Repauno Avenue in Gibbstown, Gloucester County, New Jersey. In 2017, the New Jersey Department of Environmental Protection (“NJDEP”) issued a Waterfront Development, Flood Hazard Area, Coastal Wetlands and Freshwater Wetlands Permit for the construction of a multi-purpose dock (“Dock 1”) and supporting marine terminal at the Site. Construction of Dock 2 would provide two berths dedicated to liquid bulk cargoes and, thus, would allow better utilization of the single berth at Dock 1, based on current market demand and projected future demand.

General Project Description The GLC was conceived because of opportunities within the region for the development of a private port facility. The proposed Dock 2 supports the transloading operations at the GLC, which are a critical component of the entire facility. As a result of its unique features, the Site is ripe for redevelopment, which will allow a once productive industrial site to rise again as an economic driver for the community, state, and region. Because of the Site’s location, size and characteristics, it is highly suitable for additional deep-water berths supported by an industrial logistics center.

The purpose of the Project is to develop a deep-water facility for the export of bulk liquid products. Although the initial development is focused on the export of liquid energy commodities, the proposed dock and supporting infrastructure will be designed to handle other liquid bulk commodities should such opportunities arise in the future. The Project is described in more detail in Section 4.

Regulatory Jurisdiction The Project involves construction within the waterfront development area (in water and upland) of the Delaware River. Therefore, the Project is regulated under the Coastal Zone Management Rules (CZM, N.J.A.C. 7:7) and an individual Waterfront Development Permit is required. Because the Project is located within the Delaware River, it is also within the jurisdiction of the NJDEP Flood Hazard Area Control Act Rules (FHACA Rules, N.J.A.C. 7:13). However, because the Project is expected to be authorized by a coastal permit (i.e., the previously mentioned waterfront development permit), a separate permit under the FHACA Rules is not required (see N.J.A.C. 7:13-2.1(a)). Applicable FHACA requirements are addressed in this Compliance Statement. No coastal wetlands or freshwater wetlands are affected by the Project.

Purpose The purpose of this statement is to demonstrate compliance of the proposed Project with the CZM Rules and applicable FHACA Rules.

Other Permits and Approvals In addition to the New Jersey Waterfront Development Permit, the following permits or approvals have been or will be obtained to construct Dock 2:

• NJ State Individual Water Quality Certificate

• NJ Tidelands License



• DRBC Project Approval

• USACE Jurisdictional Determination, issued July 5, 2016

• USACE Section 404/10 Individual Permit

• DOE Part 590 Approval

• USCG Part 127 Letter of Recommendation

• Gloucester County Soil Conservation District Approval

• Gloucester County Planning Board Approval

• Greenwich Township Planning Board Approval


Site Description Ramboll

2. SITE DESCRIPTION

Site Location The Site is located at the DRP Gibbstown Logistics Center on the Delaware River at approximately River Mile 86, and the Site’s physical address is 200 North Repauno Avenue, Gibbstown, Greenwich Township, Gloucester County, New Jersey. The development of the DRP Gibbstown Logistics Center occupies approximately 371 acres included in Block 8, Lots 1, 2, 3, 4 and 4.02 as shown on Figure 3. The Site is a portion of the 1,630-acre property formerly known as the DuPont Repauno Works Site (“Property”) and is bordered by the Delaware River to the north, undeveloped land to the east and west, and an industrial facility to the south. The proposed Dock 2 will be located in the Delaware River on the northwestern portion of the Site adjacent to Thompson’s Point (the “Project Area”). A United States Geological Survey quad map and a street map showing the Project Area are provided as Figure 1 and Figure 2, respectively. A photograph log depicting the Project Area is provided in Appendix A.

Site History The Property was first operated as a dairy farm before it was purchased by the E.I. du Pont de Nemours and Company (“DuPont”) in 1880. The Property has been used for industrial purposes, including the manufacture of chemicals and explosives, for more than 100 years. Atlantic City Electric operated a power plant in the vicinity of Thompson’s Point from 1951 to 1986. The northern portion of the Site was historically filled to create uplands along the Delaware River and was extensively developed prior to 1980. All manufacturing operations at the Site were discontinued by December 2006. Chemours Co. LLC (“Chemours”) became the owner of record of the Property in April 2015. DRP acquired the Property on June 30, 2016. Chemours is currently implementing a long-term environmental remediation program in certain areas at the Site (under NJDEP oversight), which is compatible with the redevelopment currently underway.

In 2017, NJDEP issued a Waterfront Development, Flood Hazard Area, Coastal Wetlands and Freshwater Wetlands Permit to DRP for the construction of Dock 1 and an associated marine terminal.1 Construction of Dock 1 was substantially completed in December 2018 and the adjacent landside development of the marine terminal facilities is ongoing.

1 NJDEP Permit Nos. 0807-16-0001.2, WFD160001, WFD160002, FHA160001, FHA160002, CSW160001.


Site Characteristics Ramboll

3. SITE CHARACTERISTICS

Site Location The Project Area is located on the Delaware River in the vicinity of Thompson’s Point at approximately River Mile 86. A double barge berth was constructed in the Project Area to transfer rail cars to barges in approximately 1916 (Hunter Resources 2016). Based on historic aerial photographs, it appears that use of the berth was discontinued sometime in the 1960s. Timber pilings and other remnants of the former structure remain (see Appendix A).

Regulated Wetlands and State Open Waters The Project Area is located below MHW of the Delaware River and therefore, no wetlands are present. As defined by the New Jersey Surface Water Quality Standards at N.J.A.C. 7:9B, the Water Quality Classification of the Delaware River in the vicinity of the Site is category 2 freshwater, non-trout waters, saline waters [FW2-NT/SE2].

Shoreline Characteristics The Project will tie into landside infrastructure at the GLC that is currently under development. The shoreline in this area is characterized by naturally deposited sands, which terminates into a steep slope of Rip-Rap shoreline armoring. At the top of the Rip-Rap slope is “Dike Road”, which extends west to east along the northern boundary of the GLC. There is a thin band of vegetation present between the road and the Rip-Rap, which is largely comprised of invasive species and species commonly found along roadsides and in waste areas.

Stream Conditions The Delaware River is approximately 6,400 feet wide at River Mile 86. The Delaware River Federal Navigation Channel (“Federal Navigation Channel”) is located approximately 650 feet from the proposed berths at Dock 2 and is approximately 800 feet wide and 45 feet deep2 at this location. Water depths within the Project Area range from under three feet near the shore to over 40 feet near the Federal Navigation Channel. Much of the Project Area exceeds 35 feet in depth.

Dominant water flow velocities are tidally driven and can exceed 2.5 to 3 knots at ebb tide and can approach two knots at flood tide. The monthly average tidal range of the river in the vicinity of the Project Area is 5.6 feet (NOAA 2018).

Submerged Aquatic Vegetation On September 28, 2018, scientists from Matrix New World Engineering, Inc. (“Matrix”) conducted a visual survey of submerged aquatic vegetation (“SAV”) to physically identify and locate the approximate extents of SAV within the Project Area. Visual surveys were conducted by scientific divers along the shoreline water areas no greater than 10 feet deep at the time of the survey. Where SAV was found to be present, the footprint of the SAV bed limits were identified and staked in the field. The field limits were then field located using global positioning system (“DGPS”) with sub-meter accuracy.

The visual survey confirmed the presence of an SAV Bed (“Bed C”) within the Project Area. Bed C is 164,653 square feet and consists of a single-species, Vallisneria americana (American eelgrass). The

2 Water depth relative to MLLW.



spatial coverage and shoot density of SAV within Bed C was observed to be similar to other recently observed beds approximately one mile upstream. The limits of observed SAV beds are depicted on Project Drawings (see Drawings 4, 5, 9, 10, 11, and 13). A copy of the Visual Survey Report is provided as Appendix C.

In addition, a SAV mitigation site is located 188 feet upstream of the eastern limit of SAV Bed C. In September 2018, a test plot was planted with turions collected from a robust SAV bed located east of the recently constructed Dock 1. The mitigation site is located 85 feet from the proposed trestle that would extend offshore to the new berths.

Threatened and Endangered Species A review of the New Jersey Natural Heritage Database search results (see Appendix B) and New Jersey Landscape Project indicates that the bald eagle (Haliaeetus leucocephalus) and osprey (Pandion haliaetus, state threatened) may use habitat within the Project Area for foraging and/or nesting. Specifically, an osprey nest is present on pilings from the former barge berth within the Project Area. Nesting bald eagle are also present west of the former barge berth on Mond’s Island; however, no eagle nests are located within 4,000 feet of the Project Area. The Natural Heritage Database search results did not identify Rare Plant Species and Ecological Communities or Natural Heritage Priority Sites in the Project Area or in the immediate vicinity.

The U.S. Fish and Wildlife Service (“USFWS”) Information for Planning and Conservation (“IPaC”) tool identified two threatened species with the potential to be present within the Project Area: red knot (Calidris canutus rufa) and bog turtle (Clemmys muhlenbergii) (Appendix B). Red knot is a migratory bird species that generally uses beaches and mudflats along the Atlantic Coast of New Jersey for stopover areas and is not expected to be present in the Project Area. Red knot in New Jersey are more frequently encountered around the Delaware Bay or along the Atlantic coast than in the highly urbanized area of the Delaware River where the Project Area is located and could readily avoid disturbance within the Project Area in favor of adjacent habitat along the Delaware River. Red knot is not expected to be adversely impacted by the Project. The bog turtle is an endangered species in New Jersey and both occurrences and habitat are mapped by the Landscape Project; no bog turtle occurrences were identified within one mile of the Project Area and it is not expected to be present within the Delaware River.

In addition, the Project Area is mapped as a migration corridor for the shortnose sturgeon (Acipenser brevirostrum), federally and state endangered) and Atlantic sturgeon (Acipenser oxyrinchus, federally and state endangered). The National Marine Fisheries Service (“NMFS”) has designated the Delaware River as critical habitat for Atlantic sturgeon. A detailed analysis of the life characteristics, potential impacts, and affected habitat for sturgeon is provided in Appendix D, Sturgeon Impact Assessment Report.

Dredged Material Characteristics Dredging is planned as part of the proposed redevelopment of the Site and is necessary to allow cargo vessels access to Dock 2, which will be located in the vicinity of a pre-existing, deteriorated wharf. The target dredging depth is -43 feet Mean Lower Low Water (“MLLW”). The dredging volume and sediment characterization also accounts for an additional two feet for overdredging. To reach the target depth, approximately 665,000 cubic yards of sediments would need to be dredged over an area of approximately 45 acres (see Drawing 5).



To characterize sediments proposed to be dredged, a sediment sampling and analysis (“SSAP”) was implemented in January 2019. The SSAP was approved by NJDEP’s Office of Dredging and Sediment Technology (“ODST”) on December 24, 2018. Subsequent to the submittal of the SSAP, the design of the dock and berth were refined to reduce the dredging footprint and volume. The dredging footprint was reduced from 52 acres to 45 acres and the dredging volume (with overdredge) was reduced from approximately 964,000 cubic yards to approximately 665,000 cubic yards. With this reduction, 13 core locations were eliminated because they were outside of the dredging footprint. Several core locations within the dredging footprint were shifted and one location was added to optimize distribution of cores. The approved SSAP identified 64 core locations based on a frequency of one core per 15,000 cubic yards. The revised SSAP includes 50 core locations based on a frequency of one core per 14,000 cubic yards. From those cores, a total of 17 composite samples were prepared, with only the same stratum among cores composited together. These samples were analyzed for bulk sediment chemistry (metals, pesticides, semi-volatiles, and PCB Aroclors). A modified elutriate analysis was perform on these composites for bulk sediment chemistry. 50% of the composites were amended with 8% Portland cement and after 24-hours cure time were analyzed for bulk sediment chemistry as well as Synthetic Precipitation Leaching Procedure analysis.


Project Description Ramboll

4. PROJECT DESCRIPTION

The proposed Dock 2 project at GLC is described below. Existing structures within the limits of the proposed Dock 2 structures have not been identified; therefore, demolition of in-water structures is not expected to be required for construction of Dock 2.

Berth Construction The proposed new docking facility and loading platform is designed to accommodate two vessels end to end. It consists of two loading platforms, eight breasting dolphins, 11 mooring dolphins, walkways to provide dockworker access between platforms and dolphins. Access from the landside area to the Dock 2 marine facility will be provided by an approximate 32-foot wide trestle, that will accommodate a one-lane vehicular roadway with adjacent pedestrian access, parallel product piping, and mechanical and electrical support systems. The landing of the trestle is within the limits of previously permitted landside development. The structural footprint over the water is approximately 139,127 square feet.

Each loading platform will be constructed on sixty 30-inch diameter x 3/4-inch wall steel pipe piles (120 piles total).

The trestle will be supported by pile bents with a total of 210 24-inch diameter x 5/8-inch wall steel pipe piles over 50 bents (210 piles total). A 50-foot wide abutment will support the landing of the trestle above the mean high water line. A retaining wall will be constructed on either side of the abutment to provide additional structural support (total length 230 feet).

The typical mooring dolphins will be constructed on nine 48-inch diameter x one-inch wall steel pipe piles; shared mooring dolphins will be constructed on fifteen 48-inch diameter x one-inch wall steel pipe piles (105 total piles). The breasting dolphins will be constructed on nine 48-inch diameter x one-inch wall steel pipe piles (72 total piles).

Walkways between loading platforms, mooring dolphins, and breasting dolphins will be provided with four intermediate support systems. The foundation of each intermediate support consists of three 24-inch diameter x 5/8-inch wall steel pipe piles (12 piles total).

4.1.1 Equipment, Access, and Material Staging Construction of the docking facility, including dolphins, loading platforms, and the offshore portion of the trestle will be completed using a combination of land-based and marine-based methods, involving barge-mounted cranes and barge-based material delivery systems. Onshore structures, consisting of a pile-supported abutment and steel sheet pile retaining wall, will be constructed using land-based equipment, with land-based (truck) material deliveries.

Insufficient water depth exists to allow barge-based construction methods all the way to the shoreline; likewise, the structure extends too far from shore to consider land-based equipment. Hence, the trestle structure will be constructed by starting on the landside portion of the Project Area, using land- based equipment for the first pile bent, then building temporary falsework within the footprint of the trestle to create access for the second and third bent. Waterward of the third bent, shallow draft marine equipment will be used.

All steel piles are anticipated to be installed by impact hammer driving. It is expected that all steel pipe piles will be installed through the overlying strata (e.g., silts and sands) into the harder



underlying weathered rock layer. Steel sheet piling that will be used for earth retention systems at the abutment will likely be installed by vibratory hammer only; the sheets will be installed to a depth only to that required to achieve resistance to lateral load.

Construction of Dock 2 will require the installation of steel piles consisting of 24-inch, 30-inch, and 48-inch diameters. As previously outlined, most construction will occur using marine-based construction equipment, including barge-mounted cranes, barge-based pile driving rigs, and waterborne material deliveries. It is expected that environmental protection measures will be employed for all construction activities, including but not limited to:

• Providing in place sediment control devices, turbidity curtains, booms, tarpaulins, floats, staging, and other devices as necessary to prevent materials from entering the water and leaving the immediate vicinity of the Site;

• Providing effluent discharge control to prevent entry into the river for all materials (e.g., oils, fluids, concrete, wash water, and other impurities) used on the construction site;

• Minimizing manipulation of piling, pile spuds, and other potential bottom disturbing activities; and

• Deploying a “bubble curtain” as needed during water-based pile driving activities.

Following the completion of pile driving activities, construction of the dolphins, loading platforms, and trestle will commence. Given the scope of the Project, it is likely that simultaneous construction activities will occur, involving pile driving, substructure, and superstructure construction in a sequential manner.

Substructure elements (trestle and loading platform bent caps, dolphin pile caps) are expected to consist of reinforced cast-in-place concrete, press-stressed, pre-cast concrete, or a combination of both. All pipe piling is expected to receive a reinforced cast-in-place concrete plug. Concrete will be delivered to the structure via trucks, piping, or barge.

The superstructure of the loading platforms are anticipated to consist of precast, prestressed concrete deck panels with an integral cast-in-place concrete deck surface. The trestle superstructure will be composed of precast, prestressed concrete elements such as AASHTO girders, NeXt Beams, or voided slabs. The deck wearing surface will consist of an integral cast-in-place concrete slab.

Once the primary structures are erected, the completion of construction will occur with a combination of structure-based and water-based equipment. Since the trestle geometry will exclude access of larger equipment and material deliveries, larger components (e.g., walkways, product piping, loading arms, and fender systems) will likely be delivered and installed with the support of barge-based equipment. Once completed, the trestle can be used for delivery and access for smaller equipment, workers, tools, and smaller components of construction.

Depending on contractor needs, a modestly-sized upland area may be used for site storage, parking, and a transition point for small vessel accommodation to handle skiffs and other workboats. It is expected that most of the major components of construction (e.g., piling, precast, and prestressed concrete elements) will be fabricated off site and transported to the construction location by way of barge. Hence, both material and equipment load-out are anticipated to occur offsite.



Dredging To create the berths, dredging is proposed within ~45 acres of the Delaware River to a depth of -46 feet NAVD88 (-43 feet MLLW), plus two feet of allowable overdredge (see Drawing 5). Current water depth in the area varies between -20 feet MLLW and -45 feet MLLW. The depth of the dredging area was based on the required clearance for vessels expected to utilize the proposed berth.

Dredging details are shown on Drawing D-101. Accounting for two feet of overdredge, the total dredging volume is approximately 665,000 cubic yards of material. Sediments within the dredge area consist of silts and sands. The depth of sediment to be dredged ranges from 20 feet nearest the berths and less than one foot nearest the Federal Navigation Channel. As described in Section 3.7, an SSAP program has been implemented and the resulting data are pending. Once the data are received, the Dredged Material Management Plan will be finalized and submitted to NJDEP and United States Army Corps of Engineers (“USACE”).

It is expected that contaminated sediments (if found) will be dredged using an environmental clamshell and Best Management Practices (“BMPs”) will be used to limit the potential for sediment resuspension and associated impacts on water quality and aquatic biota. These BMPs include:

• Using a closed clamshell environmental bucket to remove fine-grained sediments;

• Controlling the rate of descent of the bucket to maximize the vertical cut of the clamshell bucket, while not penetrating the sediment beyond the vertical dimension of the open bucket (i.e., overfilling the bucket). The dredging contractor will use appropriate software and sensors to ensure consistent compliance with this condition;

• Using an environmental clamshell equipped with sensors to ensure complete closure of the bucket before it is lifted through the water at a rate of two feet per second or less;

• Controlling the “bite” of the bucket to: (a) minimize the total number of passes needed to dredge the required sediment volume and (b) minimize the loss of sediment due to extrusion through the bucket’s vents openings or hinge area;

• Placing material deliberately in the barge to prevent spillage of material overboard;

• Using barges or scows with solid hull construction or hulls sealed with concrete to transport sediments;

• Discharging decant water only within the dredging area;

• Holding decant water in the decant holding scow for a minimum of 24 hours after the last addition of water to the scow. This holding time may be reduced if it can be demonstrated that TSS meets the background concentrations of 30 parts per million (“mg/L”), based on three consecutive TSS analyses; and

• Not dragging the dredge bucket along the sediment surface.

Sediments will be amended so that they could be transported by truck in compliance with Department of Transportation regulations and to comply with landfill requirements (e.g., soils must pass paint filter tests to demonstrate the absence of free liquids). Impacted sediments will disposed of at a permitted landfill or approved brownfield site.



Uncontaminated sediment meeting the applicable acceptance criteria will be transported via barge to the White's Basin permitted confined disposal facility (“CDF”) or other approved location.

Transportation Improvements Within the limits of the marine terminal, truck and rail off-loading tracks are being constructed to transload product to vessels. Improvements to the internal roadways is also part of the marine terminal at the Site. The Gloucester County Improvement Authority is in the process of designing and constructing a bypass road in the vicinity of the Site, and the Site will be accessible by truck traffic via the bypass road.

Vessel Traffic Once operational, it is estimated that 37 vessels capable of carrying bulk liquid products would annually call on Dock 2. This estimate is based on projected demand, expected vessel size, and time to load a vessel (10 days). Vessels would use the Federal Navigation Channel to move to and from the Site. It is expected that these would be new vessels on the Delaware River.


Project Need Ramboll

5. PROJECT NEED

Exports of bulk liquid products from the United States continue to grow at a rapid pace overall. In the last few years, the East Coast region is beginning to experience significant growth, with a 10-fold increase since 2013 (see Appendix E, Alternatives Analysis).

The completion of the Delaware River Main Channel Deepening Project3 combined with the proximity of production areas will only accelerate exports of bulk liquid products within the Southern New Jersey/Southeastern Philadelphia region. The development of Dock 2 at the GLC will address this critical infrastructure need. More specifically, this Project will accomplish the following goals:

• Provide a deep-water port along the lower Delaware River that will support the projected growth of liquid product exports;

• Provide berth capacity for bulk liquid products, thereby freeing up berth capacity at Dock 1 for accommodating roll-on/roll-off and break-bulk ships;

• Develop a state-of-the-art facility that can handle the largest bulk liquid transport vessels that are expected to be operating within the Delaware River once the Delaware River Main Channel Deepening Project is completed;

• Complement the existing liquid product terminals throughout this region; and

• Stimulate the regional and local economies both during construction and during operation.

The regional need for additional shipping infrastructure and the response to this need through the development of Dock 2 is detailed further in the Alternatives Analysis (see Appendix E).

The location of the Project represents the most suitable site for the proposed activity based on the proximity to the Federal Navigation Channel, existing on-site infrastructure, and the absence of logistical and technological barriers to development. Given that this Site is undergoing redevelopment as a marine terminal, the most feasible alternative for the proposed Project is the DRP Gibbstown Logistics Center.

Statement of Water-Dependence The Project requires direct access to the Delaware River waterfront in order to function as a transloading facility from land-based transportation to marine vessels. The deep-water berth at Dock 1 currently under construction was designed to handle a multitude of cargo types, including roll-on/roll-off, break-bulk, bulk liquids, and project cargo. A second dock will allow bulk liquid products to be transloaded to vessels more efficiently and effectively.

3 https://www.nap.usace.army.mil/Missions/Civil-Works/Delaware-River-Main-Channel-Deepening.


Compliance with Coastal Zone Management Rules Ramboll

6. COMPLIANCE WITH COASTAL ZONE MANAGEMENT RULES

This section presents and describes compliance with the applicable CZM Rules in subchapters 9, 12, 14, 15, and 16 (N.J.A.C. 7:7). Table 1 identifies those CZM Rules which are potentially applicable to the proposed Project. Only those rules which are potentially applicable are discussed in this Compliance Statement. In each sub-section, the coastal rule is summarized in italics and followed by a statement of compliance or non-applicability of that rule.

Compliance with Coastal Zone Management Rules on Special Areas Compliance with CZM special area rules are discussed below.

6.1.1 Finfish Migratory Pathways (N.J.A.C. 7:7-9.5) Finfish migratory pathways are waterways (rivers, streams, creeks, bays and inlets) which can be determined to serve as passageways for diadromous fish to or from seasonal spawning areas, including juvenile anadromous fish which migrate in autumn and those listed by H.E. Zich (1977) "New Jersey Anadromous Fish Inventory" NJDEP Miscellaneous Report No. 41, and including those portions of the Hudson and Delaware Rivers within the coastal zone boundary.

Development, such as dams, dikes, spillways, channelization, tide gates and intake pipes, which creates a physical barrier to the movement of fish along finfish migratory pathways is prohibited, unless acceptable mitigating measures such as fish ladders, erosion control, or oxygenation are used. Development which lowers water quality to such an extent as to interfere with the movement of fish along finfish migratory pathways or to violate State and Delaware River Basin Commission water quality standards is prohibited.

Based on a review of available data from the NMFS, the Project Area does not contain any designated Essential Fish Habitat (“EFH”). The Project Area is located within a portion of the Delaware River designated as critical habitat for the federally-endangered Atlantic sturgeon. Potential impacts of the proposed activities on endangered Atlantic and shortnose sturgeon and their habitat are summarized in Section 3.6 and a detailed impact assessment is provided in Appendix D.

Several species of anadromous fish species are known to migrate north through Delaware Bay and beyond to spawn, including American shad (American shad (Alosa sapidissima), alewife (Alosa pseudoharengus), blueback herring (Alosa aestivalis), striped bass (Morone saxatilis), hickory shad (Alosa mediocris), gizzard shad (Dorosoma cepedianum), and white perch (Morone americana). American eel (Anguilla rostrata) is also commonly found in the Lower Delaware River. NJDEP and the USACE restrict in-water activities where these species may be present between March 1 and July 15.

The proposed Project will not result in the creation of a physical barrier to the movement of fish through migratory pathways. A minor, temporary decrease in water quality may occur during in-water dredging activities, due to a potential increase in suspended solids as a result of disturbance of sediments. BMPs used to manage



sediment resuspension and turbidity that may be caused by dredging are identified in Section 4.2.

Dredging and demolition activities are not anticipated to have long-term adverse impacts on anadromous fish species. Furthermore, the proposed activities are not likely to interfere with the movement of fish along these pathways; therefore, the proposed activities comply with this rule.

6.1.2 Submerged Vegetation Habitat (N.J.A.C. 7:7-9.6) A submerged vegetation special area consists of water areas supporting or documented as previously supporting rooted, submerged vascular plants such as widgeon grass (Ruppia maritima), sago pondweed (Potamogeton pectinatus), horned pondweed (Zannichellia palustris) and eelgrass (Zostera marina). Other submerged vegetation species in lesser quantities include, but are not limited to, the following: water weed (Elodea nuttalli, Eriocaulon parkeri, Liaeopsis, chinesis, Naja flexilis, Nuphar variegatum, Potamogeton crispus, Potamogeton epihydrus, Potamogeton perfoliatus, Potamogeton pusillus, Scirpus subterminalis and Vallisneria Americana).

Development in submerged vegetation habitat is prohibited except for the exceptions listed at N.J.A.C. 7:7-9.6(b).

As described in Section 3.5, an SAV bed has been identified in the Project Area and is shown on Drawings 4, 5, 9, 10, 11 and 13. The Project has been designed to avoid this SAV bed. Therefore, this condition is met.

6.1.3 Navigation Channels (N.J.A.C. 7:7-9.7) Navigation channels are tidal water areas including the Atlantic Ocean, inlets, bays, rivers and tidal guts with sufficient depth to provide safe navigation. Navigation channels include all areas between the top of the channel slopes on either side. These navigation channels are often marked with buoys or stakes. Major navigation channels are shown on NOAA/National Ocean Service Charts. Development which would cause terrestrial soil and shoreline erosion and siltation in navigation channels shall utilize appropriate mitigation measures. Development which would result in loss of navigability is prohibited. Any construction which would extend into a navigation channel is prohibited.

In order to provide access to vessels traveling within the Delaware River Federal Navigation Channel, dredging is proposed within the Project Area to a depth of -43 feet MLLW plus two feet overdredge (see Drawing 5). The limits of dredging occur along the edge of the Federal Navigation Channel. The River is approximately 6,400 feet wide at this location, providing adequate room for ships to safely navigate within the Federal Navigation Channel. Dock construction activities occur approximately 650 feet away from the Federal Navigation Channel and are not expected to adversely impact navigation of vessels within the Delaware River.

The proposed in-water activities will not adversely affect navigation of vessels within the Delaware River; therefore, this condition is met.

6.1.4 Ports (N.J.A.C. 7:7-9.11) Ports are water areas having, or lying immediately adjacent to, concentrations of shoreside marine terminals and transfer facilities for the movement of waterborne cargo (including fluids), and including



facilities for loading, unloading and temporary storage. Port locations in New Jersey include, among others, Newark, Elizabeth, Bayonne, Jersey City, Weehawken, Hoboken, Woodbridge, Perth Amboy, Camden, Gloucester City, Paulsboro and Salem. Any use which would preempt or interfere with port uses of this water area is prohibited.

The nearest port facility is Port of Paulsboro, located approximately four miles east of the Project Area. The proposed Project will not interfere with existing port uses. Therefore, the proposed activities comply with this rule.

6.1.5 Submerged Infrastructure Routes (N.J.A.C. 7:7-9.12) A submerged infrastructure route is the corridor in which a pipe or cable runs on or below a submerged land surface. Any activity which would increase the likelihood of infrastructure damage or breakage, or interfere with maintenance operations is prohibited.

No existing submerged pipelines or cables were identified in or near the Project Area based on a review of NOAA Nautical Chart No. 12312. In addition, no known submerged infrastructure routes are located within the dredging area. Therefore, the proposed activities comply with this rule.

6.1.6 Intertidal and Subtidal Shallows (N.J.A.C. 7:7-9.15) Intertidal and subtidal shallows means all permanently or temporarily submerged areas from the spring high water line to a depth of four feet below mean low water. Development, filling, new dredging or other disturbance is discouraged but may be permitted in accordance with N.J.A.C. 7:7-9.15 (c), (d), (e), (f), (g) and (h) with N.J.A.C. 7:7-12.2 through 12.24.

(b) Development, filling, new dredging, or other disturbance is discouraged but may be permitted in accordance with (c), (d), (e), (f), (g), and (h) below and with N.J.A.C. 7:7-12.2 through 12.24.

(c) Maintenance dredging of intertidal and subtidal shallows is acceptable to maintain adequate water depths in accordance with N.J.A.C. 7:7-12.6.

(e) Mitigation shall be required for the destruction of intertidal and subtidal shallows in accordance with N.J.A.C. 7:7-17. Mitigation shall not be required for the following:

a. Filling in accordance with N.J.A.C. 7:7-12.11(c) and (f)1, 2, and 3;

b. Maintenance dredging in accordance with N.J.A.C. 7:7-12.6;

c. Beach nourishment in accordance with N.J.A.C. 7:7-15.11(f);

Within the Project Area, intertidal and subtidal shallows are present between the elevations of -6.82 feet NAVD88 (which is four feet below mean low water) and 3.14 feet NAVD88 (mean higher high water) as shown on Drawings 4, 5, 9, 10, 11 and 13. No dredging is proposed within intertidal or subtidal shallows. The construction of the trestle structure will require placement of 24 pilings (totaling 75 square feet) intertidal or subtidal shallows. The trestle structure will cover approximately 0.26 acres of intertidal and subtidal habitat, which may result in shading. Shading impacts will be minimized because the deck will be approximately 13 feet above MHW and the trestle will be oriented in the north-south direction, which will result in shadows cast directly under the trestle for fewer hours than if the trestle was oriented east-west.



Permanent impacts to intertidal and subtidal habitat are limited to 75 square feet associated with the footprint of steel piles. If required, mitigation will be performed in accordance with the requirements at N.J.A.C. 7:7-17. Therefore, this condition will be met.

6.1.7 Filled Water’s Edge (N.J.A.C. 7:7-9.23) (a) Filled water's edge areas are existing filled water, wetland, or upland areas lying between

wetlands or water areas, and either (a) the upland limit of fill; or (b) the first paved public road or railroad landward of the adjacent water area, whichever is closer to the water:

(b) Filled water’s edge areas shall be determined through analysis of historic data including United States Department of Agriculture soil surveys, Tidelands maps, or aerial photography. Some existing or former dredged material disposal sites and excavation fill areas are filled water's edge.

(c) The “waterfront portion” is defined as a contiguous area at least equal in size to the area within 100 feet of navigable water, measured from the mean high water line. This contiguous area must be accessible to a public road and occupy at least 30 percent of its perimeter along the navigable water’s edge.

(d) On filled water's edge sites with direct water access (that is, those sites without extensive intertidal shallows or wetlands between the upland and navigable water), development shall comply with the following:

1. Except as provided below, the waterfront portion of the site shall be:

i. Developed with a water dependent use.

(e) On filled water's edge sites without direct access to navigable water, the area to be devoted to water related uses will be determined on a case-by-case basis

(f) On filled water's edge sites with an existing or pre-existing water dependent use, that is, one existing at any time since July of 1977, development must comply with the following additional conditions:

1. 1. For sites with an existing or pre-existing marina, development that would reduce the area currently or recently devoted to the marina is acceptable if certain conditions are met.

2. For sites with an existing or pre-existing water dependent use other than a marina, development that would reduce or adversely affect the area currently or recently devoted to the water dependent use is discouraged.

The landside portion of the Project Area is within the filled water’s edge. Historically, this area was used for industrial purposes and has restricted public access due to health, safety, and security concerns. The activities that will occur in the filled water’s edge area are necessary to support the development of a dock and meet the definition of a water-dependent use, as defined at N.J.A.C. 7:7-1.4 (see Section 6.1).

The development proposed to occur in filled water’s edge areas includes construction of a dock for transloading bulk liquids to marine vessels. Therefore, the requirement to preserve the water-dependent use is met.



Compliance with public access rules (N.J.A.C. 7:7-9.48) is discussed at Section 6.5.5.

6.1.8 Flood Hazard Areas (N.J.A.C. 7:7-9.25) Flood hazard areas are areas subject to flooding from the flood hazard area design flood, as defined by the Department under the Flood Hazard Area Control Act (FHACA) rules at N.J.A.C. 7:13. Flood hazard areas include those areas mapped as such by the Department, areas defined or delineated as an A or a V zone by the Federal Emergency Management Agency (FEMA), and any unmapped areas subject to flooding by the flood hazard area design flood. Flood hazard areas are subject to either tidal or fluvial flooding. In a tidal flood hazard area below the mean high water line, this section shall apply only to the following activities: (1) development of habitable buildings; and (2) construction of railroads, roadways, bridges and/or culverts.

This Project is within a tidal flood hazard area, but does not propose development of a habitable building or construction of railroads, roadways or bridges and/or culverts. Therefore, this condition does not apply.

6.1.9 Riparian Zones (N.J.A.C. 7:7-9.26) A riparian zone exists along every regulated water, except there is no riparian zone along the Atlantic Ocean nor along any manmade lagoon, stormwater management basin, or oceanfront barrier island, spit or peninsula. Regulated waters are defined in the Flood Hazard Area Control Act rules at N.J.A.C. 7:13-2.2. The riparian zone includes the land and vegetation within each regulated water, as well as the land and vegetation within a certain distance of each regulated water. For a waterbody with discernable banks, such as the Hackensack River, the portion of the riparian zone that lies outside of a regulated water is measured landward from the top of bank and can be 50’, 150’ or 300’ wide on both sides of the water body, depending on certain criteria.

Development in riparian zones shall conform with the requirements for a flood hazard area individual permit under the Flood Hazard Area Control Act rules.

Compliance with FHACA Rules regarding regulated activities within the riparian zone is discussed at Section 7.2.

6.1.10 Historic and Archaeological Resources (N.J.A.C. 7:7-9.34) Historic and archaeological resources include objects, structures, shipwrecks, buildings, neighborhoods, districts, and man-made or man-modified features of the landscape and seascape, including historic and prehistoric archaeological sites, which either are on or are eligible for inclusion on the New Jersey or National Register of Historic Places.

Development that detracts from, encroaches upon, damages, or destroys the value of historic and archaeological resources is discouraged.

Development that incorporates historic and archaeological resources in sensitive adaptive reuse is encouraged.

Scientific recording and/or removal of the historic and archaeological resources or other mitigation measures must take place if the proposed development would irreversibly and/or adversely affect historic and archaeological resources.



New development in undeveloped areas near historic and archaeological resources is conditionally acceptable, provided that the design of the proposed development is compatible with the appearance of the historic and archaeological resource.

A Phase I Underwater Archaeology Survey was conducted in the Project Area by Dolan Research in December 2018. Dolan Research issued a report in February 2019 (see Appendix F). As stated in the report, magnetic and acoustic remote sensing data were collected to identify and assess remote sensing targets that may have an association with submerged cultural resources. Historical research was conducted to provide a proper framework for evaluating the significance of the remote sensing targets. Analysis of fieldwork data confirms the presence of three magnetic targets and nine acoustic (sonar) targets in the area of potential impact. However, none of these remote sensing targets is considered to be suggestive of potential submerged cultural resources and no additional underwater archaeological work is recommended.

In addition, a Phase IA Historical and Archaeological Survey was completed for the Site by Hunter Research Inc., Historical Research Consultants, in 2016 (see Appendix G). The small landside portion of the Project Area near Thompson’s Point was reviewed under the scope of the Phase IA Assessment. The assessment concluded that, although a Native American archaeological site was previously documented at Thompson’s Point, this location and the Property as a whole is assigned an overall low potential to yield significant Native American archaeological remains. This assessment is largely because of the extensive modifications made to the landscape over the last 130 years of industrial use and development. Thompson’s Point is also the location of a potential early historic site that may range in date from the late 17th through the 19th Century, however the historic archaeological potential of this location is also considered low for the same reasons. This report was previously submitted to NJDEP as part of the Waterfront Development permit application for Dock 1, and no further assessment of the Thompson’s Point area was required by the State Historic Preservation Office.

6.1.11 Endangered or Threatened Wildlife or Plant Species Habitats (N.J.A.C. 7:7- 9.36)

Endangered or threatened wildlife or plant species habitats are terrestrial or aquatic areas known to be inhabited on a seasonal or permanent basis by or to be critical at any stage in the life cycle of any wildlife or plant identified as "endangered" or "threatened" species on official Federal or State lists of endangered or threatened species, or under active consideration for State or Federal listing. The definition of endangered or threatened wildlife or plant species habitats includes a sufficient buffer area to ensure continued survival of the population of the species. Absence of such a buffer area does not preclude an area from being endangered or threatened wildlife or plant species habitat.

Areas mapped as endangered or threatened wildlife species habitat on the Department's Landscape Maps of Habitat for Endangered, Threatened and Other Priority Wildlife (known hereafter as Landscape Maps) are subject to the requirements of this section unless excluded based on an Endangered or Threatened Wildlife Species Habitat Evaluation. Buffer areas, which are part of the endangered or threatened wildlife species habitat, may extend beyond the mapped areas.



Development of endangered or threatened wildlife or plant species habitat is prohibited unless it can be demonstrated, through an Endangered or Threatened Wildlife or Plant Species Impact Assessment as described at N.J.A.C. 7:7-11, that endangered or threatened wildlife or plant species habitat would not directly or through secondary impacts on the relevant site or in the surrounding area be adversely affected.

As discussed in Section 3.6, the Project Site contains habitat potentially suitable for bald eagle (state endangered), osprey (state threatened) and northern long-eared bat (federally threatened). A bald eagle nest is located on Mond’s island, but is greater than 1,000 feet from the proposed Project. An osprey nest is located in a relic piling at Thompson’s Point, but this structure will not be disturbed by the proposed Project.

Atlantic sturgeon and shortnose sturgeon (federally endangered) habitat has been identified within the Delaware River. A Sturgeon Impact Assessment (Appendix D) has been prepared to evaluate the potential effects of project activities on these sturgeon species.

Through avoidance, minimization, and mitigation measures, no adverse impacts to threatened and endangered species or their habitat are expected as result of the Project.

6.1.12 Critical Wildlife Habitats (N.J.A.C. 7:7-9.37) Critical wildlife habitats are specific areas known to serve an essential role in maintaining wildlife, particularly in wintering, breeding, and migrating.

• Rookeries for colonial nesting birds, such as herons, egrets, ibis, terns, gulls, and skimmers; stopovers for migratory birds, such as the Cape May Point region; and natural corridors for wildlife movement merit a special management approach through designation as a Special Area.

• Ecotones, or edges between two types of habitats, are a particularly valuable critical wildlife habitat. Many critical wildlife habitats, such as salt marsh water fowl wintering areas, and muskrat habitats, are singled out as water or water's edge areas.

Development that would directly or through secondary impacts on the relevant site or in the surrounding region adversely affect critical wildlife habitats is discouraged, unless:

(1) Minimal feasible interference with the habitat can be demonstrated; (2) there is no prudent or feasible alternative location for the development; and (3) the proposal includes appropriate mitigation measures.

A search of the New Jersey Natural Heritage Database and the New Jersey Landscape Project identified foraging habitat for great blue heron (Ardea herodias), a state species of special concern, within the Project Area. No wintering, breeding, or migrating habitat for this species was identified within the Project Area. A breeding colony of heron was identified within one mile of the Project Site on Monds Island. A copy of the Natural Heritage Database search results is provided in Appendix B.



The Project Area is located greater than 1,000 feet from Mond’s Island and will not directly interfere with the heron breeding habitat on Mond’s Island. Therefore, this condition is met.

6.1.13 Public Open Space (N.J.A.C. 7:7-9.38) (a) Public open space constitutes land areas owned or maintained by State, Federal, county and

municipal agencies or private groups (such as conservation organizations and homeowner's associations) and used for or dedicated to conservation of natural resources, public recreation, visual or physical public access or, wildlife protection or management. Public open space also includes, but is not limited to, State Forests, State Parks, and State Fish and Wildlife Management Areas, lands held by the New Jersey Natural Lands Trust (N.J.S.A. 13:1B-15.119 et seq.), lands held by the New Jersey Water Supply Authority (N.J.S.A. 58:1B-1 et seq.) and designated Natural Areas (N.J.S.A. 13:1B-15.12a et seq.) within DEP-owned and managed lands.

(b) New or expanded public or private open space development is encouraged at locations compatible or supportive of adjacent and surrounding land uses.

(c) Development that adversely affects existing public open space is discouraged.

…

(g) All new development adjacent to public open space will be required to provide an adequate buffer area and to comply with the buffers and compatibility of uses rule, N.J.A.C. 7:7- 16.11. The buffer required will be dependent upon adjacent land uses and potential conflicts between users of public open space and the proposed adjacent land use.

Compliance with the rules on buffers is presented at 6.5.7.

The Project Area is not located within public open space. Mond’s Island, owned by The Nature Conservancy, is located greater than 2,000 feet from the Project Area. This distance provides an adequate buffer. Therefore, this condition is met.

6.1.14 Special Hazard Areas (N.J.A.C. 7:7-9.39) (a) Special hazard areas include areas with a known actual or potential hazard to public health,

safety, and welfare, or to public or private property, such as the navigable air space around airports and seaplane landing areas, potential evacuation zones, and areas where hazardous substances as defined at N.J.S.A. 58:10-23.11b are used or disposed, including adjacent areas and areas of hazardous material contamination.

(b) Coastal development, especially residential and labor-intensive economic development, within special hazard areas is discouraged. All development within special hazard areas must include appropriate mitigating measures to protect the public health and safety.

(c) Approvals from the Department’s Solid and Hazardous Waste Program shall be obtained prior to the commencement of any hazardous substance investigations or cleanup activities at contaminated sites.

The proposed Project will satisfy the provisions of N.J.A.C. 7:7-9.39 through compliance with existing regulatory programs specifically designed to implement mitigating measures to protect the public health and safety.



Dock 2 represents an expansion and reconfiguration of previously proposed and permitted development and operations associated with Dock 1 and landside improvements. Accordingly, as was the case with Dock 1, operations at the proposed facility will be subject to several regulatory programs that require development of plans and implementation of measures to protect the public health and safety. These plans must be approved by NJDEP and must be consistent with the requirements of N.J.A.C. 7:7-9.39 to employ mitigating measures to protect the public health and safety.

DRP has developed and implemented these plans for the existing operations at the facility, and would expand those plans to incorporate Dock 2 operations. To date, DRP has undertaken the following efforts to ensure the facility meets the applicable health and safety standards:

• DPR has implemented a Risk Management Program pursuant to a June 9, 2017 Consent Agreement executed between DRP and the NJDEP Bureau of Release Prevention, as authorized by the Toxic Catastrophe Prevention Act (N.J.S.A. 13:1K-19) and implementing regulations (N.J.A.C. 7:31, et seq.). To obtain this approval for the currently operating cavern transloading operation, DRP submitted the following plans:

– Process Hazard Analysis: identifies and assess potential hazards that could be associated with operations involving the storage or transfer of certain hazardous substances.

– Inherently Safer Technology Report: examines the design alternatives considered and employed by DRP to minimize or eliminate the potential for a release.

– Safety Review of Design: provides the details on the safety features involved in the design, construction, and operation of covered processes.

– Risk Management Plan: defines and documents the potential risks associated with regulated facilities, estimates impacts, and defines emergency response protocols.

• DRP submitted a detailed description of the covered processes, and a NJDEP Chemical Safety Engineer reviewed and approved those covered processes, in two phases:

– Pre-construction Safety Review: NJDEP Chemical Safety Engineer reviewed design and planning documents to ensure that the system is designed in accordance with applicable codes and standards.

– Pre-startup Safety Review: before the covered processes came online, NJDEP reviewed any changes to the documentation and performed a detailed on-site audit of all risk management procedures. This includes the management system, prevention program, and emergency response program.

As appropriate, mitigating measures to protect the public health and safety consistent with the regulatory programs outlined above will be designed and implemented and the existing plans will be revised to include the Dock 2 operations. Accordingly, the requirements of N.J.A.C. 7:7-9.39 will be satisfied by existing regulatory obligations applicable to the proposed operations.

Compliance with NJDEP’s Discharge Prevention Program, or other health and safety programs such as the USEPA’s Oil Spill Prevention and Preparedness Program, is not required as the provisions of these programs are not triggered by the operations at the proposed facility, including the transloading operations. In the future, if proposed operations at the facility do trigger these programs, then the appropriate plans will be prepared and submitted to the appropriate regulatory agency.



6.1.15 Special Urban Areas (N.J.A.C. 7:7-9.41) (a) Special urban areas are those municipalities defined in urban aid legislation (N.J.S.A.

52:27D-178) qualified to receive State aid to enable them to maintain and upgrade municipal services and offset local property taxes. Under N.J.S.A. 52:27D-178 et seq., the Department of Community Affairs (DCA) establishes a list of qualifying municipalities each fiscal year. DCA’s list of qualifying municipalities may be obtained on request from the Department’s Division of Land Use Regulation at the address set forth at N.J.A.C. 7:7-1.6.

(b) Development that will help to restore the economic and social viability of special urban areas is encouraged. Development that would adversely affect the economic well-being of these areas is discouraged, when an alternative which is more beneficial to the special urban areas is feasible. Development that would be of economic and social benefit and that serves the needs of local residents and neighborhoods is encouraged.

The Project Area is located in Greenwich Township, which is not listed on the DCA’s list of qualifying municipalities for FY 2016. However, the Site has been identified as a Metropolitan Planning Area within the New Jersey State Development and Redevelopment Plan. The Site, which was a munitions and chemical manufacturing facility for over 100 years, is undergoing remediation so that it can be redeveloped. As stated in the New Jersey State Development and Redevelopment Plan (March 2001), The Strategic Importance of New Jersey’s Ports:

“As expansion of the global economy increases the importance of import and export activity, the Delaware River ports will become critical to New Jersey’s economic future.”

Proposed Dock 2 will enhance operational efficiency at the GLC, enabling the port facility to provide increased economic and social benefits that serves the needs of the local community and the surrounding region. The Project will contribute to and enhance the economic benefits associated with the ongoing redevelopment at the Site, including job creation, community revitalization, infrastructure improvements and overall economic growth in the region. More specifically, the Project is expected to generate approximately 250-person years of construction activity, and approximately 40 to 50 full time positions once Dock 2 is in operation. In addition to on-site sustainable employment opportunities, local businesses will have the opportunity to provide services in a broad range of areas related to the construction and ongoing operation of Dock 2. The large capital investment and annual operating expenses associated with the Project will help create jobs, diversify economic activity at the local level, and will function as a primary vehicle for long-term economic stability in the region for future generations. Dock 2, and GLC as a whole, will revitalize a community and region once dependent on this former industrial facility; therefore, the proposed activities comply with this rule.

6.1.16 Lands and Water Subject to Public Trust Rights (N.J.A.C. 7:7-9.48) Lands and waters subject to public trust rights are tidal waterways and their shores, including both lands now or formerly below the mean high water line, and shores above the mean high water line. Tidal waterways and their shores are subject to the Public Trust Doctrine and are held in trust by the State for the benefit of all the people, allowing the public to fully enjoy these lands and waters for a variety of public uses.



Public access to lands and waters subject to public trust rights shall be provided in accordance with the public access rule, N.J.A.C. 7:7-16.9. Development that does not comply with N.J.A.C. 7:7-16.9, Public access, is discouraged in lands and water subject to public trust rights.

The State of New Jersey has conveyed its ownership of a portion of the tidelands located adjacent to the Site to the upland owner through previously issued tidelands grants (see property deed in Appendix H). Public access is discussed in Section 6.5.5; therefore, the proposed activities will comply with this rule.

Compliance with Coastal Zone Management Rules on General Water Areas (N.J.A.C. 7:7-12)

N.J.A.C. 7:7-12.2 through 12.24 set forth the requirements for specific types of development within general water areas as defined at (a) above. In many cases an area already identified as a special area will also fall within the definition of a general area. In these cases, both general and special area rules apply. In case of conflict between general and special area rules, the more specific special area rules shall apply.

6.2.1 Docks and Piers for Cargo and Commercial Fisheries (N.J.A.C. 7:7-12.4) (a) Docks and piers for cargo and passenger movement and commercial fisheries are structures

supported on pilings driven into the bottom substrate or floating on the water surface, used for loading and unloading passengers or cargo, including fluids, connected to or associated with, a single industrial or manufacturing facility or to commercial fishing facilities.

(b) Docks and piers for cargo and passenger movement and commercial fisheries are conditionally acceptable provided:

1. The width and length of the dock or pier is limited to only what is necessary for the proposed use;

The selected design utilizes dolphins to reduce the length of docking required to accommodate ships up to approximately 966 feet in length; therefore, this condition is met. See Alternatives Analysis (Appendix E) for additional detail.

2. The dock or pier will not pose a hazard to navigation. A hazard to navigation includes all potential impediments to navigation, including access to adjacent moorings, water areas and docks and piers;

The dock and berth layout provides for safe navigation and maneuvering in and out to the berth area. Specifically, the Project layout allows vessels to use the area in front of the two berths at Dock 2 as a turning basin and, accordingly, meets operational needs and safety requirements.

3. The associated use of the adjacent land meets all applicable rules of this chapter.

The use of the adjacent land has been approved under a previously issued Waterfront Development Individual Permit (NJDEP Permit Nos. 0807-16-0001.2, WFD 160001).

(c) The standards for port uses are found at N.J.A.C. 7:7-15.9. The standards for the construction of a dock or pier composed of fill and retaining structures are found at N.J.A.C. 7:7-12.11.



Port uses are discussed at Section 6.1.4. Concerning standards of construction dock will not be composed of fill or retaining structures. Therefore, N.J.A.C. 7:7-12.11 does not apply.

6.2.2 New Dredging (N.J.A.C. 7:7-12.7) (a) New dredging is the removal of sediment that does not meet the definition of maintenance

dredging at N.J.A.C. 7:7-12.6 or the definition of environmental dredging at N.J.A.C. 7:7-12.8. The temporary or permanent displacement or removal of sediment for the purpose of installing submerged pipelines and cables is considered new dredging.

(c) New dredging is conditionally acceptable in all general water areas for boat moorings, navigation channels, anchorages, or submerged cable or pipelines provided:

1. There is a demonstrated need that cannot be satisfied by existing facilities;

As discussed in the Alternatives Analysis (Appendix E), in light of the existing infrastructure assets and previous industrial uses, there is no comparable alternative location for the Project that would further minimize environmental impacts, nor is there an alternative site that is more suitable for the intended purpose of the Project. By selecting this Site, the Project focus is on redevelopment of a brownfield site, and avoids creating wholly new land disturbance and associated environmental externalities. Through an iterative feasibility study process, the Project has been designed to minimize adverse environmental impacts to the maximum extent practicable while restoring a brownfield site.

2. The facilities served by the new dredging satisfy the location requirements for special water’s edge areas;

Compliance with coastal rules on Special Areas (N.J.A.C. 7:7-9) is discussed in Section 6; therefore, this condition is met.

3. The adjacent water areas are currently used for recreational boating, commercial fishing or marine commerce;

The Delaware River is used for marine commerce; therefore, this condition is met.

4. The dredge area causes no significant disturbance to special water or water’s edge areas;

See Section 6.1. This condition will be met.

5. The adverse environmental impacts are minimized to the maximum extent feasible;

BMPs will be implemented to minimize sediment resuspension and limit the potential impacts to water quality and aquatic biota (see Section 4.2). In addition, no in-water construction work (dredging or pile driving) will occur between March 1 and July 15 to protect migratory and spawning fish populations. Environmental impacts arising due to new dredging will be minimized to the maximum extent practicable; therefore, this condition will be met.

6. The dredge area is reduced to the minimum practical;



As discussed in the Alternatives Analysis (Appendix E), the area of dredging proposed is the minimum feasible to provide safe navigational access to the new dock; therefore, this condition is met.

7. The maximum depth of the newly dredged area shall not exceed that of the connecting access or navigation channel necessary for vessel passage to the bay or ocean;

Based on available bathymetry data, the portion of the Federal Navigation Channel adjacent to the project area is approximately 45 feet deep. The proposed dredge depth is -43 feet MLLW (plus two feet allowable overdredge); therefore, this condition is met.

8. The new dredging will have no adverse impacts on groundwater resources;

New dredging will not adversely impact groundwater resources; therefore, this condition is met.

9. No dredging shall occur within 10 feet of any wetlands. The proposed slope from this 10-foot buffer to the nearest edge of the dredged area shall not exceed three vertical to one horizontal;

The limits of proposed new dredging are not located within 10 feet of any wetlands; therefore, this condition does not apply.

10. The new dredging shall be accomplished consistent with the conditions listed at N.J.A.C. 7:7- 12.7(c).10.i-viii.

Dredged material is being characterized in accordance with a NJDEP approved sampling plan. Based on the results of that sampling plan, a dredged material management plan will be prepared in compliance with this requirement.

6.2.3 Dredged material disposal (N.J.A.C. 7:7-12.9) Dredged material disposal is the discharge of sediments removed during dredging operations in water areas. Dredged material disposal does not include the beneficial use of dredged material for the purposes of habitat creation, restoration, or enhancement, artificial reef construction, or the establishment of living shorelines.

Dredged materials generated by the proposed activities will not be disposed in a water area; therefore, this rule does not apply. Dredge materials on land is discussed in Section 6.4.3.

6.2.4 Filling (N.J.A.C. 7:7-12.11) (b) Filling is the deposition of material including, but not limited to, sand, soil, earth, and dredged

material, into water areas for the purpose of raising water bottom elevations to create land areas.

No fill will be placed within water areas for the purpose of raising water bottom elevations to create land areas. A total of 519 piles are proposed to be installed to support Dock 2’s main trestle, loading platforms and dolphins, which will impact



approximately 3,600 square feet of benthic habitat within the Delaware River. As discussed in the Alternatives Analysis, there is no feasible alternative location for the proposed activities and the proposed trestle configuration was selected to minimize adverse impacts to aquatic habitat to the maximum extent practicable (see Appendix E).

Because the installation of pilings is required to fulfill the basic project purpose for the intended water-dependent use, the proposed activities meet the requirements for conditionally acceptable fill at N.J.A.C. 7:7-12.11(e) above. Therefore, this condition is met.

Compliance with CZM Rules on Location (N.J.A.C. 7:7-14) Compliance with CZM location rules are discussed below.

6.3.1 Basic Location Rule (N.J.A.C. 7:7-14.2) (a) A location may be acceptable for development under N.J.A.C. 7:7-9, 12, 13, and 14, but the

Department may reject or conditionally approve the proposed development of the location as reasonably necessary to:

1. Promote the public health, safety, and welfare;

2. Protect public and private property, wildlife and marine fisheries; and

3. Preserve, protect and enhance the natural environment.

The Site has been developed for industrial use and operated for over 100 years. It is optimal for redevelopment into a port facility, which will be operated in accordance with all applicable health and safety regulations. As demonstrated by compliance with Special Area rules discussed in Section 6.1, impacts to wildlife and marine fisheries have been avoided or minimized. Therefore, this rule is not implicated.

6.3.2 Secondary Impacts (N.J.A.C. 7:7-14.3) (b) Secondary impacts are the effects of additional development likely to be constructed as a

result of the approval of a particular proposal. Secondary impacts can also include traffic increases, increased recreational demand and any other offsite impacts generated by onsite activities which affect the site and surrounding region.

As presented in the Alternatives Analysis, the large capital investment and annual operating expenses associated with the Project will help create jobs, diversify economic activity at the local level, and will function as a primary vehicle for long-term economic stability in the region for future generations. Dock 2, and GLC as a whole, will revitalize a community and region once dependent on this former industrial facility (see Appendix E).

Other secondary impacts at the Site include increases in truck traffic as well as an increase in noise associated with facility construction and operations. Access to the previously permitted DRP Gibbstown Logistics Center development has been designed to provide efficient ingress and egress from the Project Area; therefore, increased traffic volumes are not anticipated to cause a significant burden to off-site roadways. The applicant also understands that the Gloucester County Improvement Authority is



currently in the design and permitting phase for the construction of a bypass road that would allow for traffic to be routed around residential areas of downtown Gibbstown, and has applied for permits from NJDEP related to that project.

With respect to increase noise, the addition of Dock 2 is not expected to contribute to a significant increase in noise beyond that of the previously permitted port development. The Site was previously operated as an industrial manufacturing facility, including the production and testing of explosives.4 Because port operations will be located within former industrial areas and are separated from nearby residential areas by undeveloped lands with heavy tree density, any increase in noise associated with Dock 2 operations is not anticipated to adversely impact off-site areas.

Compliance with CZM Use Rules (N.J.A.C. 7:7-15) Compliance with CZM use rules is discussed below.

6.4.1 Industry (N.J.A.C. 7:7-15.7) (a) Industry uses are uses that involve industrial processing, manufacturing, storage, or

distribution activities. These uses include, but are not limited to, electric power production, food and food by-product processing, paper production, agrichemical production, chemical processes, storage facilities, metallurgical processes, mining and excavation processes, and processes using mineral products. Industrial uses do not include petroleum refining which is considered and energy use and, therefore, subject to the standards of N.J.A.C. 7:7-15.4.

(b) Industrial uses are encouraged in special urban areas. Elsewhere, industrial uses are conditionally acceptable provided they comply with all applicable location and resource rules.

The primary purpose of Dock 2 is to transload bulk liquid products for export. As a port facility, operations involve the transfer of bulk liquids for transportation and do not include manufacturing activities. The Project complies with applicable location and resource rules as discussed at Section 6.3 and 6.5; therefore, this condition is met.

6.4.2 Port (N.J.A.C. 7:7-15.9) (a) Port uses are concentrations of shoreside marine terminals and transfer facilities for the

movement of waterborne cargo (including fluids), and including facilities for loading, unloading and temporary storage.

(b) Port-related development and marine commerce is encouraged in and adjacent to established port areas. Water-dependent development shall not be preempted by non-water dependent development in these areas.

(c) New port uses outside of existing ports as defined at N.J.A.C. 7:7-9.11(a) are acceptable only when there is a clear demonstration of need, and when suitable land and water area is not available in or adjacent to an existing port.

(d) New or expanded ports must be compatible with surrounding land uses and provide for maximum open space and physical and visual access to the waterfront, provided that this

4 The DuPont Repauno Works site began manufacturing and testing explosives in the late 1890s and continued

until the 1950s. Explosives manufacturing was discontinued in the 1950s. Source: 1996 Phase III Remedial Investigation Report, Vol 1. DuPont.



access does not interfere with port operations or endanger public health and safety. New or expanded ports must also not interfere with national, State, county or municipal parks, recreational areas, or wildlife refuges.

(e) New, expanded or redeveloped port facilities must have direct access to navigation channels of sufficient depth for anticipated vessel access, with minimal dredge and fill requirements, adequate access to road, rail transportation, and adjacent land with sufficient load bearing capacity for structures.

The proposed Project is a water-dependent development and is compatible with surrounding land uses as discussed at Section 6.5.6. Dredging is proposed to provide direct access to the Federal Navigation Channel. Because Dock 2 will be operated as a commercial facility for the handling of bulk liquids, visual and physical access to the waterfront may be restricted under federal law in order to prevent a homeland security vulnerability (see Section 6.5.5). Therefore, the proposed Project complies with the requirements for expanded port facilities as described above and this condition is met.

6.4.3 Dredged Material Placement on Land (N.J.A.C. 7:7-15.12) (a) Dredged material placement is the disposal or beneficial use of sediments removed during

dredging operations. Beneficial uses of dredged material include, but are not limited to, fill, capping material, topsoil, bricks, and lightweight aggregate. This rule applies to the placement of dredged material landward of the spring high water line. The standards for dredged material disposal in water areas are found at N.J.A.C. 7:7-12.9.

(b) Dredged material placement on land is conditionally acceptable provided that the use is protective of human health, groundwater quality, and surface water quality, and manages ecological risks. Testing of the dredged material may be required as needed to determine the acceptability of the placement of the material on a particular site in accordance with Appendix G.

(c) Dredged material disposal and/or construction of a confined disposal facility is prohibited in wetlands unless the criteria found at N.J.A.C. 7:7-9.27 are met.

(d) The beneficial use of dredged material of appropriate quality and particle size for purposes such as restoring landscape, enhancing farming areas, capping and remediating landfills and brownfields, transportation projects, beach protection, creating marshes, capping contaminated dredged material disposal areas, and making new wildlife habitats is encouraged.

(e)Adverse effects associated with the transfer of the dredged materials from the dredging site to the upland confined disposal facility or upland placement site shall be minimized to the maximum extent feasible.

(f) Dredged material placement in wet and dry borrow pits is conditionally acceptable (see N.J.A.C. 7:7-9.14 and 9.33).

(g) If pre-dredging sediment analysis indicates contamination, then special precautions shall be imposed including but not necessarily limited to increasing retention time of water in the disposal site or rehandling basin through weir and dike design modifications, use of coagulants, ground water monitoring, or measures to prevent biological uptake by colonizing plants.

(h) All potential releases of water from confined (diked) disposal facilities and rehandling basins shall meet existing State Surface Water Quality Standards (N.J.A.C. 7:9B) and State Ground



Water Quality Standards (N.J.A.C. 7:9).

As summarized in Section 4.2, sediments proposed to be dredged are being characterized in accordance with a SSAP approved by ODST. Based on the sediment characterization data and current NJDEP policy, dredged material will not be placed on land unless approved by NJDEP. Therefore, this requirement will be met.

Compliance with CZM Resource Rules (N.J.A.C. 7:7- 16) In addition to satisfying the location and use rules, a proposed development must satisfy the requirements of this subchapter. This subchapter contains the standards the Department utilizes to analyze the proposed development in terms of its effects on various resources of the built and natural environment of the coastal zone, both at the proposed site as well as in its surrounding region.

6.5.1 Marine Fish and Fisheries (N.J.A.C. 7:7-16.2) (a) Any activity that would adversely impact on the natural functioning of marine fish, including the

reproductive, spawning and migratory patterns or species abundance or diversity of marine fish, is discouraged. In addition, any activity that would adversely impact any New Jersey based marine fisheries or access thereto is discouraged, unless it complies with (c) below.

Shortnose sturgeon (federally endangered) habitat has been identified in the Project Area within the Delaware River. In addition, the Project Area is designated as critical habitat for the Atlantic sturgeon (federally endangered). Dredging and other in-water activities related to the construction of Dock 2 may impact sturgeon habitat within the Project Area (see Appendix D). Therefore, no in-water work will be performed between March 1 and July 15 to avoid potential impacts to migrating sturgeon. Refer to Appendix D for additional detail.

As discussed at Section 6.1.1, the Project Area does not contain any designated EFH. Other anadromous fish that may migrate up the Delaware River past the Project Area include American shad (American shad (Alosa sapidissima), alewife (Alosa pseudoharengus), blueback herring (Alosa aestivalis), striped bass (Morone saxatilis), hickory shad (Alosa mediocris), gizzard shad (Dorosoma cepedianum), and white perch (Morone americana). American eel (Anguilla rostrata) is also commonly found in the Lower Delaware River. NJDEP and the USACE restricts activities in waterfront activities where these species may be present between March 1 and July 15.

A minor, temporary decrease in water quality may occur during dredging activities due to a potential increase in suspended solids caused by disturbance of sediments. BMPs used to manage sediment resuspension and turbidity that may be caused by dredging are identified in Section 4.2.

Based on the implementation of BMPs and timing restrictions, the proposed activities for the Project are not expected to adversely impact anadromous fish species that may potentially migrate through or utilize the Project Area. Therefore, this condition is met.

6.5.2 Water Quality (N.J.A.C. 7:7-16.3) (a) As required by Section 307(f) of the Federal Coastal Zone Management Act, 16 U.S.C. §§ 1451

et seq., Federal, State, and local water quality requirements established under the Federal



Clean Water Act, 33 U.S.C. §§ 1251 et seq., shall be the water resource standards of the coastal management program. These requirements include not only the minimum requirements imposed under the Clean Water Act but also the additional requirements adopted by states, localities, and interstate agencies pursuant to Section 510 of the Clean Water Act and such statutes as the New Jersey Water Pollution Control Act, N.J.S.A. 58:10A- 1 et seq. In the Delaware River Basin, the requirements include the prevailing “Basin Regulations-Water Quality” adopted by the Delaware River Basin Commission as part of its Comprehensive Plan. Department rules related to water pollution control and applicable throughout the entire coastal zone include, for example, the Surface Water Quality Standards (N.J.A.C. 7:9B), the Ground Water Quality Standards (N.J.A.C. 7:9C), and the New Jersey Pollutant Discharge Elimination System rules (N.J.A.C. 7:14A).

As discussed, BMPs will be implemented during dredging and construction activities to manage sediment resuspension and turbidity. Therefore, the Project will be constructed in a manner that will not cause or contribute to a violation of any applicable state water quality standard.

6.5.3 Vegetation (N.J.A.C. 7:7-16.7) (b) Vegetation is the plant life or total plant cover that is found on a specific area, whether

indigenous or introduced by humans.

(c) Coastal development shall preserve, to the maximum extent practicable, existing vegetation within a development site. Coastal development shall plant new vegetation, particularly appropriate coastal species, native to New Jersey to the maximum extent practicable.

Proposed Dock 2 is located within the Delaware River, with only the landing of the trestle pier located on the shoreline of the Delaware River. As discussed in Section 3.3, little vegetation is present in the area of the trestle landing. Therefore, no vegetation will be eliminated by construction of the Project and this condition is met.

6.5.4 Air Quality (N.J.A.C. 7:7-16.8) (a) The protection of air resources refers to the protection from air contaminants that injure

human health, welfare or property, and the attainment and maintenance of State and Federal air quality goals and the prevention of degradation of current levels of air quality.

(b) Coastal development shall conform to all applicable State and Federal regulations, standards and guidelines and be consistent with the strategies of New Jersey's State Implementation Plan (SIP). See N.J.A.C. 7:27 and New Jersey SIP for ozone, particulate matter, sulfur dioxide, nitrogen dioxide, carbon monoxide, lead, and visibility.

(c) Coastal development shall be located and designed to take full advantage of existing or planned mass transportation infrastructures and shall be managed to promote mass transportation services, in accordance with the traffic rule, N.J.A.C. 7:7-16.12.

Certain transloading operations at Dock 2 may require air quality permit(s) for operation. DRP will obtain any required permit(s) for the operation of Dock 2, and monitoring and reporting of air quality will be implemented as may be required by said permit(s). The Project will be operated in accordance with the provisions of any such permit(s) such that the Project will not cause or contribute to a violation of applicable air quality standards. Accordingly, this requirement is met.



6.5.5 Public Access (N.J.A.C. 7:7-16.9) (d) Public access to the waterfront is the ability of the public to pass physically and visually to,

from, and along tidal waterways and their shores and to use such shores, waterfronts and waters for activities such as navigation, fishing, and recreational activities including, but not limited to, swimming, sunbathing, surfing, sport diving, bird watching, walking, and boating. Public accessways and public access areas include streets, paths, trails, walkways, easements, paper streets, dune walkovers/walkways, piers and other rights-of way. No authorization or approval under this chapter shall be deemed to relinquish public rights of access to and use of lands and waters subject to public trust rights in accordance with N.J.A.C.7:7-9.48. Further, no authorization or approval under this chapter shall be considered a Tidelands approval or shall exempt an applicant from the obligation to obtain a Tidelands approval, if needed.

(e)In addition to the broad coastal goals outlined at N.J.A.C. 7:7-1.1(c), public access shall be provided in a manner designed to achieve the following public access goals:

a. All existing public access to, and along tidal waterways and their shores shall be maintained to the maximum extent practicable;

b. New development shall provide opportunity for public access to tidal waterways and their shores on or offsite;

c. Public access to tidal waterways and their shores shall be provided in such a way that it shall not create conditions that may be reasonably expected to endanger public health or safety, or damage the environment. To that end, public access may be restricted seasonally, hourly, or in scope (for example, access restricted to a portion of the property, or access allowed for fishing but not swimming due to consistent strong currents); and

d. Public access to tidal waterways and their shores shall be provided in such a way that it shall not create a significant homeland security vulnerability… Therefore, public access may be prohibited in locations where homeland security concerns are present or where it is not practicable based on the risk of injury from hazardous operations or substantial permanent obstructions, and no measures can be taken to avert these risks.

(k) 5. Ports, as defined at N.J.A.C. 7:7-9.11, shall provide both visual and physical access as follows: i. For existing ports, public access shall be provided as follows:

(1) No public access is required if there is no existing public access onsite. Any existing public access shall be maintained or equivalent onsite public access shall be provided.

The DRP Gibbstown Logistics Center port development was not required to provide public access pursuant to N.J.A.C. 7:7-16.9(k)(5)(ii). However, in the spirit of neighborliness, DRP agreed to allow public access to a boat launch in a waterfront area remote from the planned port area. While the boat launch is located on land owned by DRP, it is necessary to cross through the Greenwich Township Riverfront Park in order to access the boat launch. DRP continues to coordinate with the Township of Greenwich to provide access to the boat ramp for accessibility. Therefore, this condition is met.

6.5.6 Scenic Resources and Design (N.J.A.C. 7:7-16.10) (a) Scenic resources include the views of the natural and/or built landscape. Large-scale elements of building and site design are defined as the elements that compose the developed landscape such as size, geometry, massing, height and bulk structures. New coastal development that is visually compatible with its surroundings in terms of building and site design, and enhances scenic resources



is encouraged. New coastal development that is not visually compatible with existing scenic resources in terms of large-scale elements of building and site design is discouraged.

The proposed Project is located within the Delaware River Region at a former industrial manufacturing site and will be visually compatible with surrounding industrial facilities located along the Delaware River. As stated at N.J.A.C. 7:7-16.10(d), areas within the Delaware River Region are exempt from scenic resources and design requirements; therefore, this condition does not apply.

6.5.7 Buffers and Compatibility of Uses (N.J.A.C. 7:7-16.11) (a) Buffers are natural or man-made areas, structures, or objects that serve to separate distinct uses or areas. Compatibility of uses is the ability for uses to exist together without aesthetic or functional conflicts. Development shall be compatible with adjacent land uses to the maximum extent practicable.

(b) Development shall be compatible with adjacent land uses to the maximum extent practicable.

(1) Development that is likely to adversely affect adjacent areas, particularly special areas, N.J.A.C. 7:7-9, or residential or recreation uses, is prohibited unless the impact is mitigated by an adequate buffer. The purpose, width, and type of the required buffer shall vary depending upon the type and degree of impact and the type of adjacent area to be affected by the development, and shall be determined on a case- by-case basis.

The Project Area is located immediately adjacent to the GLC, a former industrial facility currently being redeveloped into a marine terminal. Development of Dock 2 within the Project Area is buffered from surrounding undeveloped area by the GLC to the south and the Delaware River to the north, east, and west. Therefore, this condition is met.

6.5.8 Traffic ((N.J.A.C. 7:7-16.14) Coastal development shall be designed, located and operated in a manner to cause the least possible disturbance to traffic systems.

Within the limits of the marine terminal currently being developed at the GLC, truck and rail off-loading tracks will be constructed to transload product to vessels. Improvements to the internal roadways at the GLC are also included in the proposed marine terminal development, which was previously permitted by NJDEP. Further, the Gloucester County Improvement Authority is in the process of constructing a bypass road in the vicinity of the Site, and the Site will be accessible via the bypass road.


Compliance with FHA Rules Ramboll

7. COMPLIANCE WITH FHA RULES

This section presents and describes compliance with applicable FHA Rules. Only those provisions of the FHA Rules that are potentially applicable are discussed in this regulatory Compliance Statement, including area-specific requirements for individual permits (N.J.A.C. 7:13-11). In each sub-section, the FHA Rule is summarized in italics followed by a statement of compliance or non-applicability.

Regulated Activities in a Channel (N.J.A.C. 7:13-11.1) (a) This section sets forth specific design and construction standards that apply to any regulated

activity proposed in a channel.

(b) The Department shall issue an individual permit for a regulated activity in a channel only if the following requirements are satisfied:

1. The basic purpose of the project cannot be accomplished without the disturbance to the channel;

2. Disturbance to the channel is eliminated where possible; where not possible to eliminate, disturbance is minimized through methods including relocating the project and/or reducing the size or scope of the project.

3. Aquatic habitat is preserved where possible; and

4. Aquatic habitat is enhanced where preservation is not possible, such as through the placement of habitat enhancement devices, replacement of vegetation removed during construction, creation of tree canopy along the channel where no canopy exists and/or enhancement of existing tree canopy along the channel.

The proposed activities require dredging within the Delaware River (see Drawing D-101).

Dredging activities are required in order to ensure proper depths to and from Dock 2 and the Federal Navigation Channel. Such access is critical to the development of a port facility.

As stated in the Alternatives Analysis (Appendix E), the Project has been substantially reduced and reconfigured to avoid impacts to regulated areas, including riparian zones and regulated waters. Disturbance to the channel has been reduced to the maximum extent practicable and the activities proposed within a regulated channel are required to meet the basic purpose of the Project; therefore, this condition is met.

The proposed Dock 2 is located in the vicinity of a former barge berth. Dredging within a portion of the Delaware River is required in order to make Dock 2 accessible to vessel traffic from the Federal Navigation Channel. The selected location and configuration were selected to minimize impacts to aquatic resource. In addition, Dock 2 has been designed with an open, pile-supported configuration in order to minimize impacts to the aquatic environment.

Regulated Activities in a Riparian Zone (N.J.A.C. 7:13-11.2) As described at N.J.A.C. 7:13-4.1, a riparian zone exists along every regulated water and includes the land and vegetation within each regulated water as well as the land and vegetation within a certain


Compliance with FHA Rules Ramboll

distance of the regulated water. The Delaware River is not a Category One Water5, a trout production or trout maintenance water, and this segment of the Delaware River does not flow through an area that contains acid producing soils.

Impacts to the riparian zone are limited to the installation of the trestle abutment and sheet piling (280 total linear feet) along the shoreline of the Delaware River, as shown on Drawing 13. The riparian zone in this area is not vegetated. Therefore, no vegetation will be disturbed.

Requirements for a Regulated Activity in Floodway (N.J.A.C. 7:13-11.3) This section sets forth specific design and construction standards that apply to any regulated activity proposed in a floodway.

No mapped floodway for the Delaware River is shown on the current FEMA FIRM Map Panel (No. 34015C0058E) for the Site (see Drawing G-103); therefore, per N.J.A.C. 7:13-3.4(d)2.ii, the floodway limit shall be equal to the limits of the channel. Work within the channel is discussed in Section 7.1.

5 Category One Waters are defined by the Surface Water Quality Standards at N.J.A.C. 7:9B.


Summary and Conclusions Ramboll

8. SUMMARY AND CONCLUSIONS

This Compliance Statement reviewed compliance of the proposed Project with applicable requirements of the Coastal Zone Management Rules (N.J.A.C. 7:7) and Flood Hazard Area Control Act Rules (N.J.A.C. 7:13).

Based on the findings of this review, the Project is in compliance with the applicable requirements of these rules. Project development plans have undergone several design iterations in order to reduce impacts to regulated resources to the maximum extent practicable without impacting the overall Project purpose.

COMPLIANCE STATEMENT IN SUPPORT OF WFD INDIVIDUAL PERMIT APPLICATION DOCK 2 - DRP GIBBSTOWN LOGISTICS CENTER

Ramboll

TABLES

1

Table 1. Coastal Zone Management Rules Applicability Review

N.J.A.C. Section Rule

Potentially Applicable and Addressed in

Compliance Statement?

Special Areas (Subchapter 9)

7:7-9.2 Shellfish habitat No

7:7-9.3 Surf clam areas No

7:7-9.4 Prime fishing areas No

7:7-9.5 Finfish migratory pathways Yes

7:7-9.6 Submerged vegetation habitat Yes

7:7-9.7 Navigation routes Yes

7:7-9.8 Canals No

7:7-9.9 Inlets No

7:7-9.10 Marina moorings No

7:7-9.11 Ports Yes

7:7-9.12 Submerged infrastructure routes Yes

7:7-9.13 Shipwreck and artificial reef habitats No

7:7-9.14 Wet borrow pits No

7:7-9.15 Intertidal and subtidal shallows Yes

7:7-9.16 Dunes No

7:7-9.17 Overwash areas No

7:7-9.18 Coastal high hazard areas No

7:7-9.19 Erosion hazard areas No

7:7-9.20 Barrier island corridor No

7:7-9.21 Bay islands No

7:7-9.22 Beaches No

2





7:7-9.23 Filled water's edge Yes

7:7-9.24 Existing lagoon edges No

7:7-9.25 Flood hazard areas Yes

7:7-9.26 Riparian zones Yes

7:7-9.27 Wetlands No

7:7-9.28 Wetlands buffers No

7:7-9.29 Coastal bluffs No

7:7-9.30 Intermittent stream corridors No

7:7-9.31 Farmland conservation areas No

7:7-9.32 Steep slopes No

7:7-9.33 Dry borrow pits No

7:7-9.34 Historic and archaeological resources Yes

7:7-9.35 Specimen trees No

7:7-9.36 T&E wildlife or plant species habitats Yes

7:7-9.37 Critical wildlife habitat Yes

7:7-9.38 Public open space Yes

7:7-9.39 Special hazard areas Yes

7:7-9.40 Excluded Federal lands No

7:7-9.41 Special urban areas Yes

7:7-9.42 Pinelands National Reserve and Pinelands Protection Area

No

7:7-9.43 Hackensack Meadowlands District No

7:7-9.44 Wild and scenic river corridors No

3





7:7-9.45 Geodetic control reference marks No

7:7-9.46 Hudson River Waterfront Area No

7:7-9.47 Atlantic City No

7:7-9.48 Lands and waters subject to public trust rights Yes

7:7-9.49 Dredged Material Management Areas No

General Water Areas (Subchapter 12)

7:7-12.2 Shellfish aquaculture No

7:7-12.3 Boat Ramps No

7:7-12.4 Docks and piers for cargo & commercial fisheries Yes

7:7-12.5 Recreational docks & piers No

7:7-12.6 Maintenance Dredging No

7:7-12.7 New Dredging Yes

7:7-12.8 Environmental Dredging No

7:7-12.9 Dredged Material Disposal Yes

7:7-12.10 Solid waste or sludge dumping No

7:7-12.11 Filling Yes

7:7-12.12 Mooring No

7:7-12.13 Sand & gravel mining No

7:7-12.14 Bridges No

7:7-12.15 Submerged pipelines No

7:7-12.16 Overhead transmission lines No

7:7-12.17 Dams & impoundments No

7:7-12.18 Outfalls & Intakes No

4





7:7-12.19 Realignment of water areas No

7:7-12.20 Vertical wake or wave attenuation structures No

7:7-12.21 Submerged cables No

7:7-12.22 Artificial reefs No

7:7-12.23 Living shorelines No

7:7-12.24 Miscellaneous uses No

General Location Rules (Subchapter 14)

7:7-14.1 Rules on location of linear development No

7:7-14.2 Basic Location Rule Yes

7:7-14.3 Secondary Impacts Yes

Use Rules (Subchapter 15)

7:7-15.2 Housing No

7:7-15.3 Resort/recreational No

7:7-15.4 Energy facility No

7:7-15.5 Transportation No

7:7-15.6 Public facility No

7:7-15.7 Industry Yes

7:7-15.8 Mining No

7:7-15.9 Port Yes

7:7-15.10 Commercial facility No

7:7-15.11 Coastal engineering No

7:7-15.12 Dredged material placement on land Yes

5





7:7-15.13 National defense facilities use rule No

7:7-15.14 High rise structures No

Resource Rules (Subchapter 16)

7:7-16.2 Marine Fish and Fisheries Yes

7:7-16.3 Water Quality Yes

7:7-16.4 Surface Water Use No

7:7-16.5 Groundwater Use No

7:7-16.6 Stormwater management No

7:7-16.7 Vegetation Yes

7:7-16.8 Air Quality Yes

7:7-16.9 Public Access Yes

7:7-16.10 Scenic Resources & Design Yes

7:7-16.11 Buffers & Compatibility of Uses Yes

7:7-16.12 Traffic Yes

7:7-16.13 Submerged sewage disposal systems No

7:7-16.14 Solid and Hazardous Waste No


Ramboll

FIGURES

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PROJECT AREA(X) = 265,565(Y) = 370,008


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FIGURE1





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A-Line Road

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FIGURE2

STREET MAPDOCK 2


1. WORLD STREET MAPS BASELAYER. ENVIRONMENTAL SYSTEMS RESEARCH INSTITUTE (ESRI), 2015. SOURCE:


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Service Layer Credits:

PROJECT: 1690000609

FIGURE3

BOUNDARY SURVEYDOCK 2


1. TALTA/ACSM BOUNDARY SURVEY FOR GLOUCESTER COUNTY IMPROVEMENT AUTHORITY & E.I. DU PONT DE NEMOURS AND COMPANY, 2015.

SOURCE:



Ramboll

APPENDIX A SITE PHOTOGRAPHS

Site Photographs

DRP Gibbstown Logistics Center 200 North Repauno Ave

Page 1 of 1

Click Here Drag and Drop Image File

Click Photo > Format Tab > Size Group > Shape Height > Down Arrow

Click Here Drag and Drop Image File

Click Photo > Format Tab > Size Group > Shape Height > Down Arrow

Photo 1: View of facing north of the Project Area. Timber pilings from the former double barge berth are

visible in the foreground.

Photo 2: View facing northwest of the Project Area. Remnants of the former double barge berth are visible

in the background.


Ramboll

APPENDIX B NATURAL HERITAGE DATABASE SEARCH & IPAC SEARCH RESULTS

NHP File No. 18-3907573-15547

November 29, 2018

Sean Ireland

Ramboll

101 Carnegie Center, Suite 200

Princeton, NJ 08542

Re: DRP Gibbstown Logistics Center

Block(s) - 8, Lot(s) - Portions of 3, 4 & 4.01


Dear Mr. Ireland:

Thank you for your data request regarding rare species information for the above referenced project site.

Searches of the Natural Heritage Database and the Landscape Project (Version 3.3) are based on a representation of the

boundaries of your project site in our Geographic Information System (GIS). We make every effort to accurately transfer

your project bounds from the topographic map(s) submitted with the Natural Heritage Data Request Form into our

Geographic Information System. We do not typically verify that your project bounds are accurate, or check them against

other sources.

We have checked the Landscape Project habitat mapping and the Biotics Database for occurrences of any rare wildlife

species or wildlife habitat on the referenced site. The Natural Heritage Database was searched for occurrences of rare plant

species or ecological communities that may be on the project site. Please refer to Table 1 (attached) to determine if any rare

plant species, ecological communities, or rare wildlife species or wildlife habitat are documented on site. A detailed report

is provided for each category coded as ‘Yes’ in Table 1.

We have also checked the Landscape Project habitat mapping and Biotics Database for occurrences of rare wildlife species

or wildlife habitat in the immediate vicinity (within ¼ mile) of the referenced site. Additionally, the Natural Heritage

Database was checked for occurrences of rare plant species or ecological communities within ¼ mile of the site. Please

refer to Table 2 (attached) to determine if any rare plant species, ecological communities, or rare wildlife species or wildlife

habitat are documented within the immediate vicinity of the site. Detailed reports are provided for all categories coded as

‘Yes’ in Table 2. These reports may include species that have also been documented on the project site.

We have also checked the Landscape Project habitat mapping and Biotics Database for all occurrences of rare wildlife

species or wildlife habitat within one mile of the referenced site. Please refer to Table 3 (attached) to determine if any rare

wildlife species or wildlife habitat is documented within one mile of the project site. Detailed reports are provided for each

category coded as ‘Yes’ in Table 3. These reports may include species that have also been documented on the project site.

For requests submitted as part of a Flood Hazard Area Control Act (FHACA) rule application, we report records for all rare

plant species and ecological communities tracked by the Natural Heritage Program that may be on, or in the immediate

vicinity of, your project site. A subset of these plant species are also covered by the FHACA rules when the records are

located within one mile of the project site. One mile searches for FHACA plant species will only report precisely located

occurrences for those wetland plant species identified under the FHACA regulations as being critically dependent on the

watercourse. Please refer to Table 3 (attached) to determine if any precisely located rare wetland plant species covered by

MAIL CODE 501-04

DEPARTMENT OF ENVIRONMENTAL PROTECTION

DIVISION OF PARKS & FORESTRY

PHILIP D. MURPHY NEW JERSEY FOREST SERVICE CATHERINE R. MCCABE Governor OFFICE OF NATURAL LANDS MANAGEMENT Commissioner

P.O. BOX 420

SHEILA Y. OLIVER TRENTON, NJ 08625-0420 Lt. Governor Tel. (609) 984-1339 Fax (609) 984-0427

NHP File No. 18-3907573-15547

the FHACA rules have been documented. Detailed reports are provided for each category coded as ‘Yes’ in Table 3.

These reports may include species that have also been documented on, or in the immediate vicinity of, the project site.

The Natural Heritage Program reviews its data periodically to identify priority sites for natural diversity in the State.

Included as priority sites are some of the State’s best habitats for rare and endangered species and ecological communities.

Please refer to Tables 1, 2 and 3 (attached) to determine if any priority sites are located on, in the immediate vicinity, or

within one mile of the project site.

A list of rare plant species and ecological communities that have been documented from the county (or counties),

referenced above, can be downloaded from http://www.state.nj.us/dep/parksandforests/natural/heritage/countylist.html. If

suitable habitat is present at the project site, the species in that list have potential to be present.

Status and rank codes used in the tables and lists are defined in EXPLANATION OF CODES USED IN NATURAL HERITAGE

REPORTS, which can be downloaded from http://www.state.nj.us/dep/parksandforests/natural/heritage/nhpcodes_2010.pdf.

Beginning May 9, 2017, the Natural Heritage Program reports for wildlife species will utilize data from Landscape Project

Version 3.3. If you have questions concerning the wildlife records or wildlife species mentioned in this response, we

recommend that you visit the interactive web application at the following URL,

https://njdep.maps.arcgis.com/apps/webappviewer/index.html?id=0e6a44098c524ed99bf739953cb4d4c7, or contact the

Division of Fish and Wildlife, Endangered and Nongame Species Program at (609) 292-9400.

For additional information regarding any Federally listed plant or animal species, please contact the U.S. Fish & Wildlife

Service, New Jersey Field Office at http://www.fws.gov/northeast/njfieldoffice/endangered/consultation.html.

PLEASE SEE ‘CAUTIONS AND RESTRICTIONS ON NHP DATA’, which can be downloaded from

http://www.state.nj.us/dep/parksandforests/natural/heritage/newcaution2008.pdf.

Thank you for consulting the Natural Heritage Program. The attached invoice details the payment due for processing this

data request. Feel free to contact us again regarding any future data requests.

Sincerely,

Robert J. Cartica

Administrator

c: NHP File No. 18-3907573-15547

NHP File No. 18-3907573-15547

Mail Code 501-04 Department of Environmental Protection

New Jersey Forest Service Office of Natural Lands Management

P.O. Box 420 Trenton, New Jersey 08625-0420 Tel. (609) 984-1339 Fax. (609) 984-1427

Invoice

Date Invoice #

11/29/2018 15547

Bill to: Make check payable to: Ramboll 101 Carnegie Center, Suite 200 Princeton, NJ 08542

DEP - Office of Natural Lands Management And forward with a copy of this statement to: Mail Code 501-04

Office of Natural Lands Management P.O. Box 420 Trenton, New Jersey 08625-0420

Quantity (hrs.) Description Rate (per hr.) Amount

1 Natural Heritage Database search for locational information of rare species and ecological communities. Project: 18-3907573-15547

$ 70.00 $ 70.00

Sean Ireland Project Name: DRP Gibbstown Logistics Center Total $ 70.00

Table 1: On Site Data Request Search Results (6 Possible Reports)

1. Possibly on Project Site Based on Search of Natural Heritage Database: Rare Plant Species and Ecological Communities Currently Recorded in the New Jersey Natural Heritage Database

No

2. Natural Heritage Priority Sites On Site No

3. Rare Wildlife Species or Wildlife Habitat on the Project Site Based on Search of Landscape Project 3.3 Species Based Patches

Yes

4. Vernal Pool Habitat on the Project Site Based on Search of Landscape Project 3.3

No

5. Rare Wildlife Species or Wildlife Habitat on the Project Site Based on Search of Landscape Project 3.3 Stream Habitat File

No

6. Other Animal Species On the Project Site Based on Additional Species Tracked by Endangered and Nongame Species Program

No

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Thursday, November 29, 2018

Page 1 of 1

NHP File No.:18-3907573-15547

Common Name Scientific Name Feature Type Rank Federal ProtectionStatus

State ProtectionStatus

Grank SrankClass

Rare Wildlife Species or Wildlife Habitat on theProject Site Based on Search of

Landscape Project 3.3 Species Based Patches

Aves

Bald Eagle ForagingHaliaeetus leucocephalus

4 NA State Endangered

G5 S1B,S2N

Bald Eagle NestHaliaeetus leucocephalus


G5 S1B,S2N

Bald Eagle WinteringHaliaeetus leucocephalus

3 NA State Threatened G5 S1B,S2N

Great Blue Heron ForagingArdea herodias 2 NA Special Concern G5 S3B,S4N

Osprey ForagingPandion haliaetus 3 NA State Threatened G5 S2B,S4N

Osprey NestPandion haliaetus 3 NA State Threatened G5 S2B,S4N

Osteichthyes

Atlantic Sturgeon Migration Corridor - Juvenile Sighting

Acipenser oxyrinchus 5 Federally Listed Endangered

State Endangered

G3 S1

Shortnose Sturgeon Migration Corridor - Adult Sighting

Acipenser brevirostrum

5 Federally Listed Endangered

State Endangered

G3 S1

Shortnose Sturgeon Migration Corridor - Juvenile Sighting



State Endangered

G3 S1


Page 1 of 1

NHP File No.:18-3907573-15547

Table 2: Vicinity Data Request Search Results (6 possible reports)

1. Immediate Vicinity of the Project Site Based on Search of Natural Heritage Database: Rare Plant Species and Ecological Communities Currently Recorded in the New Jersey Natural Heritage Database

No

2. Natural Heritage Priority Sites within the Immediate Vicinity No

3. Rare Wildlife Species or Wildlife Habitat Within the Immediate Vicinity of the Project Site Based on Search of Landscape Project 3.3 Species Based Patches

Yes

4. Vernal Pool Habitat In the Immediate Vicinity of Project Site Based on Search of Landscape Project 3.3

No

5. Rare Wildlife Species or Wildlife Habitat In the Immediate Vicinity of the Project Site Based on Search of Landscape Project 3.3 Stream Habitat File

No

6. Other Animal Species In the Immediate Vicinity of the Project Site Based on Additional Species Tracked by Endangered and Nongame Species Program

No


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NHP File No.:18-3907573-15547

Class Common Name Feature TypeScientific Name Rank Federal Protection Status

StateProtection Status

Grank Srank

Rare Wildlife Species or Wildlife Habitat Within theImmediate Vicinity of the Project Site Based on Search of


Aves



G5 S1B,S2N



G5 S1B,S2N



Cooper's Hawk Breeding SightingAccipiter cooperii 2 NA Special Concern G5 S3B,S4N


Great Blue Heron Nesting ColonyArdea herodias 2 NA Special Concern G5 S3B,S4N



Osteichthyes


Acipenser oxyrinchus


State Endangered

G3 S1




State Endangered

G3 S1




State Endangered

G3 S1


Page 1 of 1

NHP File No.:18-3907573-15547

Table 3: Within 1 Mile for FHACA Searches (6 possible reports)

1. Rare Plant Species Occurrences Covered by the Flood Hazard Area Control Act Rule Within One Mile of the Project Site Based on Search of Natural Heritage Database

No

2. Natural Heritage Priority Sites within 1 mile No

3. Rare Wildlife Species or Wildlife Habitat Within One Mile of the Project Site Based on Search of Landscape Project 3.3 Species Based Patches

Yes

4. Vernal Pool Habitat Within One Mile of the Project SiteBased on Search of Landscape Project 3.3

Yes

5. Rare Wildlife Species or Wildlife Habitat Within One Mile of the Project Site Based on Search of Landscape Project 3.3 Stream Habitat File

No

6. Other Animal Species Within One Mile of the Project Site Based on Additional Species Tracked by Endangered and Nongame Species Program

No


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Page 1 of 1

NHP File No.: 18-3907573-15547

Class Common Name Scientific Name Feature Type Rank Federal ProtectionStatus


Grank Srank

Rare Wildlife Species or Wildlife Habitat WithinOne Mile of the Project Site Based on Search of


Aves



G5 S1B,S2N



G5 S1B,S2N



Cooper's Hawk Breeding Sighting

Accipiter cooperii 2 NA Special Concern G5 S3B,S4N


Great Blue Heron Nesting Colony

Ardea herodias 2 NA Special Concern G5 S3B,S4N



Osteichthyes


Acipenser oxyrinchus 5 Federally Listed Endangered

State Endangered

G3 S1




State Endangered

G3 S1


Page 1 of 2

NHP File No.:18-3907573-15547

Class Common Name Scientific Name Feature Type Rank Federal ProtectionStatus


Grank Srank

Rare Wildlife Species or Wildlife Habitat WithinOne Mile of the Project Site Based on Search of





State Endangered

G3 S1


Page 2 of 2

NHP File No.:18-3907573-15547

Vernal Pool Habitat Type Vernal Pool Habitat ID

Vernal Pool Habitat WithinOne Mile of the Project Site

Based on Search of Landscape Project 3.3

Potential vernal habitat area 1060

Total number of records: 1


Page 1 of 1

NHP File No.:18-3907573-15547

11/12/2018 IPaC: Explore Location

https://ecos.fws.gov/ipac/location/TYULMK4CJBAXFJC5KTWCTFXDLA/resources#endangered-species 1/18

IPaC resource listThis report is an automatically generated list of species and other resources such as critical habitat (collectively referred to astrust resources) under the U.S. Fish and Wildlife Service's (USFWS) jurisdiction that are known or expected to be on or nearthe project area referenced below. The list may also include trust resources that occur outside of the project area, but thatcould potentially be directly or indirectly aected by activities in the project area. However, determining the likelihood andextent of eects a project may have on trust resources typically requires gathering additional site-specic (e.g.,vegetation/species surveys) and project-specic (e.g., magnitude and timing of proposed activities) information.

Below is a summary of the project information you provided and contact information for the USFWS oce(s) with jurisdictionin the dened project area. Please read the introduction to each section that follows (Endangered Species, Migratory Birds,USFWS Facilities, and NWI Wetlands) for additional information applicable to the trust resources addressed in that section.

LocationGloucester County, New Jersey

U.S. Fish & Wildlife ServiceIPaC

https://ecos.fws.gov/ipac/



Local oceNew Jersey Ecological Services Field Oce

(609) 646-9310 (609) 646-0352

4 E. Jimmie Leeds Road, Suite 4Galloway, NJ 08205

http://www.fws.gov/northeast/njeldoce/Endangered/consultation.html

http://www.fws.gov/northeast/njfieldoffice/Endangered/consultation.html



Endangered speciesThis resource list is for informational purposes only and does not constitute an analysis of project level impacts.

The primary information used to generate this list is the known or expected range of each species. Additional areas ofinuence (AOI) for species are also considered. An AOI includes areas outside of the species range if the species could beindirectly aected by activities in that area (e.g., placing a dam upstream of a sh population, even if that sh does not occurat the dam site, may indirectly impact the species by reducing or eliminating water ow downstream). Because species canmove, and site conditions can change, the species on this list are not guaranteed to be found on or near the project area. Tofully determine any potential eects to species, additional site-specic and project-specic information is often required.

Section 7 of the Endangered Species Act requires Federal agencies to "request of the Secretary information whether anyspecies which is listed or proposed to be listed may be present in the area of such proposed action" for any project that isconducted, permitted, funded, or licensed by any Federal agency. A letter from the local oce and a species list which fulllsthis requirement can only be obtained by requesting an ocial species list from either the Regulatory Review section in IPaC(see directions below) or from the local eld oce directly.

For project evaluations that require USFWS concurrence/review, please return to the IPaC website and request an ocialspecies list by doing the following:

1. Draw the project location and click CONTINUE.2. Click DEFINE PROJECT.3. Log in (if directed to do so).4. Provide a name and description for your project.5. Click REQUEST SPECIES LIST.

Listed species and their critical habitats are managed by the Ecological Services Program of the U.S. Fish and Wildlife Service(USFWS) and the sheries division of the National Oceanic and Atmospheric Administration (NOAA Fisheries ).

Species and critical habitats under the sole responsibility of NOAA Fisheries are not shown on this list. Please contact NOAAFisheries for species under their jurisdiction.

1

2

https://www.fws.gov/ecological-services/

https://www.fisheries.noaa.gov/topic/consultations/endangered-species-act-consultations

http://www.nmfs.noaa.gov/pr/species/esa/listed.htm



1. Species listed under the Endangered Species Act are threatened or endangered; IPaC also shows species that arecandidates, or proposed, for listing. See the listing status page for more information.

2. NOAA Fisheries, also known as the National Marine Fisheries Service (NMFS), is an oce of the National Oceanic andAtmospheric Administration within the Department of Commerce.

The following species are potentially aected by activities in this location:

Birds

Reptiles

Critical habitatsPotential eects to critical habitat(s) in this location must be analyzed along with the endangered species themselves.

THERE ARE NO CRITICAL HABITATS AT THIS LOCATION.

NAME STATUS

Red Knot Calidris canutus rufaThis species only needs to be considered if the following condition applies:

This activity area is upstream of red knot habitat. Consultation is needed ONLY forproposed new or changed petroleum product storage or transport, and for spillresponse planning. No other activity types are expected to aect red knots in thisarea.

No critical habitat has been designated for this species.https://ecos.fws.gov/ecp/species/1864

Threatened

NAME STATUS

Bog Turtle Clemmys muhlenbergiiNo critical habitat has been designated for this species.https://ecos.fws.gov/ecp/species/6962

Threatened

https://www.fws.gov/endangered/laws-policies/esa.html

https://ecos.fws.gov/ipac/status/list

https://www.fisheries.noaa.gov/

https://ecos.fws.gov/ecp/species/1864




Migratory birds

The birds listed below are birds of particular concern either because they occur on the USFWS Birds of Conservation Concern(BCC) list or warrant special attention in your project location. To learn more about the levels of concern for birds on your listand how this list is generated, see the FAQ below. This is not a list of every bird you may nd in this location, nor a guaranteethat every bird on this list will be found in your project area. To see exact locations of where birders and the general publichave sighted birds in and around your project area, visit the E-bird data mapping tool (Tip: enter your location, desired daterange and a species on your list). For projects that occur o the Atlantic Coast, additional maps and models detailing therelative occurrence and abundance of bird species on your list are available. Links to additional information about AtlanticCoast birds, and other important information about your migratory bird list, including how to properly interpret and use yourmigratory bird report, can be found below.

For guidance on when to schedule activities or implement avoidance and minimization measures to reduce impacts tomigratory birds on your list, click on the PROBABILITY OF PRESENCE SUMMARY at the top of your list to see when these birdsare most likely to be present and breeding in your project area.

Certain birds are protected under the Migratory Bird Treaty Act and the Bald and Golden Eagle Protection Act .

Any person or organization who plans or conducts activities that may result in impacts to migratory birds, eagles, and theirhabitats should follow appropriate regulations and consider implementing appropriate conservation measures, as describedbelow.

1. The Migratory Birds Treaty Act of 1918.2. The Bald and Golden Eagle Protection Act of 1940.

Additional information can be found using the following links:

Birds of Conservation Concern http://www.fws.gov/birds/management/managed-species/ birds-of-conservation-concern.phpMeasures for avoiding and minimizing impacts to birds http://www.fws.gov/birds/management/project-assessment-tools-and-guidance/ conservation-measures.phpNationwide conservation measures for birdshttp://www.fws.gov/migratorybirds/pdf/management/nationwidestandardconservationmeasures.pdf

1 2

https://www.fws.gov/birds/management/managed-species/birds-of-conservation-concern.php

http://ebird.org/ebird/map/

https://www.fws.gov/birds/policies-and-regulations/laws-legislations/migratory-bird-treaty-act.php

https://www.fws.gov/birds/policies-and-regulations/laws-legislations/bald-and-golden-eagle-protection-act.php

http://www.fws.gov/birds/management/managed-species/birds-of-conservation-concern.php

http://www.fws.gov/birds/management/project-assessment-tools-and-guidance/conservation-measures.php

http://www.fws.gov/migratorybirds/pdf/management/nationwidestandardconservationmeasures.pdf



NAME BREEDING SEASON (IF A BREEDINGSEASON IS INDICATED FOR A BIRD ONYOUR LIST, THE BIRD MAY BREED IN YOURPROJECT AREA SOMETIME WITHIN THETIMEFRAME SPECIFIED, WHICH IS A VERYLIBERAL ESTIMATE OF THE DATES INSIDEWHICH THE BIRD BREEDS ACROSS ITSENTIRE RANGE. "BREEDS ELSEWHERE"INDICATES THAT THE BIRD DOES NOTLIKELY BREED IN YOUR PROJECT AREA.)

Bald Eagle Haliaeetus leucocephalusThis is not a Bird of Conservation Concern (BCC) in this area, but warrants attentionbecause of the Eagle Act or for potential susceptibilities in oshore areas from certaintypes of development or activities.https://ecos.fws.gov/ecp/species/1626

Breeds Oct 15 to Aug 31

Black-billed Cuckoo Coccyzus erythropthalmusThis is a Bird of Conservation Concern (BCC) throughout its range in the continental USAand Alaska.https://ecos.fws.gov/ecp/species/9399

Breeds May 15 to Oct 10

Bobolink Dolichonyx oryzivorusThis is a Bird of Conservation Concern (BCC) throughout its range in the continental USAand Alaska.

Breeds May 20 to Jul 31

Canada Warbler Cardellina canadensisThis is a Bird of Conservation Concern (BCC) throughout its range in the continental USAand Alaska.

Breeds May 20 to Aug 10

Cerulean Warbler Dendroica ceruleaThis is a Bird of Conservation Concern (BCC) throughout its range in the continental USAand Alaska.https://ecos.fws.gov/ecp/species/2974

Breeds Apr 29 to Jul 20






Dunlin Calidris alpina arcticolaThis is a Bird of Conservation Concern (BCC) only in particular Bird Conservation Regions(BCRs) in the continental USA

Breeds elsewhere

Eastern Whip-poor-will Antrostomus vociferusThis is a Bird of Conservation Concern (BCC) throughout its range in the continental USAand Alaska.


Golden Eagle Aquila chrysaetosThis is not a Bird of Conservation Concern (BCC) in this area, but warrants attentionbecause of the Eagle Act or for potential susceptibilities in oshore areas from certaintypes of development or activities.https://ecos.fws.gov/ecp/species/1680

Breeds elsewhere

Golden-winged Warbler Vermivora chrysopteraThis is a Bird of Conservation Concern (BCC) throughout its range in the continental USAand Alaska.https://ecos.fws.gov/ecp/species/8745


Gull-billed Tern Gelochelidon niloticaThis is a Bird of Conservation Concern (BCC) throughout its range in the continental USAand Alaska.https://ecos.fws.gov/ecp/species/9501


Hudsonian Godwit Limosa haemasticaThis is a Bird of Conservation Concern (BCC) throughout its range in the continental USAand Alaska.

Breeds elsewhere

King Rail Rallus elegansThis is a Bird of Conservation Concern (BCC) throughout its range in the continental USAand Alaska.https://ecos.fws.gov/ecp/species/8936

Breeds May 1 to Sep 5







Least Tern Sterna antillarumThis is a Bird of Conservation Concern (BCC) only in particular Bird Conservation Regions(BCRs) in the continental USA

Breeds Apr 20 to Sep 10

Lesser Yellowlegs Tringa avipesThis is a Bird of Conservation Concern (BCC) throughout its range in the continental USAand Alaska.https://ecos.fws.gov/ecp/species/9679

Breeds elsewhere

Long-eared Owl asio otusThis is a Bird of Conservation Concern (BCC) throughout its range in the continental USAand Alaska.https://ecos.fws.gov/ecp/species/3631

Breeds elsewhere

Prairie Warbler Dendroica discolorThis is a Bird of Conservation Concern (BCC) throughout its range in the continental USAand Alaska.


Prothonotary Warbler Protonotaria citreaThis is a Bird of Conservation Concern (BCC) throughout its range in the continental USAand Alaska.

Breeds Apr 1 to Jul 31

Red-headed Woodpecker Melanerpes erythrocephalusThis is a Bird of Conservation Concern (BCC) throughout its range in the continental USAand Alaska.

Breeds May 10 to Sep 10

Red-throated Loon Gavia stellataThis is a Bird of Conservation Concern (BCC) throughout its range in the continental USAand Alaska.

Breeds elsewhere





Probability of Presence Summary

Ruddy Turnstone Arenaria interpres morinellaThis is a Bird of Conservation Concern (BCC) only in particular Bird Conservation Regions(BCRs) in the continental USA

Breeds elsewhere

Rusty Blackbird Euphagus carolinusThis is a Bird of Conservation Concern (BCC) throughout its range in the continental USAand Alaska.

Breeds elsewhere

Semipalmated Sandpiper Calidris pusillaThis is a Bird of Conservation Concern (BCC) throughout its range in the continental USAand Alaska.

Breeds elsewhere

Short-billed Dowitcher Limnodromus griseusThis is a Bird of Conservation Concern (BCC) throughout its range in the continental USAand Alaska.https://ecos.fws.gov/ecp/species/9480

Breeds elsewhere

Snowy Owl Bubo scandiacusThis is a Bird of Conservation Concern (BCC) throughout its range in the continental USAand Alaska.

Breeds elsewhere

Willet Tringa semipalmataThis is a Bird of Conservation Concern (BCC) throughout its range in the continental USAand Alaska.

Breeds Apr 20 to Aug 5

Wood Thrush Hylocichla mustelinaThis is a Bird of Conservation Concern (BCC) throughout its range in the continental USAand Alaska.





The graphs below provide our best understanding of when birds of concern are most likely to be present in your projectarea. This information can be used to tailor and schedule your project activities to avoid or minimize impacts to birds. Pleasemake sure you read and understand the FAQ “Proper Interpretation and Use of Your Migratory Bird Report” before using orattempting to interpret this report.

Probability of Presence ( )

Each green bar represents the bird's relative probability of presence in the 10km grid cell(s) your project overlaps during aparticular week of the year. (A year is represented as 12 4-week months.) A taller bar indicates a higher probability of speciespresence. The survey eort (see below) can be used to establish a level of condence in the presence score. One can havehigher condence in the presence score if the corresponding survey eort is also high.

How is the probability of presence score calculated? The calculation is done in three steps:

1. The probability of presence for each week is calculated as the number of survey events in the week where the species wasdetected divided by the total number of survey events for that week. For example, if in week 12 there were 20 surveyevents and the Spotted Towhee was found in 5 of them, the probability of presence of the Spotted Towhee in week 12 is0.25.

2. To properly present the pattern of presence across the year, the relative probability of presence is calculated. This is theprobability of presence divided by the maximum probability of presence across all weeks. For example, imagine theprobability of presence in week 20 for the Spotted Towhee is 0.05, and that the probability of presence at week 12 (0.25) isthe maximum of any week of the year. The relative probability of presence on week 12 is 0.25/0.25 = 1; at week 20 it is0.05/0.25 = 0.2.

3. The relative probability of presence calculated in the previous step undergoes a statistical conversion so that all possiblevalues fall between 0 and 10, inclusive. This is the probability of presence score.

To see a bar's probability of presence score, simply hover your mouse cursor over the bar.

Breeding Season ( )Yellow bars denote a very liberal estimate of the time-frame inside which the bird breeds across its entire range. If there areno yellow bars shown for a bird, it does not breed in your project area.

Survey Eort ( )Vertical black lines superimposed on probability of presence bars indicate the number of surveys performed for that speciesin the 10km grid cell(s) your project area overlaps. The number of surveys is expressed as a range, for example, 33 to 64surveys.



no data survey eort breeding season probability of presence

To see a bar's survey eort range, simply hover your mouse cursor over the bar.

No Data ( )A week is marked as having no data if there were no survey events for that week.

Survey TimeframeSurveys from only the last 10 years are used in order to ensure delivery of currently relevant information. The exception tothis is areas o the Atlantic coast, where bird returns are based on all years of available data, since data in these areas iscurrently much more sparse.

SPECIES JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC

Bald EagleNon-BCC Vulnerable (Thisis not a Bird ofConservation Concern(BCC) in this area, butwarrants attention becauseof the Eagle Act or forpotential susceptibilities inoshore areas from certaintypes of development oractivities.)

Black-billed CuckooBCC Rangewide (CON) (Thisis a Bird of ConservationConcern (BCC) throughoutits range in the continentalUSA and Alaska.)

BobolinkBCC Rangewide (CON) (Thisis a Bird of ConservationConcern (BCC) throughoutits range in the continentalUSA and Alaska.)

Canada WarblerBCC Rangewide (CON) (Thisis a Bird of ConservationConcern (BCC) throughoutits range in the continentalUSA and Alaska.)



Cerulean WarblerBCC Rangewide (CON) (Thisis a Bird of ConservationConcern (BCC) throughoutits range in the continentalUSA and Alaska.)

DunlinBCC - BCR (This is a Bird ofConservation Concern(BCC) only in particular BirdConservation Regions(BCRs) in the continentalUSA)

Eastern Whip-poor-willBCC Rangewide (CON) (Thisis a Bird of ConservationConcern (BCC) throughoutits range in the continentalUSA and Alaska.)

Golden EagleNon-BCC Vulnerable (Thisis not a Bird ofConservation Concern(BCC) in this area, butwarrants attention becauseof the Eagle Act or forpotential susceptibilities inoshore areas from certaintypes of development oractivities.)

Golden-winged WarblerBCC Rangewide (CON) (Thisis a Bird of ConservationConcern (BCC) throughoutits range in the continentalUSA and Alaska.)

Gull-billed TernBCC Rangewide (CON) (Thisis a Bird of ConservationConcern (BCC) throughoutits range in the continentalUSA and Alaska.)



Hudsonian GodwitBCC Rangewide (CON) (Thisis a Bird of ConservationConcern (BCC) throughoutits range in the continentalUSA and Alaska.)

King RailBCC Rangewide (CON) (Thisis a Bird of ConservationConcern (BCC) throughoutits range in the continentalUSA and Alaska.)


Least TernBCC - BCR (This is a Bird ofConservation Concern(BCC) only in particular BirdConservation Regions(BCRs) in the continentalUSA)

Lesser YellowlegsBCC Rangewide (CON) (Thisis a Bird of ConservationConcern (BCC) throughoutits range in the continentalUSA and Alaska.)

Long-eared OwlBCC Rangewide (CON) (Thisis a Bird of ConservationConcern (BCC) throughoutits range in the continentalUSA and Alaska.)

Prairie WarblerBCC Rangewide (CON) (Thisis a Bird of ConservationConcern (BCC) throughoutits range in the continentalUSA and Alaska.)

Prothonotary WarblerBCC Rangewide (CON) (Thisis a Bird of ConservationConcern (BCC) throughoutits range in the continentalUSA and Alaska.)



Red-headedWoodpeckerBCC Rangewide (CON) (Thisis a Bird of ConservationConcern (BCC) throughoutits range in the continentalUSA and Alaska.)

Red-throated LoonBCC Rangewide (CON) (Thisis a Bird of ConservationConcern (BCC) throughoutits range in the continentalUSA and Alaska.)

Ruddy TurnstoneBCC - BCR (This is a Bird ofConservation Concern(BCC) only in particular BirdConservation Regions(BCRs) in the continentalUSA)

Rusty BlackbirdBCC Rangewide (CON) (Thisis a Bird of ConservationConcern (BCC) throughoutits range in the continentalUSA and Alaska.)

SemipalmatedSandpiperBCC Rangewide (CON) (Thisis a Bird of ConservationConcern (BCC) throughoutits range in the continentalUSA and Alaska.)

Short-billed DowitcherBCC Rangewide (CON) (Thisis a Bird of ConservationConcern (BCC) throughoutits range in the continentalUSA and Alaska.)

Snowy OwlBCC Rangewide (CON) (Thisis a Bird of ConservationConcern (BCC) throughoutits range in the continentalUSA and Alaska.)




WilletBCC Rangewide (CON) (Thisis a Bird of ConservationConcern (BCC) throughoutits range in the continentalUSA and Alaska.)

Wood ThrushBCC Rangewide (CON) (Thisis a Bird of ConservationConcern (BCC) throughoutits range in the continentalUSA and Alaska.)

Tell me more about conservation measures I can implement to avoid or minimize impacts to migratory birds.

Nationwide Conservation Measures describes measures that can help avoid and minimize impacts to all birds at any location year round.Implementation of these measures is particularly important when birds are most likely to occur in the project area. When birds may bebreeding in the area, identifying the locations of any active nests and avoiding their destruction is a very helpful impact minimization measure.To see when birds are most likely to occur and be breeding in your project area, view the Probability of Presence Summary. Additionalmeasures and/or permits may be advisable depending on the type of activity you are conducting and the type of infrastructure or bird speciespresent on your project site.

What does IPaC use to generate the migratory birds potentially occurring in my specied location?

The Migratory Bird Resource List is comprised of USFWS Birds of Conservation Concern (BCC) and other species that may warrant specialattention in your project location.

The migratory bird list generated for your project is derived from data provided by the Avian Knowledge Network (AKN). The AKN data is basedon a growing collection of survey, banding, and citizen science datasets and is queried and ltered to return a list of those birds reported asoccurring in the 10km grid cell(s) which your project intersects, and that have been identied as warranting special attention because they are aBCC species in that area, an eagle (Eagle Act requirements may apply), or a species that has a particular vulnerability to oshore activities ordevelopment.

Again, the Migratory Bird Resource list includes only a subset of birds that may occur in your project area. It is not representative of all birdsthat may occur in your project area. To get a list of all birds potentially present in your project area, please visit the E-bird Explore Data Tool.

What does IPaC use to generate the probability of presence graphs for the migratory birds potentially occurring in my specied location?

The probability of presence graphs associated with your migratory bird list are based on data provided by the Avian Knowledge Network (AKN).This data is derived from a growing collection of survey, banding, and citizen science datasets .

http://www.fws.gov/migratorybirds/pdf/management/nationwidestandardconservationmeasures.pdf

https://www.fws.gov/birds/management/project-assessment-tools-and-guidance/conservation-measures.php

https://www.fws.gov/birds/policies-and-regulations/permits.php


http://www.avianknowledge.net/

https://data.pointblue.org/api/v3/annual-summaries-about-data-types.html

https://www.fws.gov/birds/management/managed-species/eagle-management.php

http://ebird.org/ebird/GuideMe?cmd=changeLocation

http://www.avianknowledge.net/

https://data.pointblue.org/api/v3/annual-summaries-about-data-types.html



Probability of presence data is continuously being updated as new and better information becomes available. To learn more about how theprobability of presence graphs are produced and how to interpret them, go the Probability of Presence Summary and then click on the "Tell meabout these graphs" link.

How do I know if a bird is breeding, wintering, migrating or present year-round in my project area?

To see what part of a particular bird's range your project area falls within (i.e. breeding, wintering, migrating or year-round), you may refer tothe following resources: The Cornell Lab of Ornithology All About Birds Bird Guide, or (if you are unsuccessful in locating the bird of interestthere), the Cornell Lab of Ornithology Neotropical Birds guide. If a bird on your migratory bird species list has a breeding season associated withit, if that bird does occur in your project area, there may be nests present at some point within the timeframe specied. If "Breeds elsewhere" isindicated, then the bird likely does not breed in your project area.

What are the levels of concern for migratory birds?

Migratory birds delivered through IPaC fall into the following distinct categories of concern:

1. "BCC Rangewide" birds are Birds of Conservation Concern (BCC) that are of concern throughout their range anywhere within the USA(including Hawaii, the Pacic Islands, Puerto Rico, and the Virgin Islands);

2. "BCC - BCR" birds are BCCs that are of concern only in particular Bird Conservation Regions (BCRs) in the continental USA; and3. "Non-BCC - Vulnerable" birds are not BCC species in your project area, but appear on your list either because of the Eagle Act requirements

(for eagles) or (for non-eagles) potential susceptibilities in oshore areas from certain types of development or activities (e.g. oshoreenergy development or longline shing).

Although it is important to try to avoid and minimize impacts to all birds, eorts should be made, in particular, to avoid and minimize impacts tothe birds on this list, especially eagles and BCC species of rangewide concern. For more information on conservation measures you canimplement to help avoid and minimize migratory bird impacts and requirements for eagles, please see the FAQs for these topics.

Details about birds that are potentially aected by oshore projects

For additional details about the relative occurrence and abundance of both individual bird species and groups of bird species within yourproject area o the Atlantic Coast, please visit the Northeast Ocean Data Portal. The Portal also oers data and information about other taxabesides birds that may be helpful to you in your project review. Alternately, you may download the bird model results les underlying the portalmaps through the NOAA NCCOS Integrative Statistical Modeling and Predictive Mapping of Marine Bird Distributions and Abundance on theAtlantic Outer Continental Shelf project webpage.

Bird tracking data can also provide additional details about occurrence and habitat use throughout the year, including migration. Models relyingon survey data may not include this information. For additional information on marine bird tracking data, see the Diving Bird Study and thenanotag studies or contact Caleb Spiegel or Pam Loring.

https://www.allaboutbirds.org/guide/search/

https://neotropical.birds.cornell.edu/Species-Account/nb/home


https://www.fws.gov/birds/management/managed-species/bald-and-golden-eagle-information.php

http://www.northeastoceandata.org/data-explorer/?birds

https://coastalscience.noaa.gov/project/statistical-modeling-marine-bird-distributions/

http://www.boem.gov/AT-12-02/

http://www.boem.gov/AT-13-01/

mailto:[email protected]




What if I have eagles on my list?

If your project has the potential to disturb or kill eagles, you may need to obtain a permit to avoid violating the Eagle Act should such impactsoccur.

Proper Interpretation and Use of Your Migratory Bird Report

The migratory bird list generated is not a list of all birds in your project area, only a subset of birds of priority concern. To learn more about howyour list is generated, and see options for identifying what other birds may be in your project area, please see the FAQ “What does IPaC use togenerate the migratory birds potentially occurring in my specied location”. Please be aware this report provides the “probability of presence”of birds within the 10 km grid cell(s) that overlap your project; not your exact project footprint. On the graphs provided, please also lookcarefully at the survey eort (indicated by the black vertical bar) and for the existence of the “no data” indicator (a red horizontal bar). A highsurvey eort is the key component. If the survey eort is high, then the probability of presence score can be viewed as more dependable. Incontrast, a low survey eort bar or no data bar means a lack of data and, therefore, a lack of certainty about presence of the species. This list isnot perfect; it is simply a starting point for identifying what birds of concern have the potential to be in your project area, when they might bethere, and if they might be breeding (which means nests might be present). The list helps you know what to look for to conrm presence, andhelps guide you in knowing when to implement conservation measures to avoid or minimize potential impacts from your project activities,should presence be conrmed. To learn more about conservation measures, visit the FAQ “Tell me about conservation measures I canimplement to avoid or minimize impacts to migratory birds” at the bottom of your migratory bird trust resources page.

FacilitiesWildlife refuges and sh hatcheries

REFUGE AND FISH HATCHERY INFORMATION IS NOT AVAILABLE AT THIS TIME

Wetlands in the National Wetlands InventoryImpacts to NWI wetlands and other aquatic habitats may be subject to regulation under Section 404 of the Clean Water Act,or other State/Federal statutes.

For more information please contact the Regulatory Program of the local U.S. Army Corps of Engineers District.

https://www.fws.gov/birds/policies-and-regulations/permits/need-a-permit.php

http://www.fws.gov/wetlands/

http://www.usace.army.mil/Missions/CivilWorks/RegulatoryProgramandPermits.aspx



Please note that the NWI data being shown may be out of date. We are currently working to update our NWI data set. Werecommend you verify these results with a site visit to determine the actual extent of wetlands on site.

This location overlaps the following wetlands:

Data limitations

The Service's objective of mapping wetlands and deepwater habitats is to produce reconnaissance level information on the location, type andsize of these resources. The maps are prepared from the analysis of high altitude imagery. Wetlands are identied based on vegetation, visiblehydrology and geography. A margin of error is inherent in the use of imagery; thus, detailed on-the-ground inspection of any particular site mayresult in revision of the wetland boundaries or classication established through image analysis.

The accuracy of image interpretation depends on the quality of the imagery, the experience of the image analysts, the amount and quality ofthe collateral data and the amount of ground truth verication work conducted. Metadata should be consulted to determine the date of thesource imagery used and any mapping problems.

Wetlands or other mapped features may have changed since the date of the imagery or eld work. There may be occasional dierences inpolygon boundaries or classications between the information depicted on the map and the actual conditions on site.

Data exclusions

Certain wetland habitats are excluded from the National mapping program because of the limitations of aerial imagery as the primary datasource used to detect wetlands. These habitats include seagrasses or submerged aquatic vegetation that are found in the intertidal and subtidalzones of estuaries and nearshore coastal waters. Some deepwater reef communities (coral or tubercid worm reefs) have also been excludedfrom the inventory. These habitats, because of their depth, go undetected by aerial imagery.

Data precautions

Federal, state, and local regulatory agencies with jurisdiction over wetlands may dene and describe wetlands in a dierent manner than thatused in this inventory. There is no attempt, in either the design or products of this inventory, to dene the limits of proprietary jurisdiction ofany Federal, state, or local government or to establish the geographical scope of the regulatory programs of government agencies. Personsintending to engage in activities involving modications within or adjacent to wetland areas should seek the advice of appropriate federal, state,or local agencies concerning specied agency regulatory programs and proprietary jurisdictions that may aect such activities.

RIVERINER1UBV

A full description for each wetland code can be found at the National Wetlands Inventory website

https://fwsprimary.wim.usgs.gov/decoders/wetlands.aspx?CodeURL=R1UBV

https://fwsprimary.wim.usgs.gov/decoders/wetlands.aspx


Ramboll

APPENDIX C SUBMERGED AQUATIC VEGETATION SURVEY REPORT

October 19, 2018

Via Email ([email protected])

Laura George, Principal Consultant

Ramboll

1760 Market Street

Suite 1000


Dear Ms. George:

This letter report has been prepared to summarize the findings of a visual submerged aquatic vegetation (SAV)

survey conducted by Matrix New World Engineering (Matrix) in support planned improvements at the above

referenced site. The purpose of the SAV visual survey is to determine if seagrass beds are present and, if present,

to physically identify and field locate the extents of SAV within the evaluation area. The sections below provide a

brief overview of the project background, narrative descriptions of our methods for conducting the visual survey

along with a summary of our findings.

Under the State coastal zone management rules submerged aquatic

vegetation (SAV) habitat is characterized as those water areas supporting or

documented as previously supporting rooted, submerged vascular plants

such as widgeon grass (Ruppia maritima), sago pondweed (Potamogeton

pectinatus), horned pondweed (Zannichellia palustris), and eelgrass

(Zostera marina). Other submerged vegetation species in lesser quantities

include, but are not limited to, the following: water weed (Elodea nuttalli),

estuary pipewort (Eriocaulon parkeri), eastern grasswort (Liaeopsis

chinesis), nodding waternymph (Naja flexilis), yellow pond-lily (Nuphar

variegatum), curly pondweed (Potamogeton crispus), ribbonleaf pondweed

(Potamogeton epihydrus), claspingleaf pondweed (Potamogeton

perfoliatus), small pondweed (Potamogeton pusillus), water bulrush

(Scirpus subterminalis) and American eelgrass(Vallisneria americana).

Previous SAV surveys/investigations, conducted by Matrix and others, have

confirmed the presence of SAV, specifically American eelgrass (Vallisneria

americana), within the vicinity of the evaluation area subject to this survey.

A plate depicting V. americana is included as Figure 1. An aerial

photograph depicting the evaluation area subject to the SAV survey is

included as Figure 2, below.

Figure 1: Vallisneria americana

https://www.google.com/url?sa=i&rct=j&q=&esrc=s&source=images&cd=&cad=rja&uact=8&ved=2ahUKEwjF1fGEmpPeAhUJT98KHV50A_8QjRx6BAgBEAU&url=https://www.thegreenmachineonline.com/shop/vallisneria-americana-natans/&psig=AOvVaw2GcUea4twdzZVKFw_GNC-t&ust=1540062371742149

of 3

On September 28, 2018, representatives from Matrix conducted a visual SAV survey to determine if seagrass beds

are present within the evaluation area and, if present, to identify and field locate the extents of SAV. Survey

procedures utilized modified exploratory and quantitative sampling survey methodologies presented within the

Seagrass Survey Guidelines for New Jersey, 1991.

Visual surveys were conducted by scientific divers, Dr. Paul Bologna and Robert Fiorile. The visual surveys were

initiated along the shoreline and extended to deeper water areas that were no greater than 10’ deep at the time of

survey. Where SAV was found to be present, the footprint of the SAV bed “edges” or limits were identified and

staked in the field using 1-inch diameter, 10’ long polyvinyl chloride (PVC) piping. The bed limits were then field

located using global positioning system (DGPS) with sub-meter accuracy. Recorded coordinate positions were

forwarded to Ramboll to include on a plan depicting the bed limits and existing bathymetry.

The visual survey confirmed the presence of an extensive SAV bed that extends throughout the evaluation area.

Presence of SAV was observed in shallower water areas that were less than 10-feet deep at the time of survey. The

only species of SAV found to be present within the evaluation area was V. americana. At the time of survey, plants

were rooted in the sediment with full live leaf blades present. It was also noted that beds had initiated turion (winter

buds) development. Turion development appeared to be in intermediate stage with well-developed turions present.

Spatial coverage and shoot density within the evaluation area was found to be consistent with other recently

observed beds approximately 1-mile upstream. An aerial photograph depicting the bed limits recorded during the

survey is provided as Figure 2, below.

Figure 2: Observed SAV bed limits recorded within the evaluation area

of 3

This concludes the summary of our findings regarding the visual SAV. Should you have any questions regarding

our findings or require additional information/clarification, please do not hesitate to contact me at (732) 278-6226

or by email at [email protected].

Sincerely,

Robert Fiorile

Senior Scientist



Ramboll

APPENDIX D STURGEON IMPACT ASSESSMENT REPORT

Prepared for: Delaware River Partners LLC Gibbstown, NJ

Prepared By: Ramboll US Corporation Philadelphia, PA

Date: February 2019

Project Number: 1690000609

ATLANTIC STURGEON AND SHORTNOSE STURGEON IMPACT ASSESSMENT PROPOSED DOCK 2 AT DRP GIBBSTOWN LOGISTICS CENTER, GIBBSTOWN, NEW JERSEY

ATLANTIC AND SHORTNOSE STURGEON IMPACT ASSESSMENT REPORT i

Contents Ramboll

CONTENTS

1. INTRODUCTION 1 1.1 Location 1 1.2 Project History 1

2. PROPOSED PROJECT 3 2.1 Berth Construction 3 2.2 Dredging 4 2.3 Construction Schedule 5

3. MEASURES TO AVOID AND MINIMIZE EFFECT 6

4. DESCRIPTION OF ACTION AREA 7

5. IDENTIFICATION OF LISTED SPECIES IN THE ACTION AREA 8

6. DESCRIPTION AND LIFE HISTORY OF ATLANTIC AND SHORTNOSE STURGEON 9 6.1 Atlantic Sturgeon 9 6.1.1 Life Stages 9 6.2 Shortnose Sturgeon 10

7. IDENTIFICATION OF DESIGNATED CRITICAL HABITAT 14

8. EFFECTS OF THE ACTION 16 8.1 Effects of Dredging 16 8.1.1 Mechanical Dredging 16 8.1.2 Water Quality Effects from Dredging 17 8.1.3 Effects of Dredging on Habitat 18 8.1.4 Effects of In-water Construction Activities 18 8.1.5 Noise Associated with Pile Installation 18 8.1.6 Physical Effects of Pile Driving 19 8.1.7 Behavioral Effects of Pile Driving 20 8.2 Effects of Vessel Traffic from Construction Activities 21 8.3 Effects of Vessel Traffic from Dock 2 Operations 21 8.4 Effects of Ballast Water Intake 22 8.4.1 Effects of the Action on Essential Element of Critical Habitat 23

9. CONCLUSION 24

10. REFERENCES 25

TABLES

Table 1: General Schedule of Construction

Table 2: Listed Species in the Action Area

Table 3: Estimated Distances to Sturgeon Injury and Behavioral Thresholds

Table 4: Annual Estimated Vessel Calls at Gibbstown Logistics Center

ATLANTIC AND SHORTNOSE STURGEON IMPACT ASSESSMENT REPORT ii

Contents Ramboll

FIGURES

Figure 1: Site Location

Figure 2: Action Area

ATLANTIC AND SHORTNOSE STURGEON IMPACT ASSESSMENT REPORT i



ACE Ashepoo, Combahee, and Edisto

ACOE Army Corps of Engineers

ASMFC Atlantic States Marine Fisheries Council

ASSRT Atlantic Sturgeon Status Review Team

BA Biological Assessment

BBL Barrel

BMP Best Management Practice

BOD Biological Oxygen Demand

CB Chesapeake Bay

CDF Confined Disposal Facility

CFR Code of Federal Regulations

COLREGS International Regulations for Preventing Collisions at Sea

COC Chemicals of Concern

CV Coefficient of Variation

CWA Clean Water Act

CY Cubic Yard

dB: Decibel

DDFW Delaware Division of Fish and Wildlife

DNREC Delaware Division of Natural Resources and Environmental Control

DO Dissolved Oxygen

DOA Department of Army

DOT U. S. Department of Transportation

DPCC Discharge Prevention Containment and Countermeasure Plan

DPS: Distinct Population Segment

DRBC Delaware River Basin Commission

DRP Delaware River Partners LLC

EDC Endocrine Disrupting Chemicals

ESA: Endangered Species Act

ESC Ecological Screening Criteria

ESD Emergency Shut Down

FERC Federal Energy Regulatory Commission

ATLANTIC AND SHORTNOSE STURGEON IMPACT ASSESSMENT REPORT ii


FHWA Federal Highway Administration

FL: Fork Length

FRP Facility Response Plan

FSWEL Freshwater Severe Effects Level

FT Feet

GAO: Government Accountability Office

GARFO Greater Atlantic Regional Fisheries Office

GOM: Gulf of Maine

ITS: Incidental Take Statement

LNG: Liquefied Natural Gas

MG/L Milligrams per Liter

MLLW: Mean Lower Low Water

MM Millimeters

MT Metric Ton

NAVD88 North American Vertical Datum of 1988

NEFSC North East Fisheries Science Center

NJAC New Jersey Administrative Code

NJDEP New Jersey Department of Environmental Protection

NJPDES New Jersey Pollutant Discharge Elimination System

NJRDCSRS New Jersey Residential Direct Contact Soil Remediation Standards

NLAA Not Likely to Adversely Affect

NMFS: National Marine Fisheries Service

NOAA National Oceanic and Atmospheric Administration

NRC United States Nuclear Regulatory Commission

NRC: Nuclear Regulatory Commission

NYB New York Bight

PAH: Polycyclic Aromatic Hydrocarbon

PBF Physical and Biological Factor

PCBs Polychlorinated Biphenyls

PCOE: Philadelphia District of the U.S. Army Corps of Engineers

PMT: Paulsboro Marine Terminal

RCP Reinforced Concrete Pipe

RKM: River Kilometer

ATLANTIC AND SHORTNOSE STURGEON IMPACT ASSESSMENT REPORT iii


RM River Mile

RMS: Root Mean Square

RoRo: Roll-on, Roll-off

RPM: Reasonable and Prudent Measures

SA South Atlantic

SAF: Simplified Attenuation Formula

SAV: Submerged Aquatic Vegetation

SEL: Sound Exposure Level

SESC Soil Erosion and Sediment Control

SF: Square Feet

SMA Seasonal Management Area

SPCC Spill Prevention Control and Countermeasures

SPPP Stormwater Pollution Prevention Plan

sSEL: Single Strike SEL

SSSRT Shortnose Sturgeon Status Review Team

TEU: Twenty-foot Equivalent Units

TL Total Length

TOC Total Organic Carbon

TSPA Toxic Catastrophe Prevention Act

TSS Total Suspended Solids

USCG United States Coast Guard

USEPA United States Environmental Protection Agency

USFWS United States Fish and Wildlife Service

USGS United States Geological Survey

USN United States Navy

UTL Upper Tolerance Limit

WOTUS: Waters of the United States

WSDOT Washington State Department of Transportation

YOY: Young-Of-the-Year

ATLANTIC AND SHORTNOSE STURGEON IMPACT ASSESSMENT REPORT 1


1. INTRODUCTION

Delaware River Partners LLC (“DRP”) is actively redeveloping the former DuPont Repauno Works Site (the “Site” or “Property”), a brownfield site situated on the Delaware River in Greenwich Township, Gloucester County, New Jersey, into a deep-water seaport and logistics center referred to as DRP Gibbstown Logistics Center (“GLC”). In response to significant positive interest from potential users of port services at the Site, DRP seeks to add a second dock (“Dock 2”) to transload bulk liquids products (the “Project” or “Action”). The proposed Dock 2 will be in addition to the current development of a single, multi-purpose berth (“Dock 1” or “multi-purpose dock”), which is currently under construction. The addition of Dock 2 will allow better utilization of the single berth multi-purpose dock for the other permitted cargos, based on current market demand and projections.

This report provides an assessment of the potential effects of a proposed Dock 2 at the GLC on federally-listed threatened or endangered species and critical habitat under the auspices of the National Marine Fisheries Services (“NMFS”). NMFS issued a Biological Opinion (“BiOp”) in December of 2017 for the GLC Project (as defined below). The 2017 BiOp (NMFS 2017c) indicated increased vessel traffic could result in a small take of shortnose and Atlantic surgeon due to vessel strikes. No take from other activities was identified. The operation of Dock 2 is not anticipated to increase vessel traffic on the Delaware River and no additional take of shortnose or Atlantic surgeon is expected from the proposed Action. This assessment evaluates the potential effects of the proposed Action and demonstrates that the activity may affect but is not likely to adversely affect listed species.

1.1 Location The proposed Project is located at the property formerly known as the DuPont Repauno Works at 200 North Repauno Avenue in Gibbstown, Gloucester County, New Jersey ("Project Site"). The Project Site is located at river mile (“RM”) 861 and at Latitude N 39.845/Longitude W 75.306 (see Figure 1). Dock 2 would be located west (downriver) of Dock 1, which is currently under construction, and would utilize the landside marine terminal infrastructure at GLC that will be constructed at the Project Site.

1.2 Project History In January 2017, DRP submitted an application for an individual permit to United States Army Corp of Engineers, Philadelphia District (PCOE) for Dock 1 and supporting infrastructure at the Site (“GLC Project”). PCOE initiated informal Section 7 consultation with NMFS on March 7, 2017 by providing a determination that the proposed GLC Project "is not likely to adversely affect [NLAA] any listed species under NMFS jurisdiction." Thereafter, through the consultation process with NMFS, PCOE developed and submitted a final Biological Assessment on August 11, 2017. On December 8, 2017, NMFS issued a BiOp (NMFS 2017c) stating that the construction and operation of the proposed GLC Project will result in an increase of 91 large commercial cargo vessels transiting the Delaware River each year. The BiOp stated that the GLC Project “will result in an increase in vessel strikes of shortnose and Atlantic sturgeon and that six Atlantic sturgeon (four New York Bight DPS, one Chesapeake Bay DPS or one from either the South Atlantic DPS or GOM DPS) and one shortnose sturgeon would be killed over the 30-year period that the marine terminal will be operational.” NMFS anticipated no other take. With the BiOp completed, PCOE issued the individual permit for construction of Dock 1 on December

1 References are based on Delaware River Basin Commission information, 1969.



21, 2017. Construction of Dock 1 commenced in early January 2018 and as of the date of this assessment is near completion.


Proposed Project Ramboll

2. PROPOSED PROJECT

DRP seeks to add Dock 2 for the transloading of bulk liquid products at the GLC.2 Dock 2 would provide safe navigational access, mooring, and loading equipment for two vessels up to 173,400 cubic meters in capacity and up to 120,000 deadweight tons. It would be located west (downriver) of Dock 1 would utilize the landside marine terminal infrastructure at the GLC, which is under development at the Project Site. Proposed development activities related to Dock 2 are subject to PCOE review under Section 404 of the Clean Water Act and Section 10 of the Rivers and Harbors Act, including installation of docking structures, performance of dredging, and future maintenance dredging.

2.1 Berth Construction The proposed new docking facility and loading platform is designed to accommodate two vessels end to end. It consists of two loading platforms, eight breasting dolphins, 11 mooring dolphins, walkways to provide dockworker access between platforms and dolphins. Access from the landside area to Dock 2 will be provided by an approximate 32-foot wide trestle, that will accommodate a one-lane vehicular roadway with adjacent pedestrian access, parallel product piping, and mechanical and electrical support systems. The landing of the trestle is within the limits of previously permitted landside development. The structural footprint over the water is approximately 139,127 square feet.

Each loading platform will be constructed on sixty 30-inch diameter x 3/4-inch wall steel pipe piles (120 piles total).

The trestle will be supported by pile bents with a total of 210 24-inch diameter x 5/8-inch wall steel pipe piles over 50 bents (210 piles total). A 50-foot wide abutment will support the landing of the trestle above the mean high water line. A retaining wall will be constructed on either side of the abutment to provide additional structural support (total length 230 feet).

The typical mooring dolphins will be constructed on nine 48-inch diameter x one-inch wall steel pipe piles; shared mooring dolphins will be constructed on fifteen 48-inch diameter x one-inch wall steel pipe piles (105 total piles). The breasting dolphins will be constructed on nine 48-inch diameter x one-inch wall steel pipe piles (72 total piles).

Walkways between loading platforms, mooring dolphins, and breasting dolphins will be provided with four intermediate support systems. The foundation of each intermediate support consists of three 24-inch diameter x 5/8-inch wall steel pipe piles (12 piles total).

Construction of the docking facility, including dolphins, loading platforms, and the offshore portion of the trestle, will be completed using a combination of land-based and marine-based methods, involving barge-mounted cranes and barge-based material delivery systems. Onshore structures, consisting of a pile-supported abutment and steel sheet pile retaining wall, will be constructed using land-based equipment, with land-based (truck) material deliveries.

Construction of Dock 2 will require the installation of steel piles consisting of 24-inch, 30-inch, and 48-inch diameters. As previously outlined, most construction will occur using marine-based construction equipment, including barge-mounted cranes, barge-based pile driving rigs, and waterborne material

2 The Project’s purpose and need are described in the accompanying Alternatives Analysis submitted by DRP.



deliveries. It is expected that environmental protection measures will be employed for all construction activities, including but not limited to:

• All steel piles are anticipated to be installed by impact hammer driving;

• It is expected that all steel pipe piles will be installed through the overlying strata (e.g. silts, sands) into the harder underlying weathered rock layer; and

• Steel sheet piling that will be used for earth retention systems at the abutment will likely be installed by vibratory hammer only; the sheets will be installed to a depth required to achieve resistance to lateral load.

There is an existing water intake structure used for the Site’s fire protection system near the proposed location for Dock 2. It is tested on an annual basis and used only for fire protection. Disturbance of this structure will be avoided during construction.

2.2 Dredging To create the berths, dredging is proposed within ~45 acres of the Delaware River to a depth of -46 feet NAVD88 (-43 feet MLLW), plus two feet of allowable overdredge (see Drawing 5). Current water depth in the area varies between -20 feet MLLW and -45 feet MLLW. The depth of the dredging area was based on the required clearance for vessels expected to utilize the proposed berth.

Dredging details are shown on Drawing D-101. Accounting for two feet of overdredge, the total dredging volume is approximately 665,000 cubic yards of material. Sediments within the dredge area consist of silts and sands. The depth of sediment to be dredged ranges from 20 feet nearest the berths and less than one foot nearest the channel. A sediment characterization program has been implemented and the resulting data are pending. Once those data are received, the Dredged Material Management Plan will be finalized and submitted to the New Jersey Department of Environmental Protection and the United States Army Corps of Engineers (“ACOE”).

It is expected that contaminated sediments (if found) will be dredged using an environmental clamshell and Best Management Practices (“BMPs”) will be used to limit the potential for sediment resuspension and associated impacts on water quality and aquatic biota. These BMPs include:



• Using an environmental clamshell equipped with sensors to ensure complete closure of the bucket before it is lifted through the water at a rate of two feet per second (fps) or less;






• Discharging decant water only within Dredging Area;

• Holding decant water in the decant holding scow for a minimum of 24 hours after the last addition of water to the scow. This holding time may be reduced if it can be demonstrated that TSS meets the background concentrations of 30 parts per million (“mg/L”), based on three consecutive TSS analyses; and

• Not dragging the dredge bucket along the sediment surface.

Sediments will be amended so that they could be transported by truck in compliance with Department of Transportation regulations and to comply with landfill requirements (e.g., soils must pass paint filter tests to demonstrate the absence of free liquids). Impacted sediments will disposed at a permitted landfill or approved brownfield site. Uncontaminated sediment meeting the applicable acceptance criteria will be transported via barge to the White's Basin permitted confined disposal facility (“CDF”) or other approved location.

2.3 Construction Schedule Pending receipt of required approvals, construction on Dock 2 is scheduled to begin as soon as possible after July 15, 2019, with a general sequence as outlined below in Table 1. The scheduling of specific construction activities will depend on site conditions, permit conditions, and conditions of local land use approvals. With an assumed start date of July 15, 2019, the general construction sequence would be completed by the end of 2020 as presented in Table 1.

Table 1. General Schedule of Construction Activities

Date Task

July 2019 Mobilization

After July 15, 2019 Dredging commences

By March 15, 2020 Dredging completed

January 2020 Pile driving commences

March 15, 2020 pile driving suspends

July 15, 2020 Pile driving continues

September 2019 Pile driving completed and deck construction commences

December 2020 Construction complete


Measures to Avoid and Minimize Effect Ramboll

3. MEASURES TO AVOID AND MINIMIZE EFFECT The proposed Action will avoid and minimize effects to listed species by utilizing the below measures:

• All in-water work will be prohibited between March 15th and July 15th;

• During pile driving, providing in place sediment control devices, turbidity curtains, booms, tarpaulins, floats, staging, and other devices as necessary to prevent materials from entering the water and leaving the immediate vicinity of the Site;

• Minimizing manipulation of piling, pile spuds, and other potential bottom disturbing activities;

• Deploying a “bubble curtain” during all water-based pile driving activities;

• Utilize a “soft-start” procedure to allow fish to exit the work area prior to reaching maximum pile driving energy, during all water-based pile driving activities;



• Using an environmental clamshell equipped with sensors to ensure complete closure of the bucket before it is lifted through the water at a rate of two fps or less;




• Discharging decant water only within Dredging Area, as such term is defined in Section 3;

• Holding decant water in the decant holding scow for a minimum of 24 hours after the last addition of water to the scow. This holding time may be reduced if it can be demonstrated that TSS meets the background concentrations of 30 mg/L, based on three consecutive TSS analyses;

• Not dragging the dredge bucket along the sediment surface;

• Use of shallow draft construction vessels that maximize the navigational clearance between the vessel and the river bottom where practicable;

• Vessel travel to and from the proposed berth will use the Delaware River Federal Navigation Channel (“Federal Navigation Channel”) when applicable; and

• Vessels approaching the berth will not exceed two knots and vessels leaving the proposed berth will operate at speeds of less than ten knots.


Description of Action Area Ramboll

4. DESCRIPTION OF ACTION AREA

The Action Area is defined in 50 CFR § 402.02 as “all areas to be affected directly or indirectly by the Federal action and not merely the immediate area involved in the action.” The Action Area for proposed Project includes the area of Dock 2 construction ("Construction Area"), a 295 feet radius to account for the acoustic behaviors threshold for sturgeon, the area of dredging activities ("Dredging Area"), a 328 feet radius from dredging footprint to account for total suspended sediments, and all vessels routes taken to and from the Project Site. Cargo vessels traveling to Dock 2 could come from a number of different locations and neither PCOE nor DRP have authority to control these vessels. The Project Site is located at approximately RM 86 and at Latitude N 39.845/Longitude W 75.306 (see Figure 2).

Dock 2 construction is not anticipated to result in an increase in vessel traffic on Delaware River.

The habitat in the Dredging Area is estuarine freshwater subtidal and intertidal, with water depths ranging from approximately -22 to -46 NAVD88. The proposed Dredging Area has soft bottom habitat. During typical flow conditions (i.e., non-drought), water salinity is below 0.5 parts per thousand (ppt). Sediments within the Dredging Area consist of silts and sands, with grain size typically increasing toward the main channel of the Delaware River. In the nearshore area, a silt layer with varying amounts of sands is underlain by a sand layer with trace silt. Some sand lenses occur within and above the silt layers. Further offshore, where the current is greater, very little fine-grained material accumulates and the bottom surface is dominated by a firm sand layer. Hard bottom substrate (e.g., rock, cobble, gravel, limestone, boulder, etc.) generally is not present in the Dredging Area.

An SAV survey performed by Matrix New World on September 28, 2018 indicated the presence of an SAV bed (3.78 acres) in the vicinity of the Action Area. However, the bed exists outside of the Dredging and Construction Areas and will not be impacted by Project activities.


Identification of Listed Species in the Action Area Ramboll

5. IDENTIFICATION OF LISTED SPECIES IN THE ACTION AREA

The following listed species are present within the Action Area and could be adversely affected by the proposed Action:

Table 2. Listed Species in the Action Area

Species Federal Listing Status

Listing History

Atlantic sturgeon (Acipenser oxyrinchus oxyrinchus)

New York Bight DPS

Chesapeake Bay DPS

Carolina DPS

South Atlantic DPS

Endangered

10/06/2010 – Proposed Listings for five DPS

2/06/2012 – Final Listing Rule for five DPS (77 FR 5880 and 77 FR 5914)

6/03/2016 – Proposed Critical Habitat designation for five DPS (81 FR 35701)

6/28/2016 – Correction to Proposed Critical Habitat Designation for Carolina and South Atlantic DPS.

Atlantic sturgeon (Acipenser oxyrinchus oxyrinchus)

Gulf of Maine DPS

Threatened 2/06/2012 – ESA Listing (77 FR 5914)

Shortnose sturgeon (Acipenser brevirostrum)

Endangered

3/11/1967 – ESA Listing Rule (32 FR 40001)

12/17/1998 – Recovery Plan

9/2014 – Petition to Identify New Brunswick, Canada, St. John River Shortnose Sturgeon as a DPS and Delist under the ESA

10/26/2015 – “Not warranted” finding on petition to identify and delist shortnose sturgeon in the St. John River

Endangered green sea turtles, endangered leatherback sea turtles, the threatened Northwest Atlantic DPS of loggerhead sea turtles, endangered Kemp's ridley sea turtles, endangered North Atlantic right whales, or endangered fin whales can occur in the lower portions of the Delaware River. However, the proposed Action is not expected to adversely affect these species and therefore they not included in this assessment.


Description and Life History of Atlantic and Shortnose Sturgeon Ramboll

6. DESCRIPTION AND LIFE HISTORY OF ATLANTIC AND SHORTNOSE STURGEON

6.1 Atlantic Sturgeon Atlantic sturgeon originating from the New York Bight (“NYB”), Chesapeake Bay (“CB”), South Atlantic (“SA”), and Carolina Distinct Population Segments (“DPS”) are listed as endangered. The Gulf of Maine (“GOM”) Atlantic sturgeon DPS is listed as threatened. The marine ranges of all five Atlantic sturgeon DPSs extend along the Atlantic coast from Canada to Cape Canaveral, Florida. Atlantic sturgeon originating from any of the five DPSs may be present in the Delaware River.

Atlantic sturgeon are long lived, late maturing, estuarine dependent, anadromous fish (Bigelow and Schroeder, 1953; Vladykov and Greeley 1963; Mangin, 1964; Pikitch et al., 2005; Dadswell, 2006; ASSRT, 2007 as cited in NMFS 2015). The Atlantic sturgeon is a relatively large fish, even amongst sturgeon species (Pikitch et al., 2005 as cited in NMFS 2015). Atlantic sturgeons are bottom feeders that suck food into a ventrally-located protruding mouth (Bigelow and Schroeder, 1953). Sturgeon are omnivorous benthic feeders and filter quantities of mud along with their food. The diet of adult sturgeon includes mollusks, gastropods, amphipods, isopods, and fish. Juveniles generally feed on aquatic insects and other invertebrates (ASSRT 2007). Prey items for sturgeon, such as benthic invertebrates, worms, and crustaceans, are found in soft-bottom substrates throughout the Delaware River and estuary. Riparian vegetation along shorelines may also provide habitat for aquatic insects.

Atlantic sturgeon live up to 60 years (Mangin, 1964 as cited by Grunwald et al., 2007). Sexual maturity occurs from seven to 28 years, depending on geographic location and gender (Collins et al., 2000). Van Eenennaam et al. (1996) reports the transition to adult phase differing in males and females but in most instances, individuals have attained maturity at 4.36 feet total length (“TL”).

Atlantic sturgeon spawn in freshwater but move to coastal waters as subadults (ASSRT, 2007). Subadult Atlantic sturgeon travel throughout coastal and estuarine habitats, undergoing rapid growth. In the mid-Atlantic, sturgeon tend to occur at the mouths of large bays or estuaries such as the Delaware Bay during the fall and spring, and to disperse throughout the Mid-Atlantic during the winter (Dunton, et al. 2010). Spawning adults in the mid-Atlantic systems generally migrate back upriver in April-May to spawn in their natal river (ASSRT, 2007). Fisheries data suggest that most adult Atlantic sturgeon inhabit shallow inshore areas of the continental shelf (Stein et al. 2004 as cited in Dunton et al. 2010).

6.1.1 Life Stages Atlantic sturgeon are anadromous, spending the majority of their adult phase in marine waters, migrating up rivers to spawn in freshwater and migrating to brackish waters in juvenile growth phases. In the Hudson River, New York, females first spawn between the ages of 15 and 30 years and males between eight and 20 years (ASMFC 2009). Adults return to their natal freshwater rivers to spawn (Dovel and Berggren, 1983). Atlantic sturgeon eggs are highly adhesive and are deposited primarily on gravel, rocky hard-bottom substrates and fertilized externally (Borodin, 1925, Smith et al., 1980). Based on work by Breece et al. (2013), hard bottom habitat (gravel/coarse grain depositional material and cobble/boulder habitat) and areas with mixed gravel and mud substrate are preferred habitat for spawning (Breece et al., 2013). For individual adults, periods between spawning can range from two to six years (Vladykov and Greeley, 1963; Van Eenennaam et al., 1996; Stevenson and Secor, 1999). Atlantic sturgeon spawning is believed to occur in flowing water



between the salt front and fall line of large rivers, where optimal flows are 1.5 to 2.5 feet per second and depths of 36 to 89 feet (Borodin 1925, Leland 1968, Scott and Crossman 1973, Crance 1987, Bain et al. 2000). Spawning occurs in water temperatures up to 24.3 degrees Celsius (Dovel and Berggren, 1983). At the end of their first summer, the majority of young-of-the-year ("YOY") Atlantic sturgeon remain in their natal river while older subadults begin migrate offshore (Dovel and Berggren, 1983).

The eggs of Atlantic sturgeon are adhesive, and after fertilization and hydration are approximately 2.2 millimeters (0.09 inches) (Hardy and Litvak 2004). After hatching, the larvae remain closely associated with the bottom in deep channel habitats (Bain et al. 2000 as cited in FHWA 2012). Egg incubation periods vary with water temperature. Larval Atlantic sturgeon emerge from the egg in roughly four to six days (based on hatching temperatures of approximately 18 to 20 degrees Celsius). Newly hatched larvae exhibit negative phototactic behavior to avoid predation (Kynard and Horgan, 2002) and tend to migrate downstream towards more brackish waters (Smith et al., 1980; Kynard and Horgan, 2002). Newly hatched larvae are generally pelagic. After a pelagic yolk sac larval period of about 8 to 12 days, late-stage larvae settle in the demersal habitat (ASMFC 2009; NMFS 2015). Atlantic sturgeon larvae are about seven millimeters TL upon hatching. The transition from the larval to the juvenile stage is estimated to occur at about 30 to 40 mm TL (ASMFC 2009; NMFS 2017f).

For at least one year after hatching, juvenile Atlantic sturgeon remain close to their natal habitats within the freshwater portion of the estuary before migrating out to sea (ASMFC 2009). Migrations to coastal areas occur between two and six years of age (ASMFC 2009). Migrations are seasonal, with movement occurring north in the late winter and south in fall and early winter (Dovel 1978; Smith 1985b; USFWS-NMFS 1998 as cited in ASMFC 2009). Seasonal migrations of juveniles are regulated by changes in temperature gradients between fresh and brackish waters (Van Den Avyle 1984).

By the time juvenile Atlantic sturgeon reach 70 to76 centimeters TL, they begin to migrate to marine waters (NMFS 2017f; ASMFC 2009). Though subadult fish are not sexually mature, they make coastal migrations, occupying marine habitats during the winter and moving back into riverine systems. Some subadults remain in coastal marine habitats during the summer (Bain et al. 2000 as cited in ASMFC 2009).

At the time of year when Project construction activities would occur, most Atlantic sturgeon in the Action Area would be juveniles and subadults. Atlantic sturgeon eggs are highly adhesive and are deposited primarily on gravel, rocky hard-bottom substrates (Smith et al. 1980). No Atlantic sturgeon spawning habitat is present in the portion of the Action Area where construction and dredging would occur (identified as the Dredging Area and Construction Area). Therefore no eggs are expected to be present. Some late-hatching Atlantic sturgeon larvae could be present in the Action Area through August 31 (NMFS 2017f).

6.2 Shortnose Sturgeon The shortnose sturgeon is an endangered species of amphidromous fish found in major rivers of eastern North America, including the Delaware River. Like Atlantic sturgeon, shortnose sturgeon spawn in freshwater, usually above tidal influence and feed and overwinter in both fresh and saline habitats (NWMF 2017). In the Delaware River, spawning typically occurs during the middle two weeks of April (Hoff, 1965; Brundage and Meadows, 1982a). Following spawning, adult shortnose sturgeon migrate downstream to the Philadelphia area (RM 100). Overwintering adults are typically found near the Trenton reach of the Delaware River (RM 133), though they can also be found overwintering as far



downstream as Wilmington (RM 72). Juveniles migrate downstream during the fall and winter months and return upstream in spring and summer. Juvenile migration patterns follow the temperature and salinity changes that occur throughout the year, causing their likely range in the Delaware River to be between Artificial Island (RM 54) and the Schuylkill River (RM 92).

The shortnose sturgeon is an endangered species of fish found in major rivers of eastern North America. NMFS recognizes 19 separate populations occurring throughout the range of the species: New Brunswick Canada (1 population); Maine (2); Massachusetts (1); Connecticut (1); New York (1); New Jersey/Delaware (1); Maryland and Virginia (1); North Carolina (1); South Carolina (4); Georgia (4); and Florida (2). NMFS has not formally recognized DPSs of shortnose sturgeon under the Endangered Species Act. Shortnose sturgeon occur in the Delaware River from the lower Bay upstream to at least Lambertville, New Jersey (RM 148) (SSSRT 2010).

Shortnose sturgeon are benthic, amphidromous fish that live in large coastal rivers of eastern North America (SSSRT 2010). Like Atlantic sturgeon, shortnose sturgeon spawn in freshwater, usually above tidal influence and feed and overwinter in both fresh and saline habitats (NMFS 2017). Adult shortnose sturgeon are typically found in freshwater tidally influenced river reaches during summer and winter months and may only occupy a small portion of the river’s entire length (Buckley and Kynard 1985 as cited in NMFS 2017). Adults prefer deep water habitat with vegetated bottoms and soft substrates (NMFS 2017). Shortnose sturgeon are known to occur at depths up to 98 feet, but generally occur in waters with depths between two feet and 66 feet (NMFS 2015). The species typically occupies the deepest part of rivers where dissolved oxygen (“DO”) and salinity are suitable (NMFS 2017). Shortnose sturgeon are known to tolerate a range of temperatures (two to 28 degrees Celsius) and salinities (freshwater to 30 ppt) (NMFS 2017).

Shortnose sturgeon are primarily benthic feeders but will also feed off plant surfaces (Dadswell 1984). Typical food sources for shortnose sturgeon include crustaceans, insect larvae, worms, mollusks, and oligochaete worms (Dadswell 1984 as cited in NMFS 2017). Subadults are known to feed indiscriminately on aquatic insects, isopods, and amphipods along with large amounts of mud, stones, and plant material (Bain 1997; Dadswell 1979 as cited in NMFS 2017). In the Delaware River, the Asiatic river clam (Corbicula manilensis) may be a major portion of the diet of shortnose sturgeon (NMFS 2015). Shortnose sturgeon forage most heavily after spawning in spring, summer, and fall (NMFS 2015).

Spawning occurs from mid to late spring at discrete sites in northern rivers, typically at the farthest upstream reaches of the river (NMFS 2017). Shortnose sturgeon spawn over habitats containing gravel, rubble, or rock-cobble substrates in low flowing waters with water temperatures between 6.5 to 18 degrees Celsius and bottom water velocities of 0.4 to 0.8 meters per second (NMFS 2017). In the Delaware River, spawning typically occurs during the middle two weeks of April (Hoff, 1965; Brundage and Meadows, 1982a). The spawning period for shortnose sturgeon is estimated to last from a few days to several weeks (NMFS 2015). Shortly after spawning, adult shortnose sturgeon typically migrate away from spawning grounds (NMFS 2017). In the Delaware River, movement to the spawning grounds occurs in early spring, typically in late March, with spawning occurring through early May. The concentrated use of the Scudders Falls region (RM 133) in the spring by large numbers of mature male and female shortnose sturgeon indicates that the area between Scudders Falls and the Trenton rapids (RM 133-139) is where spawning occurs.



In the fall and winter, older juveniles or subadults migrate downstream with falling water temperatures and a receding salt line (NMFS 2017). Juveniles move upstream in the spring and summer. Foraging occurs in freshwater reaches; however, movements usually occur upstream the saltwater/freshwater river interface (Dadswell et al. 1984; Hall et al. 1991, as cited in NMFS 2017). Limited studies have been conducted on juveniles in the Delaware River. Shortnose sturgeon have nearly identical migration patterns in all rivers. Therefore, it is likely that juveniles in the Delaware River exhibit similar migration patterns to sturgeon in other river systems, with juveniles moving back and forth in the low salinity portion of the oligohaline/freshwater interface (i.e., salt front) during summer. In the Delaware River, the salt front can range from as far south as Wilmington, Delaware, north to Philadelphia, Pennsylvania, depending upon meteorological conditions such as excessive rainfall or drought. As a result, it is possible that juveniles could range from Artificial Island (RM 54) to the Schuylkill River (RM 92). Research in other river systems indicates that juveniles are typically found over silt and sand/mud substrates in deep water of 33 to 66 feet (10 to 20 meters).

After spawning, adult shortnose sturgeon migrate downstream to the Philadelphia area (RM 100). Within a few weeks of migrating to this area, many adult sturgeon return upriver between RM 127 and 134, while others gradually move to the same area over the course of the summer (O'Herron et al. 1993). By the time water temperatures have declined to 10 degrees Celsius, typically by mid- November, most adult sturgeon have returned to the overwintering grounds in the Roebling (RM 124), Bordentown (RM 129), or Trenton reaches (RM 133), but may overwinter as far downstream as Wilmington (RM 72) (O'Herron et al. 1993; ERC 2006). In contrast with sturgeon in other river systems, shortnose sturgeon in the Delaware River do not appear to remain stationary during overwintering periods. Overwintering fish have been found to be generally active, appearing at the surface and even breaching through the skim ice (O'Herron et. al 1993). Due to the relatively active nature of these fish, use of the River during the winter is difficult to predict. However, the typical adult overwintering movements are fairly localized, and sturgeon appear to remain within two river kilometers of the concentration site (O’Herron and Able 1986 as cited in NMFS 2015). A study by Versar (2006) supports the conclusion that the majority of adult shortnose sturgeon overwinter near Duck Island and Newbold Island and that a limited number of shortnose sturgeon occur in other downstream areas, including Marcus Hook, during the winter months. There is also evidence that, unlike adults, juveniles do not form dense concentrations and are more dispersed in overwintering areas (ERC 2007). Studies tracking the movements of juvenile sturgeon in the Delaware River indicate that individual behavior is diverse, with some individuals establishing a relatively small "home range" (Fisher 2011) during the winter months and others exhibiting extensive movements. No information on what factors contribute to different behaviors is available; these differences are seen in fish of the same year class making it difficult to determine if there are environmental or developmental factors at play or if it is merely natural variability. Overwintering juveniles are expected to occur on the freshwater side of the oligohaline/fresh water interface which in the Delaware River occurs in the area between Wilmington, Delaware and Marcus Hook/Philadelphia, Pennsylvania area (O’Herron 1990 as cited in NMFS 2015). Additional preliminary tracking studies of juveniles indicate that the entire lower Delaware River from Philadelphia (approximately RM 100) to below Artificial Island (RM 49) may be used as an overwintering area by juvenile shortnose sturgeon (ERC 2007).

At the time of year when Project activity would occur, most shortnose sturgeon in the Action Area would be juveniles or adults. Shortnose sturgeon spawning areas are 40 miles upstream of the Project Site and therefore activities would not affect shortnose sturgeon spawning areas or eggs. Shortnose sturgeon larvae are expected to have developed into a juvenile life stage before reaching



the portion of the Action Area where construction and dredging would occur (identified as the Dredging Area and Construction Area).


Identification of Designated Critical Habitat Ramboll

7. IDENTIFICATION OF DESIGNATED CRITICAL HABITAT

As described in this section, critical habitat has been designated for the Atlantic sturgeon. Critical habitat has not been proposed for the shortnose sturgeon.

On September 18, 2018, NMFS placed into effect two rules to designate critical habitat for the listed GOM, NYB, and CB DPSs of Atlantic sturgeon (81 FR 35701) and for the listed Carolina and SA DPSs (81 FR 36078). The Action Area is located within a portion of the Delaware River identified in the rule as critical habitat for the NYB DPS of Atlantic sturgeon. Federal agencies are required to confer with NMFS on any action that is likely to jeopardize the continued existence of any species proposed for listing or result in destruction or adverse modification of proposed critical habitat (50 CFR §402.10). “Destruction or adverse modification” means a direct or indirect alteration that appreciably diminishes the value of critical habitat for the conservation of a listed species. Such alterations may include, but are not limited to, those that alter the physical or biological features essential to the conservation of a species or that preclude or significantly delay development of such features (50 CFR § 402.02). For the Delaware River, critical habitat for the NYB DPS extends from the Trenton-Morrisville Route 1 Toll Bridge downstream 85 river miles to where the main stem discharges at its mouth into the Delaware Bay (approximately RM 48).

Critical habitat for Atlantic sturgeon is identified by following physical and biological features (“PBF’s”) required for reproduction and recruitment:

• PBF 1: Hard bottom substrate (e.g., rock, cobble, gravel, limestone, boulder, etc.) in low salinity waters (i.e., 0.0 to 0.5 ppt range) for settlement of fertilized eggs, refuge, growth, and development of early life stages;

• PBF 2: Aquatic habitat with a gradual downstream salinity gradient of 0.5 to 30 ppt and soft substrate (e.g., sand and mud) downstream of spawning sites for juvenile foraging and physiological development;

• PBF 3: Water of appropriate depth and absent physical barriers to passage (e.g., locks, dams, reservoirs, gear, etc.) between the river mouth and spawning sites necessary to support: (1) unimpeded movement of adults to and from spawning sites; (2) seasonal and physiologically dependent movement of juvenile Atlantic sturgeon to appropriate salinity zones within the river estuary; and (3) staging, resting, or holding of subadults or spawning condition adults. Water depths in main river channels must also be deep enough (e.g., ≥1.2 m) to ensure all times when any sturgeon life stage would be in the river; and

• PBF 4: Water, especially in the bottom meter of the water column, with the temperature, salinity, and oxygen values that, combined, support: (1) spawning; (2) annual and interannual adult, subadult, larval, and juvenile survival; and (3) larval, juvenile, and subadult growth, development, and recruitment (e.g., 13 to 26 degrees Celsius for spawning habitat and no more than 30 degrees Celsius for juvenile rearing habitat, and six parts mg/L DO for juvenile rearing habitat).

In the portion of the Action Area where construction and dredging would occur (identified as the Dredging Area and Construction Area), sediments consists primarily of fine-grained silt and sands, with sand content generally increasing toward the Federal Navigation Channel, therefore PBF 1 is not present.


Identification of Designated Critical Habitat Ramboll

Aquatic habitat with a downstream salinity gradient and soft substrate (PBF 2) is present within the Federal Navigation Channel downstream of the salt line. While the salt line varies seasonally, the median monthly location is between RM 67 and RM 76. The Dredging and Construction Areas are located within the tidal fresh portion of the Delaware River at approximately RM 86; typical salinities within the area range from 0.15 to 0.425 ppt. Therefore, PBF 2 is not present within the Dredging or Construction Areas.

There are no major barriers to passage and sufficient water quality and depth are present within the Dredging and Construction areas for PBF 3 and PBF 4 to be present. The proposed structure would not form a barrier to fish movement in Delaware River and any effects on water quality from construction activities would be temporary.


Effects of the Actions Ramboll

8. EFFECTS OF THE ACTION

The purpose of this section is to evaluate the direct and indirect effects of the proposed Action and interrelated/interdepend activities on listed species and critical habitat. Only the shortnose sturgeon, Atlantic sturgeon, and critical habitat of the NYB DPS of Atlantic sturgeon are addressed in this section, as these are the only species that could be adversely affected by the Action.

The Action is deconstructed into distinct components in order to identify the pathway, stressor, and impact of the stressor on each life stage of the listed species. Stressors for each component are analyzed based on the exposure and response of the applicable listed species (Atlantic and shortnose sturgeon) and designated critical habitat (Atlantic sturgeon). Avoidance and minimization measures are also considered. The following project components are evaluated in the subsections below:

• Effects of Dredging

• Effects of In-water Construction Activities

• Effects of Vessel Traffic from Construction Activities

• Effects of Vessel Traffic from Dock 2 Operations

• Effects of the Action on Essential Elements of Critical Habitat

8.1 Effects of Dredging 8.1.1 Mechanical Dredging Interactions with the mechanical or hydraulic dredging equipment could impinge or capture (i.e., entrain) sturgeon, resulting in death or injury. A clamshell bucket operates via the penetration of the bucket’s two "jaws" beneath the sediment and simultaneous lifting and closing of the jaws to remove the sediment. In order to be impacted by the dredge bucket, a sturgeon would have to be on the bottom directly under the bucket. Hard-digging dredges are typically heavier and have a more powerful closing mechanism than soft-digging buckets (USACE 1975). For a sturgeon to be removed by mechanical dredge, it would need to remain directly between the jaws of the bucket. A sturgeon may also be impacted if it was struck by the dredge bucket as the bucket enters the waterway.

Late hatching Atlantic sturgeon larvae may be present during dredging activities that take place from July 15 through August 31. Upon hatching, sturgeon larvae remain near spawning grounds, seeking cover in well-oxygenated, hard-bottom refugia before migrating downstream (Kynard and Horgan 2002). Since the portion of the Action Area where dredging would occur does not contain suitable hard-bottom refugia, it is very unlikely that any larvae would be present during dredging. Atlantic sturgeon larvae are free swimming and typically congregate in deep channel habitat (Taubert and Dadswell 1980; Bath et al. 1981; Kieffer and Kynard 1993 as cited in NMFS2017b). Given that the Dredging Area is outside the main river channel, it is unlikely that sturgeon larvae would be present. Atlantic sturgeon larvae in the Delaware River are expected to be developed into juveniles by August 31, allowing for a small period (July 15 through August 31) of potential overlap between dredging activities and possible presence of larvae. Based on the limited spatial and temporal overlap of Atlantic sturgeon larvae in the Dredging Area during dredging, it is unlikely that sturgeon larvae would be captured by the dredge bucket during dredge operations. Effects to sturgeon larvae from the proposed mechanical dredging activities are discountable.



Juvenile and adult sturgeon of either species may be present throughout the year in the portion of the Action Area where dredging would occur. For the proposed Project, the bucket will move at a speed of two feet per second or less and it would be expected that highly mobile sturgeon would therefore be able to detect and avoid the bucket. In rare instances, sturgeon have been captured in dredge buckets. ACOE reported four instances of sturgeon captured in dredge buckets along the East Coast of the United States since 1990 (USACE 2012). The risk of interactions between the dredge buckets and sturgeon are thought to be highest in areas where sturgeon are known to concentrate, such as overwintering sites or foraging concentrations (NMFS 2016e). The Dredging Area is not located within a known high concentration area of sturgeon. The closest high concentration area of sturgeon is located several miles downstream at Marcus Hook. In a study examining habitat use of juvenile sturgeon in the Delaware River, Hale et al. (2016) showed that 91.1 percent of acoustically tagged juveniles were located downstream (RM 72 to RM 83) of the Dredging Area (RM 86). Because the Dredging Area is not located in a known high concentration area of sturgeon, the risk of interaction between juvenile sturgeon and the dredge bucket is relatively low. Overall, the likelihood of capture in a mechanical dredge is extremely low due the slow speed at which the bucket moves and the relatively small area of the river bottom that the bucket interacts with at any one time (NMFS 2016e). Based on this information, and given the time of year restrictions of the Action, it is unlikely that an adult or juvenile sturgeon would be captured by the dredge bucket during dredge operations within the Dredging Area and effects to sturgeon from the proposed dredging activities are discountable.

8.1.2 Water Quality Effects from Dredging Dredging activities to remove fine-grained silt would suspend sediment within the water column, resulting in a short-term increase in turbidity. Elevated turbidity may directly harm fish by clogging their gills or interfering with their ability to find prey and avoid predators. Turbidity may also have indirect effects on sturgeon through the burial of benthic prey or creation of a barrier to movement within the river. Resuspension of impacted sediments could affect sturgeon directly (i.e., acute toxicity) or indirectly through ingestion of exposed prey.

The primary water quality effect of dredging is increased turbidity or TSS. Therefore, water quality effects would be limited to the Dredging Area and the immediate vicinity of the Dredging Area where turbidity is elevated, measured as an increase in TSS. Dredging for the Project is a short-term activity (approximately six to eight months in duration), such that any adverse effects on water quality would be temporary.

Mechanical dredging could result in a temporary increase of TSS but maximum concentrations (i.e., up to 120 mg/L) are expected to be less than the concentration that would result in a direct adverse effect on juvenile and adult sturgeon (i.e., 580.0 mg/L). Limited information is available regarding the impacts of elevated TSS on larval sturgeon. Morgan et al. (1983, as cited in USACE & ECORP 2009) found that striped bass and white perch eggs and larvae were not affected by suspended sediment concentrations from 20 to 2,300 mg/L, suggesting that TSS from dredging are not likely to adversely affect sturgeon larvae. Further, maximum expected TSS levels (120 mg/L) are below concentrations shown to negatively impact benthic communities (390 mg/L) and no reduction in foraging habitat quality is expected. Elevated TSS concentrations could affect sturgeon if the plume causes a barrier to movement or migration. Sturgeon are benthic fish and tolerate high levels of turbidity, so this outcome is unlikely. Even at the highest expected TSS concentrations, the plume is not expected to form a barrier to sturgeon, since other anadromous species do not avoid high TSS concentrations (954 to 1,920 mg/L). Additionally, only a small area around the dredge would have high TSS concentrations (120 mg/L with 328 feet down-current from the dredge bucket). Further, given the



width of the Delaware River at this location (approximately 0.9 miles wide and 0.5 miles from the edge of the proposed Dredging Area to Tinicum Island), the sediment plume would not be wide enough to form a barrier to sturgeon moving up or down river. Water quality impacts from mechanical dredging would cause a temporary increase in TSS, but mitigation measures would prevent any effects of TSS from mechanical dredging activities from being meaningfully measured, detected, or evaluated. Therefore, such effects are insignificant.

8.1.3 Effects of Dredging on Habitat Dredging would temporarily reduce foraging habitat in the Dredging Area and may impact local composition of shallow water benthic community. Wilbur and Clarke (2007) demonstrated that benthic communities in temperate regions with substrate of sand, silt, or clay recover from channel dredging between one month and four years after the disturbance, with an average recovery time of approximately 11 months. Based on this information, it is expected that benthic communities within the majority of the Dredging Area would recover within one year of dredging. Maintenance dredging is expected to be required approximately every 10 to 15 years. Therefore, the benthic community is anticipated to recover between dredging events. Ample food resources are available outside the Dredging Area within the Delaware River. Dredging within the Action Area is not expected to reduce availability of forage to sturgeon to the degree where a reduction in growth, survival, or reproduction could be meaningfully measured or detected. Therefore, habitat modification due dredging activities is expected to have insignificant effects on federally-listed Atlantic sturgeon or shortnose sturgeon.

8.1.4 Effects of In-water Construction Activities Construction activities associated with the Project include the installation of piles and decking. Potential effects of these construction activities are described in this section.

Construction would occur at the time of year when most Atlantic sturgeon and shortnose sturgeon in the Construction Area would be juveniles (shortnose), subadult (Atlantic), or adults. In-water construction activities would be conducted no sooner than July 15 and no later than March 15. Sturgeon eggs are not expected to be in the Construction Area because no spawning habitat is present and they will have already developed into later life stages by the time construction would occur. Sturgeon larvae also are not expected to be present in the Construction Area. Shortnose sturgeon spawn over 40 miles upriver. Therefore, it is expected that any larvae will have developed into later life stages by the time construction would occur. No Atlantic sturgeon spawning habitat is present within the Construction Area. Late-hatching larvae from possible upstream spawning areas could be carried into the Construction Area by the current. Larvae would be expected to have developed into a later life stage by the end of August (NMFS 2017f). After hatching, Atlantic sturgeon larvae seek refuge in hard bottom substrate before migrating downstream using a “swim and drift behavior” (ASMFC 2009). The proposed construction activities are located in a low-velocity environment and no hard bottom substrate is present; therefore, it is extremely unlikely any Atlantic sturgeon larvae would be present during construction.

Pile driving has the potential to cause physical and behavioral effects on aquatic species. Installation of concrete decking will also generate noise, but at levels lower than pile driving, as discussed below.

8.1.5 Noise Associated with Pile Installation Pile driving produces underwater sound pressure waves that can affect aquatic species, including sturgeon (NMFS 2017g). Effects on fish can range from temporary avoidance of an area to death due to injury of swim bladders or other internal organs. Factors that contribute to the likelihood of an



adverse effect include type and size of pile, installation method (i.e., vibratory vs. impact hammer), size and species of the organism (smaller individuals are more susceptible to effects), and distance from the sound source. Generally, the larger the pile and the closer an individual is to the pile, the greater the likelihood of effects (NMFS 2017g).

Pilings for the berth structures would be primarily installed from a barge, with initial work beginning with landside equipment. An impact hammer would be used to drive the piles. The piling driving work would require approximately 2.5 months to complete.

To attenuate noise levels from pile driving, the proposed Project would use a bubble curtain. Additional mitigation measures include a reduced energy “soft start” procedure for either type of pile driving equipment (i.e., half-power start for 15 minutes) that would enable sturgeon to leave the Construction Area as work commences.

As the distance from the source increases, underwater sound levels produced by pile driving dissipate rapidly. Underwater noise levels attenuate approximately five decibels (“dB”) every 33 feet (Buehler et al. 2015). If significant obstacles or variable bathymetry are present in an area, attenuation may occur more rapidly, dampening the sound pressure by an even greater factor.

8.1.6 Physical Effects of Pile Driving Exposure to underwater noise levels of 206 dBPeak and 187 dBcSEL can result in physiological injury to sturgeon. Sturgeon exposure to peak pressure levels that may result in injury (i.e., 206 dBPeak) is not expected, as five dB attenuation as a result of using bubble curtains prevent peak levels from approaching the injurious level (Table 3).

Table 3. Estimated Distances to Sturgeon Injury and Behavioral Thresholds

Type of Pile Hammer Type

Distance (feet) to 206dBPeak

(injury)

Distance (feet) to sSEL of 150 dB

(surrogate for 187 dBcSEL injury)

Distance (feet) to Behavioral Disturbance

Threshold (150 dBRMS)

24" Steel Pipe Impact NA 183.7 288.7

30" Steel Pipe Impact NA 196.6 262.5

60” CISS Steel Pipe3 Impact NA 229.7 295.3

In addition to the "peak" exposure criteria that relate to the energy received from a single pile strike, the potential for injury exists for multiple exposures to noise over a period of time. The cSEL threshold accounts for multiple exposures. The cSEL is a measure of the accumulated energy over a specific period of time (e.g., the period of time it takes to install a pile), rather than an instantaneous maximum noise threshold. When it is not possible to accurately calculate the distance to the 186 dB cSEL isopleth, we calculate the distance to the 150 dB sSEL isopleth. The greater the distance 3 Although the Project will use 48-inch CISS steel pipes, the analysis presented herein utilizes a 60-inch CISS steel

pipe scenario as a proxy in the GARFO Acoustics Tool because water depth values used in the analysis more closely aligned with Project specifics.



between the fish and the pile being driven, the greater the number of strikes it must be exposed to in order to be injurious. The threshold distance from the pile indicates that the fish is far enough away that, regardless of the number of strikes it is exposed to, the energy accumulated is not sufficient to cause injury. This distance is where the 150 dB sSEL isopleth occurs (Stadler and Woodbury 2009). A fish located outside of this isopleth has no risk of injury, regardless of the number of pile strikes.

Sturgeon that remain within 230 feet of the pile driving activities could be exposed to injurious levels of noise during installation of the piles. Sturgeon are not expected remain within 230 feet of the pile driving activities because they would avoid an ensonified area upon exposure to underwater noise levels of 150 dBRMS. Behavioral modification (avoidance) is expected at 295 feet. Even if a sturgeon is within 230 feet of the pile when pile driving begins, injury is unlikely because the cSEL injury threshold is cumulative (requiring prolonged exposure to the noise at that level). Sturgeon would leave the area immediately upon the start of pile driving. The use of a reduced energy "soft start" technique would help ensure that sturgeon would be exposed to reduce noise levels for several minutes before maximum noise levels are reached. Thus, sturgeon would exit the 230 feet radius of the pile before cumulative effects reach the cSEL injury threshold. For the above reasons, the physiological effects of pile driving and demolition on sturgeon are discountable.

8.1.7 Behavioral Effects of Pile Driving Behavioral effects, such as avoidance or disruption of foraging activities, may occur in sturgeon exposed to noise above 150 dBRMS (NMFS 2017g). Underwater noise levels would be less than 150 dBRMS at distances greater than 295 feet from the pile being installed or demolished. If sturgeon move into the Construction Area where the 150 dBRMS isopleth extends, the sturgeon would redirect its path away from the ensonified area upon detecting underwater noise levels of 150 dBRMS. Such avoidance behavior is extremely unlikely to affect essential sturgeon behaviors (e.g., spawning, foraging, resting, and migration).

As discussed above, pile driving activities could cause fish to alter movements, as sturgeon that may be near the Construction Area would likely move to avoid the ensonified area. NMFS (2017c) suggested the pile driving activities may cause sturgeon near the Construction Area to move into the Federal Navigation Channel, where there is an increased risk of interaction with vessels. Sound levels from pile driving activities are expected to dissipate rapidly away from the pile site. Therefore, temporary elevated noise levels that may modify fish behavior are expected only up to a maximum of 295 feet from the pile location. The proposed berth construction activities are located approximately 650 feet from the Federal Navigation Channel. Thus, any sturgeon that are present in the Construction Area would have ample clearance to avoid elevated noise areas without entering the Federal Navigation Channel. Further, the time of year restrictions for in-water work means that adult sturgeon would not be migrating through the Construction Area to spawning locations during pile-driving.

In conclusion, underwater noise from pile driving is not likely to form a barrier to Atlantic sturgeon or shortnose sturgeon movements during any period of pile installation. The river is approximately 0.9 miles wide at the Construction Area and there are no obstructions that would prevent sturgeon from swimming either away from the ensonified area or to any other areas. Underwater noise from pile driving would not present a barrier to Atlantic or shortnose sturgeon movements during any period of pile installation. Noise generated from placement of concrete decking would be below noise thresholds identified for steel pipe pile installation and, therefore, is expected to cause neither physiological or behavioral effects on sturgeon nor present a barrier to sturgeon movement. Given the temporary



nature of the disturbance and the small distance a sturgeon would need to move to avoid noise, any effects on sturgeon would not be meaningfully measured or detected, the behavioral effects of noise are insignificant.

8.2 Effects of Vessel Traffic from Construction Activities Vessel trips associated with construction, pile driving, and dredging activities could cause a temporary increase of vessels during the period of construction. The majority of vessel transit would occur within the Federal Navigation Channel which highly trafficked and would represent a small temporary increase. Construction and dredge disposal vessel have a minimal draft (three to six feet) and would be traveling at speeds of no more than 10 knots, which would reduce the likelihood of interacting with sturgeon. Vessel interaction with sturgeon in the Delaware River are more likely to occur when sturgeon are migrating to spawning areas. Construction and dredging vessels would not transit the Action Area from March 15 to July 15 and would avoid this critical time of year for sturgeon interaction. The temporary duration, shallow draft, slow speed, and time of year when the vessels would operate would limit potential for interactions between sturgeon and vessels. Given this slight increase in vessel traffic relative to the existing baseline within the Action Area, any increase in risk of vessel strike for sturgeon would not be meaningfully measured or detected. Therefore, Project-related dredging and construction vessel traffic is insignificant and not likely to adversely affect sturgeon.

8.3 Effects of Vessel Traffic from Dock 2 Operations Dock 1 was expected to have 133 vessel calls per year with 91 vessels representing new traffic on the Delaware River for total of 182 new vessels trips (see Alternatives Analysis for Proposed Dock 2 at DRP Gibbstown Logistics Center). The 182 vessel trips were accounted for under the previously authorized project for Dock 1 and constitute the baseline vessel traffic for the marine terminal. The addition of Dock 2 is not expected to increase vessels trips (see Table 4). Market conditions have shifted and stimulated demand for capacity to accommodate bulk liquid products. In addition, given the type of vessels expected to call at the GLC, the estimated time that vessels will remain at dock has increased overall. Accordingly, despite an increase in the number of the berths (three total), the number vessels calls will not increase due to the longer residence times of liquid bulk cargo vessels in berth (10 days).4 No additional vessel traffic relative to baseline is anticipated and no adverse effect to sturgeon from increased vessels interactions is expected.

Table 4 Annual Estimated Vessel Calls at Gibbstown Logistics Center

Cargo Type Annual Volume Units Ship

Capacity Number of

Vessels New

Vessels Displaced Vessels

RoRo 100,000 units 2,500 40 40 0

Break Bulk 288,000 MT 12,000 24 0 24

Refined Products 4,800,000 bbls 400,000 12 0 12

Bulk Liquids 12,768,000 bbls 532,000 24 12 12

Total – Dock 1 - - - 100 52 48


4 Commercial contracts for use of port facilities are generally long-term agreements with minimum terms of 10 to

20 years.



Table 4 Annual Estimated Vessel Calls at Gibbstown Logistics Center

Total – Dock 2 - - - 37 37 48

Total – Dock 1 & 2 - - - 137 89 48

Overall, as noted in the 2017 BiOp related to approvals for Dock 1, the increase in vessel traffic associated with Dock 1 was very small (0.37%) relative to the then-existing baseline of traffic on the Delaware River (see NMFS 2017c at p. 170). The impacts of this marginal increase were already evaluated by NMFS with respect to the approvals process for Dock 1. As detailed above, no increase in new vessel traffic over current baseline and no additional risk of sturgeon take by vessels is anticipated. 8.4 Effects of Ballast Water Intake Vessels calling at the proposed Dock 2 would be required by law to abide by USCG regulations in order to avoid adverse effects of invasive species that may be present in ballast water, and to minimize intake of larvae and juvenile fish. Based on these regulations, the majority of all ballast water exchanges for vessels calling on Dock 2 will occur in off-shore marine waters. While at berth, the discharge and intake of ballast water is limited to the minimum needed to assure vessel stability.

Intake of ballast water can directly affect fish by entraining or impinging on the screens. The discharge of ballast water may release invasive species, which may negatively affect native communities.

Prakash et al. (2014) determined the ability of mobile fish life stages to avoid impingement for vessels at Crown Landing terminal in the Delaware River. The zone of influence was calculated to approximately five to six meters in the vertical directions and about 50 meters in the horizontal direction. When the vessel is taking on ballast, the intake experiences water velocities of 30 to 50 centimeters per second (“cm/s”). The velocity rapidly decreased with distance from the intake. Close to the bottom (at a distance of six meters), velocities ranged from 0.5 to six cm/s and dropped to <0.5 cm/s at 50 meters in the horizontal direction. Bulk liquid vessel ballast rates at the GLC are not likely to exceed the modeled vessel.

Sturgeon are likely to avoid the berth area because of vessel activity and limited foraging habitat. If sturgeon eggs, larvae, and juveniles less than 30 centimeters TL are present they are expected to be mostly on the bottom and in deeper portions of the Delaware River. Ballast intakes are not generally located near the bottom of a vessel’s hull but further up on the vessel’s sides. Eggs, larvae, and smaller juveniles are extremely unlikely to entrained in the ballast intake and effects to eggs and larvae are discountable.

Juvenile and adult sturgeon are expected to avoid the berth but may swim higher in the water column and near vessels during seasonal movements and spawning migrations. Intake velocities of 30 to 50 cm/s may occur at the mouth of the intake but do not exceed the mean burst swimming speeds of both Atlantic and shortnose sturgeon. Sturgeon over 30 centimeters TL would be able to escape entrainment in and avoid impingement. It is extremely unlikely that sturgeon would be entrained or impinged and effects on sturgeon from pumping of ballast water are discountable.



In light of the foregoing, and the fact that USCG regulations governing the discharge and intake of ballast water will apply to vessels calling at Dock 2, no impacts to sturgeon from vessel ballast functions are anticipated.

8.4.1 Effects of the Action on Essential Element of Critical Habitat The Action Area lies within an area of critical habitat. The objective of this section is to evaluate the effects of the Action on the four PBFs identified in Section 6.

PBF 1 and PBF 2 do not occur within the Action Area. Therefore, the proposed Project is not expected to adversely affect PBF 1 or PBF 2.

No portion of the Action Area is dammed, and the movement of sturgeon is unimpeded to and from spawning sites; therefore, PBF 3 is likely present within the Action Area. The proposed Project involves construction of a pile-supported wharf and associated structures. The proposed Dock 2 would extend approximately 800 feet from the shoreline and the Delaware River is approximately 0.9 miles wide at this location; therefore, the proposed Action would not create a physical barrier to movement of sturgeon. Project activities, such as dredging and noise from construction, may cause sturgeon to temporarily modify behavior to avoid the active work area, but these activities would be temporary and would not prevent sturgeon from accessing areas farther upstream. Dredging would increase water depths in a small portion of the Action Area, but otherwise would not affect water depth within the Delaware River. Based on this information, no adverse effects to PBF 3 are expected.

PBF 4 exists in the Action Area. Flow, temperature, and DO are likely to be highly spatially and temporally variable throughout the Action Area. ACOE determined that the Project would not change the flow or hydraulics of the river channel within the Action Area and therefore would not measurably change normal tidal or salinity conditions. Suspension of sediment during dredging may temporarily affect DO, but flow and settling of sediment would return to pre-project conditions within a few days after dredging is complete. Bottom water temperatures in the Dredging Area and Construction Area may decrease slightly because of increased depth and shading, but changes in average water temperature within the Action Area would not be meaningfully measured, detected, or evaluated within the temporal and spatial natural variation in water temperatures of the river channel.

Given the anticipated insignificant level of effects, the proposed Action is not likely to destroy or adversely modify proposed critical habitat for the Atlantic sturgeon.


Conclusion Ramboll

9. CONCLUSION

This assessment of potential effects of the proposed Project relative to baseline provided herein supports a finding that the proposed activity may affect but is not likely to adversely affect any federally-listed threatened or endangered species or designated critical habitat for Atlantic and shortnose sturgeon under the auspices of NMFS. This determination is based on the best available information at the current time.

As detailed above, neither development nor operational activities associated with the Project are likely to result in negative impacts to protected marine species. Considerable mitigation effort, including specific techniques, will be employed during construction to limit or eliminate risk of impacts to Atlantic and shortnose sturgeon. In terms of operations, Dock 2 will not result in additional vessel traffic beyond the new vessel traffic considered by PCOE, NMFS, and other agencies when evaluating plans for Dock 1. Importantly, due to fact that no additional vessel traffic over baseline is expected as result of Dock 2 operations no take of any federally-listed threatened or endangered species is anticipated. In sum, Dock 2 is not likely to adversely affect any federally-listed threatened or endangered species or designated critical habitat.


References Ramboll

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Dadswell, M.J. 1979. Biology and population characteristics of the shortnose sturgeon, Acipenser brevirostrum LeSueur, 1818 (Osteichthyes: Acipenseridae), in the Saint John River estuary, New Brunswick, Canada. Canadian Journal of Zoology 57:2186-2210.

Dadswell, M. J., B. D. Taubert, T. S. Squiers, D. Marchette, and J. Buckley. 1984. Synopsis of Biological Data on Shortnose Sturgeon, Acipenser brevirostrum, LeSuer.

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Environmental Research and Consulting, Inc. (ERC). 2006. Acoustic telemetry study of the movements of shortnose sturgeon in the Delaware River and bay progress report for 2003- 2004. Prepared for NOAA Fisheries. 11 pp.

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Fisher, M. 2011. Atlantic Sturgeon Final Report. State Wildlife Grant Project T-4-1. Delaware Division of Fish and Wildlife Department of Natural Resources and Environmental Control. Smyrna, Delaware. 44 pp.

Grunwald, C., L.Maceda, J.Waldman, J. Stabile, and I. Wirgin. 2007. Conservation of Atlantic sturgeon Acipenser oxyrinchus: delineation of stock structure and distinct population segments. Conservation Genetics DOI 10.1007/s10592-007-9240-1.

Hale, E. A., et al.. 2016. Abundance Estimate for and Habitat Use by Early Juvenile Atlantic Sturgeon within the Delaware River Estuary. Transactions of the American Fisheries Society 145(6):1193-1201.

Hardy RS, Litvak MK. 2004. Effects of temperature on the early development, growth, and survival of shortnose sturgeon, Acipenser brevirostrum, and Atlantic sturgeon, Acipenser oxyrhynchus, yolk-sac larvae. Environ. Biol. Fishes 70(2): 145-154.

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Kreeger, D., J. Adkins, P. Cole, R. Najjar, D. Velinsky, P. Conolly and J. Kraeuter. 2010. Climate change and the Delaware Estuary: Three case studies in vulnerability assessment and adaptation planning. Partnership for the Delaware Estuary Report No. 10‐01. 117 pp.

Kieffer, M.C. and B. Kynard. 1993. Annual movements of shortnose and Atlantic sturgeons in the Merrimack River, Massachusetts. Transactions of the American Fisheries Society 122:1088-1103.

Kynard, B. and M. Horgan. 2002. Ontogenetic behavior and migration of Atlantic sturgeon, Acipenser oxyrinchus oxyrinchus, and shortnose sturgeon, A. brevirostrum, with notes on social behavior. Environmental Behavior of Fishes 63: 137-150.

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National Marine Fisheries Service (NMFS). 2015. Biological Opinion: Deepening of the Delaware River Federal Navigation Channel (Reinitiation) NER-2015-12624. Conducted by National Marine Fisheries Service, Greater Atlantic Regional Fisheries Office. November 20.

National Marine Fisheries Service (NMFS). 2016e. Letter regarding Manchester Harbor Dredging, NAE-2012-558. October 27.

National Marine Fisheries Service (NMFS). 2017. Biological Opinion: Biological and Conference Opinion on the Proposed Implementation of a Program for the Issuance of Permits for Research and Enhancement Activities on the Atlantic and Shortnose Sturgeon Pursuant to Section 10(a) of the Endangered Species Act. Conducted by Endangered Species Act Interagency Cooperation Division, Office of Protected Resources, National Marine Fisheries Service. March 20.

National Marine Fisheries Service (NMFS). 2017b. Biological Opinion: Tappan Zee Bridge Replacement NER-2016-13822. Conducted by National Marine Fisheries Service, Greater Atlantic Regional Fisheries Office. January 4.

National Marine Fisheries Service (NMFS). 2017c.Biological Opinion: CENAP-OR-R-2016-0181-39. Gibbstown Shipping Terminal and Logistics, December 8.

National Marine Fisheries Service (NMFS). 2017f. GAFRO Master ESA Species Table – Atlantic sturgeon. Accessed at: https://www.greateratlantic.fisheries.noaa.gov/protected/section7/listing/garfo_master_esa_species_table_-_atlantic_sturgeon_051917.pdf

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169000609-001

ATLANTIC AND SHORTNOSE STURGEON IMPACT ASSESSMENT REPORT

Ramboll

FIGURES

Y:\_

Proj

ects\

Repa

uno\

GIS\

MXD\

D2 M

aps\

CGP2

3_ap

plica

tion\

1_SL

M.m

xd

PROJECT AREA(X) = 265,565(Y) = 370,008


1 inch = 2,000 feet

0 2,000

SCALE IN FEET

PROJECT: 1690000609

FIGURE1





Y:\_Projects\Repauno\GIS\MXD\D2 Maps\Buffer_Areas.mxd

ACTION AREA

DRAFTED BY: SKI DATE: 2/21/2019 1690000609-001

0 1,000

SCALE IN FEET

FIGURE2DRP GIBBSTOWN LOGISTICS CENTER

200 N REPAUNO AVEGIBBSTOWN, NEW JERSEY

FEDERAL NAVIGATION CHANNEL

328 FT. DREDGE TSS RADIUS(LESS THAN 120 MG/L ABOVE BACKGROUND

DREDGING AREA

CONSTRUCTION AREA295 FT. NOISE RADIUS

NOTES:1. The Action Area for proposed project includes the area of Dock 2 construction ("Construction Area") and 295 feet radius to accountfor the acoustic behaviors threshold for sturgeon, the dredging activities ("Dredging Area") and a 328 feet radius from dredgingfootprint to account for total suspended sediments. While not shown on the this figure, the Action Area also includes all routes taken byproject vessels. Service Layer Credits: Sources: Esri, HERE, Garmin, USGS, Intermap, INCREMENT P, NRCan, Esri Japan, METI, Esri China (Hong

Kong), Esri Korea, Esri (Thailand), NGCC, © OpenStreetMap contributors, and the GIS User Community


Ramboll

APPENDIX E ALTERNATIVES ANALYSIS

Prepared for: Delaware River Partners LLC Gibbstown, New Jersey

Prepared By: Ramboll US Corporation and Moffat & Nichol

Date February 2019

Project Number 1690000609

ALTERNATIVES ANALYSIS DOCK 2 DRP GIBBSTOWN LOGISTICS CENTER GIBBSTOWN, GLOUCESTER COUNTY, NEW JERSEY

ALTERNATIVES ANALYSIS: DOCK 2 DRP GIBBSTOWN LOGISTICS CENTER i

Contents

CONTENTS

0. EXECUTIVE SUMMARY 1

1. INTRODUCTION 4 1.1 Background 4 1.2 Project Description and Requirements 4 1.3 Report Purpose 5 1.4 Report Organization 6

2. PROJECT PURPOSE AND NEED 7 2.1 Project Purpose 7 2.2 Project Need 9 2.2.1 Regional Market Outlook for Energy Liquid Exports 9 2.2.2 Existing Regional Capacity 12 2.2.3 Need for Additional Facilities 12 2.2.4 Berth Demand at Gibbstown Logistics Center 12

3. ALTERNATIVE PROJECT LOCATIONS 13 3.1 Existing SJPC facilities in Camden County 14 3.1.1 Environmental Considerations 16 3.1.2 Potential to Meet Project Purpose 16 3.2 DuPont Property in Carneys Point, Salem County 16 3.2.1 Environmental Considerations 18 3.2.2 Potential to Meet Project Purpose 18 3.3 Ferro Industrial Site in Logan Township, Gloucester County 18 3.3.1 Environmental Considerations 20 3.3.2 Potential to Meet Project Purpose 20 3.4 Raccoon Island Site in Bridgeport, Logan Township, Gloucester County 21 3.4.1 Environmental Considerations 23 3.4.2 Potential to Meet Project Purpose 23 3.5 Paulsboro Marine Terminal (Former BP Oil Terminal), Paulsboro, Gloucester County 23 3.5.1 Environmental Considerations 24 3.5.2 Potential to Meet Project Purpose 24 3.6 DRP Gibbstown Logistics Center - Preferred Alternative 25 3.6.1 Environmental Considerations 27 3.6.2 Potential to Meet Project Purpose 28 3.7 Southport Brownfield Development Area in Gloucester City, Camden County 29 3.7.1 Environmental Considerations 29 3.7.2 Potential to Meet Project Purpose 30 3.8 Penn Terminal Site, Eddystone, Delaware County, Pennsylvania 30 3.8.1 Environmental Considerations 31 3.8.2 Potential to Meet Project Purpose 31 3.9 Southport Marine Terminal Complex in Philadelphia, Pennsylvania 32 3.9.1 Environmental Considerations 33 3.9.2 Potential to Meet Project Purpose 33

ALTERNATIVES ANALYSIS: DOCK 2 DRP GIBBSTOWN LOGISTICS CENTER ii

Contents

4. ANALYSIS OF ALTERNATIVE PROJECT LOCATIONS 34 4.1 Analysis Criteria 34 4.1.1 Potential Impacts to Environmental Resources 34 4.1.2 Project Purpose 34 4.1.3 Logistics 34 4.1.4 Cost 34 4.1.5 Technology and Infrastructure 34 4.2 Evaluation of Alternative Sites 35 4.2.1 Existing SJPC facilities in Camden County 35 4.2.2 DuPont Property in Carneys Point, Salem County 35 4.2.3 Ferro Industrial Site in Logan Township, Gloucester County 35 4.2.4 Raccoon Island Site in Logan Township, Gloucester County 36 4.2.5 Paulsboro Marine Terminal (Former BP Oil site) in Paulsboro, Gloucester County 37 4.2.6 DRP Gibbstown Logistics Center Site - Preferred Alternative 37 4.2.7 Southport Brownfield Development area in Gloucester City, Camden County 38 4.2.8 Penn Terminal Site in Eddystone, Delaware County, Pennsylvania 38 4.2.9 Southport Marine Terminal Complex in Philadelphia, Philadelphia County, Pennsylvania 38 4.3 Alternative Site Recommendations 39 4.4 Sites Potentially Suitable for Project Purpose 39

5. DESCRIPTION OF PREFERRED SITE – DRP GIBBSTOWN LOGISTICS CENTER 42 5.1 Former Thompson’s Point Pier 42 5.2 Landside Conditions 43 5.3 Existing Ship Traffic on the Delaware River 44 5.4 Project Vessel Traffic for the Project 45 5.5 Ballast Water Considerations 45

6. ALTERNATIVE DOCK CONFIGURATIONS 46 6.1 Berth Configuration Requirements 46 6.2 Other Berth Location Considerations 47 6.2.1 Berth Layout 1 47 6.2.2 Berth Layout 2 48 6.2.3 Berth Layout 3 49 6.2.4 Berth Layout 4 50 6.3 Comparison of Alternatives 51 6.4 Preferred Berth Alternative 52

7. SUMMARY 53

8. REFERENCES 54

ALTERNATIVES ANALYSIS: DOCK 2 DRP GIBBSTOWN LOGISTICS CENTER iii

Contents

FIGURES

Figure 1: General Location Map

Figure 2: Dock 1 and Dock 2 General Arrangement Plan

Figure 3: Two Large Liquefied Gas Carriers Moored at Dock 2

Figure 4: U.S. Net Trade of Gas Liquids – Historical and Forecast

Figure 5: Gas Liquids Exports – Total East Coast and By Product

Figure 6: Gas Liquids Exports – East Coast (PADD1) Trends

Figure 7: Gas Liquids Production and Processing Capacity in Appalachian Region

Figure 8: Alternative Marine Terminal Locations

Figure 9: SJPC Camden County Terminals

Figure 10: DuPont Property at Carneys Point

Figure 11: Ferro Industrial Site

Figure 12: Ferro Industrial Site Proximity to Rail

Figure 13: Raccoon Island Site

Figure 14: Raccoon Island Site Proximity to Rail

Figure 15: Paulsboro Marine Terminal Planned Layout

Figure 16: DRP Gibbstown Logistics Center – 1930 Aerial Photograph

Figure 17: DRP Gibbstown Logistics Center

Figure 18: Southport Brownfield Development Area

Figure 19: Penn Terminal Site

Figure 20: Southport Marine Terminal Complex

Figure 21: Marine Structures and Bathymetry

Figure 22: Existing Marine Facilities, 2018

Figure 23: Layout 1 Berth Alternative




TABLES

Table 1: Berth Demand Estimate at DRP Gibbstown Logistics Center

Table 2: Alternative Site Comparison

Table 3: Existing Ship Traffic

Table 4: Design Ship Dimensions

Table 5: Comparison of Alternative Configurations

ALTERNATIVES ANALYSIS: DOCK 2 DRP GIBBSTOWN LOGISTICS CENTER iv

Acronyms and Abbreviations


DRP: Delaware River Partners LLC

DRPA: Delaware River Port Authority

DOE: Department of Energy

EIA: U.S. Energy Information Administration

FUSRAP: Formerly Utilized Sites Remedial Action Program

MED: Manhattan Engineering District

MLLW: Mean Lower Low Water

NJDEP: New Jersey Department of Environmental Protection

SJPC: South Jersey Port Corporation

SNJWPM: Southern New Jersey Waterfront Master Plan

ALTERNATIVES ANALYSIS: DOCK 2 DRP GIBBSTOWN LOGISTICS CENTER 1

Executive Summary

0. EXECUTIVE SUMMARY

Delaware River Partners LLC (“DRP”) is actively redeveloping the former DuPont Repauno Works Site (the “Site” or “Property”), a brownfield site situated on the Delaware River in Greenwich Township, Gloucester County, New Jersey, into a deep-water seaport and logistics center (“Gibbstown Logistics Center” or “GLC”). After starting construction of a new wharf at the Site in 2017, DRP has received significant positive interest and commitments from potential users of port services. In response, DRP seeks to add a second dock (“Dock 2”) to transload bulk liquid products to complement the current redevelopment of the multi-purpose berth (“Dock 1”). The construction of this new facility (the “Project”) would provide safe navigational access, mooring, and loading equipment for two vessels up to 173,400 cubic meters in capacity and up to 120,000 deadweight tons displacement. It would be located west (downriver) of Dock 1, which is currently under construction, and would utilize the landside marine terminal infrastructure at the Gibbstown Logistics Center, which is under development at the Site. Once operational, Dock 2 is initially expected to facilitate the transloading of bulk liquid products. The addition of Dock 2 will allow better utilization of the single berth Dock 1 for the other permitted cargo, based on current market demand and projections of future demand. However, once operational, Dock 2 is not expected to increase the total number of vessels calling on the Site. The construction of Dock 2 would establish GLC as a deep-water seaport for transloading of liquid products that will serve as a catalyst for economic growth in the local community and the wider Delaware Valley region. Dock 2 will be the first seaport facility of its kind on the east coast of the United States (“East Coast”), serving as an international product transfer hub and economic growth driver.

The Site is a brownfield that housed industrial development and operations for over a century, and DRP is rehabilitating the Site to once again be put to productive use. The Site contains hundreds of acres of previously developed waterfront land, approximately 371 acres of which is currently being redeveloped into the GLC, with existing internal railways with connectivity to regional rail corridors and proximity to major highways. Highlighting its suitability for improvement, the Site was designated as an area in need of redevelopment pursuant to the Local Redevelopment and Housing Law, N.J.S.A. 40A:12A-1, et seq., in 2003. In order to successfully advance DRP’s redevelopment goals, improvements at the Site have been designed to minimize environmental impacts by focusing on previously disturbed areas associated with prior industrial operations. Moreover, developing Dock 2 in the vicinity of a prior dock and in coordination with the ongoing development allows the Project to take advantage of years of experience with the Site, as well as synergies in development and construction techniques, to further minimize impacts. Specifically, the ongoing redevelopment of the Site as a logistics center and multi-faceted port facility provides a unique opportunity to capitalize on existing and planned infrastructure, minimizing the need for new construction landside. In that respect, the Site is entirely unique among available alternative locations in the region.

Critically, there is no suitable alternative site for this Project in the region. An investigation of alternative locations reveals that the Site is the only location that offers vital infrastructure assets as well as close proximity to transportation corridors, which will enable DRP to reduce land disturbance and avoid adverse impacts to sensitive environmental areas that would be necessary to replicate this critical infrastructure at another location. Given this confluence of existing on-site conditions and access to major transportation infrastructure, the Project would have the least cumulative adverse environmental impact if it is developed at the Site as opposed to an alternative location. Moreover, by furthering the rehabilitation of a former major industrial site and job generator, DRP has selected the alternative that best avoids or minimizes overall environmental impacts. In short, there is no practicable alternative to the Site, as detailed in Section 3 below.


Executive Summary

Within the Property, previous development was concentrated in the northern waterfront area, and the Project has been designed to generally correspond to these former industrial and manufacturing areas. The proposed Dock 2 will be located in the general vicinity of a pre-existing, deteriorated timber pier that previously provided direct rail access to vessels. Several alternative layouts were considered. The proposed alternative reduces the total amount of in-water work and potential for disturbance of protected habitat. The landing for the proposed pier would be located within the footprint of the marine terminal that is currently under development.

To meet the project purpose (as detailed in Section 2, below), the landside improvements supporting vessel loading operations must be near the proposed Dock 2 in order to accommodate transit. Through its iterative design process, DRP has been able to design Dock 2 to avoid sensitive aquatic vegetation and minimize the amount of dredging. Relatedly, through the feasibility and design process, configurations were developed based on project needs while considering site constraints and the objective of reducing impacts to sensitive environmental areas to the greatest extent practicable. The following table summarizes the Dock 2 layout configurations considered and the associated impacts, particularly to wetlands and sensitive aquatic vegetation.

The preliminary engineering analysis concluded that Layouts 1 and 4 have the best overall maritime safety performance. For Layouts 1 and 4, moorings have the highest at-berth wind limits with the least impact from passing vessels. Layout 2 is subject to potential risks from passing vessel traffic, whereas mooring performance for Layout 3 is marginal with lower safety factors under high wind and current. Layouts 1 and 4 have the best access for vessels with turning areas immediately adjacent to the berths, the shortest duration for berthing, and the most separation from the Federal Navigation Channel. Layout 3 is unacceptable for navigation with very limited access windows for vessels and difficulty departing berth under tidal currents. It is important to note that Layout 4, while similar to Layout 1, reduces dredging volumes and locates the access trestle to minimize impacts to submerged aquatic vegetation.

In summary, particularly in light of the existing infrastructure assets and previous industrial uses, there is no comparable alternative location for the Project that would further minimize environmental impacts, nor is there an alternative site that is more suitable for the intended purpose of the Project. 1 Cost are preliminary estimates based on general location and configuration of the proposed structure.

Alternative

Dock 2 Layouts

Total Over-Water

Footprint

Total Dredging Area/ Volume

Intertidal/ Subtidal Shallows Impact

SAV Impact

Cost1 Meets Project

Purpose & Logistics

Layout 1 3 acres 59 acres 1,181,750 cy

0.38 acres 0.18 acres

Moderate Cost ($129M)

Suitable

Layout 2 3.1 acres 21 acres 104,350 cy


Lowest Cost ($100.3M)

Not practicable



Highest Cost ($133.3M)

Not practicable


0.26 acres 0 acres Moderate Cost ($120M)

Suitable


Executive Summary

By selecting this Property, the Project focus is on redevelopment of a brownfield site, and avoids creating wholly new land disturbance and associated environmental externalities. Through an iterative feasibility study process, the Project has been designed to minimize adverse environmental impacts to the maximum extent practicable while restoring a brownfield site. The Project will also contribute to and enhance the economic benefits associated with the ongoing redevelopment at the Site, including job creation, community revitalization, infrastructure improvements, and overall economic growth in the region. More specifically, the Project is expected to generate approximately 250-person years of construction activity, and approximately 40 to 50 full time positions once Dock 2 is in operation. In addition to on-site sustainable employment opportunities, local businesses will have the opportunity to provide services in a broad range of areas related to the construction and ongoing operation of Dock 2. The large capital investment and annual operating expenses associated with the Project will help create jobs, diversify economic activity at the local level, and will function as a primary vehicle for long-term economic stability in the region for future generations. Dock 2, and the GLC as a whole, will revitalize a community and region once dependent on this former industrial facility.


Introduction

1. INTRODUCTION

1.1 Background The former DuPont Repauno Works Site2 is an approximately 1,630-acre brownfields site in Greenwich Township, Gloucester County, New Jersey (see Figure 1). The Site is currently being redeveloped into the GLC, a multi-use, deep-water seaport and industrial logistics center. The proposed project that is the subject of this alternatives analysis involves the construction of a second dock at the DRP Gibbstown Logistics Center. Construction of Dock 2 would allow better utilization of the single berth at Dock 1 for other cargo, based on current marketing demand and projected future demand. During the permitting process for development of the GLC, including Dock 1, DRP evaluated other properties along the Delaware River for suitability. The Site represented a unique opportunity to create a new marine terminal in one of the most active seaport markets in North America while redeveloping an underutilized former industrial facility and, as a result, minimizing environmental impacts associated with development. DRP acquired the Property in March 2016 and construction of Dock 1 commenced in December 2017.

1.2 Project Description and Requirements The GLC was conceived because of opportunities within the region for the development of a private port. Dock 2 supports the transloading operations at the GLC, which are a critical component of the facility. The unique features of the Site have resulted in an ongoing redevelopment effort which will allow a once productive industrial site to rise again as an economic driver for the community, state, and region. Because of the Site’s location, size, and characteristics, it is highly suitable for additional deep-water berths supported by an industrial logistics center. The Site offers the following key features which are well suited to the proposed use and not found elsewhere in the geographic region:

1. Size and Current Use: The Site is approximately 1,630 acres, with approximately 371 acres of developable land near the waterfront, which is currently being redeveloped as a deep-water seaport and industrial logistics center.

2. Location: The Site is located within the greater Philadelphia market area and is within close proximity of the greater New York/New Jersey market area. The Site is also less than 90 nautical miles from the Atlantic Ocean. This location provides ease of access for an array of commercial opportunities.

3. Road Access: The Site will have sufficient and suitable roadway access to support sitewide operations.

4. Access to Navigation Channel: The Delaware River Federal Navigation Channel (“Federal Navigation Channel”) is located approximately 650 feet from the proposed berths.

5. Existing Waterfront Infrastructure: Historically, the Site had two separate operational wharfs or piers. The former wharf at Crab Point is currently under development by DRP as a multi-purpose dock (Dock 1). A double barge berth was located at Thompson’s Point, the location identified for

2 This property was owned by DuPont until 2015, when it was transferred to The Chemours Company. It was also

known as DuPont Repauno Works.


Introduction

Dock 2. In addition, the waterfront is being developed as a marine terminal to provide the landside infrastructure needed for Dock 1, and would also support Dock 2.

6. Existing Inland Distribution Infrastructure: The portion of the Site proposed for redevelopment has existing rail and road access, which can be enhanced or rehabilitated to meet the project purpose with less overall land and environmental disturbance than other existing or new facilities. Portions of this upland infrastructure are already permitted for redevelopment associated with the GLC and Dock 1, which are currently under construction.

7. Subterranean Storage Cavern: The Site features a unique subterranean storage cavern with a shell capacity of approximately 7.8 million gallons (186,000 barrels) of bulk liquids, reducing the necessary land disturbance to accommodate storage demands by 2.1 acres.

Figure 1: General Location Map

1.3 Report Purpose This alternatives analysis provides: (1) a comparative analysis of other potential sites in the region that may have suitable characteristics for this type of development; (2) a discussion of alternative


Introduction

configurations of the proposed Project for the preferred site; and (3) the efforts taken to reduce impacts to environmentally sensitive areas to the maximum extent practicable while meeting the Project purpose.

1.4 Report Organization This report is organized as follows:

• Section 0, Executive Summary.

• Section 1, Introduction, provides background information, project description and requirements, and the purpose of this report.

• Section 2, Project Need, describes the current state of ports in the greater Philadelphia region and the need for additional port capacity.

• Section 3, Alternative Project Locations, describes alternative locations in the region that may have suitable characteristics for the Project.

• Section 4, Analysis of Alternative Project Location, provides an analysis of alternative locations for this project and explains the preferred location.

• Section 5, Description of Preferred Site, provides a description of the Site, the preferred alternative for the Project.

• Section 6, Alternative Project Configurations, provides a review of alternative configurations that were considered for the Site and describes the selection of a configuration with the least environmental impact practicable given project requirements and site constraints.

• Section 7, Summary.


Project Purpose and Need

2. PROJECT PURPOSE AND NEED

Dock 2 was conceived to address the growing demand for port infrastructure in the Southern New Jersey/Southeastern Philadelphia Region along the Delaware River to support the transloading of bulk liquid products.

Exports of bulk liquid products from the United States continue to grow at a rapid pace overall. In the last few years, the East Coast region is beginning to experience significant growth, with a 10-fold increase since 2013, according to the data reported by the United States Energy Information Administration (“EIA”)3.

The completion of the Delaware River Main Channel Deepening Project4, combined with the proximity of production areas, will only accelerate the exports of bulk liquid products within the Southern New Jersey/Southeastern Philadelphia region. The development of Dock 2 at the GLC will address this critical infrastructure need. More specifically, the Project will accomplish the following goals:

• Provide a deep-water port along the lower Delaware River that will support the projected growth of liquid product exports;

• Provide berth capacity for bulk liquid products, thereby freeing up berth capacity at Dock 1 for accommodating roll-on/roll-off (“RoRo”), break-bulk ships, and other project cargo;

• Develop a state-of-the-art facility that can handle the largest bulk liquid transport vessels that are expected to be operating within the Delaware River once the deepening project is completed;

• Complement the existing liquid product terminals throughout this region; and

• Stimulate the regional and local economies both during construction and operation.

The regional need for additional shipping infrastructure and the response to this need through the development of Dock 2 is detailed further below.

2.1 Project Purpose The purpose of the Project is to develop a deep-water facility for the export of bulk liquid products. To provide the necessary capacity to handle the projected terminal throughput, Dock 2 will include two liquids berths so one ship can be docked at Dock 1 and two ships can be docked at Dock 2. All three berths will be capable of loading from either trucks or rail cars. The general arrangement plan of Dock 1 and Dock 2 is depicted in Figure 2.

3 https://www.eia.gov/dnav/pet/pet_move_exp_dc_NUS-Z00_mbblpd_m.htm. 4 https://www.nap.usace.army.mil/Missions/Civil-Works/Delaware-River-Main-Channel-Deepening.



Figure 2: Dock 1 and Dock 2 General Arrangement Plan

Source: Moffatt & Nichol

Dock 2 must have adequate length to accommodate jetty terminal structures, including access trestle, pipe racks, loading platforms, mooring dolphins, and breasting dolphins, for two berths. Each berth will be capable of docking bulk liquid product carriers with a capacity of approximately 173,400 cubic meters and a maximum draft of 40 feet. The configuration of Dock 2 with bulk liquid product carriers moored at each berth is shown in Figure 3.



Figure 3 Two Bulk Liquid Carriers Moored at Dock 2

Source: Moffatt & Nichol

2.2 Project Need 2.2.1 Regional Market Outlook for Energy Liquid Exports According to the EIA, existing production facilities are expected to produce an additional 400,000 barrels per day (b/d) of bulk liquids in 20195. Similarly, it is expected that net exports of liquid products will increase by approximately 350,000 b/d by 2019. An additional increase of approximately 250,000 b/d is expected by 2020. This equates to an increase of roughly 20% annually, as shown in Figure 4.

5 EIA’s Short-Term Energy Outlook. July 26, 2018. U.S. Energy Information Administration.



Figure 4 U.S. Net Trade of Gas Liquids (million barrels per day) – Historical and Forecast

Source: U.S. Energy Information Administration, Short-Term Energy Outlook, February 2019 Most of these products are exported from the Gulf Coast region; however, the East Coast is also experiencing significant growth. Certainly, the East Coast exports reported by the EIA demonstrate this ongoing growth (see Figure 5).

Figure 5 Gas Liquid Exports (million barrels per year) – Total East Coast (PADD1)

Source: U.S. Energy Information Administration The trend of bulk liquid products exported from the East Coast using historical data demonstrates the likelihood of steady growth over the coming years. As presented in Figure 6 below, considering a five-year horizon (2024), two projections were calculated, the first using five years of data (2012-2017) and the second using 10 years (2007-2017), obtaining export projections around 80,000 million

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

20172016201520142013201220112010200920082007



barrels per year (Mbbls/year) and 50,000 Mbbls/year for 2024, respectively. The former is more in line with the 20% yearly projection reported by the EIA.

Figure 6: Gas Liquids Exports (million barrels per year) – East Coast (PADD1) Trends

Source: M&N based on data from the U.S. Energy Information Administration

Processing capacity for bulk liquid products in the Appalachian region has grown dramatically over the past several years. Together with the processing capacity increase, bulk liquid production has increased in that region.

Figure 7: Gas Liquids Production and Processing Capacity in Appalachian Region

Source: U.S. Energy Information Administration

The expected increase of production of bulk liquid products in the Appalachian region, suggests the need for greater bulk liquids export capacity along the Delaware River.



2.2.2 Existing Regional Capacity

The Sunoco Marcus Hook Industrial Complex is the only active export facility along the Delaware River for the product mix that Dock 2 is designed to accommodate. Total storage capacity is about three million barrels. Marcus Hook can receive product via pipeline, truck, or rail. The terminal currently ships 70,000 barrels per day but is expected to increase to 345,000 barrels per day in the future. There are four berths with deep water draft capable of accommodating bulk liquid carriers and one additional position for river barges. This one location may not be able sustain the increase in demand long term.

2.2.3 Need for Additional Facilities From a commodity perspective, the GLC is unique. By comparison, the neighboring Paulsboro facility will focus on handling dry bulk (e.g., salt and aggregates), project cargo, steel, and other break bulk cargos (e.g., forest products and lumber). The GLC, with the addition of Dock 2, will complement the Paulsboro facility by focusing on bulk liquid cargos.

The current port capacity along the Delaware River for accommodating the growing liquid product export volumes is therefore limited and may be strained in the short/mid-term. By providing additional berths dedicated to liquid product deep draft vessels at the GLC, the market pressure on a single facility in Pennsylvania will be alleviated and continued export growth benefitting New Jersey and the region are ensured.

2.2.4 Berth Demand at Gibbstown Logistics Center The original business plan for Dock 1 was based on handling RoRo, break-bulk, crude oil, and refined product ships. However, due to market conditions, expected business for Dock 1 has shifted, with an increase in projected demand for bulk liquid products. The resulting number of berth-days for all ships expected to call on Dock 1 at the GLC as shown in Table 1 is 290. This results in an 80% berth occupancy for a single berth. Industry standards recommend a maximum 50% berth occupancy for a single berth with random arrivals (which is applicable to multipurpose terminals)6. In addition, Dock 2 will handle vessels that require longer loading periods. As a result, additional berths are now required to handle the projected number of ship calls.

Table 1 Berth Demand Estimate at Gibbstown Logistics Center

Cargo Type Annual Volume Units Ship

Capacity Number of

Vessels

Days at Dock Per

Ship

Total Dock Days

RoRo 100,000 units 2,500 40 2 80

Break Bulk 288,000 MT 12,000 24 3.5 84

Refined Products 4,800,000 bbls 400,000 12 3.5 42

Bulk Liquids 12,768,000 bbls 532,000 24 3.5 84

Total – Dock 1 100 290


Total – Dock 2 37 370

6 Port Development Handbook, UNCTAD, 1985.


Alternative Project Locations

3. ALTERNATIVE PROJECT LOCATIONS

DRP has evaluated several alternative locations, which reveals that the Site is the only location that offers critical infrastructure assets as well as close proximity to transportation corridors, which will enable DRP to reduce land disturbance and avoid adverse impacts to sensitive environmental areas associated with replicating these features at another location. The Site’s legacy infrastructure and current redevelopment as a marine terminal are unique assets, and the Project would have the least cumulative adverse environmental impact if it is developed at the Site rather than alternative locations.

Given the nature of the proposed Project, alternative terminal locations were evaluated from sites considered in the Alternatives Analysis performed for the Dock 1 permit applications. Alternative locations were examined based upon proximity to the Federal Navigation Channel and potential access to rail and highways. Potential environmental constraints were identified using available national, New Jersey, and Pennsylvania state GIS resources7. When publicly available, site-specific reports were considered, as indicated in the sections below. The location alternatives evaluated included the following sites as shown on Figure 8:

• Existing SJPC facilities in City and County of Camden

• DuPont property in Carneys Point, Salem County

• Ferro Industrial site in Logan Township, Gloucester County

• Raccoon Island site in Logan Township, Gloucester County

• Former BP Oil Terminal site in Paulsboro, Gloucester County

• Former DuPont Repauno site in Greenwich Township, Gloucester County

• Southport Brownfield Development Area in Gloucester City, Camden County

• Penn Terminal site in Eddystone, Delaware County, Pennsylvania

• Southport Marine Terminal Complex in Philadelphia, Philadelphia County, Pennsylvania

7 Data sources include the National Wetlands Inventory, National GAP Analysis Program, USFWS Information for

Planning and Conservation tool, and New Jersey Landscape Project Species-Based Habitat (v3.1).



Figure 8: Alternative Marine Terminal Locations8

3.1 Existing SJPC facilities in Camden County Three terminals comprise the South Jersey Port Corporation (“SJPC”) Port of Camden: Balzano Marine Terminal; Broadway Terminal; and Broadway Pier 5. The Port of Camden has direct access to I-676, I-76, U.S. Rt. 130, and I-295. It is served by CSX and NS rail systems with integrated on-dock rail infrastructure. Figure 9 illustrates the location and relative layout of the Port of Camden. The following description gives specifics for each terminal. However, for the purposes of this Alternatives Analysis, the SJPC's Port of Camden will be evaluated as a single port location.

8 All maps in Section 3 prepared using map data from ©Google, 2016.



Figure 9: SJPC Camden County Terminals

Balzano Marine Terminal (formerly the Beckett Street Terminal) is a 122-acre complex located in Camden that handles wood products, steel products, cocoa beans, containers, iron ore, furnace slag, scrap metal, and project/over-dimensional cargo movements. The terminal has four berths (total 2,655 linear feet) at a depth of 35 feet to 40 feet (at MLLW), 21 dry warehouses comprising 1,168,441 square feet, one multi-purpose Kocks 95T bulk/container crane, and one general-purpose Paceco 35T cargo/container crane. This facility has no capabilities for handling bulk liquids.

Broadway Terminal is a 180-acre industrial port complex that handles petroleum coke, furnace slag, dolomite, other dry bulk items, steel products, wood products, minerals, and cocoa beans. The facility can also handle containerized cargo. Broadway Terminal covered storage totals 1.128 million square



feet. The terminal has two berths: Pier 1 at 900 linear feet with 35 feet of depth and Pier 1A at 850 linear feet with 40 feet of depth. This facility has no capabilities for handling bulk liquids.

Broadway Pier 5 (formerly Broadway Produce Terminal) is a 26-acre center located in Camden that is leased by Camden Waterfront Development LLC and operated by Southport Distribution. Both companies are part of the Holt Logistics family of companies. The facility handles bananas, pineapples, and other perishables. The terminal has one berth at 1,135 linear feet with 35 feet of depth. On-terminal refrigerated warehouse capacity includes three temperature-controlled warehouses: 60,000 square feet, 75,000 square feet, and 53,400 square feet. The terminal also has one 25,000-square-foot dry (non-refrigerated) warehouse for miscellaneous cargo. Containerized refrigerated cargo can be accommodated at the on-terminal storage site with 175 reefer plugs. This facility has no capabilities for handling bulk liquids.

3.1.1 Environmental Considerations The Port of Camden site is a previously developed and historically disturbed site. A review of available data did not identify any known freshwater wetlands on the site. Areas within the Broadway Terminal are identified as potentially suitable habitat for foraging bald eagle (a state endangered species). In addition, the portion of the Delaware River adjacent to the Port of Camden site is mapped as critical habitat for Atlantic sturgeon (federally endangered), an adult migration corridor for Atlantic and shortnose sturgeon (federally endangered), and an overwintering and foraging area for juveniles of both species. This portion of the Delaware is also mapped as Rank 3 habitat for freshwater mussel species.

3.1.2 Potential to Meet Project Purpose Collectively, the Port of Camden is an existing terminal facility located in a heavily populated urban area within the City of Camden. Much of the infrastructure needed to operate a marine terminal already exists at the site and opportunities may exist to increase terminal capacity. Additionally, the Port of Camden is rated well in terms of meeting local planning guidelines and avoiding environmental impacts due to its existing infrastructure. However, the Port of Camden is currently at its development limits and directly abuts Camden's Waterfront South neighborhood community. Additional site limitations include:

1. No land or additional wharf space available to expand beyond the current borders of the Port of Camden.

2. Aging waterfront infrastructure will require significant reconstruction to handle additional vessel calls or larger ships.

3. The project requires dredging to 43 feet below MLLW, plus two feet of allowable overdredge. With the exception of Pier 1A at Broadway Terminal and Berth 4 at the Balzano Terminal, the existing berths cannot be deepened below 35 feet MLLW without strengthening.

4. The Port of Camden does not support or have the capabilities necessary for operations related to handling bulk liquids.

3.2 DuPont Property in Carneys Point, Salem County The DuPont Chambers Works site is a 1,455-acre complex which includes Chambers Works chemical manufacturing area and the former Carneys Point Smokeless Powder Works. Figure 10 shows the location of the Chambers Works and Smokeless Powder Works within Pennsville and Carney Point



Townships, along the southeastern shore of the Delaware River, just north of the I-295 Delaware Memorial Bridge, and adjacent to the residential community of Deepwater, New Jersey. In the 1940s, the United States Army Corps of Engineers Manhattan Engineer District (“MED”) and the Atomic Energy Commission (“AEC”) contracted with DuPont to process uranium at the Chambers Works site.9

Figure 10: DuPont Property at Carneys Point

In 1974, the AEC (succeeded by the United States Department of Energy) established a site investigation and cleanup program that later became the Formerly Utilized Sites Remedial Action Program (“FUSRAP”). This program was initiated to identify, investigate, and clean up, or otherwise control, sites where residual radioactivity remained from activities conducted under contract with the MED or the AEC during the early years of the nation’s atomic energy program, or from commercial operations as directed by Congress.

MED activities were conducted within the 700-acre Chambers Works site. No MED research, processing activities or waste disposal occurred within the Carneys Point Smokeless Powder Works, located in the northern portion of the property, and therefore, that area is not part of the FUSRAP investigation.

The Chamber’s Works Industrial Facility has an existing timber pier structure that was used previously to load and unload product and materials destined to and from the facility. The pier structure is no

9 U.S. Army Corps of Engineers, Final Feasibility Study DuPont Chambers Works FUSRAP Site, Deepwater, New

Jersey; October 2012.



longer used due to changes at the facility as well as the pier’s deteriorated condition. This facility has no existing serviceable port infrastructure.

A previous report10 estimated three million cubic yards of sediment dredging would be required to accommodate a new wharf, with berths and access to the shipping channel. Even with design modifications to reduce dredging, Carneys Point is likely to require excess sediment removal and disposal to accommodate the anticipated calling vessels.

3.2.1 Environmental Considerations Carneys Point is a previously developed and historically disturbed site. Approximately 5.5 acres of freshwater wetlands are mapped on a portion of the site. In addition, portions of the Site are identified as habitat potentially suitable for foraging osprey (state threatened). The portion of the Delaware River adjacent to the Carneys Point site is also Essential Fish Habitat (“EFH”), critical habitat for Atlantic sturgeon (federally endangered), an adult migration corridor for Atlantic and shortnose sturgeon (federally endangered), and an overwintering and foraging area for juveniles of both species.

3.2.2 Potential to Meet Project Purpose Conceptually, the Carneys Point site could address many elements of the Project’s needs. Carneys Point is a brownfield site that is only suitable for industrial uses with rail access and connections to the interstate highway system. The Carneys Point site would enable expansion of terminal capacity in southern New Jersey and would provide adequate land area to develop transloading facilities. In addition, the relatively large developable land area would enable the Project to avoid many environmentally sensitive areas, and could result in lesser impact to freshwater wetlands. However, the Carneys Point site currently has a number of significant redevelopment constraints:

1. A relatively large volume of dredging (estimated at over three million cubic yards) would be required for adequate berthing. These impacts have the potential to adversely impact EFH or migrating adult or juvenile sturgeon, whereas these impacts are avoided or greatly diminished at the proposed GLC terminal.

2. The site has an ongoing FUSRAP investigation and remediation program as well as the potential for other sources of hazardous contamination or buried ordinance.

3. The existing pier adjacent to the hazardous FUSRAP Chambers Works site and the structure is not suitable for reuse and would have to be demolished and replaced.

4. There is no existing serviceable port infrastructure.

5. The Smokeless Powder Works site, although not contaminated with fissionable materials, may include other project impediments yet to be mapped.

3.3 Ferro Industrial Site in Logan Township, Gloucester County The proposed Ferro Industrial Site for a new marine terminal would occupy a portion of a 175-acre undeveloped parcel located along the Delaware River between Oldmans Creek and the Logan Generating Station, a pulverized coal-fired power plant owned by National Energy Power Company, L.L.C. The site is predominantly agricultural land and wetlands. Ten pipelines, including three natural

10 South Jersey Port Corporation, Executive Order No. 215 Environmental Impact Statement for the Paulsboro

Marine Terminal Project, May 2009.



gas pipelines, one nitrogen pipeline, and six Sun Oil Company pipelines traverse the site. Of the six Sun Oil Company pipelines on the site, three of the pipelines transport petroleum products (butane, jet fuel, and gasoline) and the other three pipelines are currently inactive.11 Figure 11 illustrates the site location.

Figure 11: Ferro Industrial Site

In 2003 the United States Fish and Wildlife Service (“USFWS”), in conjunction with the Logan Generating Station, initiated a habitat restoration program along the riverfront. Ten acres of fallow fields were planted to native trees and shrubs. In addition, a 0.2-mile long riparian area was revegetated using the same species as were used at the upland restoration site.

An Environmental Impact Statement (“EIS”) was prepared in 2006 for development of a liquefied natural gas import terminal that included gasification, storage and distribution at this site. However, the project was abandoned when market conditions were found to be unfavorable to the development. In the EIS process, several wetland areas were identified on the site.

There is presently a 1,600-foot coal-unloading pier with an 850-foot barge berth that serves the power plant. U.S. Route 130 borders the southern boundary of the site and provides access to the site via the existing road to the Logan Generating Station.

There are no existing rail lines servicing the Ferro Industrial Site. The nearest existing rail line is located approximately 0.35 miles west of the site (Figure 12). Developing a direct connection from

11 Final Environmental Impact Statement on the Crown Landing LNG and Logan Lateral Projects; Federal Energy

Regulatory Commission; April 28, 2006.



the site to existing rail would likely require additional environmental impacts, as many of the areas surrounding the site are mapped as freshwater wetlands.

Figure 12: Ferro Industrial Site Proximity to Existing Rail

3.3.1 Environmental Considerations Based on a 2006 EIS, freshwater wetlands are present on approximately 48 acres of the Ferro Industrial site. Much of the site is also mapped as suitable habitat for foraging bald eagle (state endangered). In addition, the portion of the Delaware River adjacent to the Ferro Industrial Site is also mapped critical habitat for Atlantic sturgeon (federally endangered), an adult migration corridor for Atlantic and shortnose sturgeon (federally endangered), and an overwintering and foraging area for juveniles of both species.

3.3.2 Potential to Meet Project Purpose A significant portion of the Ferro Industrial site contains freshwater wetlands and bald eagle habitat, which would be difficult to avoid due to the limited land area available for development (the site is 175 acres in total). The site is only partly zoned for industrial use and rezoning from farmland and open space to an industrial/maritime use would be required at the site. In addition, the site has significant waterfront constraints for port use:

1. Extensive intertidal and subtidal shallows lie offshore of the land area and dredging of at least two million cubic yards would be necessary to provide deep-water vessel access. Water shading, shoreline fill, and disruption of shoreline habitats may be unacceptable impacts.

2. There is no existing or planned useable landside infrastructure. Right of way restrictions of existing pipeline crossings may constrain use of this site.

3. Reconstruction and expansion of the existing barge berth will be necessary to handle the liquid bulk ships.



4. There is no existing rail access at the site. Development of rail access involves several significant logistical challenges, including a pipeline crossing and passage through existing residential and commercial developments.

3.4 Raccoon Island Site in Bridgeport, Logan Township, Gloucester County The Raccoon Island Site is an approximately 520-acre parcel located along the Delaware River at the outlet of Raccoon Creek in Logan Township, Gloucester County. This site is zoned for low density marina, located at the southwest corner of the intersection of Route 130 and Route 322. The site is bordered by the Commodore Barry Bridge to the north, the Delaware River to the west, Raccoon Creek to the south, and Route 130 to the east. The site is undeveloped and predominantly agricultural fields and wetlands. Figure 13 shows the site location.

Although the site is zoned for industrial development, approximately half of the site is currently being used for agricultural purposes. Several wetland areas have been identified on the site. Highway access to the site is extremely limited and there is no direct connection to Route 130 or Route 322. Main access to the site would be via Springer Lane which would require major improvements to accommodate vehicle traffic generated by the Project.

There are underground pipelines and utilities crossing the site to the Delaware River which restrict/encumber berth positioning.

There are no existing rail lines servicing the Raccoon Island Site. The nearest existing rail line is located approximately one mile south of the site (Figure 14). Connecting the site to the existing rail line would require crossing a major highway and passage through residential and commercial properties in the town of Bridgeport, New Jersey. Due to the presence of wetlands in areas surrounding the site, establishing a connection to the mainline rail would also likely require additional environmental impacts.



Figure 13: Raccoon Island Site

Figure 14: Raccoon Island Site Proximity to Existing Rail



3.4.1 Environmental Considerations As an agricultural and undeveloped wetlands area, the Raccoon Island site contains a number of potentially sensitive environmental areas. Over 30% of the site is mapped as freshwater wetlands habitat, including approximately 10 acres of forested wetlands. The site contains over 200 acres of contiguous forest and has been identified as potential habitat for the federally-endangered northern long-eared bat. In addition, much of the available land area of the site has been identified as potentially suitable habitat for foraging and nesting bald eagle, foraging osprey, and migrating adult shortnose sturgeon. Tidal areas of the site along Raccoon Creek may also provide suitable habitat for sensitive joint vetch, a federally-endangered plant species. The portion of the Delaware River adjacent to Raccoon Island Site is also critical habitat for Atlantic sturgeon (federally endangered), an adult migration corridor for Atlantic and shortnose sturgeon (federally endangered), and an overwintering and foraging area for juveniles of both species.

3.4.2 Potential to Meet Project Purpose At 520 acres, the Raccoon Island site has sufficient area to meet Project needs. The site is zoned for low density marina, so rezoning for industrial/maritime use would be required at the Logan Township site. Forest clearing may also be required to develop access and storage at the site, which may be unacceptable due to adverse impacts to endangered bat species. In addition, the site has significant waterfront constraints for port use:

1. There is no existing wharf or pier at this site. Water shading, shoreline fill, and disruption of shoreline habitats may be unacceptable impacts.

2. Extensive intertidal and subtidal shallows lie offshore of the land area and dredging of at least three million cubic yards would be necessary to provide deep-water vessel access.

3. Right of way restrictions of existing pipeline and utility crossings may constrain use of this site.

4. Highway access is extremely limited and would require substantial work to overcome. Truck access to/from Route 130 North would route the traffic through a residential neighborhood. Truck traffic to/from Route 130 South would involve improving several rural roads. New entry and exit ramps would be required at Route 130.

5. There is no existing rail access at the site. Development of rail access involves several significant logistical challenges, including a major highway crossing and passage through existing residential and commercial developments. In addition, due to the presence of surrounding wetlands, extending rail access would necessitate additional environmental impacts.

3.5 Paulsboro Marine Terminal (Former BP Oil Terminal), Paulsboro, Gloucester County

Paulsboro Marine Terminal located in Paulsboro, New Jersey, will be a multi-use general cargo terminal with heavy-lift capabilities. The 190-acre project site is located along the Delaware River directly across from the Philadelphia International Airport. The upland site is bounded by residential neighborhoods, waterways, and wetlands (Figure 15).



Figure 15: Paulsboro Marine Terminal Planned Layout

At full build-out, the terminal will handle lumber, forest and metal products, refrigerated fruit, project cargo, recycled metal, dry bulk, and heavy-lift cargo movements. The terminal will have three ship berths for general cargo, and one barge berth for recycled metal and bulk cargo. Phase I was completed in 2016 and included 150 acres of land, one ship berth at 850 feet length and 40 feet depth, and an adjacent transfer shed. Phase II to be constructed includes two berths, with 1,500 feet of wharf along the Delaware River and one 500 feet long barge berth on Manuta Creek. This facility has no capabilities for handling bulk liquids.

3.5.1 Environmental Considerations The Paulsboro Marine terminal is a previously developed and disturbed site. An EIS prepared in 2009 identified less than one acre of freshwater wetlands on the site (SJPC 2009). A relatively large portion of the site (>100 acres) is mapped as wintering, nesting, and/or foraging habitat for bald eagle (state endangered). In addition, the portion of the Delaware River adjacent to the site has been identified as critical habitat for Atlantic sturgeon (federally endangered), an adult migration corridor for Atlantic and shortnose sturgeon (federally endangered), and an overwintering and foraging area for juveniles of both species.

3.5.2 Potential to Meet Project Purpose The 190-acre Paulsboro site is currently under redevelopment with a focus on other cargos (and not liquid products). As a result of the current redevelopment, there is highway and rail access to the Paulsboro terminal and the site has a petroleum pipeline at its southern boundary. However, at 190 acres, and considering that most of the site is dedicated to another development, the site does not have sufficient land area to accommodate the identified Project need and still maintain its intended



purpose, particularly area to generate a dedicated pier with two berths. In addition, the following factors further limit the potential use of this site:

1. Due to the limited land area available for development, avoidance of sensitive environmental features, such as bald eagle habitat, will be difficult.

2. The most significant constraint to the Paulsboro site is that the terminal planning and development has been committed to different cargo types than those targeted for the Dock 2. Therefore, the terminal infrastructure does not meet the Project’s needs.

3. The Paulsboro Marine Terminal does not support or have the capabilities necessary for operations related to handling bulk liquids.

3.6 DRP Gibbstown Logistics Center - Preferred Alternative The DRP Gibbstown Logistics Center site is situated on 1,630 acres along the Delaware River in Gibbstown (Greenwich Township), New Jersey, which is approximately 20 miles south of Philadelphia (see Figure 17). The Site has been used for industrial purposes, including the manufacture of chemicals and explosives, for more than 100 years. Atlantic City Electric (“ACE”) operated a power plant in the northwestern part of the Site from 1951 to 1986. The northern portion of the Site was historically filled to create uplands along the river and was extensively developed prior to the effective date of wetland regulations (see Figure 16). Industrial operations were focused in an approximately 371-acre area, with munitions testing bunkers and related roads and railways scattered throughout a large portion of the remainder of the property. A multi-purpose dock is currently under construction (completion expected February 2019) at the location of a former wharf. A double-barge berth was also located at the Site that was operated by ACE for the transfer of coal to the power plant. The Project location that is being proposed is very close to the derelict barge berth. Chemours, a successor to DuPont, is currently implementing a long-term environmental remediation program in certain areas at the Site (under NJDEP oversight), which is compatible with the redevelopment currently underway. The addition of a dock dedicated to vessels transporting bulk liquid products is complementary to the ongoing redevelopment of the Site, particularly the upland infrastructure and improvements, currently accessed by rail and road.



Figure 16: DRP Gibbstown Logistics Center – 1930 Aerial Photograph



Figure 17: DRP Gibbstown Logistics Center

3.6.1 Environmental Considerations The Site is a large property (~1,630 acres) that contains a mix of developed and undeveloped land. A portion of the Site (>100 acres) is mapped as wintering, nesting, and/or foraging habitat for state-endangered bald eagle. The portion of the Delaware River adjacent to the Site has been identified as critical habitat for Atlantic sturgeon (federally endangered), an adult migration corridor for Atlantic and shortnose sturgeon (federally endangered), and an overwintering and foraging area for juveniles of both species. However, methods for avoiding or minimizing impacts to any endangered species have been identified so that the Project can be developed with minimal impacts. The majority of the area currently being redeveloped was historically disturbed for industrial operations, has laid dormant as a brownfields site for several years, and is deed restricted for industrial use. Consequently, the



Site presents a unique redevelopment opportunity. Additionally, development of Dock 2 at the Site will minimize necessary landside impacts given that Dock 2 will utilize the marine terminal infrastructure currently under development at the GLC. Accordingly, construction of Dock 2 at the Site avoids the need for new development and associated impacts at an alternative location.

3.6.2 Potential to Meet Project Purpose With the ongoing redevelopment of the Property into a marine terminal the Site is uniquely qualified to accommodate the proposed project purpose. The unique features of this Site enable redevelopment that would return an inactive brownfield site to productive commercial use. Because of the location, size, and characteristics, the Site is highly suitable for a deep-water pier capable of handling bulk liquid products, supported by landside marine terminal infrastructure under development. The Site offers the following key features which are well suited to the proposed use and not found elsewhere in this geographic region:

1. Size and Current Use: The Site is approximately 1,630 acres, with approximately 371 acres of developable land near the waterfront, which is currently under redevelopment as a deep-water seaport and industrial logistics center.

2. Location: The Site is located within the greater Philadelphia market area and is within close proximity of the greater New York/New Jersey market area. The Site is also approximately 86 nautical miles from the Atlantic Ocean. This location provides ease of access for an array of commercial opportunities.

3. Access to Navigation Channel: The Federal Navigation Channel is located approximately 650 feet from the proposed berths.

4. Road Access: The Site will be accessible by new bypass road that was funded in 2018 by the New Jersey Department of Transportation and that is currently in the design phase.

5. Existing Waterfront Infrastructure: Historically, the Site had two separate operational wharfs or piers. The former wharf at Crab Point is currently under development as Dock 1. At Thompson’s Point, the location identified for Dock 2 had been in use for almost 70 years. A double barge berth was located there. In addition, the waterfront is being developed as a marine terminal to provide the landside infrastructure needed for Dock 1 and Dock 2.

6. Existing Inland Distribution Infrastructure: The portion of the Site proposed for redevelopment has existing rail and highway access, which can be enhanced or rehabilitated to meet the project purpose with less overall land and environmental disturbance than other existing or new facilities. Portions of this upland infrastructure are already permitted for redevelopment associated with the marine terminal and Dock 1, which is currently under construction.

7. Existing Subterranean Storage Cavern: The Site features a unique subterranean storage cavern with a shell capacity of approximately 7.8 million gallons (186,000 barrels) of bulk liquids or gasses.



3.7 Southport Brownfield Development Area in Gloucester City, Camden County

This 145-acre waterfront property, previously home to a number of industrial companies and activities, but now abandoned, was purchased by Gloucester City in 2015. Environmental remediation is currently being undertaken to prepare the site for industrial redevelopment. The remedial actions will address contaminated soils, groundwater, sediments and surface waters, enabling reuse of the property. There are no existing marine assets and no previously dredged channel to the waterfront. There is an out-of-service rail siding that serves the site that is located approximately 0.4 miles from the mainline rail connection.

The site, shown in Figure 18, is being subdivided into parcels for industrial development as they are remediated. Currently, construction of a food-waste recycling plant is underway.

Figure 18: Southport Brownfield Development Site

3.7.1 Environmental Considerations The Southport Brownfield Site contains both developed and undeveloped areas. Undeveloped areas are located primarily to the south and southeast of the site; dominant land cover in these areas is forest and old field/shrubland. There are approximately 16 acres of freshwater wetlands on the site. In addition, portions of the site along the Delaware River have been identified as potentially suitable habitat for foraging bald eagle. Further, the Delaware River adjacent to the site has been designated critical habitat for Atlantic sturgeon (federally endangered), an adult migration corridor for Atlantic and shortnose sturgeon (federally endangered), and an overwintering and foraging area for juveniles of both species.



3.7.2 Potential to Meet Project Purpose As noted in the site description provided above, construction is already underway for a food-waste recycling operation on one of the parcels, diminishing the available space required to meet the project purpose. In addition, the site has the following constraints in regard to developing a marine terminal:

1. There is no existing wharf or pier at this site, so existing shoreline and riparian areas would be disturbed.

2. Over 700,000 cubic yards of dredging would be required to provide deep-water navigational access. Because there is not an existing wharf or pier structure, this would be all new dredging of previously undisturbed areas.

3. A sewer outfall at the waterfront may need to be relocated depending on the preferred location for a new pier.

4. There is an out-of-service rail spur at the site. However, re-activation of the rail connection to support a marine terminal will require significant investment.

3.8 Penn Terminal Site, Eddystone, Delaware County, Pennsylvania The Penn Terminal site, located just north of Chester, Pennsylvania (see Figure 19), was originally utilized for shipbuilding, with peak activity occurring during WWII. In 1986, 80 acres of the original shipyard facility was converted to a multi-purpose marine terminal, now known as Penn Terminals, Inc. This privately-owned terminal handles containers, perishable goods, steel, forest products, and miscellaneous break-bulk cargos. The marginal wharf is 1,150 feet long and is served by several old cranes. The access channel and quayside channel are 37 feet deep. There are several sheds within the yard, including a refrigerated shed.

The terminal has a single-track rail feed providing on dock rail service by CSX, Conrail, and Norfolk Southern.



Figure 19: Penn Terminal Site

3.8.1 Environmental Considerations The Penn Terminal site is a previously developed and disturbed area. Minimal wetlands and forested habitat are mapped on the site. Based on information from the National Gap Analysis Program (“GAP”), no known state species protection mandates exist for the site; however, the USFWS Information for Planning and Conservation (“IPaC”) tool identified the potential for Indiana bat, northern long-eared bat, and bog turtle to be present on the site. The Delaware River adjacent to the site has been designated critical habitat for Atlantic sturgeon (federally endangered), an adult migration corridor for Atlantic and shortnose sturgeon (federally endangered), and an overwintering and foraging area for juveniles of both species.

3.8.2 Potential to Meet Project Purpose The backland areas within the terminal are already dedicated to existing customers with limited capacity to accommodate additional cargos. In addition, the site has the following constraints regarding future marine terminal development:

1. The water depth at the existing wharf and the access channel will be very expensive to deepen due to relatively high rock formations in this area of the River.

2. In addition, deepening the access channel may require rock blasting, which may cause unacceptable impacts to endangered sturgeon populations that may be present in the Delaware River in the vicinity of the site.

3. The site is already developed for marine related activities, and there is no area available for expansion.



3.9 Southport Marine Terminal Complex in Philadelphia, Pennsylvania The Southport Marine Terminal Complex consist of three sites as shown on Figure 20. They are: (1) the 120-acre Southport Marine Terminal, “Site 1”; (2) the 75-acre Southport West Terminal, “Site 2”; and (3) Pier 124 North Berth, “Site 3”. Collectively, Site 1, Site 2, and Site 3 are referred to as the “Southport Sites”.

The complex, which is adjacent to the Norfolk Southern intermodal yard at Mustin Field to the north, as well as proximate to CSX’s Greenwich Yards facility, will have two 1,064 linear feet berths. Providing access to the berths off the existing channel will involve dredging approximately 34 acres of river bottom and generate over one million cubic yards of dredge spoils.

The Southport Sites are controlled by the Philadelphia Regional Port Authority (“PRPA”) who is seeking to partner with one or more private developers who will: (i) design and build industrial/commercial revenue-generating facilities on the Southport Sites; (ii) finance all or substantial portion of the initial capital costs of the Project through private equity and debt and use revenues to fund the operations and maintenance period; and (iii) operate and maintain the facilities (including all lifecycle work) under a long-term leased-based contract.

In November 2016, PRPA suspended the bid process for the vacant 195-acre Southport Marine Terminal Complex (Loyd 2017). Instead, the State of Pennsylvania recently committed $93 million in investment to expand operations at this site. At present, there are no plans to develop any of the Southport sites as bulk liquid terminals.

Figure 20: Southport Marine Terminal Complex



3.9.1 Environmental Considerations The Southport Marine Terminal complex consists of developed and undeveloped areas. Land cover on undeveloped portions is a mix of old fields and forested areas. Freshwater wetlands are mapped on less than 10% of the total site area. Based on information from GAP, no known state species protection mandates exist for the site; however, the IPaC tool identified the potential for swamp pink (an endangered plant species) to be present on the site.12 Based on the site’s proximity to and similarities with the Southport Brownfield development, the Southport Marine Terminal may also support potentially suitable habitat for foraging bald eagle. The Delaware River adjacent to the site has been designated critical habitat for Atlantic sturgeon (federally endangered), an adult migration corridor for Atlantic and shortnose sturgeon (federally endangered), and an overwintering and foraging area for juveniles of both species.

3.9.2 Potential to Meet Project Purpose In addition to developing facilities to handle RoRo cargo, one of the primary goals of the Southport project is the development of an automated container terminal. The primary goal of the Southport development does not align with the primary types of cargo targeted for Dock 2 (i.e., bulk liquid products). Given the focus on containerized cargo and constrained land area, DRP is not a viable partner for PRPA as this site cannot meet the project purpose.

12 The IPaC tool additionally identified red knot, an endangered bird species, as potentially present on the site. Red

knot is a migratory shore bird that is unlikely to be encountered at the Southport Marine Terminal location.


Analysis of Alternative Project Locations

4. ANALYSIS OF ALTERNATIVE PROJECT LOCATIONS

DRP evaluated each of the alternative sites to identify the most practicable alternative based on the needs of the Project, logistics, cost, and likelihood of adverse environmental impacts. DRP determined that there is no suitable alternative location for the Project in the region. In light of the fact that DRP already has control of the Site and has already started development of Dock 1 and the GLC, and understands the environmental constraints of the Site, none of the alternative sites meet the project purpose or minimize potential environmental impact. In light of the Site’s preexisting marine terminal infrastructure, ongoing redevelopment, and access to major transportation corridors, the Project would have the least cumulative adverse environmental impact if it is developed at the Site as opposed to an alternative location. Moreover, by choosing to restore this previously disturbed property, DRP has selected the alternative that best avoids or minimizes environmental impacts while rehabilitating a former industrial site that will help to create jobs and revitalize a community and region once dependent on the Site as a driver of local and regional economic growth.

4.1 Analysis Criteria The analysis criteria considered in this evaluation are described below.

4.1.1 Potential Impacts to Environmental Resources Impacts to waters of the United States, threatened and endangered species habitat, and other protected resources are based on available information for each alternative site, and can include indirect, secondary, and cumulative impacts. Possible compensatory mitigation actions were not considered as part of this evaluation.

4.1.2 Project Purpose Overall project purpose must be met by any alternative for it to be practicable. That is, either an alternative was found to satisfy the project purpose or it did not. Project purpose considerations did not include management plans, political issues, or social benefits.

4.1.3 Logistics Logistics issues include governmental or other impediments that could eliminate the project proponent’s ability to implement an alternative. Logistics considerations included landside infrastructure, existing and potential use designations, site access (including truck and rail), and timeliness (availability of a buildable site).

4.1.4 Cost The project cost criterion was only applied where there was a disproportionate relation between increased development costs and reduced impacts.

4.1.5 Technology and Infrastructure Aspects of the potential sites were evaluated to determine if use of unusual technologies are necessary to develop the site without incurring significant additional costs, such as available infrastructure and the need for significant power source and fiber optic access.



4.2 Evaluation of Alternative Sites The evaluation of each alternative site is presented below. Note that the “No Action Alternative” would have no environmental impacts, but is not a viable alternative because the project purpose would not be met.

4.2.1 Existing SJPC facilities in Camden County Potential Impacts to Environmental Resources – Expansion of the existing SJPC facilities to fill the project purpose and need can be accomplished with minor Section 404 regulated dredging impacts. In-water work has the potential to affect adult and juvenile shortnose sturgeon utilizing adjacent summering areas in the Delaware River.

Project Purpose – No additional waterfront area is available and the berths cannot be dredged deeper than 35 feet MLLW, which is inadequate for the project purpose.

Logistics – The SJPC terminals do not have additional area available to provide necessary infrastructure and near-terminal access roads are congested.

Cost – A moderate investment in dredging and pier improvements would be necessary before SJPC facilities could suit the Project’s needs.

Technology and Infrastructure – Significant technology improvements would be required at the site to allow the existing cargos to co-exist with those proposed by the Project.

4.2.2 DuPont Property in Carneys Point, Salem County Potential Impacts to Environmental Resources – As there is no usable pier structure at this site, extensive overwater construction would be necessary to fulfill the project purpose. Additionally, over three million cubic yards of dredging could be needed. In-water construction activities have the potential to impact EFH as well as adult and juvenile sturgeon. In addition, to construct a usable pier, some portion of the Delaware River shore would require bulkheading and backfill. Avoiding contaminated areas at this site may require development within wetland areas.

Project Purpose – The DuPont property has sufficient waterfront and land area, highway access, and rail access to fulfill the project purpose.

Logistics –The ongoing FUSRAP remediation and the potential for abandoned ordinance could pose a significant constraint.

Cost – The cost of berth construction and upland development would not be significantly higher than other alternatives. However, increased dredged quantities would likely push wharf development costs higher.

Technology and Infrastructure – Significant technology issues will likely be necessary to mitigate the fissionable materials hazards at this site.

4.2.3 Ferro Industrial Site in Logan Township, Gloucester County Potential Impacts to Environmental Resources – As there is no usable pier structure at the Ferro Industrial site, extensive overwater construction will be necessary to fulfill the project purpose. Additionally, over two million cubic yards of dredging could be needed. To construct a usable pier,



some portion of the Delaware River shore would require bulkheading and backfill. In-water work has the potential to affect adult and juvenile shortnose sturgeon. Development of the site may necessitate the filling a relatively large area of wetlands and may also disturb recent wetlands enhancement programs on portions of the site. In addition, development of the site may necessitate disturbance to a large portion of potentially suitable bald eagle foraging habitat.

Project Purpose – The Ferro site has sufficient waterfront area, but does not have suitable road or rail access to meet the project purpose. Extensive disturbance to wetland areas and other project habitat would be needed to develop landside infrastructure.

Logistics – The Ferro Industrial site would require rezoning and re-allocation of land to be developed into a marine terminal.

Cost – As much of the land is now agricultural and may be below flood elevation, land improvement costs may be excessive.

Technology and Infrastructure – New engineering technologies may be necessary to avoid impacts to the existing pipelines on the site.

4.2.4 Raccoon Island Site in Logan Township, Gloucester County Potential Impacts to Environmental Resources – As there is no usable pier structure at the Raccoon Island site, extensive overwater construction will be necessary to fulfill the project purpose. Additionally, over three million cubic yards of dredging could be needed. In-water work has the potential to affect adult and juvenile shortnose sturgeon. Extensive forest clearing and filling of wetlands may be necessary to develop upland infrastructure. Development of the site may also adversely impact a large area of mapped bald eagle habitat. Development of rail access would necessitate additional environmental impacts due to the presence of wetlands between the property and active rail corridor.

Project Purpose – The Raccoon Island site has sufficient waterfront area, but does not have suitable road or rail access to meet the project purpose. Extensive disturbance to wetland areas and other project habitat would be needed to develop landside infrastructure.

Logistics – There are no existing rail lines servicing the Raccoon Island Site. The nearest existing rail line is located approximately one mile south of the site (Figure 16). Connecting the site to the existing rail line would require crossing a major highway and passage through residential and commercial properties in the town of Bridgeport, New Jersey. Due to the presence of wetlands in areas surrounding the site, establishing a connection to the mainline rail would also likely result in additional environmental impacts.

Cost – As much of the land is now agricultural and may be below flood elevation, land improvement costs may higher than other alternatives. No existing infrastructure is present; therefore, costs to develop may be significantly higher compared with other alternatives.

Technology and Infrastructure – As an undeveloped, new power, water and sewer and communications infrastructure would be required.



4.2.5 Paulsboro Marine Terminal (Former BP Oil site) in Paulsboro, Gloucester County

Potential Impacts to Environmental Resources – The Paulsboro Marine Terminal is a permitted project, currently under construction. To develop sufficient additional upland storage area, some wetland impacts may be necessary to fulfill the project purpose. Permanent disturbance to a relatively large area of bald eagle foraging and nesting habitat may also be necessary. The limited land area available to meet the project purpose will make avoidance of these areas difficult.

Project Purpose – While the planned Paulsboro project includes significant waterfront infrastructure that could complement the project purpose, it is unlikely that the existing or planned facilities could be converted to fill the project purpose without displacing other uses. Additionally, the site does not include existing upland facilities necessary for the proposed Project uses.

Logistics – There are existing roadway and rail improvements that provide access to the site. However, the waterfront area is already developed for non-compatible uses.

Cost – A wharf structure is already in place. Certain aspects of the wharf and landside infrastructure would require modification to be suitable for the Project.

Technology and Infrastructure – Significant technology improvements may be required at the Paulsboro site to allow the cargos there to co-exist with the proposed Project cargos.

4.2.6 DRP Gibbstown Logistics Center Site - Preferred Alternative Potential Impacts to Environmental Resources – Dredging of approximately 600,000 to 800,000 cubic yards will be required to establish the dredged access channel for deep-water vessel access to the Federal Navigation Channel. This dredging will not occur in nearshore areas avoiding impacts to submerged aquatic vegetation (“SAV”) and intertidal shallows. Dock 1 and the marine terminal have been permitted for construction and impacts to protected resources, includes wetlands, vernal habitat, SAV, bald eagle and osprey habit have been avoided or mitigated.

Project Purpose – The Site has sufficient waterfront area, interstate highway access, and sufficient rail service to fulfill the project purpose.

Logistics – The Site is currently being developed as a marine terminal, including a multi-purpose dock. The marine terminal will have suitable landside infrastructure for the proposed bulk liquid pier. In addition, the Site will be accessed by a new bypass road that was funded in 2018 by the New Jersey Department of Transportation and that is currently in the design and permitting phase.

Cost – A significant investment in dredging and pier construction will be a necessary part of the marine terminal development.

Technology and Infrastructure – No additional technologies will be required to make this project viable.



4.2.7 Southport Brownfield Development area in Gloucester City, Camden County Potential Impacts to Environmental Resources – As there is no usable pier structure at the Southport Brownfield Development area, extensive overwater construction will be necessary to fulfill the project purpose. Additionally, over 700,000 cubic yards of dredging could be needed. In-water work has the potential to affect adult and juvenile shortnose sturgeon.

Project Purpose –The site has sufficient waterfront area to support the Project, but does not have enough upland area to support the project purpose.

Logistics – The site is currently under construction for a food-water recycling operation that will occupy a portion of the parcel, thus reducing the ability to develop and available land area further. But, it is important to note that the site is not well-positioned relative to road and rail access

Cost – A significant investment in dredging, pier construction, rail and road access would be a necessary part of the marine terminal development.

Technology and Infrastructure – Significant technology improvements may be required at the Southport Brownfield development area to allow the existing infrastructure to co-exist with the proposed new project purpose and need.

4.2.8 Penn Terminal Site in Eddystone, Delaware County, Pennsylvania Potential Impacts to Environmental Resources – Expansion of the existing Penn Terminal marine facilities to fill the project purpose and need can be accomplished with limited dredging. However, deepening of the access channel may require rock blasting and therefore cause potentially unacceptable impacts to endangered sturgeon species. Expansion of upland facilities can be accomplished with relatively low impacts to terrestrial threatened and endangered species habitat.

Project Purpose – The Penn Terminal site has sufficient waterfront area that is a fully utilized marine terminal for container and bulk cargo, so it is not available for the proposed Project.

Logistics –The Penn Terminal is already dedicated to existing customers with limited capacity to accommodate additional cargos. There is existing rail and road access, but there is limited ability to expand it for the proposed Project.

Cost – Certain aspects of the wharf and landside infrastructure would require modification to be suitable for the Project. Additional cost would be required to deepen the access channel through relatively high rock formations.

Technology and Infrastructure – Significant technology improvements may be required at the Penn Terminal site to allow the existing cargos to co-exist with the proposed new project purpose and need.

4.2.9 Southport Marine Terminal Complex in Philadelphia, Philadelphia County, Pennsylvania

Potential Impacts to Environmental Resources – Expansion of the existing Southport Marine Terminal facilities to fill the project purpose and need can be accomplished with minor Section 404 regulated dredging impacts. Expansion of upland facilities may require the filling of wetlands and disturbance to bald eagle foraging habitat.



Project Purpose –The primary goals of the Southport project are the development of an automated container terminal. This goal does not align with the purpose of Dock 2.

Logistics – The complex is being developed as a public-private partnership which introduces constraints on the development timelines and limited control over project direction. Proposed cargo types at the facility do not align with cargo types targeted for the GLC.

Cost – Certain aspects of the wharf and landside infrastructure would require modification to be suitable for the Project.

Technology and Infrastructure – Significant technology improvements may be required at the Southport Marine Terminal complex to allow the existing cargos to co-exist with the proposed new project purpose and need.

4.3 Alternative Site Recommendations As summarized in Table 2 and discussed further below, in addition to the No Action Alternative, six sites were not suitable for the project purposes. Of the three remaining sites evaluated, only one met the other evaluation criteria.

Sites Not Suitable for Project Purpose:

1. SJPC Terminals: The SJPC terminals in Camden were eliminated from consideration due to their constrained land area and current commodity use that is not compatible with commodities proposed at the GLC.

2. Ferro Industrial Site: The Ferro Industrial site was also found to be unsuitable for a commercial port development due to its constrained developable land area, existing wetlands enhancement programs, pipeline rights of way, encumbrances, lack of existing pier structures, and considerable dredging needs.

3. Paulsboro Marine Terminal: Paulsboro Marine Terminal cannot fulfill the Project need due to existing and planned uses. The Paulsboro project is under construction and the majority of its upland area committed to dry bulk storage and general cargo handling. Any additional facilities to accommodate the Project need (including a bulk liquid storage terminal) would require displacement of other currently existing or planned uses.

4. Penn Terminal: Penn Terminal was eliminated from consideration due to the constrained land area and high likelihood of operations conflicts.

5. Southport Terminal: Southport Terminal was eliminated from consideration due to the constrained land area and high likelihood of operations conflicts

6. Southport Brownfield Development Area: The Southport Brownfield Development may have sufficient waterfront area, but the landside area is too small to fulfill the project need.

4.4 Sites Potentially Suitable for Project Purpose Other factors determining location suitability were the location of the proposed wharf in relationship to the Federal Navigation Channel, the amount of dredging required to access the berthing facility, and other environmental impacts. The distance to the Federal Navigation Channel tends to decrease northward (upriver) at each location.



1. DuPont Carneys Point: The DuPont Property at Carneys Point has too many ongoing conflicting issues to allow a large-scale port development. Specifically, the site is subject to ongoing FUSRAP remediation, lacks existing pier structures, and would require considerable waterfront development involving significant environmental disturbances and increased dredging and disposal costs.

2. Raccoon Island: The Raccoon Island site was eliminated from consideration due to the lack of nearby rail suitable roadway access. There is also the potential for extensive environmental impacts.

3. DRP Gibbstown Logistics Center: The unique features of the Site will best suit DRP’s objective for a liquid products transloading dock, particularly because it will be developed in coordination with the ongoing marine terminal development at the Site. Development of Dock 2 alongside ongoing redevelopment activities at the Site will allow DRP to capitalize on its extensive knowledge of the Site and to coordinate work to minimize environmental impacts. The Site is also the best location alternative from the perspective of minimizing distance to the Federal Navigation Channel, which, in turn, minimizes the dredge footprint and related environmental impacts. Because of the Site’s location, synergy with the marine terminal and multi-purpose dock, available waterfront area and sufficient road and rail access, the Site is highly suitable for a second dock dedicated to vessels transporting bulk liquid products. Moreover, the redevelopment of this brownfield will reinvigorate a once productive site, resulting in significant investment in the Greenwich Township community which will create jobs and spur economic growth locally and in the region.

Table 2 Alternative Site Comparison

No

Act

ion

A

lter

nat

ive

SJP

C C

amde

n

Term

inal

s

Du

Pon

t C

arn

eys

Poi

nt

Ferr

o In

dust

rial

S

ite

Rac

coon

Isl

and

Pau

lsb

oro

Mar

ine

Term

inal

DR

P G

ibb

stow

n

Log

isti

cs C

ente

r

Sou

thp

ort

Bro

wn

fiel

d

Pen

n T

erm

inal

Sou

thp

ort

Mar

ine

Term

inal

Environmental Impacts

No Impact

2 – Low Impact

4 – High Impact

5 – Highest Impact

5 – Highest Impact

3 – Low to Medium Impact

2-3 Low to Medium Impact

4 – High Impact

3 – Medium Impact

3 – Medium Impact

Project Purpose

Not Met

Not Suitable

Suitable Not Suitable



Not Suitable

Not Suitable

Logistics N/A Not Favorable

Not Favorable

Not Favorable

Not Favorable

Favorable Favorable Not Favorable

Not Favorable

Not Favorable

Cost N/A Moderate Cost

Moderate Cost

Highest Cost

Highest Cost

Lowest Cost

Moderate Cost

High Cost Moderate Cost

Moderate Cost

Technology and Infrastructure

N/A Required May be Required

May be Required

Not Required

Not Required

Not Required

May be Required

Required May be Required

In summary, the Gibbstown Logistics Center is the best-suited location for this Project. The Site is already under development as a marine terminal, is proximate to the Federal Navigation Channel, has existing internal railways with connectively to regional and national rail corridors, and proximity to



several major highways that will be enhanced by a new bypass road that is being undertaken by the Gloucester County Improvement Authority and that is currently in the design and permitting phase. The Site is therefore entirely unique among available alternative locations in the region. This enables DRP to avoid adverse impacts to sensitive environmental areas associated with replicating this critical infrastructure at other locations. Thus, the Project would have the least cumulative adverse environmental impact if it is developed at the Site as opposed to an alternative location. DRP has selected the alternative site that best avoids or minimizes environmental impacts while meeting the Project’s needs.


Description of Preferred Site – DRP Gibbstown Logistics Center

5. DESCRIPTION OF PREFERRED SITE – DRP GIBBSTOWN LOGISTICS CENTER

As discussed above, the Site is brownfield with a long industrial history. Chemours, as successor to DuPont, is implementing a long-term environmental remediation program in certain site areas (under NJDEP oversight), which is compatible with the redevelopment currently underway and not in close proximity to the area proposed for Dock 2, as described below.

5.1 Former Thompson’s Point Pier The location identified for Dock 2 is in the vicinity of the derelict remains of an old timber pier. The pier, formerly known as Thompson Point Wharf, was constructed in the early 1900s and was historically used for barge to rail transfer supporting an Atlantic City Electric station at the Site. In 1988, portions of the Thompson’s Point Wharf were decommissioned as former industrial operations wound down on the Site. Based on historical aerial images and documents describing the long industrial history of the Site, it appears that other in-water structures may have historically existed in the vicinity of the former pier. See Figures 21 and 22 for image depicting the current marine structures and surrounding bathymetry.

The abandoned marine structures in this area have not been well-maintained at least since the DuPont plant closed in 1995, and the timber wharf has been unused and in derelict condition since at least the 1980s.

The following conditions have been observed of the marine facilities in this portion of the Site:

• Remains of Existing Timber Pier: The location on the Site identified for Dock 2 contains the derelict remains of an old timber pier. The selected alignment identified for Dock 2 will determine the extent of demolition required for these remains, if any.

• Existing Bathymetry: The areas near the shoreline are relatively shallow, with depths of approximately 10 feet or less within 500 feet of the shore. Beyond this, the depths increase toward the edge of the marked navigational channel, with much of the area being greater than 30 feet deep. The area overlaps with Delaware Bay and River Anchorage Area 8. The Delaware River Channel has been deepened to -45 feet MLLW. Navigational access to Dock 2 will also provide approach and quayside channels to a depth of -43 feet MLLW.



Figure 21: Marine Structures and Bathymetry

5.2 Landside Conditions The Site is relatively flat with elevation ranging from -4 to 12 feet NAVD88. The area is mapped within the 100-year floodplain of the Delaware River.

Previously developed areas are concentrated in the northern waterfront portion of the Site and include former industrial and manufacturing areas, which generally correspond to the area proposed for the Project. These areas are characterized by limited vegetation; historic development has left large areas of impervious surface. The vegetation that is present is largely dominated by invasive species, or species that thrive in a highly disturbed environment such as common reed (Phragmites australis) and common mugwort (Artemisia vulgaris). Trees that are present are typically found in small patches and are relatively small in size.



Figure 22: Existing Marine Facilities at Dock 2 Location, 201813

5.3 Existing Ship Traffic on the Delaware River The United States Army Corps of Engineers (“USACE”) publishes data on waterborne traffic movements involving the transport of goods on navigable waters of the United States. In 2016, there were 24,015 inbound and 24,025 outbound vessel movements within the Federal Navigation Channel between Philadelphia and the sea. A breakdown by ship type is shown in Table 3.

Table 3: Existing Ship Traffic (USACE 2016)

Vessel Type Number of Domestic Vessel Passes -Domestic 2015

(Inbound + Outbound)

Number of Foreign Vessel Passes - 2015


Total Number of Vessel Passes (Inbound +

Outbound)

Dry Cargo 30,751 3,267 38,215

Tanker 120 1,283 1,267

13 Google earth image ©2018 Google.



Table 3: Existing Ship Traffic (USACE 2016)

Vessel Type Number of Domestic Vessel Passes -Domestic 2015


Number of Foreign Vessel Passes - 2015


Total Number of Vessel Passes (Inbound +

Outbound)

Tow or Tug 4,428 7 3,870

Non-Self-Propelled 8,181 1 8,222

Total 43,480 4,560 48,040

5.4 Project Vessel Traffic for the Project Once operational, it is estimated that 37 vessels capable of carrying bulk liquid products would annually call on Dock 2. This estimate is based on projected demand, expected vessel size, and time to load a vessel (10 days). Vessels would use the Federal Navigation Channel to move to and from the Site. It is expected that these would be new vessels on the Delaware River.

5.5 Ballast Water Considerations All operations at Dock 2 will comply with the Unites States Coast Guard (“USCG”) ballast water regulations pertaining to ballast water exchange (33 C.F.R. 151.1510). The ballast water exchange regulations require international ships to: (1) conduct mid-ocean ballast exchanges more than 200 miles off-shore, (2) retain ballast water, or (3) use an approved ballast water management system that meets USCG discharge standards relative to organism content. In addition, the United States Environmental Protection Agency (“USEPA”) regulates incidental discharges into waters of the United States from commercial vessels greater than 79 feet in length and for ballast water from commercial vessels of all sizes through the Vessel General Permit program.

DRP will require that vessels calling at Dock 2 abide by applicable USCG and USEPA regulations in order to avoid adverse effects of non-invasive species that be present in ballast water, and to minimize to every extent possible the intake of larvae and juvenile fish. In particular, DRP will require that discharge and intake of ballast water while at berth will be limited to the minimum needed to assure vessel stability. Based on these regulations, the majority of all ballast water exchanges for vessels calling on the proposed terminal will occur in off-shore marine waters, where early life stages of anadromous fish are not present. Modern design features, which allow ships to redistribute ballast rather than taking on new water at port, significantly reduce the potential for entrainment of mobile larvae and release of non-indigenous species. In addition, ballast water intake openings are screened to prevent the intake and release of debris and aquatic life.


Alternative Dock Configurations

6. ALTERNATIVE DOCK CONFIGURATIONS

Under Section 404 of the Clean Water Act, 33 U.S.C. 1344, et seq., when aquatic resources would be impacted by a project, it is necessary to provide an alternatives analysis demonstrating that:

• there is no practicable alternative to the proposed facility and regulated activities that would have a less adverse environmental impact;

• the alternative would not have other significant adverse environmental consequences; and

• the proposed Project has been designed to avoid and minimize impacts to the maximum extent practicable.

In order to demonstrate that the proposed configuration of Dock 2 meets these requirements, the following section provides a comparative evaluation of the design alternatives, in terms of the Project's needs, environmental impact, and cost.

To identify the alternative design configuration that would minimize impacts to protected resources to the maximum extent practicable, the following aspects of Dock 2 were evaluated:

1. Berth position relative to shore;

2. Berth and dock configuration relative to channel line;

3. Berth location relative to the existing pier and previously dredged areas;

4. Method of construction;

5. Dredging footprint relative to previously dredged areas;

6. Proximity of proposed uses to the berth; and

7. Possible impacts to aquatic resources.

6.1 Berth Configuration Requirements Dock 2 as proposed will be capable of handling the range of ships transporting liquids, including carriers up to approximately 173,400 cubic meters in capacity. The dimensions of the vessels expected to call at the GLC are summarized in Table 4.


TANKER DESIGN VESSELS

PROPERTY 59,000 m3

78,500 m3

125,000 m3

136,000 m3

156,000 m3

173,400 m3

LENGTH OVERALL (LOA) 672.5’ 740.6’ 842.4’ 951.4’ 945.5’ 966.2’

LENGTH BETWEEN PERPENDICULARS

639.8’ 717.1’ 849.7’ 905.5’ 902.2’ 930.1’

WIDTH/BEAM (B) 105.6’ 119.4’ 154.9’ 151.2’ 145.0’ 152.2’




TANKER DESIGN VESSELS

PROPERTY 59,000 m3

78,500 m3

125,000 m3

136,000 m3

156,000 m3

173,400 m3

MAXIMUM DRAFT 39.7’ 36.9’ 37.4’ 37.4’ 39.4’ 37.7’

MOULDED DEPTH 68.2’ 72.2’ 86.9’ 83.7’ 85.3’ 86.9’

DISPLACEMENT (LONG TONS)

57,984 68,921 95,981 103,318 112,127 115,636

Each berth must be constructed to accommodate the largest ship to call at the GLC, which is 966.2 feet long (see Table 4). The total length of berth required to dock a single design ship (including bow and stern moorings) is approximately 1,200 feet.

6.2 Other Berth Location Considerations The general location of Dock 2 must be near the Federal Navigation Channel but provide suitable clearances for navigation into the berths. Dock 2 must also be located to avoid conflict with navigation of vessels to Dock 1. The location should also generally align with the location of the planned landside improvements.

Four alternative layouts were conceived to provide bounding solutions for providing two additional vessel berths at the Site. Each berth requires with breasting dolphins, mooring dolphins, and a loading platform designed to accommodate the range of design vessels.

6.2.1 Berth Layout 1 Layout 1 orients the two berths parallel to shore with the vessels berthed end-to-end. The berths are placed offshore with a minimum clearance to the water intake structure of 50 feet. A dredge pocket is provided with lateral limits extending 100 feet beyond the mooring dolphins. The berth face is approximately 800 feet from the Federal Navigation Channel, yielding a turning area diameter in front of the berth of 1,600 feet including the Federal Navigation Channel.

The trestle from shore meets the berths at the midpoint and splits in each direction to form a “T” shape (see Figure 23). The trestle is positioned to align with a former barge berth at Thompson’s Point.



Figure 23: Berth Layout 1

This option would impact approximately 0.38 acres of intertidal shallows. It will directly impact 0.18 acres of SAV. It would also require approximately 59 acres of dredging, with a total volume of 1,181,750 cubic yards.

6.2.2 Berth Layout 2 Layout 2 is similarly oriented, but is only 238 feet from the Federal Navigation Channel (two beam widths of the design vessel). The shift of the berths minimizes dredging but places the berthed vessel closer to traffic in the Federal Navigation Channel. There is insufficient area to turn in front of the berth, so the terminal is shifted eastward to share the turning basin with Dock 1.

The trestle from shore meets the terminal near the loading platform for the west berth with a parallel trestle to the west berth, forming an “L” shaped berth (see Figure 24). The trestle is positioned to align with a former barge berth at Thompson’s Point.




This option would impact 0.4 acres of intertidal and subtidal shallows. It will directly impact 0.23 acres of SAV. It would also require 21 acres of dredging, with a total volume of 104,350 cubic yards.

6.2.3 Berth Layout 3 Layout 3 is oriented perpendicular to shore with a vessel berth on each side of the terminal (see Figure 25). This layout minimizes berth infrastructure with the two berths sharing a loading platform as well as three mooring dolphins. The trestle is positioned to align with a former barge berth at Thompson’s Point.

The loading platform is moved as far from the Federal Navigation Channel as possible without impinging on the existing shoreline. Layout 3 has the shortest trestle and piping to the terminal loading platform. However, due to the proximity to shore, demolition of the remnant structures and water intake structures would be required.




This option would impact approximately 9.8 acres of intertidal and subtidal shallows. It will directly impact 3.24 acres of SAV. It would also require approximately 52 acres of dredging, with a total volume of approximately 1,687,600 cubic yards.

6.2.4 Berth Layout 4 Layout 4 is oriented similarly to Layout 1, with two berths parallel to shore with the vessels berthed end-to-end. The berths are placed offshore with a minimum clearance to the water intake structure of 215 feet. The berth face is approximately 650 feet from the Federal Navigation Channel, yielding a turning area diameter in front of the berth of 1,600 feet including the Federal Navigation Channel.

The trestle from shore meets the berths at the eastern end to form an “L” shape (see Figure 26).




This option will require approximately 45 acres of dredging, with a total volume of approximately 665,000 cubic yards. However, the berth has been positioned to avoid direct impacts to the SAV bed and minimize impacts to intertidal and subtidal shallows, which would be approximately 0.26 acres due to shading.

6.3 Comparison of Alternatives A summary comparison of the alternatives described above is presented in Table 5 in terms of environmental impact, cost, and ability to meet the project purposes and need. The design alternatives provide a variety of mechanisms to reduce impacts associated with dredging, overwater footprint, fill of open waters, and impacts to SAV. However, not all design alternatives considered have the potential to meet the project purpose and logistical requirements.

Of the alternatives considered, Layout 4 best suits the project needs. In general, Layout 4 is preferred over the other options for the following reasons:

1. Layout 1 allows vessels to use the area in front of the Dock 2 berths as a turning basin and, accordingly, meets operational needs. However, Layout 1 does not minimize environmental impacts as effectively as Layout 4.

2. Vessel mooring performance is impacted by Layout 2. Similarly, maneuvering is an impediment for Layout 2 because vessels would be required to use the turning basin for Dock 1. Moreover, the proximity to the Federal Navigation Channel may cause moored vessels to exceed safe limits unless channel traffic is slowed which will impede existing navigation practices.

3. Vessel mooring performance is impacted by Layout 3. Because current velocities increase towards the Federal Navigation Channel, ship maneuvering is more difficult utilizing Layout 3, which would



require that vessels stop in the channel and back into the berth. Additionally, Layout 3 places vessel perpendicular to river currents which would adversely affect mooring performance.

4. Layout 4 provides a safe navigation and maneuvering in and out to the berth area. Specifically, Layout 4 allows vessels to use the area in front of the Dock 2 berths as a turning basin and, accordingly, meets operational needs. From an environmental perspective, Layout 4 is the preferred alternative because it eliminates direct impacts to SAV and minimizes impacts to intertidal/subtidal shallows, reducing potential impacts to habitat for migratory fish species.

Table 5: Comparison of Alternative Configurations

Alternative Total Over-Water

Footprint

Total Dredging

Area/ Volume

Intertidal/ Subtidal Shallows Impact

SAV Impact

Cost14 Meets Project

Purpose & Logistics


0.38 acres 0.18 acres Moderate Cost ($129M)

Suitable


0.4 acres 0.23 acres Lowest Cost ($100.3M)

Not practicable


9.8 acres 3.24 acres Highest Cost ($133.3M)

Not practicable


0.3 acres 0.0 acres Moderate Cost ($120M)

Suitable

6.4 Preferred Berth Alternative After taking into consideration environmental impact, cost, existing technology, and logistics in light of the overall project purpose, the preferred alternative is Layout 4. Overall, Layout 4 achieves the overall project purpose and offers significant logistical benefits while minimizing adverse impacts to aquatic resources associated with dredging, shading, and berth construction, relative to other design alternatives.

14 Cost estimates are preliminary and were determined based on general location and configuration of the dock

structure.


Summary

7. SUMMARY

The Project presents a unique opportunity to enhance the redevelopment of a brownfield site that once served as the economic driver of the local community. Continued and renewed market demand for increased port capacity and facilities with transloading capabilities within the region has attracted private funding to develop the Project, which will enhance the multi-purpose marine terminal which is currently under construction. The Site is the preferred alternative to other possible locations given the available land area, the wharf and marine terminal currently being constructed, the presence of existing rail access, the proximity to highways for the transport of waterborne goods, planned and budgeted improvements to local transportation infrastructure, and the absence of logistical and technological barriers to redevelopment. Notably, other site alternatives do not feature the infrastructure assets and proximity to transportation corridors, and to outfit alternative sites with the features already offered by the GLC Site would result in unnecessary adverse environmental impacts. Nor would the other sites evaluated allow DRP to benefit from its experience with the Site and the ongoing development activities at the Site.

After taking into consideration cost, existing technology, and logistics in light of the overall project purpose, the preferred alternative for the berth configuration of Dock 2 is Layout 4. Overall, Layout 4 achieves the overall project purpose and offers significant logistical benefits while minimizing adverse impacts to aquatic resources associated with dredging, shading, and berth construction, relative to other design alternatives.

In summary:

• there is no practicable alternative location for the Project that will have a less adverse environmental impact;

• the Project has been designed to minimize impacts to the maximum extent practicable; and

• the Project will not have other significant environmental consequences.

The Project will also revive an underutilized brownfield site and put an otherwise blighted property to productive use once again. Importantly, the Project will create jobs and attract investment to the region, help to revitalize the local community, and ultimately contribute to overall economic growth in New Jersey.


References

8. REFERENCES

Delaware River Port Authority, 2006. Southern New Jersey Waterfront Master Plan.

United States Energy Information Administration (USEIA). 2018. EIA’s Short-Term Energy Outlook. 26 July.

USEIA Website. 2018. https://www.eia.gov/dnav/pet/pet_move_exp_dc_NUS-Z00_mbblpd_m.htm.

Federal Energy Regulatory Commission. 2006 Final Environmental Impact Statement on the Crown Landing LNG and Logan Lateral Projects. April 28.

New Jersey Department of Transportation (NJDOT). 2010. South Jersey Freight Transportation & Economic Development Assessment. December.

South Jersey Port Corporation. 2009. Executive Order No. 215 Environmental Impact Statement for the Paulsboro Marine Terminal Project. May.

United Nations Conference on Trade and Development (UNCTD). 1985. Port Development Handbook.

USACE. 2012. Final Feasibility Study DuPont Chambers Works FUSRAP Site, Deepwater, New Jersey. October.

USACE Website. https://www.nap.usace.army.mil/Missions/Civil-Works/Delaware-River-Main-Channel-Deepening.

United States Department of Commerce (USDC), Census Bureau Trade Data Portal. https://usatrade.census.gov/.

169000609-001\PRIN_WP\v1


Ramboll

APPENDIX F PHASE I UNDERWATER ARCHAEOLOGY REPORT

PHASE I

UNDERWATER ARCHAEOLOGICAL INVESTIGATIONS

THOMPSON POINT,

REPAUNO SITE

DELAWARE RIVER,

GREENWICH TOWNSHIP

GLOUCESTER COUNTY, NEW JERSEY

DOLAN RESEARCH, Inc.

February 2019

PHASE I

UNDERWATER ARCHAEOLOGICAL INVESTIGATIONS

THOMPSON POINT

REPAUNO SITE

DELAWARE RIVER,

GREENWICH TOWNSHIP

GLOUCESTER COUNTY, NEW JERSEY

Submitted to:

Ramboll Environ

1760 Market Street

Suite 100


Submitted by:

J. Lee Cox, Jr.

Dolan Research, Inc.

30 Paper Mill Road

Newtown Square, PA 19073

February 2019

ABSTRACT

In conjunction with planned dredging activities for the proposed Thompson Point port facility at

DRP Gibbstown Logistics Center in Greenwich Township, Gloucester County, New Jersey, a Phase

I Underwater Archaeological Remote Sensing Investigations were conducted to assess the potential

presence or absence of potential submerged cultural resources within the project Area of Potential

Effect (APE).

Magnetic and acoustic remote sensing data were collected to identify and assess remote sensing

targets that may have an association with submerged cultural resources. Historical research was

conducted to provide a proper framework for evaluating the significance of the remote sensing

targets. Analysis of fieldwork data confirms the presence of three magnetic targets and nine

acoustic (sonar) targets in the APE. However, none of these remote sensing targets are considered

to be suggestive of potential submerged cultural resources and no additional underwater

archaeological work is recommended.

TABLE OF CONTENTS

Abstract

List of Tables

List of Figures

1.0 Introduction .......................................................................................................................... 1

2.0 Project Location and Description ......................................................................................... 2

3.0 Maritime Historical Background .......................................................................................... 3

3.1 Methodology ................................................................................................................... 3

3.2 Maritime Historical Synopsis ......................................................................................... 3

3.2.1 Naval Activity in Delaware River ....................................................................... 5

3.2.2 Delaware River/Bay Shipping ............................................................................. 9

3.2.2.1 Delaware and New Jersey Regional Shipping ...................................... 10

3.2.3 Shipbuilding in Delaware Valley ...................................................................... 12

3.2.4 Overview of Delaware Bay/River Navigational Improvements ....................... 14

3.2.4.1 Seventeenth and Eighteenth Century Navigational Improvements ...... 14

3.2.4.2 Hazards to Navigation: Ice ................................................................... 15

3.2.4.3 Hazards to Navigation: Chevaux-de-Frise ........................................... 17

3.2.4.4 Nineteenth Century Navigational Improvements ................................. 17

3.2.4.5 Chesapeake and Delaware Canal.......................................................... 18

3.2.4.6 Twentieth Century Navigational Improvements .................................. 18

3.2.5 Shipwrecks and Salvage Operations in Delaware River/Bay ........................... 19

3.2.6 Shoreline Development at the Repauno Site ..................................................... 20

4.0 Submerged Cultural Resources Potential ........................................................................... 21

4.1 Criteria of Evaluation ................................................................................................... 21

4.2 Potential Shipwreck Types in Project Area .................................................................. 22

4.2.1 Potential Site Integrity ....................................................................................... 22

4.2.2 Anticipated Property Types ............................................................................... 22

5.0 Fieldwork Investigations .................................................................................................... 23

5.1 Fieldwork Methods ....................................................................................................... 23

5.2 Data Products - Magnetometer ..................................................................................... 23

5.3 Data Products - Side Scan Sonar .................................................................................. 24

5.4 Evaluation of Remote Sensing Targets ......................................................................... 24

5.5 Remote Sensing Findings ............................................................................................. 25

6.0 Summary and Recommendations ....................................................................................... 37

7.0 References Consulted ......................................................................................................... 38

Figures ........................................................................................................................................ 41

Appendix: Qualifications of the Principal Investigator .............................................................. 53

LIST OF TABLES

Table 1. Magnetic Targets at Thompson Point APE .................................................................. 27

Table 2. Sonar Targets at Thompson Point APE ........................................................................ 28

LIST OF FIGURES

Figure 1. Project Location Map Overlaid on NOAA Chart #12312 ................................... 43

Figure 2. Project APE Overlaid on Aerial Photograph ....................................................... 44

Figure 3 1896 Topographic Map of Thompson Point at Repauno Site ............................. 45

Figure 4. 1940 Topographic Map of Thompson Point at Repauno Site ............................. 45

Figure 5. 1964 Topographic Map of Thompson Point at Repauno Site ............................. 46

Figure 6. 1940 Aerial of Thompson Point at Repauno Site ................................................ 46

Figure 7. 1965 Aerial of Thompson Point at Repauno Site ................................................ 47

Figure 8. Survey Track Plots............................................................................................... 48

Figure 9. Magnetic Contours .............................................................................................. 49

Figure 10. Sonar Mosaic and Sonar Targets Overlaid on Aerial Photograph ....................... 50

Figure 11. Onshore View of Sonar Mosaic Overlaid on Aerial Photograph ........................ 51

Figure 12. Magnetic Contours Overlaid on Sonar Mosaic at APE ....................................... 52

1

1.0 INTRODUCTION

In conjunction with planned dredging activities for the proposed Thompson Point port facility at DRP

Gibbstown Logistics Center in Greenwich Township, Gloucester County, New Jersey, a Phase I

Underwater Archaeological Remote Sensing Investigation was conducted to assess the presence or absence

of potential submerged cultural resources within the proposed dredging impact areas. Dredging activities

in the Delaware River may be required. The project’s Area of Potential Impact (APE) is the entire dredging

footprint that consists of a rectangular area centered on the former ferry dock at Thompson Point of the

Repauno Site and adjacent to the main navigational channel in the Delaware River. The proposed marine

facility is located offshore of the New Jersey shoreline of the Delaware River upstream of the Commodore

Barry Bridge and across from Little Tinicum Island and the mouth of Darby Creek on the Pennsylvania

side of the river (Figure 1).

Comprehensive acoustic and magnetic remote sensing survey investigations were conducted to assess the

presence or absence of potential submerged cultural resources within the APE. The underwater

archaeological project was completed under a subcontract agreement between Ramboll Environ, Inc. and

Dolan Research, Inc.

The investigation included background documentary research, acoustic, and magnetic remote sensing to

determine the presence or absence of remote sensing targets that possessed characteristics suggestive of

submerged cultural resource sites that might be affected by the proposed dredging activities. The

underwater archaeological investigation will assist in compliance with: Section 106 of the National Historic

Preservation Act of 1966, as amended; the regulations of the Advisory Council on Historic Preservation

(30 CFR Part 800); the National Environmental Policy Act of 1969, as amended; other applicable federal

and state mandates; and Corps of Engineers regulations (33 CFR Part 325, Appendix C). This investigation

was conducted in accordance with the instructions and intents of the Secretary of the Interior’s Standards

and Guidelines for Archaeology and Historic Preservation (48 FR 44716).

Previous to fieldwork activities, documentary research was undertaken to determine the likelihood and

nature of potentially significant submerged archaeological and historical resources within the APE.

Gathered documentary data were used to provide a framework for identifying historic archaeological

resources that may have been deposited within the Project area, and to determine the extent of subsequent

activities that may have removed or disturbed such material. Background research on the historic period

established a generalized context for ultimate evaluation of any potential historic submerged sites that were

identified.

Fieldwork investigations were completed in the Delaware River on 06 December, 2018. The survey goal

was to identify remote sensing targets of potential historical significance from the gathered remote sensing

data sets. Analysis of fieldwork data confirms the presence of three magnetic targets and nine acoustic

(sonar) targets in the APE. None of these remote sensing targets are considered to be suggestive of potential

submerged cultural resources and no additional underwater archaeological work is recommended.

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2.0 PROJECT LOCATION AND DESCRIPTION

The APE was a roughly rectangular-shaped area that is centered on the former ferry dock at Thompson Point

at the former Repauno Site. The project area is adjacent to the Tinicum Range of the main navigational

channel in the Delaware River. Remnants of a wood pier and water intake structure for the Rapauno site

extend into the river away from Thompson Point, Greenwich Township, Gloucester County, New Jersey.

The APE sits directly across the main navigational channel from the downstream end of Little Tinicum

Island in the Delaware River. The proposed dredging limits for the project are contained within an area that

is roughly 3,200 feet long x 1,500 feet wide (Figure 2).

Overall, the Delaware River is 5,300’ wide at this location. However, the distance from the shoreline at

Thompson Point across to Little Tinicum Island is slightly less than 3,000’. The main navigational channel

in the Delaware River is maintained at 800 feet wide and is presently being deepened from 40 to 45 feet.

Depths within the APE ranged from less than three feet close to the New Jersey shoreline to over 40 feet

on the offshore side. Much of the APE had water depths in excess of 35 feet.

The Delaware River, with its headwaters in upstate New York's Catskill Mountains and which empties into

the Atlantic Ocean through Delaware Bay, is approximately 300 miles long. The river is tidal, influenced by

tidal changes in the ocean below Trenton, New Jersey. A rock outcrop, stretching roughly from New York

City to Washington, D.C., separates the hard rocks of the rolling Piedmont from the sands of the coastal zone

and forms the fall line on the river at Trenton, approximately 125 miles from the Atlantic Ocean. Below

Trenton, the waterway is an estuary of the Atlantic Ocean, while above Trenton, the river descends through a

series of rapids and falls. Delaware Bay is situated approximately equidistant from New York Bay and the

mouth of the Chesapeake Bay - affording the only break in a dangerous 295-mile section of the Atlantic coast.

A considerable portion of the topography of the Delaware Valley was formed during the ice age. A series of

four continental ice sheets advanced south into North America over one million years ago. Each successive

ice sheet retreated further as the ice warmed. As recently as 15,000 years ago, during the peak of the last

advance, glaciers still covered the northern portion of the Delaware River Basin. Throughout the warming

periods large amounts of debris were washed into streams and deposited as sand and clay over the coastal

lowlands by the Delaware River. The Schuylkill River and the rivers near present Wilmington also deposited

this material. In that era the rivers followed a parallel course and separately emptied in the ocean. Eventually,

the Schuylkill, the Christina and the Brandywine Rivers eroded to the east and joined the Delaware River. As

the glaciers continued to retreat and melt, the sea level rose, inundating the lower estuary and forming the

present conditions of Delaware Bay (Council on Environmental Change, 1975).

Today well over seven million people live in the Delaware River Basin. Along the tidal portion of the river

Trenton, Philadelphia, Camden, Chester, and Wilmington form a vast and expanding urban area where the

suburbs of adjacent cities merge into one sprawling metropolitan region. A characteristic of these port cities

is the almost complete "filling" of the original shoreline. Riverfront property along the Delaware River has

hosted a vast network of industrial facilities, including; oil refineries, chemical plants, shipyards, storage

terminals, steel mills and warehouses. Light industry, power plants, piers, railroad yards, and highways

dominate much of the Delaware River shoreline between Wilmington and Trenton. Sea level navigation on

the Delaware River was possible as far north as Trenton. Above the fall line of the river at Trenton, there is

little or no industry along the shores of the river. The countryside is generally rural with rolling farmland and

forests. Small towns, the exception being Easton, are interspersed with natural environmental features. The

major portion of the river bank in this area is tree-lined. Riegelsville, Durham Furnace, New Hope, and

Yardley each developed because of their involvement with river transportation.

Delaware Bay and River is navigable from the Atlantic Ocean to Trenton, New Jersey. The width at the

mouth of Delaware Bay, between Cape Henlopen and Cape May, is 12 miles. However, the width of the bay

rapidly expands to a maximum distance of 25 miles and then gradually contracts to a width of four miles at

Liston Point, approximately 48 miles from the mouth of the bay. While the entrance to Delaware Bay from

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the north or Cape May side is obstructed by numerous shoals, there is an approximately four-mile wide

corridor at the southern side of the mouth of the Bay near Cape Henlopen, Delaware that has served as a

natural and unobstructed channel. Depths within this channel naturally range from 30 to 100 feet. Throughout

the length of the waterway there are numerous shoals in close proximity to the main channel. A series of 19

ranges have been established to guide pilots up the shipping channel from the mouth of the Bay to the Walt

Whitman Bridge in Philadelphia. The Project Area is located adjacent to the Tinicum Range. Presently, the

main navigational channel from the mouth of Delaware Bay to Philadelphia is maintained at a 45-foot depth

by the U.S. Army Corps of Engineers (COE). The channel is 1,000 feet wide up to the middle of Liston Range

where it contracts to 800 feet for the rest of its length to Philadelphia. In addition to maintaining the depth of

the main channel, the ongoing COE Main Channel Navigation Project provides six anchorages, each located

adjacent to the shipping channel, where ships may anchor while awaiting entrance to the harbor terminals.

3.0 MARITIME HISTORICAL BACKGROUND

3.1 Methodology

In addition to producing a generalized historical overview of activity in and around Delaware Bay and

River, specific research was conducted on maritime themes; including naval activity, shipping,

shipbuilding, navigational improvements and hazards, and shoreline development at the Repauno facility.

Both primary and secondary source material were consulted to provide data on local and regional historical

developments. Research was conducted at national and local venues. Repositories in Washington D.C.;

Alexandria, Virginia; Dover, Delaware; and Philadelphia, Pennsylvania, were visited by survey personnel

while compiling information for inclusion in the historical background.

Historical research was designed to determine the potential presence of submerged cultural resources in

Delaware Bay/River. The background research included a records check for known sites and National

Register properties within the Project vicinity, and review of state archaeological site and historic structure

files in New Jersey, as well as an examination of prior technical reports and preservation planning tools.

Background research on the historic period established a generalized context for ultimate evaluation of

historic submerged sites identified.

3.2 Maritime Historical Synopsis

Historic activity in Delaware Bay dates to 1609 when Henry Hudson first discovered the Bay while surveying

the northeast coast of North America for the Dutch East India Company. Hudson noted the entrance of

Delaware Bay, but did not explore up into the upper Bay and River. His observations of Delaware Bay were

recorded and eventually stimulated a significant interest in additional exploration, trade, and colonization of

the region. In 1614 the State General of Holland granted the merchants of Amsterdam and Hoorn exclusive

privileges to trade between 40 and 45 degrees of latitude in an area identified as the territory “New

Netherland.” The first Dutch explorers came to Delaware Bay from New Amsterdam (New York City) in

October 1614. By decree from The Hague, October 11, 1614, the owners of five Dutch ships were authorized

to establish the United Company of Merchants with the exclusive rights to explore the area between New

France in the north and Virginia to the south. Captain Cornelius Hendrickson was one of the first to explore

the bay aboard the Onrust (Restless). Captain Hendrickson produced the first chart of Delaware Bay and

River in 1615. Included in a brief report submitted to the Dutch merchants, Hendrickson claimed to have

found “certain lands, a bay and three rivers situated between 38 degrees and 40 degrees” (Weslager 1961; 45).

Soon the Dutch merchants set up trading stations and settlements at various locations along the banks of

Delaware Bay and River. In 1623, the Dutch East India Company constructed the first of several fortifications

on the east shore of the bay.

Swedish explorers were also active in the Delaware Bay region. In 1629 the Swedish West Indian Company

purchased from the Indians a two mile wide tract of land on the west side of the bay which extended 32 miles

from Cape Henlopen north to a location above present Bowers Beach, Delaware. Although the purchase was

4

ratified in 1630, it was not until Peter Minuit arrived with an expedition in 1638 that the Swedish attempted

to settle the region (Hazard 1850). The Swedes eventually settled further upriver at a more suitable landing

site on the west shore, near present Wilmington, Delaware.

For the next three decades the Swedes and Dutch co-existed in the Delaware Valley until 1664 when the

British, under the command of Sir Robert Carr, assumed command of the region. When King Charles II made

a grant of lands in the Delaware Valley to his brother James, Duke of York, the Duke sent a flotilla of warships

under Carr’s direction to subjugate the Dutch and Swedes and institute British control in the area. After

several years of limited interest on the part of the Duke of York, King Charles II deeded a substantial portion

of the territory to William Penn in 1682. Penn subsequently established an English colony, Pennsylvania, on

the Delaware River with Philadelphia as its capital (Weslager 1961).

In 1684, Penn also acquired the “three lower counties” (present-day Delaware) from the Duke of York to add

to his Pennsylvania holdings. With Penn’s involvement the colonization process and economic growth in

Delaware became tied more closely to Philadelphia and Pennsylvania. Throughout the colonial period,

settlement in the lower Delaware Valley consolidated in regions where solid banks came to the Delaware’s

edge; for most of the waterfront was marshland and unhealthy for habitation. New Castle, and Wilmington,

Delaware, Burlington, and Bordentown, New Jersey, and Philadelphia, Pennsylvania developed at locations

of this type. In the lower portion of the Delaware Valley, population centers were again on high land. The

high land was often some distance up a creek navigable only by shallow-draft vessels. Dover, Delaware, and

Salem, New Jersey, were examples of this. Some colonial–era towns developed because they were stopping

points along the 60-mile stretch of river on the much-traveled route from New York to Baltimore. This applies

to Trenton and Bordentown, New Jersey, near the northeast bend of the river, and to New Castle and

Wilmington, Delaware, near the southwest bend. Philadelphia, in the middle of this line of travel, was not

merely a stop on the line but developed into a trade and travel center itself (Tyler 1955).

Throughout much of the colonial period, wheat, rye, barley and tobacco were the principle colonial products

of Delaware Valley inhabitants. After being hauled by wagon to mills established along the banks of the

Schuylkill River, Brandywine Creek, and other swift-water tributaries of the Delaware, the flour was placed

aboard shallops and taken down the Christina River to the Delaware River for shipment up to Philadelphia

for consumption or further shipment. For the duration of the colonial period, the Delaware Valley region

remained predominantly agricultural. The agricultural landscape that developed in response emphasized the

importance of river and coastal transportation routes over roads. The system of agricultural production and

transportation routes facilitated the rise of Philadelphia as one of the most important ports in the British Empire

at the onset of the Revolutionary War.

Revolutionary War activities disrupted the economic development of the Wilmington and New Castle region

when the British blockaded all shipping and conducted raids along the shores of Delaware Bay (DeCunzo and

Catts 1990). After the war, Delaware Valley merchants were freed from the restrictions of the Navigation

Acts, and again prospered. Philadelphia became the most active port in North America, with its ships reaching

new markets in the East Indies and across the world. By 1800 there were 40 Philadelphia vessels in the China

trade, about as many more trading in South America, and a considerable number still trading in Europe. The

War of 1812 caused a second disruption to the social and economic life of Delaware Valley residents, but

shortly thereafter, local inhabitants began to focus again on industry and agriculture. A water link between

Delaware Bay and Chesapeake Bay was forged when the Chesapeake and Delaware Canal opened in 1829.

Traffic across the peninsula between the two bays was so heavy that it supported the canal, a previously

constructed turnpike, and within a few years, the New Castle and Frenchtown Railroad, one of the first

railroads in America (Tyler 1955). Manufacturing came to the upper Delaware Valley in the first half of the

nineteenth century. By 1850 Wilmington had become a leading manufacturer of railroad cars, heavy

machinery, gunpowder, textiles, flour, and iron steamships (Weslager and Heite 1988).

The introduction of steam technology had a dramatic effect on industries throughout the Delaware Valley.

Regional companies became leaders in the production of steam engines for railroad locomotives and

5

steamships. Several local companies also made railroad cars and car wheels, before expanding into the

production of iron-hulled steamships. Delaware River shipyards gained an international reputation for

producing quality iron hulled steam vessels. Coal fuel was needed to power steam engines. Extensive

anthracite coal reserves along the Lehigh and Schuylkill rivers were developed. Coal became a leading export

for Delaware River ports during the nineteenth and twentieth centuries. Related industries of iron and steel,

initially founded in the Delaware Valley since the colonial period, expanded after the nineteenth century.

The large chemical industry of the Delaware Estuary began with the development of several small tanneries

in and around New Castle County, Delaware, during the nineteenth century. Native black oak trees provided

tanbark and local livestock production provided skins for the tanners. By the middle of the nineteenth century,

Wilmington became a major producer of leather merchandise. Experiments were conducted in the tanning

process that would revolutionize the leather making process. Prosperity gained from gunpowder production

during the Civil War, allowed the local DuPont Company to expand over the next thirty years into one of the

world’s largest producer of chemicals and munitions. Petroleum-related industries and refineries were also

established shortly after the discovery of oil in central and northwestern Pennsylvania in the nineteenth

century. Philadelphia refineries are among the oldest in the world still producing refined oil products

(Weslager and Heite 1988).

Several specific historical maritime themes relating to Delaware Bay and River are discussed in detail in the

following sections.

3.2.1 Naval Activity in Delaware River

There was a significant naval engagement waged on the Delaware River during the Revolutionary War.

English and Colonial forces fought for control of the river and water access to Philadelphia. While

Philadelphia fell to British forces in September 1777, the colonials remained in control of the Delaware River.

In an attempt to gain control of the only supply route available to them, the British sent a large naval fleet of

warships to attack and destroy the colonial forces controlling the river. The Americans attempted to counter

the awesome strength of the English warships with a defense system including three forts (Billingsport,

Mifflin, and Mercer), two tiers of river obstructions (known as chevaux-de-frise), and numerous and assorted

small craft: row galleys, guard boats, floating batteries, fire rafts, sloops, and schooners. Altogether, a fleet

of 57 vessels was assembled by the Colonial forces on the Delaware River (Jackson, 1974).

Prior to the major engagement between the naval forces which was fought in the fall of 1777 in the upper

reaches of the river just below Philadelphia, an initial encounter took place in the spring of 1776 near

Wilmington. In May 1776 a fleet of three English vessels under the command of Captain Hammond was

ordered up the Delaware River to determine the strength of the colonial forces. The Americans, who had

placed two tiers of river obstructions across the river as part of their defensive scheme, sent a portion of the

small boat fleet below the lower tier of obstructions to meet the English force. Between May 8 and May 12,

the two sides met on two separate occasions. The first encounter was adjacent to the mouth of the Christina

River and the second incident was slightly down-river from there. Both skirmishes were inconclusive; neither

side suffered a loss in either engagement.

The two forces did not meet again until October 1777. A vastly superior English force of nine warships with

285 guns made their way up the Delaware River to meet the American fleet which was stationed in and around

Forts Mifflin and Mercer. The British first encountered and quickly overran Fort Billingsport in New Jersey

which guarded the lower tier of river obstructions. Fort Billingsport was poorly planned and ineffective as a

defensive fortification. One engineer noted before the battle, that "the Fort is badly situated, the battery which

forms its principal object is improperly directed, which renders half the guns useless." He goes on to state,

"the fort cannot prevent the passage of the enemy and when they have passed, it can be of no use, consequently

it can answer no valuable purpose." (McGeorge, 1905; p. 1). Having overtaken Fort Billingsport, the British

next cleared a channel through the lower tier of chevaux-de-frise on October 20. A subsequent survey of the

river, conducted by the Port Wardens of Philadelphia in 1784, actually documented that the British succeeded

in removing three frames of chevaux-de-frise off of Fort Billingsport (Jackson, 1974).

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With a channel cleared through the obstructions, six vessels proceeded up the river on October 22. The

frigates Augusta (64 guns), Roebuck (44), Liverpool (28), and Pearl (32), and sloop of war Merlin (18), and

galley Cornwallis proceeded to anchor near Hog Island to prepare the attack on the two remaining forts. The

large vessels had a problem navigating in the narrow confines of the channel in this portion of the Delaware.

Liverpool ran aground that day, as did Roebuck. Lighters were kept busy in helping these ships to be

re-floated (Jackson, 1974). The difficulty in maneuvering these warships forced the British to limit the size

of the fleet which could engage the American forts. However, the British did organize a well-conceived plan

of attack. The main flotilla operated in the main channel above the lower chevaux-de-frise. The Vigilant and

Fury were slowly brought up the shallow west channel behind the series of islands that lined the Pennsylvania

shore. They were used in flanking action against the weak west wall of Fort Mifflin. The Americans had

never fortified the west side of Fort Mifflin, obviously not believing a war ship could advance up that shallow

channel. Several American row galleys dropped down the west side of Fort Island to contest the position of

the Fury and Vigilant, but quickly had to retreat due to the fire from the British shore batteries located west

of Fort Mifflin (Jackson, 1974).

The battles fought on October 22, 1777 were contested at long range. The American row galleys remained at

a relatively safe distance, while still protecting the chevaux-de-frise from the British attempts to remove them.

That night the British fleet returned downstream to a safe anchorage. However, the Augusta and Merlin ran

aground. A report from the British Admiral Howe mentioned that

"the change in the natural course of the river caused by the obstructions, appearing to have

altered the channel, the Augusta and Merlin unfortunately grounded some distance below the

second line of chevaux-de-frise and the fresh northwardly wind which then prevailed, greatly

checking the rising of the tide, they could not be got afloat on the subsequent flood."

(McGeorge, 1905; p. 1)

The Augusta had grounded below Fort Mercer, near the mouth of Woodbury Creek, while the Merlin was

stuck about two-thirds of a mile below the Augusta, near the mouth of Mantua Creek. After an American

attack on the stranded vessels the next morning, an accidental fire ignited aboard the Augusta. The fire spread

rapidly and the ship was hastily abandoned before it blew up. After the Augusta exploded, the British decided

to scuttle the Merlin which was still aground. The remainder of the British fleet dropped down river to

Billingsport, vacating that portion of the river to avoid other possible explosions (Jackson, 1974).

Despite these two losses, the British regrouped and prepared another assault on the forts in November. The

British were anxious to control the river before the onset of winter. The colder temperatures periodically froze

the river, closing it to navigation. Again, Fury and Vigilant worked their way up the western channel.

"The Vigilant is to come up as soon as the tide will admit her. She is not to come over or

through any part of the chevaux-de-frise, but up a creek between Providence Island and

another small isle. Her station is to be on the angle of the rebel grand battery and on the right

of our batteries. A sloop (Fury) likewise, with 3 18-pounders, is to follow the Vigilant and

after she is moored the sloop is to anchor just ahead of her." (Downman, 1898; p. 271)

The main British fleet assembled in the center channel adjacent to Fort Mifflin, while the Vigilant and Fury,

along with land batteries initiated a massive bombardment to the west side of Fort Mifflin. The siege on Fort

Mifflin raged for five days until the fortification was bombed into submission by November 15. By 11:00

a.m. on November 15, the Vigilant and Fury commenced a final bombardment on the fort. The larger British

warships were occupying the attention of the row galleys and floating batteries in the main channel. Fort

Mifflin had only two guns on its western flank to reply to the assault from the Vigilant and Fury. By 1:00

p.m., the fort was badly damaged and ammunition was running out. Furthermore, an American sloop carrying

ten eight-pound guns was sunk near the fort (Jackson, 1974). At 5:00 p.m. the British, satisfied that the fort

7

would be evacuated that night, fell back to Billingsport. They prepared to take over the fort the next morning.

The Americans evacuated the fort that night, but not until they destroyed all remaining guns and carriages.

With the evacuation of Fort Mifflin and the decision to remove the garrison from Fort Mercer, the fleet of

American vessels became vulnerable to attack. The fleet was temporarily stationed at "Ladd's Cove" at the

mouth of Big Timber Creek, a short distance above Fort Mercer. On November 19, colonial leaders decided

to send the fleet upstream past the English positions at Philadelphia, to seek winter refuge in any of the creeks

and tributaries above the city. The fleet was divided into two squadrons: the first group was comprised of

the larger vessels of the State Navy and all the remaining Continental vessels, and the second group included

the galleys and other smaller vessels. The latter group successfully slipped past the city undetected on the

night of November 19. By rowing the vessels upstream along the eastern or New Jersey shoreline, the

Americans succeeded in getting half their fleet upriver to Bristol by 10:00 a.m. on November 20. Thirteen

galleys and nine armed boats successfully slipped by the city and headed for the various creeks upstream to

join the already scuttled fleet of merchant vessels. Records indicate that the complete listing of vessels which

successfully passed Philadelphia include: 13 galleys, 12 armed boats, sloops Province and Ammunition, brig

Convention, one ammunition sloop, one provision sloop, one provision schooner and two flats with stores and

11 18-pound cannon (Pennsylvania Archives, First Series, volume VI; p. 50).

The larger vessels attempted to pass the city the following night. However, these vessels had to use their sails

to get underway and were spotted by the British in Philadelphia. Land-based batteries and guns from the

captured ship Delaware opened fire on the prone fleet. Two sloops were driven ashore on the New Jersey

side as they attempted to pass the northern batteries in Philadelphia. One was captured and the other was set

afire. Only one schooner, five sloops and the brig Convention safely passed the city that night. The remainder

of the fleet, including the flagship Montgomery, all Continental vessels and the two floating batteries, were

destroyed in accordance with the preconceived plan to laden all vessels with combustibles and ignite them in

the event of imminent capture (Pennsylvania Archives, First series, Vol. VI, 27-28). Joshua Barney, aboard

the Convention, later wrote:

"On our evacuation of the forts and the destroying of our fleets, (ours) was the only boat that

arrived at Bordentown loaded with powder, the remainder were drove on shore in passing

the city by the very severe fire from the enemy. Our ships on fire making it as bright as day,

the gallies escaped the night before." (Matthewman, 1878; p. 178).

Pennsylvania Navy Commodore Hazelwood recounted the actions in a letter to President Wharton:

"...we on that day (November 17) brought the galleys up into Lads Cove where we held

council...we lay two nights for a wind to pass the fleet but having none it was agreed by the

whole Gentleman that galleys ought to pass that night, accordingly I got them under way at

3:00 a.m. and about 4:00 a.m. they past the city without having one shott fired at them, they

had with them nine armed boats whom all got safe up about 10:00 a.m. same day..."

(Pennsylvania Archives, First series, vol. VI; p. 49).

Hazelwood went on to mention the outcome of trying to pass the larger ships past Philadelphia on the

following night:

"...(I) dispatched the galleys down to assist in getting the remainder of the fleet past the city

but it being late when I got up and the tide not answering until morning and before day I

heard a firing at town and soon after saw one of our boats whom told me that what part of

the fleet they thought could be got bye was passed and the rest was sett on fire agreeable to

a council held in the evening." (Pennsylvania Archives First series, vol. VI; p. 49).

Among the Continental vessels destroyed were the brigs Andria Doria, Xebecks, Repulse, and Champion.

The fleet was set afire "near League Island." As the ships were burning, Robert Morton mentioned that "the

8

American Navy was on fire coming up with the flood tide and burning with the greatest fury. Some of them

drifted within two miles of the town and were carried back by the ebb tide. They burned nearly five hours:

four of them blew up" (Smith, 1970; p. 40).

The surviving colonial naval force was then trapped between the British warships downstream and the British

Army in Philadelphia to the north. An attempt was made to send the trapped ships past the British forces in

Philadelphia on two separate nights. On the following night, November 21, an attempt was made to pass the

larger colonial warships past the city. However, most of the ships were sighted as they came abreast of the

British fortifications on the city's riverfront and were either destroyed by enemy fire or burned to prevent

capture.

During the winter of 1778, the fleet of colonial merchant and naval vessels remained hidden in the various

creeks between Philadelphia and Trenton. Once a tactical decision had been made by the British to vacate

Philadelphia the following summer, British officers decided that the hidden colonial fleet must first be

destroyed to prevent attack on the withdrawing troops. On May 7, 1778, a 700-man expedition under the

command of Captain John Henry set off from Philadelphia on numerous galleys, gunboats and flatboats up

the Delaware River to attack and destroy as much of the hidden fleet as possible. Surviving documents from

the British raid indicate that a total of 44 ships were burned during the two-day assault. Twenty-two of the

vessels were located near the town of Bordentown and in Crosswicks Creek where the British met little

resistance. Henry wrote in his report that:

"the troops then marched and took possession of Bordentown and destroyed a battery of six

3 lbers (3 pdrs), where upon the galleys, armed vessels, etc., proceeded to that place where

they burnt two new ships, one of which was pierced for 18 guns, one privateer sloop for ten

guns, with 10 sail of brigs, schooners and sloops...This service being executed, the boats

proceeded up Crosswell Creek and set fire to the Sturdy Beggar, privateer, pierced for 18

guns and 8 sail of brigs, sloops and schooners..." (Universal Magazine, June, 1778; p. 320).

The assault continued further upriver and in Pennsylvania on the next day. Henry listed 44 as the total number

of vessels destroyed, including two frigates, nine large ships, three privateer sloops (16 guns each), three

privateers (20 twenty guns each), along with a number of sloops and schooners.

Remains from the fleet destroyed by the British attack have periodically been referred to in historic accounts

and references. A nineteenth century publication written by a Bordentown resident refers to the existence of

Revolutionary War hulks:

"When the British approached, two Continental galleys lying near the town were moved up

Crosswicks Creek, about a mile, and an attempt made to conceal them in Bards Creek. One

of them was towed up the creek, but the other was grounded near its mouth, thus revealing

their presence. The enemy sent several armed boats up and boarded and burnt them. Their

position was preserved by tradition and during the summer of 1875, Mr. Frederick Wiese,

taking advantage of a remarkable low tide, made a thorough search for them. One was found

near the mouth of Bard's Creek, partly buried beneath an island that had formed over it. The

other was found a short distance from the mouth, the bottom and some of the ribs were still

in a good state of preservation..." (Woodward, 1876; p. 202).

Another mid-nineteenth century account refers to wrecks in the area. Researchers compiling information for

Historical Collections of New Jersey, Past and Present included this reference to the British activity in the

area: "Before landing (at Bordentown), they burnt two frigates at White Hills, just below the village.

Afterward they destroyed several smaller vessels, the hulk of one of which, at very low tide, is still to be seen

in Crosswicks Creek" (Barber & Howe, 1868; p. 100). The Bordentown Register mentions the wrecks in a

piece from the April 22, 1910 edition: "Some of the oldest residents still remember the old wrecks which for

years lay near the entrance to Blacks Creek and were well known as "Hulks of the Revolutionary War."

9

A further mention of the wrecks is provided by another Bordentown resident, Edward Shippen, who wrote in

the 1830s: "Bordentown was then full of old people who could tell of Hessian occupation, and of foraging

upon hen roosts and diaries: and of gunboats and gondolas chased by the British into Crosswicks Creek and

there burned. The wrecks of some of them to be seen in the 'mash' in my time" (Shippen, 1954; p. 208).

However, additional information on the history of the Revolutionary War battle in May 1778, and the

subsequent fate of the colonial fleet in the Bordentown area has not been discovered.

There were no further documented naval engagements in the Delaware River after the Revolutionary War.

3.2.2 Delaware River/Bay Shipping

The Delaware River/Bay was the vital transportation artery which fostered the social and economic

development of the entire Delaware Valley. Trade in the Delaware Valley dates to the seventeenth century

fur traders, but it was not until the colonial era that it proliferated into a large and organized international

network. During the eighteenth century, merchants shipped and imported goods to and from other colonies in

coastal trade, and England, southern Europe and several Caribbean ports in overseas trade. Philadelphia was

one of several American ports that comprised the network of trade routes within the colonies. Each colony

contributed its local products for export. Pennsylvania primarily shipped lumber, staves, wheat, and flour

(Brewington, 1939).

The trade between Philadelphia and the English ports was constantly a one-sided venture. The upstart colony

received a wide assortment of products from England, including; manufactured goods, textiles, metals, tea,

shoes, and tools. Meanwhile, Philadelphia only exported lumber, foodstuffs, and furs to England. The

imbalance created by this unequal trade was alleviated by the subsequent development of a triangular trade

route that moved items from Philadelphia to the West Indies before the ships crossed over to England. Another

trade system involved the southern European nations of Spain and Portugal. This trade brought wine as the

primary import into the Delaware Valley.

An account of the trade network which originated from Delaware Valley ports, particularly Philadelphia, is

offered by Gabriel Thomas at the start of the eighteenth century:

"Now the true reason why this flourishing city advance so considerably...is their great and

extended traffique and commerce both by sea and land, viz, to New York, New England,

Maryland, Carolina, Jamaica, Barbadoes, Nevis, Monsurat, Antego, St. Christophers,

Barmudees, New Foundland, Maderus, Saltetudeus, and old England...Their merchandise

chiefly consists (of) horses, pipe stoves, pork and beef...bread and flour, all sorts of grain,

peas, beans, skins, fur, tobacco and potashes; wax which bartered for rumm, sugar, molasses,

silver, negroes, salt, wine, linen, household goods..." (Brandt, 1929; p. 87).

A more comprehensive account of trade in and out Philadelphia at a slightly later period, ca. 1754, is provided

by Acrelius. He listed articles which were shipped to and from the port of Philadelphia. He mentioned that

wheat, flour, bread and beef were the major exports to the West Indies - which in return sent rum and sugar.

Similar items were sent to Carolina, which in turn exported tar, pitch and turpentine. Philadelphia merchants

sent rawhides, deerskins, and several items previously acquired from the West Indies to London, Bristol and

Liverpool. In return, "there are brought all kinds of English manufactures and even bottled liquors. But as

this commerce is carried on with a very heavy balance against it, this must be made up by bills of exchange

and by money..." (in Brandt, 1929; p. 97). Acrelius continues to state that wheat, bread and wax were sent to

Lisbon, whose merchants shipped wine, salt, olive oil, silk, satin, and tea (Brandt, 1929) back to the Delaware

Valley.

Delaware Valley shipping activities increased throughout the eighteenth century. Port entrances and

clearances in 1730 placed Philadelphia third in the colonies behind Boston and New York. By 1772,

Philadelphia's shipping commerce had exceeded both of those ports to become the most active port in North

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America before the Revolutionary War. The Revolutionary War completely disrupted the commercial

development of the Delaware River ports. The British Navy all but stopped shipping in and out of Delaware

Bay. Delaware Valley merchants sought to establish new trade routes to revitalize the local maritime economy

after the war. A trade relationship with the Far East was sponsored. Shortly thereafter, ships were also leaving

Delaware Bay for such destinations as Russian, Baltic and South American ports. Often times these new

routes were necessitated by the tendency of each state to regulate their trade by levying stiff tariffs on shipped

goods. In 1800, some 40 vessels were involved in the China trade alone (Brewington, 1939).

The development of shipping in the early nineteenth century was again disrupted by several events. The

Napoleonic Wars tied up the majority of the European fleets in an embargo. In 1812 the British blockaded

the Delaware once again in conjunction with the War of 1812. However, several developments stimulated

the revival of shipping following these restrictive actions. The introduction of an anthracite coal trade, the

growth of packet line, and the slow but steady conversion to steam navigation all helped to keep the Delaware

ports active.

The first regular steamboat service on the Delaware was in operation from 1809 to 1813. The steamers

Phoenix and Philadelphia carried passengers on the upper Delaware River between Philadelphia and

Bordentown, New Jersey. The Phoenix was then replaced by the Eagle, which ran to Burlington, New Jersey

three times a week. Seven steamboats were reported to be operating on the Delaware River in 1813.

Steamboats were gradually used with increasing frequency. In 1819, the Vesta was the first steamboat to

venture down Delaware Bay from Philadelphia to Cape May, New Jersey. It completed the trip twice a week

(Baker, 1976). Since it took a while before mariners gained sufficient confidence with steam propelled vessels,

most of the initial steam craft were also outfitted with a sail rig and limited to operation in a relatively protected

environment. Other early steamboat lines which operated within Delaware Bay extended from Philadelphia

to Wilmington and Smyrna, Delaware and Salem, New Jersey.

Coastal steam lines lagged behind the steam service in rivers and harbors. Steamboats were initially designed

only to withstand calmer waters. Steamboats were eventually modified for open-water transit; however, most

of the initial changes in hull design and steam technology did not produce more seaworthy vessels. In 1836,

the 596-ton steamboat Charlestown, built at Philadelphia, ran to South Carolina. This service experienced

many difficulties and was discontinued in 1839. It was not until 1849 that a steamship (a vessel designed

specifically for the rigors of the open sea), the Philadelphia, was built for coastal service. She was equipped

with side-paddle wheels and driven by two side-lever engines. Other coastal steamers were rapidly built as

the early steamship lines began to thrive. The 227-foot paddle-wheel steamer Quaker City ran between

Philadelphia and Havana in 1854. The Clyde Line to New York and Boston was started in 1842 (Baker,

1976).

Large sailing vessels were still exclusively used during the first half of the eighteenth century to transport

cargo overseas. Shipping companies used the large, ship-rigged sailing vessels on established routes that

became known as packet lines. Regularly scheduled packet lines were sailing out of Philadelphia by the

1820s. Thomas Cope in 1822 initiated Philadelphia's first transatlantic packet line to Liverpool with two

ships, the 290-ton Lancaster and the 278-ton Tobacco Plant. Packet lines continued to thrive in Philadelphia

until after the Civil War. Other lines that operated out of Delaware River ports included the Welsh Line

(1823-1824); the New Line of Liverpool and Philadelphia Packets (1824-1837); Black Diamond Line

(1823-1824); New Line (1847-1855), Line of Liverpool Packets (1850-1861); and the

Philadelphia - Liverpool Line (1852-1854) (Baker, 1976).

3.2.2.1 Delaware and New Jersey Regional Shipping

There were several small, yet historically active ports along the several tributaries of Delaware Bay in the

coastal counties of New Jersey and Delaware. A strong regional trade network developed between various

ports in New Jersey, Delaware and Philadelphia. New Jersey farmers and merchants used the Salem, Maurice,

and Cohansey Rivers to transport their products to Philadelphia. In fact, the town of Salem, on the Salem

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River, became an official port of entry in 1682 and was one of only three official ports of entry for the entire

colony of New Jersey and enjoyed periods of extended prosperity during the early eighteenth century (Sebold

& Leach, 1991). However, the vast majority of shipping traffic from the New Jersey rivers was closely

connected to the port of Philadelphia. By the end of the nineteenth century, Salem had 13 wharves on the

waterfront, 12 of which were associated with the Pennsylvania Railroad. Steamers, sailing vessels, barges,

and canal boats carried glass, canned goods, iron and brass castings, agricultural products and fertilizer from

the Salem River to Philadelphia (Department of the Army, 1909).

The rise of Cape May as a summer resort destination caused steamboat companies to develop direct steamer

routes from Philadelphia to the southern tip of New Jersey at the mouth of Delaware Bay. Several steamboat

companies conducted successful passenger lines to the resort community of Cape May. As early as 1816, the

steamboat Baltimore traveled between Philadelphia and Salem twice a week; from Salem, passengers

continued to Bridgeton and Cape May via stagecoach. In 1824 the Delaware, under the command of Captain

Whilldin, began shuttling vacationers from Philadelphia and Wilmington and New Castle, Delaware, to the

Jersey shore. As demand for this service increased, established and new lines competed for riders and the

ticket prices fell from $5 to $.50 (Sebold & Leach, 1991).

Passengers and much of the commerce from Cumberland County, New Jersey, was carried down the Maurice

River by steamboats into Delaware Bay and up to Philadelphia. The Maurice River Steamboat Company

operated the Thomas Salmond which offered excursions from its home port to Philadelphia (Sebold & Leach,

1991). Sand, for the glass industry, was the principal item shipped through the Maurice River. During the

first half of the nineteenth century, bog iron was smelted and shipped down the Maurice River for export.

Gravel, oysters, and fish were also transported down the river and up to Philadelphia, and to a lesser degree

New York.

A steamboat line was also established on the Cohansey River connecting Bridgeton, New Jersey with

Philadelphia and other Delaware ports. In 1844, the Cohansey began making three excursions a week from

Bridgeton to Philadelphia with stops at Greenwich, Port Penn, Delaware City, New Castle, Marcus Hook, and

Chester, as well as occasional trips to Cape May. Three other steamboats operated on the Cohansey: the

Arwames, Patuxent, and Express (Sebold & Leach, 1991).

Fishing, oystering and later crabbing were major industries in southern New Jersey. Building ships for the

oystering and fishing fleets was another major industry on South Jersey rivers. Shallops and sloops were

typical vessels used in trade on the Delaware Bay and its rivers in the Colonial period. Use of shallops and

sloops for fishing, oystering, and trading, declined after the introduction of the versatile schooner (Sebold &

Leach, 1991).

In Delaware, Sussex and Kent County merchants used landings along each of the major streams

(Appoquinimink Creek; and Murderkill, Broadkill, St. Jones, Smyrna, Mispillion, and Leipsic Rivers) to ship

agricultural products to Philadelphia in exchange for manufactured items. Settlers engaged to build various

types of vessels, primarily sloops and schooners, at strategic locations along the river banks. By 1860,

three-masted schooners carrying 400 tons of cargo entered and cleared the rivers of Delaware. Lebanon,

Forest Landing, Barkers Landing and Dover all served as ports for the shipment of produce from Delaware

farms to Philadelphia. Lebanon, originally called Lisbon, quickly became the most active port in Kent County

(Valle, 1984).

Steamboats were introduced to the trade by the middle of the nineteenth century. At the end of the nineteenth

century, surprisingly large steamboats were involved in the trade between Delaware merchants and the port

of Philadelphia. Steamers Diamond State, Maid Of Kent, City of Milford, and Lamokin were carrying

passengers and cargo from various Delaware ports. Arrivals and departures of streamers were planned around

favorable high tides. After 1887, when a dredge cleared a six-foot channel as far inland as Drapers wharf,

steamboats were able to penetrate the St. Jones River all the way to Dover (Valle, 1984). The Dover and

Philadelphia Navigation Company commenced a regular service from the St. Jones River with two large

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steamers, John P. Wilson and City of Dover. In addition to the steamers, freight boats and two- and

three-masted schooners were actively engaged in transporting farm produce from Delaware to Philadelphia.

Railroads and all weather highways offered strong competition to the steamboat lines and by the Depression

most of the lines ceased to operate (Valle, 1984).

Dating back to 1820 the Wilmington Steamboat Company began regular freight and passenger service from

Philadelphia to Wilmington, Delaware using the steamer Superior. Superior made regular eight-hour trips

between Wilmington and Philadelphia. Several years later, the 156 foot-long steamer Wilmington also joined

the service. Although the Reybold Line also operated steamers out of Wilmington, the Wilmington Steamboat

Company, later known as the Wilson Line, dominated steamboat activity out of Wilmington throughout the

second half of the nineteenth century. Its major competition came from railroad companies (primarily the

Philadelphia, Wilmington and Baltimore Railroad) that offered rail service between Baltimore and

Philadelphia, as well as their own line of steamers (Elliott 1970).

Shields Wilson reorganized the Wilmington Steamboat Company in 1882 and henceforth it was known as

The Wilson Line. The Wilson Line began a period of sustained growth that lasted until the 1930s. Wilson

Line steamers used on the Philadelphia-Wilmington run included; Wilmington, Brandywine, City of Chester,

City of Trenton, Quaker City, City of Wilmington, City of Philadelphia, City of Camden, State of Delaware

and State of Pennsylvania (Elliott 1970). All of these steamers with the exception of the two State boats were

built at Harlen & Hollingsworth shipyard in Wilmington. The last Wilson Line steamers, State of

Pennsylvania and State of Delaware, were built in 1922-1923 at the other prominent Wilmington shipyard,

Pusey & Jones. Competition for the Wilson Line’s Philadelphia-Wilmington route arose in 1901. In that year

the Delaware River Navigation Company, which formerly operated only on the upper Delaware River,

established a new line that linked Philadelphia, Chester, and Wilmington in direct competition with the Wilson

Line. The steamers John A. Warner and Diamond State provided service for the Delaware River Navigation

Company’s new southern steamboat route.

World War I triggered significant industrial expansion on the Lower Delaware. The DuPont Powder Works

received enormous war orders and had to open new facilities at several sites in New Jersey to meet increased

product demand. Thousands of powder workers from the tri-state region were recruited for the new plants

located in the vicinity of Penn’s Grove, New Jersey. The majority of the Pennsylvania and Delaware workers

took Wilson Line ferries across the Delaware River to Penn’s Grove to get to work. New ferry piers had to

be built at Deepwater Point and Carney’s Point, New Jersey. Overwhelmed by this new traffic, the Wilson

Line purchased several steamers to handle the new ferry service load. Wilson Line purchased the following

boats for use in the Penn’s Grove ferry service; Long Beach, Artic, Cape May, Peerless, and City of Reading.

During peak years, steamboats and ferries made more than 30 Wilson trips from Wilmington every day.

Wilmington became a thriving steamboat port in the second decade of the twentieth century. By 1916, the

Penn’s Grove ferries alone were making 16 trips daily. Two separate ferry entities, Christina Ferry Company

and the Wilmington & Penn’s Grove Transportation Company were established accommodate this new traffic

(Elliott 1970).

However, competition from trucks took away much of the freight business, and trains were carrying more

passengers. The Depression took away much of the steamboat business and the steamboat traffic in

Wilmington began a slow and steady decline until all operations ceased out of Wilmington in the 1960s. The

Wilson Line ferries across the Delaware River were replaced by the opening of the Delaware Memorial Bridge

in 1951.

3.2.3 Shipbuilding in Delaware Valley

Historically, the Delaware Valley had a strong shipbuilding industry. From the years before William Penn

founded Pennsylvania up through the Second World War, Delaware Valley shipyards have been among the

most productive in the country. With the combination of available resources and skilled labor, Delaware

Valley shipyards rapidly established a strong shipbuilding tradition. The first documented ships built by

Europeans date to the middle of the seventeenth century during the Dutch and Swedish occupation. Although

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references to shipbuilding from this period are sparse, records indicate that the Swedes in 1644 endeavored to

build “two large, beautiful boats, one for use at Elfsborg, the other at Fort Christina” (Brewington 1939; 50).

The Swedes remained active in shipbuilding for the next several years; their carpenters finished a sloop, a

barge, and a 200-ton ship by 1651. However, Swedish shipbuilding ceased in 1655 when the Dutch assumed

control of the valley. There is no record of Dutch boat building during this era, but it would not be

unreasonable to assume that some boat building was being completed to support the several forts and outposts

that were built.

Shipbuilding increased dramatically with the English presence in the Delaware Valley after 1664. One of the

first vessels built by English settlers was the ship Glob, constructed in 1675. At least two other vessels were

built that year along the Delaware River shoreline (Brewington 1939). In his designs for his colony, William

Penn had intended to establish a strong tradition of shipbuilding. He recognized the potential of the hardwood

forests that stretched along the upper portions of the Delaware River. This vast source of timber suitable for

shipbuilding was vital, particularly since much of England’s natural wood supply had been exhausted by the

end of the seventeenth century.

With the combination of available resources and skilled labor, Delaware Valley shipyards rapidly became

among the most active in all the colonies. In 1700, there were four commercial shipyards in operation along

the Delaware River. Between 1682 and the beginning of maritime records in 1722 (ship registers, started by

the port authorities to collect customs), the average number of ships built is estimated to be slightly less than

ten vessels per year, most less than 50 tons in size (Crowther 1973). Several family shipyards were responsible

for the majority of the early eighteenth century vessels built in the Delaware Valley. West, Penrose,

Humphries, Bowers, Eyre, Cramp, Lynn and Vaughan were some of the prominent shipyards in the area.

After 1722 an estimation of the output of the shipyards in the Delaware Valley can be determined from the

Ship Registers of Pennsylvania, 1722-1775. A total of 3,241 vessels were registered in Philadelphia over this

period. A large percentage of that number was undoubtedly built in local yards. Between 1722 and 1776

Delaware Valley yards produced approximately 95,000 tons of shipping if one estimates the output of missing

years in the registers and adds that number to the total recorded output of 87,346 tons (Crowther 1973). The

average tonnage of individual vessels increased steadily throughout the entire 54-year period. Six types of

vessels were listed in the registers: square-rigged ships, sloops, brigantines, snows, schooners and shallops.

These were the vessel types predominantly used in the Delaware River and Bay during the colonial period.

Their basic distinguishing characteristics were the type of sails and rigging used, but they also varied in size

as well. By 1770, Pennsylvania, New Jersey and Delaware shipyards were among the most active in terms of

tonnage of vessels built.

Technological innovations ushered in with the Industrial Revolution helped to change the nature of shipping

and shipbuilding on the Delaware River and Bay during the nineteenth century. Iron-hulled steam vessels

rapidly became the standard vessel type operating on the waterway. Shipbuilding yards along the banks of the

Delaware soon were producing more iron-hulled vessels than any other region in the country and quickly

earned the reputation as the “Clyde” of American shipbuilding. Harlan and Hollingsworth Shipyard of

Wilmington became the nation’s leader in producing quality iron-hulled steam vessels. Originally opened as

a yard to build railroad cars in 1836, the firm was foundered Mahlon Betts, a foundryman and Samuel Pusey,

a machinist. Samuel Harlen, a cabinetmaker, who led the firm into steam engine building and vessel repair

work and eventually into iron shipbuilding, soon joined them. Elijah Hollingsworth, who had been a foreman

with the Baldwin Locomotive works, became a partner in 1841 after buying out Samuel Pusey’s interest

(Tyler 1958).

The yard then known as Betts, Harlen & Hollingsworth built its first two iron-hulled boats in 1844. The two

98-foot long screw steamers, Ocean and Ashland, were intended for a new steamboat line from Philadelphia

to Albany via the new Delaware-Raritan Canal. After Betts retired in 1849, the yard became known as Harlan

& Hollingsworth. Over the next 70 years Harlen & Hollingsworth established itself as the country’s leading

shipyard producing iron-hulled steam vessels. Between 1844 and 1887, Harlan & Hollingsworth built 232

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boats of all descriptions and sizes. The company grew so large that it occupied a 43-acre plant on both sides

of the river that involved 168 distinct industries, trades and callings in building its ships (Brandt 1929). The

other prominent Wilmington shipyard that produced iron-hulled ships was Pusey & Jones, which was started

in 1849 by two machinists Joshua Pusey and John Jones. They opened their yard at the site of the former

Wilmington Whaling Co. at the foot of Walnut Street on the Christina River. Among other noteworthy

achievements, Pusey & Jones launched the country’s first iron hulled sailing vessel in 1854 (Tyler 1958).

In the 12-year span from 1845-1857 Wilmington shipyards constructed more iron tonnage that all the rest of

the country combined. During that period, Wilmington yards built 10,886 tons -35 ships, while the second

most active city Philadelphia launched only 2,430 tons -13 ships (Tyler 1958). In support of the iron

shipbuilding industry, several machine shops and sawmills were successfully operated in Wilmington dating

to the middle of the nineteenth century.

Several nineteenth century Wilmington shipyards were building traditional wooden-hull sailing vessels.

Dating back to the start of the nineteenth century, local shipwrights produced sloops, schooners, shallops, and

a variety of small vessels for local trade and the thriving fish/shellfish industry. Occasionally, much larger

vessels were constructed for overseas trade. The schooner rig, adapted from early eighteenth-century English

and European vessel types, became popular throughout the lower Delaware Bay. A small crew could

effectively operate a schooner-rigged vessel. Various types of schooners were developed in the eastern United

States: “Virginia Schooner,” “Baltimore Clipper,” and “Bay Schooner” versions were all developed by

American shipwrights in the nineteenth century. Delaware boat builders, adapting to the Delaware River and

Bay’s strong tides and shallow waters, modified a version of the bay schooner (referring to the Chesapeake

Bay). “By the 1920’s Delaware Bay schooners had taken on their own unique characteristics. Increased

length of the hull lines, a freeboard with a long sweeping sheer line, and smaller heart-shaped sterns with

elliptical tops characterized New Jersey schooners” (Witty 1986; 96). As schooners became more popular

among watermen, Delaware Bay sloops were dismantled and refitted as schooners with their characteristic

fore and aft sail rig. During the first half of the twentieth century wind powered oyster schooners were

eventually outfitted with motors and pilot- houses (Sebold and Leach 1991).

Enoch Moore operated one of Wilmington’s earliest shipyards at the foot of East Fourth Street. Other

prominent Wilmington wood shipbuilders include; W. & A. Thatcher (at the foot of Walnut Street), and

Young (at the foot of Walnut Street) (Tyler 1958). The majority of the vessels built at these yards were

schooners, sloops, shallops, and fishing boats that utilized local wood products, particularly white oak and

pine. Productivity of the yards began to decline in the 1880s when wooden sailing ships were gradually

phased out of coastal shipping (Hoffecker 1977).

3.2.4 Overview of Delaware Bay/River Navigational Improvements

Although the Delaware Bay was visited by Henry Hudson in 1609 and explored by others within the next

decade, the first comprehensive navigational chart of the Delaware Coast vicinity was not completed until

1756. In that year Joshua Fisher charted the waters of the Delaware Bay and provided the first bottom

contours based on soundings. In the first half of the 19th century several other maps and charts of the

vicinity were privately published, but standardized charting of the coast was not initiated until the first

United States Coast Survey was completed in the middle of the 19th century. In 1878, this agency was

reconstituted as the United States Coast and Geodetic Survey and, from this time on, has periodically

updated the chart of the vicinity with increasingly detailed and more accurate hydrographic information.

3.2.4.1 Seventeenth and Eighteenth Century Navigational Improvements

Shoals throughout the length of the Delaware have hampered shipping activities since the arrival of the first

Dutch and Swedish settlers. The inhabitants of New Amstel often complained of the river conditions. John

Alricks, after hearing numerous complaints, conferred with the seafaring men and later reported that, "it was

agreed that it would be best to lay five or six buoys there [in the river]" (Weslager, 1961; p. 207). Apparently

this was the first effort to provide navigational aids on the river. Alricks also suggested the need for dredging,

by mentioning that "appropriations ought to be made to render it safer and better for incoming ships"

15

(Weslager, 1961; p. 207). The Dutch did succeed in establishing a system of pilotage by hiring persons "who

have a perfect knowledge of the bottom depths and shoals in and about the South (Delaware) River, to make

use of them as pilots" (Hazard, 1828; p. 181). Two men, Sol Garrotson and Peter Lourison, were engaged as

pilots for a fee of ten shillings a day.

While the Dutch were active in their commitment to improving navigation on the river, the English neglected

it. After the British assumed control of the Delaware Valley in 1664, they failed to maintain the system of

buoys which the Dutch had established. William Penn recognized this shortcoming and laid a tax on vessels

entering the river. The money collected was to be used to continue the Dutch system of buoys (Pennsylvania

Colonial Records, vol. 1). In 1687 the Assembly agreed to "take a speedy account of the monies paid for the

erecting of buoys and to place them as soon as possible..." (Slaski, 1979; p. 3). Despite these efforts, little

work to improve the river was recorded as having been done. Nor was any substantial work done to improve

navigation throughout the first half of the eighteenth century, despite the continued pleas of merchants. They

often saw their shipping disrupted because of the shoaled waters. Merchants constantly sought assistance

from the government in installing permanent navigational aids. Through its early development there was no

coordination among the various parties involved with the port. In addition to the stalled efforts to improve

navigation, there was no plan for the establishment of a system that would coordinate the port's development.

There were no regulations to check the rapidly expanding wharf-line and no procedures to license qualified

pilots (Slaski, 1979). In 1765 the merchants, supported by maritime insurers, petitioned the Commonwealth

by complaining of "grievous losses because of the lack of proper regulation of pilots" (Slaski, 1979; p. 6).

Finally, the first organized efforts to overcome the navigational hazards facing mariners traversing up the

Delaware River were established in 1766 when the port was placed under the control of the Wardens of the

Port of Philadelphia. The office of the wardens was created by the enactment of "An Act for Appointing

Wardens for the Port of Philadelphia and for Regulating Pilots Plying the River and Bay to and from Said

Port" (Slaski, 1979, p. 6). The wardens were issued the responsibility of licensing pilots, placing buoys,

alleviating the problem of winter icing, the erection of lighthouses, and the dredging of wharves and piers.

Port wardens were partially responsible for the development of sailing instructions for the bay in 1796 that

mentions buoys were placed on Brown, Brandywine and Cross Ledge Shoals. By 1827, additional buoys

were placed on Joe Flogger, Fourteen Bank and Upper Middle Shoals. Navigational lights were not

standardized until the second half of the nineteenth century. However, in terms of physical improvements or

installation of navigational aids, little was done until the nineteenth century.

3.2.4.2 Hazards to Navigation: Ice

Historically, ice has been a serious threat to navigation on the Delaware River. Every winter, almost without

exception until the middle of the nineteenth century, portions of the Delaware River froze over. Ice not only

closed ports in the river for a period each winter, sometimes lasting over a month, it also posed a serious threat

to any unfortunate vessel that became entrapped by ice floes. Sharp ice masses severed anchor cables and

could easily sheer a wooden hull. Despite all measures taken to alleviate shipping concerns, the problem of

the river freezing was overcome primarily by the fact that by the latter part of the nineteenth century, the river

did not freeze that frequently. Urbanization and pollution both contributed to warming the river.

In 1822 the attention of the Philadelphia Chamber of Commerce was called to the subject of the “perils and

difficulties of the winter navigation of the Delaware” in a communication by William Jones, a former

Secretary of the Navy, which was published in a pamphlet. Jones proposed four plans in the pamphlet:

“1st, the construction of two ice boats to be propelled by steam. 2nd, the

excavating to the required depth, or otherwise improving the ice harbors

formed by the existing public piers. 3rd, the construction of new harbors at

the confluence the Christina and Cohanzey creeks with the Delaware, 4th,

the construction of small intermediate harbors in the channel side of the river

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where the tides are strong, and sweep alternately the same ground in a

direction parallel to the shore.” (in Hazard 1828; 51).

A breakwater at the mouth of Delaware Bay was also seen as a critical component to combating the ice threat

to safe winter navigation in the bay. In a report by the Corps of Engineers discussing the need for a breakwater,

Captain Bainbridge commented on the utility of a pier or breakwater near the Capes of the Delaware, which

would protect vessels against floating ice and wind:

“The Delaware bay is not only obstructed by fixed ice during a part of the

winter, but it is without a harbour near its mouth in which vessels can secure

themselves either against winds blowing from the northwest to the

southeast, round by the north, or against floating ice. It is frequently the

case, that the navigation of the bay is impeded by the ice, as early as the

month of December...For two months at least, therefore, between December

and March, vessels bound up the bay will be uncertain as to their passage to

the city; and being without shelter when they arrive at the Capes will be

exposed to the greatest dangers, should they find the passage

obstructed...These general conditions show important it is, that something

be done to secure, if possible, a safe anchorage near the mouth of this great

communication with the ocean...” (in Hazard 1828; 52).

The first attempt to manage the ice problem was in 1762 when the first of a series of ice piers was privately

constructed above the northern shore of Reedy Island, south of New Castle, Delaware. Originally, two piers

were built there. The first was 180 feet long, by 30 feet wide, and the second was 205 feet long and 30 feet

wide. They served to break up the floes as they came down the river and to provide a safe anchorage for

ships.

The idea of an ice harbor at New Castle was started after the state legislature passed “An Act to enable the

persons therein named to raise a sum not exceeding Twelve Thousand Dollars, by a lottery, for the purpose

of erecting piers in the harbor of the Town of New Castle.” (USACE 1997; 7). However, construction of the

first ice piers New Castle was not started until 1796, when 50-foot by 30-foot piers were sunk into 20 foot

deep water off of Harmony and Delaware Streets.

“Everything was conducted with the greatest regularity and order, and no

misfortune or accident damped their spirits, or retarded the work. It is

intended to complete a Second Pier this season, which will afford a

temporary and tolerable secure harbour for vessels in time of ice”

(Philadelphia Daily Advertiser 10/2/1795).

These initial piers proved to be ineffective and had to be repaired and upgraded. In 1802, the first federally

sponsored civil works project was authorized for the repair existing and construction of new public piers at

four ports on the Delaware River; New Castle, Port Penn, Marcus Hook and Chester. Other ice piers on the

Delaware were also built at Penn’s Grove, New Jersey, and Lewes, Delaware (Baker 1976).

The first ice piers at New Castle were rectangular, stone-filled wooden cribs. In 1827, Army Major Samuel

Babcock directed the construction of new timber wharves at New Castle, which joined the two ice piers to the

wharves and filled up the two sluiceways. These timber piers were later razed to low water and replaced with

rectangular stone superstructures. In 1835, Major Delafield directed the construction project to build two

new, hexagonal ice piers just offshore of the original two rectangular ice piers. Several improvement and

expansion projects were conducted at New Castle between 1854 and 1882. This included the construction of

four additional ice-piers with masonry superstructures. By the end of the nineteenth century New Castle had

seven ice piers that created a protected harbor measuring approximately 900 feet by 300 feet.

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3.2.4.3 Hazards to Navigation: Chevaux-de-Frise

Another navigational hazard present in the Delaware River was the placement of chevaux-de-frise by Colonial

forces during the Revolutionary War. They were rock-filled timber cribs that had one or more spear-like poles

extending up to a few feet below the water surface. These frames, designed to defend the river against a

British naval invasion, became serious threats to commercial shipping after the conclusion of the war. In

1783, the Port Wardens determined the location of the obstructions and placed buoys to mark their locations.

Arthur Donaldson and Levi Hollingsworth were contracted by the Port Wardens in May, 1784, to remove the

frames. After six months of work, they succeeded in removing 54 of the obstructions (Slaski, 1979). It is

difficult to determine how thorough their effort was because there is no way of knowing how many frames

the British had removed while they were clearing a passage through the river in 1776. A report from the Port

Wardens mentioned that during the year following the removal project, only one incident concerning an

obstruction frame was reported. Dredges working in the river during the 1930s and 1940s periodically struck

a stray frame while dredging the main channel in the Delaware River. Several decades ago a frame from the

river was recovered and is on display at Fort Mercer Historical Site, National Park, New Jersey. More recently

in 2009, divers inspecting a sonar target at Sunoco’s Fort Mifflin marine terminal dock, recovered a well

preserved, chevaux-de-frise iron-tipped spear, from the river bottom.

3.2.4.4 Nineteenth Century Navigational Improvements

The principal navigational hazard in the Delaware River was shoaled waters. Shoals accumulated throughout

the river and were continually shifting. The average water depth in the early part of the nineteenth century

varied from 15 to 25 feet in the main channel. This proved adequate for most of the vessels then plying the

river. Dredging was required in the harbors, where wharves accumulated considerable amounts of silt. It was

in the harbors of Philadelphia where Arthur Donaldson in 1774 used his invention, the forerunner of the

clamshell dredge, to clear silt and mud. However, his pioneering efforts were diverted by the Revolutionary

War. It was not until Oliver Evans equipped a "carriage" with a steam engine and stern paddle wheel and

operated it on the Delaware River in 1804 that any notable dredging was completed. This "Orukterg

Amphibolos" was probably the first application of a mechanically powered dredge on the Delaware River

(Synder, 1974). In 1805 the Philadelphia Chamber of Commerce requested the Port Wardens to administer a

tonnage "to be laid on vessels employed on foreign trade for the improvement and protection of the Delaware

River and Bay" (Slaski, 1979; p. 45). The five percent duty was intended to pay for the removal of natural

obstructions in the river and to erect winter-ice piers.

The first substantial dredging was not undertaken until 1864, when an act was passed that provided the Port

Wardens with jurisdiction over wharves and piers. Once vested with this right, they forced the owners of all

wharf property and waterfront facilities to:

"Maintain a minimum depth of water at the bulkhead of not less than 3 feet at low water and

as much great depth as in the judgement of the wardens may be required for the

accommodations of...vessels as usually require berths at the piers surrounding such docks."

(Wardens of the Port, Minute Books, vol. 40, 1864).

Earlier, in 1829, Congress addressed the problem of navigation in the river by approving an appropriation for

the procurement of a "dredging machine to be applied to the deepening of the Delaware River harbors"

(Synder, 1974; p. 65). This device was likely some form of a ladder dredge, but major dredging operations

out in the river and bay were not possible until the technological advances of the 1870s. There are 18 major

shoals or bars in the vicinity of the main shipping channel of the Delaware River and Bay. Historically,

mariners had to navigate through these shoals in a winding channel that was not improved until the last quarter

of the nineteenth century. Before permanent navigational improvements were implemented to the Delaware

Shipping channel in 1879, a sea-going vessel with a normal draft of 20 to 24 feet could ground in the channel

without the benefit of a full tide.

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The first major obstacle in the Delaware Channel to be removed was a rock reef known as "Schooner's Ledge."

It was located between Chester and Marcus Hook and "could be regarded as the most dangerous if not the

most serious obstruction in the river" (Synder, 1974; p. 67). Rock excavations at Schooner Ledge were started

in 1879. The rock face was drilled with a rack and pinion device and blasting charges were inserted into the

rock. After being exploded, the dispersed rock material was removed with a dipper dredge and most of the

material was placed behind Chester Island. Other major natural obstructions attended to during this period

included shoals at Petty Island and near Fort Mifflin. Spoil from these shoals was deposited on government

land at League Island and Fort Mifflin, respectively (Synder, 1974).

Another major navigational obstacle in the Delaware River that had to be removed at a slightly later period

was Smith and Windmill Island. Smith and Windmill Island likely formed from two shoals or mud banks that

appear on Holmes' map of 1865: one opposite Spruce and Pine Streets and the other lying below South Street.

They slowly developed, united and formed one island. In 1838, a channel was created through the island to

facilitate the crossing of ferries between Philadelphia and Camden. Increasingly larger ships using the port

facilities during the second half of the nineteenth century required greater pier space and a wider turning

radius. The continued growth of the port made the islands a hazard to effective navigation in the river. In

1887, a report was written that recommended the removal of the two islands, the extension of the wharves in

Philadelphia and the modification of the harbor lines (Port of Philadelphia, 1926). The islands were removed

in 1894 and much of the debris was used as fill for the expansion of the new Navy Yard at League Island in

South Philadelphia. Most of the initial dredge spoil removed from the Delaware River near Philadelphia was

used as fill around the city. In accordance with the provisions of the Ordinance of Councils, approved in April

1898, the material dredged by the city from the Delaware and Schuylkill Rivers, with the exception of the

rock from Schooner Ledge, was deposited on low ground adjacent to the rivers, within Philadelphia city limits.

As mentioned, a great portion of this material was placed on League Island Park at the southern end of Broad

Street. A portion of the rocky debris from Schooner Ledge was placed in front of the city as a support for the

piles of bulkheads and new piers constructed along Delaware Avenue. The rest of the rock was deposited in

back of Chester Island (Webster, 1905).

Finally, by 1885 Federal legislation was approved which authorized the permanent improvement of the

Delaware River. The previous dredging operations had only been sporadic, in specific areas, according to

necessity.

3.2.4.5 Chesapeake and Delaware Canal

The Chesapeake and Delaware Canal, connecting the Delaware River just above Reedy Island to the

Chesapeake Bay via the Elk River, was opened on October 14, 1829. Originally, the canal was 36 feet wide

at the bottom, 66 feet wide at the top, and ten feet deep. A series of locks were required to allow navigation

between the two waterways. Although the canal had little impact on shipping in lower Delaware Bay, it

forged a water link between Philadelphia and Baltimore. The advent of railroads throughout the region limited

the initial success of the canal. However, the Federal government took over control of the canal in 1919,

widened it, deepened it, and removed the locks, allowing sea level navigation by 1923. Several decades later

the canal was again enlarged to the present depth of 35 feet with a width of 450 feet and is ranked by the COE

as the busiest canal in the United States (Heite, 1988). Use of the canal did not have a direct impact on

shipping in the lower Delaware Bay until after the canal was reopened without locks. North bound ships

leaving and calling on Baltimore used the shorter canal route to reach the Atlantic Ocean via Delaware Bay

instead of traveling down Chesapeake Bay and passing around Cape Charles.

3.2.4.6 Twentieth Century Navigational Improvements

The U.S. Army Corps of Engineers (COE) has supervised all improvements to the Federal channel on the

Delaware, including the dredging, construction and maintenance of anchorages, dikes and harbors. A 30-

foot channel from Bombay Hook Point to Philadelphia was authorized by the River and Harbor Act of 1895.

The existing main shipping channel project was adopted in 1910 and modified in 1930, 1935, 1938, 1945,

1954 and 1958. The original 30-foot channel depth was revised twice during the twentieth century, first to 35

feet, then 40 feet and finally to 45 feet. The existing COE project also provides for six anchorages and the

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further construction of dikes and training works for the regulation and control of tidal flow. Presently, the

main shipping channel in the Delaware River is maintained at a minimum 45-foot depth from deep water in

the bay to Philadelphia. Near the mouth of the bay, the channel becomes naturally deeper than 45 feet. The

width of the channel is 1,000 feet from the mouth of the bay to approximately halfway up along Liston Range

where it narrows to 800 feet wide. From Liston Range the 800-foot wide channel is maintained up to

Philadelphia. The 40-foot channel from the Philadelphia Navy Base to the sea was completed in 1942. The

40-foot channel from the Navy Base to Allegheny Avenue, Philadelphia, was completed in 1962.

3.2.5 Shipwrecks and Salvage Operations in Delaware River/Bay

Several high profile salvage efforts of historic shipwrecks have been conducted in Delaware Bay over the last

century. Back in 1986, the wreck of the DeBraak was raised by salvers after reaching an agreement with the

State of Delaware. Salvage of the wreck, while not an archaeological project, produced a rich collection (well

over 2,000 items) of eighteenth century artifacts. Salvage of the historic vessel confirmed that a high degree

of preservation of historically significant material is possible from a dynamic, high-energy environment.

While the wreck rested in 70 feet of water, the remains were still exposed to the strong currents at the mouth

of the bay.

The Revolutionary War wreck of the Augusta was significant enough to raise the interest of certain eighteenth

century parties. Attempts were made to salvage items immediately after she sank; apparently, the Americans

succeeded in recovering two 24-pound guns from her. However, the Augusta carried a total of 64 guns on her

two decks. American soldiers also salvaged red coats, blue coats, waistcoats, jackets, bretchs, frocks, shirts,

stockings, shoes, shot gun barrels, and sundry doctor's instruments (Blewer, 1777).

The wreck remained on the Red Bank Shoal relatively undisturbed until 1867 when five men seeking to

recover gold attempted to raise the Augusta. James Powell, Joseph Moore, George Murphy, Gabriel Shapley,

and Charles Myers worked for over two years and eventually succeeded in raising the wreck and moving her

to Gloucester City, New Jersey. Sand and mud had to be dredged out of her before pontoons could be used

to float the hulk after the water was pumped out. A miscellaneous collection of items were collected from the

wreck; however, no gold was discovered. After mooring the vessel at the foot of Market Street in Gloucester

City and enclosing it with a stockade, the salvagers opened the wreck to the public. One of the three guns

taken from the wreck was also placed on exhibit but later sold for scrap. However, public interest lagged after

two years and the site fell into disrepair. A storm and unusually high tide destroyed the stockade and washed

the Augusta up on a beach. Later in the nineteenth century, a man who claimed to own that portion of the

shoreline made repeated efforts to set the wreck on fire in an attempt to clear his property. Portions of the

wreck still remain visible off the shoreline during unusually low tides.

Several submerged cultural resource sites in the Delaware River have been discovered, and subsequently

impacted by the cutter-head of dredges working to deepen the navigational channel. Two historic shipwreck

sites were encountered near Fort Mifflin during dredge operations on the Delaware River in the 1940s. The

first site was discovered while a new 34-foot channel off Hog Island, Philadelphia was being dug in January,

1941. The Atlantic Refining Company was building a large wharf on the island and received permission to

have the access channel cleared. The oil company built a dike on Hog Island that was eventually filled with

more than 100,000 square yards of dirt and fill. Three suction dredges were then floated out over the spots

where the channel was to be cleared. The bottom material was brought up through a cutter head and was sent

through a large pipeline to the shore disposal site (Philadelphia Bulletin, January 6, 1941).

Among the items discovered in the disposal area were various artifacts dating to the different periods. An

iron anchor, hand forged and weighing about 40 pounds, was found with one fluke missing and in a good state

of preservation. Some 280 pounds of copper sheathing, hand-made nails, a hand forged brass spike, an iron

cannon ball, a brass collar marked "USNYN, 1871," and a copper spoon were among the items recovered.

A second shipwreck site was discovered in 1948 on the New Jersey side of the river. Actually, two separate

sites were encountered by a dredge removing bottom sediment from the Mantua Creek Anchorage. The

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wrecks, one west of the mouth of Woodbury Creek and the other near the mouth of Mantua Creek, were

reported to be imbedded in six feet of mud under 30 feet of water. The wreck near Woodbury Creek was

estimated by divers to be 200 feet long. Divers reported that the cutter head had clipped off part of the deck,

revealing a vast number of "kegs of nails." Among the items that were drawn up from the bottom and survived

the mile and a half journey through a 27-inch dredge pipe to the disposal area on a farm near Thorofare, New

Jersey, included a harpoon, table knives, hand scythes, brass locks and keys, pewter plates, hoes, hinges, silver

shoe buckles, copper tea kettles and bottles (Philadelphia Inquirer, August 18, 1948). Material from the sites

were dated as early as 1700 and debates ensued as to whether the vessel(s) were English or Dutch.

3.2.6 Shoreline Development at the Repauno Site

The Repauno Chemical Company was incorporated in the Superior Court of Delaware on June 7, 1880 by

Lammot and William du Pont for the purposes of manufacturing the new high explosive dynamite. The

company built its works at a remote site on the Delaware River near Gibbstown, New Jersey, taking its name

from nearby Repauno Creek. The Repauno Chemical Company was merged with the Eastern Dynamite

Company in May 1904. Despite several disastrous explosions, the plant continued to thrive well into the

twentieth century throughout the interwar period and following World War II. Dynamite production was not

phased out until 1954 when the plant shifted its focus to produce commodity chemicals, primarily nitric acids

(Hagley Museum and Library, E.I. du Pont de Nemours & Company Repauno Works Historical Files).

In the 1890s, the Repauno Chemical Company applied to the Army Corps of Engineers to improve piers at

Thompson Point and Crab Point. By the early 1900s, the Crab Point wharf was the more substantial of the

two, a large timber-cribbed structure with a finger pier at its northwest corner extending northward some 150

feet into the Delaware River. This wharf became the plant’s main access to ocean-going craft that delivered

raw materials and received dynamite for shipment. In 1916, DuPont designed a new pier at Thompson Point

extending northward some 300 feet into the river. This pier was exclusively used to transfer rail cars to barges

via a transfer bridge at the end of the pier. In the early 1950s, a water intake system was installed at Thompson

Point at the Repauno site. Large steel sheet-pile cells were installed on the east side of the Thompson Point

pier to protect the offshore end of the water intake pipe system (Hagley Museum and Library, E.I. du Pont de

Nemours & Company, Historical Files).

A review of historical topographic maps and aerials photos indicates the lack of any docking structure at

Thompson Point by 1896 (Figure 3). The railroad car pier and transfer bridge that was constructed in 1916 at

Thompson Point is clearly visible in images from 1940, prior to World War II (Figures 4 & 6). A 1964

topographic map and a 1965 aerial photograph both indicate the presence of the water intake structure on the

upstream side of the Thompson Point pier and transfer bridge (Figures 5 & 7). Periodic dredging permits

were approved for the Repauno terminal to create a 35-foot deep ship berth between 1968 and 1983.

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4.0 SUBMERGED CULTURAL RESOURCES POTENTIAL

This chapter addresses in broad terms the potential for submerged cultural resources within the APE.

4.1 Criteria of Evaluation

The information generated by these investigations was considered in terms of the criteria for evaluation

outlined by the U.S. Department of the Interior, National Register Program. Nautical vessels and shipwreck

sites, generally excepting reconstructions and reproductions, are considered historic if they are eligible for

listing in the National Register of Historic Places at a local, regional, national, or international level of

significance. To be eligible for the National Register of Historic Places, a vessel or site “must be significant

in American history, architecture, archaeology, engineering, or culture, and possess integrity of location,

design, setting, materials, workmanship, feeling, and association.” To be considered significant the vessel

or site must meet one or more of four National Register criteria:

A. Association with events that have made a significant contribution to the

broad patterns of our history; or

B. Association with the lives of persons significant in our past; or

C. Embodiment of the distinctive characteristics of a type, period, or

method of construction, or that represent the work of a master, or that

possess high artistic values, or that represent a significant and

distinguishable entity whose components may lack individual

distinction; or

D. Sites that have yielded, or may be likely to yield, information important

in prehistory or history.

National Register of Historic Places Bulletin 20 clarifies the National Register review process with regard

to shipwrecks and other submerged cultural resources. Shipwrecks must meet at least one of the above

criteria and retain integrity of location, design, settings, materials, workmanship, feelings and association.

Determining the significance of a historic vessel depends on establishing whether the vessel is:

1. the sole, best, or a good representative of a specific vessel type; or

2. is associated with a significant designer or builder; or

3. was involved in important maritime trade, naval recreational,

government, or commercial activities.

Properties which qualify for the National Register, must have significance in one or more “Areas of

Significance” that are listed in National Register Bulletin 16A. Although 29 specific categories are listed,

only some are relevant to the submerged cultural resources in the Delaware River. Architecture, commerce,

engineering, industry, invention, maritime history and transportation are potentially applicable data

categories for the type of submerged cultural resources that may be expected in the Delaware River study

area.

Historic records indicate the presence of no documented shipwreck sites within this APE.

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4.2 Potential Shipwreck Types in Project Area

4.2.1 Potential Site Integrity

The effect of geomorphology and environment on shipwreck material can be quite different. In most cases

the remains of shipwrecks are not subjected to the processes of inundation. Shipwreck material deposited

in even the shallowest environment can settle rapidly into the bottom with its associated archaeological

record intact. The wreck of the DeBraak (1798), discovered at the mouth of Delaware Bay provides a

classic example. A good portion of the lower hull survived intact, along with an extensive associated

artifact assemblage. A second local example if site integrity comes from the wreck of the Roosevelt Inlet

wreck (ca. 1783). Located in 2005 at the mouth of Delaware Bay near Roosevelt Inlet, this site had had

very little surviving hull structure but contained a large volume of well-preserved cultural material from

the vessel’s cargo. These two examples at the mouth of Delaware Bay confirm that even in extremely high-

energy environments, archaeological evidence of historic wreck sites almost inevitably survives. Numerous

other archaeological investigations off the coasts of the states Maine, Massachusetts, New Jersey, Virginia,

Maryland, New York, North Carolina, Florida, and Texas, and the countries of England, Greece, Italy,

Israel and Turkey, offer examples that ship remains survived to preserve valuable archaeological data.

At many of the shipwreck sites sand and light mud similar to the bottom sediments in portions of the study

area provided an excellent environment for preservation. Given the level of maritime activity in Delaware

Bay and River, the extent of vessel losses in the vicinity of the study area, and the level of preservation at

shipwreck sites in other similar environments, it is probable that well-preserved shipwreck sites exist in the

vicinity of the study area.

4.2.2 Anticipated Property Types

In conjunction with exploration, naval activity, colonization and the expansion of coastal commerce,

Delaware Bay has become a likely repository for a wide range of submerged cultural resources. Strong

coastal storms, very swift tidal currents and numerous treacherous shoals throughout the waterway, all

combined with historically heavy vessel traffic, Delaware Bay and River has become the final resting place

for hundreds of vessels of all types.

Although there are no documented submerged historical sites within the defined boundaries of the survey

area, secondary and primary historical sources suggest that numerous vessels from a wide range of historical

eras may have been deposited in the general vicinity of these section of the Delaware. The British naval

ships Augusta and Merlin were both lost in October 1777 near the mouth of Mantua Creek, slightly

upstream from the project area. The potential does exist for the survey area to contain National Register

eligible submerged cultural resources.

A listing of shipwrecks and all types of ship losses in Delaware Bay and River was gathered during previous

underwater archaeological projects in Delaware Bay (Cox 2016). Drawing from a variety of primary and

secondary sources, the extensive shipwreck list, while far from comprehensive, nonetheless gives an

indication into the wide variety of shipwrecks that have been lost near the project area over the last 350

years. More than 300 shipwrecks and ship losses were documented in Delaware Bay and River since the

first reported loss in 1641.

Potential submerged cultural resource types in the project area may include a variety of material dating

from the first half of the 17th century through the Second World War. To discuss the types of vessels

potentially present, it is necessary to include vessels from all phases of the commercial and naval activity

in Delaware Bay and River. Wood-hulled ships, ranging from small fishing sloops, shallops, recreational

sailing and motor craft, and coastal schooners, to ship-rigged warships, have been lost in Delaware Bay and

River. Iron-hulled vessels, including paddle wheel steamboats and World War II-era merchant ships sunk

by German submarines at the mouth of Delaware Bay, have also been lost in the waterway. In addition to

potential ship losses, this portion of the river may contain evidence from a network of navigational

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obstructions (chevaux-de-frise) that were installed on the river bottom by colonial forces attempting to

thwart British ships from attacking Fort Mifflin and Philadelphia.

These potential submerged cultural resource types would lend historic insights into a wide range of

maritime related topics, including the contexts of naval activity, shipbuilding, regional shipping, and

industry patterns. A Bureau of Land Management “Summary and Analysis of Cultural Resource

Information on the Continental Shelf from the Bay of Fundy to Cape Hatteras,” (Bourque, et. al. 1979)

identifies the Delaware Coastal Zone as an area of “moderately heavy” predicted shipwreck density and

acknowledges the potential for inundated prehistoric archaeological sites.

5.0 SURVEY INVESTIGATIONS

A comprehensive remote sensing survey was conducted in the Delaware River on 06 December 2018. The

purpose the survey was to locate, identify, and preliminarily assess the significance of submerged cultural

resources that might be impacted by potential dredging operations needed for construction of a potential

new marine terminal at Thompson Point at the Repauno site. The underwater survey was designed to

generate sufficient magnetic and acoustic remote sensing data to identify anomalies caused by submerged

cultural resources. Analysis of the remote sensing data aimed to isolate targets of potential historical

significance that might require further investigation or avoidance.

5.1 Fieldwork Methods

Sonar and magnetic survey operations were conducted simultaneously from a 27-foot aluminum survey

vessel. Sonar data were gathered with a Marine Sonic HDS two channel digital side scan sonar unit with a

dual frequency 600/1200kHz side scan sensor. The sonar sensor was towed from the bow of the survey

vessel and operated at a range of 150 feet in either channel which created a swath of acoustic coverage 300

feet wide on each survey lane. Marine Sonic data acquisition software was used to merge the acoustic data

with real-time positioning data.

Magnetic data were collected with a Geometrics 881 cesium marine magnetometer, capable of +/- 1/10

gamma resolution. A ½ -second sampling rate by the magnetometer's towed sensor, coupled with a four-

knot vessel speed generated a magnetic sample every two feet. The magnetometer sensor was towed 50

feet aft of the survey vessel to provide optimal conditions for collecting magnetic data in the Delaware

River environment.

Hypack, a laptop PC-based software package in conjunction with a Differential Global Positioning System

(DGPS) onboard the survey vessel provided positioning accuracy for the survey area of +/- two (2) feet.

The computer converted positioning data from the DGPS to New Jersey State Plane Coordinates (U.S. feet)

in real time. These X,Y coordinates were used to guide the survey vessel precisely along predetermined

survey lines that had been established at 75-foot offsets, parallel with the shoreline. While surveying, vessel

positions were continually updated on the computer monitor to assist the vessel operator, and the processed

X,Y data were continually logged on computer disk for post-processing and plotting (Figure 8).

The survey horizontal reference is the New Jersey State Coordinate System, NAD83, in feet.

5.2 Data Products - Magnetometer

The magnetometer collected data on the ambient magnetic field strength by measuring the variation in

cesium electron energy states. As the sensor passed over objects containing ferrous metal, a fluctuation in

the earth’s magnetic field was recorded. The fluctuation was measured in gammas and is proportional to

the amount of ferrous metal contained in the sensed object.

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Magnetic data were edited for detailed analysis of all anomalies. During the editing process background

noise and diurnal change were removed and a magnetic contour map was created with five-gamma intervals

for the survey area. Magnetic data editing consisted of using Hypack’s single-beam editing program to

review raw data (of individual survey lines) and to delete any artificially induced noise or data spikes. Once

all survey lines for an area were edited, the edited data were converted to an XYZ file also using Hypack

(easting, and northing coordinates, and magnetometer data – measured in gammas). Next, the XYZ files

were imported into a Triangular Irregular Network (TIN) modeling program in Hypack) that was used to

contour the data in five-gamma intervals.

5.3 Data Products - Side Scan Sonar

The side scan sonar derives its information from reflected acoustic energy. Side looking sonar, which

transmits and receives swept high frequency bandwidth signals from transducers mounted on a sensor that

is towed from a survey vessel. Two sets of transducers mounted in an array along both sides of the towfish

generate the short duration acoustic pulses required for high resolution images. The pulses are emitted in

a thin, fan-shaped pattern that spreads downward to either side of the towfish in a plane perpendicular to its

path. As the fish is towed along the survey trackline this acoustic beam sequentially scans the bottom from

a point beneath the fish outward to each side of the trackline.

Acoustic energy reflected from any bottom discontinuities (exposed pipelines, rocks, or other obstructions)

is received by the set of transducers, amplified and transmitted to the survey vessel via a tow cable. The

digital output from state of the art units is essentially analogous to a high angle oblique photograph provided

detailed representations of bottom features and characteristics. Sonar allows display of positive relief

(features extending above the bottom) and negative relief (such as depressions) in either light or dark

opposing contrast modes on a video monitor. Examination of the images thus allows a determination of

significant features and objects present on the bottom within a survey area.

Raw sonar records were inspected for potential man-made features and obstructions present on the bottom

surface. Sonar data were saved in separate files for each survey lane. Individual acoustic data files were

initially examined using SeaScan™ acoustic data review software to identify any unnatural or man-made

features in the records. Once identified, acoustic features were described using visible length, width, and

height from the bottom surface. Acoustic targets are normally defined according to their spatial extent,

configuration, location and environmental context. As a last step, edited acoustic data were merged into a

geo-referenced sonar mosaic that was overlaid onto an aerial photograph of the survey area.

5.4 Evaluation of Remote Sensing Targets

Target signatures were evaluated using the National Register of Historic Places criteria as a basis for the

assessment. For example, although an historic object might produce a remote sensing target signature, it is

unlikely that a single object (such as a historic anchor or cannon ball) has the potential to meet the criteria

for nomination to the National Register of Historic Places.

Target assessment was based primarily on the nature and characteristics of the acoustic and magnetic

signatures. Shipwrecks – large or small – often have distinctive acoustic signatures, which are characterized

by geometrical features typically found only in a floating craft. Most geometrical features identified on the

bottom (in open water) are manmade objects. Often an acoustic signature will have an associated magnetic

signature. Generally, if the acoustic signature demonstrates geometric forms or intersecting lines with some

relief above the bottom surface and have a magnetic signature of any sort; it can be categorized as a

potentially significant target. Often, modern debris near docks, bridges, or an anchorage is easily identified

solely based on the characteristics of its acoustic signature. However, it is more common to find material

partially exposed. Frequently, these objects produce a record that obviously indicates a man-made object,

but the object is impossible to identify or date. Also in making an archaeological assessment of any sonar

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target, the history and modern use of the waterway must be taken into consideration. Naturally, historically

active areas tend to have greater potential for submerged cultural resources. The assessment process

prioritizes targets for further underwater archaeological investigations.

Magnetic target signatures alone are more difficult to assess. Without any supporting acoustic records, the

type of the bottom sediments and the water currents become more important to the assessment process. A

small, single-source magnetic signature has the least potential to be a significant cultural resource.

Although it might represent a single historic object, this type of signature has limited potential to meet

National Register criteria.

A more complex magnetic anomaly, represented by a broad monopolar or dipolar type signature, has a

greater potential to be a significant cultural resource, depending on bottom type. Shipwrecks that occur in

areas where the river bottom is firm similar to the Delaware River bottom at this survey location, with little

migrating sand, tend to remain exposed and are often visible on sonar records. A magnetic anomaly that is

identified in such an area and has no associated acoustic signature frequently can be discounted as being a

historic shipwreck. Most likely, such an anomaly is modern debris, such as wire rope, chain, or other

ferrous material.

Soft migrating sand or mud can bury large wrecks, leaving little or no indication of their presence on the

bottom surface (via sonar data). The types of magnetic signatures that a boat or ship might produce are

infinite, because of the large number of variables including location, position, chemical environment, other

metals, vessel type, cargo, sea state, etc. These variables are what determine the characteristics of every

magnetic target signature. Since shipwrecks occur in a dynamic environment, many of the variables are

subject to constant change. Thus, in making an assessment of a magnetic anomalies potential to represent

a significant cultural resource, investigators must be circumspect in their predictions.

Broad, multi-component signatures (again, depending on bottom characteristics and other factors) often

have the greatest potential to represent a shipwreck. On the other hand, high-intensity, multi-component,

magnetic signatures (without an accompanying acoustic signature) in areas of relatively high velocity

currents can be discounted as a historic resource. Eddies created by the high-velocity currents almost

always keep some portion of a wreck exposed. Generally, wire rope or some other low-profile ferrous

debris produces this type of signature in these circumstances. Many types of magnetic anomalies display

characteristics that are not easily interpreted. The only definitive method of determining the nature of the

object creating these anomalies is by physical examination.

Because the river bottom generally consists of hard, consolidated sands, most potentially significant

submerged cultural resources sites are expected to be evident on the side scan sonar records. Typically,

target locations with suspect cultural resource images on the sonar records coupled with associated and

appropriate magnetic signatures were considered to be high probability targets.

5.5 Remote Sensing Findings

After all the remote sensing data sets were processed, reviewed, and cross-referenced a total of 12 remote

sensing targets were identified were identified in the Thompson Point APE; three magnetic targets and nine

side scan sonar targets. Two of the magnetic anomalies listed had associated sonar signatures and were

also considered as combined magnetic-sonar targets. However, none of these 12 targets generated signature

characteristics that are considered suggestive of submerged cultural resources.

Magnetic data collected near the water intake structure at Thompson Point was heavily influenced by the

presence of steel and other ferrous material in the protective structure. A large magnetic disturbance was

detected around the entire perimeter of this near-shore structure. Otherwise, three large scale, high-intensity

linear magnetic anomalies were recorded within the Thompson Point survey area. A magnetic contour

26

map, contoured at five-gamma intervals, graphically displays the characteristics of the near-shore anomaly

associated with the water intake structure and the three offshore linear anomalies (Figures 9 & 12).

Two of these linear magnetic anomalies were characterized as combined magnetic-sonar targets since they

had associated sonar signatures. At both target locations (Targets M2/S3 and M3/S6), sonar records

confirmed the presence of small diameter pipe or wire rope at the two sites. Magnetic Target M1 had no

associated sonar target confirming that the source of the magnetic anomaly is buried. The signature

characteristics of this target are suggestive of a buried pipeline or utility crossing under the Delaware River.

The M1 target signature extended in a linear orientation across the entire northwestern corner of the survey

area.

None of the magnetic targets were considered to be suggestive of submerged cultural resources. More

detailed information on the magnetic targets is contained in the Table 1, below.

The evaluation of the sonar records confirmed the presence of nine sonar targets in the Thompson Point

survey area (Figures 10-12). As mentioned above, two of the sonar targets had associated magnetic

anomalies and were characterized as combined magnetic-sonar targets. All seven of the other sonar targets

are clusters of tree and timber debris. Two of these seven timber debris cluster targets are located adjacent

to the near-shore water intake structure that is located on the upstream side of the water intake structure.

The other five sonar targets with linear components appear to be collections of tree timbers that have

amassed in those locations on the otherwise featureless bottom surface across the survey area. The two

combined magnetic- sonar targets were identified as long stretches of wire rope/cable and or small diameter

dredge pipes and these features had corresponding magnetic signatures confirming the ferrous nature of the

targets (Targets M2/S3 and M3/S6). None of the side scan sonar targets are considered to be suggestive of

potential submerged cultural resources.

More detailed information on these sonar targets is contained in the Table 2, below.

In summary, inspection of all the remote sensing data from the Thompson Point APE failed to identify any

potentially significant anomalies considered to be suggestive of historically significant submerged cultural

resources. No additional underwater archaeological investigations are recommended.

27

Table 1. Magnetic Targets at Thompson Point APE (3 targets total; 2 were combined mag/sonar targets)

Notes: 1) Coordinates are expressed in the New Jersey State Plane System, NAD83, in feet

2) Large scale magnetic disturbance were recorded adjacent to the Water Intake Structure

3) No magnetic targets were recommended for additional underwater archaeological investigations

4) See Figures 9 & 12

Name X Y Sonar Notes

M1 264,206 370,339 No Coordinates are for the center of the anomaly within APE. This anomaly generated a 125 gamma, dipolar signature that extended across and area 690’ long by 90' wide. This linear anomaly was detected in all of the offshore lanes and the magnetic signature extended across entire the north west corner of APE. There is no associated sonar signature indicating the anomaly source is buried. This target signature is strongly suggestive of a buried pipeline or utility under the river bottom. No additional archaeological investigations are recommended.

M2 266,684 370,153 S3 Coordinates are for the center of the anomaly within APE. The anomaly generated a 130 gamma, dipolar signature that extended across an area 1,390’ long by 50 ' wide. This long linear anomaly was oriented parallel with the direction of the river. This magnetic signature is associated with Sonar Target #S3 – a suspect section of small diameter pipe or wire rope. No additional archaeological investigations are recommended.

M3 266,935 369,844 S6 Coordinates are for the center of the anomaly within APE. This anomaly generated a 155 gamma dipolar signature that extended across an area 140’ long by 80 ' wide. This long linear anomaly was oriented parallel with the direction of the river. This magnetic signature is associated with Sonar Target #S6 – a suspect section of small diameter pipe or wire rope. No additional archaeological investigations are recommended.

28

Table 2. Sonar Targets at Thompson Point APE (9 targets total; 2 combined mag/sonar targets)

Notes: No sonar targets were recommended for additional underwater archaeological investigations. See Figures 10-12.

Target # S1 Click Position

39° 50.82098' N 075° 18.12877' W (WGS84)

(X) 266913.77 (Y) 370201.86 (Projected

Coordinates)

Map Projection: NJ83F

Acoustic Source File: I:\Sonar

Data\Repauno\20181206\2018DEC06_0006.sds

Line Name: 2018DEC06_0006

Dimensions and attributes

Target Width: 23.12 US ft

Target Height: 1.39 US ft

Target Length: 49.10 US ft

Mag Anomaly: No

Description: Suspect timber debris pile.

29


39° 50.82405' N 075° 18.16390' W (WGS84)

(X) 266749.53 (Y) 370221.98 (Projected

Coordinates)









Mag Anomaly: No

Description: Suspect timber/tree debris pile

30


39° 50.81099' N 075° 18.19837' W (WGS84)

(X) 266587.52 (Y) 370144.11 (Projected

Coordinates)








Target Length:1350+ US ft

Mag Anomaly: Yes: M2

Description: Long linear feature exposed on bottom

surface. Coordinates represent the approximate center of

the feature that is laying parallel with the course of the

river. Feature is a long section of suspect small dredge

pipe or wire rope/cable – this feature is over 1,350’ long

31


39° 50.80339' N 075° 18.11055' W (WGS84)

(X) 266998.07 (Y) 370094.29 (Projected

Coordinates)









Mag Anomaly: No

Description: Oblong feature is lying flat on the bottom.

Suspect tree timbers. A section of the suspect pipe/wire

rope (Mag Target #03) is lying nearby.

32


39° 50.76535' N 075° 18.32522' W (WGS84)

(X) 265991.48 (Y) 369872.41 (Projected

Coordinates)









Mag Anomaly: No

Description: A cluster of linear debris

33


39° 50.76190' N 075° 18.12603' W (WGS84)

(X) 266923.37 (Y) 369843.08 (Projected

Coordinates)









Mag Anomaly: Yes; M3

Description: Linear feature is stretched out across the

bottom across an area over 110' long. Feature is

suggestive of a section of wire rope/cable.

34


39° 50.69613' N 075° 18.35288' W (WGS84)

(X) 265858.25 (Y) 369453.36 (Projected

Coordinates)









Mag Anomaly: No – but in direct proximity of water

intake structure

Description: Oblong feature and linear cluster on the

downstream side of water intake structure.

35


39° 50.72025' N 075° 18.31761' W (WGS84)

(X) 266024.59 (Y) 369598.31 (Projected

Coordinates)









Mag Anomaly: No

Description: Two linear features are lying flat on the

bottom surface; offshore of the water intake structure

36


39° 50.69096' N 075° 18.34090' W (WGS84)

(X) 265914.03 (Y) 369421.44 (Projected

Coordinates)









Mag Anomaly: No – but in direct proximity of water

intake structure

Description: A large debris cluster has accumulated on

the inside (onshore) face of the water intake structure.

37

6.0 SUMMARY AND RECOMMENDATIONS

Historic maritime activity in Delaware Bay and River dates from the first half of the seventeenth century

when Dutch, Swedish and English pioneers commenced trading and settlement in the Delaware Valley.

Since that time, the Delaware River and its tributaries have served as vital transportation arteries for the

subsequent colonization and socio-economic development of Delaware, New Jersey, and eastern

Pennsylvania. The entire region has a strong maritime tradition that dates back to the first half of the

seventeenth century when Dutch settlers first arrived in the Delaware Valley. Specifically, this portion of

the Delaware River was the scene of significant naval activities between colonial and English forces from

September – November, 1777.

As a result of the extensive historic maritime activity in Delaware Bay and River, a variety of underwater

resources that are associated with every phase of the region’s historical development may be anticipated in

the Delaware River Project area location offshore of Greenwich Township, Gloucester County, New Jersey.

The identification of underwater resources relating to this historic maritime activity is critically relevant to

the goals developed in New Jersey’s published statewide historic preservation planning documents.

In an effort to identify potentially significant historic submerged cultural resources that may be impacted

by proposed construction activities within the Thompson Point Project’s APE a comprehensive acoustic

and magnetic remote sensing survey was completed in December, 2018.

Remote sensing data were collected to identify and assess targets that may have an association with

submerged cultural resources. The comprehensive remote sensing survey of the Thompson Point APE

resulted in the identification of 12 remote sensing targets: three magnetic targets and nine sonar targets. Of

these twelve targets, two locations had associated magnetic and sonar target signatures and were classified

as combined magnetic-sonar targets.

The two combined targets had linear magnetic anomalies and associated sonar records that confirmed the

presence of small diameter pipe or wire rope at both locations (Targets M2/S3 and M3/S6). Magnetic

Target M1 generated signature characteristics that are suggestive of a buried pipeline or utility crossing

under the Delaware River. The M1 target signature extended in a linear orientation across the entire

northwestern corner of the survey area. None of the magnetic targets were considered to be suggestive of

submerged cultural resources.

The evaluation of the sonar records confirmed the presence of nine sonar targets in the Thompson Point

survey area. Seven of the sonar targets are clusters of linear and timber debris. The other two sonar targets

were the combined targets (Targets M2/S3 and M3/S6) described above. None of these nine side scan sonar

targets are considered to be suggestive of potential submerged cultural resources.

Inspection of that remote sensing data from the Thompson Point APE failed to identify any potentially

significant anomalies considered to be suggestive of historically significant submerged cultural resources.

No additional underwater archaeological investigations are recommended.

Notes:

All underwater survey field notes, magnetometer and sonar records, are stored at the

offices of Dolan Research, 30 Paper Mill Road, Newtown Square, Pennsylvania,

19073.

38

7.0 REFERENCES CONSULTED

Ames, David, Mary Callahan, Bernard Herman and Rebecca Siders

1989 “Delaware Comprehensive Historic Preservation Plan.” Center for Historic

Architecture and Engineering, College of Urban Affairs and Public Policy, University

of Delaware, Newark, Delaware.

Ames, David, Leslie Bashman and Rebecca Siders

1991 “Delaware’s Aids to Navigation: A Survey and National Register Eligibility

Evaluation.” University of Delaware Center for Archaeological Research.

Manuscript is on file at the Delaware State Historic Preservation Office. Dover,

Delaware.

Baker, William,

1976 “Commercial Shipping and Shipbuilding In the Delaware Valley.” Society of

Naval Architects and Marine Engineers, Spring Meeting Papers. Philadelphia,

Pennsylvania.

Blewer, Joseph

1777 "Invoice of Sundries from the Burnt Ships." Account Book of Commander

Joseph Blewer. Manuscript Collection, Historical Society of Pennsylvania,

Philadelphia, Pennsylvania.

Brandt, Francis

1929 The Majestic Delaware, The Nation’s Foremost Historic River. The Brandt and

Gummere Company, Philadelphia, Pennsylvania.

Brewington, M.V.,

1939 “Maritime Philadelphia, 1609-1836.” Pennsylvania Magazine of Biography

and History, Historical Society of Pennsylvania, Philadelphia, Pennsylvania.

Crowther, Simeon

1973 “The Shipbuilding Output of the Delaware Valley, 1722-1775.” Proceedings,

American Philosophical Society, Volume 117, Philadelphia, Pennsylvania.

Cox, J. Lee

1999 “Phase I Submerged Cultural Resources Investigation, Christina Riverwalk Project,

Construction Sections V, VI, VII, & II-B, Wilmington, Delaware.” Report was

submitted to Rummel, Klepper, & Kahl, LLP, Baltimore, Maryland.

2016 “Phase I Underwater Archaeological Investigations Silver Run Project Delaware

River, Salem County, NJ & New Castle County, DE.” Report was submitted to

Silver Run Electric, LLC, St. Louis, Missouri.

DeCunzo, LuAnn and Wade Catts

1990 “Management Plan for Delaware’s Historical Archaeological Resources.” University

of Delaware Center for Archaeological Research, Newark, Delaware.

39

DeCunzo, LuAnn and Barbara Hsiao Silber

1992 “Intensive Archaeological Survey and Historical Documentation of the Bombay Hook

Light Station and Keeper’s House, Kent County, Delaware (7K-A-130).”

Manuscript is on file at the Delaware State Historic Preservation Office, Dover,

Delaware.

Elliott, Richard

1970 The Saga of the Wilson Line, Last of the Steamboats. Tidewater Publishers,

Cambridge, Maryland.

Hagley Museum and Library

E.I. du Pont de Nemours & Company Repauno Works historical files

Hazard, Samuel, editor

1828 The Register of Pennsylvania. 16 Vols. (Vol. 1 – January to July 1828).


1850 Hazard’s Annuals of Pennsylvania 1609 - 1682. Hazard and Mitchell, Philadelphia,

Pennsylvania.

Hoffecker, Carol

1977 Delaware, A Bicentennial History. W.W. Norton & Company, New York, New

York.

Jaquett, Josephine

1961 Letter, on file, Salem County Historical Society, Salem County, NJ.

Jaquett, Josephine and Elmer VanName

1964 Place Names in Salem County, N.J. 2(4)4-5. Salem County Historical Society, Salem,

NJ. Electronic Resource, http://www.westjerseyhistory.org/books/salemnames/,

Accessed March 2016.

Koski-Karell, Daniel

1984 “Underwater Cultural Resources Background Study and Field Survey for the

Development of Wilmington Harbor, Delaware, South Disposal Area”. Report is on

file with the U.S. Army Corps of Engineers, Philadelphia District Library,


1985 “Underwater Cultural Resources Background Study and Field Survey for the

Development of Wilmington Harbor, Delaware, Extended Part of the South Disposal

Area”. Report is on file with the U.S. Army Corps of Engineers, Philadelphia District

Library, Philadelphia, Pennsylvania.

1995 “Historic Archaeological Context on the Maritime Theme with the Sub-Theme

Shipwrecks, Coastal Zone (1495-1940+/-). Volume I—Historic Context.” Delaware

Division of Historical and Cultural Affairs, Bureau of Archaeology and Historical

Preservation, Dover, Delaware.

40

Ocean Surveys, Inc.

2016 “Geophysical and Geotechnical Investigations, Proposed Silver Run Transmission

project, Delaware River Crossing, Lower Alloways Creek, NJ to Odessa, DE.” OSI

Report No. 6ES008; report submitted to Sliver Run Electric, St. Louis, MO.

Paul, Michael

1989 “Historic Context for Aids to Navigation in Delaware.” Manuscript is on file at the

Delaware State Historic Preservation Office. Dover, Delaware.

Philadelphia Daily Advertiser

1795 October 2nd Edition. Philadelphia, Pennsylvania.

Philadelphia Bulletin.

1941 "Delaware Dredge Digs Up Relics," (January 6, 1941). Philadelphia, Pennsylvania.

Philadelphia Inquirer.

1948 (August 18, 1948). Philadelphia, Pennsylvania.

Sebold, Kimberly and Leach, Sara.

1991 Historic Themes and Resources within the New Jersey Coastal Heritage Trail,

Southern New Jersey and the Delaware Bay: Cape May, Cumberland, and Salem

Counties. Department of the Interior, National Park Service, Washington D.C.

Tyler, David

1955 The Bay and River Delaware, A Pictorial History. Cornell Maritime Press,

Cambridge, Maryland.

1958 The American Clyde, A History of Iron and Steel Shipbuilding on the Delaware From

1840 to World War I. University of Delaware Press, Newark, Delaware.

U. S. Army Corps of Engineers

1879 Annual Report to the Chief of Engineers to the Secretary of War. “Plan of Ice Harbor

at New Castle, Delaware.” Government Printing Office, Washington, D.C.

1903 Report of the Chief of Engineers. U.S. Government Printing Office, Washington D.C.

1929 Report of the Chief of Engineers. (1) 346. U.S. Government Printing Office,

Washington D.C.

1962 Annual Report to the Chief of Engineers, U.S. Army. Washington, D.C.

“Water Resources Study, Metropolitan Christina River Basin, Plan of Study.” Report

is on file with the U.S. Army Corps of Engineers, Philadelphia District Library.


1997 Historic Properties Management Plan, Ice Harbors at New Castle, Delaware and

Marcus Hook, Pennsylvania. Report is on file with the U.S. Army Corps of

Engineers, Philadelphia District Library. Philadelphia, Pennsylvania.

Visit Salem New Jersey

41

2016 “Artificial Island.” Electronic Resource, http://visitsalemcountynj.com/salem-county-

history- project/towns-and-county-names/, accessed March 2016.

Weslager, Charles,

1961 Dutch Explorers, Traders and Settlers in the Delaware Valley, 1609-1664.


Weslager, Charles and Louise Heite

1988 “History of the Delaware Estuary.” In, The Delaware Estuary: Rediscovering

Forgotten Resource. University of Delaware Seagrant Program, Newark, Delaware.

Witty, Anne

1986 “The Oystering Fleet of Delaware Bay.” In, The Challenge of Folk Materials for New

Jersey Museums. Trenton, New Jersey.

42

FIGURES

43

Figure 1. Project Location Map Overlaid on NOAA Chart #12312

Notes: 1) Project Area is indicated in red

2) Background Grid = New Jersey State Plane Coordinates, NAD83, U.S. feet

10,000’

N

44

Figure 2. Project APE Overlaid on Aerial Photograph

Source: New Jersey NJGIN Information Warehouse

Thomson Point APE

N

45

Figure 3: 1896 Topographic Map of Thompson Point at Repauno Site. Map Courtesy of Historic Aerials.


46


Figure 6: 1940 Aerial of Thompson Point at Repauno Site. Map Courtesy of Historic Aerials.

47

Figure 7: 1965 Aerial of Thompson Point at Repauno Site. Map Courtesy of Historic Aerials.

48

Figure 8. Survey Track Plots

Notes: 1) Outline of Dredge Limits/Project Area is the irregular, roughly rectangular shape centered above the former ferry dock

2) Background Grid = New Jersey State Plane Coordinates, NAD83, U.S. feet

3) Lane Spacing = 75 feet

4) A prominent water intake structure and remnants of a former ferry dock are visible at this site

5) Shallow water/mud flats and numerous abandoned vertical piles prevented survey lanes closer to shoreline

2000’

N

49

Figure 9. Magnetic Contours

Notes: 1) Background Grid = New Jersey State Plane Coordinates, NAD83, U.S. feet

2) Outline of Dredge Limits/Project Area is the irregular, roughly rectangular shape (green line) centered above the former ferry dock

3) Contour Intervals = 5 gammas

4) Large background magnetic disturbance was recorded adjacent to water intake structure on the east (upstream) side at former pier (red & purple)

5) Three linear magnetic anomalies were identified. They are described in Table 1.

N

1000’

M1

M3

M2

50

Figure 10. Sonar Mosaic and Sonar Targets Overlaid on Aerial Photograph

Note: Locations of nine (9) sonar targets are depicted with red numbers. Information and details of all targets are contained in Table 1.

N

S1

S4

S2

S3

S5

S6 S7 S8

S9

51

Figure 11. Onshore View of Sonar Mosaic Overlaid on Aerial Photograph

N

52

Figure 12. Magnetic Contours Overlaid on Sonar Mosaic at APE

1000’

N

53

APPENDIX:

QUALIFICATIONS OF THE PRINCIPAL INVESTIGATOR

J. Lee Cox, Jr., owner of Dolan Research, Inc. served as the Principal Investigator. He directed the

underwater archaeological investigation. Mr. Cox received a MA from East Carolina University in

Maritime Research/Underwater Archaeology and a BA from Duke University in Archaeology. He meets

or exceeds the standards for a principal investigator in archaeology as set forth in the Secretary of the

Interior's Professional Qualifications Standards (36 CRF Part 61). He has been involved with over 150

different underwater archaeological projects over the last 32 years in 22 different states, Bermuda, Puerto

Rico, Trinidad and Tobago, and Canada. He has authored over 100 reports and published seven articles

and one book in conjunction with professional experience. He is a member of the Register of Professional

Archaeologists (RPA).


Ramboll

APPENDIX G PHASE IA HISTORICAL & ARCHAEOLOGICAL RESOURCE IMPACT SURVEY

Prepared for:

Ramboll Environ

Prepared by:

Patrick Harshbarger, M.A., M.P.A.James Lee, M.A., R.P.A.

may 2016

Phase Ia hIstorIcal and archaeologIcal survey

gIbbstown logIstIcs center

greenwIch townshIPgloucester county, new Jersey

i

This technical report describes the results of a Phase IA historical and archaeological survey undertaken by Hunter Research, Inc. for Ramboll Environ in connection with the proposed redevelopment of the Chemours Company FC, LLC Repauno property in Greenwich Township, Gloucester County, New Jersey. Archaeological and architectural survey work was conducted in anticipation of New Jersey Historic Preservation Office (NJHPO) review as part of New Jersey’s Land Use Regulation Program permitting requirements for project compliance with N.J.A.C. 7:7A.

The subject property is an approximately 376-acre parcel that was the site of the core operations of the former E.I. du Pont de Nemours & Company (DuPont) Repauno Works from circa 1880 to 2009. The property is currently undergoing environmental remediation prior to proposed redevelopment as the Gibbstown Logistics Center, a new Delaware River port facility and intermodal transportation center. The property is bounded on the north by the Delaware River, on the west by wetlands known as the Repaupo Meadows at the mouth of Repaupo Creek, on the south by a wooded tract approximately 2,000 feet north of the built-up area of Gibbstown, and on the east by undeveloped woodlands and wetlands on reclaimed industrial property.

Although several architectural resources in excess of 50 years in of age were identified, none of these properties area considered potentially eligible for this in the New Jersey or National Registers. Fieldwork and research also took into consideration whether there were any significant landscape features or viewsheds surrounding the project site that could be impacted by project activities. None were noted. No further architectural investigation is recommended. The proposed Gibbstown Logistic Center project is considered to have no potential to impact significant architectural resources.

Although a Native American archaeological site was previously documented within the project site at Thompson Point, this location and the property as a whole is assigned an overall low potential to yield significant Native American archaeological remains. This assessment is largely because of the extensive modifications made to the landscape over the last 130 years of industrial use and development. Thompson Point is also the location of a potential early historic site that may range in date from the late 17th through the19th century, however the historic archaeological potential of this location is also considered low for the same reasons.

One area that is considered to still hold archaeological potential is the Miller/Mullin Farm site located along C Line Road in the southeastern portion of the project site. This area should, if possible, be avoided during the future development of the project site. If avoidance is not possible further archaeological investigation and assessment of the site is recommended started at the Phase IB (identification) level.

management summary

iii

Table of ConTenTs

pageManagement Summary ......................................................................................................................................... iTable of Contents ................................................................................................................................................iiiList of Figures ...................................................................................................................................................... vList of Photographs ............................................................................................................................................viiAcknowledgments ............................................................................................................................................... ix 1. Introduction ..................................................................................................................................................1-1 A. Project Background and Scope-of-Work .............................................................................................1-1 B. Previous Research and Principal Sources of Information ...................................................................1-4

2. Geographical Setting ...................................................................................................................................2-1

3. Prehistoric Background ...............................................................................................................................3-1 A. Prehistoric Overview ...........................................................................................................................3-1 B. Project Site Prehistory ..........................................................................................................................3-2

4. Historical Background .................................................................................................................................4-1

5. Field Investigations ......................................................................................................................................5-1 A. Architectural Survey ............................................................................................................................5-1 B. Archaeological Survey .......................................................................................................................5-17

6. Conclusions and Recommendations ............................................................................................................6-1 A. Architectural Resources .......................................................................................................................6-1 B. Archaeological Resources ....................................................................................................................6-2

References ........................................................................................................................................................ R-1

AppendicesA. Resumes ......................................................................................................................................................A-1B. New Jersey Historic Preservation Office Bibliographic Abstract .............................................................. B-1C. Project Administrative Data ........................................................................................................................ C-1

v

page1.1. Location of the Project Site .......................................................................................................................1-21.2. Aerial Photograph of the Project Site ........................................................................................................1-3

2.1. Physiographic Map of New Jersey Showing the Location of the Project Site ........................................2-22.2. Aerial Photograph of the Project Site Showing the Soil Classifications .................................................2-32.3. Aerial Photograph of the Project Site Showing Land Use in 1842. .........................................................2-4

4.1. Faden, W., The Course of the Delaware River from Philadelphia to Chester, 1778 ................................4-24.2. Watson, W., A Map of the State of New Jersey, 1812 ...............................................................................4-44.3. U.S. Coast Survey. Map of Delaware River, Mantua Creek-Paulsboro-Fort Mifflin, 1842 .....................4-64.4. Stansbie, C., A Map of the Counties of Salem and Gloucester, 1849 .......................................................4-74.5. Beers, S.N., Map of the Vicinity of Philadelphia, 1861 ............................................................................4-84.6. Everts and Stewart, Combination Atlas Map of Salem and Gloucester Counties, 1876 ..........................4-94.7. Bacot, R.C., Shore Front of the Delaware River, 1877 ...........................................................................4-104.8. Hopkins, G.M., Atlas of Philadelphia and Environs, 1877 .................................................................... 4-114.9. U.S. Geological Survey, Topographic Quadrangle, 1894 .......................................................................4-154.10. Wolf, G., Bird’s Eye View of Repauno, 1895 .......................................................................................4-164.11. U.S. Geological Survey, Topographic Quadrangle, 1940 ......................................................................4-22

5.1. Aerial Photograph of the Project Site Showing Areas Mentioned in Text. ..............................................5-2

lIst of fIgures

vii

page4.1. DuPont Repauno Works, circa 1900 .......................................................................................................4-134.2. DuPont Repauno Works, Acid Houses, 1900 ..........................................................................................4-144.3. DuPont Repauno Works, Acid Waste Travelling Tank, circa 1900 ........................................................4-184.4. DuPont Repauno Works, Explosion “C” Gelatin Mixing House #1. September 22, 1913 ....................4-194.5. DuPont Repauno Works, Crab Point Wharf, circa 1915 .........................................................................4-204.6. DuPont Repauno Works, Fence Line Looking Toward “C” Line Gate, 1916 ........................................4-214.7. DuPont Repauno Works, circa 1925 ......................................................................................................4-234.8. DuPont Repauno Works, circa 1940 .......................................................................................................4-244.9. DuPont Repauno Works, C Line, circa 1955 ..........................................................................................4-264.10. DuPont Repauno Works, Mullin House, circa 1955 .............................................................................4-274.11. DuPont Repauno Works, circa 1960 .....................................................................................................4-284.12. DuPont Repauno Works, circa 1960 ....................................................................................................4-294.13. DuPont Repauno Works, circa 1970 .....................................................................................................4-304.14. DuPont Repauno Works, circa 1980 .....................................................................................................4-31

5.1. Former acid-production area at the DuPont Repauno Works ...................................................................5-35.2. Concrete slab foundations of former warehouse area at the DuPont Repauno Works .............................5-45.3. Pump house at the DuPont Repauno Works ..............................................................................................5-55.4. Office near the entrance to the DuPont Repauno Works ..........................................................................5-65.5. Concrete-block shack on the Crab Point dock at the DuPont Repauno Works ........................................5-75.6. View looking west on B Line road at the DuPont Repauno Works ..........................................................5-85.7. Abandoned railroad spur at the DuPont Repauno Works ..........................................................................5-95.8. Crab Point dock at the DuPont Repauno Works .....................................................................................5-105.9. Detail of timber cribbing and pilings on the north side of the Crab Point dock..................................... 5-115.10. Finger pier and derrick at the Crab Point dock .....................................................................................5-125.11. Remnant of the Thompson Point dock ..................................................................................................5-135.12. Modern floodgate and dike east of Crab Point......................................................................................5-145.13. Dike and roadway to the west of Thompson Point ...............................................................................5-155.14. View toward Gibbstown from the entrance to the DuPont Repauno Works.........................................5-165.15. View looking north along the C Line Road...........................................................................................5-185.16. View looking north showing the eastern labs area at the north end of C Line Road ...........................5-205.17. View looking northwest showing concrete building pads and parking areas .......................................5-215.18. View looking west showing the overgrown former industrial area north of B Line Road ...................5-22 5.19. View looking southwest showing the industrial area north of B Line Road ........................................5-23 5.20. View looking southwest from Thompson Point towards the tidal meadows ........................................5-255.21. View looking south along A Line Road from Thompson Point ............................................................5-265.22. View looking north along A Line Road .................................................................................................5-275.23. View looking southwest towards the remnants of a storage bunker .....................................................5-28

lIst of PhotograPhs

ix

We offer our thanks to Thomas Newcomb, Senior Associate, Ramboll Environ, who managed this study and provided critical project-related information; and Owen Zalme, Associate, Ramboll Environ, who acted as our guide during the site visit and his knowledge of the site. Gregory Lattanzi, Assistant Curator, and James Moss, Registrar, kindly assisted us in our research at the New Jersey State Museum. We also received valuable assis-tance from the staffs of the New Jersey Historic Preservation Office and the New Jersey State Library.

With regard to Hunter Research staff involvement, the project was largely conducted by James Lee and J. Patrick Harshbarger. Background research and architectural evaluations were carried out by Patrick Harshbarger. The fieldwork was carried out by James Lee and Patrick Harshbarger. Report graphics and layout were completed by Evan Mydlowski under the direction of Patricia Madrigal. This report was written and edited by James Lee and Patrick Harshbarger.

Richard W. Hunter, Ph.D., RPAPrincipal/President

acKnowledgments

Chapter 1

IntroduCtIon

Page 1-1

a. ProJect bacKground and scoPe-of-worK

This technical report describes the results of a Phase IA historical and archaeological survey undertaken by Hunter Research, Inc. for Ramboll Environ in connection with the proposed redevelopment of the Chemours Company FC, LLC Repauno property in Greenwich Township, Gloucester County, New Jersey (Figures 1.1 and 1.2). Archaeological and architec-tural survey work was conducted in anticipation of New Jersey Historic Preservation Office (NJHPO) review as part of New Jersey’s Land Use Regulation Program permitting requirements for project compli-ance with N.J.A.C. 7:7A. All work was completed in accordance with the procedures and standards of the NJHPO and N.J.A.C. 7:4-8:7, “Standards for Combined Archaeological and Architectural Survey Reports.”

The subject property is an approximately 376-acre parcel that was the site of the core operations of the former E.I. du Pont de Nemours & Company (DuPont) Repauno Works from circa 1880 to 2009. The property is currently undergoing environmental remediation prior to proposed redevelopment as the Gibbstown Logistics Center, a new Delaware River port facility and intermodal transportation center. The property is bounded on the north by the Delaware River, on the west by wetlands known as the Repaupo Meadows at the mouth of Repaupo Creek, on the south by a wooded tract approximately 2,000 feet north of the built-up area of Gibbstown, and on the east by undeveloped woodlands and wetlands on reclaimed industrial property.

This Phase IA historical and archaeological inves-tigation was conducted to identify architectural and archaeological resources that are listed, eligible or potentially eligible for listing in the New Jersey Register of Historic Places or the National Register of Historic Places pursuant to N.J.A.C. 7:7E-3.36 and per land-use regulations of the New Jersey Department of Environmental Protection (NJDEP). If architectural or archaeological resources were identified, these were to be preliminarily evaluated in terms of their eligibility using the National Register Criteria for Evaluation (36 CFR 60.4). Potential project effects were also to be assessed. This investigation was tasked with identifying historic architectural resources more than 48 years in age that may be affected by the project. The principal archaeological concern relating to this project was the potential for Native American and historic period deposits surviving within the area of study.

Architectural and archaeological surveys were con-ducted in accordance with federal and state legislation and guidelines governing the evaluation of project impacts on cultural resources, notably Section 106 of the National Historic Preservation Act of 1966 and its implementing regulations (36 CFR 800), as well as three publications of the New Jersey Historic Preservation Office (NJHPO): “Guidelines for Preparing Cultural Resources Management Archaeological Reports Submitted to the Historic Preservation Office” (NJHPO 2000b); “Guidelines for Architectural Survey” (NJHPO 2000a); and “Guidelines for Phase I Archaeological Investigations: Identification of Archaeological Resources” (NJHPO 2004).

HUNTER RESEARCH, INC.

Page 1-2

Figure 1.1. Location of Gibbstown Logistics Center Project Site (outlined). Scale: 1 inch = 2,000 feet. Source: USGS 7.5’ Topographic Series, Bridgeport, NJ Quadrangle (1967, photorevised 1994) .

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Phase Ia hIstorIcal and archaeologIcal survey: gIbbstown logIstIcs center

Page 1-3

Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics,CNES/Airbus DS, USDA, USGS, AEX, Getmapping, Aerogrid, IGN,IGP, swisstopo, and the GIS User Community

LegendProject Area ±

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Figure 1.2. Aerial Photograph of Gibbstown Logistics Center Project Site and 150-foot Buffer (outlined).

4


Notice to proceed with this survey was received on March 4, 2016. Background research and fieldwork were performed thereafter in March and April 2016. Senior Hunter Research personnel who were respon-sible for undertaking these investigations met the federal standards for qualified professional archaeolo-gists, historians and architectural historians as speci-fied in 36 CFR 61. All documentation from this study will be stored at Hunter Research’s offices in Trenton, New Jersey until acceptance of the final report by the appropriate review agencies.

b. PrevIous research and PrIncIPal sources of InformatIon

Background research involved assembling informa-tion on the geology, soils, prehistory and history of the project site through consultation of primary and secondary sources, historic maps, and site file and sur-vey report information. In-house and online research materials and the site maps and files of the New Jersey Historic Preservation Office (NJHPO) and the New Jersey State Museum were reviewed, as were pub-lished secondary sources and historic maps at the New Jersey State Library. Primary research consisted of review of the DuPont corporate archives at the Hagley Museum and Library in Wilmington, Delaware. These records were consulted for photographs and records related to the history and physical development of the Repauno Works.

According to NJHPO National Register files, no listed historical or archaeological resources have been previously identified within the 376-acre Gibbstown Logistics Center project site or within a one-mile radi-us. One eligible prehistoric archaeological site (28-Gl-326), approximately 0.5-mile east of the Gibbstown Logistics Center project site, was subjected to a com-bined Phase I/II/III identification and data recovery in 2004 prior to excavation of a borrow pit on property owned by DuPont (URS Corporation 2004).

The 376-acre Gibbstown Logistics Center project site has been the subject of one prior cultural resources investigation. In 2008, a reconnaissance-level inves-tigation was undertaken in advance of environmental remediation activities. This investigation focused spe-cifically on three areas of concern (AOCs) and one solid waste management unit (SWMU) where there was known contamination associated with former industrial activities. These AOCs and SWMU were located in the northern section of the site and repre-sented about 43 acres or slightly over 11 percent of the project site’s total area. Borings and soil data indicated fill or disturbed soils in all AOCs and the SWMU. No archaeological or historical resources were iden-tified and no further work was recommended (URS Corporation 2008).

NJHPO survey and compliance files were reviewed for cultural resource studies within a one-mile radius of the Gibbstown Logistics Center project site. The oldest of these studies date to the late 1970s to mid-1980s and none identify or raise expectations for sig-nificant cultural resources associated with the project site.

In 1979, the U.S. Army Corps of Engineers undertook an archaeological sensitivity analysis for the lower Delaware River Valley placing the project site within an area of low sensitivity (Fitting et. al. 1979).

In 1981, an NJDEP Green Acres riverfront park plan-ning study evaluated a tract of land at the mouth of Repaupo Creek approximately one mile west of the project site. This study identified no archaeological resources in the park, although noting documentary evidence for the presence of prehistoric archaeologi-cal sites in the vicinity of Repaupo Creek and sug-gesting that the dike structures might have historic significance (Fittipaldi 1981).

5


In 1982, the U.S. Army Corps of Engineers, Philadelphia District sponsored a planning study of Monds Island, which lies offshore just to the north-west of the Gibbstown Logistics Center project site. This study, based on documentary evidence and pedestrian reconnaissance, resulted in an evaluation of no expectation for archaeological resources on the island (Mintz 1982).

In 1983, a U.S. Army Corps of Engineers cultural resources survey of the Delaware River in Camden and Gloucester counties focused specifically on ship-wrecks, piers and wharves along the shoreline. The wharves at the DuPont Repauno Works were not called out as potentially significant (Louis Berger & Associates, Inc. 1983).

In 1984, a Phase IA archaeological study for a sewage treatment plant site, approximately 2,500 feet south-east of the DuPont Repauno Works, recommended Phase IB testing based on the presence of prehistoric artifact finds further to the east and south sides of Gibbstown. It is undetermined if the Phase IB test-ing was conducted since no report was found in the NJHPO’s files (Landscape Studies, Inc. 1984).

More recent cultural resources investigations have refined understanding of properties adjacent to the Gibbstown Logistics Center project site and sug-gested some greater potential for significant cultural resources in the vicinity.

In 1996, a Phase I investigation for two bridge replacement projects on Tomlin Station Road less than one mile south of the project site identified no known prehistoric or historic archaeological resources. The investigation did suggest however that the vast system of dikes and ditches to the southwest of the former DuPont Repauno Works, known collectively as the Repaupo Meadows, were of probable significance based on their historic context as one of the “larg-est historical land reclamation efforts in the state”

with some of the dikes and ditches speculatively originating in the colonial period (Hunter Research 1996: 5-3). A comprehensive study and survey of the Repaupo Meadows was beyond the scope of work and no opinion of eligibility was issued by the NJHPO.

As mentioned previously, in 2004 a combined Phase I/II/III investigation identified an eligible prehistoric site (28-Gl-326) on DuPont property approximately 0.5 mile east of the Gibbstown Logistics Center project site. Site 28-Gl-326 indicated there was the potential for significant prehistoric archaeological sites, particularly in locally isolated areas near natu-ral streams where there had been little previous ground disturbance from industrial activities (URS Corporation 2004).

In 2004-05, Phase IA/IB investigations were under-taken on the Hercules site, a former industrial prop-erty approximately 0.5 mile to 1 mile east of the Gibbstown Logistics Center and immediately to the east of Site 28-Gl-326. The Hercules property, like the DuPont Repauno Works, historically produced explosives and chemicals. Phase IA investigation sug-gested high prehistoric archaeological potential in an undisturbed area of the site but Phase IB subsurface investigations consisting of over 300 shovel test pits encountered only five isolated prehistoric artifacts, consisting mostly of flakes. No further investigation was recommended (Richard Grubb & Associates, Inc. 2004, 2005).

As part of the current project Hunter Research under-took additional background research into agency files and secondary and historic cartographic materials. The principal sources of information concerning pre-historic archaeological resources in the project vicin-ity were the files of the New Jersey State Museum and reports from other cultural resource studies. For contextual background on Native American sites in the lower Delaware Valley, several standard texts were consulted (e.g., Skinner and Schrabish 1913;

6


Cross 1941; Kraft 1986, 2001; Custer 1989, 1996; Mounier 2003). A number of secondary sources on the history of Greenwich Township and Gloucester County were consulted for contextual information (Gordon 1834; Cushing and Sheppard 1883; Simpson 1965; Stewart 1977), while the series of historic maps and 20th-century and 21st-century aerial photography available for the area has provided much valuable locational data (Faden 1778; Watson 1812; U.S. Coast Survey 1842; Stansbie et. al. 1849; Beers et. al. 1861; Everts and Stewart 1876; Bacot 1877; Hopkins 1877; U.S. Geological Survey 1894-1967; Nationwide Environmental Title Research 1894-2007). A gener-ous level of site-specific data regarding industrial development of the Repauno Works from the 1880s to the 1980s was gathered from DuPont-related archival materials housed at the Hagley Museum and Library in Wilmington, Delaware (Eastern Dynamite Company 1889-1906; E.I. du Pont de Nemours & Company, 1895-1975, 1918-1986, 1930, 1955, 1969, 1981; Pratt 1970)

1

chapter 2

geograPhIcal settIng

In general, the project site lies within the inner low-land subprovince of the Coastal Plain physiographic province.(Figure 2.1) The inner lowland is, for the most part, underlain by gently southeastward-dipping unconsolidated marine and fluvial deposits of late Cretaceous and Tertiary age. These deposits take the form of clays, silts, sands, and gravel of variable thickness and distribution, overlain in places by inter-glacial fluvial deposits of the Quarternary Period. In the vicinity of Gibbstown, the sands and gravels of the interglacial Cape May Formation are present to thick-nesses of up to 3 meters, masking the Late Cretaceous sands and clays of the Raritan Formation beneath. The latter deposits typically range between 45 and 90 meters in thickness (Kummel 1940; Markley 1962:70-71; Wolfe 1977:98-100, 207, 276-293).

Soils within the project site are characterized as either Udorthents consisting of dredged coarse material or Mannington-Nanticoke-Udorthents (NRCS 2016) (Figure 2.2). The Udorthents are the result of the constant filling and mixing soils in areas related to the construction and expansion of industrial opera-tions within the project site, predominantly in the northern end of the project site. The areas mapped as Mannington-Nanticoke-Udorthents have limited areas of natural soil stratigraphy, although most of these have also been filled and relocated. Generally these soils are very poorly drained and wet almost to the surface. These soils are concentrated in the wooded or brushy areas in the southern half of the project site. The built up areas of this property lie a few feet above mean sea level and area connected by roadways on similarly built-up berms, while the low lying areas in the center and on either side of the project site would historically have been tidal marsh. These have been diked and drained to create meadows. Although

the meadows have long been abandoned, the land remains substantially better drained than it was in its natural state. Modern tidal gates are present along the Delaware River at the northwest and northeast corners of the project site keeping the low areas from flooding more regularly.

The vegetation in the project vicinity is typical of that found in the vicinity of a brackish tidal marsh. The widened Sand Ditch lies to the west of the project site while Clonmell’s Creek is situated a few hundred feet past the eastern boundary of the project site. Much of what was once meadow land can today be best described as shrubby thicket intermingled with reed. Phragmites, or Reed grass, is the dominant plant species. Cattails are also quite common. (Robichaud and Buell 1983:123; Markley 1962: 13-14). Several stands of pines are present on the drier soils in the southern part of the project site amongst larger areas dominated by silver maples.

A United States Coast Survey map from 1842 (see below, Figure 4.3), which shows the uses of the various landforms within the project site, was geo-referenced onto a current aerial photograph (Figure 2.3). The resultant map illustrates that more than half of the project site was either tidal meadow, marsh or mud in the middle of the 19th century. Only the southern third of the project site and the area around Thompson’s Point were under cultivation at this time. Considering how much of the northern half of the project site is now above sea level and covered by building sites and roads, a substantial amount of fill appears to have been brought into the project site.


Page 2-2

Figure 2.1. Physiographic Map of New Jersey Showing the Location of the Project Site. Source: Wolfe 1977.


Page 2-3

Figure 2.2. Aerial Photograph of the Project Site Showing the Soil Classifications. Source: NRCS 2016.

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Feet00210080040020

MetersMap Scale: 1:13,800 if printed on A portrait (8.5" x 11") sheet.

MamuAv = Mannington-Nanticoke-Udorthents complex, 0 to 1 percent slopes, very frequently flooded; UddcB = Udorthents, dredged coarse materials, 0 to 8 percent slopes; UddrB = Udorthents, dredged materials-Urban land complex, 0 to 8 percent slopes slopes; USDOWB = Urban land-Downer complex, 0 to 5 percent slopes


Page 2-4

Figure 2.3. Aerial Photograph of the Project Site Showing Land Use in 1842.

Meadow

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1

a. PrehIstorIc overvIew

The first evidence of human activity in the Middle Atlantic region occurs during the PaleoIndian period, which is commonly dated to around 10,0008,000 B.C. and characterized by terminal Pleistocene and early Holocene environments. From the shoreline along the continental shelf to the interior highlands the region slowly warmed after the last glacial maximum to sup-port stands of spruce, pine and birch and species such as musk ox, mammoth, horse and caribou. In the early Holocene the project area would have been located at some distance from the shoreline of the Delaware River as relative sea levels were lower at that time.

The current model of PaleoIndian settlement involves small, extremely mobile groups subsisting mostly through hunting. Most stone tools found from the PaleoIndian period are associated with the processing of foods and other raw materials acquired through hunting. Clovis-type projectile points have been found in the coastal areas of Salem County (Kraft 2001: Figure 3.25). The tool kit typically contained fluted projectile points for the killing and butchering of animals, biface knives for butchering and for the manufacture of other non-stone tools, and flaked tools for various purposes, such as working bone, antler or hide (Kraft 1986a; 2001; Custer 1989).

Around 6,500 B.C., evolving Holocene environments continued to change with a gradual warming of the climate, while increasing precipitation was sufficient to support dense hemlock and oak forests. These environmental changes spurred a shift in human adap-tation strategies producing new settlementsubsistence patterns based around exploitation of new season-ally rich environments. This period, referred to as the

Archaic period, is marked archaeologically by the appearance of the bifurcated projectile point, which generally date no later than 6,000 to 5,500 B.C. Many Archaic period sites are categorized as macroband and microband base camps and are typically found in or close to areas of maximum habitat overlap such as interior freshwater swamps and river confluences. There is also a marked difference in the use of lithic resources in the Archaic period. The use of crypto-crystalline material declines noticeably as emphasis is placed instead on alternative lithic sources, such as rhyolite. Exploitation of rarelyoccurring rhyolite outcrops suggests changes in patterns of mobility and possibly of social organization. The Archaic period tool kit is more expansive and includes flaked stone artifacts and a range of ground stone tools, such as axes, gouges, grinding stones and plant processing tools (Custer 1989; 1996).

Further climatic changes, about 4,600 years B.P., produced the warmest and driest conditions of the current postglacial period, with oak and hickory emerging as the dominant tree species in the Middle Atlantic region. These climatic shifts roughly coincide with what is defined archaeologically in the Lower Delaware Valley and Delmarva peninsula as the Woodland I period (this corresponds approximately to what have traditionally been referred to as the Late Archaic, Early Woodland and Middle Woodland periods), dating to circa 3,000 B.C. to A.D. 1,000 (Custer 1989). The Woodland I period is exempli-fied by a greater degree of sedentism presumed to have been associated with larger stratified societies exploiting estuarine and riverine environments. The archaeological expression of this sedentism is most evident in large macroband base campsites estab-lished in the freshwater/saltwater interface zone and

chapter 3

PrehIstorIc bacKground

2


along the floodplains of major drainages. Evidence of long-distance trade/exchange networks involving exotic raw materials and finelyfinished artifacts is characteristic of this period, as is evidence of complex mortuary ceremonies, often in the form of cemeteries containing rich grave offerings. The appearance of cache pits and ceramic storage vessels coincides with new diagnostic lithic projectile point forms, such as large narrowbladed stemmed points, smaller stemmed points, broadspear types and triangles.

By about 2,000 years B.P., shorelines and landforms similar to those of today had emerged as warm and dry climatic conditions gave way to a cooler, modern climate with more moisture. The dominant oakhickory forest was also superseded by oak and chestnut veg-etation. By A.D. 1000 the archaeologicallydefined Woodland II period is recognizable (this corresponds approximately to what has traditionally been referred to as the Late Woodland period). The intensive trade and exchange network noted during the Woodland I Phase fades from the archaeological record, although increasing evidence of sedentism is manifested in the expanded use of storage facilities and more perma-nent house structures. Increased harvesting of plants reflects an intensification of food procurement, both of which are generally accepted as being brought about by population growth. Formal agricultural production also stems from this entrenchment of a sedentary settlement pattern and was maintained until European contact. Material culture of this period is typified by distinctive ceramic forms with more com-plex decorations and by small triangular projectile points reflective of bowandarrow technology (Custer 1989; Kraft 2001).

b. ProJect sIte PrehIstory

Examination of the site maps and files of the New Jersey State Museum and the New Jersey State Historic Preservation Office found evidence of only

one documented prehistoric site within the immediate confines of the project area. This site was identified in 1880 at Thompson’s Point when the plant was first constructed, the details of which are described in a later history of the site:

Indian Mounds Found

When construction work started at Repauno early in 1880 excavation for buildings uncovered numerous Indian burial mounds containing the skeletons of 25 or 30 Indian and the graves of perhaps 10 squaws. The stone implements and weapons found were turned over to Lammot DuPont, who was well versed in Indian lore. Mr. DuPont had advised the plant men that if they found a woman’s grave, they would easily tell it, as the squaws were buried in a sitting posture with a few articles like cooking utensils beside them

In an old house which was located near the wharf and had been built before the revolution, an old pot and several old English coins weree found (E.I. du Pont de Nemours & Company 1955:6).

Skinner and Scrabisch also report that human remains were recovered at Thompson’s Point stating, “A burial at Thompson’s Point (near the site of the Du Pont powder works) where many teeth and a jaw bone were dug up is reported by a Dr. George Laws, of Paulsboro” (Skinner and Schrabisch 1913:59). This site, 28-Gl-20, appears to have been a substan-tial prehistoric cemetery. The mix of flexed and extended burials may suggest that its use spanned a long period of time, perhaps from the Late Archaic into the Woodland period. Its position near the river, potentially set apart from occupation areas, is similar to other prehistoric burial grounds known in the Delaware Valley particularly at the Abbott Farm near Trenton (Cross 1956) and Minisink Island north of the Delaware Water Gap (Heye and Pepper 1915). It appears that the site was destroyed during the con-struction of the factory and considering the intensity of 20th-century development of this area of the project site it is considered very unlikely that any elements of this cemetery remain intact.

3


Approximately 13 prehistoric sites were identified within approximately one mile of the project area. The majority of the sites are located near a water course. The closest site, the Dupont Repauno prehistoric site (28-Gl-326) situated to the east near Clonmell Creek, was identified during a survey associated with the use of the area as a soil borrow pit. The site was char-acterized as a minimally stratified, multicomponent prehistoric site with diagnostic evidence ranging from the Early through Late Woodland period (circa 1,000 B.C. to A.D. 1,500) (URS 2004:1.6). The site yielded evidence of potentially two Late Woodland period structures, along with refuse/storage pits and posthole patterns. Limited amounts of 18th- and 19th-century historic artifacts were also recovered. The site was subjected to a Phase III archaeological data recovery and completely removed as part of the subsequent soil borrowing activities.

Sites 28-Gl-155, 28-Gl-156, 28-Gl-235, 28-Gl-256 and 28-Gl-37 are located along the banks of the Repaupo Creek, southwest and west of the project area. 28-Gl-155 and -156 are both part of the same large multi-component camp site affiliated with the Poplar Island and Otter Creek cultures. These sites range in date from the Mid-Late Archaic to the Early-Late Woodland. The specific cultural association of site 28-Gl-235 and 28-Gl-256 is unknown. Artifacts collected from these sites were limited to thermally altered rock and flakes. Site 28-Gl-37 has no informa-tion associated with its site form other than its location on the banks of the Repaupo creek near its confluence with the Delaware River.

Site 28-Gl-59 is located southeast of the project site, along the Nehansey Brook. It was identified during the survey of archaeological sites in New Jersey by Skinner and Schrabisch in the early part of this cen-tury (Skinner and Schrabisch 1913). Surface finds at this site consisted of flakes and fire-cracked rocks. No additional information is available about this site.

The following sites are located south of the project site, along the I-295 corridor on small branches of the Repauno Creek. Site 28-Gl-112 is a Late Archaic-Early Woodland period site identified during a survey along I-295 (Mounier 1982). Artifacts collected from this site include lithic debitage, an early stage lithic biface and thermally altered rock. Site 28-Gl-113 had lithics and fire cracked rock. 28-Gl-265, identified during a survey of interchange 16 of I-295, is a Late Woodland period site (Mounier 1994). Mounier col-lected pottery sherds of the Riggens variety, character-ized by the grit temper and fabric and cord impres-sions, and a fragment of a triangular biface as well as lithic debitage.

The remaining sites are located southeast of the proj-ect area on high ground within the tidal marsh, but are not associated with any particular watercourse. Site 28-Gl-234 was identified during the power line survey. Thermally altered rock and a quartz reduc-tion fragment were recovered from this site. 28-Gl-259, -261, and -262 were all identified during an archaeological survey around interchange 14 of I-295 (Mounier 1993). Sites 28-Gl-259 and 28-Gl-261 are Late Woodland period sites. Ceramic sherds were collected from both sites with lithic biface fragments being collected from site 28-Gl-261. Artifacts col-lected from site 28-Gl-262 included a quartz core fragment and a quartz reduction fragment as well as thermally altered rocks. No further information is available about this site.

Almost all of the prehistoric sites mentioned above are located on well-drained soils near freely flowing streams, particularly the Repauno Creek and its tribu-taries, which lie approximately a mile to the southwest and west. This may partially be a result of a collec-tion bias with open farmland being more accessible to collectors than a closed industrial site. The former presence of a potential Native American burial ground at Thompson’s Point does suggest the project site was used in some manner during the prehistoric period.

4


However, given the lack of an open stream flow-ing through the project site and the limited areas of well-drained soils, most of which have been built up over the last 130 years, the prehistoric archaeological potential of the site is considered low.

1

chapter 4

hIstorIcal bacKground

colonial Period

Gloucester County was officially formed in 1694, and Greenwich Township is the oldest township in the county, having been formed in 1695. European colonization of Greenwich Township, however, began more than four decades earlier making it among the oldest colonized areas in the lower Delaware Valley. The project site lies at the nexus of the principal area of Swedish settlement on the Delaware, which com-monly is considered to have taken place from 1638 to 1655. By 1654, Raccoon, a Swedish village, was in place at the present-day location of Swedesboro about five miles south of the project site. Another settle-ment, the town of New Stockholm, was located about six miles to the southwest at the mouth of Raccoon Creek, while across the Delaware but only about two miles to the north was the capital of New Sweden, New Gottenborg. Much closer was Repaupo, a village situated on Repaupo Creek less than two miles to the south of the project site (Hunter Research, Inc. 1996: 3-3).

Strong Swedish influences persisted in this area over several generations. The total population of New Sweden likely never exceeded 900 individuals, but the largest portion, numbering about 400, lived in what later became the southwestern portions of Gloucester County and northwestern portions of Salem County, New Jersey. When the Swedish naturalist and traveler Peter Kalm visited Repaupo in 1749, he described the town as, “a great village, whose farms lie all scattered. It was inhabited merely by Swedes, and not a single Englishman or people of any other nation lived in it” (Kalm 1937 (1770): 295). The Swedish influence in the area cannot be said to have dwindled until 1786 when the Swedish Lutheran churches were ceded over

to the Episcopalian Church and Swedish-language services were terminated (Pomfret 1956: 277, 280; Hunter Research, Inc. 1996: 3-3).

Evidence for Swedes settling within the boundaries of the project site can be found in the latter half of the 17th century, conforming to an overall pattern of Swedish colonization in the region. In 1679/80, Israel Helm, who had arrived in New Sweden as a boy in 1643, reportedly sold his primary house in present Upland, Pennsylvania, and moved across the Delaware to his plantation called “Helmstatt” located at the present Thompson Point in Gloucester County. He died at Helmstatt between June 17, 1701 and March 2, 1701/02 (Klett 1996: 90-91). Presumably, Helm’s plantation house was in the vicinity of the point somewhere near the northwest corner of the project site, lying on the higher ground to the east of the Repaupo Meadows.

Prior to the American Revolution, Isaac Thompson took over the plantation at Helmstatt and the point became known as Thompson Point (Lewis Publishing Company 1900: 585). William Faden’s map of 1778, The Course of the Delaware River from Philadelphia depicts Thompson Point as a wooded piece of land projecting north into the Delaware (Figure 4.1). From the vantage point of the river, the trees at Thompson Point likely would have stood out from the diked meadows that surrounded the mouths of the Repaupo and Clonmell creeks to its east and west.

hunter research, inc.

Page 4-2

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3


meadow banking

In 1749, Peter Kalm noted that the inhabitants in the vicinity of Repaupo “had in several places thrown up walls or dykes [sic] of earth near the river to prevent its overflowing the land which they made use of as meadows” (Kalm 1937 [1970]: 174). The meadows were used to grow hay and pasture livestock. Gates in the dikes allowed water to be drawn off or led into the meadows through ditches, depending on the farmers’ requirements. The ditches were also used to impound fish during the annual catches of migrating shad and sturgeon. The shoreline in the vicinity of the Gibbstown Logistics Center was reportedly the site of a large number of fishing shacks used by local fisher-men for their seasonal headquarters as late as 1880 (E.I. du Pont de Nemours & Company 1955: 6).

Beginning in the colonial period, New Jersey law-makers passed legislation that allowed the owners of meadows to join together in meadow-banking compa-nies to jointly administer and levy fees for the mainte-nance of dikes, ditches and gates. An early reference to the Repaupo Meadows is an act of 1774 enabling the owners to make improvements to drain the meadows. This act referred to the need to construct a large ditch, which likely represents the “Sand Ditch,” a prominent canal-like water feature draining the east side of the Repaupo Meadows just to the west of the Gibbstown Logistics Center project site. The course of the Sand Ditch was straightened and widened after 1876.

Much of the post-Revolution meadow banking was undertaken under the auspices of the Repaupo Meadow Company, which was incorporated in 1787 and reincorporated in 1831. At its greatest extent, the Repaupo Meadow was estimated to have covered about 3,300 acres (5.2 square miles), likely making it one of the largest managed meadows in the state. During the 20th century, new farming methods led to the decline of meadow banking, with many of the meadow companies dissolving or becoming moribund

during the Great Depression. The meadows returned to wetlands, often falling under the management of various local, state and federal agencies that took over upkeep and improvement of the dikes and gates to control flooding and protect natural resources.Since the early 1960s, the Gloucester County Soil Conservation District, the New Jersey Division of Fish and Game, the U.S. Soil Conservation Service (now the Natural Resources Conservation Service), the U.S. Army Corps of Engineers and large land owners like DuPont among others have pooled their resources to manage the Repaupo Meadows and improve the dikes and gates. In 1998, a bill was introduced in the New Jersey Senate to officially dissolve the Repaupo Meadow Company, giving over its remaining property to local townships and appropriating $2 million for sluice gate and dike repairs (Cushing and Sheppard 1883: 167; USDA Soil Conservation Service 1962; Sebold and Leach 1992: 57-65; Hunter Research, Inc. 1996: 3-5; New Jersey Senate Bill No. 765 1998; USDA Natural Resources Conservation Service 2004).

gibbstown and thompson Point

The Gibbstown Logistics Center project site is located to the north of the village of Gibbstown. The vil-lage formed in the early 19th century along Crown Point Road (Main Street/New Jersey Route 44), one of Gloucester County’s main roads leading from Westville to Gibbstown and southwestward to Salem County. The town took its name from a Mr. Gibbs, variously listed to be either Edward or Ethan, a blacksmith and landowner with property near where Democrat Road and Tomlin Station Road intersect Crown Point Road. Although the crossroads hamlet is reported to have been in existence by 1808, neither the Watson map of 1812 (Figure 4.2) nor Gordon’s Gazetteer of the State of New Jersey, published in 1834, suggest that the town had become prominent enough to be worthy of mention.


Page 4-4

Figure 4.2. Watson, William. A Map of the State of New Jersey (detail). 1812. Project site indicated (approxi-mately). Scale: 1 inch = 2.35 miles (approximately).

5


The name Gibbstown seems to have come into use by the 1840s since it appears on the Stansbie Map of the Counties of Salem and Gloucester, published in 1849. This and later maps of the 1860s and 1870s indicate a village of no more than a dozen dwellings. Gibbstown remained at about this size until the year 1880 when the Delaware Seashore Railroad (later West Jersey Seashore and Pennsylvania Reading Seashore) was laid through town and the Repaupo Chemical Company, associated with gunpowder maker E.I. du Pont de Nemours & Company of Wilmington, Delaware, established a dynamite factory just to the north of town on the project site. By 1886, Gibbstown had grown to 21 houses and 197 persons, with most of the men employed at the dynamite works. Growth continued and by 1944 there were several hundred buildings in the town. Much of the construction appears to have taken place during the 20th-century’s two world wars when explosives production ramped up at the DuPont Repauno Works (Simpson 1965: 20, 238; Daniel 1969: 11; Hunter Research, Inc. 1996: 3-3).

Until the latter decades of the 19th century, culti-vated fields, wood lots and meadows characterized the ground to the north of Gibbstown and east of the Repaupo Meadows. The U.S. Coast Survey map of 1842 (Figure 4.3) provides one of the earliest detailed cartographic depictions of the project site. It shows a road, later known as A Line Road, connect-ing Gibbstown and Thompson Point, where a pier extended a short distance into the Delaware River. The road passed through cultivated fields and wood lots, bounded west and northeast by meadows. An orchard was also located on the east side of the road near the point.

The U.S. Coast Survey map of 1842 and subsequent historical maps (Figures 4.4 to 4.8) are consistent in showing two areas of historic occupation within the boundaries of the proposed Gibbstown Logistics Center. The first area of occupation was a farmstead

at the northern end of a lane that corresponds with present C Line Road approximately 500 feet north of the main gate to the former DuPont Repauno Works. According to the historical maps, this property was occupied by H. Miller (1849), H.H. Miller (1861) and John S. Mullin (1876-77). The Hopkins Atlas of Philadelphia and Environs of 1877 illustrated the 328-acre Mullin farm encompassing the eastern and south-ern sections of the project site plus adjacent meadow lots and fields to the south and west. A photograph of the Mullin farmhouse (see Photograph 4.10), taken in the mid-1950s, shows a three-bay stone house with a hipped roof and a rear ell.

The second area of occupation was a farmstead and tavern a few hundred feet from the shoreline at Thompson Point. This location was near the northern end of a lane that corresponds with present A Line Road. The lane terminated at a pier that extended a short distance across the mud flat at the river’s edge. Presumably, this was a local transshipment point where farmers could send their produce by boat to Philadelphia and other nearby urban markets. Early in the 19th century William W. Wilson ran a tavern at Thompson Point. In 1826, William R. Wood peti-tioned the county for a license to take over operation of Wilson’s tavern (Stewart 1977: II: 67). Both the U.S. Coast Survey map of 1842 and the Stansbie map of 1849 indicate two buildings to either side of the road at the landing, suggesting one was the tavern and the other a farmhouse. Later maps of 1861 to 1877 do not show a building on the east side of the road, sug-gesting that the tavern may have ceased operations, but the building on the west side of the road, presum-ably a residence, was occupied by Samuel Salisbury. Salisbury’s 300-acre farm encompassed the northern and northwestern areas of the project site and adjacent areas of the Repaupo Meadows (Beers et. al. 1861, Everts and Stewart 1876; Bacot 1877; Hopkins 1877).


Page 4-6

Figure 4.3. U.S. Coast Survey. Map of the Delaware River, Mantua Creek-Paulsboro-Fort Mifflin. T Sheet # 0164 (detail). 1842. Project site indicated. Scale: 1 inch = 1,560 feet (approximately).


Page 4-7

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Page 4-11

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12


duPont repauno works

In 1880, Lammot and William du Pont, descendants of a well-known Delaware family that had founded a gunpowder (black powder) works outside Wilmington in 1803 (E.I. du Pont de Nemours & Company, aka DuPont), embarked on a new business venture to manufacture dynamite. Dynamite had been previ-ously made in the United States under license of Swedish chemist Alfred Nobel. In the mid-1860s, Nobel had discovered that mixing nitroglycerin with an absorbent material (termed dope) created a new form of explosive that could be more safely handled than nitroglycerine alone. Early attempts at dynamite manufacture in the United States, however, had fre-quently ended in disaster, including an explosion that destroyed the first Nobel-licensed factory at Little Ferry, New Jersey in 1870.

Given the risk involved in dynamite production, the du Ponts formed a joint stock company called the Repauno Chemical Company (du Pont liked the name Repauno better than Repaupo) and selected a factory site on the Delaware River about 13 miles northeast of Wilmington in Gloucester County, New Jersey. The location was relatively distant from population centers but with good transportation connections via the river and a spur to the newly constructed Delaware Seashore Railroad in Gibbstown. In late 1880, the company purchased the farms of Samuel Salisbury and John Mullin (or Mullen) comprising close to 700 acres. In later years adjacent properties would be acquired for expansion and to ensure buffer zones. These buffer areas continued to be leased to farmers until the late 1940s or 1950s. Ultimately, the property encompassed more than 1,800 acres, much of it large-ly undeveloped woods, fields and meadows fringing the main dynamite and chemical works. Some of these areas were also used to store explosives in widely spaced bunkers (E.I. du Pont de Nemours & Company 1918-1983; 1930).

Construction of the Repauno Works began in 1880 with the first buildings spaced out over several thou-sand feet along the old lane to Thompson Point. This line of buildings was termed the “A Line” and the wide gaps between the buildings were a precaution against an explosion in one building setting off a chain reaction in adjacent buildings. Reportedly, some 35 to 40 Native American graves were encountered at an unspecified location during construction (E.I. du Pont de Nemours & Company 1955: 6). The build-ings were mostly one story, timber construction of a somewhat temporary-looking nature, and often with earthen berms on one or more sides to protect workers and to direct explosions away from other operations. By 1881, the plant was producing upwards of 2,000 pounds of dynamite per day under the direct super-vision of Lammot du Pont, a trained chemist who was deeply involved in experiments to improve the manufacturing process. One of these experiments was an attempt to recover spent nitric acid that was going to waste and also polluting drainage ditches and kill-ing fish, drawing complaints from local residents. On March 29, 1884, the experiment went wrong setting off an explosion that killed du Pont and five other men (Pratt 1970: 8-17).

The loss of Lammot du Pont was a major blow to the Repauno Chemical Company and E.I. du Pont de Nemours & Company but the demand for dyna-mite was high and the Repauno Works recovered and continued to expand. In the early 1890s, the plant opened another manufacturing line, “B Line,” which ran perpendicular to A Line and parallel to the river between Thompson Point to the west and another less prominent point known as Crab Point to the east (Photograph 4.1). Situated on the north side of B Line adjacent to the river was a large complex for the manufacture of nitric acid, essential for the manufacture of dynamite (Photograph 4.2). Near the eastern end of the B Line were a series of lab buildings responsible for improving the production of dynamite. These labs became known as the Eastern Laboratory


Page 4-13

Photograph 4.1. DuPont Repauno Works, view looking east from in front of Laboratory Office (B Line). Circa 1900. Source: E.I. du Pont de Nemours & Company, Photograph Collection, Repauno Works.


Page 4-14

Photograph 4.2. DuPont Repauno Works, Acid Houses, view looking northeast. 1900. Source: E.I. du Pont de Nemours & Company, Photograph Collection, Repauno Works.


Page 4-15

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Page 4-16

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17


after the Eastern Dynamite Company acquired the Repauno Chemical Company in 1895. The USGS topographic map of 1894 (Figure 4.9) and the Wolf bird’s eye view of 1895 (Figure 4.10) illustrate how the plant was laid out parallel to A and B Lines. The nature of the manufacturing processes and the fear of explosions kept the initial operations spread out and decentralized. Rows of trees were planted along the lines to provide windbreaks and shade. Within the plant, product was moved using mule-drawn rail cars since steam locomotives introduced the risk of fire from hot cinders and sparks (Photograph 4.3). Even so, explosions were not infrequent and they created some awesome ground disturbing craters (Photograph 4.4) (Eastern Dynamite Company, 1889-1906; E.I. du Pont de Nemours & Company 1955: 7).

In the 1890s, the dynamite company applied to the Army Corps of Engineers to improve piers at Thompson Point and Crab Point. By the early 1900s, the Crab Point wharf was the more substantial of the two, a football size timber-cribbed structure with a finger pier at its northwest corner extending northward some 150 feet into the Delaware River (Photograph 4.5). This wharf became the plant’s main access to ocean-going craft that delivered raw materials and received dynamite for shipment. In 1916, DuPont designed a new pier at Thompson Point extending northward some 300 feet into the river. This pier was exclusively used to transfer rail cars to barges via a transfer bridge at the end of the pier (Eastern Dynamite Company, 1889-1906; E.I. du Pont de Nemours & Company, Historical Files, Repauno Works 1918).

In 1912, only two years before the outbreak of World War I, the Eastern Dynamite Company became wholly owned by E.I. du Pont de Nemours & Company (DuPont). During the war years, DuPont’s Repauno Works continued to manufacture dynamite but also expanded into ingredients for smokeless powder and other forms of high explosives for the military. A third

dynamite line, C Line, was opened in the mid-1910s. C Line was located in line with the old lane to the Mullin farm and continued northward from the old farmhouse to meet the western end of B Line near the Delaware River. DuPont also built a series of board-ing houses in Gibbstown to accommodate the influx of wartime workers. Security was heightened at the plant during the war due to concerns about saboteurs. This included the hiring of guards and the construc-tion of a barbed wire fences with elevated pathways for the guards who patrolled the plant’s perimeter (Photograph 4.6).

Following World War I, explosives manufacture at the Repauno Works slowed but DuPont chemists began looking at new methods to produce nitric acid through the oxidization of ammonia. During the 1920s, a series of technical breakthroughs resulted in more efficient processes and a significant expansion and improve-ment of Repauno’s acid production plant. Nitric acid is a base chemical with a wide range of uses in explo-sives, fertilizers, dyes and industrial processes. By the mid-1920s, the Repauno Works was beginning to take on more of the character of a modern chemical plant featuring a maze of tanks, towers and pipes at the northern end of the property. The A and C Lines how-ever continued to make dynamite and other explosives (Figure 4.11, Photograph 4.7). And in 1939, with war once again on the horizon, the Repauno Works accel-erated explosives production. Between May 1940 and August 1945, the works manufactured more than 4.5 billion pounds of military explosives. This massive effort included expansion of the production lines into the southern portion of the works between A and C Line roads. Lacking space for a linear arrangement, the buildings were spaced out around an oval track that can be made out in some aerial photographs of this period (Photograph 4.8). After the war, these facilities, now within dense woods, were among the first torn down and abandoned (Pratt 1970: 30-40; E.I. du Pont de Nemours & Company 1981: 9-12).


Page 4-18

Photograph 4.3. DuPont Repauno Works, Acid Waste Travelling Tank (horse-drawn intraplant tramway), view looking north with Delaware River in the background. Circa 1900. Source: E.I. du Pont de Nemours & Com-pany, Photograph Collection, Repauno Works.


Page 4-19

Phot

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Page 4-20

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Page 4-21

Phot

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Page 4-22

Figu

re 4

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Page 4-23

Phot

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Page 4-24

Phot

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.

25


Following World War II, DuPont made a strate-gic decision to phase out dynamite manufacture at Repauno although chemicals for use in explosive components such as blasting caps and fuses contin-ued to be produced until the 1970s. In 1954, C Line, the last of the dynamite lines, was closed and sub-sequently all of the buildings were burned to ensure destruction of any volatile materials (Photograph 4.9). The old Mullin farmhouse at the south end of the C Line was also demolished (Photograph 4.10). DuPont made significant new investments at Repauno to introduce processes for the production of benzene and dimethyl terephthalate (DMT, used in the production of polyesters), as well as continued expansion and improvement of the nitric acid and ammonia plants. These operations concentrated in the northern section of the project site between Crab and Thompson points to the north and south sides of B Line Road. As a result of these improvements, nearly all vestiges of the explosives buildings and structures from the 1880s to the mid-1950s were razed, and older acid-production operations modernized. In their place were construct-ed chemical units, storage tanks and warehouses of modern steel-frame or reinforced-concrete construc-tion on concrete slab foundations. These mid-20th-century buildings and structures significantly chang-ing the character of the DuPont site (Photographs 4.11 to 4.14) (Pratt 1970: 41-44; E.I. du Pont de Nemours & Company 1955: 16-17; 1981: 14-18, 55-56).

At the height of production in the mid-1960s, more than 2,000 people were employed at the Repauno Works but downsizing occurred rapidly in the 1970s when DuPont determined to retrench in the face of competition and process obsolescence. By 1976, the DMT units and the laboratory at Repauno had been closed, along with several other smaller product lines, reducing the workforce to about 500 employees. Pollution control requirements also cut into the plant’s profits requiring the construction of waste treatment facilities, but DuPont was proud of its efforts to neu-tralize the impact of waste chemicals on water qual-

ity and most of the property surrounding the plant’s production area became managed marsh or woodland. Production of nitric and sulfuric acid continued, how-ever, along with sodium nitrite and other smaller prod-uct lines including nitrobenzene, aniline, pyromellitic anhydride (PMDA) and industrial diamonds. A huge underground tank was installed just east of Thompson Point as a storage terminal for anhydrous ammonia. The choice of an underground tank was driven in large part by the need to eliminate aboveground tanks that posed greater safety risks (E.I. du Pont de Nemours & Company 1981: 19-21, 55-58, 63-65).

Efforts to revitalize the Repauno Works could only go so far. In 1990, DuPont entered into an agreement with the New Jersey Department of Environmental Protection to conduct investigations and remediate 12 solid waste management unit (SWMUs) and 11 areas of concern (AOCs). In 1998, the sodium nitrate and sulfuric acid operations were purchased from DuPont by Repauno Products LLC. By 2009, industrial pro-duction was winding down at the site when DuPont announced the Repauno Works would be permanently closed. Since 2009, most of the plant’s buildings have been razed, leaving less than a handful of standing structures including an office building, elevated water tank and a small pump house at the underground ammonia tank. In 2015, Chemours Company was formed from DuPont taking over the Repauno Works site and other former DuPont properties.


Page 4-26

Phot

ogra

ph 4

.9. D

uPon

t Rep

auno

Wor

ks, C

Lin

e. C

irca

1955

. Thi

s vi

ew o

f the

C L

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was

take

n sh

ortly

bef

ore

dem

oliti

on.

Dur

ing

the

mid

-195

0s, t

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con

verte

d fr

om e

xplo

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s to

che

mic

al m

anuf

actu

ring.

Sou

rce:

E.I.

du

Pont

de

Nem

ours

&

Com

pany

, Pho

togr

aph

Col

lect

ion,

Rep

auno

Wor

ks.


Page 4-27

Photograph 4.10. DuPont Repauno Works, Mullin House. Circa 1955. DuPont apparently retained this farm house for use as on-site housing from 1880 until the mid-1950s. It was located just to the west side of C Line Road. This photograph was taken shortly before the house was demolished. Source: E.I. du Pont de Nemours & Company, Photograph Collection, Repauno Works.


Page 4-28

Phot

ogra

ph 4

.11.

DuP

ont R

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Page 4-29

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Page 4-30

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Page 4-31

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1

a. archItectural survey

The reconnaissance-level architectural investigation focused on identifying any buildings, structures or landscapes of potential historical significance over 48 years old within or visible from the project site. Field data were verified against historic maps and aerial photographs gathered during the background research task (see above, Chapter 4). Survey was conducted through a combination of windshield and pedestrian survey and proceeded systematically from the north to the south sides the site.

The vast majority of standing structures at the for-mer DuPont Repauno Works have been razed. Aerial photographs indicate that the plant has been system-atically dismantled starting about 2009 (Figure 5.1). Architectural survey identified no major surviving factory buildings or structures. Remnants consist mostly of concrete slab foundations (Photographs 5.1 and 5.2).

Of the dozens of industrial buildings and structures that once existed on the site only three minor build-ings were identified as standing in April 2016. The first of the buildings is a flat-roof, one-story, corrugat-ed-metal-sided pump house on a concrete slab foun-dation on the east side of A Line Road approximately 100 feet south of the Delaware River (Photograph 5.3).This utilitarian building is associated with an underground ammonia storage tank that remains in use. Aerial photographs suggest the pump house dates to the mid-1950s, although a wing that once extended off of the southwest corner appears to have been removed prior to the 1990s. The second of the build-ings is a flat-roof, one-story, three-bay, brick office building on the west side of C Line Road at the plant’s

main entrance (Photograph 5.4). This office was built circa 1954-55. It is a modest example of post-WWII minimalist design with simple running-bond brick façade and plate-glass doors and windows. The third of the buildings is a flat-roof, one-story, two-bay, concrete-block shack located on the Crab Point dock (Photograph 5.5).

Perhaps the most prominent landscape feature that survives of the DuPont Repauno Works is the trans-portation pattern consisting of a railroad spur and three roads, historically known as A Line, B Line and C Line roads, forming a roughly triangular plan. From the 1880s to the mid-1950s when explosive manufacture stopped at the DuPont plant, the manu-facture of dynamite and high explosives occurred mostly within buildings in production “lines” aligned to narrow-gauge railways that moved product from process to process along the line. This was a tradi-tional arrangement in explosives plants where the buildings were spaced apart along the line to prevent fires or explosions in one structure from setting off a chain reaction in neighboring structures. Today, all evidence of the A, B, and C lines is gone except for the pattern of roads that continues to parallel the old explosives lines that were discontinued in the mid-1950s. The later motor roads are asphalt-paved, two-lanes wide with compacted dirt shoulders (Photograph 5.6). The DuPont plant was also served by a standard-gauge railroad spur of the West Jersey and Seashore Railroad’s Pennsgrove Branch. This spur ran west of A Line Road from the 1880s to the mid-1950s but was then shifted to the east side of the road where evidence of it can still be seen in the form of abandoned tracks and ties (Photograph 5.7).

chapter 5

fIeld InvestIgatIons


Page 5-2

Figure 5.1. Aerial Photograph of the Project Site Showing Areas Mentioned in Text.


LegendProject Area ±

0 750 1,500 2,250 3,000375

Feet

B Line Road

A Line Road

C Line R

oad

Rapauno Avenue

Clonmell Creek

Sand Ditch

Deleware River

ThompsonPoint

CrabPoint

Miller/Mullin Farm Site


Page 5-3

Photograph 5.1. View looking west at site of former acid-production area at the DuPont Repauno Works. Concrete slab foundations are all that remain (Photographer: Patrick Harshbarger, April 2016) [HRI Neg. #16009/D1:29].


Page 5-4

Photograph 5.2. View looking north at concrete slab foundations of former warehouse area at the DuPont Repauno Works (Photographer: Patrick Harshbarger, April 2016) [HRI Neg. #16009/D1:19].


Page 5-5

Photograph 5.3. View looking southwest at pump house at the DuPont Repauno Works (Photographer: Patrick Harshbarger, April 2016) [HRI Neg. #16009/D1:36].


Page 5-6

Photograph 5.4. View looking north at office near the entrance to the DuPont Repauno Works (Photog-rapher: Patrick Harshbarger, April 2016) [HRI Neg. #16009/D1:61].


Page 5-7

Photograph 5.5. View looking south at concrete-block shack on the Crab Point dock at the DuPont Repauno Works (Photographer: Patrick Harshbarger, April 2016) [HRI Neg. #16009/D1:06].


Page 5-8

Photograph 5.6. View looking west on B Line road at the DuPont Repauno Works (Photographer: Pat-rick Harshbarger, April 2016) [HRI Neg. #16009/D1:23].


Page 5-9

Photograph 5.7. Abandoned railroad spur at the DuPont Repauno Works. View looking north near the south end of A Line Road before the spur shifts to the east side of the road (Photographer: Patrick Harshbarger, April 2016) [HRI Neg. #16009/D1:42].


Page 5-10

Photograph 5.8. View looking northwest at the Crab Point dock at the DuPont Repauno Works (Pho-tographer: Patrick Harshbarger, April 2016) [HRI Neg. #16009/D1:09].


Page 5-11

Photograph 5.9. Detail of timber cribbing and pilings on the north side of the Crab Point dock at the DuPont Repauno Works. Note the erosion that has washed away the fill within the cribbing, also the later concrete tie off for ship’s rope. View looking northwest (Photographer: Patrick Harshbarger, April 2016) [HRI Neg. #16009/D1:04].


Page 5-12

Photograph 5.10. View looking north at the finger pier and liquid products pump at the Crab Point dock at the DuPont Repauno Works (Photographer: Patrick Harshbarger, April 2016) [HRI Neg. #16009/D1:03].


Page 5-13

Photograph 5.11. View looking northeast at the landward rock-fill remnant of the Thompson Point dock. Remnant piles and dolphins visible in the background (Photographer: Patrick Harshbarger, April 2016) [HRI Neg. #16009/D1:38].


Page 5-14

Photograph 5.12. View looking northeast at the modern floodgate and dike east of Crab Point (Photog-rapher: Patrick Harshbarger, April 2016) [HRI Neg. #16009/D1:11].


Page 5-15

Photograph 5.13. View looking southwest at dike and roadway to the west of Thompson Point (Pho-tographer: Patrick Harshbarger, April 2016) [HRI Neg. #16009/D1:39].


Page 5-16

Photograph 5.14. View looking south from south of the DuPont Repauno Works entrance along Re-pauno Avenue toward Gibbstown (Photographer: Patrick Harshbarger, April 2016) [HRI Neg. #16009/D1:58].

17


The DuPont Repauno Works was also served by two marine docks. Remnants of those docks were observed during the architectural survey. The east-ernmost dock, known as Crab Point, is approximately 450 feet east-to-west (parallel with the shore) and 300 feet north-to-south (perpendicular to the shore as measured along its east side). The dock is com-posed of timber sheet piling and cribs with rock fill (Photographs 5.8 and 5.9). There is a single 170-foot-long finger pier at the northwest corner of the dock, which leads out to a timber walkway and three steel sheet pile dolphins (Photograph 5.10). A tower on the pier supports a swing-arm hose derrick for on or off-loading liquid product from tanker ships. This derrick is estimated by aerial photography to date to the late 1960s. DuPont Company records and maps suggest that sub-structural timber elements of the dock could date to the 1890s. The plan (shape) of the dock has not changed significantly since the late-19th century although more modern materials have been used for repairs and strengthening including concrete and metal sheet piling. The westernmost dock, known as Thompson’s Point, exists only as a remnant of rock fill at the shoreline and isolated timber pilings in the river (Photograph 5.11). According to plans produced by DuPont in 1916, the dock consisted of a 270-foot-long, timber-pile finger pier that carried a railroad track to a car float bridge, which has not survived intact.

No historic landscapes, views or buildings were observed within the immediate setting or along the perimeter of the project site. Most views are dominat-ed by wooded tracts (east, west and south), wetlands (west) or the Delaware River (north). Particular atten-tion was paid to looking for evidence of any historic dike, gate or ditch structures that might be associated with pre-industrial meadows. Floodgates, like the one just east of Crab Point (Photograph 5.12), were observed to have a modern character with welded

steel construction. Dikes also had a modern character with rip-rap protection with roadways wide enough for heavy modern vehicles (Photograph 5.13).

Historically, the DuPont plant maintained a buffer between the industrial sector and neighboring proper-ties due to concerns for security and the risks of explo-sions explaining the lack of development around the periphery of the plant. The southern entrance to the plant at C Line Road is approximately 700 feet north of the developed part of Gibbstown. Visible in the distance from the entrance is a streetscape of late 19th to early 20th century buildings along Gibbstown’s Repauno Avenue (Photograph 5.14).

b. archaeologIcal survey

A one-day field visit was made to the project site on April 6, 2106 during which a combination pedestrian and windshield survey was conducted. The project site is a highly modified industrial landscape composed of 376 acres situated on the right bank of the Delaware River directly north of the town of Gibbstown. Prior to the development of the Dupont Repauno Works, the area consisted of an agriculturally modified landscape of upland cultivated fields and low bank and ditch meadows and tidal marshes. Currently the project site is a combination of relatively wooded areas, tidal marshlands, substantial areas of made ground, road-ways parking lots and rail alignments.

The entrance to the Gibbstown project site is located at its southeastern end where a lawn and unpaved parking lot surround a small early-20th-century office building. After driving north on C Line Road (the northern end of Repauno Avenue) through the main gate the project area becomes increasingly wooded on either side of the road, which appears to be built on a slight berm (Photograph 5.15). A fringe of grass extends approximately 20 feet to each side of the road to the edge of woods dominated by pine trees


Page 5-18

Photograph 5.15. View looking north along the C Line Road (Photographer: Patrick Harshbarger, April 2016) [HRI Neg. #16009/D1:51].

19


with some oaks. A powerline corridor parallels C Line Road to the west. A Line Road branches off to the west-northwest through this wooded area. Just north of this road, approximately 500 feet north of the main gate, a small unpaved lane is visible entering the woods to the west. This appears to be the lane associated with the Miller/Mullin farm mentioned in Chapter 4 (Figure 5.1). No surface evidence of this historic site is currently visible other than the lane that curves through the woods at this location. To the north of this site the woods become increasingly wet with surface water visible amongst the trees, which are transitioning from pines to more wet-resistant varieties such as swamp maples. To the east of C Line Road the project site boundary extends another approximately 50 feet with an additional 150 feet of buffer to the east of that. The woods on this side of the road also transitions from drier soils and associated tree species to increasing wet soils as one progresses north towards the Delaware River. Approximately 2,500 feet north of the main entrance gate a small electrical substation is present east of C Line Road. This substation, which was built circa 1963 judging from historic aerial photographs, is situated on a sandy fill in an otherwise marshy area (NETR 2016). Across C Line Road from this substation area a series of filled in and modified marshy areas, former settling ponds and waste piles, one of which is the subject of ongoing soil remediation activities. Further to the east is an area of ponds, wetlands and water channels that were periodically inundated prior to the construction of the Dupont Repauno Works. Judging from aerial photo-graphs these areas were also highly modified during the 20th century.

At the north of C Line Road are the remnants of parking lots and concrete foundations for the eastern lab complex associated with the Dupont Repauno Works from the second quarter of the 20th-century (Photograph 5.16). Historic maps and aerial pho-tographs indicated that these features were built on soils brought to the site in the early 20th century,

potentially as dredge spoil from the nearby Delaware River. North of this area, in the northwest corner of the project site, are the Crab Point docks described above as part of the historic architectural survey. A dike extends from this dock area to the east along the Delaware River to a modern tide gate just outside of the project site boundaries.

The B Line Road extends roughly west to southwest from the northern end of the C Line Road through an area that was formerly the heavily industrialized center of the DuPont Repauno Works. Numerous con-crete pad foundations area visible on either site of the road along with the bases of large storage tanks, drive-ways, parking lots and rail spurs (Photographs 5.17, 5.18, 5.19). None of these buildings remain standing and most of this area is overgrown. A water tower is still standing just south of the road at its western end. To the north the bank along the Delaware River has been armored with stone and a gravel drive is located just to the south of this. Development extends south of B Line Road until it hits the wetlands. Aerial photographs from the 1930s onward show extensive earthmoving and construction activities in this area, which suggest that there little to no chance of pre-1880 archaeology surviving.

At its western end B Line Road meets the A Line Road, which runs northwest and southeast. North of its intersection with B Line Road, A Line Road runs through the western extent of the former industrial site. Several concrete pad foundations are present on either side of the road along with the remnants of a rail spur and a powerline corridor. Thompson Point is located at its northern end. A 20th-century pump house building is still standing at this location maintained to empty out chemicals still stored on size in a massive underground storage tank located just east of the northern end of A Line Road. Remnants of a dock extend into the river from this area and are described above in the historical architectural assessment. This area is also the possible location of


Page 5-20

Photograph 5.16. View looking north showing the eastern labs area at the north end of C Line Road (Photographer: Patrick Harshbarger, April 2016) [HRI Neg. #16009/D1:18].


Page 5-21

Photograph 5.17. View looking northwest showing concrete building pads and parking areas associated with the late 20th-century chemical plant north of B Line Road (Photographer: Patrick Harshbarger, April 2016) [HRI Neg. #16009/D1:20].


Page 5-22

Photograph 5.18. View looking west showing the overgrown former industrial area north of B Line Road (Photographer: Patrick Harshbarger, April 2016) [HRI Neg. #16009/D1:17].


Page 5-23

Photograph 5.19. View looking west at the indutrial area north of B Line Road (Photographer: Patrick Harshbarger, April 2016) [HRI Neg. #16009/D1:33].

24


the 17th-century Swedish plantation of Israel Helm, named “Helmstatt”, which was occupied, and for a time used as a tavern, through the 18th-century right up to 1880 (Figure 5.1). As potentially significant as such a site would be, there is very little potential that any significant archaeological expression of this site remains in this area, given the extensive modifica-tions that have been made to this area over the last 130 years.

The project site extends further to the southwest along the river bank almost to a waterway known as the Sand Ditch were a relatively modern tidal gate has been built. This part of the project site encompasses of an area of former meadow, the northeastern end of which was at least partially modified for use as a coal ash storage area (Photograph 5.20). The remainder of the meadow seems to have been kept as an unmanaged tidal wetland throughout most of the 20th century.

A Line Road extends southeast from B Line Road along the western boundary of the project site (Photograph 5.21). A rail corridor is located to the east of A Line Road, which cross the road and heads south at the point where the road diverts to the east-southeast (Figure 5.1; Photograph 5.22). This rail corridor is overgrown now with some rails, ties and a single overhead signal bridge still extant. Beyond the rails to the east are the wetlands in the center of the property, which drain in a ditch to the east under A Line Road where there is a bridge and a small water treatment facility. West of A Line Road, beyond the project site but within the buffer is an area of woods and wetlands that have variously used by the Dupont Repauno Works. The A Line Road turns to the east-southeast and runs through the southern woods described above. The woods to the north and south of this road were used, particularly during the mid-20th-century for the storage of combustible materials in bunkers, which were spread through this area to avoid a chain reaction if one were to explode. The remnants of some of these bunkers and the roads used to access

them are visible on the ground surface in this area (Figure 5.1; Photograph 5.23). The A Line Road for-merly extended directly to the south-southeast along the rail corridor. It currently ends at a modern factory, situated just off the project site, that still utilizes the rail lines.


Page 5-25

Photograph 5.20. View looking southwest from Thompson Point towards the tidal meadows (Photog-rapher: Patrick Harshbarger, April 2016) [HRI Neg. #16009/D1:40].


Page 5-26

Photograph 5.21. View looking south along A Line Road from Thompson Point. Note the water tower and extant catenary poles (Photographer: P atrick Harshbarger, April 2016) [HRI Neg. #16009/D1:41].


Page 5-27

Photograph 5.22. View looking north along A Line Road. The rail corridor is located in the overgrown area to the right of the road (Photographer: Patrick Harshbarger, April 2016) [HRI Neg. #16009/D1:44].


Page 5-28

Photograph 5.23. View looking southwest towards the remnants of a storage bunker in the wooded area west of C Line Road and north of A Line Road (Photographer: Patrick Harshbarger, April 2016) [HRI Neg. #16009/D1:52].

1

chapter 6

conclusIons and recommendatIons

a. archItectural resources

A reconnaissance-level survey confirmed that the 376-acre project site is largely devoid of standing buildings or structures due to remediation of the former DuPont chemical works. Remaining features are mostly confined to concrete slab foundations, deteriorated wharves and the plant’s circulation pat-tern of roads and railroad tracks. Those few buildings and structures that do remain intact – a small brick office near the entrance, an elevated steel water tower, a concrete-block shack and a corrugated-metal sided pump house – are architecturally and technologically unexceptional as individual resources under Criterion C. They date to a major makeover of the Repauno Works during the 1950s and the 1960s and do not embody distinctive characteristics of a type, period or method of construction. They also do not possess high artistic value. Buildings and structures such as acid houses or dynamite lines that were distinctive to what DuPont produced at the Repauno Works have been lost. The few surviving, widely scattered intact features are representative of mid-20th-century utili-tarian architecture that could be found at almost any industrial site and thus are not distinctive of the spe-cialized nature of the technological processes used by DuPont. As a designed industrial landscape, the site has lost integrity of design, materials, workmanship, setting and feeling. It also does not possess historic district potential under Criterion C due to loss of the aspects of integrity.

Historical research conducted for this study suggests that the establishment and operation of the DuPont Repauno Works had significance as an event, both within the context of the development of DuPont, a major American corporation, and within the context of local community development. Several technologi-

cally important breakthroughs in explosives manufac-turing occurred at Repauno, which opened in 1880 and by the early 20th century was the largest dynamite works in the United States. In later years, the Repauno Works was a leading center for the production of acids and other chemicals used in a variety of products from textiles to fertilizers. The Repauno Works was also consistently one of, if not the largest, employer in Greenwich Township; Gibbstown largely owes its growth from a small 19th-century rural crossroads hamlet into a 20th-century town due to the employ-ment provided by DuPont. For these reasons, the Repauno Works can be argued to have had potential historical significance under Criterion A as being associated with significant events and broad patterns of industrialization and local community develop-ment. That said there are no remaining resources or features that either individually or collectively convey the property’s association with a significant single event or pattern of events, particularly the dangerous and large-scale character of the industrial processes that took place at the site. The loss of integrity is so complete that there are no longer any resources within the project site that could adequately represent Criterion A significance.

The project site has no resources with potentially significant associations to individuals important in history that would qualify for consideration under Criterion B.

Fieldwork and research also took into consideration whether there were any significant landscape features or viewsheds surrounding the project site that could be impacted by project activities. None were noted. An area of concern was the potential for dikes, gates, ditches and other structures associated with 18th or 19th-century meadow banking. While dikes, gates and

2


ditches were observed in some areas of the site, these were determined to consist principally of materials such as thick sheets of stone riprap, steel sheet-piling, concrete walls and earthen berms compacted and wide enough for heavy vehicles. These materials and construction techniques were considered indicative of late 20th and early 21st century projects to strengthen flood control and environmental protection of the marshes.

No further architectural investigation is recommend-ed. The proposed Gibbstown Logistic Center project is considered to have no potential to impact significant architectural resources.

b. archaeologIcal resources

Important to any assessment of the archaeological potential of the project site is an examination of the pre-DuPont Repauno Works landscape. The soils and hydrological mapping, combined with early his-toric maps, particularly the U.S. Coast Survey map from 1842, suggests that the project site was largely wetlands separating two drier upland areas; one in the south closer to Gibbstown and another in the northwest corner around Thompson Point. When this pre-industrial landscape is compared with the location of known prehistoric sites in the project vicinity, only limited areas within its boundaries show the same topographic characteristics. Most of the prehistoric sites nearby are located on well-drained soils near (within a few hundred feet of) open water, particularly along Repaupo Creek and its tributaries to the south and southwest. One site is known just outside of the project boundaries to the east and it is situated right on Clonmell Creek. No free flowing, open streams flow through the project site and the only part of the site adjacent to an open body of water is along the Delaware River, particularly Thompson Point, where a prehistoric cemetery was reported late in the 19th century. The other parts of the site with at least mod-

erately suitable soils are hemmed in by wetlands and tidal marshes and while these areas were certainly vis-ited and traversed by prehistoric people the likelihood of them establishing significant campsites in these interior areas is considered low.

In addition, the industrial development of the proj-ect site that took place after 1880 is likely to have removed or severely damaged any prehistoric archae-ology in these areas. Not only was this industrial development concentrated on prehistorically popular well-drained soils, such as at Thompson Point; as the works grew construction expanded beyond these soils into the wetlands, which were filled, dredged and channelized to suit the purposes of the plant. While there is the potential for a stray prehistoric artifact or feature to remain within the property, the potential for the preservation of a significant prehistoric site within the project site is considered extremely low.

This assessment of low archaeological potential applies to Thompson Point, despite the reported presence of a prehistoric cemetery, a potential mid-17th-century Swedish plantation site and an 18th- and 19th-century tavern site. It is known from historical records that the prehistoric cemetery and 18th-century buildings were removed to make way for the works (see above, Chapter 3). This account, along with the extensive evidence of plant construction activities during the 20th century, which culminated in the con-struction of a massive underground storage tank in the 1960s, leaves little possibility that significant intact archaeological remains are still present in this area.

One area where industrial development does not appear to have greatly modified the landscape is the area around the Miller/Mullin Farm site. The primary residence of this farm, which may date well back into the 18th century, was still standing into the middle of the 20th century. Although it was likely removed mechanically the site saw no further development and appears to have been left alone to be enveloped by the

3


surrounding woods. This limited area, as delineated on Figure 5.1, retains a high historic archaeological potential and should, if possible, be avoided during the future development of the project site. If avoid-ance is not possible further archaeological investiga-tion and assessment of the site is recommended.

The post-1880 remnants of the DuPont Repauno Works are not considered to possess any potential to yield significant industrial archaeological informa-tion under Criterion D. As detailed above, the works largely represent the 1950s or later phase of the plant as a producer of acids and other chemicals and there is very little potential for the survival of elements of the more historically significant explosives manufactur-ing period. There is in fact extensive documentation of the systematic destruction, for safety reasons, of these elements. What limited archaeological evidence remains of the production of explosives on the A, B and C production lines would have been severely impacted by the construction of the rail corridor along A Line Road, the massive buildup of industrial facili-ties on either side of B Line Road and the remediation activities taking place along C Line Road. The early labs were, because of the dangerous nature of the research, insubstantial facilities and all that is left of the more substantial laboratories from the mid-20th century are featureless concrete pads. The limited remains of the storage bunkers in the woods in the southern half of the project area are a later addition to the works, mostly built in the late 1930s and 1940s, and have little information potential. Finally, the documentary evidence of the DuPont Repauno Works, largely available at the Hagley Museum, already serves as a more substantial and complete record of the development of the site and the activities and pro-cesses that took place there than any further archaeo-logical investigation could contribute.

references

Page r-1

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established by the Riparian Commissioners of the State of New Jersey. Riparian Commissioners of the State of New Jersey, Trenton, New Jersey.

Beers, S.N., F.W. Beers, D. J. Lake, L.B. Lake and D.G. Beers 1861 Map of the Vicinity of Philadelphia from Actual Surveys. J.E. Gillette & Company, Philadelphia,

Pennsylvania.

Cross, Dorothy 1941 Archaeology of New Jersey, Volume I. The Archaeological Society of New Jersey and the New Jersey

State Museum, Trenton, New Jersey.

1956 Archaeology of New Jersey. Volume II: the Abbott Farm. Archaeological Society of New Jersey and the New Jersey State Museum, Trenton.

Cushing, Thomas and Charles E. Sheppard 1883 History of the Counties of Gloucester, Salem, and Cumberland, New Jersey with Biographical

Sketches. Everts and Peck, Philadelphia, Pennsylvania.

Custer, Jay F. 1989 Prehistoric Cultures of the Delmarva Peninsula: An Archaeological Study. Newark, Delaware:

University of Delaware Press.

1996 Prehistoric Cultures of Eastern Pennsylvania. Anthropological Series No. 7. Pennsylvania Historical and Museum Commission, Harrisburg, Pennsylvania.

Daniels, O. 1969 “A Brief History of Gibbstown, New Jersey.” Bulletin of the Gloucester County Historical Society,

Volume 8, Number 11.

E.I. du Pont de Nemours & Company 1895-1975 Photograph Collection, Repauno Works. On file at the Hagley Museum and Library, Wilmington,

Delaware.

1918-1983 Historical Files, Repauno Works. Historical Files. On file at the Hagley Museum and Library, Wilmington, Delaware.

Page r-2


1930 Repauno Works: Fiftieth Anniversary. Gibbstown, New Jersey.

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1981 Repauno: The First Hundred Years. Wilmington, Delaware.

Eastern Dynamite Company 1889-1906 Superintendent’s Files. On file at the Hagley Museum and Library, Wilmington, Delaware.

Everts and Stewart 1876 Combination Atlas Map of Salem and Gloucester Counties, compiled, drawn and published from

personal examinations and surveys by Everts and Stewart. Philadelphia.

Faden, William 1778 The Course of the Delaware River from Philadelphia to Chester, exhibiting the several works erected

by the rebels to defend its passage, etc. London. On file at the Library of Congress, Washington, D.C.

Fitting, James E., John R. Kern and Stephen R. Claggett 1979 Cultural Resources Review and Sensitivity Analysis for the Delaware River and Bay. Submitted to the

U.S. Department of the Army, Philadelphia District, Corps of Engineers. On file at the New Jersey Historic Preservation Office, Trenton, New Jersey.

Fittipaldi, Janet 1981 Archaeological Report on the Proposed Delaware Riverfront Park, Greenwich Township, Gloucester

County, New Jersey. Prepared for the N.J. Department of Energy – Federal Coastal Energy Impact Program and N.J. DEP Green Acres Program. On file at the New Jersey Historic Preservation Office, Trenton, New Jersey.

Gordon, Thomas F. 1834 Gazetteer of the State of New Jersey. Daniel Fenton, Trenton, New Jersey.

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American Indian, New York.

Hopkins, G.M. 1877 Atlas of Philadelphia and Environs. Philadelphia.

Hunter Research, Inc. 1996 Historic and Archaeological Evaluation, Replacement of Two Bridges on Tomlin Station Road,

Page r-3


Gloucester County, New Jersey. Prepared for the Delaware Valley Planning Commission. On file at the New Jersey Historic Preservation Office, Trenton, New Jersey.

Indian Site Survey 1940 On file, New Jersey State Museum (NJDS), Trenton, New Jersey.

Kalm, Peter 1937 [1770] Peter Kalm’s Travels in North America. Edited by A. Benson. 2 vols. Wilson Erickson Inc., New

York, New York.

Klett, Joseph R. 1996 Genealogies of New Jersey Families: from the Genealogical Magazine of New Jersey. Genealogical

Publishing Company, Baltimore, Maryland.

Kraft, Herbert C. 1986 The Lenape: Archaeology, History and Ethnography. Newark, New Jersey: New Jersey Historical

Society.

2001 The Lenape-Delaware Indian Heritage: 10,000 B.C. to A.D. 2000. Union, New Jersey: Lenape Books.

Kummel, Henry B. 1940 The Geology of New Jersey. Bulletin 50. New Jersey Department of Conservation and Development,

Trenton.

Landscape Studies Inc. 1984 State IA Cultural Resources Survey of the Gloucester County Utilities Authority, 201 Facilities Plan,

Gloucester County, New Jersey. On file at the New Jersey Historic Preservation Office, Trenton, New Jersey.

Lewis Publishing Company 1900 Biographical, Genealogical and Descriptive History of the First Congressional District of New Jersey.

Volume I. New York, New York.

Louis Berger & Associates, Inc. 1983 A Cultural Resources Survey of the New Jersey Shore of the Delaware River in Camden and Gloucester

Counties. Prepared for the New Jersey Division of Building and Construction. On file at the New Jersey Historic Preservation Office, Trenton, New Jersey.

Markley, Marco L. 1962 Soil Survey of Gloucester County, New Jersey. United States Department of Agriculture, Soil

Conservation Service, Washington, D.C.

Page r-4


Mintz, Elizabeth R. 1982 The Chester – Monds Islands, Gloucester County, New Jersey, Cultural Resources Survey. Prepared

for the Department of the Army, Philadelphia District Corps of Engineers. On file at the New Jersey Historic Preservation Office, Trenton, New Jersey.

Mounier, R. Alan 1982 Interstate 295 section 1W and 1X Hessian Avenue to Repaupo Road, Gloucester County, New

Jersey technical environmental studies archaeology and architecture. On file, New Jersey Historic Preservation Office, Trenton.

1993 An archaeological survey of Interstate Highway 295(3) Interchange 14 Logan Township, Gloucester County, New Jersey. On file, New Jersey Historic Preservation Office, Trenton.

1994 An archaeological survey of Interstate Highway 295(3) Interchange 16 Greenwich Township, Gloucester County, New Jersey. On file, New Jersey Historic Preservation Office, Trenton.

2003 Looking Beneath the Surface: The Story of Archaeology in New Jersey. Rutgers University Press, New Brunswick, New Jersey.

Nationwide Environmental Title Research [NETR] Historic Aerials and Topographic Maps of Gibbstown, New Jersey 1931-2007. Electronic document,

http://historicaerials.com/. Accessed April 2016.

Natural Resources Conservation Service 2015 Web Soil Survey, National Cooperative Soil Survey. Electronic Document: http://njwebmap.state.nj.us/

NJGeoWeb/Web Pages. Accessed 8/17/15.

New Jersey Department of Environmental Protection 2014 NJGeoWeb. Electronic Document: http://njwebmap.state.nj.us/NJGeoWeb/Web Pages. Accessed

8/17/15.

New Jersey Historic Preservation Office 2000a Guidelines for Architectural Survey. On-line at www.nj.gov/dep/hpo/1identify/survarcht.htm [accessed

October 2015].

2000b Guidelines for Preparing Cultural Resources Management Archaeological Reports. On-line at www.nj.gov/dep/hpo/1identify/culreso.pd [accessed October 2015].

2004 Guidelines for Phase I Archaeological Investigations. On-line at www.nj.gov/dep/hpo/1identify/arkeoguide1.htm [accessed October 2015].

Page r-5


Pomfret, J.E. 1956 The Province of West New Jersey 1609-1702: A History of the Origins of an American Colony.

Princeton University Press, Princeton, New Jersey.

Pratt, Robert L. 1970 The Repauno Works: A History. On file at the Hagley Museum & Library, Wilmington, Delaware.

Richard Grubb & Associates, Inc. 2004 Stage IA Cultural Resources Survey, Hercules Site, Gibbstown, Greenwich Township, Gloucester

County, New Jersey. On file at the New Jersey Historic Preservation Office, Trenton, New Jersey.

2005 Stage IB Cultural Resources Survey, Hercules Site, Gibbstown, Greenwich Township, Gloucester County, New Jersey. On file at the New Jersey Historic Preservation Office, Trenton, New Jersey.

Robichaud, Beryl and Murray F. Buell 1983 The Vegetation of New Jersey. Rutgers University Press, New Brunswick, New Jersey.

Sebold, Kimberly 1992 From Marsh to Farm: The Landscape Transformation of Coastal New Jersey. National Park Service,

Washington, D.C.

Simpson, Hazel B., editor 1965 Under Four Flags, Old Gloucester County, 1686-1964, A History of Gloucester County, New Jersey.

Board of Chosen Freeholders, Gloucester County, Woodbury, New Jersey.

Skinner, Alanson, and M. Schrabisch 1913 A Preliminary Report of the Archaeological Survey of the State of New Jersey. Bulletin No. 9.

Geological Survey of New Jersey, Trenton, New Jersey.

Snyder, John P. 1969 The Story of New Jersey’s Civil Boundaries, 1606-1968. Bureau of Geology and Topography, Trenton,

New Jersey.

Stansbie, Alexander C., James Keily and Samuel M. Rea 1849 A Map of the Counties of Salem and Gloucester, New Jersey from Original Surveys. Smith and Wistar,


Stewart, Frank H. 1977 Notes on Old Gloucester County, New Jersey. 4 Volumes. Genealogical Publishing Company,

Baltimore, Maryland.

Page r-6


URS Corporation 2004 Phase I/II/III Cultural Resource Investigations for a Proposed Borrow Area at the DuPont Repauno

Plant, Gloucester County, New Jersey. Prepared for DuPont Remediation Group. On file at the New Jersey Historic Preservation Office, Trenton, New Jersey.

2008 Cultural Resource Reconnaissance Management Summary for the Remediation of Four Areas at the DuPont Repauno Plant, Gloucester County, New Jersey. On file at Hunter Research, Inc., Trenton, New Jersey.

U.S. Coast Survey 1842 Mantua Creek-Paulsboro-Fort Mifflin. T Sheet # 0164. On file, Office of Coast Survey, National

Oceanic and Atmospheric Administration, Washington, D.C.

U.S. Geological Survey 1888-1967 Historical Topographic Map Collection. On-line at http://ngmdb.usgs.gov/maps/topoview/viewer

[accessed April 2016].

USDA Natural Resources Conservation Service 2004 Repaupo Creek. Electronic document, online at www.nj.nrcs.usda.gov [accessed May 2016].

USDA Soil Conservation Service 1962 Watershed Work Plan for the Repaupo Creek Watershed, Gloucester County, New Jersey. Somerset,

New Jersey.

Watson, William 1812 A Map of the State of New Jersey. W. Harrison, Philadelphia, Pennsylvania.

Wolfe, Peter E. 1977 The Geology and Landscapes of New Jersey. Crane Russak, New York, New York.

Appendix A

RESUMES

PATRICK HARSHBARGER Principal Historian/Architectural Historian, M.A., M.P.A.

EDUCATION M.A., History, Hagley Fellow, University of Delaware, Newark, Delaware, 1990

Major Fields of Study: History of Technology (focus on built environment, structural engineering and architecture); American Colonial History

Minor Fields of Study: American Labor History; European Industrialization Museum Studies Certificate, University of Delaware, Newark, Delaware, 1990 M.P.A., Public Administration, Florida International University, Miami, Florida, 1988 B.A. magna cum laude, American History, Brown University, Providence, Rhode Island, 1984 EXPERIENCE 2010-present Principal Historian/Architectural Historian

Hunter Research, Inc., Trenton, New Jersey

Technical and day-to-day managerial responsibilities for historical and archival research in support or historic architecture and archaeology. Participation in:

Section 106 and state preservation law compliance review

historical architectural survey, evaluation and recording of buildings and structures

historical research

preservation planning

public outreach

historical exhibits and signage

interpretive planning and development

report preparation

proposal preparation 1996-present National Editor, Society for Industrial Archeology Newsletter

(www.sia-web.org/siapubs/publications.html)

Full editorial responsibilities inclusive of identifying and providing assistance to contributing authors and photographers, copy editing and oversight of graphic design and production on a quarterly basis.

1991-2010 Senior Historian/Preservation Planner TranSystems Corp. (formerly Lichtenstein Consulting Engineers) Langhorne, Pennsylvania and Paramus, New Jersey Served as one of two staff historians to a national engineering and transportation consulting

firm specializing in historic bridges and roads, as well as general cultural resources management services (Sections 106 and 4f), to a client base consisting mainly of local, state and federal transportation agencies.

1991-2009 Historian McKelvey Museum Services, Wilmington, Delaware

On-call interpretive planning, exhibit development and collections management for historic sites

PATRICK HARSHBARGER Page 2

and museums in the Mid-Atlantic region inclusive of historical research, meetings with trustees and staff, and report preparation and editing.

1990 Historian, National Park Service Historic American Engineering Record, Boston, Massachusetts 1989 Architectural Historian Intern Bucks County Conservancy, Doylestown, Pennsylvania 1986-88 Special Assistant/Newsletter Editor Office of the Vice President, Florida International University, Miami, Florida

1984-1986 Deputy Director Slater Mill Historic Site, Pawtucket, Rhode Island CONTINUING EDUCATION AND CERTIFICATIONS Secretary of the Interior’s Professional Qualifications Standards for Historians (36 CFR Part 61) Secretary of the Interior’s Professional Qualifications Standards for Architectural Historians (36 CFR Part 61) National Register Nomination Preparation, New Jersey Historic Preservation Office and National Register of Historic Places Joint Workshop, Trenton, New Jersey, 2011 Iron and Steel Preservation Workshop Certificate, Lansing Community College, Lansing, Michigan, 2010, 2012 Section 106 Training Certificate, Ohio Department of Transportation, Columbus, Ohio, 2010 HAZWOPER 24-hr. Training Section 106 Training Workshop, Pennsylvania Department of Transportation, Allentown, Pennsylvania, 2009 Museum Studies Certificate, University of Delaware, Newark, Delaware, 1990 Hagley Fellow in the History of Industry and Technology/Museum Studies, Hagley Museum & Library, Wilmington, Delaware, 1988-1991 SPECIAL SKILLS AND INTERESTS

historic bridges

historic transportation systems (roads, canals, railroads)

preservation of historic machinery and tools

industrial and commercial architecture

engineering heritage

industrial archaeology

public history and heritage tourism

photography

historical survey digital databases (MS-Access) PROFESSIONAL AFFILIATIONS Association for Industrial Archaeology (U.K.) Association for Preservation Technology International National Railway Historical Society National Society for the Preservation of Covered Bridges National Trust for Historic Preservation Newlin Foundation, Board of Directors Society for Commercial Archeology Society for the History of Technology Society for Industrial Archeology Society for the Preservation of Old Mills Vernacular Architecture Forum

PATRICK HARSHBARGER Page 3 SELECTED PUBLICATIONS Co-author with Richard W. Hunter. Sartori to Sacred Heart: Early Catholic Trenton. Sacred Heart Parish, Trenton, New Jersey, 2014. New Jersey Department of Transportation’s Fernwood Service Station, Serving New Jersey’s Highways Since 1922. New Jersey Department of Transportation, Trenton, New Jersey. 2014. “Two Pioneering American Roadways.” Proceedings of the Institution of Civil Engineers – Engineering History and Heritage. London, England, May 2010. Editor. Abstracts of American Truss Bridge Patents, 1817-1900. Society for Industrial Archeology, Houghton, Michigan, 2009. Robert John Prowse, New Hampshire State Bridge Engineer. New Hampshire State Historic Preservation Monograph Series. Concord, New Hampshire, 2009. Co-author. National Guidelines for Historic Bridge Rehabilitation and Replacement. Washington, D.C.: American Association of State Highway and Transportation Officials, 2008. “Defining Historic Roads.” Proceedings of the 6th Preserving the Historic Road in America Conference. Albuquerque, New Mexico, 2008. Historic Bridge Basics. South Carolina Department of Transportation. Columbia, South Carolina, 2004. “Strategies for Historic Evaluation of Standard Highway Bridges, 1920-1960.” Proceedings of the Preserving the Recent Past 2 Conference. Philadelphia, Pennsylvania, October 2000. “So Your Dualized Highway is 50 Years Old? Is It Historic?” Proceedings of the Preserving the Historic Road in America Conference. Morristown, New Jersey, April 2000. Editor and Co-author. Delaware’s Historic Bridges: Survey and Evaluation of Historic Bridges with Historic Contexts for Highways and Railroads. 2nd Edition Revised. Dover, Delaware: Delaware Department of Transportation, 2000. "Metal Truss Bridges and Their Builders in Historical Perspective: Some Thoughts from a Case Study of the Phoenix Bridge Company.” Spans of Time. Historic Ithaca: Ithaca, New York, 1999. “The Providence School Board Reform Movement, 1898-1924.” Rhode Island History, Volume 44, Number 2 (May 1985).

JAMES S. LEE, III, M.A., RPA

Vice President Principal Investigator/Archaeologist

EDUCATION M.A., Archaeology, University of Durham, Durham, United Kingdom, 1996 B.A., Anthropology and History, Rutgers University, New Brunswick, New Jersey, 1995 EXPERIENCE 2015-present Vice President/Principal Investigator/Archaeologist Hunter Research, Inc., Trenton, NJ

Vice President of firm providing archaeological and historical research, survey, excavation, evaluation, report preparation and public outreach services in the Northeastern United States. Responsible for:

Project management, budgeting and scheduling

Technical and synthetic writing

Proposal preparation, contract negotiation and management

Hiring and supervision of personnel

Supervision of research, fieldwork, analysis and report preparation 2001-2015 Principal Investigator Hunter Research, Inc., Trenton, NJ Technical and managerial responsibilities for survey, evaluation and mitigation of selected archaeological projects. Technical and managerial responsibility for report production. Participation in:

overall site direction and day-to-day management

development and implementation of research, excavation and analysis strategies for prehistoric and historic archaeological sites

supervision of cartographic and GIS product, graphic design and report layout

hiring and supervision of personnel

2001 Crew Chief Kittatinny Archaeological Research, Stroudsburg, Pennsylvania

survey and excavation

supervision of field personnel

stratigraphic and artifact analysis

1997-2001 Principal Investigator/Project Manager

Cultural Resource Consulting Group, Highland Park, New Jersey

overall site direction and day-to-day management

development and implementation of research, excavation and analysis strategies for prehistoric and historic archaeological sites

report and proposal preparation

hiring and supervision of personnel

James S. Lee PAGE 2

1997-2000 Laboratory Supervisor Cultural Resource Consulting Group, Highland Park, New Jersey

Technical and managerial responsibilities for laboratory components of archaeological projects. Participation in: management of laboratory operations supervision of laboratory personnel computerization of artifact data prehistoric and historic ceramic analysis preparation of artifact inventories and writing of artifact sections of reports

1996-1997 Field Technician Cultural Resource Consulting Group, Highland Park, New Jersey SPECIAL SKILLS AND INTERESTS

canals and associated water control structures

waterpowered mill sites

iron manufacture

prehistory of the northeastern United States

prehistoric lithic technology

historic sites interpretation and public outreach CERTIFICATIONS OSHA 40-hour Initial Training, 2002 OSHA 8-hour Refresher Course, 2012 Register of Professional Archaeologists PROFESSIONAL AFFILIATIONS Society for Industrial Archaeology Archaeological Society of New Jersey, Member at Large Society for Pennsylvania Archaeology New York State Archaeological Association Canal Society of New Jersey Warren County Morris Canal Committee Eastern States Archaeological Federation Middle Atlantic Archaeological Conference SELECTED PRESENTATIONS “The Fishkill Supply Depot: Archaeological Synthesis” Paper presented to the Friends of the Fishkill Supply Depot, October 25, 2015. “Archaeological Investigations at the Tulpehacken Nature Center, Abbott Marshlands, Mercer County, New Jersey.” Paper presented to the Archaeological Society of New Jersey, March 21, 2015. “The Last 100 Years at Morris Canal Plane 9 West.” Paper presented to the Canal Society of New Jersey, November 21, 2014 (with James Lee Jr.).

James S. Lee PAGE 3

“Ephrata Tract Archaeological Assessment.” Paper presented to the Moravian Historical Society, October 20, 2014. “Archaeological Investigations in the Shadow of the Gap, I-80 Weigh Station Site (28Wa290).” Paper presented to the Society for Pennsylvania Archaeology, Forks of the Delaware Chapter 14. April 3, 2013. “Exploring the Industrial Archaeological Resources of Waterloo Village.” Paper presented to the Canal Society of New Jersey, March 15, 2013 (with Richard W. Hunter). “Archaeological Investigations at Morris Canal Lock 2 East, Wharton, New Jersey.” Paper presented to the Canal Society of New Jersey, March 16, 2012. “Delaware and Raritan Canal Lock #1, Hamilton Township, Mercer County, New Jersey.” Paper presented to the Canal Society of New Jersey, December 1, 2010 (with Richard W. Hunter). “The Archaeological Potential of the Morris Canal.” Paper presented to the Archaeological Society of New Jersey, March 19, 2007. “Planes and Plans: The Morris Canal in Warren County.” Paper presented to the New Jersey Historic Preservation Conference, April 23, 2004.

Appendix B

NEW JERSEY HISTORIC PRESERVATION OFFICE BIBLIOGRAPHIC ABSTRACT

New Jersey Historic Preservation Office


Bibliographic Abstract

APPENDIX B

Project: Phase IA Historical and Archaeological Survey, Gibbstown Logistics Center, Greenwich Township, Gloucester County, New Jersey

Level of Survey: Phase IA

Location: E.I. du Pont de Nemours & Company (DuPont) Repauno Works, Greenwich Township, Gloucester County, NJ

Drainage Basin: Repaupo Creek; Delaware River

U.S.G.S. Quadrangle: Bridgeport

Cultural Resources: E.I. du Pont de Nemours & Company (DuPont) Repauno Works

B-1

Appendix C

PROJECT ADMINISTRATIVE DATA

Project Administrative Data


PROJECT SUMMARY

APPENDIX C

Project Name: Phase IA Historical and Archaeological Survey, Gibbstown Logistics Center, Greenwich Township, Gloucester County, New Jersey

Level of Survey: Phase IA

Review Agency: NJHPOAgency Reference: N/A

PROJECT CHRONOLOGY

Date of Contract Award: March 4, 2016Notice to Proceed: March 4, 2016Background Research: March-April 2016Fieldwork: March-April 2016Analysis: N/AReport Written: May 2016

Artifacts/Records Deposited: N/A

Report Author(s): Patrick Harshbarger and James Lee

16009Date of Report: May 2016Client: Fortress Investment GroupPrime: Ramboll Environ

HRI Project Reference:

PROJECT PERSONNEL

Draftperson(s): Evan Mydlowski

Analyst(s): N/A

Field Supervisor(s): James Lee

Background Researcher(s): Patrick Harshbarger

Field Assistant(s): N/A

Principal Investigator(s): Richard W. Hunter, James Lee

C -1


Ramboll

APPENDIX H PROPERTY DEED AND PROOF OF TIDELANDS OWNERSHIP

26512 Page 1 of 1~

, (,

Prepared by: Jeffrey S. Beenstock, Esq.Ballard Spahr LLP~

DEED

11I1~11~111I11111~lilllI1IIM~I~I~~mi~IIIIII~II~1Docket: 00026512Type:DEE Pnses:l~JD~es N. HDsnn, Gloucester County ClerkReceipt~:55239? 10:4~:~9A Jul 14,2016Recordins Fee: 170.00 DB 5498 46

This Deed is made effective as of 3.0 ,2016,

BETWEEN

THE CHEMOURS COMPANY FC, LLC, a Delaware corporation having an address at 1007

Market Street, Wilmington, Delaware 19899, referred to as the Grantor,

AND

DELAWARE RIVER PARTNERS LLC, a Delaware limited liability company having an

address at 1345 Avenue of the Americas, 45th

Floor, New York New York 10105, referred to as

the Grantee.

The words "Grantor" and "Grantee" shall mean all Grantors and all Grantees listed above.

Transfer of Ownership. The Grantor grants and conveys (transfers ownership of) the

property described below to the Grantee. This transfer is made for the sum TWENTY-FOUR

MILLION DOLLARS ($24,000,000.00).

The Grantor acknowledges receipt of this money.

Tax Map Reference. (NJ.S.A. 46:15-1.1) Township of Greenwich, County of

Gloucester, State of New Jersey, Block 3, Lots 8, 9,10,11, 12,21,27 & 37; Block 4, Lot 1;

Block 5, Lots 3 & 5, Block 6, Lot 2; Block 8, Lots 1,2,3,4,4.01,4.02 & 5; Block 9, Lots 1, 2,

3,4 & 5; and Block 246, Lot 1.

o No property tax identification number is available on the date of this Deed. (Check box if

applicable ).

Property. The property consists of the land and all the buildings and structures on the

land in the Township of Greenwich, County of Gloucester, and State of New Jersey. The legal

description is:

See Exhibit A attached hereto.

UNDER AND SUBJECT to all restrictions, easements, covenants, conditions of record.

2~,OOO.OO stnte: 60,000.0035.775.00 F'HPFA: 12.000.0054,300.00

101,300.00.00 REALTY TOTAL: n7.B?5.00

Consicierution:2~,OOO,OOO.OO Tn~/Code: SCounty:NJAHTF:EM(ienPur:OHI1 :

DMEAST #25793595 v2

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DEED

This Deed is made effective as of _________ , 2016,

BETWEEN

THE CHEMOURS COMPANY FC, LLC, a Delaware corporation having an address at 1007 Market Street, Wilmington, Delaware 19899, referred to as the Grantor,

AND

DELAWARE RIVER PARTNERS LLC, a Delaware limited liability company having an address at 1345 Avenue of the Americas, 45th Floor, New York New York 10105, referred to as the Grantee.


Transfer of Ownership. The Grantor grants and conveys (transfers ownership of) the property described below to the Grantee. This transfer is made for the sum TWENTY-FOUR MILLION DOLLARS ($24,000,000.00).


Tax Map Reference. (N.J.S.A. 46:15-1.1) Township of Greenwich, County of Gloucester, State of New Jersey, Block 3, Lots 8, 9, 10, 11 , 12, 21, 27 & 37; Block 4, Lot 1; Block 5, Lots 3 & 5, Block 6, Lot 2; Block 8, Lots 1, 2, 3, 4, 4.01, 4.02 & 5; Block 9, Lots 1, 2, 3, 4 & 5; and Block 246, Lot 1.

D No property tax identification number is available on the date of this Deed. (Check box if applicable).

Property. The property consists of the land and all the buildings and structures on the land in the Township of Greenwich, County of Gloucester, and State of New Jersey. The legal description is:



DMEAST #25793595 v2

' 'J I 1.

1.,

' j ; :

~ I '

ALSO UNDER AND SUBJECT to the following restriction: The property shall not be used for (a) residential uses; or (b) any use of the property for schools, day care, child care, elder care facilities, hospitals, entertainment/amusement/sports or other centers or facilities which will be used primarily by children or other sensitive populations, or childhood education uses; or (c) any use of the property for retail food establishments or other commercial food handling, manufacturing or processing operations that is not protective of human health. The Grantee, for itself, its successor and assigns, by acceptance of this Deed, agrees with the Grantor that the foregoing restrictions shall be covenants running with the land, binding upon its successors, and that in any deed of conveyance of the property or any part thereof to any person or person, such restrictions and conditions shall be incorporated by reference to this Deed and the record hereof as fully as the same are contained herein without any modification. The restrictions provided herein may be enforced by the Grantor against any person who violates such restrictions.

Promises by Grantor. The Grantor promises that the Grantor has done no act to encumber the property. This promise is called a "covenant as to grantor's acts" (N.J.S.A. 46:4-6). This promise means that the Grantor has not allowed anyone else to obtain any legal rights which effect the property (such as by making a mortgage or allowing a judgment to be entered against the Grantor).

[Signature and Notary Acknowledgement Continue on the Next Page]

DMEAST #25793595 v2 2

Signatures. This Deed is signed by the Grantor's proper corporate officer and witnessed effective as of the date at the top of the first page.

Witness:

STATE OF /Jal,utV.P 1

COUNTY OF te,,rfA,10e~ SS.:

THE CHEMOURS COMPANY FC, LLC, a Delaware limited liability company

By: The Chemours Company, a Delaware corporation and its sole member

By·~:t!-. SherYiA eord Director, Environm:H:lth> Safety and Remediation

I CERTIFY that on J ..;:::=....;U=-.;....Jot..__....._;::~='---"2016, Sheryl A. Telford personally came before me and stated to my satisfaction that:

(a) this person signed this Deed as the voluntary act of the corporation named in this Deed;

(b) this person was authorized to and did execute this Deed as the Dir~tor of The Chemours Company, a Delaware corporation, the sole member of The Chemours Company FC, LLC, the limited liability company named in this Deed; and

( c) the full and actual consideration paid or to be paid for the transfer of title is TWENTY-FOUR MILLION DOLLARS ($24,000,000.00) (such consideration is defined in

N.J.S .A. 46:15-5\\\\\Wf/f/f \\\\_r.~RIE 11,.

11// ~ ~ \V~ , , 0 ,'Vf/<_ 0:

S ~~ •0~ M / s' • .<'~ 'l ~ - . ,.. IS'/. ~ ~ "· " o·-::=. - .~ . - ' .

NOTARY PUBLIC

7I 1 ~ EXPIRES $ • := 1 ~. Oct. 27, 201~ .• : § My commission expires: ) d . &'7, ;() 16 ";\ p,·. ""oh ~;'. ~ ~

,~~ \:J~ • • ' "I/ff p\J •• ~- " ~ '4/Jr,,...• ••••• ~ "' ~~., ~ OF ot.\.~ ,,~

t.1Num111'''''

Signature and Acknowledgement Page to Bargain and Sale Deed

DEED

THE CHEMOURS COMPANY FC, LC, a Delaware corporation,

Grantor,

TO

DELAWARE RIVER PARTNERS LLC, a Delaware limited liability company

Grantee.

I ,.

Dated: _______ _ , 2016

Record and return to:

I -

EXHIBIT "A"

Legal Description

THE LAND REFERRED TO HEREIN BELOW IS SITUATED IN THE TOWNSHIP OF GREENWICH, COUNTY OF GLOUCESTER, AND STATE OF NEW JERSEY, AND IS DESCRIBED AS FOLLOWS:

TRACT I (Block 3, Lots 8-12, 21, 27 & 37; Block 4, Lot 1; Block 5, Lots 3 & 5; Block 6, Lot 2; Block 8, Lots 1-4, 4.01, 4.02 & 5)

BEGINNING at a point in the Easterly line of Block 8, Lot 4, where the same intersects the Northerly line of the West Jersey & Seashore Rail Road-Penns grove Branch (66.00 feet wide), said point being South 86 degrees 29 minutes 05 seconds West, 209.51 feet as measured along said line of the Rail Road from the Easterly line of Repauno Avenue (43.00 feet wide), said point also having the following New Jersey State Plane Coordinate values: North 362810.4513, East 269352.6490 and from said point runs; thence

1. along said Easterly line Block 8, Lot 4, Nmth 02 degrees 53 minutes 25 seconds West, 742.92 feet to a point in the division line between Block 8, Lot 4 and Lot 4.03, witnessed by a found pin & cap 0.10 feet south and 0.11 feet west from corner; thence

2. along the same, South 87 degrees 06 minutes 35 seconds West, 178.50 feet to a point in the same, witnessed by a found pin & cap 0.02 feet south and 0.17 feet west from corner; thence

3. along the same, North 02 degrees 53 minutes 25 seconds West, 224.95 feet to a point in the same, witnessed by a found pin & cap 0.35 feet northeast and 0.18 feet northwest from corner; thence

4. along the same, North 55 degrees 03 minutes 48 seconds East, 64.89 feet to a point in the same, witnessed by a found pin & cap on corner; thence

5. along the same, North 02 degrees 53 minutes 25 seconds West, 96.62 feet to a point in the same, witnessed by a found pin & cap 0.03 feet south and 0.03 feet east from comer; thence

6. along the same, North 87 degrees 06 minutes 35 seconds East, 300.00 feet to a point in the same, witnessed by a found pin & cap on line and 0.15 feet south from comer; thence

7. along the same, South 02 degrees 53 minutes 25 seconds East, 347.90 feet to a point in the Northerly line of Morse Street (45.00 feet wide); thence

8. along said line of Morse Street, North 87 degrees 05 minutes 51 seconds East, 781.34 feet to an angle point in the same, witnessed by a set pin & cap on corner; thence

,,

9. along the same, North 85 degrees 43 minutes 36 seconds East, 484.30 feet to an angle point in the same, witnessed by a set pin & cap on corner; thence

10. along the san1e, South 88 degrees 29 minutes 24 seconds East, 473.77 feet to an angle point in the same, witnessed by a found pin & cap 0.60 feet southwest and 0.03 feet southeast from corner; thence

11. along the same, North 15 degrees 33 minutes 02 seconds East, 5.15 feet to an angle point in the same, witnessed by a found pin & cap 0.20 feet southwest and 0.40 northwest from comer; thence

12. along the same, South 88 degrees 29 minutes 24 seconds East, 318.00 feet to a point in the westerly line of School Street (50.00 feet wide), witnessed by a found pin & cap 3.83 feet west and 0.10 feet north from comer; thence

13. along the same, North 27 degrees 57 minutes 36 seconds East, 370.90 feet to a point in the Southerly line of Block 8, Lot 8, witnessed by a found pin & cap 2.15 feet northeast and 0.45 feet northwest from corner; thence

14. along the same, North 62 degrees 02 minutes 24 seconds West, 363 feet more or less to the edge of Wiggins Pond, also 363.43 feet to a connecting course shown on the herein referenced survey; thence

15. along the same Northwestwardly, 524 feet more or less to a point in the Northerly line of Block 8, Lot 8, also having a connecting course of North 12 degrees 48 minutes 46 seconds West, 396.15 feet as shown on the herein referenced survey; thence

16. along the same, South 62 degrees 02 minutes 24 seconds East, 1200.00 feet to a point in the division line between Block 8, Lots 4 and 10, witnessed by a found concrete monument 1.81 feet northwest and 0.07 feet southwest from corner; thence

17. along the same and along the division line between Block 8 Lots 5 and 6, North 27 degrees 43 minutes 14 seconds East, 3085.07 feet to an angle point in said division line between Block 8, Lots 5 and 6; thence

18. along the same North 00 degrees 30 minutes 46 seconds West, 1000.00 feet to an angle point in the same; thence

19. along the same North 10 degrees 15 minutes 25 seconds West, 6 feet more or less to the mean high water line of the Delaware River, also being 6.20 feet to the connecting course shown on the herein referenced survey; thence

20. along the same Northwestwardly, 5263 feet more or less to the easterly line of a Riparian Grant described in Deed Book 448, page 224, also having a connecting course of North 73 degrees 41 minutes 17 seconds West, 4 793. 70 feet as shown on the herein referenced survey; thence

DMEAST #25793595 v2 6

I I

21. along said Grant line North 01 degrees 30 minutes 10 seconds East 631 feet more or less, 630.83 from said connecting course to a point corner to the same and in line of the Pierhead and Bulkhead Line adopted August 21, 1916; thence

22. along the same and along a Riparian Grant described in, North 79 degrees 36 minutes 47 seconds West, 627.45 a point corner to said Deed Book 680, Page 283, also in the Pierhead and Bulkhead line adopted October 16, 1916 as shown on a plan entitled "Map showing lands under tide-water situate in the Township of Greenwich, in the County of Gloucester- Grant to E. I. Du Pont De Nemours, a corporation of the State of Delaware, dated September 29, 1967"; thence

23. along the same and along the Riparian Grants described in Deed Book 914, Page 578, Deed Book 448, Page 224 and Deed Book 914, Page 578, South 87 degrees 56 minutes 35 seconds West, 327.77 feet to a point corner to said Deed Book 914, Page 578; thence

24. along the same, South 01 degrees 30 minutes 10 seconds West , 549 feet more or less, feet to a point in the aforesaid mean high water line along the Delaware River and 549.33 to the connecting course as shown on the herein referenced survey; thence

25. along the same Southwestwardly, 2314 feet more or less to a point in the easterly line of a Riparian Grant described in Liber L-3, Pg. 244, also having a connecting course of South 82 degrees 19 minutes 10 seconds West 2264.46 feet; thence

26. along said Grant line North 01 degrees 30 minutes 10 seconds East 772 feet more or less, to a point corner to the same, 771.65 feet from said connecting course; thence

27. along the same and along a Riparian Grant described in Deed Book 680, Page 277, South 87 degrees 56 minutes 35 seconds West, 475.53 feet to a point comer to said Grant; thence

28. along said Grant and along a Riparian Grant described in Deed Book 680, Page 283 South 01 degrees 30 minutes 10 seconds West, 1081 feet more or less to a point in the mean high water line along the Delaware River also being 1081.02 to a connecting course shown on the herein reference survey; thence

29. along the same Southwestwardly, 7149 feet more or less to a point where the easterly line of Block 3, Lot 13 intersects the same, also having a connecting course of South 57 degrees 29 minutes 33 seconds West, 4877.31 feet, witnessed by a set pin & cap; thence

30. along the same, South 20 degrees 42 minutes 33 seconds East, 361.16 feet to a point corner to the same, witnessed by a set pin & cap; thence

31. along the Southerly line of said lot, South 67 degrees 16 minutes 26 seconds West, 174.94 feet to a point corner to the same; thence

32. along the division line between Block 3, Lots 12 and 13, North 20 degrees 58 minutes 33 seconds West, 376.52 feet to a point, witnessed by a set pin & cap; thence

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33. South 72 degrees 16 minutes 27 seconds West, 483.12 feet to a point in the division line between Block 3, Lots 7 and 8, witnessed by a set pin & cap; thence

34. along the same, South 17 degrees 43 minutes 33 seconds East, 171.00 feet to a point corner to the same and in the line of Block 3, Lot 6, witnessed by a found iron pipe 0.18 feet southwest and 0.05 feet southwest from corner; thence

35. along said Lot 6, South 78 degrees 54 minutes 54 seconds East, 45.65 feet to a point corner to the same, witnessed by a found iron pipe 0.12 feet northwest and 0.08 feet southwest from comer; thence

36. along the same, North 85 degrees 21minutes22 seconds East 78.16 feet to a point the same, witnessed by a found iron pipe 0.57 feet northeast and 0.34 feet northwest from corner; thence

37. along the same and along Block 3, Lot 18, South 20 degrees 38 minutes 57 seconds East, 1056.07 feet to a point corner to the same; thence

38. along the same, South 69 degrees 21minutes03 seconds West, 317.66 feet to a point common corner to Block 3, Lot 20; thence

39. along the same, South 22 degrees 01minutes07 seconds East, 496.13 feet to a point in line of Block 3, Lot 25; thence

40. along the same North 70 degrees 07 minutes 57 seconds East, 478.13 feet to a point for a corner to the same; thence

41. along the same and along Block 3, Lots 26, 30, 31 , and 33, South 13 degrees 42 minutes 57 seconds East, 1717.84 feet to a point common corner to Block 3, Lot 35; thence

42. along the same South 07 degrees 15 minutes 15 seconds East, 679.02 feet to a point comer to the same; thence

43. along the same South 63 degrees 14 minutes 46 seconds West, 34 feet more or less to the centerline of the Repaupo Creek, also being 34.22 feet to the connecting course shown on the herein referenced survey; thence

44. Soutbeastwardly, along the centerline of said creek a distance of 2278 feet more or less to a point where the northerly line of Block 5, Lot 2 intersects the same, also having a connecting course of South 59 degrees 36 minutes 37 seconds East, 1601.72 feet; thence

45. along the same the following three (3) courses, South 89 degrees 20 minutes 56 seconds East, 270.00 feet more or less to a point, 269.58 feet from said connecting course; thence

46. North 43 degrees 09 minutes 04 seconds East, 435.95 feet to a point; thence

47. South 30 degrees 52 minutes 07 seconds East, 395.92 feet to a point; thence

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48. still along the same and along Block 5, Lot 1, South 59 degrees 35 minutes 04 seconds West, 1040 feet more or less to a point in the centerline of said Repaupo Creek, also being 1039.66 feet to a connecting tie shown on the herein reference survey; thence

49. Southeastwardly, along the centerline of said creek a distance of 1070 feet more or less to a point where the northwesterly line of Block 5, Lot 4 intersects the same, also having a connecting course of South 77 degrees 08 minutes 05 seconds East, 986.47 feet; thence

50. along said Lot 4 the following three (3) courses, North 59 degrees 42 minutes 00 seconds East 759 feet more or less to a point, 758.85 feet from said connecting course; thence

51. South 17 degrees 18 minutes 00 seconds East, 621 . 72 feet to a point; thence

52. South 64 degrees 12 minutes 00 seconds West, 621 feet more or less to a point in the centerline of said Repaupo Creek, also being 620.73 feet to a connecting course shown on the

-herein reference survey; thence

53. Southeastwardly, along the centerline of said creek a distance of 756 feet more or less to a point where the same intersects the northerly line of New Jersey State Highway Route 44 also having a connecting course of South 25 degrees 17 minutes 07 seconds East, 644.55 feet; thence

54. along the same, North 41 degrees 08 minutes 06 seconds East 1650 feet more or less, 1649.95 feet as measured from said connecting course to an angle point in the same, witnessed by a set pin & cap; thence

55. along the same, North 40 degrees 40 minutes 06 seconds East, 228.84 feet to a point in the westerly line of Block 6, Lot 1, witnessed by a found concrete monument on corner; thence

56. along the same, North 63 degrees 03 minutes 56 seconds West, 708.95 feet to a point corner to the same, witnessed by a set pin & cap on corner; thence

57. along the Northerly line of the same, North 62 degrees 44 minutes 04 seconds East, 737.05 feet to a point corner to the same, witnessed by a set pin & cap on corner; thence

58. along the easterly line of the same, South 18 degrees 57 minutes 56 seconds East, 477.26 feet to a point in the aforementioned Northerly line of New Jersey State Highway Route 44, witnessed by a found concrete monument 0.11 feet northeast and 0.09 feet southeast from corner; thence

59. along the same, North 40 degrees 40 minutes 06 seconds East, 720.30 feet to a point of curvature in the same; thence

60. along the same and along a curve to the right having a radius of 1,472.69 feet, an arc distance of 143.65 feet , the chord of said arc being North 43 degrees 27 minutes 50 seconds East 143.59 feet to a point of tangency in the same; thence

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61. along the same, North 40 degrees 40 minutes 06 seconds East, 430.98 feet to a point in the same, witnessed by a found concrete monument 0.76 feet southwest and 0.11 feet southeast from comer; thence

62. along the same, North 83 degrees 28 minutes 06 seconds East, 430.98 feet to a point on a curve in the same, witnessed by a set pin & cap; thence

63 . along the same and along a curve to the right having a radius of 1,472.69 feet, an arc distance of 143.65 feet, the chord of said arc being North 80 degrees 40 minutes 26 seconds East 143 .58 feet to a point of tangency in the same, witnessed by a set pin & cap; thence

64. along the same, North 83 degrees 28 minutes 06 seconds East, 72.00 feet to a point in the aforementioned Northerly line of the West Jersey & Seashore Rail -Pennsgrove Branch; thence


66. along the same and along a curve to the right having a radius of 1,466.00 feet , an arc distance of 524.62 feet, the chord of said arc being North 54 degrees 09 minutes 46 seconds East 521.83 feet to a point on a curve corner to Block 8, Lot 7, witnessed by a set pin & cap; thence

67. along the curved westerly line of Block 8, Lot 7 having a radius of 419 .00 feet, an arc distance of 424.23 feet, the chord of said arc being North 5 degrees 44 minutes 09 seconds East 406.34 feet to a point on a curve corner to the same, witnessed by a set pin & cap; thence

68. along the curved Easterly line of Block 8, Lot 7 having a radius of 967 .87 feet, an arc distance of 524.34 feet, the chord of said arc being South 58 degrees 49 minutes 39 seconds East 517.95 feet to a point in the aforementioned curved Northerly line of the West Jersey & Seashore Rail Road-Pennsgrove Branch, witnessed by a found concrete monument 0.50 feet south and 0.14 feet west from corner; thence

69. along the same and along a curve to the right having a radius of 1466.00 feet, an arc distance of 59.86 feet, the chord of said arc being North 85 degrees 18 minutes 57 seconds East 59.85 feet to a point of tangency in the same; thence

70. along the same, North 86 degrees 29 minutes 05 seconds East, 119.84 feet to a point and place of BEGINNING.

TRACT II (Block 246, Lot 1)

BEGINNING at a point in the Southerly line of the West Jersey & Seashore Rail Road -PENNSGROVE BRANCH (66.00 feet wide) where the same is intersected by the division line between Block 246, Lots 1and8, said point having the following New Jersey State Plane Coordinate values: North 360486.4400, East 266558.6011 and from said point runs; thence

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l. along the southerly line of said Railroad, North 43 degrees 54 minutes 06 seconds East 1111.63 feet to a point in the centerline of Sand Ditch; thence

2. along the same, South 10 degrees 15 minutes 40 seconds East 237.17 feet to an angle point in the same; thence

3. along the same, South 44 degrees 35 minutes 40 seconds East 666.99 feet to a point in the division line between Block 246, Lots 1 and 2; thence

4. along the same, South 50 degrees 38 minutes 20 seconds West 175.00 feet to a point corner to Block 246, Lot 5, witnessed by a found iron pipe 0.23 feet southwest and 0.06 feet northwest from corner; thence

5. along the same, North 45 degrees 11minutes40 seconds West 618.15 feet to a point corner to the same, witnessed by a found concrete monument 0.14 feet southwest and 0.02 feet northwest from corner; thence

6. along the same and along Block 246, Lot 6, South 39 degrees 38 minutes 02 seconds West 785.61 feet to a point in line of the aforementioned Lot 8, witnessed by a found iron pipe on comer; thence

7. along the line of Lot 8, North47 degrees 41minutes58 seconds West 279.00 feet to the point and place of BEGINN1NG.

TRACT ill (Block 9, Lots 1 - 5)

BEGINNING at a point in the Southerly Line of Morse Street (33.00 feet wide) where the same is intersected by the westerly line of Repauno Avenue ( 43.00 feet wide), said point having the following New Jersey State Plane Coordinate values: North 363527.8591, East 269483.1432, witnessed by a pin & cap set on corner and from said point runs; thence

1. along said westerly line of Repauno A venue, South 02 degrees 53 minutes 25 seconds East 298.30 feet to a point common corner to Block 9, Lots 5 and 6, witnessed by a pin & cap set on comer; thence

2. along the same, South 87 degrees 06 minutes 35 seconds West 146.50 feet to a point common comer to Lots 5 and 6, witnessed by a pin & cap set on corner; thence

3. along Block 9, Lots 1through5, North 02 degrees 53 minutes 25 seconds West 298.30 feet to a point corner to Lot 1, witnessed by a pin & cap set on corner; thence

4. along the same, North 87 degrees 06 minutes 35 seconds East 146.50 feet to the point and place of BEGINNING.

The above Tracts 1 and 2 being together with the beneficial easement rights as set forth in unrecorded Deed made by E.1 Du Pont De Nemours and Company to the Township of Greenwich, dated September 12, 1984.

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Ramboll

APPENDIX I TIDELANDS LICENSE APPLICATIONS

Bureau of Tidelands Management 1/2

Ramboll 1760 Market Street Suite 1000 Philadelphia, PA 19103 USA

T +1 215 523 5600 F +1 215 496 0164 www.ramboll.com

March 1, 2019

Via Federal Express

State of New Jersey Department of Environmental Protection Bureau of Tidelands Management P.O. Box 420 Code 501-02B Trenton, NJ 08625-0420

APPLICATIONS FOR TIDELANDS LICENSES: 1) FIXED STRUCTURE LICENSE2) DREDGING LICENSE

APPLICANT: DELAWARE RIVER PARTNERS LLC 200 NORTH REPAUNO AVENUE BLOCK 8, LOT 4.02 GREENWICH TOWNSHIP, GLOUCESTER COUNTY, NEW JERSEY

Dear Sir/Madam:

On behalf of the applicant, Delaware River Partners LLC, please find enclosed an application for a Fixed Structure Tidelands License and a Dredging Tidelands License for the development of a multi-purpose pier at the DRP Gibbstown Logistics Center project located at 200 North Repauno Avenue in Greenwich Township, Gloucester County, New Jersey. Ramboll U.S. Corporation is serving as agent for this application.

DRP submitted a Waterfront Development (WFD) Permit application to NJDEP for the above-referenced project on February 27, 2019. DRP understands that the Bureau of Tidelands Management will not issue a Tidelands License until a copy of the approved permit has been received. The Waterfront Development Permit will be provided as soon as it is acquired.

To satisfy the requirements of the Bureau of Tidelands Management, the following items are enclosed:

• Item 1: Completed License Application Form

– Includes supporting documentation such as Affidavit of Title andOrganizational Data Form

• Item 2: Recorded Property Deed

• Item 3: Site Plans

– 3A: Site Plan for Dredging– 3B: Site Plan for Fixed Structures

Bureau of Tidelands Management 2/2

Should you have any questions or require any additional information, please do not hesitate to contact Laura George at [email protected] or 215-523-5603.

Sincerely, Laura George Principal Consultant

LG:jap 169000609-001

Attachment

cc: Gary Lewis, DRP Jimmy Osman, DRP Kenn Charron, Esq. DRP David Miller, Esq. Gibbons PC


ITEM 1 COMPLETED LICENSE APPLICATION FORM


Bureau of Tidelands Management P.O. Box 420 Code 501-02B

Trenton, NJ 08625-0420

TIDELANDS LICENSE APPLICATION FORM

PLEASE INCLUDE SIGNATURES OF ALL PERSONS LISTED ON THE CURRENT RECORDED DEED ATTACH A SIGNATURE ADDENDUM PAGE IF MORE THAN TWO SIGNATURES ARE REQUIRED

Title Holder(s)

Name: Delaware River Partners LLC

MciWng_Address: 200 N. Repauno Avenue G_it~,i:. Gibbstown State: NJ

:, Address: 200 North Repauno Avenue Municipality: Greenwich "fownship cou_nty:. Gloucester I

Lot: 2,3, 4.01, 4.02 & portions of 1.4 waterwa : Delaware River

Please select all that apply:

IX! Fixed Structure License, Bulkhead Extension License and/or Yacht or Boat Club License

• 0 Marina License

GfJ Dredging License

D Utility or Utility-related License

0 Bridge License

_ E::J M_o_~ifi~ation_ofExisting Lic~nSE:) ~ii~#===--=--,.,.,..-~--,.,,=---A ent Information o tional

Agent Name: Laura George, Rambo! Environ US Corporation

)Jllailing ,A.ddress: 1760 Market Street, Suite 1 OO_Q City: Philadelphia

19103 215-523-5603 ...... "' Slate: PA

I, the undersigned, hereby request a Tidelands License from the State of New Jersey. I understand that construction may : not be performed until said License is delivered. I also understand that the State has the right to revoke any License as set ' forth in N.J.S.A 12:3-10. Furthermore, I agree to abide by the terms and conditions contained in the License Document.

! 0 I agree to act as my own representative in all matters pertaining to my Tidelands License.

"

IX] I authorize the person named above to act as my agent in all matters pertaining to my Tidelands License. I understand that the Bureau of Tidelands Management will correspond only with this agent. Furthermore, I understand that I should direct future questions or concerns regarding my conveyance to my agent. This agreement will remain in effect unless I

:~,:~:::::::''"/t~n4• M•n•••mant D•t• z/ u /1r , Print Name: Gtt.f ~~~ . .\U:·~ • \>.Jcu.J~ ~l'vq ftM..~.C l L.(..

SigQatureof Title Holder:

: Print Name:

Date:




ORGANIZATION DATA FORM***

ATTACH AN ADDITIONAL PAGE IF SPACE FOR MORE THAN FOUR NAMES IS NEEDED

Organization Information

. Narrie_of_()rg,anization: Delaware River Partners LLC

_Plea§e list_ the persons authorized to act on behalfof the. above. org9nization:

Name: Gary Lewis

: Address: 200 N. Repauno Avenue, Gibbstown, NJ 08027

Ken Charron

i Address: 200 N. Repauno Avenue, Gibbstown, NJ 08027

Name: Jack Gallagher

Address: 200 N. Repauno Avenue, Gibbstown, NJ 08027

'Name: David Miller, Esq., Gibbons Law Firm

' Address: One Gateway Center, Newark, NJ 07102

Or anization Data

Is this organization based in New Jersey? _O Yes ijJNo

If No, is this organization authorized to do business in New Jersey? OCI Yes 0 No

Is the organization currently in good standing? _ fil Y~§ QNo

If No, please explain.

Title:

_,Till~:

; Title:

',Title:

• When was the First Annual Report filed with the Secretary of State in Trenton? 2017

Are there any Franchise Taxes currently due to the Corporation Tax Bureau? .. 0 '(es Qg No_

If Yes, in what year were the last taxes paid?

President

Vice President - Law

Controller

Legal Counsel

***Complete this form only if the applicant is not a private citizen




AFFIDAVIT OF TITLE

PLEASE INCLUDE THE NAMES AND SIGNATURES OF ALL PERSONS LISTED ON THE CURRENT RECORDED DEED ATTACH A SIGNATURE ADDENDUM PAGE IF MORE THAN TWO SIGNATURES ARE REQUIRED

I, the undersigned, being of lawful age, hereby attest to the following:

1. I am the current owner of the following property:

Address __ 2_o_o_N_ort_h_R_e_p_a_un_o_A_ve_n_u_e ______________ _

Gibbstown, Greenwich Township Municipality ________________________ _

county Gloucester

Block Block 3, Lots 8, 9, 10, 11, 12, 27, and 37; Block 4, Lot 1; Block 5, Lots 3 & 5; Block 6, Lot 2; Block 8, Lots 1, 2, 3, 4, 4.01, 4.02, & 5; Block 9, Lots 1, 2, 3, 4 & 5;

Lot and Block 246, Lot 1.

2. I am the owner of this property by virtue of the following deed:

DateofDeed ___ Ju_n_e_3_0_,_2_0_1_6 _________________ _

Recorded in County of __ G_lo_u_c_e_s_te_r _______________ _

DeedBook __ 5_4_9_8 _____________________ ~

PageNumber __ 4_6 _____________________ ~

3. I have not sold or in any other way relinquished my ownership interest in this property.

/ ~~.

~4-v1 Signature of Title Holder

Date

Gary Lewis, President Delaware River Partners _______________ _

Print Name

'-

Affix Seal:

Print Name

Date

Nancy M. Molloy NOTARY PUBLIC

STA TE OF NEW JERSEY My Commission Expires September 6, 2022

ITEM 2 RECORDED PROPERTY DEED

26512 Page 1 of 1~

, (,

Prepared by: Jeffrey S. Beenstock, Esq.Ballard Spahr LLP~

DEED

11I1~11~111I11111~lilllI1IIM~I~I~~mi~IIIIII~II~1Docket: 00026512Type:DEE Pnses:l~JD~es N. HDsnn, Gloucester County ClerkReceipt~:55239? 10:4~:~9A Jul 14,2016Recordins Fee: 170.00 DB 5498 46

This Deed is made effective as of 3.0 ,2016,

BETWEEN

THE CHEMOURS COMPANY FC, LLC, a Delaware corporation having an address at 1007

Market Street, Wilmington, Delaware 19899, referred to as the Grantor,

AND

DELAWARE RIVER PARTNERS LLC, a Delaware limited liability company having an

address at 1345 Avenue of the Americas, 45th

Floor, New York New York 10105, referred to as

the Grantee.


Transfer of Ownership. The Grantor grants and conveys (transfers ownership of) the

property described below to the Grantee. This transfer is made for the sum TWENTY-FOUR

MILLION DOLLARS ($24,000,000.00).


Tax Map Reference. (NJ.S.A. 46:15-1.1) Township of Greenwich, County of

Gloucester, State of New Jersey, Block 3, Lots 8, 9,10,11, 12,21,27 & 37; Block 4, Lot 1;

Block 5, Lots 3 & 5, Block 6, Lot 2; Block 8, Lots 1,2,3,4,4.01,4.02 & 5; Block 9, Lots 1, 2,

3,4 & 5; and Block 246, Lot 1.

o No property tax identification number is available on the date of this Deed. (Check box if

applicable ).

Property. The property consists of the land and all the buildings and structures on the

land in the Township of Greenwich, County of Gloucester, and State of New Jersey. The legal

description is:



2~,OOO.OO stnte: 60,000.0035.775.00 F'HPFA: 12.000.0054,300.00

101,300.00.00 REALTY TOTAL: n7.B?5.00

Consicierution:2~,OOO,OOO.OO Tn~/Code: SCounty:NJAHTF:EM(ienPur:OHI1 :

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