19890051 Ver 4_Check on chronic and acute_20211118

From: Manning, Jeff
To: Snider, Holley
Subject: RE: Check on chronic and acute RE: [External] Fw:
Date: Thursday, November 18, 2021 12:49:17 PM
Hi Holley,
I reviewed your request. I think you (and Autumn) are asking for clarification on how the water
quality standards are applied.
I can help you with that.
Here's a link to the water quality standards rules, which I will refer to in my responses below:
https://deq.nc.gov/media/15676/open
With regard to Autumn's question, do acute or chronic standards apply? The answer is, both apply.
Acute is defined in rule 15A NCAC 02B .0202 (1) acute toxicity to aquatic life....
Chronic is defined in ....0202 (15)...chronic value to aquatic life...
Standards are developed to protect aquatic life from acute and chronic effects, so both are
applicable.
Usually, these are implemented through discharge permits.
SC (basic saltwater) standards are in 15A NCAC 02B .0220
The WER, or the Water Effects Ratio, is a factor that is relevant for all the metals standards, and is
something that can be used to be relevant in very unique situations where, for example, a consultant
would collect a lot of site specific information to develop a WER that is different than the default of
"1", and it would allow them to create a site specific standard. For example, a WER of 2 would
essentially double the standard, etc. It is generally very expensive and lengthy to develop such a
WER, But the option is there. The WER is defined as default of "1" in the rule in .0220(b). (I know
it's confusing!) But when you multiply by 1, you get the same thing, so again, it's there if someone
chooses to use it to develop a different standard (but that's not the case here.)
Compliance with metals standards uses both acute and chronic, and differentiates between the two
standards, in .0220 (c). Again, this is for compliance purposes (and I don't think a dredge permit was
envisioned to require the multiple samples so long as 1 sample wasn't exceeding either the acute or
the chronic value. If a single sample were exceeding either value, then the consultant could
implement the definition of acute and take two sample in an hour and average them. And chronic
would be 4 samples over 4 days, and calculate a 96 hour average, to see if they were still exceeding
the standard.
Hopefully this helps!
Let me know!
Thanks,
Jeff

Jeff Manning
Chief, Classifications & Standards/Rules Review Branch (CSRRB)
Water Planning Section, Division of Water Resources, Department of Environmental Quality
1611 Mail Service Center, Raleigh, NC 27699-1611
(Archdale Building)
CSRRB online: http://deq.nc.gov/about/divisions/water-resources/planning/classification-standards
Direct: 919-807 G415 707-3676 (NEW Number as of Aug 2018)
Main: 919-707-9000
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed
to third parties.
From: Snider, Holley <[e-mail]>
Sent: Thursday, November 18, 2021 11:21 AM
To: Manning, Jeff <[e-mail]>
Subject: FW: Check on chronic and acute RE: [External] Fw:
Morning Jeff,
Jim Hawhee directed me to you and I am hopeful you may be able to assist me in providing
recommendations and/or permit conditions that may be appropriate for dredging activities where
known COCs are present in the spoil material. I have attached the Engineer's response to my
request to identify the COCs. Unfortunately, some of this language and terminology is hard for me
to understand. I have also been discussing these concerns with Autumn Romanski with DWM
reading the transport and disposal of the material once it has been dried. I will forward her previous
email. I welcome and appreciate any assistance you can offer. Thanks in advance.
Sincerely,
Holley Snider ,><((((°>•, ...,,..><((((°>.•—
Environmental Specialist II
Division of Water Resources
North Carolina Department of Environmental Quality
Phone: [phone]
N(SI:T i i:Afk:n. ihN
P$MM M bN1'utrn nlsl PNs7ily
127 Cardinal Drive Ext.
Wilmington, NC 28405
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties

From: Romanski, Autumn R <[e-mail]>
Sent: Wednesday, November 17, 2021 10:35 AM
To: Snider, Holley <[e-mail]>
Subject: Check on chronic and acute RE: [External] Fw:
Holley,
Thank you for forwarding the UNC Wilm information.
When you check with WQ Planning Section, can you ask about the WQ limits reference for chronic
vs. acute.
I am unsure if chronic — would apply due to long operation of marine activities, OR if acute would
apply as an acute release could happen due to the disturbance during the project?
The note on WRE limit value is worth noting that we should understand if exceedance of WRE limit
values happens? What will that mean?
The WER shall be assigned a value equal to one unless any person demonstrates to the Division's
satisfaction in a permit proceeding that another value is developed in accordance with the "Water
Quality Standards Handbook: Second
Edition" published by the US Environmental Protection Agency (EPA-823-B-12-002), free of charge,
at http://water.epa.gov/scitech/swguidance/standards/handbook/, hereby incorporated by
reference including any subsequent amendments. Alternative site -specific standards may also be
developed when any person submits values that demonstrate to the Commissions' satisfaction that
they were derived in accordance with the "Water Quality Standards Handbook: Second Edition.
Recalculation Procedure or the Resident Species Procedure", hereby incorporated by reference
including subsequent amendments at
http://water.epa.gov/scitech/swguidance/standards/handbook/.
Thank you,
Autumn
From: Snider, Holley <holley.sniderPncdenr.gov>
Sent: Wednesday, November 17, 2021 9:56 AM
To: Romanski, Autumn R <Autumn.RomanskiPncdenr.gov>
Subject: FW: [External] Fw:
Holley Snider .•" ,><((((°>." ><((((°
Environmental Specialist II

Division of Water Resources
North Carolina Department of Environmental Quality
Phone: [phone]
GD_EQ5
P4pIl tT t'l u' Enyunnrnonitl ihull
127 Cardinal Drive Ext.
Wilmington, NC 28405
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
From: Avery, Gene <averygPuncw.edu>
Sent: Friday, September 17, 2021 12:42 PM
To: Snider, Holley <holley.sniderPncdenr.gov>
Subject: [External] Fw:
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.
Hi Holley,
Here are the papers.
Brooks
Dr. Brooks Avery
Professor of Chemistry and Biochemistry
University College faculty advisor
UNC-Wilmington
910-962-7388
[e-mail]
From: Skrabal, Stephen <skrabalsPuncw.edu>
Sent: Wednesday, September 15, 2021 11:57 AM
To: Avery, Gene <[e-mail]>
Subject:

It was Linda's work — see beginning part for some analyses from CB
Stephen A. Skrabal, Ph.D.
Professor, Department of Chemistry and Biochemistry
Graduate Program Director, M.S. in Marine Science, Center for Marine Science
University of North Carolina Wilmington
Wilmington, NC 28403-5932
[phone]
[e-mail]