20230797 Ver 1_Other Agency Correspondence_20230929

From: Behm, Pamela
To: Snider, Holley; Wojoski, Paul A; Painter, Andv; Lin in
Cc: Goss, Stephanie; Higgins, Karen; Homewood, Sue
Subject: RE: [External] RE: West Carteret Boat Ramp Flushing Model
Date: Friday, September 29, 2023 1:05:28 PM
Attachments: imaae002.ona
imaae003.inci
I'm sure other branches will have comments, but we offer the following from the modeling branch
(which are pretty much the exact same as we've already provided.
There are three key steps from the Marina Planning guidance document that are impacting
Modeling Branch review because these steps were not followed:
From page 15 — "All models used must be in open format (no proprietary models) and
all data used to populate models must be included."
From page 16 — "Pre -project sampling locations and parameters must be pre -approved
by DWQ..."
From page 17 — "Consultations with DWQ at an early stage in the project proposal can
greatly enhance the prospect of achieving a successful marina development. Once the
various site assessments and technical analyses have been completed, it will be possible
to prepare a preliminary development proposal. It is advisable the developer "Scope"
the process with DWQ before commencing work on preparing project proposals.
Scoping meetings are an excellent avenue to discuss project feasibility with various
permitting authorities and give the developer an early indication of the views of the
permitting authorities."
The model described in the memo is not open format. This is a real sticking point and the reason
why it is critical to meet with DWR prior to beginning a project to make sure cases like this don't
happen. Collected data were not submitted either (first bullet above).
The model review process and model performance criteria should be based on the model's usage.
We are not clear how the model was used by the other state agencies and what kind of model
review process is used by those agencies (e.g. regulatory decision making or scoping). Regardless,
DWR Modeling Branch will not review the model because it does not meet our requirements and we
have no in-house expertise anyway.
The best we can do is provide comments on the submitted report:
1. As currently written in the provided memo, the flushing capability was assessed using MIKE21
by releasing dye (conservative tracer) at one point of the basin for 20 min at the
concentration of 100. The time series of dye concentration was then used to assess flushing.
In fact, the time series of dye concentration at the releasing point is heavily influenced by
how much (or how long) dye was released. It's a function of both mixing (with neighboring
cells) and tidal flushing. In order to look at the capability of tidal flushing in the basin, either
dye needs to be released into the entire basin (e.g. initial condition set to 100) or, for current

model scenario, the time series of total volume of dye within the entire basin needed to be
assessed.
2. Model calibration was mentioned in the document, but calibration results were not shown.
3. Boundary condition is critical to the well representation of tidal flushing capability
represented in this model, a detailed description or a good reference to the "Flather
condition" is needed to clarify the boundary condition used. In addition, "average tide" and 5
tidal constituents are both mentioned in the MEMO, but more detailed descriptions should
have been included.
From: Snider, Holley <[e-mail]>
Sent: Wednesday, September 27, 2023 1:46 PM
To: Behm, Pamela <[e-mail]>; Wojoski, Paul A <[e-mail]>;
Painter, Andy <[e-mail]>; Lin, Jing <[e-mail]>
Cc: Goss, Stephanie <[e-mail]>; Higgins, Karen <[e-mail]>;
Homewood, Sue <[e-mail]>
Subject: RE: [External] RE: West Carteret Boat Ramp Flushing Model
Good afternoon All,
Carteret County replied to the DWR RFAI that included the comments on the flushing model from
your section in the email below. The attached document is in response to those comments. Please
take a moment to moment to review and provide comment. Thanks in advance for you assistance.
Sincerely,
Holley Snider -
Environmental Specialist II
Division of Water Resources
North Carolina Department of Environmental Quality
Phone: [phone]
*please note my email address has changed [e-mail]*
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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: Behm, Pamela <pamela.behm(@deq.nc.gov>

Sent: Friday, July 7, 2023 3:12 PM
To: Snider, Holley <holley.snider(@deq.nc.gov>; Wojoski, Paul A <Paul.Woioski(@deq.nc.gov>;
Painter, Andy <and)1_painter(@deq.nc.gov>; Lin, Jing <6ing.lin(@c1eq.nc.gov>
Cc: Goss, Stephanie <stephanie.goss(@deg. nc.gov>; Higgins, Karen <karen.higgins(@deq.nc.gov>;
Homewood, Sue <sue.homewood(@deq.nc.gov>
Subject: RE: [External] RE: West Carteret Boat Ramp Flushing Model
Hi Holley,
One issue is we don't know this model, so I'm not sure how we can review it, even if we somehow
found time to have them provide training and pay for a subscription. This model isn't something we
would allow for NPDES permitting because it is not free, I don't know that 401 should be any
different. Bottom line is, if a model is needed. I don't know how we can use what they gave us. It's
a shame really, this is the reason we ask for a modeling study plan prior to wasting money on
something we can't use.
Is there a way to use what they've given us without us expressly approving the model? Here are
some of Andy's initial comments:
1. I'm not familiar with the TOPEX/POSEIDON global tidal model they got hydrodynamic
conditions from and what time frame they used. I'm not familiar with the model or
the coefficients used, and the model is not free.
2. Based on newer design of the basin, in my opinion the basin would have no problem
flushing and the model results sound reasonable. Had the newer design been
proposed initially I don't think modeling would have been necessary.
3. 1 looked up DO near the project yesterday (images attached). The data ends a while
back but DO looked good and I don't see DO being an issue here.
4. FYI, there is a much larger upland basin with a worse design than the proposed here,
0.6 miles up the intracoastal; that could have been monitored for a worst case
scenario.
Happy to have a group call to strategize if necessary.
Thanks,
Pam
From: Snider, Holley <holley.snider(@deq.nc.go >
Sent: Friday, July 7, 2023 2:29 PM
To: Behm, Pamela <pamela.behm(cDdeq.nc.gov>; Wojoski, Paul A <Paul.Woioski(@deq.nc.gov>;
Painter, Andy <andy_painter(@deq.nc.gov>
Cc: Goss, Stephanie <stephanie.goss(cDdeq.nc.gov>; Higgins, Karen <karen.higginsPdeq.nc.gov>;
Homewood, Sue <sue.homewood(@deq.nc.gov>
Subject: RE: [External] RE: West Carteret Boat Ramp Flushing Model

Hey Pam,
I certainly wish they had consulted with us as well. The applicant and consultant were advised
during multiple interagency scoping meetings that the modeling and DO info would need to be
reviewed by DWR. During those meetings the applicant had not quantified impacts associated with
the development of the site nor provided any basin or channel dimension plans for review. The
circulation of the CAMA major permit application to the resource agencies for comment is the first
presentation of all of the impacts proposed, the ramp, channel, basin design, etc. If your group
requires more information on the model utilized for DWR to complete a thorough analysis of the
report submitted, please advise ASAP. DWR is able to place the 401 review 'on -hold' pending
receipt of the information that will allow you to review the model, the results and provide
comment. I am happy to communicate your request for the model information to the applicant and
consultant if necessary.
The DWR 60-day deadline to take action in accordance with 15A NCAC 02H .0507 is 8/4/23.
Thanks again for your assistance.
Sincerely,
Holley Snider.' -
Environmental Specialist II
Division of Water Resources
North Carolina Department of Environmental Quality
Phone: [phone]
*please note my email address has changed ho11ey.sniderPdeq.nc.gov*
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tlpjiarin eiil of lnri�onnl0nl+l u.,.,e
127 Cardinal Drive Ext.
Wilmington, NC 28405
From: Behm, Pamela <pamela.behmPdeq.nc.gov>
Sent: Friday, July 7, 2023 11:09 AM
To: Snider, Holley <holley.snider(@deq.nc.gov>; Wojoski, Paul A <Paul.Woioski(@deq.nc.gov>;
Painter, Andy <and)1_painterCcDdeq.nc.gov>
Cc: Goss, Stephanie <stephanie.goss(@deq.nc.gov>; Higgins, Karen <karen.higgins(@deq.nc.gov>
Subject: RE: [External] RE: West Carteret Boat Ramp Flushing Model
Hi Holley,
When do you need comments? I wish they had consulted with us first, I'm not sure how much help
we can provide as we are not familiar with the model they used.
Thanks,

Pam
From: Snider, Holley <holley.snider(@c1eq.nc.gov>
Sent: Wednesday, July 5, 2023 4:31 PM
To: Wojoski, Paul A <Paul.WoioskiPc1eq.nc.gov>; Painter, Andy <andy_painter(@deq.nc.gov>; Behm,
Pamela <pamela.behm(@c1eq.nc.gov>
Cc: Goss, Stephanie <stephanie.goss(@deq.nc.gov>; Higgins, Karen <karen.higgins(@deq.nc.gov>
Subject: FW: [External] RE: West Carteret Boat Ramp Flushing Model
Good afternoon All,
Please review the attached document and provide comments when you are able, including the lack
of information provided regarding DO. The project is a new proposed Western Carteret County Boat
ramp facility (20230797). As always, I thank you in advance and appreciate your assistance. Let me
know if you have any questions.
Sincerely,
Holley Snider.' -
Environmental Specialist 11
Division of Water Resources
North Carolina Department of Environmental Quality
Phone: [phone]
*please note my email address has changed holley.snider(@deq.nc.gov*
WIE
�Op>n[1 a d o1 6n�aromf Ial Quality.
127 Cardinal Drive Ext.
Wilmington, INC 28405
From: Huggett, Douglas <dhuggett(@moffattnichol.com>
Sent: Wednesday, July 5, 2023 11:20 AM
To: Bodnar, Gregg < regg.bodnarPdeq.nc.gov>
Cc: Hair, Sarah E CIV CESAW CESAD (US) <Sarah.E.Hair(@usace.army.mil>; Snider, Holley
<holley.sniderPdeq.nc.gov>; Huggett, Douglas <dhuggett(@moffattnichol.com>
Subject: [External] RE: West Carteret Boat Ramp Flushing Model
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Gregg
I apologize for that — I looked into this and you are correct that it does not look like I uploaded the
flushing study. The study is attached. By copy of this email, I am also sending a copy of the flushing
study to the Corps and DWR.

Please let me know if you have any questions on this.
Sorry again about the confusion.Doug
lDo-tAq,7 f uV9-eit
Environmental Permit Specialist/Project Manager
Moffatt & Nichol
305 Commerce Ave.
Morehead City, NC 28557
Main 919.781.4626 ext.12149
Direct 919.645.0649
Cell 919.534.6834
Creative People, Practical Solutions. 11
From: Bodnar, Gregg <gregg.bodnar(@deq.nc.gov>
Sent: Wednesday, July 5, 2023 10:58 AM
To: Huggett, Douglas <dhuggett(@moffattnichol.com>
Subject: West Carteret Boat Ramp Flushing Model
CAUTION: This email originated from outside of the organization.
Morning Doug,
Is the flushing model available? And was it uploaded into the ePermit system? I cannot locate it.
Thanks,
Gregg
Gregg Bodnar (he/him/his)
Major Permits Coordinator
Division of Coastal Management
North Carolina Department of Environmental Quality
[phone] (NEW OFFICE NUMBER)
As part of DEQs phased email update, all Division of Coastal Management emails are now
@deq.nc.gov. Please note my new email address (gregg.bodnar(a deq.nc.gov). Our email addresses
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Department of Environmental Quality
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Carolina Public Records Law and may be disclosed to third parties.
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parties by an authorized state official.