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Home My WebLink About20190397_RE R-2566BA Toxicity comments_20180820Carpenter,Kristi From: Hollenkamp, Carol Sent: Monday, August 20, 2018 4:01 PM To: Wanucha, Dave Cc: Moore, Cindy Subject: RE: R-2566BA Toxicity comments H i Dave, Cindy and I reviewed the information you provided for CMA. Based on this information, there does not appear to be substantial aquatic toxicity concerns with the occasional use of the product for deicing during the winter. Based on the data provided, we would not anticipate acute toxicity if the CMA concentration in the stream remained at 250mg/L or below for a shorter period of time, and we would not anticipate chronic toxicity if the CMA concentration in the stream remained below 25 mg/L for an extended period of time (such as 7 days). We calculated those values from the CMA PNS Biomonitoring results. These results indicate chronic effects at 0.5 g/L (500 mg/L). The acute No Observed Effect Level was 0.25g/L (250 mg/L) for both the Ceriodaphnia (an invertebrate) and Fathead Minnows (vertebrate). These acute and chronic effect levels appear to be among the most conservative (offering the most protection) from the material provided. The CMA applications would most likely result in exposures that were acute (24-96 hrs) rather than long term chronic exposure (7 or more days). However, to provide chronic protection in the event that chronic exposure might occur, we can apply an acute to chronic ratio of 1:10 as recommended in the EPA Technical Support Document for Water Quality Based Toxic Control. This would mean a chronic effect would not be expected at a long term exposure concentration of 25 mg/L. In reading the material provided, it appears that CMA breaks down into calcium, magnesium, and acetate. The acetate breaks down and uses oxygen in the process. However, I would not think oxygen depletion would be an issue in the Watauga River in the winter. It does not sound like CMA would persist in the water for chronic, long term exposures. The Environmental Evaluation of CMA document (1985) has a long term No Observed Effect Chronic Level of 125 mg/L. The same study does show an chronic effect for Daphnia Magna at 250 mg/L. This data supports that information provided in the CMA PNS. The Chemical Deicers in the Environment book and the New Zealand environmental effects monitoring report also indicates that risk to the aquatic environment is negligible. The New Zealand study indicated that negative effects would mostly be restricted to areas where the runoff went into a small enclosed waterbody. The Watauga does not sound like it would fit into that situation. A final thought is that is sounds as though the current bridge and system already uses this product. Would the proposed bridge be similar in the application and amount of i runoff that would occur? It sounds as though the biological community has been in good condition with the historical use of the product on the bridge. Please feel free to call or email if you would like to discuss further. Thanks, Carol Hollenkamp Environmental Specialist Aquatic Toxicology Branch/Water Sciences Section/Division of Water Resources Department of Environmental Quality 919-743-8440 office Carol.hollenkamp@ncdenr.gov Mailing: 1621 Mail Services Center, Raleigh, NC 27699-1621 Physical: 4401 Reedy Creek Road, Raleigh, NC 27607 x�: ' x�:. a�� ,��s�� `��,� ��,�,� �,� ,��.�� `�� 'J��`� �°�� .�� :�,� ��W�r �� .� �� ,��,�� :s��,�. From: Wanucha, Dave Sent: Friday, August 10, 2018 9:58 AM To: Moore, Cindy «i_n_d.y.:_a.._m�ca.cr_re(�_n�den_r.:�crv> Subject: FW: R-2566BA Hi Cindy, Would your group take a look at the deicer and let me know if there are aquatic toxicity issues to be concerned about? This is a controversial bridge replacement project because of the occurrence of the hellbender and long tail salamander. We're meeting out there on August 22 with WRC, FWS, and DOT and it would be great if we could have some input by then. Thanks. Dave Wanucha Division of Water Resources Transportation Permitting Unit NC Department of Environmental Quality 336-776-9703 office 336-403-5655 mobile ��u�_.�OV�ii�_u�lh�_�u��d�u�ir.ar�u NC DEQ Winston Salem Regional Office 450 West Hanes Mill Road, Suite 300 Winston Salem, NC 27105 a�� ,��s�� `��,� ��,�,� �,� ,��.�� `�� 'J��`� �°�� .�� :�,� ��W�r �� .� �� ,��,�� :s��,�. From: Zerman, William S Sent: Thursday, August 09, 2018 2:30 PM To: Chambers, Marla J<rrr�a_rla.:_charrr�_�ers_(c�_n_�wi.l_dl.i�e_:cr_r�>; Wanucha, Dave <dave_:wa_n_u�ha_..C,�_n_cd_e_nr.:.�crv>; �e.l.l_wa_n.�er(c�_fiws..�ca.v; Patterson, Robert D <rcrk�ert.�atte_rscrnC�_n�d_e_n_r:.�crv>; Steve Kichefski <Steven.I.kichefskiC�_�a.sa�e.._a_rm�.y.:_m�i.l>; ................................. . ......_. _ ...................................................................................� . ...._... rn�a_re.l I_a....._� u n�i c_k..C,�.�.ws.:.�ca.v Cc: Lipscomb, Brian S<�I.i�s�ca.rn��(c�_n�dcrt...�ca.v>; Adima, Nathan N<na_d.i_rn�a(c�_n�dcrt.:.�ca.v> Subject: R-2566BA � r . ��'�� ,� �,� , � Th�r� is a holding tank insid� a small pump station building b�sid� th� bridg�. Th� Cryot�ch CMA granul�s ar� mix�d vvith vvat�r in th� holding tank and spray�d on th� bridg� as n��d�d d�p�nding on vv�ath�r conditions. Th� stirring and spraying of tanks is activat�d via c�ll phon�. htt�r..:../..�www..�r.yca.tech_:�ca_rrr�./�rycatec_h.-�rrr�_a.-cca_rrr�_rrr� e rci a_I If there are any concerns with the deicer, please let me know. � William (Bill) S. Zerman, Jr., PE Project Manager Project Management Unit — Divisions 11-14 North Carolina Department of Transportation 919 707 6755 office 919 810 8990 mobile bzerman@ncdot.�ov 1000 Birch Ridge Drive Raleigh, North Carolina 27610 1582 Mail Service Center Raleigh, North Carolina 27699-1582 a�� ,��s�� `��,� ��,�,� �,� ,��.�� `�� 'J��`� �°�� .�� :�,� ��W�r �� .� �� ,��,�� :s��,�. I rr�7all �:urrc,��u � � � � � � � � y I�c rli��;lu�e,rl �u �C�h•ih�rl I i� ci��;e, Cu ai� rur°r7 �mii;, ;;e,i� cr i;, ;;u� ��;� �u Cmie, ,..,u� i�; ta�:ur�: ;, ..,aw ai� ir7a, I�arti��,