Buhec Heaty People Haaty Communes September 13, 2019 Colone Daniel Hibner Commander US. Army Corp of Engineers, Savannah District 100 West Oglethorpe Avenue Savannah, Georga 31401-0869 Dear Colonel Hiner: In accordance with the Compromise and Settlement Agreement (the Agreement, finalzd on May 22, 2013, the purpose ofthis iter to provide the South Carolina Department of Heath and Envcnmental Conta’ (DHEC) evaluation of the Water Column Transfer EMciency Report and Test Run Data Colection and Madkling Report (Transfer Efclency and Test Run Reports) provided by the U.S. Army Corps of Engineers (Corps) on August 15,2019. “The Transfer fiency Report evaluates a key assumption n the solved oxygen impact milton ‘modding anaiyss. The Test Run Report evaluates the fist phase of testing ofthe dissolved oxygen facity and was provided to DHEC, and ethers, fora 30-day review as requred by the Agreement. The second ‘hase of testing requle by the Agreement, the Start-up Run Is Fequired to take piace during the sumer ‘months. The Department offers the folowing general comments on the Transfer Efficiency and Test Run reports. COnce the superoxygenated flows are delivered tothe dfusersin the rier, sucessful mitigation of dlssolved ‘ygen impacts largely depends on two factors. Fist the Injected oxygen must be mixed in the bottom waters and avoid any igifcant effervescent or diffusive loss tothe atmosphere. Second, once entrained, ‘enough oxygen mus then be transported tothe affected areas in the estuary to ost the impacts of the project. The retention and spreading ofthe injected oxygen must be effective ring te summer when ‘gen levels in the ever are lowest. {In accordance with the Agreement, the Corps has conducted testing and data callecton forthe Transfer EMicency and Test Run studes ding the months of February, March, Apri and May. These studies appear to demonstrate effective oxygen transfer and transport under certain énvronmental condor, namely (1) the cooler months wher the data collection and model simulations wee conducted and (2) normal and sping tide conditions which hve larger tidal ranges and higher tidal vlotes and flows compared to neap des. However, thre sno testing, data, or modeling presented that represents erica! condtions during July, ‘August and September when the system will actualy be operated. Furthermore, in accordance with the Agreement, the Corps" Test Run evaluation Includes only 30 percent of ‘he total oxygen input to the harbor. The remainder wal come from the upriver plant which fs cureny under ‘onstruction end willbe elude Uwe Sar-up Run testing ws speed In the Agerent. In addition tothe Corps data, DHEC contracted withthe USGS te conduct Independent monitoring n Back River dig testing, ‘Tre USGS deployed Autonomous Underwater Vehicles (ALVs) to measure dssohed -axygen (00), water temperature, specie conductance and other parameters throughout the water column ‘the area around the Back River dfs. ‘The AUV monitoring focused on or cose to slack tide contons on ‘three dates, February 2" during the Transfer ffiency study and Apel 11° and May 1 during the Test Run ‘study. This effort resulted in tree short-term but very dense 3-dmenslonal datasets with avery large ‘umber of measurements in the area around the Back River injection ste. The complete dataset and ‘sessment tool are puttshed onthe USGS webste at: hns//doLora/1O.O68/PSTTSCST. DHEC st have 'SC.Departmentof Heath and Emironmental Conta 2600 Bul Sweet Cohiba SC2S201 (O3E883422 wesleyUs Army Corps ~ Sept. 13, 2019 9.2 concluded thatthe USGS data are consistent overall with the Corps data. The USGS data show ite ‘opportunity fr oxygen ess fom the river (high tener effciency) on February 11° and Apt 11° and Increased potentat for oxygen loss (possibly Inceating reduced transfer efclency) on May 1". The Corps reports reduced trense efficiency on Back ver forthe full week begining Apel 25" though May 1 ‘Nong with the USGS AU data, OHEC staf separately collected surface and profile measurements on Api {and May 1%. Alrge numberof individual measurements of dssoWed oxygen, water temperature, specie conductance end other parameters were taken. DHEC's data are conastent with the USGS and Corps data in icing ite opprtuny for oxygen lass from the ver on Api 11” and increased potential fr oxygen logs on May 1*. In adation, DHEC also collected water samples before the de release on May 1" for laboratory analysis ofclorophyl-, Results showed elevated chorophyl levels of 6 and 79 ug/L, possibly Inceating an algal contibuton tothe supersaturated oxygen conltons observed near the surface In Back River on May 1" and perhaps the week before. In any case, there appears to have been a source of excess ‘angen in Gack River net accounted for nthe model based on comparison of Test Run Report Hgures 6-14 and 6-15 with Figures 624 and 6-25. In accordance wth the Agreement, DHEC, "wl independenty evaluate the Test Run report and other relevant information to assess achievement ofthe Success Ctra,” Given the issues noted ln this etter ‘oncerring testing outste ofthe crcl conditions ec, DHEC Is unable to determine whether the Success Citeria have been met. Since the future Start-up un wil be conducted during the sumer months anc wl ince the ful oxygen injection capacty, DHEC ks wltholding judgement on whether the Success Crea have been achieved und aftr the completion of the Start-Up Run TT you have any questions concerning this eter, please contact Heather Preston at 803-898-3105 or by email at prestahsedhee.segev. ike Marcus, Ph. Chief, Bureau of Water