1

Weitzler Ellen

From Kavanah Brian W BrianWKavanah mainegov

Sent Monday September 16 2013 237 PM

To Weitzler Ellen

Cc Margerum Mark T Sheehan Bill J Wood Gregg PamelaDParker mainegov

Subject RE adopted revision of phenol for consumption of water organism

Thanks Ellen

As per your phone message regarding this issue and the email below we agree that

we miscalculated the criteria for phenol Maine DEP’s intent is to correct this

mathematical error during the next opportunity for rulemaking

Brian Kavanah

Director Division of Water Quality Management

Bureau of Land and Water Quality

Maine Department of Environmental Protection

Station 17 Augusta ME 04333

207 2877700

www maine gov dep

brianwkavanah mainegov

From Weitzler Ellen mailtoWeitzlerEllenepa gov

Sent Wednesday September 04 2013 128 PM

To Kavanah Brian W

Cc Margerum Mark T

Subject FW adopted revision of phenol for consumption of water organism

Hi Brian

Here’s the phenol calculation That you sent me for phenol As you can see Bob calculated the criteria for water

organisms as follows

AWQC RfD x RSC x BW DI FCR xBCF x 1000 ugmg

However the correct formulais

AWQC RfD x RSC x BW x 1000 ugmg

DI FCR x BCR

I can see where he might have misinterpreted the reference he used An additional parenthesis might have helped in

the expression of the equation in that reference Nevertheless the units just don’t work out the way it was calculated

and the value is higher than it would be if calculated correctly

Best regards

Ellen

Ellen Weitzler PE

Water Quality Standards Coordinator

EPA003534
2

USEPA New England Region 1

5 Post Office Square Suite 100

Boston MA 02109 3912

Tel 617 918 1582

From Kavanah Brian W mailtoBrianWKavanah mainegov

Sent Monday July 22 2013 512 PM

To Weitzler Ellen Margerum Mark T

Subject RE adopted revision of phenol for consumption of water organism

Hi Ellen

I looked through Bob’s rulemaking files and found this Page 2 has his

calculations Please let me know if this clarifies the issue for you

Thanks

From Weitzler Ellen mailtoWeitzlerEllenepa gov

Sent Monday July 22 2013 952 AM

To Margerum Mark T

Cc Kavanah Brian W

Subject adopted revision of phenol for consumption of water organism

Hi Mark

I’m working on the approval letter for acrolein and phenol in state waters

Using the EPA methodologies and Maine’s fish consumption rate of 32.4 gmday I was able to calculate human health

criteria for acrolein that agreed with Maine’s adopted revisions to 3.9 ugL for consumption of water organisms and

5.0 for consumption of organismsonly I was also able to calculate the human health criteria for phenol for

consumption of organisms only that agreed with Maine’s adopted revision to 462,963 ugL

However I was not able to derive Maine’s adopted revision of the phenol criteria for consumption of water organisms

to 10,514 ugL

Using the following criteria derivation equation forAmbient Water Quality Criteria AWQC

AWQC RfD x RSC x BW DI FI x BAF see parameter definitions and values below

leads to a criteria of 10,267 ugL

Please let me know if you have made any other assumptions regarding the parameters below or any other revision to

the methodology to account for the difference

Thanks

Ellen

Human Health Criteria for Phenol for

consumption of Water and Organisms

EPA003535
3

RfD Reference Dose inmgkgday 0.3

RSC Relative Source Contribution to

account for other sources of exposure as a

of total exposure 1

BW Human Body Weight for average

adult in kg 70

DI Drinking Water Intake for average

adult in Lday 2

FI fish Intake in kgday 0.0324

BAF bioaccumulation Factor in Lkg or

BCF if no BAF 1.4

AWQC inmgL 10,267

Ellen Weitzler PE

Water Quality Standards Coordinator

USEPA New England Region 1

5 Post Office Square Suite 100

Boston MA 02109 3912

Tel 617 918 1582

EPA003536