20190752 Ver 4_2020-08-12 RPT Chemours WOTUS Flow-through Cells, Seep C Pilot Study, Seep A Revisions Draft V1_20200813

Waters of the United States Technical Report
The Chemours Company
Fayetteville Works Project
Flow -through Cells,
Seep C Pilot Study,
no Wei
Revised Seep A
Bladen County, North Carolina
Prepared by:
PARSONS
August 2020

Table of Contents
Table of Contents
INTRODUCTION.......................................................................................................................1
Introduction......................................................................................................................................................1
ProjectLocation and Background..................................................................................................................1
AgencyField Review Meeting.......................................................................................................................2
METHODOLOGY....................................................................................................................... 4
DesktopReview...............................................................................................................................................4
NWIand Floodplain Mapping........................................................................................................4
USGSMapping..................................................................................................................................4
NRCSSoil Mapping..........................................................................................................................4
Watersheds.......................................................................................................................................................4
FieldReconnaissance.......................................................................................................................................5
RESULTS....................................................................................................................................... 5
Wetlands...........................................................................................................................................................5
RevisedSeep A Wetlands.................................................................................................................5
SeepB Wetland..................................................................................................................................5
Seep B Temporary Crossing Wetland.............................................................................................6
SeepC Wetland - Pilot Study........................................................................................................... 6
SeepD Wetland.................................................................................................................................6
Streams..............................................................................................................................................................5
CONCLUSION............................................................................................................................7
REFERENCES............................................................................................................................... 8
LISTOF ACRONYMS................................................................................................................9
APPENDIX A —MAPPING
Project Area Vicinity Map
Project Plans
NWI Map
USGS 7.5-Minute Topographic Map — Duart Quadrangle
USGS 7.5-Minute Topographic Map (Excerpt)
FEMA Map
i

NRCS Soil Map
APPENDIX B — WETLAND DETERMINATION DATA FORMS AND PHOTOGRAPHS
APPENDIX C — STREAM DATA FORMS AND PHOTOGRAPHS

Introduction
Introduction
Introduction
This Waters for the United States (WOTUS) report presents the results of a field survey conducted on behalf
of The Chemours Company FC, LLC (Chemours). On May 18-19, 2020, a field survey was conducted by
Parsons to determine the location and extent of any potential WOTUS, including wetlands and
waterbodies, that would be regulated by the Clean Water Act (CWA) and/or Section 10 of the Rivers and
Harbors Act (RHA) subject to the jurisdiction of the United States Army Corps of Engineers (USACE) and
the United States Environmental Protection Agency (USEPA). The field survey was also conducted to
determine the location and extent of any potential Waters of the State which include any wetland, stream,
or waterbody as defined in North Carolina's General Statute 143-212.
Project Location and Background
On July 1, 2015, The Chemours Company, a spin-off company from DuPont, became the owner of the 2,177-
acre property along with DuPont's manufacturing units. The Chemours Company continues to use the
property as a manufacturing facility (Fayetteville Works) of plastic sheeting, fluorochemicals, and
intermediates for plastic manufacturing.
The Chemours Company Fayetteville Works Project area is located approximately 15 miles southeast of
the City of Fayetteville in Bladen County, North Carolina. The 2,177-acre site is relatively flat and has
undeveloped, open land and woodland. It is bounded on the east by the Cape Fear River, on the west by
North Carolina Highway 87, and on the north and south by farmland.
On February 25, 2019, the North Carolina Superior Court for Bladen County entered a Consent Order (CO)
among The Chemours Company FC, LLC (Chemours) and the State of North Carolina and Cape Fear River
Watch to address discharges of perfluoroalkyl and polyfluoroalkyl substances (PFAS) at the Chemours
Fayetteville Works (the Site). Among other things, the CO requires Chemours to develop a remedial plan
for reducing PFAS loading from Old Outfall 002 at the Site to the Cape Fear River. Design and
implementation details for near -term remedial actions at the facility have been developed' (Parsons 2018).
Ongoing planning documents addressed PFAS releases to groundwater from historical and current
operations. An option considered in these documents included the capture and pumping of groundwater
to a new wastewater treatment facility designed to treat PFAS. Two pump station locations were
considered; however, the study area discussed below is the only pump station location currently being
considered. According to the CO, Chemours shall implement measures to reduce PFAS loading to the Cape
Fear River that will achieve the reduction in controlling indicator parameters [GenX and PFMOAA]. To
meet this PFAS reduction, Chemours will construct instream flow -through structures in four streams. The
instream flow -through structures would each create a very small impoundment above a gabion filter basket
' Per a Consent Order, dated February 25, 2019, The Chemours Company denies any violation of any law,
regulation or permit, and has agreed remediation to avoid the expense, burden, and uncertainty of
litigation and to address community concerns about the facility.
1

Introduction
that is designed to minimize the PFAS entering the Cape Fear River. Note that the consent order is currently
being updated which could affect project milestones.
The study area that encompasses approximately 55 acres is located north of Glengerry Road in the Cape
Fear River floodplain extending north and parallel to the river to approximately 200 yards south of the
mouth of Willis Creek, crossing four unnamed tributaries to the Cape Fear River (Seep A, B, C, and D). All
of these streams have a perennial flow that originates in groundwater seepage from the adjacent uplands
that includes most of the east side of the Fayetteville Works facility. The streams also receive stormwater
flow and occasional backwater flooding from the Cape Fear River. Detailed mapping of the project area is
provided in Appendix A. On May 18-19, 2020, a field survey was conducted by Parsons to determine the
location and extent of any potential WOTUS within the study area for the proposed flow -through cell
project. This report presents the results of that field survey.
Agency Field Review Meeting
An agency coordination meeting with the Wilmington District, U.S. Army Corps of Engineers (USACE)
and the North Carolina Department of Environmental Quality (NCDEQ) Division of Water was held at the
Chemours Fayetteville Works Facility on June 30, 2020. Following a tailgate safety meeting and
coordination with Chemours safety personnel, a walking tour of the Cape Fear River floodplain east of the
Fayetteville Works facility was completed.
There were four primary objectives for this agency meeting:
1) to review the flow -through cell locations that were proposed in the June 3, 2020 NWP 38
application;
2) to survey the WOTUS resources (i.e. regulated streams and wetlands) in the project area;
3) to discuss the long-term WOTUS implication from a groundwater extraction/barrier wall project;
and
4) to discuss potential future mitigation for impacts to WOTUS from a groundwater
extraction/barrier wall project.
The areas known as Seeps B, C, and D were visited during the field review. At each location the seep
landscape, proposed flow -through cell design and location (per the June 3, 2020 submittal), and the WOTUS
resources were discussed. Mr. Chris Shores indicated that the structures would likely not be those proposed
in the original June 3, 2020 NWP 38 application. He explained that the current plan is to prepare a pilot
study installation at Seep C. Geosyntec's new design would likely require concrete. Ms. Greer explained
that the USACE has regulations against pouring raw concrete into WOTUS, which would require that the
structures are either pre -cast, or flow would have to be diverted during construction per USACE
guidelines. Mr. Shores further explained that the Seep C structure would be a pilot study that would last
for 90 days to ensure that the structures function as designed. The agencies supported this approach, and
Ms. Greer suggested that since the design would change, Chemours should recall the current NWP 38
permit application (Project Action ID Number SAW-2019-00206). Mr. Turlington said that he would
determine what procedure the NCDEQ would follow to recall the permit. NCDEQ may require a formal
letter requesting that the permit be recalled. Note: the previous NWP 39 PCN was withdrawn on July 15,
2020, and the pilot study flow -through cell at Seep C will be permitted as an individual permit (IP).
A discussion of the current NWP and the impacts to WOTUS, including the access/roadway crossings of
WOTUS, occurred throughout the survey. The USACE and NCDEQ concurred with the WOTUS field
determinations completed by Parsons. Hydric soils were examined in several locations in wetland areas.
Mr. Turlington asked that the entire floodplain and the area that will be impacted by future per- and
polyfluoroalkyl substances (PFAS) reduction measures (i.e., groundwater extraction/barrier wall project)
be completed. Mr. Eggering explained that the entire area will be surveyed and mapped, however the NWP
2

Introduction
areas were surveyed first to expedite approvals for the construction of flow -through cells in compliance
with the current Consent Order. Mr. Turlington was satisfied that the entire impacted area will be
delineated, and that future WOTUS mapping would reflect all of the streams and wetlands that could be
affected.
3

Methodology
!J
Methodology
Desktop Review
Prior to field investigations, a desktop analysis of available information was reviewed, and potential
wetland areas were identified using published data, including: National Wetlands Inventory (NWI) maps;
United States Geological Survey (USGS) 7.5-minute series topographic maps; and Natural Resources
Conservation Service (NRCS) soil mapping for Bladen County, North Carolina.
NWI and Floodplain Mapping
The NWI mapping was used as an initial screen to determine locations of potential water resources within
the project area. NWI wetlands are illustrated in the detailed mapping provided in Appendix A. Wetlands
on NWI maps are classified in accordance with (Cowardin et al. 1979).
USGS Mapping
During review of USGS 7.5-minute series topographic mapping (Appendix A), there were no blueline or
intermittent streams mapped within the project area. The Cape Fear River is a 202-mile long river that
touches parts of Harnett, Cumberland, Bladen, Columbus, Pender, Brunswick, and New Hanover counties
in North Carolina before emptying into the Atlantic Ocean.
NRCS Soil Mapping
NRCS database includes a listing of soil map units that relate to specific soil series. A soil series is the
lowest, most homogeneous class in the soil taxonomy system. Each soil series has distinct soil attributes
that are defined by the NRCS. The soil attributes include physical and chemical properties and interpretive
groupings produced by the NRCS, including attributes that relate to potential soil impacts. Examples of
those soil attributes include the topographic setting and average slope, hydric soil conditions, drainage
characteristics, susceptibility to water and wind erosion, and suitability for use as farmland. The NRCS
classifies each soil type as follows: hydric (100%), predominately hydric (66-99%), partially hydric (33-65%),
predominately non-hydric (1-32%), and not-hydric (0%).
Hydric soils are soils that are inundated with water long enough to produce anaerobic conditions, and they
are an indicator of jurisdictional wetlands. Generally, hydric soils are those soils that are poorly drained or
very poorly drained. Hydric soils may indicate the presence of wetlands or high-water tables.
According to the Soil Survey Geographic Database, two mapped soil units fall within the study area of
Fayetteville Works flow -through cell project: Congaree silt loam, frequently flooded (Cn) (primarily in the
Cape Fear River floodplain) and Wickham fine sandy loam, 1-6 percent slopes (WmB), (predominantly at
the toe of slope between the Cape Fear River floodplain to the east and the uplands to the west). NRCS soil
map units are illustrated in the detailed mapping provided in Appendix A.
Watersheds
The Chemours Company Fayetteville Works Project is located within the following hydrologic unit code
(HUC) 12-digit watersheds: Phillips Creek -Cape Fear River (030300050104). The Phillips Creek -Cape Fear
River watershed has an area of 44.0 square miles (NCWSN 2019). Landcover types within this watershed
include wetlands (33.0%), agriculture (19.1%), shrubland (16.7%), grassland (2.1%), forest (24.4%),
developed (2.9%), and open water (1.8%) (NCWSN 2019).
4

Methodology
Field Reconnaissance
A field survey was conducted on May 18-19, 2020 to determine the presence of streams, wetlands, and
other water resources within the project area (i.e., the proposed flow -through cell areas). An additional
field survey was conducted on June 16, 2020 in the vicinity of Seep A. Wetlands, streams, and other waters
were evaluated in the field and mapped with a handheld Global Positioning System (GPS) unit (Trimble
Geo7x). Data were recorded on applicable datasheets and features were photographed. The GPS data was
converted to ArcGIS shapefiles, data was attributed, and entered into the project GIS database.
Wetlands were delineated using guidance set forth in the 1987 Corps of Engineers Wetlands Delineation
Manual (USACE 1987) and the Regional Supplement to the Corps of Engineers Wetland Delineation Manual:
Atlantic and Gulf Coastal Plain Region (Version 2.0) (USACE 2010). Data points were taken in locations that
exhibited one (or more) wetland indicators based on visual observations and for upland locations adjacent
to the wetlands. If all indicators were missing, no formal data was collected.
Streams were evaluated using the 2010 North Carolina Division of Water Quality (NCDWQ) Methodology
for Identification of Intermittent and Perennial Streams and Their Origins (NCDWO 2010). The upstream
drainage area for each stream was calculated using StreamStats Version 4.3 (USGS 2019). All streams were
photographed and mapped with a GPS unit.
5

Results
Results
Wetlands
The May 18-19, 2020 field investigation resulted in the identification of four, likely jurisdictional, wetlands
in the vicinity of the flow -through cell project area. Approximately 0.696 acres were delineated in the four
wetland areas, however all the wetlands are larger than the delineated area. The June 16, 2020 field
investigation resulted in the identification of four additional, likely jurisdictional, wetlands in the vicinity
of the flow -through cell project area near Seep A. Approximately 0.15 acres were delineated for two
potential flow -through cell locations for Seep A and approximately 0.19 acres of two potential road
crossings near Seep A were identified. Detailed mapping of the delineated features is provided in
Appendix A. The wetland determination data forms and accompanying upland data forms, photographs,
and wetland functions and values datasheets are presented in Appendix B.
Revised Seep A Wetlands
In order to ensure that there were more options for flow -through cell locations at Seep A, on June 16, 2020
a broader area around the Seep A stream was surveyed. There were two Seep A fringe seep wetlands (Seep
A north and Seep A South) identified and two bottomland hardwood floodplain swale wetlands (Seep A
North Crossing and Seep A South Crossing) identified. The two Seep A fringe wetlands are likely
hydrologically connected, and the overall area is greater than 0.5 acres. The Seep A North Crossing wetland
and the Seep A South Crossing wetland are both cleared areas in primarily floodplain swales that must be
crossed by equipment and vehicles during construction and operation of any future Seep A flow -through
cell(s). Both floodplain swales are forested with the exception of already cleared vehicle/equipment access
routes, and they are over 1.0 acre each.
Seep B Wetland
The Seep B wetland is a seep wetland adjacent and parallel to the Seep B stream, which is deeply incised
in the Cape Fear River floodplain. The hydrology of the seep wetland is primarily from groundwater that
emerges in the stream banks above the ordinary high water mark (OHWM). The Seep B Wetland is very
small, with approximately 0.062-acre groundwater -fed seep within the Seep B stream banks. The wetland
extends downstream (east) beyond the project area. The direct impact to the wetland is estimated to be
0.007 acres. The small seep receives infrequent overflow flooding from the Cape Fear River, overflow
flooding during stormwater runoff, and has groundwater to the surface on both sides of the stream. The
seep appears to remain saturated for long durations during the growing season. Dominant vegetation
within this wetland includes lizard's tail (Saururus cernuus) and Gray's sedge (Carex grayi). The overstory
trees and brush had been cleared at the sample point. Within the wetland, soils are sandy loams that are
clearly anaerobic/depleted. The soils are saturated to the surface.
The upland data point (Seep B Upland 1) is well -drained and had recently been cleared adversely affecting
the plant community. The upland data point was dominated by Virginia creeper (Parthenocissus
quinquefolia) and American holly (Ilex opaca). Soils are a sandy loam that transitioned into a sandy clay loam.
The upland point was on a stream terrace that was moderately well -drained.
5

Results
Seep B Temporary Crossing Wetland
An access road to the Seep B equipment area will cross the Seep B Temporary Crossing Wetland. This
wetland is a bottomland hardwood swale in the Cape Fear River floodplain. Approximately 0.465 acres
were delineated, however the wetland extends to the south in the Cape Fear River floodplain. The direct
impact to the wetland is estimated to be 0.060 acres. The impacted area has already been cleared of trees
and brush to avoid potential impacts to the northern long-eared bat. It appears that the wetland receives a
minor amount of groundwater seepage, however the primary hydrology comes from surface water runoff
during stormwater events and infrequent overflow flooding from the Cape Fear River.
The bottomland hardwood swale appears to remain saturated for long durations during the growing
season. Since the area was recently cleared, the trees and shrubs had been removed. The dominant trees
south of the temporary crossing were American elm (Ulmus americana), box elder (Acer negundo), and red
maple (Acer rubrum). The dominant herbaceous vegetation in the impacted area included Gray's sedge,
Japanese stiltgrass (Microstegium vimineum), and red maple. Within the wetland, soils are silt loam that
transition to silty clay loam at a depth of three inches. Wetland hydrology indicators for this floodplain
swale include its terrain position in the Cape Fear River floodplain with obvious drainage patterns,
oxidized rhizospheres on living roots, and crayfish burrows.
Seep C Wetland - Pilot Study
The Seep C wetland is a seep wetland adjacent and parallel to the Seep C stream, which is deeply incised
in the Cape Fear River floodplain. The hydrology of the seep wetland is primarily from groundwater that
emerges in the stream banks above the OHWM. The Seep C Wetland is small, with approximately 0.85-acre
groundwater -fed seep within the Seep C stream banks. The direct impact to the wetland is estimated to be
0.16 acres that includes the impact from the instream structure and the impounded area. The wetland
extends downstream (south then east) beyond the project area. The small seep receives overflow flooding
from the Cape Fear River, overflow flooding during stormwater runoff, and has groundwater to the surface
on both sides of the stream. The seep appears to remain saturated for long durations during the growing
season. Dominant vegetation within this wetland includes lizard's tail (Saururus cernuus), Frank's sedge
(Carex frankii), and Gray's sedge (Carex grayi). The overstory trees and brush had been cleared at the sample
point, however knees from bald cypress (Taxodium distichum) remained. Within the wetland, soils are silt
loam that transition to sandy loam at depths greater than 6 inches, and they are clearly anaerobic/depleted.
The soils are saturated to the surface.
The upland data point (Seep C Upland 1) is well -drained and had recently been cleared adversely affecting
the plant community. The upland data point was primarily bare/denuded, and it had recently been treated
with herbicide. The only dominant species present was Gray's sedge (Carex grayi). Soils are silt loam. The
upland point was on a stream terrace that was moderately well -drained.
Seep D Wetland
The Seep D wetland is a seep wetland adjacent and the origin of the Seep D stream, which is deeply incised
in the Cape Fear River floodplain. The hydrology of the seep wetland is primarily from groundwater that
emerges in the stream banks above the OHWM. The Seep D Wetland is small, with approximately 0.105-
acre groundwater -fed seep within the Seep D stream banks. The direct impact to the wetland is estimated
to be 0.009 acres. The wetland extends downstream (south then east) beyond the project area. The small
seep receives overflow flooding from the Cape Fear River, overflow flooding during stormwater runoff,
and has groundwater to the surface on both sides of the stream. The seep appears to remain saturated for
long durations during the growing season. Dominant vegetation within this wetland includes lizard's tail
(Saururus cernuus), Frank's sedge (Carex frankii), and Grays sedge (Carex grayi). The overstory trees and
brush had been cleared at the sample point, however knees from bald cypress (Taxodium distichum)
Ce

Results
remained. Within the wetland, soils are silt loam that transition to sandy loam at depths greater than
6 inches, and they are clearly anaerobic/depleted. The soils are saturated to the surface.
The upland data points (Seep D Upland 1 and Upland 2) are well -drained and had recently been cleared
adversely affecting the plant communities. The Seep D Upland 1 data point was primarily bare/denuded,
and it had recently been treated with herbicide. The dominant species that remained included Japanese
stiltgrass and pineland threeawn (Aristida stricta). The Seep D Upland 2 data point was also dominated by
Japanese stiltgrass and pineland threeawn, however this area was not treated with herbicide. The trees that
were recently cleared near the upland points included cherrybark oak (Quercus pagoda), red maple, and
sugarberry (Celtis laevigata). Soils are silt loam. The upland points were on relatively high stream terraces
that were moderately well -drained.
7

Results
fr,
!}'SEEP A
a�
SEEP
- f4
_ ` 6
t
1Y • - 91
• • • • • Ephemeral Stream ® Culvert The Chemours Company
— Intermittent Stream 0 Data Sheet Point Fayetteville Works
0 250 500 Bladen County, North Carolina
Perennial Stream ® Wetland/Seep mommooK== Feet
5

Results
Streams
The May 18-19, 2020 field investigation resulted in the identification of four (Seep A, Seep B, Seep C, and
Seep D), likely jurisdictional, streams within the project area, and one ephemeral channel, likely not
jurisdictional, totaling approximately 200 linear feet of potential impact. The June 16, 2020 further defined
the Seep A streams. There are several branches of perennial steam channel in Seep A, and one ephemeral
stream channel that extends north through the Seep A North Wetland. The ephemeral channel is likely an
old drainage ditch in the floodplain swale that has an existing concrete culvert in the channel.
Seep A unnamed tributary to Cape Fear River
The Seep A stream is an unnamed tributary to Cape Fear River that is an incised stream bed below east of
the Fayetteville Works site in the Cape Fear River floodplain. Most of the base flow within this stream is
from groundwater. The Seep A stream is not shown on USGS 7.5-minute series topographic mapping;
however, based on the 2010 North Carolina Division of Water Quality Methodology for Identification of
Intermittent and Perennial Streams and Their Origins, this is a perennial stream. This determination was
supported by a NCDWQ Stream Identification Form score of 36.52. The upstream drainage of this tributary
is 0.7 square miles (USGS 2019). Approximately 70 linear feet of the Seep A stream lies within the study
area, of which, approximately 50 linear feet, would be impacted by the flow -through cell. The Seep A
stream is likely a WOTUS because of the presence of an OHWM and its connectivity to the Cape Fear River,
a traditionally navigable waterway.
Seep B unnamed tributary to Cape Fear River
The Seep B stream is an unnamed tributary to Cape Fear River that is an incised stream bed east of the
Fayetteville Works site in the Cape Fear River floodplain. Most of the base flow within this stream is from
groundwater, and there are fringe seep wetlands above the OHWM. The Seep B stream is not shown on
USGS 7.5-minute series topographic mapping; however, based on the 2010 North Carolina Division of Water
Quality Methodology for Identification of Intermittent and Perennial Streams and Their Origins, this is a perennial
stream. This determination was supported by a NCDWQ Stream Identification Form score of 41.0. The
upstream drainage of this tributary is 0.7 square miles (USGS 2019). Approximately 70 linear feet of the
Seep B stream lies within the study area, of which, approximately 50 linear feet, would be impacted by the
flow -through cell. The Seep B stream is likely a WOTUS because of the presence of an OHWM and its
connectivity to the Cape Fear River, a traditionally navigable waterway.
Seep B temporary crossing unnamed tributaCL to Cape Fear River
The Seep B temporary crossing channel is an unnamed ephemeral channel that is a tributary to Cape Fear
River east of the Fayetteville Works site in the Cape Fear River floodplain. The ephemeral channel appears
to be an old ditch that was excavated in the floodplain to improve drainage. The ditch is in a wetland swale
(Seep B Temporary Crossing Wetland), and there is no base flow. The Seep B temporary crossing stream is
not shown on USGS 7.5-minute series topographic mapping. Based on the 2010 North Carolina Division of
Water Quality Methodology for Identification of Intermittent and Perennial Streams and Their Origins, this is an
ephemeral stream. This determination was supported by a NCDWQ Stream Identification Form score of
2 Per the 2010 North Carolina Division of Water Quality Methodology for Identification of Intermittent and
Perennial Streams and Their Origins, a stream is ephemeral if it obtains a score less than 19. A stream is at
least intermittent if it obtains a score greater than or equal to 19. A stream is perennial is it obtains a score
greater than or equal to 30.
5

Results
11.75. The upstream drainage of this tributary is 0.7 square miles (USGS 2019). Approximately 30 linear
feet of the Seep B temporary crossing ephemeral channel lies within the study area, of which,
approximately 20 linear feet, would be impacted by the culvert and temporary crossing. The Seep B
temporary crossing ephemeral channel is likely not a WOTUS, because there is no base flow and the feature
appears to be an old drainage ditch. The ephemeral channel in a bottomland hardwood wetland swale does
have connectivity to the Cape Fear River, a traditionally navigable waterway, and it would likely be
regulated as part of a jurisdictional wetland (Seep B Temporary Crossing Wetland).
Seep C unnamed tributary to Cape Fear River
The Seep C stream is an unnamed tributary to Cape Fear River that is an incised stream bed east of the
Fayetteville Works site in the Cape Fear River floodplain. Most of the base flow within this stream is from
groundwater, and there are fringe seep wetlands above the OHWM. The Seep B stream is not shown on
USGS 7.5-minute series topographic mapping; however, based on the 2010 North Carolina Division of Water
Quality Methodology for Identification of Intermittent and Perennial Streams and Their Origins, this is a perennial
stream. This determination was supported by a NCDWQ Stream Identification Form score of 43.5. The
upstream drainage of this tributary is 0.7 square miles (USGS 2019). Approximately 70 linear feet of the
Seep C stream lies within the study area, of which, approximately 50 linear feet, would be impacted by the
flow -through cell. The Seep C stream is likely a WOTUS because of the presence of an OHWM and its
connectivity to the Cape Fear River, a traditionally navigable waterway.
Seep D unnamed tributary to Cape Fear River
The Seep D stream is an unnamed tributary to Cape Fear River that is a deeply incised stream bed southeast
of the Fayetteville Works site in the Cape Fear River floodplain. The Seep D stream originates in a seep
wetland at the project location, and it appears that most of the base flow within this stream is from
groundwater. The Seep D stream is not shown on USGS 7.5-minute series topographic mapping; however,
based on the 2010 North Carolina Division of Water Quality Methodology for Identification of Intermittent and
Perennial Streams and Their Origins, this is a perennial stream. This determination was supported by a
NCDWQ Stream Identification Form score of 39.5. The upstream drainage of this tributary is 0.7 square
miles (USGS 2019). Approximately 60 linear feet of the Seep D stream lies within the study area, of which,
approximately 50 linear feet, would be impacted by the flow -through cell. The Seep D stream is likely a
WOTUS because of the presence of an OHWM and its connectivity to the Cape Fear River, a traditionally
navigable waterway.
Ce

Conclusion
Conclusion
Based on the field review, the project area has features that are likely WOTUS. Four streams, totaling 270
linear feet, were identified within the project area. Approximately 200 feet of stream will be directly
impacted by the flow -through cell construction. One ephemeral channel that flows through the Seep B
Temporary Crossing Wetland was identified, but the area would be regulated as a wetland and not as a
stream. Four wetlands, totaling 0.696 acres, were identified in the vicinity of the project area.
Approximately 0.082 acres of those wetlands will be directly impacted.
Efforts to avoid, minimize, and mitigate impacts to WOTUS will continue through the design phase of the
project. If other impacts are unavoidable, mitigation may be required. The final determination of
jurisdictional waters is ultimately made by the USACE. This report reflects the analysis and best judgment
of the wetland scientists based on the guidelines set forth by the USACE.
7

References
References
The list of published references and information sources is presented below.
Cowardin et al.
1979 Cowardin, L.M., Carter, V., Golet, F.C., and LaRoe, E.T. Classification of Wetlands and
Deepwater Habitats of the United States. FWS/OBS-79/31, U.S. Fish and Wildlife Service, Office of
Biological Services, Washington, DC, December 1979.
North Carolina Division of Water Quality
2010 Methodology for Identification of Intermittent and Perennial Streams and Their Origins. Version
4.11. [http://portal.ncdenr.org/c/document_library/get_file?uuid=Oddc6eal-d736-4b55-8e50-
169a4476de96&groupld=38364]
North Carolina Watershed Stewardship Network (NCWSN)
2019 Watershed Stewardship Network. Phillips Creek -Cape Fear River. 2019.
[http://wsnet.renci.org/htmINew/huc_report/index.html?huc=0303000501041
Natural Resources Conservation Service (NRCS)
2019 Natural Resources Conservation Service, United States Department of Agriculture. Web Soil
Survey. [https://websoilsurvey.sc.egov.usda.gov/App/HomePage.htm]
Parsons
2018 Focused Remedial Action Plan for PFAS in Groundwater. Chemours Fayetteville Works. RCRA
Permit No. NCD047368642-R2-M3. March 2018.
U.S. Army Corps of Engineers (USAGE)
1987 Wetlands Research Program Technical Report Y-87-1 (online edition), Corps of Engineers, 1987
Wetlands Delineation Manual. [http://www.cpe.rutgers.edu/Wetlands/1987-Army-Corps-
Wetlands-Delineation-Manual.pdf]
2010 Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Atlantic and Gulf
Coastal Plain Region (Version 2.0), November 2010.
[https://usace.contentdm.ocic.org/utils/getfile/collection/p26600lcolll/id/7594]
U.S. Geological Survey (USGS)
2019 Stream Stats. Version 4.3.[https:Hstreamstats.usgs.gov/ss/]
H

List of Acronyms
List of Acronyms
The list of acronyms is shown in the table below.
Acronym
Full Acronym Reference
CO
Consent order
CWA
Clean Water Act
GenX
hexafluoropropylene oxide dimer acid (HFPO-DA)
GIS
geographic information system
GPS
global positioning system
HUC
hydrologic unit code
NCDWQ
North Carolina Division of Water Quality
NRCS
Natural Resources Conservation Service
NWI
National Wetlands Inventory
OHWM
Ordinary high water mark
PFAS
Perfluoroalkyl and polyfluoroalkyl substance
PFMOAA
2,2-difluoro-2(trifluoromethoxy)acetic acid
RHA
River and Harbors Act
US
United States
USACE
United States Army Corps of Engineers
USEPA
United States Environmental Protection Agency
USGS
United States Geological Survey
WOTUS
Waters of the United States

Appendix A
AMapping and Plans
Chemours Project Area Vicinity Map
Project Plans
NWI Map
Stream Map
USGS 7.5-Minute Topographic Map — Duart Quadrangle
USGS 7.5-Minute Topographic Map (Excerpt)
FEMA Map
NRCS Soil Map

Appendix A
The Chemours Company, Fayetteville Works Vicinity Map
tell,
z
The Chemours Company
n
m
a
r
m
taas m
87 z
m

Appendix A
The Chemours Company, Flow -through Cells
Project Plans — Pilot Study Seep C

Appendix A
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NOTES:
1. cwo COOTa1MWTE srs TEA CORRE3PCIDS TD NADB3, NORTH GARL1JNt
2 ELEVA-nom PRESENT@ARE IN FEET, NA1ID8d
3. TOPCGFAPHC RCNDS, BULDN(;r, Ala PROPERTY DNE IHFORlMT1OH OHTAYA@ FROM
FREF1AND-CL14K XALE38 ASSOCIATES, NC. OF NG 3URLEY OF THE CHUMS.
FAYETTEMIJ-E WOPoCSSITE DATE73ANl 2019.
4. I31PP. S SPILLWAY AND SLOPES SHALL BE ARMORED VM 12�NGII THING (MINI LAYER OF
RJPRAP AND IINDEFLNN WDHA GEOTE%Tf LE SEPARATOR
5. MNNTENANCE PLATF OW SWILL BE SURFACED WITH WNCH T9A IN( IAYE{ OF AGGR)SVE
AND UNDERLAIN WITH ACEOTECOLE SEPARATOR
d. DISMUIffD AREl3 NOT SLRFAOEO VRTM A.GGRE GATE OR CONCRETE WILL BE SEEDED AND
MJLC7®.

I.K
National Wetlands Inventor
U.S. Fish and Wildlife Service
The Chemours Company
Fayetteville Works
February 27, 2019
This map is for general reference only. The US Fish and wildlife
Service is not responsible for the accuracy or currentness of the
Wetlands
Freshwater Emergent Wetland
Lake
base data shown on this map. All wetlands related data should
be used in accordance with the layer metedeta found on the
Estuarine and Marine Deepwater
. Freshwater Forested/Shrub Wetland
❑ Other
Wetlands Mapper web site.
❑ Estuarine and Marine Wetland
n Freshwater Pond
E-] Riverine

Appendix A
r
M
4f% '
The Chemours Company
Fayetteville Works
Bladen County, North Carolina
MM �
Obs
i
Perennial Stream
0 025 1150 ? 500
Feet

Appendix A
EMS U.S. DEPARTMENT OF THEINTERIOR DUART QUADRANGLE
U.S. GEOLOGICAL SURVEY US T NORTH CAROLIHA
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w.w .. isn o�. •�.,ya ie.,rea.�M�ry a ., P.,.i,sM��mMcr OOART, NC
MR
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Appendix A
USGS 7.5 Minute Topographic Map (Excerpt) - Duart Quadrangle
Wi l li -
reek�
�—" 3-`
Flow -through Cell
Project Location
ram,
LL
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150
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FEMA Floodplain Information [https://msc.fema.gov/portal/search#searchresultsanchorl
Apprumrate kwato taxd on u wMa
aro dow not ropy -t an aull+onta m
t'ilf wa)"kr0t.7@+ SPECIAL FLOOD
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MAP PA 1E151 unnapoec
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ur Lti arnrua LI1arICe fldu0 r@IYl aotPdg'e
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�� Future Candltwre 14 Annual
Clancy I"Hamid z—
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STWCYLRES r r r r _c%ne. Drkc. w Frwdxal

3.slwN
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Sail Map --Baden Ocun[y, Norlh Carolina
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Conservabon Service Nabanal CooperAve Sal Survey
Appendix A
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Page 1 of 3

Saa Map-6✓aderr Gmmty, NxM Ca3ira
f fhe C✓Irernours Gary - FayetLev& Winks)
MAPLEGEND
Appendix A
MAP INFORMATION
Arm of Interest4hu)
Sp AI AMa
The soil suveysthatocnrpnse ywrAa vrere nrappedat
A -Ea or Irtiafst (ACH i
SbT� SPA
1:24,00D.
S olla
Please rely cn the bar wale an each map sFreea Rm reap
—�
SJI MT LNI Pot}yo-
terry
rneasummerrts-
SdI Map Urtl Lures
lhlet
Scurre of KV. Natural Resnunres Cron Semie
0uW
Web Soil Sunny URL-
0
Shc Map tlrfl Points
Coarinate Syshern: Web Memcx fEPSG:3DbF)
r�
�clal LheFeadrrfs
Sp$daI
Paint Feab.rree
Maps fforn Me Web Soil Survey are based rntheVkbNlemator
am t
Mbf FaAuree
p gertm whdrpreserves diredan arrd scrape but distorts
=mrre antl Canals
distance and area. A projection that preserves area, sudr as die
BWW Rt
PLkrs equal-mea om c W eoban, shadd ba used if more
CLiry SPa
rransportauion
wwratecatoaiatm sofdistanceorareaarerequied.
a F t
FWE
Closed DaResam
This product is gerrerated from the USDA-M1RCS aerdfied data as
,.�.
IntarEm Hglnaye
of the wersian daM5) listed belaac
*
{WH PH
.xt
US RDLfe6
Soil Surrney,4rea: filaden County, North Cxdina
A
Qweq Sp3t
M4VFOaM
Survey kea Dab- Lrersion 21, Sep 10, 201B
0
tanalll
UXW F
Sail map uric arelaheled fas Wa a dkws,l fw map scams
PL
Lama RC%
1:50,000 a larger.
Marr3horsharrp
asa
■
Aerial RXtXyADty
0ate(s) aerial images were: Apr22, 2015—Nkw
19,
mPie rx 4tlar-y
The orftpk D or other base map on which the sail lines mere
m"lar+eo smer
Dx*led ardd4tzed pmba*ali fern fiom thebmApm nd
inagery drsplayed onifresemap. As a resit, scare ninor
PaemtalWXrx
shifting of map unit bandarim mar be euiderrt
RDI CrrtcrW
SAIrre Spot
t
Sardf Spol
Sefaety EMdM
0
smai e
SW OF Slip
-9=
IJSpJ NaiFIral Resmrees
Canservation Service
Mob Sal Survey
National Cooperative Sail Survey
2127f2019
Page 2 of 3

Sail Map--Chcen County North Cardina The Churrnrs C rrpany -
F3remwille %%brl�s
Map Unit Legend
Map Unit Symbol
Map Unit Nance
Acres .n AOI
Percent of ACI
C-
ChE r. a am Chastain soh,
�equendyfb ded
0.6
r,a
Crn
Congaree silt loan, frequently
Iloaded
z5.?
6-4%
DyF
Dfn:t�, steep
212.9
29-9%
JO
Jolrrstan muc; ykxun
20.0
28M
L.a6
Lakeland sand, 1 to 7 ptw",--:
1.8
0
Nab.
ND fdk laamyr fine sand_ 0 to 2
percent slopes
46.8
I
Nob
Norfdk loamy fine sand.2 to 6
percent slopes
BA
1-2%
Nub
Nafdk-UrbanIardcDrTlex, 0
to 6 Agent Dopes
156.5
22
%V
Mter
15.3
21%
WaB
Vbgm m Fire sand, a Io 9
percerrt slopes
1 F7.4
24
%%We
WkAharn fine sandy koark 1 to
e penxrrt 5"
21.2
20%
Totals forArea of Interesk
712.7
100-0 .
,Is, Natural Resaurces %Web SDI Survey 2l27i2019
ComerwatiDn Service National Cccperatiwe Soil Sum Page 3 of 3

Appendix B
BStream Data Sheets and Photographs

Appendix C
Wetland Determination Data Forms and Photographs