20190752 Ver 4_More Info Received_20200921

Strickland, Bev
From: Christopher Shores <[e-mail]>
Sent: Monday, September 21, 2020 5:13 PM
To: Greer, Emily C CIV USARMY CESAW (USA); Wojoski, Paul A
Cc: Eggering, Luke; Compton, Christel E; Garon, Kevin P; Postaski, Lindsey; Bahr, Sebastian
Subject: [External] RE: SAW-2019-00206 Chemours Pilot Study IP-Request for additional
information
Attachments: 2020-09-21 Revised Seep C Permit Drawings.pdf
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
Good afternoon Emily, as we discussed by phone Luke is on vacation, so I've prepared the following responses with help
from his team. Also see attached revised drawings referenced below in responses. Thank you very much for your
attention on this.
1. Please provide further information on the process of replacing GAC media. Enough detail should be
provided so the Corps can determine if ongoing disturbances to wetlands and/or waters are required.
The permanent impacts as shown include the construction of a maintenance platform on the northeast
side of the concrete flow -through cell structure. The platform will be constructed to support the
equipment that will remove spent GAC and replace it with new GAC. It is anticipated that the removal
will be performed with a vacuum truck (a fully self-contained, pneumatic system with mechanical
blowers onboard the truck), and that emplacement will be performed with a forklift boom and
supersacks of GAC. Replacing GAC media will not require ongoing disturbances to wetlands or waters.
2. The WOTUS report mentions a pump station. Please clarify if this terminology is loosely referencing the
proposed structure or if there are associated upland structures that have not been presented in the
application.
The WOTUS report was originally prepared for the Old Outfall 002 remediation pumping system, which
was permitted on October 29, 2019 (SAW-2019-00206). The application for the interim remediation
system for Seep C leveraged this previous work and inadvertently referenced the pumping station
locations discussed for the Old Outfall 002. To clarify, the interim remediation system for Seep C does
not involve any mechanical pumping, and relies solely on the hydraulic head from the impoundment to
passively remediate the impacted seep baseflow.
3. On drawing C-02, please clearly show the entire stream and the overall impact area and discern
between impact types (direct fill vs impoundment, wetland vs stream, temporary vs permanent). Using
different colors is recommended. Please also provide the impact length and acreage and break impacts
out in the some manner.
To show the entire stream, and to respond to Comment 4 below regarding the cross -sections, Drawing
C-02 has been divided into three drawings (C-02A, C-0213, and C-02C):

• Drawing C-02A, at a larger scale, shows the entire stream, including unimpacted reaches
upgradient of the culvert. The two types of impacts to wetlands (direct fill and impoundment)
are contrasted with dark red and light red hatching, respectively. The two types of impacts to
streams (direct fill and impoundment) are contrasted with dark blue and light blue lines,
respectively.
• Drawing C-0213, at a smaller scale, shows finer details of the impoundment grading plan.
• Drawing C-02C shows the cross -sections formerly on Drawing C-02.
As discussed in Comment 6 below, all impacts are being noted as permanent, including the area
between the downstream riprap and the silt fence (2,500 SF wetlands and 35 LF stream). This small
area would not be practical to restore post -construction, and will be beneficial to retain as a
construction area for potential maintenance work in the future. The impact lengths and areas have
been revised accordingly, and are now shown on C-02A.
4. Please provide a separate page for the cross -sections provided on drawing C-02. Also, ensure all
drawings are scaled and no larger than 11x17" format and provide a revision date where applicable.
Drawing C-02C has been developed to show the cross -sections on a separate page. C-02A, C-0213, and
C-02C are marked as a Revision set and resized to 11x17.
5. Please clarify that the entire length of the stream and/or acreage of upstream wetlands, if present, that
will be affected by impoundment have been correctly quantified and depicted. The quantification must
include any discernable rise in water depths that will occur as a result of impoundment. The reviewer is
unable to determine if the area above the culvert is included in the impact area. This comment should
be noted when responding to #3 above.
The August 13, 2020 application delineated the impoundment as the normal pool, where the elevation
is equal to the inlet weir (39.85 ft msl). During high stormflow conditions, the impoundment may
increase up to the point of the elevation of the filter bed perimeter walls and maintenance platform
(42.35 ft msl). This is a temporary condition that will revert back to 39.85 ft msl once the stormflow
subsides. However, as noted in the comment "the quantification must include any discernable rise in
water depths that will occur as a result of impoundment," Drawings C-02A/B has been revised to show
the impoundment as the worst -case condition (42.35 ft msl). The calculated quantity of impacts, now
shown in C-02A, has been revised accordingly.
6. The location of the LOD and silt fencing downstream of the structure alludes to the need for temporary
impacts; however, no temporary impacts were included in the application. Please clarify if temporary
impacts are required, update the drawing(s) accordingly, and provide a restoration plan. If no
temporary impacts are needed, the location of silt fencing needs to be corrected on the drawing(s) to
align with the project footprint.
As discussed in Comment 3 above, as a simplification, all impacts are being noted as permanent,
including the small area between the downstream riprap and the silt fence (2,500 SF wetland and 35 LF
stream), which would not be practical to restore post -construction and will be beneficial to retain as a
construction maintenance area for potential future work.
7. Please provide information regarding either the lack thereof or the potential for downstream effects on
hydrology as a result of impounding waters. Although groundwater is not being directly impacted, the

Corps is concerned that the interception of contributing upstream surface flows may have a
measurable, adverse effect on downstream aquatic resources. If the applicant determines that effects
will occur, the impacts need to be included in project totals and affected areas identified on
corresponding drawings according to the directions above and labeled as secondary hydrology impacts.
If the applicant is unsure of downstream effects, please provide a simple monitoring plan that will
capture or disprove whether impacts are occurring. This data will be used to ascertain impacts for the
permit modification project. Please note that previous comments by the applicant indicate the entire
wetland area has not been delineated. A delineation of the entire reach of Seep C may be required.
The flow -through cells will not have an adverse effect on downstream aquatic resources, but rather
will improve water quality through the reduction of PFAS concentration. Water is not diverted away
from the seep channel, but is released after completing treatment within the cell. Chemours recently
submitted an Interim Seep Remediation System Plan on August 31, 2020 as required by the Consent
Order Addendum. This document required the development of a Sampling and Effectiveness Plan,
which effectively fulfills the downstream monitoring requirements discussed in this comment. A copy
of the Interim Seep Remediation System plan that was submitted to NCDEQ can be provided to USACE
upon request.
As detailed in this Sampling and Effectiveness Plan, autosamplers will collect routine composites of
influent and effluent samples. The specified frequency, required by Consent Order Addendum
Paragraph 2(a)(iii), is 14-day composites, twice per month. In addition to analytical sampling for PFAS
reduction efficiency, composite samples will be analyzed by the laboratory for total suspended solids,
and measured in the field with calibrated water quality meters for turbidity, dissolved oxygen, pH,
conductivity, and temperature. The flow -through cells will not have an adverse effect on any of these
parameters:
• Turbidity and suspended solids: seep baseflow will filter through several layers of #5 stone,
geotextile, and GAC media, which will reduce, not increase, ambient loads of these
constituents. Geotextile layers on top of the GAC media will be considered sacrificial and
routinely replaced.
• Dissolved oxygen: the treatment mechanism is adsorption, not biological, and the flow through
cell is open to the atmosphere; the flow through cells will not appreciably impact DO levels.
• pH: the treatment mechanism is adsorption, not chemical; the flow -through cells will not
impact pH.
• Temperature: the median residence time of water flowing through the cells is approximately
two hours; this will not appreciably increase ambient temperature.
Regarding delineation, the area around Seep C has been fully delineated. Applicant comments about
incomplete delineation were likely referring to other areas of the Site with associated proposed
remedies like Seeps A, B, and D. Please note that a comprehensive wetland mapping event was
recently completed by Geosyntec on September 14-17, 2020 to support that upcoming work.
B. Please provide a mitigation credit reservation letter from a service area mitigation bank that reflects
ratios for the currently proposed impacts at 2:1 for direct fill of wetlands and perennial stream length,
1:1 for conversion of wetlands and waters by the impoundment, and 1:1 for the secondary effect of loss
of function related to #7 above, if applicable.

Per Emily Greer's recommendation, Parsons reviewed the Regulatory In -lieu Fee and Bank Information
Tracking System (RIBITS) for available mitigation credits at the following:
Barra Farms II Mitigation Bank, a private/commercial mitigation bank, is located in Cumberland
County. Per RIBITS, the bank has 53.32 non -riparian wetland credits available.
Lower Cape Fear Umbrella Bank (Sneeden & White Springs Tracts), a private/commercial mitigation
bank, is located in Brunswick and New Hanover Counties. Per RIBITS, the bank has 42.576 non -
riparian and 49.9 riparian/riverine wetland credits available in addition to 4,154 stream credits.
Parsons will reach out to the appropriate mitigation bank(s) to initiate coordination. It is proposed that
Parsons will acquire a mitigation credit reservation letter once all impacts have been finalized, as the
most efficient path forward given the sequential nature of work required by the Consent Order
Addendum.
9. It appears the applicant may have began coordination with NCSHPO. If so, please provide SHPO's
response or state the contrary.
SHPOs typically requires Section 106 consultation to be conducted by the federal agency, which in this
case, would be USACE. Similar to the Old Outfall 002 permitting process from 2019, for this Seep C
submittal, Parsons provided a coordination letter with NC SHPO for USACE transmittal. Parsons will
contact USACE directly to inquire if additional assistance can be offered.
10. For your knowledge, no public comments were received. USFWS provided a not likely to affect response
letter.
Acknowledged.
From: Greer, Emily C CIV USARMY CESAW (USA) <[e-mail]>
Sent: Wednesday, September 16, 2020 12:36 PM
To: Eggering, Luke <[e-mail]>; Compton, Christel E <[e-mail]>
Cc: Wojoski, Paul A <[e-mail]>
Subject: ?SAW-2019-00206 Chemours Pilot Study IP-Request for additional information
External email. Confirm links and attachments before opening.
This request is related to the above referenced project. The following information is needed to complete
the review process. Please respond in direct reply to this correspondence no later than close of business
Monday, September 21, 2020. You must communicate with the Corps and state PMs prior to this date if
you cannot meet this deadline.
11. Please provide further information on the process of replacing GAC media. Enough detail should be
provided so the Corps can determine if ongoing disturbances to wetlands and/or waters are required.
12. The WOTUS report mentions a pump station. Please clarify if this terminology is loosely referencing the
proposed structure or if there are associated upland structures that have not been presented in the
application.
13. On drawing C-02, please clearly show the entire stream and the overall impact area and discern
between impact types (direct fill vs impoundment, wetland vs stream, temporary vs permanent). Using

different colors is recommended. Please also provide the impact length and acreage and break impacts
out in the same manner.
14. Please provide a separate page for the cross -sections provided on drawing C-02. Also, ensure all
drawings are scaled and no larger than 11x17" format and provide a revision date where applicable.
15. Please clarify that the entire length of the stream and/or acreage of upstream wetlands, if present,
that will be affected by impoundment have been correctly quantified and depicted. The quantification
must include any discernable rise in water depths that will occur as a result of impoundment. The
reviewer is unable to determine if the area above the culvert is included in the impact area. This
comment should be noted when responding to #3 above.
16. The location of the LOD and silt fencing downstream of the structure alludes to the need for temporary
impacts; however, no temporary impacts were included in the application. Please clarify if temporary
impacts are required, update the drawing(s) accordingly, and provide a restoration plan. If no
temporary impacts are needed, the location of silt fencing needs to be corrected on the drawing(s) to
align with the project footprint.
17. Please provide information regarding either the lack thereof or the potential for downstream effects
on hydrology as a result of impounding waters. Although groundwater is not being directly impacted,
the Corps is concerned that the interception of contributing upstream surface flows may have a
measurable, adverse effect on downstream aquatic resources. If the applicant determines that effects
will occur, the impacts need to be included in project totals and affected areas identified on
corresponding drawings according to the directions above and labeled as secondary hydrology impacts.
If the applicant is unsure of downstream effects, please provide a simple monitoring plan that will
capture or disprove whether impacts are occurring. This data will be used to ascertain impacts for the
permit modification project. Please note that previous comments by the applicant indicate the entire
wetland area has not been delineated. A delineation of the entire reach of Seep C may be required.
18. Please provide a mitigation credit reservation letter from a service area mitigation bank that reflects
ratios for the currently proposed impacts at 2:1 for direct fill of wetlands and perennial stream length,
1:1 for conversion of wetlands and waters by the impoundment, and 1:1 for the secondary effect of
loss of function related to #7 above, if applicable.
19. It appears the applicant may have began coordination with NC SHPO. If so, please provide SHPO's
response or state the contrary.
20. For your knowledge, no public comments were received. USFWS provided a not likely to affect
response letter.
Please feel free to contact me with any questions.
Emily Greer, Regulatory Specialist
Wilmington District - Wilmington Regulatory Field Office
69 Darlington Avenue, Wilmington, NC 28403
910.251.4567 (o)
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4. BYPASS SPILLWAY AND SLOPES SHALL BE ARMORED WITH 12-INCH THINK (MIN) LAYER OF
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AND UNDERLAIN WITH A GEOTEXTILE SEPARATOR.
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MULCHED.
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2501 BLUE RIDGE ROAD, SUITE 430 F
NC License No.: C-3500 and C-295 RALEIGH, NC 27607
consultants 919.870.0576
TITLE: SEEP C INTERIM REMEDIATION SYSTEM
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PROJECT: THE CHEMOURS COMPANY
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DATE: SEPTEMBER 2020
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FILTER BED
B
09.21.20 REVISED PERMIT SUBMITTAL JFH CAS
PERIMETER WALL
BOTTOM OF SLAB
A
08.12.20 30% DESIGN SUBMITTAL JFH CAS
20 1
EL = 34.18
20
REV
DATE DESCRIPTION DRN APP
0+00 INLET WEIR
1+00
1+40
pp pp(> ATRIUM AT BUE D GE
Geosyntec
=
EL = 40.85
DISTANCE (FEET)
GeosyntecConsultants ofNC, P.C. 2501 BLUE RIDGE ROADLSUITE 30 E
NC License No.: C-3500 and C-295 RALEIGH, NC 27607
consultants
B SECTION
919.870.0576
TITLE:
SEEP C INTERIM REMEDIATION SYSTEM
C-02B SEEP C REMEDIATION
SCALE: 1" = 20'
SECTIONS
PROJECT:
THE CHEMOURS COMPANY
SEEP C INTERIM REMEDIATION SYSTEM
SITE:
FAYETTEVILLE WORKS SITE
DESIGN BY: CMDS DATE: SEPTEMBER 2020
F
DRAWN BY: JFH PROJECT NO.: TR0795
CHECKED BY: JWE FILE: TR0795-CO2C.DWG
30% DESIGN
DRAWINGS
REVIEWED BY: JJD DRAWING NO.:
C-02C
NOT FOR
CONSTRUCTION
APPROVED BY: CAS