Loading...
HomeMy WebLinkAbout20190752 Ver 6_401 Monitoring Plan Addendum - 2022-09-08_20220908Staff Review Form NORTH CAROLINA Envlronm¢ntcl Qvofiry Updated September 4, 2020 Staff Review Does this application have all the attachments needed to accept it into the review process?* Yes No ID# * 20190752 Version* 6 Is this project a public transportation project?* Yes • No Reviewer List: * Paul Wojoski:EADS\pawojoski Select Reviewing Office: * Central Office - (919) 707-9000 Does this project require a request for payment to be sent?* Yes No Project Submittal Form * Please note: fields marked with a red asterisk below are required. You will not be able to submit the form until all mandatory questions are answered. Project Type: * For the Record Only (Courtesy Copy) New Project Modification/New Project with Existing ID More Information Response Other Agency Comments Pre -Application Submittal Re-Issuance\Renewal Request Stream or Buffer Appeal Pre -Filing Meeting Date Request was submitted on: Is this supplemental information that needs to be sent to the Corps?* Yes No Project Contact Information Name: Matt Vanderkooy Who is submitting the information? Email Address: mvanderkooy@geosyntec.com Project Information Existing ID #: 20190752 20170001 (no dashes) Existing Version: 6 Project Name: Chemours — Fayetteville Works — Barrier Wall Project Is this a public transportation project? Yes No Is the project located within a NC DCM Area of Environmental Concern (AEC)? Yes No Unknown County (ies) Cumberland Bladen Please upload all files that need to be submited. Click the upload button or drag and drop files here to attach document 401 Monitoring Plan Addendum - 2022-09-08.pdf 1.96MB Only pdf or kmz files are accepted. Describe the attachments or comments: Attached please find the revised and updated "Monitoring Plan" in response to your request in review of the 401 permit modification for the Chemours Fayetteville Works Barrier Wall Project. Sign and Submit By checking the box and signing box below, I certify that: • I, the project proponent, hereby certifies that all information contained herein is true, accurate, and complete to the best of my knowledge and belief. • I, the project proponent, hereby requests that the certifying authority review and take action on this CWA 401 certification request within the applicable reasonable period of time. • I agree that submission of this online form is a "transaction" subject to Chapter 66, Article 40 of the NC General Statutes (the "Uniform Electronic Transactions Act"); • I agree to conduct this transaction by electronic means pursuant to Chapter 66, Article 40 of the NC General Statutes (the "Uniform Electronic Transactions Act"); • I understand that an electronic signature has the same legal effect and can be enforced in the same way as a written signature; AND • I intend to electronically sign and submit the online form. Signature: Submittal Date: 2022-09-08 Is filled in automatically. Geosyntec ° consultants Geosyntec Consultants of NC. P.C. NC License No.: C-3500 and C-295 Date: To: From: Subject: Memorandum September 8, 2022 The Chemours Company, FC, LLC Geosyntec Consultants of NC, P.C. Wetland Monitoring Plan: Addendum Chemours Fayetteville Works Project Bladen/Cumberland County, North Carolina DWR # 20190752v6; USACE Aid # SAW-2019-00296 2501 Blue Ridge Road, Suite 430 Raleigh, NC 27607 PH 919.870.0576 FAX 919.870.0578 www.geosyntec.com INTRODUCTION This Wetland Monitoring Plan Addendum ("Addendum") has been prepared by Geosyntec Consultants of NC, P.C. (Geosyntec) for The Chemours Company FC, LLC (Chemours). On August 13, 2021 the Wetland Monitoring Plan ("Monitoring Plan") was submitted to the North Carolina Department of Environmental Quality (NCDEQ) along with a Section 404 permit modification request (SAW-2019-00296) through the United States Corps of Engineers (USACE). This addendum to the previously submitted plan is based on comments by the North Carolina Department of Environmental Quality (NCDEQ) via email on August 25, 2022. This document first presents a summary of the stream and wetland monitoring scope described in both the Monitoring Plan and this Addendum, and then presents the Addendum monitoring scope additions based on comments and recommendations received from NCDEQ. SUMMARY OF MONITORING SCOPE The table on the following page summarizes the monitoring scopes to be implemented based on both the Monitoring Plan and this Addendum. engineers I scientists I innovators Wetland Monitoring Plan: Addendum September 8, 2022 Page 2 Table 1 Summary of Monitoring Scope Geosyntec ° consultants Geosyntec Gmsulla nle of NC, P.C. NC F.ioense Nu.: G35tl9 and C-2.95 Scope / Item Described in Document Duration and Frequency Location Performance Standards Groundwater Gauges USACE Datapoints NCWAM Forms DWR Stream Form Wetland Delineation Reports Monitoring Plan and Addendum Addendum Monitoring Plan and Addendum Addendum Addendum Annual, 5 years Continuous, 5 years Annual, 5 years Annual, 5 years Semi-annual (early and late growing season), 5 years Monitoring Plan Pre -construction: 2020 Post Construction: 2027 Addendum Annual, 5 years Wetland Study Area Wetlands 2, 3, 4, and 6 Wetland and Upland (Figure 1) Central Area of Each Wetland Stream reaches above and below barrier wall Wetland Study Area N/A Notes: USACE: United States Army Corps of Engineers DWR: North Carolina Department of Environmental Quality, Division of Water Resources NCWAM: North Carolina Wetland Assessment Method MONITORING PLAN ADDENDUM This section presents first comments received from NCDEQ on August 25, 2022 in italicized text followed by responses in plain text. Responses are provided for comments numbered 5.a.i through 5.d.i in the DEQ comment letter. These responses describe additions and modifications to the monitoring scope and serve as an addendum supplement to the existing Monitoring Plan. Wetlands referenced in this addendum are described in Section 3.1.1. of the Waters of the US Findings Report and detailed in Figure 1(a-c). 5a.i "Please sped the `additional information' that will be gathered as part of the baseline characterization. Specifically what data will be collected and how will it be collected? In Section 3.1.1. of the Waters of the US Findings Report seven distinct wetland areas were identified based on initial observations. Please expand the baseline assessment for the seven wetland areas to include characterization of landscape, soils, vegetation, and hydrology. The Division recommends NC Wetland Assessment Methodology (NCWAM) forms completed for each of the seven wetland areas identified to document baseline conditions of these wetland systems. Ideally, a licensed soil scientist should conduct the soils assessments." Geosyntec will collect NCWAM forms within the center of each of the seven wetlands during 2022 data collection field effort, prior to barrier wall construction. Additionally, NCWAM forms engineers I scientists I innovators Wetland Monitoring Plan: Addendum September 8, 2022 Page 3 Geosyntec ° consultants Geosyntec Gmsulie nle of NC, P.C. NC F.ioense Nu.: G35tl9 and C-2.95 will be completed at the same locations for each subsequent year of the monitoring period. NCWAM forms will be completed by an experienced biologist who has completed Wetland Delineation training for USACE methodology, including soil identification and characterization. Additionally, a licensed soil scientist will conduct the soils assessments during the baseline characterization effort planned for September 2022. 5a. ii "The initial wetland determination sample points focus on wetland/upland edges which is appropriate for a delineation effort. However, the Division believes that plan should focus on systemwide functional monitoring of the resources. Therefore, please add additional data collection points in the central areas of wetlands W2, W3, and W6." In an effort to better characterize the wetland form and function as a whole, and not just along the delineated boundaries, Geosyntec established nine additional data points during a 2021 preliminary baseline assessment within the central areas of the wetlands. Data points appended with a "U" (upgradient of the original datapoint) or "D" (downgradient of the original data point) are additional datapoints sampled in 2021 to supplement the original data points (Table 2). The locations of the original and additional data points are provided in Figure 1 of the addendum. These additional data points already established by Geosyntec are consistent with NCDEQs' request for additional data points. Table 2 Wetlands and Associated Datapoints Wetland Type Data Points Additional Data Points Wetland 1 (WI) Wetland 2 (W2) Wetland 3 (W3) Wetland 4 (W4) Wetland 6 (W6) Wetland 6 (W6) Wetland 7 (W7) PFO PFO PFO PFO PEM PFO PFO 1, 2 3, 4 5, 6 7, 8 9, 10 11, 12 14 1U 3U 5U, 5U2, 5U3 N/A N/A 9U, 11D 13D, 13, 13U 5a. iii "At least 4 representative baseline groundwater gauges should be installed before construction to document pre -construction data such as the existing hydroperiod and be used in postconstruction monitoring." At the request of NCDEQ five transects with representative baseline groundwater gauges will be installed within wetlands 2, 3, 4, and 6. Five pairs of upland/wetland gauges will be installed in the wetlands and adjacent upland areas along a transect perpendicular to the wetland boundary (Figure 2); and remain in place throughout the course of the monitoring period. The gauges will be installed to a minimum depth of 15 inches below surface using USACE technical specifications outlined in the June 2005 Technical Standard for Water -Table Monitoring of Potential Wetland Sites, ERDC TN-WRAP-05-2. The gauges are anticipated to be installed during mid - September 2022 prior to barrier wall installation to establish baseline conditions. engineers I scientists I innovators Wetland Monitoring Plan: Addendum September 8, 2022 Page 4 Geosyntec ° consultants Geosyntec Gmsulla nle of NC, P.C. NC F.ioense Nu.: G35tl9 and C-2.95 5a.iv "For any stream segments left as `non -impacted' on the western side of the proposed wall, please propose a baseline assessment. The Division recommends conducting DWR Stream Forms assessments pursuant to the North Carolina Methodology for Identification of Intermittent and Perennial Streams and their Origins, Version 4.11 for all stream proposed to be `nonimpacted. "' Geosyntec will conduct baseline assessment west of the barrier wall for the four non -impacted areas of the streams above the barrier wall using the DWR stream form identified by NCDEQ. These forms will be completed by an experienced biologist or one who has completed the NC Surface Water Identification Training Certificate program. Geosyntec will resurvey the streams west (non -impacted) and east (impacted) of the barrier wall semi-annually to occur in the early growing season and the late growing season. An emphasis of the detailed documentation of monitored streams' biology (macrobenthics and other biological indicators) will be incorporated into the development of the forms. 5b. i "Given the permanent drawdown expected from the proposed barrier wall and the connection between several of the wetlands' primary hydrology to the hillside/upstream seeps, the Division is concerned that visual observation monitoring is not sufficient to demonstrate a 'no impact' determination. Therefore, the Division recommends direct hydrologic measurement using multiple groundwater gauges over a multiyear monitoring period. Groundwater gauges should be installed per US Army Corps of Engineers (USACE) technical specifications guidance." As described in response to comment 5a.iii., multiple groundwater gauges will be installed prior to the construction activities to provide baseline data. These data will be monitored continuously during the five year monitoring period. These data will offer further understanding of the influence of the remedy construction on recorded groundwater levels within the wetland study area. This will also allow specific measurement of hydrological changes of the ground water table in the wetlands. 5b.ii "The monitoring plan's performance standards need to be more specific and measurable. For example, groundwater gauges should meet a minimum 5% hydroperiod during the growing season each year under normal rainfall conditions. Please update the plan to include specific/measurable performance standards. The growing season start/end dates (and source of this information) should be specified in the monitoring plan. In addition, the distance from the site to the rainfall data sources should be provided if there is no on -site rain gauge." To assess groundwater levels within the wetlands groundwater gauges will be monitored throughout the requested 5-year monitoring period post -construction. Each gauge will log groundwater elevation throughout the length of the study. A performance monitoring line of evidence for wetland conditions will be groundwater gauge data meeting a minimum of 5% hydroperiod (12.15 days) each year during the growing season indicated by groundwater within 12 inches (") of soil surface to meet the primary hydrology indicator for high water table. The growing season is 16 March to 14 November (243 days) based on the Natural Resource Conservation Service (NRCS) Bladen County Soil Survey, for each year engineers I scientists I innovators Wetland Monitoring Plan: Addendum September 8, 2022 Page 5 Geosyntec ° consultants Geosyntec Gmsulla nle of NC, P.C. NC License Nu.: G35tl9 and C-2.95 under normal rainfall conditions (a review of NRCS WETS table growing season data did not yield any available data for Bladen or Cumberland Counties). Normal rainfall conditions are determined to occur when rainfall values for a typical year. Typical year conditions will generally be determined by: Normal precipitation conditions based on the three 30-day periods preceding the observation date. For each period, a weighted condition value is assigned by determining whether the 30-day precipitation total falls within, above, or below the 70th and 30th percentiles for totals from the same date range over the preceding 30 years. A determination of "normal," "wetter than normal," or "drier than normal" is made based on the condition value sum. The USACE's Antecedent Precipitation Tool will be consulted to assess typical year precipitation totals. Additional reference rainfall data will be assessed from the Fayetteville Area (PWC) monitoring station, located approximately 15 miles north of the Site. This station is the closest station to the Site which includes historical average month -to -date and year-to-date data to use as a reference for "normal" conditions. Rainfall data may also be augmented using data from Chemours' Onsite meteorological data station which records data on five minute intervals and the United States Geological Survey (USGS) W.O. Huske Dam precipitation gauge (station 02105500) which records rainfall data on 15 minute intervals. The Onsite met station is approximately one mile away from the wetlands and the USGS station is between 100 yards and one mile away from the wetlands. 5b. iii "In addition to groundwater monitoring, the Division believes that an annual assessment of vegetation composition and health is important. The proposed monitoring plan does ident0; good examples of negative wetland plant stressors (lack of growth/vigor, mortality, upland/pioneer plant competition). However, the monitoring plan proposes use of USACE wetland data forms as the assessment tool for identification of the vegetation stressors. These forms were developed as a delineation tool and not a monitoring/functional assessment tool. Therefore, please expand the proposed data collection to include information such as tree/shrub species, height, DBH, health, and wetland indicator status to assess changes in wetland community diversity, density and health. The Division recommends using NCWAM forms. " While use of the USACE methodology can provide adequate data on vegetative conditions by detailing species composition, dominance, indicator status, etc.; Geosyntec agrees with NCDEQ that additional data using NCWAM forms will provide even more detail on vegetative community species composition and condition/health and will supplement the monitoring plan well. Geosyntec will utilize NCWAM forms within each of the seven wetlands. Each form will be completed annually for a five year period at the same location within each wetland. 5c. i "To assess potential secondary impacts to surface waters, the Division believes that semi- annual assessments of surface hydrology indicators is necessary. Please update the monitoring plan to include conducting DWR Stream Form assessments pursuant to the North Carolina Methodology for Identification of Intermittent and Perennial Streams and their Origins, Version 4.11 for all stream segments on a semi-annual basis." engineers I scientists I innovators Wetland Monitoring Plan: Addendum September 8, 2022 Page 6 Geosyntec ° consultants Ceasynlec Gmsulla nle of NC, P.C. NC 1,ioense Nu.: G35tl9 and C-2.95 DWR Stream Form assessments will be conducted for each stream (Figure 1) by an experienced biologist or one who has completed the Surface Water Identification Training Certification course. The form will be completed at the same location semi-annually (early growing season and late growing season) to monitor for potential changes in surface hydrology and the effects on the biological community. Sd. i "The Division believes that three years will likely not be a sufficient length of time to visually assess the extent of stream and wetland function degradation or loss. Therefore, please update the plan to include five years of monitoring for all elements. After five years, the groundwater data, surface hydrology indicators and vegetation composition/health should collectively provide evidence ofwhether the barrier wall is having an impact on adjacent wetlands and surface waters. This information along with a site re -delineation should allow proper assessment ofwhether state wetland and surface water resources have been lost or significantly degraded thereby potentially requiring mitigation." At the request of NCDEQ, the monitoring period will be extended from three years to five years post -construction, while also including the additional monitoring protocol adjustments detailed above. Reports will be submitted annually to NCDEQ by January 31' of the following year. Encl. Tables Table 1: Summary of Monitoring Scope Table 2: Wetlands and Associated Datapoints Figures Figure la-c: Wetland Monitoring Point Locations Wetland Monitoring Plan: Addendum DWR # 20190752v6; USACE Aid # SAW-2019-00296 engineers I scientists I innovators Figures Legend ▪ 2020 Upland Datapoint O 2021 Additional Wetland Datapoint • 2020 Wetland Datapoint OStream Monitoring Datapoint Delineated Feature: i, 111111 Ordinary High Water Mark (OHWM) Palustrine Emergent (herbaceous) Wetland (PEM) Palustrine Forested Wetland (PFO) Wetlands Investigation Area Exclusion Areas Groundwater Guage Transect Notes: 1. The outline of Cape Fear River is a roximate and is based on open data from ArcGIS Online and North Carolina Department of Environmental Quality Online GIS ajorHydro shapefile). 2. Basemap sources: NC OneMap (2 19). North Carolina Department of Information Technology, Government Data Analytics Center, Center for Geographic Information and Analysis. Available at https://vvww.nconemap.gov. 250125 0 250 Feet Wetland Monitoring Point Locations Wetland Monitoring Report - 2021 Chemours Fayetteville Works Cumberland/Bladen County, North Carolina Geosyntec r. consultants Geosyntec ConsulLants al NC, P.C. NC License No.: C-3500 and C-295 Figure Raleigh September 2022 1 Projection. NAD 1983 StatePlane South Carolina FIPS 3900 Feet, Units in Foot US Legend ▪ 2020 Upland Datapoint O 2021 Additional Wetland Datapoint • 2020 Wetland Datapoint OStream Monitoring Datapoint Delineated Feature: i, 111111 Ordinary High Water Mark (OHWM) Palustrine Emergent (herbaceous) Wetland (PEM) Palustrine Forested Wetland (PFO) Wetlands Investigation Area Exclusion Areas Groundwater Guage Transect Notes: 1. The outline of Cape Fear River is a roximate and is based on open data from ArcGIS Online and North Carolina Department of Environmental Quality Online GIS ajorHydro shapefile). 2. Basemap sources: NC OneMap (2 19). North Carolina Department of Information Technology, Government Data Analytics Center, Center for Geographic Information and Analysis. Available at https://vvww.nconemap.gov. 250 125 0 250 Feet Wetland Monitoring Point Locations Wetland Monitoring Report - 2021 Chemours Fayetteville Works Cumberland/Bladen County, North Carolina Geosyntec r. consultants Geosyntec ConsulLants al NC, P.C. NC License No.: C-3500 and C-295 Figure Raleigh September 2022 la Projection. NAD 1983 StatePlane South Carolina FIPS 3900 Feet, Units in Foot US DP9 DP10 %o ❑ AS5-TRI BU; AR�I ES Legend ❑ 2020 Upland Datapoint O 2021 Additional Wetland Datapoint • 2020 Wetland Datapoint OStream Monitoring Datapoint Delineated Feature: i, 111111 Ordinary High Water Mark (OHWM) Palustrine Emergent (herbaceous) Wetland (PEM) Palustrine Forested Wetland (PFO) Wetlands Investigation Area Exclusion Areas Groundwater Guage Transect Notes: 1. The outline of Cape Fear River is a roximate and is based on open data from ArcGIS Online and North Carolina Department of Environmental Quality Online GIS ajorHydro shapefile). 2. Basemap sources: NC OneMap (2 19). North Carolina Department of Information Technology, Government Data Analytics Center, Center for Geographic Information and Analysis. Available at https://vvww.nconemap.gov. 250 125 0 250 Feet Wetland Monitoring Point Locations Wetland Monitoring Report - 2021 Chemours Fayetteville Works Cumberland/Bladen County, North Carolina Geosyntec r. consultants Geosyntec ConsulLants al NC, P.C. NC License No.: C-3500 and C-295 Figure Raleigh September 2022 1b Projection. NAD 1983 StatePlane South Carolina FIPS 3900 Feet, Units in Foot US Legend ▪ 2020 Upland Datapoint O 2021 Additional Wetland Datapoint • 2020 Wetland Datapoint OStream Monitoring Datapoint Delineated Feature: i, 111111 Ordinary High Water Mark (OHWM) Palustrine Emergent (herbaceous) Wetland (PEM) Palustrine Forested Wetland (PFO) Wetlands Investigation Area Exclusion Areas Groundwater Guage Transect Notes: 1. The outline of Cape Fear River is a roximate and is based on open data from ArcGIS Online and North Carolina Department of Environmental Quality Online GIS ajorHydro shapefile). 2. Basemap sources: NC OneMap (2 19). North Carolina Department of Information Technology, Government Data Analytics Center, Center for Geographic Information and Analysis. Available at https://vvww.nconemap.gov. 250 125 0 250 Feet Wetland Monitoring Point Locations Wetland Monitoring Report - 2021 Chemours Fayetteville Works Cumberland/Bladen County, North Carolina Geosyntec r. consultants Geosyntec ConsulLants al NC, P.C. NC License No.: C-3500 and C-295 Figure Projection. NAD 1983 StatePlane South Carolina FIPS 3900 Feet, Units in Foot US Raleigh September 2022 1c