20120107 Ver 1_PCS Closeout Request for P&U Land Mitigation Site Phase 1_20180829

Nutrien-
Feeding the Future -
Hand Delivered
August 29, 2018
Mr. Tom Steffens
U.S. Army Corps of Engineers
Washington Regulatory Field Office
2407 West 5th Street
Washington, North Carolina 27889
Mr. Anthony Scarbraugh
NC Division of Water Resources
Department of Environmental Quality
943 Washington Square Mall
Washington, North Carolina, 27889
Dear Mr. Steffens and Mr. Scarbraugh:
The P and U Lands Phase 1 mitigation site in Beaufort County, NC, approved for mitigation under a
404 permit issued to PCS Phosphate on June 10, 2009 (Action ID 200110096), and 401 Water Quality
Certification DWQ #2008-0868, version 2.0 (January 15, 2009), has been verbally "signed off' as
successful by the Corps of Engineers and the NC Division of Water Resources during a site visit on
May 3, 2017. Attached is our determination of wetland mitigation credits for the site based on the
5 -year monitoring program and the mitigation ratios specified in the 404 permit. I am now
requesting written approval of the successful completion of the mitigation site and the attached
credit calculations.
If you have any questions, please call me at [phone], or e-mail me at
[e-mail].
incerrely,
1IA'(J. l
e reyV'Furness
enior Scientist
Attachments
PC: Mac Haupt, NCDWR — Raleigh w/attach (Fed Ex)
S. Cooper, CZR — w/attach
23-16-020 — w/attach
1530 NC Hwy 306 South, Aurora, NC USA 27806 / nutden.com
1 Effective January 1, 2018, PCs Phosphate Company, Inc. is an Indirect subsidiary of Nutrien Ltd. PCs Phosphate Company, Inc.
remains the legal operating entity and permittee.

MITIGATION CREDIT CALCULATIONS FOR P AND U LANDS PHASE 1 MITIGATION SITE
Based on Fifth Annual (2016) Report and Monitoring Summary for the P and U Lands Restoration Site
Phase 1, Richland Township, Beaufort County, North Carolina
Prepared by CZR Incorporated
March 2017
(Refer to this report for data)
WETLAND (See enclosed Figure for depiction of areas of types of mitigation).
PHASE 1
Vegetation: Overall Site 317 tpa of planted trees after 5 years
Hydrology:
Nonriparian restoration: 57 of 60 wells > 6.0% hydrology over at least 4 of the 5
monitoring years. Wells 35, 36 and 37 remained <6.0% two or less years out of 5. The
area around each of these wells was delineated, and the results are enclosed in this
package. The total non -wetland area that is represented by these three wells was
determined to be 1.72 acres. This acreage has been pulled out of the success area. 922
acres —1.72 acres = 920.28 acres @ 2:1 = 460.14 credits.
Phase 1 TOTAL WETLAND CREDITS: 460.14 credits

FIFTH ANNUAL (2016) REPORT AND MONITORING SUMMARY
FOR THE
P AND U LANDS RESTORATION SITE PHASE 1
RICHLAND TOWNSHIP
BEAUFORT COUNTY, NORTH CAROLINA
f
Prepared for:
PCS Phosphate Company, Inc.
Prepared by:
CZR Incorporated
March 2017

1.0 PROJECT OVERVIEW
1.1 History. The approximately 3,667 -acre P and U Lands restoration site is part of
the PCS Phosphate Company Inc.'s (PCS) compensatory mitigation to offset unavoidable
impacts to wetlands and waters authorized under United States Army Corps of Engineers
(USACE) Action ID: 2001-10096 and North Carolina Division of Water Quality (DWQ) Water
Quality Certification (WQC) #2008-0868 version 2.0. As described in the mitigation plan prepared
for the pre -construction notification (PCN) to the USACE (CZR 2012), the site was planned to be
constructed in three phases as shown on Figure 1, but as Phase 3 was constructed/planted in
2014, completion of approximately 138 acres of Phase 3 was delayed until 2015. These 138
acres comprise Phase 4 monitoring and are one year behind Phase 3. This annual report
documents the fifth annual monitoring of the 970 acres of Phase 1 of the P Lands portion,
conducted by CZR Incorporated (CZR) of Wilmington, NC. (The P and U designation have no
special meaning other than that was the historic label given to PCS and Weyerhaeuser properties
with similar ownership agreements.)
The design team consisted of Jonathan T. Ricketts, Inc. of Palm Beach Gardens, FL, the
restoration design engineer, PCS, and CZR. Earthwork was performed by Sawyer's Land
Developing, Inc. out of Belhaven, NC and supervised by the design team. Restoration activities
occurred September 2011 -March 2013. Phase 1 construction was authorized with a total of six
NC Division of Land Resources Erosion and Sediment Control permits and included modifications
to four of those permits as construction progressed. Planting of Phase 1 occurred from 12-23
March 2012. Further details of construction and monitoring are included in the As Built Report for
P and U Lands Phase 1 and the first - fourth annual reports (CZR 2013a, 2013b, 2014, 2015, and
2016).
The P and U Lands site is a key component linking PCS Phosphate Company, Inc.'s
(PCS) Parker Farm mitigation site, Bay City Farm mitigation site, Gum Run mitigation site, and
the South Creek Corridor into a large and varied collection of restored wetland and preserved
natural areas (South Creek Corridor Complex). The headwaters and upper valley of historic Gum
Swamp Run, a tributary to South Creek, was also restored as part of the P and U Lands
mitigation site, in Phase 3. Unlike most other PCS mitigation sites, the P and U Lands are not
prior -converted agricultural fields. Other than the existing roads, all of Phase 1 acreage in which
earthwork occurred was in some stage of silvicultural activity, usually various -aged pine stands,
and contained regularly spaced ditches (deeper than the agricultural ditches on other restoration
sites that were filled in as part of restoration work). The removal of all standing timber and
stumps and post-harvest debris presented particular challenges as the organic soils precluded
safe burning of the timber slash on site. To compensate for this, much of the debris was pushed
into mostly uniform piles that provide habitat to wildlife and provide roosting sites for birds.
1.2 Location. The P and U Lands site is located east and west of Bay City Road
(SR1002), approximately 4.5 miles southeast of Aurora, Richland Township, North Carolina. Bay
City Road runs through the P Lands portion of the site, which is bounded on the east by SR 1918
(Peale Road is the unpaved extension of SR 1918) and on the south by "County Line Road" (a
gated gravel road that functions as the Beaufort/Pamlico County border). The U Lands portion of
the site lies west and southwest of Bay City Farm (the western portion of the P Lands site
referred to as the "panhandle" separates Bay City Farm from the U Lands). South Creek and the
South Creek Canal form the northern and northwestern boundaries, Bonner Road forms the
western boundary, and the Pamlico/Beaufort County line forms the southern boundary of the U
Lands (County Line Road itself is the southern boundary of only the eastern half of the U Lands
as the western limit of County Line Road terminates at the midpoint of the south property line).
The entire site is accessed via multiple gated roads along Bay City Road, Peale Road, County
Line Road, and/or Jaime/Executive Road. The site is located within the Pamlico Hydrologic Unit
03020104 of the Tar -Pamlico River basin within the South Creek subbasin at latitude
P and U Lands Restoration Site Phase 1 1 PCS Phosphate Company, Inc.
Fifth Annual Monitoring and Summary Report March 2017

35.233831and longitude 76.775742. Portions of the site can be found on the USGS Aurora,
Bayboro, South Creek, and Vandemere quadrangles (Figure 1).
1.3 Goals and Performance Criteria. The primary goal of Phase 1 activities is to re-
establish a self-sustaining functional wetland complex to allow surface flow to move through
vegetated wetlands before it reaches any stream. Mitigation yields are estimated and
performance criteria are described for the project in detail in the Compensatory Mitigation Plan for
P and U Lands Restoration Site (CZR 2012). Performance criteria and the current status are
summarized in Table 1. Over time the Phase 1 portion of the site is expected to successfully re-
establish approximately:
302 wetland acres of non-riverine swamp forest,
327 wetland acres of pond pine pocosin forest,
238 wetland acres of hardwood flat forest,
25 acres of open water in plugged ditches, and
30 wetland acres of swales.
The remaining 49 acres are comprised of existing roads, perimeter berms, and other
man -dominated areas. Approximately 25,131 linear feet of jurisdictional waters in roadside
ditches and canals were plugged in order to increase the hydroperiods within the adjacent
planted areas (these plugged jurisdictional ditches and canals are included in the 25 acres of
reestablished open water). Approximately 8,700 feet of roadside ditch adjacent to Phase 1 along
the south side of Small Road were plugged in 2013.
Included in the planted communities above are 19.5 acres underlain by hydric soils which
may be "potential non -wetland" areas due to predicted drainage effects from perimeter ditches
that must remain open. Perimeter berm design included a "keyway" feature to interrupt the lateral
drainage effect from the open ditch. Monitoring well data was used to determine the
effectiveness of the interruption.
2.0 REQUIREMENTS
2.1 Normal Rainfall and Growing Season. A continuous electronic rain gauge on the
adjacent Bay City Mitigation Site is downloaded once a month and its data are used in
conjunction with data from nearby automated weather stations (e.g., NRCS WETS data from
NOAA's site at Aurora and at other nearby monitored sites) to determine normal rainfall during
the monitoring period. Bay City rainfall data were compared to the WETS range of normal
precipitation to determine if Bay City rainfall was within the normal range. The range of normal
precipitation for this report refers to the 30`h and 701h percentile thresholds of the probability of
having onsite rainfall amounts less than or higher than those thresholds. The range of normal
and the 30 -day rolling total data lines begin on the last day of each month and the 2016 Aurora
monthly precipitation total is plotted on the last day of each month.
Under the 2010 regional guidance from the Corps of Engineers for wetland hydroperiods,
the normal growing season for Beaufort County is 28 February to 6 December or 282 days,
(WETS table for Beaufort County first/last freeze date 28 degrees F 50 percent probability) (US
Army Corps of Engineers 2010). At the suggestion of the Corps' Washington regulatory field
office, data collected between 1 February and 27 February provide important information related
to analyses of site hydrology during the early growing season, but are not part of the hydroperiod
calculation for success.
2.2 Hydrology. Figure 2 depicts the locations of hydrology monitoring equipment,
Figure 3 shows the locations on Beaufort County soil polygons, and Figure 4 shows the
monitoring locations on the as -built LiDAR. To document surface storage and hydroperiods of all
P and U Lands Restoration Site Phase 1 2 PCS Phosphate Company, Inc.
Fifth Annual Monitoring and Summary Report March 2017

3.4 Design Activities. Approximately 8,700 feet of roadside ditch adjacent to Phase 1
along the south side of Small Road were plugged in 2013. When original planting occurred, fill
was stored along open ditches to be used as future plugs, so those storage areas were not
planted in 2012. The fill was used to plug the roadside ditches and those areas were planted in
February 2014 in conjunction with Phase 3 planting. Approximately 14 acres were planted in
2014 with 7,750 stems of swamp chestnut oak (Q. michauxir), swamp black gum, willow oak (Q.
phellos), and bald cypress (Taxodium distichum) in various combinations dependent on planting
zone; these areas included the plugs, a segment inside the berm along Peale Road, and areas
adjacent to the NCWRC-requested parking lots at the west end of Bay City Roads 1 and 3 and on
the south side of Bay City 4. There are no monitoring plots within these planted areas.
3.5 Photographic Documentation. A few photos representative of 2016 conditions
are included with this report (Appendix B). More are available upon request.
Over the five monitoring years (2012-2016), rainfall recorded at the Bay City rain gauge
was considered normal or below normal WETS rainfall for all of 2012 and 2013, above normal for
two months in 2014, above normal for slightly over two months in 2015, and above normal for
over four months in 2016, as shown in Table 6. Post -restoration wetland hydroperiods during all
and normal rainfall conditions demonstrate that by the fifth monitoring year, 93 percent of wells
(56 of 60) recorded a wetland hydroperiod for all monitoring years, PUM45 had a wetland
hydroperiod for four out of five monitoring years, and three wells (PUM35, 36, and 37) had a
wetland hydroperiod for less than 50 percent of monitoring years (Tables 7a and 7b). Of the 60
wells, 57 wells have met or exceeded the hydrological performance criteria as described in Table
1.
A field investigation of non -hydric soils around the three wells that did not meet the
hydrology restoration criterion was conducted on 23 February 2017 (Appendix C). A 1.7 -acre
polygon of non -hydric soil has been subtracted from the 15 acres represented by PUM35 and the
0.02 -acre non -hydric soil area also has been subtracted from the 15 acres represented by
PUM36. However, for PUM37, no acres will be subtracted from the 15 -acre area represented by
this well as all soils were found to be hydric. Based on the field investigation, it appears PUM36
and PUM37 were installed on or next to old woody debris piles. Although PUM36 and PUM37 did
not exhibit a wetland hydroperiod during the monitoring period, they are surrounded by hydric soil
and as the woody debris in the soil profile decays further, wetland hydrology in the vicinity of each
well is expected to return.
Overall survival of trees that were unquestionably alive in the 58 plots from the time of
planting (2012) to the fifth annual fall survey was 62 percent, with a corresponding density of 317
trees per acre. Overall survival of shrubs that were unquestionably alive from the time of planting
to the fifth annual fall survey was 53 percent with a corresponding density of seven shrubs per
acre. The density of unquestionably alive trees and shrubs combined is 324 stems per acre. The
current planted tree density is higher than the 260 stems required for success. Woody non -
nuisance wetland volunteers provide an average of an additional 104 stems per plot and as
shown in Table 5, they increase the stem count per acre to 428. There is a diverse assemblage of
planted trees interspersed with planted shrubs in addition to a woody wetland volunteer
component which demonstrate the site has met or exceeded the vegetation performance criteria
as described in Table 1.
P and U Lands Restoration Site Phase 1 6 PCS Phosphate Company, Inc.
Fifth Annual Monitoring and Summary Report March 2017

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SCALE: AS SHOWN
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DATE: 10/20/16
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ZONE 6 HARDWOOD FLAT 2
ZONE 7 SWALES
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SCALE: AS SHOWN JAPPROVED BY: DRAWN BY: TLJ
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APPENDIX C
P and U Lands Phase 1 Non -hydric Soil Field Investigation
23 February 2017
1. P and U Lands Phase 1 non -hydric Soil Field Investigation - text and photos
2. Table C
3. Figure C-1
4. Figure C-2

P and U Lands Phase 1
Non -hydric Soil Field Investigation
23 February 2017
A field investigation of the soils surrounding the three wells (PUM35, 36, and 37) that did not meet the
hydrology restoration criterion was conducted on 23 February 2017 (Figures C-1 and C-2, Table C).
According to the Beaufort County soil survey, two of the wells (PUM36 and PUM37) are underlain by
hydric soils, Ponzer and Wasda respectively, and PUM35 is underlain by Tarboro, a non -hydric soil.
At the time of the field investigation on 23 February, the roadside ditch on the south side of Bay City Road
No 4 was fully charged as were the partially filled/plugged ditches on either side of the two field sections
of the site where the three wells are located. At each well, the soil profile was explored in the immediate
vicinity of the well to a depth of at least 15 to 20 inches and then away from the well along a vector until
non -hydric soil was encountered. If non -hydric soil was encountered, then further holes were augured in
the vicinity to refine the non-hydric/hydric boundary and a polygon was delineated to represent the non -
hydric soils encountered. If only hydric soil was encountered in the vicinity of the well, then numerous
holes were augured in concentric circles around the well at 10-, 15-, and 30 -foot distances from the well
to ensure an adequate area around each well was investigated.
PUM35
From the road, the herbaceous vegetation around PUM35 appeared to somewhat follow the shape of the
Tarboro polygon shown in the soil survey, so that vegetation boundary was investigated first; however,
contrary to expectations, the herbaceous vegetation was not an accurate indicator of the hydric/non-
hydric soil boundary. In the vicinity of PUM35, the investigation revealed that a 1.7 -acre polygon around
the well was non -hydric and presumed to be Tarboro soil. The non -hydric soil had a top layer around 1 to
4 inches thick of dark loamy sand followed by a layer of yellow or reddish orange sand. There was an
obvious elevation difference and change in hydrology surrounding the area that was delineated as non -
hydric soil.
PUM35 well marker pole is circled.
The hydric soil had a top layer of dark loamy sand 4 inches thick with faint redox concentrations occuring
as pore linings. The next layer was a mixture of 10YR 4/1 and 10YR 6/2 sand with 5 percent of the matrix
as faint redox concentrations. The soil shown in Photo 3 met hydric soil national hydric soil indicator S7
Dark Surface described in the Field Indicators of Hydric Soils in the United States (USDA 2010).
F and U Lands Restoration Site Phase 1 C-1 PCS Phosphate Company, Inc.
Fifth Annual and Summary Report March 2017

looking towards hydric soil.
PUM36
At PUM36, a soil plug next to the well revealed a top layer of black soil with some muck present
approximately eight inches thick, and was followed by a layer of yellowish brown soil. Among all the
holes dug within the concentric circles around the well, only two contained non -hydric soil. Approximately
15 feet away from the well, the top black layer was thicker and underlain by a depleted layer with a
chrome of 2; therefore, a 15 -foot radius around the well (0.02 acre) was considered non -hydric soil based
on the yellowish brown soil horizon found in the two holes near the well. It is also important to note older
woody debris in various stages of decay was found in many of the soil plugs near the well. The small,
dense clump of Rhus copalllnum (winged sumac) about 8 feet wide suggests a drier area next to the well.
Like living and decaying tree roots which are known to affect hydraulic conductivity of soils, the woody
debris creates pathways for water to migrate lower in the profile and be held in the profile for shorter
periods; either characteristic would alter the hydrology in the immediate vicinity.
Photo 5. Soil plug next to PUM36.
PUM37
The soil surrounding PUM37 was black sandy muck deeper than 12 inches with uncoated sand grains
present in various amounts within most all of the holes dug, suggesting the movement of water through
the profile. All soil plugs in a 30 -foot radius around the well were considered hydric, met the A7 5 cm
Mucky Mineral indicator, and appeared to confirm the Wasda muck as shown and described in the county
soil survey. The well was surrounded by a small, dense clump of winged sumac about 10 feet wide, and
similar to PUM36, woody debris in various stages of decomposition was found in the soil plugs. In the
investigation of the soils around PUM37, many of the holes encountered more "resistant" woody material
than that at PUM36; another hole often needed to be started in order examine the target profile thickness.
As at PUM36, it is likely that the woody debris in the vicinity of PUM37 alters the hydrology.
P and U Lands Restoration Site Phase 1 C-2 PCS Phosphate Company, Inc.
Fifth Annual and Summary Report March 2017

standing at edge of 30 -foot radius in the
background through sumac clump (circled).
SUMMARY
The 1.7 -acre polygon of non -hydric soil has been subtracted from the 15 acres represented by PUM35
and the 0.02 -acre non -hydric soil area also has been subtracted from the 15 acres represented by
PUM36. However, for PUM37, no acres will be subtracted from the 15 -acre area represented by this well
as all soils were found to be hydric. We propose that the non -wetland hydroperiods demonstrated at
PUM36 and PUM37 are representative of a very small area near each well and can be regarded in the
same manner as the acres beneath the piles of woody debris left on the surface of the site. Although the
surface woody debris piles were not planted with hardwood seedlings, they are underlain by hydric soils,
the debris piles will eventually decay, and appropriate volunteer wetland vegetation will colonize the
footprint over time. Although PUM36 and PUM37 did not exhibit a wetland hydroperiod during the
monitoring period, they are underlain by (except for the 0.02 -acre around PUM36) and surrounded by
hydric soil, and as the woody debris in the soil profile decays further, wetland hydrology similar to that of
the surrounding areas will return.
P and U Lands Restoration Site Phase 1 C-3 PCS Phosphate Company, Inc.
Fifth Annual and Summary Report March 2017

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