Rivnuts from Homestead, PA on 9/1/2021 9:58:13 AM:
Under wet, rainy conditions fenders will be fine on the GAP and much of the C&O, especially the restored sections of the C&O. The fenders would obviously reduce the amount of trail grit and mud on your shoes and lower legs...as well as your back.
With 3/4" clearance between your tires and fenders, you should be able to traverse the C&O successfully. There would usually be enough water in standing puddles in the tracks to partially flush the mud. At worst you may want/need to stop at some of the trailside hiker/biker campsites with functioning pumps to use a water bottle to help spray some water up under the fenders, especially at day's end so the mud does dry underneath the fenders before starting the next day. If your are diligent and stealthy enough, you'll also find places such as hotels, convenience stores, gas stations, banks, etc. with a hose to flush out your fenders.
As a suggestion, you should probably not try to skirt around the perimeters of the puddles in the tracks to avoid the water. The sides of the puddles become quite slick and add to the risk of crashing should the tires slide back into the bottom of the puddle. I recommend you simple grin and bear it and ride straight through the puddles. You 38mm tires should be ok in doing so but care is always advised.