NCS000222_Fact sheet binder_20240208

DEQ / DEMLR
FACT SHEET FOR NPDES INDUSTRIAL INDIVIDUAL
STORMWATER PERMIT DEVELOPMENT
Basic Information for Permit Issuance and Renewals:
Permit Writer/Date Brianna Young 1/30/2024
Permit Number NCS000222
Owner/Facility Name Leland Land,LLC/Carolina Pole Leland, Inc.
SIC AICS Code/Category 2491 (32111)/Wood preserving
Basin Name/Sub-basin number Cape Fear/03-06-17
Receiving Stream/HUC UT to Sturgeon Creek/030300050502
Stream Classification/Stream Segment Q Sw/ 18-77-1
Is the stream impaired on 303 d list]? Yes; See Section 2 below
Any TMDLs? No
Any threatened and/or endangered species? Yes; See Section 2 below
Any compliance concerns? See Section 2 below
Any pennit mods since lastpermit? Yes; See Section 1 below
New expiration date 2/28/2029
Comments on Draft Permit? See Section 6(below)
Section 1. Facility Activities and Process:
Carolina Pole Leland, Inc. is a wood treatment facility that treats utility poles using chromated copper
arsenate (CCA). Per information provided via email 4/25/2023, the facility no longer uses Penta and
only treats wood with CCA. The facility previously used pentachlorophenol (penta) for wood treatment
but ceased in April 2022. At specific customer requests, the site will add a water-soluble oil treatment to
keep the poles soft for climbing.
With the permit renewal application,permittee requested the following changes:
• Removal of dioxins from monitoring requirements and continued monitoring of
pentachlorophenol only be continued as dioxins are entering the stormwater from offsite and
dioxins found in stormwater are in the particulate form, so monitoring would not reflect a water
concentration.
• Removal of monitoring for penta as Carolina Pole must transition to another preservative system.
• Substitute monitoring for chromium III rather than copper as stormwater from offsite already
contains copper at levels exceeding the benchmark of 10 ppb.
Per information available in the permit file, the site is a brownfield site. An email dated 5/10/2005 from
Daphne Olszewski (Brownfields Program Manager) states dioxins were discovered onsite and two areas
would be capped. Requested dioxin monitoring be added in order to simplify RCRA regulation of the
site. Per the 2018 review document, the materials used on site for wood treatment indicate that dioxin
may be in the material used(PCP) or produced with some of the treatment activities (heating of PCP),
and that it was also possible dioxin is due to past activities at the site. An email dated 2/23/2018 states
Pentachlorophenol concentrate contains microcontaminants of hexachlorobenzene (HCB),
polychlorinated phenols, CDDs, and CDFs. Diesel fuel was used to dilute pentachlorophenol
concentrate from 40%to between 5-9%, and the diluted PCP was the wood treatment solution. Per an
email dated 1/24/2024 from the Division of Waste Management(DWM), the site is still considered a
Brownfields site and will likely remain a Brownfields site for a very long time.
Page 1 of 8

Per information provided by the DEQ Division of Waste Management(DWM) (via email dated
1/29/2024), there are 2 areas capped and dioxins are present on site. Historical contaminants at the site
include arsenic, organics including PAHs, chromium, copper,pentachlorophenol, and dioxins. The
property owner is required to maintain the existing caps and to continue to monitor groundwater
conditions annually for VOCs, SVOCs, and metals and monitor soil every 5 years for dioxins, arsenic,
and pentachlorophenol. More recently there have been releases of pentachlorophenol and copper
chromated arsenic to uncoated concrete in multiple areas of their facility, and the HWS required a soil
assessment around the transfer deck concrete slab and the sub-slab area adjacent to the inactive steam
line/filter press, which found exceedances for arsenic and pentachlorophenol in all samples collected and
hexavalent chromium in some of the samples. They also had a release of copper chromated arsenate
product in December 2022 and a fire in the kiln building (no releases associated with the fire) around
April 2023.
Outfall SW001:
Drainage area consists of treated material storage areas, diesel tank, scale, peeler, boiler, maintenance,
treating plant tanks, and a drip bay. Potential pollutants include CCA, wood chips, bark, diesel, and oil.
Why Industrial Sites with Stormwater are Subject to a Permit: Federal NPDES regulations define
stormwater discharge associated with industrial activity in 40 CFR §122.26 (b)(14) as: "the discharge
from any conveyance that is used for collecting and conveying storm water and that is directly related to
manufacturing,processing or raw materials storage areas at an industrial plant. The term does not
include discharges from facilities or activities excluded from the NPDES program under this part 122.
For the categories of industries identified in this section, the term includes, but is not limited to, storm
water [sic] discharges from industrial plant yards; immediate access roads and rail lines used or traveled
by carriers of raw materials, manufactured products, waste material, or byproducts used or created by
the facility; material handling sites; refuse sites; sites used for the application or disposal of process
waste waters (as defined at part 401 of this chapter); sites used for the storage and maintenance of
material handling equipment; sites used for residual treatment, storage, or disposal; shipping and
receiving areas; manufacturing buildings; storage areas (including tank farms) for raw materials, and
intermediate and final products; and areas where industrial activity has taken place in the past and
significant materials remain and are exposed to storm water. For the purposes of this paragraph, material
handling activities include storage, loading and unloading, transportation, or conveyance of any raw
material, intermediate product, final product, byproduct or waste product. The term excludes areas
located on plant lands separate from the plant's industrial activities, such as office buildings and
accompanying parking lots as long as the drainage from the excluded areas is not mixed with storm
water [sic] drained from the above described areas."
Section 2. Monitoring Information and Compliance History:
• June 2018 to July 2022,benchmarks exceeded for:
o TSS Ix
o Copper 3x
o Penta Ix
o Dioxin was detected in every sample taken
o pH min not reached 1 x
o June 2020 toluene sample was not down sampled to benchmark level—unable to
determine if actually above benchmark or not
Page 2 of 8

• Previous permit required monitoring for benzene, toluene, and total xylene during 2020 only (no
benchmarks)
o Monitoring was not conducted
• Previous permit required a feasibility study for dioxin to reduce dioxin discharges from the
facility.
o Study results were due by 4/30/2020; received 4/28/2020
• Per the July 2023 inspection report, the facility has changed methods from oil-based application
to water-based application. The facility keeps less inventory on site than previously and the
treated poles are kept onsite no more than a week before being shipped out.
303(d) listing:
#urgeon Creek " ;5w 5. FW Miles
5262 From source to Brunswick River
PARAMETER IR CATEGORY CRITERIA STATUS REASON FOR RATING 303D YEAR
Hexmient Chromium Fish Tissue Advisory =1ExceedingCriteria 10HHS Fish Consumption Advisory
(Advisory,FC,NC)
�rsenic Fish Tissue Advisory[Advisory,FC,NC} 0JExceeding Criteria IIDHHS Fish Consumption Advisory
Threatened/Endangered Species:
There is one endangered species in the vicinity of discharge, Littleleaf Sneezeweed(Helenium
brevifolium; NC status: E), and one species of concern, Coppery Emerald (Somatochlora georgiana;NC
status: SR). In the nearby vicinity, there are additional threatened/endangered and species of concern in
the nearby vicinity of the facility, including: Savannah Indigo-bush (Amorpha confuse; NC status: T),
Hidden-flowered Witchgrass (Dichanthelium Cryptanthum; NC status: SR-T), Venus Flytrap (Dionaea
muscipula; NC status: T), Rough-leaf Loosestrife (Lysimachia asperulifolia;NC status: E; Federal
status: E), Running Oak(Quercus elliottii;NC status: E), Savannah Nutrush (Scleria verticillate;NC
status: SR-P), and Twisted-leaf Goldenrod(Solidago tortifolia;NC status: E).
Section 3. Proposed Monitoring for Stormwater Discharges:
The Division considered potential pollutants from past and present industrial activities and data was
submitted for June 2018 to July 2022. Quantitative sampling included pH, TSS, arsenic, copper,penta,
COD, O&G, dioxin, benzene, toluene, and xylene.
Parameters are based on potential pollutants in the drainage area, sampling results, and in some cases,
dependent upon future activities (e.g., ash removal through the drainage area). Below is a table of the
proposed monitoring for each outfall at the Carolina Pole Leland, Inc. site.
Page 3 of 8

Outfall SW001
Quarterly monitoring
Total Suspended Solids BASIS: Potential pollutant from drainage area and BMP effectiveness
(TSS) indicator.
Quarterly monitoring
pH BASIS: Pollutant indicator
Quarterly monitoring
Total Rainfall BASIS: Discharge potential indicator
Quarterly monitoring
Non-Polar Oil &Grease BASIS: Potential pollutant from lubricants; Method 1664 SGT-HEM
targets petroleum-based O&G
Quarterly monitoring
Monthly Oil Usage BASIS: Potential pollutant from drainage area
Quarterly monitoring
BOD BASIS: Discharge potential indicator
Quarterly monitoring
COD BASIS: Discharge potential indicator
Quarterly monitoring
Total Arsenic BASIS: Potential pollutant from drainage area
Quarterly monitoring
Total Chromium BASIS: Potential pollutant from drainage area
Quarterly monitoring
Total Copper BASIS: Potential pollutant from drainage area
Quarterly monitoring
Dioxin BASIS: Potential pollutant from drainage area
Quarterly monitoring
Pentachlorophenol BASIS: Potential pollutant from drainage area
Quarterly monitoring
Total Hardness BASIS: Monitoring required for hardness dependent metals
Stormwater Benchmarks and Tiered Response: Rather than limits,North Carolina NPDES
Stormwater permits contain benchmark concentrations. Stormwater benchmarks are numerical action
levels for stormwater monitoring. Benchmarks are not effluent limits, and benchmark exceedances are
not permit violations. Benchmarks provide facilities a tool for assessing the significance of pollutants in
stormwater discharges and the effectiveness of best management practices (BMPs). Benchmark
Page 4 of 8

concentrations are intended as guidelines for the facility's development and implementation of the
Stormwater Pollution Prevention Plan(SWPPP).
Benchmark exceedances require the permittee to increase monitoring, increase management actions,
increase record keeping, and/or install stormwater BMPs in a tiered program. The permit establishes a
tiered approach to specify actions the permittee must take in response to analytical results above
benchmark concentrations. The tiered structure of the permit provides the permittee and DEMLR wide
flexibility to address issues that may arise with one or more parameters and/or outfalls.
Metals benchmarks are calculated to mimic acute water quality standards and with the guidance of
DWR. NC DWR follows established federal procedures for calculating acute standards when developing
the benchmarks. Just like the acute standards, metals benchmarks normally reflect one half of the
calculated Final Acute Value (the "1/2 FAV"). In most cases, translation into total recoverable values is
based on an assumed hardness of 25 mg/L and a total suspended solids (TSS) concentration of 10 mg/L.
Acute standards protect aquatic life from negative impacts of short-term exposure to higher levels of
chemicals where the discharge enters a waterbody. The Stormwater Permitting Program applies this
approach because of the ephemeral nature of rainfall events.
The Division may evaluate results to determine if a smaller suite of parameters for some outfalls is
adequate to characterize potential pollution or BMP effectiveness. For example, one or more metals or
other parameters may serve as an adequate tracer for the presence of ash pollution during disturbance or
ash removal in specific drainage areas at this site. For parameters that do not have a stormwater
benchmark, the Division may develop a benchmark value if appropriate toxicity data become available
or if rising trends in concentrations suggest a persistent source.
A summary of the benchmarks in the draft permit, and their basis, is below:
Parameter Benchmark Basis
Total Suspended 100 mg/L National Urban Runoff Program(NURP) Study, 1983
Solids TSS
H 6 s.u. —9 s.u. NC Water Quality Standard(Range)
Non-Polar Oil & Review of other state's daily maximum benchmark
Grease 15 mg/L concentration for this more targeted O&G;NC WQS that
EPA Method 1664 does not allow oil sheen in waters
SGT-HEM
BOD 30 mg/L BPJ; Based on Secondary Treatment Regulation(40 CFR
133.03
COD 120 mg/L BPJ; Generally found at levels 4x BOD5 in domestic
wastewaters
Arsenic Total 340 /L Acute Aquatic Criterion, '/2 FAV
'/2 FAV; Based on (Cr III+Cr VI) acute thresholds and
Chromium (Total) 905 µg/L assumption that industrial activities here are not a source of
hexavalent chromium
Copper Total 10 /L Acute Aquatic Criterion, '/2 FAV
Dioxin Detection Dioxins are bioaccumulants; Any detection is recognition of a
problem
Pentachlorophenol 19 µg/L '/2 FAV at pH 7.8
Page 5 of 8

Stormwater Pollution Prevention Plan: The proposed permit conditions reflect the EPA and NC's
pollution prevention approach to stormwater permitting. The Division's maintains that implementation
of Best Management Practices (BMPs) and traditional stormwater management practices that control the
source of pollutants meets the definition of Best Available Technology (BAT) and Best Conventional
Pollutant Control Technology(BCT). The permit conditions are not numeric effluent limitations but are
designed to be flexible requirements for implementing site-specific plans to minimize and control
pollutants in stormwater discharges associated with the industrial activity. Title 40 Code of Federal
Regulations (CFR) §122.44(k)(2) authorizes the use of BMPs in lieu of numeric effluent limitations in
NPDES permits when the agency finds numeric effluent limitations to be infeasible. The agency may
also impose BMP requirements which are "reasonably necessary" to carry out the purposes of the Act
under the authority of 40 CFR 122.44(k)(3). The conditions proposed in this draft permit are included
under the authority of both of these regulatory provisions. In essence, the pollution prevention and BMP
requirements operate as limitations on effluent discharges that reflect the application of BAT/BCT.
Flexibility in Tier Responses: Tier Two actions provide an opportunity for the permittee to propose an
alternative monitoring plan for approval by the Region:
• Alternatively, in lieu of steps 2 and 3, the permittee may, after two consecutive exceedances,
exercise the option of contacting the DEMLR Regional Engineer as provided below in Tier
Three. The Regional Engineer may direct the response actions on the part of the permittee as
provided in Tier Three, including reduced or additional sampling parameters or frequency.
• If pursuing the alternative above after two consecutive exceedances, the permittee may propose
an alternative monitoring plan for approval by the Regional Engineer.
The permit therefore allows the permittee to petition the Regional Office for monitoring changes sooner
than Tier Three (upon any four benchmark exceedances) and gives guidance on one option to take. For
example, the permittee may request that mercury only be monitored semi-annually under the tiers, or
that only parameters over the benchmark be monitored more frequently. In this way, changes to the
monitoring scheme for any outfall could be handled outside of a permit modification.
Other Proposed Requirements:
• It is standard for Stormwater Pollution Prevention Plan(SWPPP)requirements to include an
annual certification that stormwater outfalls have been evaluated for the presence of non-
stormwater discharges, and if any are identified, how those discharges are permitted or otherwise
authorized.
• Requirement to submit a request for permit modification if the facility identifies or creates any
new outfalls, removes outfalls, or alters any drainage area that changes potential pollutants.
• The Division expects the permittee to apply best professional judgment and consider the safety
of its personnel in fulfilling sampling obligations under the permit.
• Federal regulations require electronic submittal of all discharge monitoring reports (DMRs). If a
state does not establish a system to receive such submittals, then permittees must submit DMRs
electronically to the EPA.
• Quarterly QualitativeNisual Monitoring to assure regular observation of outfalls throughout
year.
Page 6 of 8

Section 4. Changes from previous permit to draft:
• Regulatory citations have been added
• Monitoring increased from semi-annually to quarterly for all parameters (qualitative and
quantitative)
• "No discharge" clarifications made
• Feasibility study and online SWPPP requirements have been removed per updated stormwater
program requirements
• eDMR requirement added
• Boilerplate language moved into body of the permit; boilerplate no longer attached
• Outfall-specific monitoring been implemented to reflect industrial activity and potential
pollutants specific to each discharge area
• Permit condition for dioxin feasibility study removed as the study was received by DEMLR on
4/28/2020
• Monitoring for BOD added based on materials stored onsite
• Monitoring for total chromium added due to CCA usage onsite
• Monitoring for penta, benzene, toluene, and xylene have been removed as penta is no longer
used as a wood treatment process
• Monitoring for total hardness added as monitoring for hardness dependent metals is required
• Benchmarks updated for parameters per guidance from DWR Standards group on stormwater
benchmarks
Section 5. Changes from draft to final:
• Monitoring for pentachlorophenol added back into the permit
o Potential pollutant of concern due to previous usage in industrial process, one benchmark
exceedance during previous permit cycle, and DWM provided information regarding a
release of penta
o Footnote added regarding sampling during release and spills
o Removal can be considered at next renewal
• Monitoring for dioxin reduced to annually
o Potential pollutant of concern due to previous usage in industrial process
o Footnote added regarding sampling during release and spills
o Removal can be considered at next renewal
Section 6. Discussions with the Facility and Regional Office:
• Initial contact with facility: 4/6/2023
• Initial contact with Regional Office: 4/6/2023
• Draft sent to CO peer review: 11/15/2023
• Draft sent to Regional Office: 12/15/2023
• Final permit sent for supervisor signature: 1/31/2024
Page 7 of 8

Section 7. Comments received on draft permit:
• Michael Rouse (Carolina Pole Leland, Inc.; via email 1/8/2024): Carolina Pole is requesting that
the dioxin monitoring requirement be removed when the final permit is issued. (see attached
document for full comments)
o DEMLR response: Dioxin is a pollutant of concern due to its historical usage for wood
treatment at the site. Additionally, it has come to the Stormwater Program's attention that
pentachlorophenol is still a potential pollutant of concern after reviewing information
provided by the DEQ Division of Waste Management(DWM). Therefore monitoring for
dioxin shall remain in the permit and monitoring for pentachlorophenol will be added
back into the permit.
Page 8 of 8

LOCALiQ
StarNews I The Dispatch PO Box 631697 Cincinnati,OH 45263-1697
Times-News
NORTH CAROLINA
PROOF OF PUBLICATION ENVIRONMENTAL
MANAGEMENT COMMIS-
SION ITENT TO Joyce Sanford NPDES STORMWATER
Joyce Sanford DISCHARGE PERMITS
Nc Division Of Energy,Mineral And Land Resources The North Carolina Environ-
1612 Mail Service CTR mental Management Cam-
mission Raleigh NC 27699-1600 NPDES Proposes to
isdis-
charge Permit(s) to the Per-
son(s) listed below. Public
comment or oblection to the
STATE OF NORTH CAROLINA,COUNTY OF NEW HANOVER draft Permits is Invited.
Written comments regarding
The Wilmington Star-News, a newspaper printed_and published in the Proposed Permit will beaccepted until 30 days after
the city of Wilmington,and of general circulation in the County of the Publish date of this notice
New Hanover,State of North Carolina,and personal knowledge of and considered in the final
P 9 determination regarding Per-
the facts herein state and that the notice hereto annexed was mit issuance and Permit
Published in said newspapers in the issue dated: provisions. The Director of
the NC Division of Energy,
Mineral, and Land Re-
12/22/2023 sources (DEMLR) may hold
a public hearing should there
be a significant degree of
and that the fees charged are legal. public interest. Please mail
Sworn to and subscribed before on 12/22/2023 comments and/or informa-
tion requests to DEMLR at
1612 Mail Service Center,
Raleigh, NC 27699-1612.
•Leland Land, LLC (PO Box
370, Leland, NC 28451-03701
has requested renewal of
permit NCS000222 for the
Carolina Pole Leland Inc.
facility in Brunswick County.
This facility discharges to
unnamed tributary to Stur-
geon Creek in the Cape Fear
River Basin.
Interested persons may visit
DEMLR at 512 N. Salisbury
Legal Clerk street, Raleigh, NC 27604 to
g review information on file.
Additional information on
NPDES permits and this no-
Notary,'State of Wl,County of Brown rice mar be found on our
arY+ ty webs://d
I https://deci.nc.gov/obout/
tlivlsions/energy-minerol-
My cor elision expires and-land-resourcesistorm
water/stormwater-program/
Publication Cost: $168.74 stormwater-public-notices,or
by contacting Brionna Young
Order No: 9648239 #of Copies: at brionno.young®deq.nc.gov
or 919-707-3647.
Customer No: 745790 1
PO#:
THIS IS NOT AN INVOICE!
Please do not we(his farm for payment remittance.
KAITLYN FELTY JAN0
Notary Public 9107�
State of Wisconsin StO�WaterPro�
�-� Page 1 of 1

Young, Brianna A
From: Reams, Michele B <[e-mail]>
Sent: Monday,January 8, 2024 3:34 PM
To: Young, Brianna A
Cc: Wiseman, Kevin W; Rouse, Michael T;Jones, George D; [e-mail]; House,
Sarah J
Subject: [External] RE: Draft stormwater permit NCS000222
Attachments: 2023 Stormwater Permit Draft Response Letter.pdf
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Brianna—
Please find attached the response to the Stormwater Permit Draft for NCS000222 for our facility. If there are any
questions, please feel free to contact us.Thanks
Respectfully,
�chele
Michele Reams
Zero Harm Coordinator
Koppers Utility& Industrial Products I P.O.Box 370 1 Leland, NC 28451 1 United States
T: [phone] M: [phone]
reamsmb(cDkoppers.com
K0PPERS
Responsible Care I A member of the American Chemistry Council
Learn more about Koppers: http://www.koppers.com
The contents of this a-mail are intended for the use of the intended addressee(s)only and maybe confidential.If you are not an intended addressee,note that any disclosure,copying,distribution or use
of this e-mail message or the contents hereof is prohibited.
From:Young, Brianna A<[e-mail]>
Sent: Friday, December 15, 2023 10:04 AM
To: Rouse, Michael T<[e-mail]>
Cc: Reams, Michele B<[e-mail]>; Wiseman, Kevin W<[e-mail]>
Subject: Draft stormwater permit NCS000222
WARNING: External Sender
Good morning,
Please find attached a copy of the draft stormwater permit for Leland Land, LLC(NCS000222).A hard copy of this draft
permit will be placed in the mail to Michael Rouse. Please provide any comments by January 22, 2024.
Thank you,
Brianna Young, MS(she her)
1

Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
Brian na.Young@d eq.nc.goy(e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
2

Michael Rouse KOPPERS .
Assistant Operation Manager
Koppers Utility and Industrial Products
P.O.Box 370
Leland, NC 28451
Tel [phone]
January 8, 2024 Fax [phone]
[e-mail]
www.koj)pers.com
VIA EMAIL AND USPS
NC DEMLR
Stormwater Permitting Program
Attn: Brianna Young
1612 Mail Service Center
Raleigh, NC 27699-1612
Re: Draft NPDES Stormwater Permit
NPDES Permit NCS 000222
Carolina Pole Leland, Inc.
Brunswick County
Dear Ms. Young:
Carolina Pole Leland, Inc. (Carolina Pole) has reviewed the Draft Permit, NCS 000222, which
was transmitted to us on December 15, 2023. Although the draft permit is generally as expected,
there is one provision that was not expected. That provision is the requirement to monitor for
dioxins, and Carolina Pole would like to provide comments on that provision, seeking its removal
from the final permit.
Our environmental consultants discussed the dioxin monitoring requirements in our present
permit with DEQ representatives during the preparation of the application for renewal in 2021.
This issue was discussed with Ms. Bethany Georgoulias and Ms. Aana Gamble. After discussing
the issue with Ms. Gamble, and providing background information, Ms. Gamble indicated that
monitoring for dioxins was not typically required of industrial facilities and that she thought it
would be possible to eliminate it from the Carolina Pole permit since the basis for requiring the
analysis, the use of pentachlorophenol at the site, was no longer applicable since
pentachlorophenol is no longer available in the U.S. Although DEQ removed the requirement to
monitor for pentachlorophenol, it retained the requirement to monitor for dioxins.
Carolina Pole is requesting that the dioxin monitoring requirement be removed when the final
permit is issued. Although the basis of this request was submitted in the permit application,
Carolina Pole would like to provide additional information in these comments in support of this
request.
The basis of the request to discontinue dioxin monitoring is based on regulatory, technical, and
monetary considerations. The transmittal letter with the draft permit states: "Monitoring for
dioxins shall remain in the permit as dioxins are present in the stormwater being discharged from
the site." If that is the basis for requiring dioxin analyses, then every stormwater permit should
contain a requirement to monitor for dioxins because it is impossible to take a stormwater sample

NC DEINLR
Stormwater Permitting Program
Attn: Brianna Young
January 08,2024
Re: Draft NPDES Stormwater Permit
NPDES Permit NCS 000222
Carolina Pole Leland, Inc.
Brunswick County
Page 2
at any location, even pristine and remote locations, that does not contain detectable levels of
dioxins. Given the analytical methods available today, it is impossible to take any environmental
sample of soil or surface water and have the results be ND for all the dioxins and dioxin-like
compounds (DDLCs), generally due to the deposition of airborne particulates containing DDLCs.
So, the stormwater leaving every industrial site, every highway, every parking lot, and every
municipal storm sewer system will contain detectable levels of DDLCs. This is confirmed by
testing of stormwater that enters the Carolina Pole site from off-site as reported in the Carolina
Pole permit application. The ubiquitous nature of DDLCs makes them a poor candidate for
stormwater monitoring purposes unless there is a recognized source of DDLCs on the site being
monitored, as was the case for the Carolina Pole site when it was using pentachlorophenol as a
wood preservative. Now that this potential source is no longer present at the site, there is no
regulatory basis to continue this monitoring. There is already 15 years of site DDLC monitoring
data available indicating its presence in stormwater entering the site from off-site sources as well
as leaving the site in the monitored outfall. There are now no on-site activities that could be
contributing DDLCs to the stormwater, other than air emissions from the boiler or mobile
equipment operated at the site. Many hundreds of industrial, commercial, and governmental sites
in North Carolina have boilers or other combustion sources and mobile equipment operating on
their sites, and Carolina Pole is not aware of any of these sites being required to monitor for
DDLCs. Continued monitoring will find the presence of DDLCs in every sample, requiring
immediate notifications and putting the site into the Tier 3 response mechanism, when there is
nothing the site can do to mitigate these positive results.
There are presently no State surface water standards for DDLCs, so there is no basis for the
determination of whether the concentrations found entering the site in stormwater from off-site or
exiting the site at the permitted outfall are acceptable. For the metals and other site monitoring
parameters, there are some water quality standards or benchmarks to serve as tools to evaluate
the effectiveness of the facility stormwater pollution prevention activities. As explained earlier, the
stated benchmark for DDLCs, of non-detectable, is unreasonable, as every stormwater sample
taken anywhere in the State of North Carolina would contain detectable levels of DDLCs. Given
the above discussion, it would appear that monitoring for DDLCs in the Carolina Pole outfall will
not provide any new data that would be of any utility to the facility or the regulatory agency.
From a technical perspective, monitoring for DDLCs in stormwater is unproductive because the
compounds have very, very, low water solubilities and very high partition coefficients. This
means that most of the DDLCs present in the stormwater exist in particulate form or sorbed to
particulate matter. This is demonstrated by the data submitted with the application that shows
measured concentrations for some congeners that are several orders of magnitude higher than
the aqueous solubility of the congener. Given this fact, it is impossible to use the data for aquatic
or other toxicity evaluations because there is no basis to estimate the bioavailability of the
congeners reported as present.
The previous regulatory and technical discussions are presented to support the removal of the
requirement to monitor for DDLCs, but the more important aspect from the facility's perspective
is that of the cost to perform these analyses. A reasonable estimate for one analysis of DDLCs is
$1,0001sample, including transportation and sampling supplies. Although Carolina Pole only has
one outfall that requires monitoring for DDLCs, there are at least two locations where stormwater

NC DEMLR
Stormwater Permitting Program
Attn: Brianna Young
January 08,2024
Re: Draft NPDES Slormwater Permit
NPDES Permit NCS 000222
Carolina Pole Leland,Inc.
Brunswick County
Page 3
from off-site locations combines with on-site flows before the combined flows leave through the
permitted outfall. Data contained in the permit application showed that this flow from off-site
locations contained DDLCs. Since the facility will immediately be in the Tier 3 Response
category, the facility would be required to monitor on a monthly basis. In order to demonstrate
the potential impact from off-site, the facility would have to take a minimum of two samples
where stormwater enters the site, in addition to the facility outfall sample. It is likely that a
downstream sample would also be required. Therefore, the facility would be required to take four
samples per month, resulting in an expected cost of$4,000 per month, or $48,000 per year, to
provide data that is of very limited value to the DEQ. This would be a substantial waste of
monetary resources and could lead to demands for facility responses that are costly,
unreasonable, and ineffective.
The 15 years of already available data is more than adequate to provide data on the
concentrations of DDLCs in the facility outfall, as well as off-site contributions. With the cessation
of the use of pentachlorophenol resulting in the lack of storage of pentachlorophenol-treated
wood in outdoor locations, there should be no need for future monitoring of DDLCs in the facility
stormwater. It would be known with certainty that any potential previous DDLC surface water
impact from facility operations is now greatly reduced, to that expected from any other similar
industrial facility, for which monitoring is not typically required.
If the DEQ evaluation of this request is not viewed favorably, Carolina Pole would request a
meeting to discuss this issue further in order to develop an understanding of the basis for the
DEQ position, why the agency needs this data and what it will be used for, and what other
industrial facilities or cities in North Carolina are being required to monitor stormwater for DDLCs.
Carolina Pole would like to understand how the decision to require, or not require, DDLC
monitoring is made for a particular permit, given the understanding that the stormwater from all of
these industrial facilities and municipalities will contain measurable levels of DDLCs.
Carolina Pole appreciates the opportunity to provide these comments on the draft permit and
looks forward to a positive resolution of the issue we have identified. Please let us know if
additional information is needed.
Thank you for your help.
Sincerely,
CAROL PA POLE LELA D, INC.
Michael Rouse
Assistant Operations Manager
cc: H. M. Rollins Company, Inc.

Young, Brianna A
From: Romanski, Autumn R
Sent: Tuesday, January 30, 2024 2:46 PM
To: Young, Brianna A
Cc: Hanks,Joshua M; Concepcion, Richard C
Subject: RE: Carolina Pole Leland, Inc. in Brunswick County
Attachments: REVISED Koppers Carolina Pole Groundwater Characterization Work Plan 04122023.pdf;
Ltr Report of Findings Koppers Carolina Pole Leland 11292022highlighted.pdf
Brianna,
My apologies, I have been in transition to a new position in the Solid Waste Section.
The analytes of concern identified from the soil sampling requested by the Hazardous Waste Section include Arsenic
(note several locations were over Brownfield Limit of 100 mg/kg), with a few other analytes of concern identified
Pentachlorophenol, Copper, and Chromium.The sampling location is provided in the results report attached.The site
will be implementing a groundwater sampling plan (also attached), (installing new wells in area by the Hazardous Waste
drip pad operation) per 2.4 and 3.0 below and summarized from the groundwater sampling plan
2.4 Groundwater Sample Analysis
The groundwater sample analysis will be via the following methods,which were also used for the
concrete cleaning test evaluation performed at the facility in 2022:
• Pentachlorophenol—Method 8151A(extraction and analysis)
• Arsenic/Copper/Chromium— Method 3005A(preparation) and EPA 6020B (analysis)
3.0 DATA EVALUATION
Following receipt of the analytical results,the unfiltered sample analytical results will be compared with the 15A NCAC
2L groundwater standard for arsenic (10 µg/L),chromium (10 µg/L), copper(1 mg/L), and
pentachlorophenol (0.3 µg/L). Depending on the unfiltered sample analytical results,the filtered sample analytical
results may also be considered, along with the turbidity data collected during purging.
When scheduled for implementation later in 2024,this groundwater sampling plan under the Hazardous Waste Section
will be overseen by Josh Hanks, hydrogeologist for the Compliance Branch Hazardous Waste Section.
You may want to review the SW Permit and determine if these analytes are covered in SW Sampling?
Thank you for your consideration.
Sincerely,
Autumn Romanski
Environmental Senior Specialist
Division of Waste Management—Solid Waste Section
North Carolina Division of Environmental Quality
Cell: [phone]
Autumn.Roma [e-mail]
i

E_
cl ;
NORTH CAROLINA
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From:Young, Brianna A<[e-mail]>
Sent: Monday,January 29, 2024 9:35 AM
To: Romanski,Autumn R<[e-mail]>
Subject: RE: Carolina Pole Leland, Inc. in Brunswick County
Good morning Autumn,
I am following up on my previous email.Any guidance you are able to provide would be appreciated.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From:Young, Brianna A
Sent:Wednesday,January 24, 2024 12:02 PM
To:Watson, Samuel <[e-mail]>
Cc: Peacock, David <david.Peacock@ deg.nc.gov>; Romanski,Autumn R<Autumn.Roma [e-mail]>
Subject: RE: Carolina Pole Leland, Inc. in Brunswick County
Samuel,
Thank you for the prompt response. Monitoring data provided by the company shows results of dioxin in every sample
taken (8 taken between June 2018 and July 2022), ranging from 11.1 picograms/L to 2,000 picograms/L.
Autumn, any additional information you can provide would be greatly appreciated.
Thank you,
2

Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From:Watson, Samuel <[e-mail]>
Sent:Tuesday,January 23, 2024 3:09 PM
To:Young, Brianna A<[e-mail]>
Cc: Peacock, David <david.Peacock@ deg.nc.gov>; Romanski,Autumn R<Autumn.Roma [e-mail]>
Subject: RE: Carolina Pole Leland, Inc. in Brunswick County
Brianna,
The site is still considered a Brownfields site and will likely remain a Brownfields site for a very long time. The
Brownfields Redevelopment Section (BRS) does not remediate sites, but mitigates the risks in order to make it safe to
use. The capping of the dioxins and any remedial work that was done at the site was done under the supervision and
direction of the Hazardous Waste Section(HWS) of DWM, and thus mitigated the risks at the site to acceptable
levels. Autumn Romanski, with HWS, should be able to answer some of your questions more completely, if needed. I
have copied her on this response.
The bottom line, however,from a Brownfields standpoint is that anything currently present at the site is either being
contained at levels that do not present a risk(historical releases), or is currently being addressed by the HWS(resent
issues, including a fire at the site). If your required monitoring reporting has not shown any exceedances of any of your
requirements/restrictions/standards, or presented any other red flags for you,then containment would appear to
successful at the site.And as such would not be an issue with the BRS.
However, if there have been any red flags, or violations, we would like to be aware of those. Part of the requirements
for the Brownfields Agreement is that they must remain compliant with the rules/regulations of all other agencies.
Let me know if you have any questions or wish to discuss further.
Thanks,
Samuel P. Watson
Project Manager, Brownfields Property Management Branch
Brownfields Redevelopment Section
Division of Waste Management
North Carolina Department of Environmental Quality
Wilmington Regional Office
3

910-796-7408 (office), 910-508-2214 (cell)
somuel.watson@ deg.nc.ciov
E-mail correspondence to and from this address may
be subject to the North Carolina Public Records Law
and may be disclosed to third parties.
From:Young, Brianna A<[e-mail]>
Sent:Tuesday,January 23, 2024 1:54 PM
To:Watson, Samuel <[e-mail]>; Peacock, David <[e-mail]>
Subject: Carolina Pole Leland, Inc. in Brunswick County
Good afternoon,
I am reviewing the stormwater permit renewal for the Carolina Pole Leland, Inc.facility(located at 1901 Wood
Treatment Road NE, Leland, NC in Brunswick County) and it has come to our attention that this site has a history of being
a brownfield. Our permit file history states that dioxins were discovered at the site and that two areas would be capped.
Can you provide an update on whether this site is still considered a brownfield, and what, if any, clean-up operations
occurred onsite? Is DWM still concerned about the presence of dioxins (or any other pollutants) onsite?
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
4

y
- - www.kuresources.com
April 12, 2023
Autumn Romanski
Environmental Chemist
North Carolina Department of Environmental Quality
Division of Waste Management
217 West Jones Street
1646 Mail Service Center
Raleigh, North Carolina 27699-1646
VIA EMAIL
Subject: REVISED Groundwater Characterization Work Plan
Immediate Action Notice of Violation
Docket#2022-037
Koppers—Carolina Pole Leland, Inc.
1901 Wood Treatment Road
Leland, NC 28451
Site EPA ID# NCR093137636
Brunswick County
Dear Ms. Romanski:
In response to the comments received from the Department regarding the March 28, 2023 Groundwater
Characterization Work Plan for the Koppers—Carolina Pole Leland, Inc. facility in Leland, North Carolina,
have attached a revised plan for your final review and approval. The revisions have been made
pursuant to my April 11, 2023 emailed response to comments, and the Department's April 12, 2023
emailed approval of those responses.
Please let me know if you have any questions or need any additional information.
Sincerely,
Da id R. Kerschner, CPG
Principal
[e-mail]
cc: Joshua Hanks (NCDEQ)
Wes Hare (NCDEQ)
Michele Reams (Carolina Pole Leland)
Jane House (Koppers)
Kevin Wiseman (Koppers)
Michael Rouse (Carolina Pole Leland)
22 South Linden Street Duquesne, PA 15110 412.469.9331 412.469.9336 fax

GROUNDWATER CHARACTERIZATION WORK PLAN
KOPPERS CAROLINA POLE
LELAND, NORTH CAROLINA
Prepared for.
KOPPERS INC.
436 SEVENTH AVENUE
PITTSBURGH, PENNSYLVANIA 15219
REVISED
APRIL 2023
22 South Linden Street I Duquesne, PA 15110
KU Resources, Inc. 412.469.9331 1 412.469 9336 fax
Innovative Solutions. Outstanding Support. www.kuresources.com

GROUNDWATER CHARACTERIZATION WORK PLAN
KOPPERS CAROLINA POLE
LELAND, NORTH CAROLINA
Prepared for:
KOPPERS INC.
436 SEVENTH AVENUE
PITTSBURGH, PENNSYLVANIA 15219
Prepared by:
KU RESOURCES, INC.
22 SOUTH LINDEN STREET
DUQUESNE, PENNSYLVANIA 15110
REVISED
AP RI L 2023

GROUNDWATER CHARACTERIZATION WORK PLAN
KOPPERS CAROLINA POLE
LELAND, NORTH CAROLINA
REVISED APRIL 2023
TABLE OF CONTENTS
1.0 INTRODUCTION..............................................................................................................................1
2.0 SCOPE OF WORK..........................................................................................................................1
2.1 Temporary Monitoring Well Installation..................................................................................1
2.2 Temporary Monitoring Well Surveying and Development....................................................2
2.3 Temporary Monitoring Well Sampling.....................................................................................2
2.4 Groundwater Sample Analysis.................................................................................................3
2.5 Investigation Derived Waste Management .............................................................................3
3.0 DATA EVALUATION.......................................................................................................................3
4.0 PROJECT SCHEDULE ...................................................................................................................4
FIGURE
Figure 1 Temporary Well Locations
ATTACHMENT
Attachment A Example Groundwater Sampling Log Form

GROUNDWATER CHARACTERIZATION WORK PLAN
KOPPERS CAROLINA POLE
LELAND, NORTH CAROLINA
REVISED APRIL 2023
1.0 INTRODUCTION
In a letter dated January 27, 2023, the North Carolina Department of Environmental Quality, Division of
Waste Management, Hazardous Waste Section (NCDEQ) requested that Koppers Carolina Pole Leland
(Koppers) submit a plan for a groundwater quality investigation of the areas previously designated AOC 2
(Transfer Deck) and AOC 5 (Filter Press). The request was made on the basis of the results of soil
sampling and analysis performed by Koppers and reported to NCDEQ in a letter dated November 29,
2022.
The December 7, 2004 MACTEC Engineering and Consulting, Inc. Assessment Report determined that
the uppermost groundwater was present in a predominantly fine-to medium-grained sand unit, and
concluded that the uppermost groundwater flow direction at the facility was to the southeast. However,
because the areas of investigation are in a heavily trafficked operational area of the facility, and because
groundwater quality and groundwater flow direction information in this investigation area is limited, the
investigation will use temporary wells to provide preliminary groundwater quality and groundwater flow
information. This information will be evaluated and used to determine the need for, and location of, any
permanent monitoring wells that may be installed to provide further information.
Six temporary monitoring wells will be installed at the generalized locations shown on Figure 1. These
locations were selected to:
• Be in close proximity to the areas of investigation;
• Provide sufficient areal coverage of the areas of investigation to allow an evaluation of
groundwater quality and flow direction, taking into consideration the presumed southeasterly
groundwater flow direction; and
• Be in areas that are relatively protected from normal plant traffic/operations to prevent damage
during the investigation process.
One or more of the temporary monitoring well locations shown on Figure 1 may be adjusted in the field in
response to access constraints or other considerations. The location adjustments, if any, will be
minimized to the extent possible, and the reason(s)for adjusting the location(s)will be documented.
2.0 SCOPE OF WORK
The following sections describe the work scope for the groundwater quality investigation.
2.1 Temporary Monitoring Well Installation
The temporary monitoring wells will be installed using direct-push equipment. Because the depth to the
water table in the areas of investigation is known to occur at an average depth of four to seven feet below
ground level, the total depth of the temporary wells will be 13 feet. The temporary wells will be installed
using drive casing equipped with expendable points. The drive casing will be advanced to the termination
depth; a one-inch diameter, ten-foot length, threaded, flush-joint PVC well screen with solid riser will be
inserted into the tooling (resulting in a screened interval of three to 13 feet below ground surface); and the
tooling will be extracted from the ground while holding the screen/riser in place. During tooling extraction,
1

GROUNDWATER CHARACTERIZATION WORK PLAN
KOPPERS CAROLINA POLE
LELAND, NORTH CAROLINA
REVISED APRIL 2023
filter sand will be slowly poured into the annulus between the well screen/riser and the drive casing.
Additional filter sand will be added to the well annulus as appropriate following the complete extraction of
the tooling. Hydrated bentonite pellets will be installed into the annulus at ground surface.
The drive casing will be decontaminated prior to use, between each temporary well installation, and
following completion of all temporary well installations by washing with potable water and detergent.
2.2 Temporary Monitoring Well Surveying and Development
Following installation, the temporary wells will be developed using a peristaltic pump. Development
activities will continue until the extracted groundwater is visibly free of significant turbidity, or it is
determined in the field that the turbidity level cannot be further reduced.
The temporary well locations will also be surveyed and mapped in relation to other fixed reference points
(structures), and the top-of-riser elevations will be surveyed established to an elevation to ±0.01 foot in
relation to existing site datum.
2.3 Temporary Monitoring Well Sampling
The temporary monitoring wells will be allowed to stand undisturbed for at least one day following the
completion of well development activities. Prior to purging/sampling, depth-to-water level measurements
will be collected to±0.01 foot at each well.
Monitoring wells will be purged prior to sampling using a peristaltic pump and low-flow techniques, with a
targeted flow rate of one liter per minute. The well will be pumped until the discharged groundwater is
visibly free of significant turbidity, or it is determined in the field that the turbidity level cannot be further
reduced. An in-line water quality measurement device will then be used to continuously monitor
groundwater quality indicator parameters. The water quality indicator parameters will include pH, redox
potential (ORP), specific conductance, dissolved oxygen (DO), and turbidity. Measurements will be taken
every five minutes. Stabilization will be considered to be complete after all parameters meet the following
stabilization criteria for three successive measurement periods:
• Turbidity: 10%for values greater than 5 nephelometric turbidity unit (NTU); if three Turbidity
values are less than 5 NTU, consider the values as stabilized;
• DO: 10% for values greater than 0.5 milligrams per liter(mg/L); if three DO values are less
than 0.5 mg/L, consider the values are stabilized;
• Specific Conductance: 3%;
• Temperature: 3%;
• pH: +/- 0.1 unit; and
• ORP: +/- 10 mv.
Purging and sampling information will be recorded in groundwater purge and sampling logs. An example
log form is included as Attachment A.
2

GROUNDWATER CHARACTERIZATION WORK PLAN
KOPPERS CAROLINA POLE
LELAND, NORTH CAROLINA
REVISED APRIL 2023
It should be noted that it may be determined in the field, following the removal of a minimum of three
equivalent casing volumes of groundwater, that stabilization of one or more field parameters is not
possible. In such a case, the details will be recorded in the field notes and the sample will be collected.
In the event that a well purges to dryness, the well will be allowed to recover and the purging flow rate will
be adjusted downward. In the event that the well continues to purge to dryness, the details will be
recorded in the field notes and the well will be allowed to recover sufficiently to collect the sample.
Following completion of the purging process, the low-flow sampling equipment will continue to be
operated to collect groundwater samples. The groundwater samples will be collected for
pentachlorophenol (unfiltered), and arsenic/copper/chromium (filtered and unfiltered) analysis. The
filtered samples will be collected by routing the water flow through in-line 0.45-micron filters with
discharge to pre-preserved sample bottles.
Sample collection will include one duplicate sample from a field-selected well location.
Samples will be placed on ice in a cooler pending transport under chain-of-custody procedures to the
analytical laboratory.
Following completion of sampling, the temporary well materials will be removed and the resulting
borehole will be backfilled with hydrated bentonite chips.
2.4 Groundwater Sample Analysis
The groundwater sample analysis will be via the following methods, which were also used for the
concrete cleaning test evaluation performed at the facility in 2022:
• Pentachlorophenol —Method 8151A(extraction and analysis)
• Arsenic/Copper/Chromium — Method 3005A(preparation) and EPA 6020B (analysis)
2.5 Investigation Derived Waste Management
The direct-push temporary monitoring well installation methodology does not generate cuttings. The
water generated during drive casing decontamination, and temporary monitoring well development and
purging activities will be collected and placed in the facility's process water management system.
Following removal from the ground, the temporary well PVC well screen and riser materials will be placed
in drums with hazardous waste generated in facility operations and disposed with that waste.
3.0 DATA EVALUATION
Following receipt of the analytical results, the unfiltered sample analytical results will be compared with
the 15A NCAC 2L groundwater standard for arsenic (10 pg/L), chromium (10 pg/L), copper(1 mg/L), and
pentachlorophenol (0.3 pg/L). Depending on the unfiltered sample analytical results, the filtered sample
analytical results may also be considered, along with the turbidity data collected during purging. A letter
report of findings will be prepared that includes a description of the work performed (with supporting
3

GROUNDWATER CHARACTERIZATION WORK PLAN
KOPPERS CAROLINA POLE
LELAND, NORTH CAROLINA
REVISED APRIL 2023
documentation), an evaluation of the groundwater flow direction, an evaluation of the groundwater quality
results, and recommendations for further investigation activities, if any.
4.0 PROJECT SCHEDULE
The facility is currently undergoing major production area upgrades, which have resulted in significant
process equipment cleaning/decommissioning, and process upgrade construction activities in the general
area of excavation. It is anticipated that the construction activities would interfere with the groundwater
quality investigation activities, and vice versa. In order to avoid such interferences, which could
potentially result in damage to one or more of the temporary monitoring wells during the period while
those wells are in service, it is recommended that the groundwater quality investigation take place
following the completion of the plant upgrades, which is currently targeted for the second quarter of 2024.
In the event that the area of investigation becomes accessible prior to the completion of these upgrade
activities for a sufficient amount of time to complete the groundwater characterization work, and the well
installation contractor and field sampling personnel are available, Koppers may elect to move forward with
the groundwater characterization. In that case, Koppers will provide NCDEQ with a minimum two-week
advance notice that the field work will take place.
4

FIGURE

INACTIVE STEAM LINE/FILTER PRESS AREA
y
1_ z
NORTH
"fai
TRANSFER DECK SLAB AREA _
J 1
LIZ
3bt a 4 b �
' g 4 t
r
LEGEND FIGURE 1
— TEMPORARY WELL TEMPORARY WELL LOCATIONS
REFERENCE: SCALE — FEET — PRESUMED DIRECTION of SAMPLING AND ANALYSIS PLAN
GOOGLE EARTH — SEPTEMBER 2021. 0 200 GROUNDWATER FLOW
APPROVED DIRK 03/22/2023 TOWN OF LELAND
KU Resources,Inc. BRUNSWICK COUNTY, NORTH CAROLINA
CHECKED DIRK 03/22/2023 22 South Linden Street
DRAWN JDS 03/22/2023 Duquesne, PA 15110 PREPARED FOR
CAD FILE NO. 22253AO05 412.469.9331 KOPPERS - CAROLINA POLE LELAND, INC
412.469.9336 fax
PROJECT NO. K122253LEL www.kuresources.com LELAND, NORTH CAROLINA

ATTACHMENT

Attachment A
Example Groundwater Sampling Log Form

Well SamDlina Form Page 1 of 1
Location (Site/Facility Name): Project Number:
Well Number: Screen setting (ft. below MP) Top Bottom
Field Personnel:
Sampling Organization: Pump Intake at (ft. below MP):
Identify MP: Top of Casing Purging Device; (pump type):
Date: I Initial Water Level (ft. below MP):
Time Pumping Began: Total Well Depth (ft. below MP):
Time Pumping Ended: Well Diameter:
Total Vol. Removed: Well Volume:
Evacuated to Dryness: Well Volumes Removed:
Stabilization Data
Clock Water Pump Purge Rate Cum. Temp. Spec. pH ORP/Eh DO Turbidity Comments
Time Depth Dial Volume Cond.
Below MP Purged
3% 3% +/-0.1 +/- 10 10% 10%
24 Hr ft ml/min liters degrees C US/cm my mg/L NTU
Sample Collection Information
Sample Collection Matrix Parameters Number of Field Preserved Grab/
ID Time Containers Filtered Composite
1 Field Observations
2 Odor:
3 Color:
4 Sediment:
Duplicate? 5 Well Condition:
Duplicate ID: 6 Well Capped & Locked Upon Completion:
Notes: Analyzing Laboratory: Temperature:
Delivery Method to lab: Tracking Number: Precip:

III
_ ----- _ ----- --, www.l(uresources.com
November 29, 2022
Autumn Romanski
Environmental Chemist
North Carolina Department of Environmental Quality
Division of Waste Management
217 West Jones Street
1646 Mail Service Center
Raleigh, North Carolina 27699-1646
VIA EMAIL
Subject: Letter Report of Findings— Sampling and Analysis Plan Implementation
Immediate Action Notice of Violation
Docket#2022-037
Koppers—Carolina Pole Leland, Inc.
1901 Wood Treatment Road
Leland, NC 28451
Site EPA ID# NCR093137636
Brunswick County
Dear Ms. Romanski:
This Letter Report of Findings presents the results of soil sampling and analysis performed at the
Koppers—Carolina Pole Leland, Inc. facility in Leland, North Carolina. Work was generally performed
pursuant to the September 2022 Sampling and Analysis Plan (SAP) that was approved by NCDEQ on
September 16, 2022, and consisted of the collection and analysis of discrete soil samples collected from
multiple locations. Deviations from the SAP protocols were either recommended to NCDEQ
representatives or requested by NCDEQ representatives during the implementation of field activities.
Two areas of the facility were subject to the SAP investigation activities:
• The areas immediately adjacent to the east and west sides of the Transfer Deck concrete slab,
for the purpose of evaluating soil quality conditions that may be the result of precipitation runoff
from that concrete slab; and
• The sub-slab area adjacent to an inactive steam line/filter press, for the purpose of evaluating the
potential that constituents associated with observed staining on the concrete had migrated to the
subsurface via cracks and gaps in the concrete slab.
In addition to the SAP-directed activities, grid-based composite soil samples were collected and analyzed
from the east and west sides of the Transfer Deck following the protocols established for the facility's
NCDEQ Brownfields Agreement activities.
The soil sample locations are shown on Figure 1. Soil samples were collected using direct-push
sampling equipment. Notes regarding field sampling activities are included as Attachment A. A NCDEQ
RCRA Inspection Report also describing the field sampling activities is included as Attachment B.
The laboratory analytical results for the SAP and grid-based samples are summarized on Table 1.
Laboratory analytical reports are included as Attachment C. As shown on Table 1, and pursuant to the
SAP, the analytical results for the SAP samples were compared with the NCDEQ Preliminary Soil
Remediation Goals (PSRGs) for data evaluation purposes. Site-specific concentration-based worker risk
standards have also been established under the Brownfields Agreement; these standards were also used
as comparison values. Both sets of comparison values are also shown on Table 1.
22 South Linden Street I Duquesne, PA 15110 1 412.469.9331 1 412.469.9336 fax

Autumn Romanski
November 29,2022
Page 2
SUMMARY OF RESULTS
The following summarizes the results for each area investigated.
Transfer Deck Area— East Side: The samples from the east side of the Transfer Deck (locations TD-3,
TD-5, and TD-6) all had arsenic and pentachlorophenol concentrations that were above the PSRG. The
arsenic concentrations were above the Brownfields Agreement risk-based standard of 100 mg/kg in TD-3
(113 mg/kg) and TD-5 (220 mg/kg). The pentachlorophenol concentrations were all notably below the
Brownfields Agreement risk-based standard.
A sample-by-sample comparison of total chromium and hexavalent chromium concentrations indicates
that the chromium detected in the soil samples is primarily trivalent in form. No total chromium
concentrations exceeded the PSRG; TD-3 and TD-5 had hexavalent chromium concentrations that were
above the PSRG (0.99 mg/kg and 3.85 mg/kg, respectively versus a 0.31 mg/kg PSRG). The facility's
Brownfields Agreement has not established a site-specific worker risk standard for total or hexavalent
chromium.
No other constituents were detected at concentrations that exceeded their respective PSRGs.
The Brownfields Agreement protocol grid-based sampling results for arsenic and pentachlorophenol did
not exceed their respective Brownfields Agreement risk-based standards.
Transfer Deck Area— West Side: The samples from the west side of the Transfer Deck (locations TD-
1/TD-7D (duplicate), TD-2, and TD-4) all had arsenic and pentachlorophenol concentrations that were
above the PSRG. The arsenic concentration was above the Brownfield Program standard of 100 mg/kg
in TD-1 (117 mg/kg). The pentachlorophenol concentrations were all notably below the Brownfield
Program standard.
A sample-by-sample comparison of total chromium and hexavalent chromium concentrations indicates
that the chromium detected in the soil samples is primarily trivalent in form. No total chromium
concentrations exceeded the PSRG; TD-4 had a hexavalent chromium concentration that was above the
PSRG (0.814 mg/kg versus a 0.31 mg/kg PSRG). The Brownfield Program has not established a site-
specific worker risk standard for total or hexavalent chromium.
No other constituents were detected at concentrations that exceeded their respective PSRGs.
The Brownfields Agreement protocol grid-based sampling results for arsenic and pentachlorophenol did
not exceed their respective Brownfields Agreement risk-based standards.
Inactive Steam Line/Filter Press Area: Soil samples were collected from two borings, in close proximity
to each other, from a cracked area in the concrete slab. Samples were collected from two depth intervals
at location SL1 (2.9—4 feet and 4.5—5 feet, and from 3.9—5 feet at SL2. The samples all had arsenic
concentrations that were above the PSRG, and the SL1 2.9—4 feet sample had an arsenic concentration
(113 mg/kg) that exceeded the Brownfields Agreement risk-based standard of 100 mg/kg. The
pentachlorophenol concentrations in SL1 2.9—4 feet and SL2 3.9 —5 feet exceeded the PSRG, but did
not exceed the Brownfields Agreement risk-based standard.
No other constituents were detected at concentrations that exceeded their respective PSRGs.
v

Autumn Romanski
November 29, 2022
Page 2
CONCLUSIONS
It is important to note that the facility has entered into a Brownfields Agreement with NCDEQ. This
Brownfields Agreement developed risk-based soil quality criteria, and required extensive soil sampling at
the facility as well as routine ongoing soil sampling into the future. The presence of historical releases of
wood preserving constituents to the ground at the facility has been documented and addressed via the
Brownfields Agreement. Given the facility's long history of treating wood and handling treated wood, it
would therefore not be unexpected to detect wood preserving constituents in the soil surrounding the
wood treating process area, and virtually impossible to identify the specific source of and timing of the
release of those constituents to the soil.
Although concentrations of arsenic, chromium, and pentachlorophenol exceeded PSRGs in samples
collected immediately adjacent to the east and west sides of the Transfer Deck concrete slab, the
magnitudes of these concentrations are not suggestive of a release of a wood preservative product— in
such a case, the constituent concentrations would be expected to be at least several orders of magnitude
higher. As noted above, it is not possible to determine whether these concentrations are the result of
precipitation runoff from the Transfer Deck slab given the Transfer Deck slab conditions noted in the
NCDEQ inspection, the result of long-term wood preserving operations and the management of treated
wood products in and around the operations area (as has been addressed via the Brownfields
Agreement), or both. Further, the concentrations in the discrete samples are predominantly below the
Brownfields Agreement risk-based standards. Where arsenic concentrations exceed the Brownfields
Agreement risk-based standard, the exceedances are not notable. Finally, the Brownfields Agreement
protocol grid-based sampling results do not exceed the Brownfields Agreement standards on either the
east or west side of the Transfer Deck slab.
Similarly, the magnitudes of the arsenic and pentachlorophenol concentrations in the soil samples
collected in the Inactive Steam Line/Filter Press area are not suggestive of a release of wood
preservative product. Further, the results indicate that concentrations of arsenic and pentachlorophenol
decrease with depth. The presence of the roof and concrete slab mitigate the potential for lateral or
vertical migration of these constituents.
In consideration of the above, we believe that the areas of interest have been fully characterized, and that
the results do not represent a potential adverse risk to human health or the environment, and that the
results demonstrate that no further soil remediation activities beyond those that have been previously
conducted under the Brownfields Agreement are warranted.
Sincerely,
David R. Kerschner, CPG
Principal
[e-mail]
cc: Wes Hare (NCDEQ)
Jane House (Koppers)
Michael Rouse (Carolina Pole Leland)

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SOIL SAMPLING LOCATIONS
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DATED 2021. 0 40 SAMPLING AND ANALYSIS PLAN IMPLEMENTATION
-
APPROVED DIRK 11/28/2022 TOWN OF LELAND
KU Resources,Inc. BRUNSWICK COUNTY, NORTH CAROLINA
CHECKED DIRK 11/28/2022 22 South Linden Street
/ DRAWN RAM 11/28/2022 Duquesne,PA 15110 PREPARED FOR
CAD FILE N0. 22253A004 412.469.9331 KOPPERS - CAROLINA POLE LELAND, INC
412.469.9336 fax
kuresource LELAND, NORTH CAROLINA
x PROJECT N0. KI22253LEL www.kuresources.com

TABLE 1
SOIL QUALITY SUMMARY
OCTOBER 2022
Koppers - Carolina Pole Leland, Inc.
Leland, North Carolina
SAP (DISCRETE) SAMPLES GRID SAMPLES
CONSTITUENT PSRG BRN STD TD-1 TD-2 TD-3 TD-4 TD-5 TD-6 TD-7D SL1 2.9-4ft SL1 4.5-5ft SL2 3.9-5ft SL Blank* 5-13E 5-14W
Arsenic 0.68 100 117 18.6 113 22.9 220 40.6 4.04 113 41.9 52.1 <5.00 82.3 19.4
Barium 580 NS 1.11 9.97 3.66 2.99 2.31 3.10 0.256 J 1.81 1.12 1.12 <1.00 NA NA
Cadmium 3 NS <0.0973 <0.116 0.197 J 0.113 J 0.243 J <0.1 <0.102 <0.0895 <0.102 <0.0968 <1.00 NA NA
Chromium (Total) 23000 NS 237 13.5 125 34.8 534 84.8 38.7 125 0.304 J 32.9 <1.00 NA NA
Chromium (Hexavalent) 0.31 NS <0.180 <0.193 0.99 0.814 3.85 <0.211 <0.219 <0.162 <0.163 <0.147 NA NA NA
Copper 700 NS 73.4 14 74.7 11.4 389 65.0 1.46 J 84.4 0.424 J 22.6 <3.00 NA NA
Lead 270 NS 1.25 J 1.26 J 2.58 0.733 J 1.41 J 1.8 J 0.527 J 2.34 0.488 J 1.31 J <3.30 NA NA
Mercury 1 NS 0.0212 J <0.00978 0.00927 J 0.0138 J <0.00829 0.00884 J 0.0274 0.154 <0.00751 <0.00799 <0.0670 NA NA
Selenium 2.1 NS <0.487 <0.581 <0.536 <0.527 <0.528 <0.502 <0.512 <0.448 <0.508 <0.484 8.69 J NA NA
Silver 3.4 NS <0.0973 <0.116 0.137 J <0.105 1.52 J <0.100 <0.102 <0.0895 <0.102 <0.0968 <1.00 NA NA
Pentachlorophenol 1 0.0083 1 280 1 0.236 1 0.107 1 0.19 1 0.0202 1 0.203 1 0.0138 P 1 0.0229 1 28.2 1 0.00815 1 1.87 1 <0.417 1 <0.00192 1 0.00344 J
NOTES:
Values are in mg/kg. *Values for SL Blank are in µg/L
"PSRG" Denotes NCDEQ Preliminary Soi Remediation Goal
"BRN STD" Denotes the Brownfields Program NCDEQ Approved Worker Risk Standard
"NS" Denotes No Standard
"NA" Denotes Not Analyzed
"J" Denotes an Estimated Value
"P" Denotes the Concentrations Between the Primary and Confirmation Columns/Detectors is>40% Different. For HPLC,the difference is >70%.

ATTACHMENT A
FIELD NOTES

y 5
Ah
mmftftft A
a
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TD-1= 13'from start of transfer deck concrete Filter press—under cover Approx. 34.251045 DEG,-78.076173 DEG
TD-2=68'from start of transfer deck S1 34.251041,-78.076157
TD-4= 125' from start of transfer deck S2 34.251034,-78.076112
TD-3= 19'from start of transfer deck TDl 34.250589,-78.076434
TD-5=46'from start of transfer deck TD2 34.250433,-78.076454
TD-6=90'from start of transfer deck TD4 34.250288,-78.076470
TD-71) TD6 34.250323,-78.076074= 16' from start of transfer deck TD5 34.250434,-78.076059
TD3 34.250523,-78.076039
STEAM LINE NOTES
• Overhead power line—Determined by probe operator(Mike Tynan with IET)that it will not interfere
• Concrete approximately 6 inches with gravel under
• Due to water table between 4-5 feet, compression of sand in sleeve 2 was not enough sample to collect both
metals and pentachlorophenol for the shallow (2 to 3.9 feet) sample. It was determined to collect only the
pentachlorophenol for that one.
• Sample below 5 feet was"wet" and unusable.
c: SL 1 = 2.9.4 feet&4.5-5 feet samples
■ Dark Brown, loose sand
c: SL-2 = 2-3.9 feet- Pentachlorophenol only/3.9-f feet—Penta and metals
■ Dark Brown, loose sand. Very fine grain to silt.
Sleeve 3—Saturated— Not used
• Autumn suggested a "Blank" so this was taken as water running through a clean sleeve. Analytical for RCRA
Meta ls/Cu/Pentachlorophenol.

L
8
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F
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TRANSFER DECK NOTES—It was determined to use the probe for sampling around the transfer deck
• TD-3—Light gray/tan,very fine grain, unconsolidated,well sorted sand (light odor)
• TD-5—0-1.9 feet looked like fill sand and was not used for sampling
o A= Metal sampling 1.9-2.4 feet
o B= Penta sampling 2.4-3 feet
• TD-6-0-1.4 feet looked like fill sand and was not used for sampling
o A= Penta sampling 1.4-2.2 feet
o B= Metals sampling 2.2-2.9 feet (Wet and light odor)
• TD-4—Light tan/gray/light tan
o A= Metal sampling 0-0.9 feet
o B= Penta sampling 0.9-1.9 feet
• TD-2—Light gray, almost white at bottom
o A= Metal sampling 0-0.9 feet
o B= Penta sampling 1-1.10 feet
• TD-1—Gray/tan/orange/bottom marble tan. Gravel to .6 feet
o A= Metal sampling 0.6-1.4 feet
o B = Penta sampling 1.4-2.6 feet
• TD-7D—Pulled by TD-1. Light gray/tan/marble orange
o A= Metal sampling 0.5-1.2 feet
o B= Penta sampling 1.2-2 feet

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IMAGE BYDATED 202toocLF EARTH SAMPLING AND ANALYSIS PLAN
0 40
APPROVED 0RK 09/08/2022 TOWN OF LELAND
CHECKED DRK Ds 0s/2022 KU Resoumes.Inc. BRUNSWICK COUNTY, NORTH CAROLINA
/ 22 South linden Street PREPARED FOR
N DRACAD FILE
RAM 022253A 03 41DILI2469.933A 1511i) KOPPERS --� CAROLINA POLE LELAND, INC
CAD FILE N0. 22253AOD3
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ATTACHMENT B
NCDEQ RCRA INSPECTION REPORT

NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL
QUALITY DIVISION OF WASTE MANAGEMENT
HAZARDOUS WASTE SECTION (HWS) / COMPLIANCE BRANCH
RCRA INSPECTION REPORT
1) Facility Information: Koppers Carolina Pole Leland,Inc.
1901 Wood Treatment Road
Leland NC,28451
Brunswick County
EPA ID Number: NCR093137636
2) Property Owner: Leland Land, LLC
436 7TH AVE STE 1750
Pittsburgh,PA 15219-1886
3) Facility Address: 1901 Wood Treatment Rd
Leland,NC
Brunswick County
4) Facility/Owner Contact: Michael Rouse,Plant Manager
RouseMTkkoppers.com
Sarah House, SH&E Manager
HouseSJkkoppers.com
Michelle Reams, SH&E Coordinator
ReamsMB(kkoppers.com
5) Facility Consultant Contact: Dave Kerschner, CPG
KU Resources,Inc.
Duquesne,PA
dkerschner&kuresources.com
6) Inspector(s): Autumn Romanski,Eastern Region Environmental Chemist,
NCDEQ/HWS
Wes Hare, Environmental Specialist 11,NCDEQ/HWS
7) Sampling Consultant: Ron Yarborough, Geologist
ERM
Mount Pleasant, SC
ron.yarborou ghkoutlook.com
Mike Tynan, Southeast Drilling Manager
IET,Inc.
infokiet-inc.net
8) Date/Time of Inspection: October 5,2022—Arrived: —08:15 am,Departed: —02:30 pm
1

9) Date of Report: October 31, 2022—Prepared by: Autumn Romanski
10) Purpose of Inspection: Remedial Action Oversight(SPL)
11) Facility Description:
Carolina Pole Leland, Inc. is a wood treating facility that specializes in the pressure treatment
of utility poles and pilings primarily for the home construction industry. Timber is bought from
off-site,de-barked,then loaded into pressure chambers for chemical treatment.After treatment,
the trams are rolled onto a transfer deck,which directs the trams into one of multiple drip bays
for initial drying and capture of liquid chemical run-off.At the time of the inspection,treatment
chemicals included chromated copper arsenate (CCA) and pentachlorophenol (penta).
The drip bays consist of metal pans incorporated into rails, onto which trams laden with
newly treated wood are rolled and allowed to drip. The drip pan/rail assemblies are affixed to
an uncoated concrete floor. These pans are designed to direct drippage into one of two metal
troughs located along the front edge of the concrete floor,which lead to a sump and treatment
system where the liquid is processed for reuse.
In addition to wood treatment,the facility accepts wastewater containing pentachlorophenol
from similar Koppers,Inc. facilities in Alabama and Georgia. This wastewater is processed
though the on-site non-discharge treatment system regulated by the NCDEQ Division of
Water Resources.Additionally,there is a Brownfields agreement in place which addresses
specific areas on the site grounds.
On February 25, 2021, Wes Hare and Heather Goldman with the Hazardous Waste Section
(HWS) visited Koppers Carolina Pole Leland, Inc. at 1901 Wood Treatment Road in Leland,
NC to conduct a Large Quantity Generator Comprehensive Evaluation Inspection. Following
the inspection an Immediate Action Notice of Violation (IA-NOV) Docket # 2022-037 was
issued on February 21, 2022 that required the facility to perform a comprehensive assessment
of any areas impacted by releases to uncoated concrete in the copper chromated arsenic and
pentachlorophenol Drip Pad areas (AOC 1, AOC 2, and AOC 3); the uncoated concrete
secondary containment areas for the copper chromated arsenic and pentachlorophenol
hazardous waste tanks (AOC 3 and AOC 4); as well as spills of listed hazardous waste to the
uncoated concrete in (AOC 5). This assessment was required to determine the extent of
hazardous waste releases. A hazardous waste determination and appropriate disposal was
required for any contaminated media or contaminated debris excavated or removed during the
assessment by using representative analytical sampling or generator knowledge.
Prior to initiating the corrective actions or sampling activities,a site meeting was conducted on
June 20. 2022 at Koppers Carolina Pole, Inc. with facility personnel, Mike Rouse, Plant
Manager, Sarah House, Safety, Health, & Environmental Manager, and Michelle Reams,
Safety and Health Environmental Coordinator, and DWM staff, Autumn Romanski, Eastern
Environmental Chemist. Wes Hare, Environmental Specialist II/Inspector, Heather Goldman,
Eastern Unit Compliance Branch Supervisor,Kim Caulk,Compliance Branch Hydrogeologist,
and Samuel Watson,Brownfields Project Manager.
On September 9, 2022,Mr. Dave Kerschner, CPG,with KU Resources on behalf of Koppers
Carolina Pole Leland, Inc, submitted an initial draft of the first phase of an In-situ Soil
Characterization Sampling Plan, and a second phase (as/if needed)would require submittal of
an ISSP plan to address underlying soil and or background sampling(as/if needed). Comments
and recommendations by the Eastern Environmental Chemist NCDEQ-HWS were provided by
email on September 16, 2022, as part of the plan review, and the plan dated September 2022
2

was approved on September 16, 2022, prior to commencing with the In-situ Soil
Characterization.
12) Remedial Action Oversight of In-situ Soil Characterization/Waste Determination
Sampling Event:
On October 5, 2022, a remediation oversight visit at Koppers Carolina Pole Leland, Inc.,
located in Leland, NC (Brunswick County) was conducted of the phase 1, In-situ Soil
Characterization Sampling Event. The purpose of the visit was to observe the in-situ soil
sampling of the soil underlying the Wastewater Treatment System Filter Press containment pad
where cracks and staining had been observed during prior Compliance Evaluation Inspection
conducted and to investigate the steam line conduit located within the containment area and
observed at a subsequent site visit to confirm impacted areas of possible releases through
cracks, and or under the pad near the filter press (AOC-5).
Sampling of two (2) areas near the steam line conduit by the filter press and cracked cement
pad per Figure 2.1 and 6.1 of the approved In-situ Soil Characterization Sampling Plan was
conducted. The facility hired Mike Tynan of IET, Inc. to conduct the drilling of sample
locations using a Geoprobe to facilitate representative collection of multiple unmixed soil
samples per core from the surface to below 6 inches. The facility also hired Ron Yarborough,
geologist with ERM to complete the sampling. It was noted that use of the Geoprobe was a
change from the original sampling plan to accommodate sampling at depth. Originally, auger
sampling had been proposed,which in sandy soils below 6 inches of depth proves difficult, so
the Geoprobe use was approved. Also, noted was the two borings that were drilled for soil
sample collection were as close to the inactive steam line/filter press as possible given
Geoprobe clearance of overhead power lines. The soil sample locations were noted by phone
GPS. See Sampling event photos section of this report. Depths of soil samples collected for
analysis were noted and varied dependent upon depth of fill/gravel layer on top of the soil layer.
Sampling of both sides of the transfer deck incorporated(6) sample locations per figure 6.1 in
the approved In-situ Soil Characterization Sampling Plan. Each side of the transfer deck area
was gridded into 3 sections,with soil sample location noted by phone GPS, and the Geoprobe
was used to collect multiple unmixed soil samples per core from the surface to below 6 inches.
It was noted that the length of the transfer deck provided in the initial sampling plan
correspondence of 150 feet was inaccurate based on field measurement,so the sample locations
were adjusted based on actual length of the deck encountered in the field and measured the day
of the sampling event. The original intent of sampling three equal distant areas of each side of
the transfer deck closest to the deck was accomplished,however,one side of the deck contained
underground and overhead power lines,and one sample location was moved to avoid any issues
with the Geoprobe and minimize risk to the power source and lines. Also, there was a slight
shift in sample location placement to avoid Geoprobe drill encounter with the transfer deck
anchoring cables.
Soil samples were collected in clean clear glass containers and amber glass containers provided
by the facility and one water sample container preserved with nitric acid (for metals water
analysis)provided by the laboratory was used to complete one equipment blank near the filter
press area.
Soil cuttings and PPE waste were collected in a 55-gallon container labeled hazardous
waste pending analysis.
No Background soil samples were collected during this sampling event.
Sampling protocols outlined in the first phase of an In-situ Soil Characterization Sampling
Plan, except otherwise noted in this Sampling Event Report were observed followed and were
3

in general accordance with the Guidelines and/or EPA Standard Operating Procedures
(SOP) Manual. Michelle Reams completed field notes and photos of the sampling
event. Ron Yarbrough and Sarah House completed the Chain of Custody and samples were
shipped to Gel Laboratories for analysis.
13) Sampling Event Photo's:
Photo of the AOC- Cement containment ad and steam line conduit at Filter Press _
Photo of Sampling Location May—sample locations approximated from GAIA GPS
and Goo-le Earth
7 jl
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n
/* (�
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4

Photo of IET Inc. Geo robe used for borings.
ti
'r
1
S 1
T•' I ��rJk.. rt�__�'titi _
.r�. �*r•T' .
r �_� v �t•• •�.. •,I •tip Iti'+}'`_• �r7i• 'ti �.�+iF
L
_ � r•�• 1 _ _ L
�L•'.P i � T3�r i��i .r �.•r � r r 5'.���•r'7���rimer �� � ~�
Photo of overhead and underground power pole and lines at the transfer deck
near TD6 samplin2 Location
01!
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a
Photo of soil cuttings and waste collected for waste determination and disposal
14) Findings and Recommendations:
No recommendations are associated with this report at this time.
Thank you for your time and cooperation to complete phase one of the sampling required by IA-
NOV Docket#2022-037 regarding the(AOC-5 )Filter press/inactive steam line conduit and the
Transfer Deck(AOC-2)where cracks, open conduits, and staining had been observed during an
inspection at the site. The phase one In-situ Soil Characterization Sampling Event was
necessary to verify if contaminant levels are present in the soil over preliminary soil
remediation goals and to determine if cleanup actions are necessary.
In the meantime,if you have any questions about this activity report,please contact Autumn
Romanski at 919.2 80.15 10.
Eastern Region
Environmental Chemist
ec: Mr.Mike Rouse
RouseMTkkoppers.com
Ms. Michelle Reams
ReamsMB(a,koFpers.com
Mr. Dave Kerschner,KU Resources,Inc.
dkerschner(a,kuresources.com
Ms. Heather Goldman,HWS CB Eastern Region
Supervisor Heather.Goldman(kncdenr.gov
Mr. Wes Hare,HWS Environmental Specialist II
Wes.Harekncdenr.gov
Mr. Samuel Watson
S amuel.Watsonkncdenr.gov
DWM Central files
6

ATTACHMENT C
LABORATORY ANALYTICAL REPORTS

® LaboratorieS LLc
PU Box N712 Charleston_SC 29417
a member of The GEL Group ivc 2040 Savage Road Chad"on.8C 2N07
P 843.556.8171
F 843.766.1178
gel.com
October 27,2022
Jane House
Koppers Utility and Industrial Products(KUIP)
P. O.Box 1124
Orangeburg, South Carolina 29116
Re: Soil RCRA
Work Order: 595762
Dear Jane House:
GEL Laboratories,LLC(GEL)appreciates the opportunity to provide the enclosed analytical results for the
sample(s)we received on October 06,2022.This original data report has been prepared and reviewed in
accordance with GEL's standard operating procedures.
Test results for NELAP or ISO 17025 accredited tests are verified to meet the requirements of those standards,
with any exceptions noted. The results reported relate only to the items tested and to the sample as received by
the laboratory.These results may not be reproduced except as full reports without approval by the laboratory.
Copies of GEL's accreditations and certifications can be found on our website at www.gel.com.
Our policy is to provide high quality,personalized analytical services to enable you to meet your analytical needs
on time every time.We trust that you will find everything in order and to your satisfaction.If you have any
questions,please do not hesitate to call me at(843)556-8171,ext. 1648.
Sincerely,
Tn"� tia"
Meredith Boddiford
Project Manager
Purchase Order:TBD
Enclosures
Page 1 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407 - [phone] -www.gel.com
Certificate of Analysis Report
for
KURI00I KUIP Carolina Pole Leland
Client SDG: 595762 GEL Work Order: 595762
The Qualifiers in this report are defined as follows:
* A quality control analyte recovery is outside of specified acceptance criteria
** Analyte is a Tracer compound
** Analyte is a surrogate compound
E Concentration of the target analyte exceeds the instrument calibration range
J See case narrative for an explanation
J Value is estimated
P OrganicsThe concentrations between the primary and confirmation columns/detectors is>40%different. For
HPLC,the difference is>70%.
U Analyte was analyzed for,but not detected above the MDL,MDA,MDC or LOD.
Where the analytical method has been performed under NELAP certification,the analysis has met all of the
requirements of the NELAC standard unless qualified on the Certificate of Analysis.
The designation ND,if present,appears in the result column when the analyte concentration is not detected above
the limit as defined in the 'U' qualifier above.
This data report has been prepared and reviewed in accordance with GEL Laboratories LLC
standard operating procedures.Please direct any questions to your Project Manager,Meredith Boddiford.
wLt't'� sr&"
Reviewed by
Page 2 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-1 Project: KURIO0122
Sample ID: 595762001 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22 12:39
Receive Date: 06-OCT-22
Collector: Client
Moisture: 8.11%
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Mercury Analysis-CVAA
SW846 7471B Mercury, Solid"Dry Weight Corrected"
Mercury J 21.2 7.65 22.8 ug/kg 105 1 JP2 10/17/22 0924 2329118 1
Metals Analysis-ICP
SW846 3050B/6010D Metals, Solid"Dry Weight Corrected"
Arsenic 117 0.487 2.92 mg/kg 89.4 1 TXT1 10/13/22 0052 2325850 2
Barium 1.11 0.0973 0.487 mg/kg 89.4 1
Cadmium U ND 0.0973 0.487 mg/kg 89.4 1
Chromium 237 0.146 0.973 mg/kg 89.4 1
Copper 73.4 0.292 1.95 mg/kg 89.4 1
Lead J 1.25 0.321 1.95 mg/kg 89.4 1
Selenium U ND 0.487 2.92 mg/kg 89.4 1
Silver U ND 0.0973 0.487 mg/kg 89.4 1
Semi-Volatiles-HERB
SW846 8151A Herbicides,Solid"Dry Weight Corrected"
Pentachlorophenol 0.236 0.00902 0.0272 mg/kg 0.200 5 YS1 10/19/22 0635 2327654 4
Spectrometric Analysis
SW846 7196A Hexavalent Chromium"Dry Weight Corrected"
Hexavalent Chromium U ND 0.180 0.449 mg/kg 41.3 1 VHl 10/27/22 1439 2327899 5
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 3050B SW846 3050B Prep CD3 10/11/22 1650 2325849
SW846 3060A SW846_7196A Hexavalent Chromium in Soil HH2 10/27/22 1105 2327898
SW846 7471B Prep SW846 7471B Mercury Prep Soil RM4 10/14/22 1147 2329110
SW846 8151A 8151A Herbicides Prep in Soil Si 10/14/22 0754 2327652
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 7471B
2 SW846 3050B/6010D
3 SW846 8151A
4 SW846 8151A
5 SW846 7196A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW846 8151A Herbicides,Solid"Dry Weight 0.0484 mg/kg 0.109 45 (34%-149%)
Page 3 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-1 Project: KURIO0122
Sample ID: 595762001 Client ID: KURI001
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
Corrected"
Notes:
Column headers are defined as follows:
DF: Dilution Factor LC/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 4 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-2 Project: KURIO0122
Sample ID: 595762002 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22 12:30
Receive Date: 06-OCT-22
Collector: Client
Moisture: 21.8%
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Mercury Analysis-CVAA
SW846 7471B Mercury, Solid"Dry Weight Corrected"
Mercury U ND 9.78 29.2 ug/kg 114 1 JP2 10/17/22 0932 2329118 1
Metals Analysis-ICP
SW846 3050B/6010D Metals, Solid"Dry Weight Corrected"
Arsenic 18.6 0.581 3.49 mg/kg 90.9 1 TXT1 10/13/22 0115 2325850 2
Barium 9.97 0.116 0.581 mg/kg 90.9 1
Cadmium U ND 0.116 0.581 mg/kg 90.9 1
Chromium 13.5 0.174 1.16 mg/kg 90.9 1
Copper 14.0 0.349 2.33 mg/kg 90.9 1
Lead J 1.26 0.384 2.33 mg/kg 90.9 1
Selenium U ND 0.581 3.49 mg/kg 90.9 1
Silver U ND 0.116 0.581 mg/kg 90.9 1
Semi-Volatiles-HERB
SW846 8151A Herbicides,Solid"Dry Weight Corrected"
Pentachlorophenol 0.107 0.00424 0.0128 mg/kg 0.200 2 YS1 10/19/22 0658 2327654 4
Spectrometric Analysis
SW846 7196A Hexavalent Chromium"Dry Weight Corrected"
Hexavalent Chromium U ND 0.193 0.482 mg/kg 37.7 1 VHl 10/27/22 1440 2327899 5
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 3050B SW846 3050B Prep CD3 10/11/22 1650 2325849
SW846 3060A SW846_7196A Hexavalent Chromium in Soil HH2 10/27/22 1105 2327898
SW846 7471B Prep SW846 7471B Mercury Prep Soil RM4 10/14/22 1147 2329110
SW846 8151A 8151A Herbicides Prep in Soil Si 10/14/22 0754 2327652
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 7471B
2 SW846 3050B/6010D
3 SW846 8151A
4 SW846 8151A
5 SW846 7196A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW846 8151A Herbicides,Solid"Dry Weight 0.105 mg/kg 0.128 82 (34%-149%)
Page 5 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-2 Project: KURIO0122
Sample ID: 595762002 Client ID: KURI001
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
Corrected"
Notes:
Column headers are defined as follows:
DF: Dilution Factor LC/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 6 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-3 Project: KURIO0122
Sample ID: 595762003 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22 11:40
Receive Date: 06-OCT-22
Collector: Client
Moisture: 11.5%
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Mercury Analysis-CVAA
SW846 7471B Mercury, Solid"Dry Weight Corrected"
Mercury J 9.27 7.97 23.8 ug/kg 105 1 JP2 10/17/22 0934 2329118 1
Metals Analysis-ICP
SW846 3050B/6010D Metals, Solid"Dry Weight Corrected"
Arsenic 113 0.536 3.22 mg/kg 94.9 1 TXT1 10/13/22 0118 2325850 2
Barium 3.66 0.107 0.536 mg/kg 94.9 1
Cadmium J 0.197 0.107 0.536 mg/kg 94.9 1
Chromium 125 0.161 1.07 mg/kg 94.9 1
Copper 74.7 0.322 2.14 mg/kg 94.9 1
Lead 2.58 0.354 2.14 mg/kg 94.9 1
Selenium U ND 0.536 3.22 mg/kg 94.9 1
Silver J 0.137 0.107 0.536 mg/kg 94.9 1
Semi-Volatiles-HERB
SW846 8151A Herbicides,Solid"Dry Weight Corrected"
Pentachlorophenol 0.190 0.00933 0.0281 mg/kg 0.199 5 YS1 10/19/22 0722 2327654 3
Spectrometric Analysis
SW846 7196A Hexavalent Chromium"Dry Weight Corrected"
Hexavalent Chromium 0.990 0.160 0.401 mg/kg 35.5 1 VHl 10/27/22 1440 2327899 4
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 3050B SW846 3050B Prep CD3 10/11/22 1650 2325849
SW846 3060A SW846_7196A Hexavalent Chromium in Soil HH2 10/27/22 1105 2327898
SW846 7471B Prep SW846 7471B Mercury Prep Soil RM4 10/14/22 1147 2329110
SW846 8151A 8151A Herbicides Prep in Soil Si 10/14/22 0754 2327652
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 7471B
2 SW846 3050B/6010D
3 SW846 8151A
4 SW846 7196A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW846 8151A Herbicides,Solid"Dry Weight 0.0801 mg/kg 0.112 71 (34%-149%)
Corrected"
Page 7 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-3 Project: KURIO0122
Sample ID: 595762003 Client ID: KURI001
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Notes:
Column headers are defined as follows:
DF:Dilution Factor Lc/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 8 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-4 Project: KURIO0122
Sample ID: 595762004 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22 12:21
Receive Date: 06-OCT-22
Collector: Client
Moisture: 8.81%
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Mercury Analysis-CVAA
SW846 7471B Mercury, Solid"Dry Weight Corrected"
Mercury J 13.8 8.04 24.0 ug/kg 109 1 JP2 10/17/22 0936 2329118 1
Metals Analysis-ICP
SW846 3050B/6010D Metals, Solid"Dry Weight Corrected"
Arsenic 22.9 0.527 3.16 mg/kg 96.2 1 TXT1 10/13/22 0121 2325850 2
Barium 2.99 0.105 0.527 mg/kg 96.2 1
Cadmium J 0.113 0.105 0.527 mg/kg 96.2 1
Chromium 34.8 0.158 1.05 mg/kg 96.2 1
Copper 11.4 0.316 2.11 mg/kg 96.2 1
Lead J 0.733 0.348 2.11 mg/kg 96.2 1
Selenium U ND 0.527 3.16 mg/kg 96.2 1
Silver U ND 0.105 0.527 mg/kg 96.2 1
Semi-Volatiles-HERB
SW846 8151A Herbicides,Solid"Dry Weight Corrected"
Pentachlorophenol 0.0202 0.00182 0.00548 mg/kg 0.200 1 YS1 10/19/22 0745 2327654 4
Spectrometric Analysis
SW846 7196A Hexavalent Chromium"Dry Weight Corrected"
Hexavalent Chromium 0.814 0.176 0.441 mg/kg 40.2 1 VHl 10/27/22 1441 2327899 5
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 3050B SW846 3050B Prep CD3 10/11/22 1650 2325849
SW846 3060A SW846_7196A Hexavalent Chromium in Soil HH2 10/27/22 1105 2327898
SW846 7471B Prep SW846 7471B Mercury Prep Soil RM4 10/14/22 1147 2329110
SW846 8151A 8151A Herbicides Prep in Soil Si 10/14/22 0754 2327652
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 7471B
2 SW846 3050B/6010D
3 SW846 8151A
4 SW846 8151A
5 SW846 7196A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW846 8151A Herbicides,Solid"Dry Weight 0.0692 mg/kg 0.110 63 (34%-149%)
Page 9 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-4 Project: KURIO0122
Sample ID: 595762004 Client ID: KURI001
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
Corrected"
Notes:
Column headers are defined as follows:
DF: Dilution Factor LC/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 10 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-5 Project: KURIO0122
Sample ID: 595762005 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22 11:55
Receive Date: 06-OCT-22
Collector: Client
Moisture: 14.9%
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Mercury Analysis-CVAA
SW846 7471B Mercury, Solid"Dry Weight Corrected"
Mercury U ND 8.29 24.7 ug/kg 105 1 JP2 10/17/22 0937 2329118 1
Metals Analysis-ICP
SW846 3050B/6010D Metals, Solid"Dry Weight Corrected"
Arsenic 220 0.528 3.17 mg/kg 89.9 1 TXT1 10/13/22 0124 2325850 2
Barium 2.31 0.106 0.528 mg/kg 89.9 1
Cadmium J 0.243 0.106 0.528 mg/kg 89.9 1
Copper 389 0.317 2.11 mg/kg 89.9 1
Lead J 1.41 0.349 2.11 mg/kg 89.9 1
Selenium U ND 0.528 3.17 mg/kg 89.9 1
Chromium 534 0.793 5.28 mg/kg 89.9 5 TXTl 10/13/22 1441 2325850 3
Silver J 1.52 0.528 2.64 mg/kg 89.9 5
Semi-Volatiles-HERB
SW846 8151A Herbicides,Solid"Dry Weight Corrected"
Pentachtorophenot 0.203 0.00971 0.0292 mg/kg 0.199 5 YS1 10/19/22 0809 2327654 4
Spectrometric Analysis
SW846 7196A Hexavalent Chromium"Dry Weight Corrected"
Hexavalent Chromium 3.85 0.191 0.477 mg/kg 40.6 1 VHl 10/27/22 1441 2327899 5
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 3050B SW846 3050B Prep CD3 10/11/22 1650 2325849
SW846 3060A SW846_7196A Hexavalent Chromium in Soil HH2 10/27/22 1105 2327898
SW846 7471B Prep SW846 7471B Mercury Prep Soil RM4 10/14/22 1147 2329110
SW846 8151A 8151A Herbicides Prep in Soil Si 10/14/22 0754 2327652
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 7471B
2 SW846 3050B/6010D
3 SW846 3050B/6010D
4 SW846 8151A
5 SW846 7196A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW846 8151A Herbicides,Solid"Dry Weight 0.0864 mg/kg 0.117 74 (34%-149%)
Page 11 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-5 Project: KURIO0122
Sample ID: 595762005 Client ID: KURI001
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
Corrected"
Notes:
Column headers are defined as follows:
DF: Dilution Factor LC/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 12 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-6 Project: KURIO0122
Sample ID: 595762006 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22 12:07
Receive Date: 06-OCT-22
Collector: Client
Moisture: 10.3%
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Mercury Analysis-CVAA
SW846 7471B Mercury, Solid"Dry Weight Corrected"
Mercury J 8.84 8.46 25.2 ug/kg 113 1 JP2 10/17/22 0939 2329118 1
Metals Analysis-ICP
SW846 3050B/6010D Metals, Solid"Dry Weight Corrected"
Arsenic 40.6 0.502 3.01 mg/kg 90.1 1 TXT1 10/13/22 0127 2325850 2
Barium 3.10 0.100 0.502 mg/kg 90.1 1
Cadmium U ND 0.100 0.502 mg/kg 90.1 1
Chromium 84.8 0.151 1.00 mg/kg 90.1 1
Copper 65.0 0.301 2.01 mg/kg 90.1 1
Lead J 1.80 0.332 2.01 mg/kg 90.1 1
Selenium U ND 0.502 3.01 mg/kg 90.1 1
Silver U ND 0.100 0.502 mg/kg 90.1 1
Semi-Volatiles-HERB
SW846 8151A Herbicides,Solid"Dry Weight Corrected"
Pentachlorophenol P 0.0138 0.00184 0.00554 mg/kg 0.199 1 YS1 10/19/22 0832 2327654 3
Spectrometric Analysis
SW846 7196A Hexavalent Chromium"Dry Weight Corrected"
Hexavalent Chromium U ND 0.211 0.528 mg/kg 47.3 1 VHl 10/27/22 1442 2327899 4
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 3050B SW846 3050B Prep CD3 10/11/22 1650 2325849
SW846 3060A SW846_7196A Hexavalent Chromium in Soil HH2 10/27/22 1105 2327898
SW846 7471B Prep SW846 7471B Mercury Prep Soil RM4 10/14/22 1147 2329110
SW846 8151A 8151A Herbicides Prep in Soil Si 10/14/22 0754 2327652
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 7471B
2 SW846 3050B/6010D
3 SW846 8151A
4 SW846 7196A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW846 8151A Herbicides,Solid"Dry Weight 0.0834 mg/kg 0.111 75 (34%-149%)
Corrected"
Page 13 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-6 Project: KURIO0122
Sample ID: 595762006 Client ID: KURI001
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Notes:
Column headers are defined as follows:
DF:Dilution Factor Lc/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 14 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-71) Project: KURIO0122
Sample ID: 595762007 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22 12:51
Receive Date: 06-OCT-22
Collector: Client
Moisture: 9.71%
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Mercury Analysis-CVAA
SW846 7471B Mercury, Solid"Dry Weight Corrected"
Mercury 27.4 7.92 23.6 ug/kg 107 1 JP2 10/17/22 0944 2329118 1
Metals Analysis-ICP
SW846 3050B/6010D Metals, Solid"Dry Weight Corrected"
Arsenic 4.04 0.512 3.07 mg/kg 92.4 1 TXT1 10/13/22 0130 2325850 2
Barium J 0.256 0.102 0.512 mg/kg 92.4 1
Cadmium U ND 0.102 0.512 mg/kg 92.4 1
Chromium 38.7 0.154 1.02 mg/kg 92.4 1
Copper J 1.46 0.307 2.05 mg/kg 92.4 1
Lead J 0.527 0.338 2.05 mg/kg 92.4 1
Selenium U ND 0.512 3.07 mg/kg 92.4 1
Silver U ND 0.102 0.512 mg/kg 92.4 1
Semi-Volatiles-HERB
SW846 8151A Herbicides,Solid"Dry Weight Corrected"
Pentachlorophenol 0.0229 0.00184 0.00553 mg/kg 0.200 1 YS1 10/19/22 0856 2327654 3
Spectrometric Analysis
SW846 7196A Hexavalent Chromium"Dry Weight Corrected"
Hexavalent Chromium U ND 0.219 0.548 mg/kg 49.5 1 VHl 10/27/22 1442 2327899 4
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 3050B SW846 3050B Prep CD3 10/11/22 1650 2325849
SW846 3060A SW846_7196A Hexavalent Chromium in Soil HH2 10/27/22 1105 2327898
SW846 7471B Prep SW846 7471B Mercury Prep Soil RM4 10/14/22 1147 2329110
SW846 8151A 8151A Herbicides Prep in Soil Si 10/14/22 0754 2327652
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 7471B
2 SW846 3050B/6010D
3 SW846 8151A
4 SW846 7196A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW846 8151A Herbicides,Solid"Dry Weight 0.0763 mg/kg 0.111 69 (34%-149%)
Corrected"
Page 15 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-71) Project: KURIO0122
Sample ID: 595762007 Client ID: KURI001
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Notes:
Column headers are defined as follows:
DF:Dilution Factor Lc/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 16 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: SL1 2.9-4ft Project: KURIO0122
Sample ID: 595762008 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22 09:50
Receive Date: 06-OCT-22
Collector: Client
Moisture: 5.49%
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Mercury Analysis-CVAA
SW846 7471B Mercury, Solid"Dry Weight Corrected"
Mercury 154 8.12 24.2 ug/kg 115 1 JP2 10/17/22 0946 2329118 1
Metals Analysis-ICP
SW846 3050B/6010D Metals, Solid"Dry Weight Corrected"
Arsenic 113 0.448 2.69 mg/kg 84.6 1 TXT1 10/13/22 0134 2325850 2
Barium 1.81 0.0895 0.448 mg/kg 84.6 1
Cadmium U ND 0.0895 0.448 mg/kg 84.6 1
Chromium 125 0.134 0.895 mg/kg 84.6 1
Copper 84.4 0.269 1.79 mg/kg 84.6 1
Lead 2.34 0.295 1.79 mg/kg 84.6 1
Selenium U ND 0.448 2.69 mg/kg 84.6 1
Silver U ND 0.0895 0.448 mg/kg 84.6 1
Semi-Volatiles-HERB
SW846 8151A Herbicides,Solid"Dry Weight Corrected"
Pentachlorophenol 28.2 1.75 5.27 mg/kg 0.199 1000 YS1 10/19/22 1241 2327654 4
Spectrometric Analysis
SW846 7196A Hexavalent Chromium"Dry Weight Corrected"
Hexavalent Chromium U ND 0.162 0.405 mg/kg 38.3 1 VHl 10/27/22 1443 2327899 5
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 3050B SW846 3050B Prep CD3 10/11/22 1650 2325849
SW846 3060A SW846_7196A Hexavalent Chromium in Soil HH2 10/27/22 1105 2327898
SW846 7471B Prep SW846 7471B Mercury Prep Soil RM4 10/14/22 1147 2329110
SW846 8151A 8151A Herbicides Prep in Soil Si 10/14/22 0754 2327652
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 7471B
2 SW846 3050B/6010D
3 SW846 8151A
4 SW846 8151A
5 SW846 7196A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW846 8151A Herbicides,Solid"Dry Weight 0.000 mg/kg 0.105 0* (34%-149%)
Page 17 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: SL1 2.9-4ft Project: KURIO0122
Sample ID: 595762008 Client ID: KURI001
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
Corrected"
Notes:
Column headers are defined as follows:
DF: Dilution Factor LC/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 18 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: SL1 4.5-5ft Project: KURIO0122
Sample ID: 595762009 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22 09:50
Receive Date: 06-OCT-22
Collector: Client
Moisture: 9.54%
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Mercury Analysis-CVAA
SW846 7471B Mercury, Solid"Dry Weight Corrected"
Mercury U ND 7.51 22.4 ug/kg 101 1 JP2 10/17/22 0948 2329118 1
Metals Analysis-ICP
SW846 3050B/6010D Metals, Solid"Dry Weight Corrected"
Arsenic 41.9 0.508 3.05 mg/kg 91.9 1 TXT1 10/13/22 0138 2325850 2
Barium 1.12 0.102 0.508 mg/kg 91.9 1
Cadmium U ND 0.102 0.508 mg/kg 91.9 1
Chromium J 0.304 0.152 1.02 mg/kg 91.9 1
Copper J 0.424 0.305 2.03 mg/kg 91.9 1
Lead J 0.488 0.335 2.03 mg/kg 91.9 1
Selenium U ND 0.508 3.05 mg/kg 91.9 1
Silver U ND 0.102 0.508 mg/kg 91.9 1
Semi-Volatiles-HERB
SW846 8151A Herbicides,Solid"Dry Weight Corrected"
Pentachlorophenol 0.00815 0.00182 0.00549 mg/kg 0.199 1 YS1 10/19/22 1005 2327654 3
Spectrometric Analysis
SW846 7196A Hexavalent Chromium"Dry Weight Corrected"
Hexavalent Chromium U ND 0.163 0.408 mg/kg 36.9 1 VHl 10/27/22 1443 2327899 5
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 3050B SW846 3050B Prep CD3 10/11/22 1650 2325849
SW846 3060A SW846_7196A Hexavalent Chromium in Soil HH2 10/27/22 1105 2327898
SW846 7471B Prep SW846 7471B Mercury Prep Soil RM4 10/14/22 1147 2329110
SW846 8151A 8151A Herbicides Prep in Soil Si 10/14/22 0754 2327652
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 7471B
2 SW846 3050B/6010D
3 SW846 8151A
4 SW846 8151A
5 SW846 7196A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW846 8151A Herbicides,Solid"Dry Weight 0.0514 mg/kg 0.110 47 (34%-149%)
Page 19 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: SL1 4.5-5ft Project: KURIO0122
Sample ID: 595762009 Client ID: KURI001
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
Corrected"
Notes:
Column headers are defined as follows:
DF: Dilution Factor LC/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 20 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: SL2 3.9-5ft Project: KURIO0122
Sample ID: 595762010 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22 10:30
Receive Date: 06-OCT-22
Collector: Client
Moisture: 10.8%
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Mercury Analysis-CVAA
SW846 7471B Mercury, Solid"Dry Weight Corrected"
Mercury U ND 7.99 23.9 ug/kg 106 1 JP2 10/17/22 0949 2329118 1
Metals Analysis-ICP
SW846 3050B/6010D Metals, Solid"Dry Weight Corrected"
Arsenic 52.1 0.484 2.90 mg/kg 86.4 1 TXT1 10/13/22 0142 2325850 2
Barium 1.12 0.0968 0.484 mg/kg 86.4 1
Cadmium U ND 0.0968 0.484 mg/kg 86.4 1
Chromium 32.9 0.145 0.968 mg/kg 86.4 1
Copper 22.6 0.290 1.94 mg/kg 86.4 1
Lead J 1.31 0.320 1.94 mg/kg 86.4 1
Selenium U ND 0.484 2.90 mg/kg 86.4 1
Silver U ND 0.0968 0.484 mg/kg 86.4 1
Semi-Volatiles-HERB
SW846 8151A Herbicides,Solid"Dry Weight Corrected"
Pentachlorophenol 1.87 0.0923 0.278 mg/kg 0.198 50 YS1 10/19/22 1130 2327654 3
Spectrometric Analysis
SW846 7196A Hexavalent Chromium"Dry Weight Corrected"
Hexavalent Chromium U ND 0.147 0.368 mg/kg 32.8 1 VHl 10/27/22 1443 2327899 4
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 3050B SW846 3050B Prep CD3 10/11/22 1650 2325849
SW846 3060A SW846_7196A Hexavalent Chromium in Soil HH2 10/27/22 1105 2327898
SW846 7471B Prep SW846 7471B Mercury Prep Soil RM4 10/14/22 1147 2329110
SW846 8151A 8151A Herbicides Prep in Soil Si 10/14/22 0754 2327652
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 7471B
2 SW846 3050B/6010D
3 SW846 8151A
4 SW846 7196A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW846 8151A Herbicides,Solid"Dry Weight 0.0829 mg/kg 0.111 75 (34%-149%)
Corrected"
Page 21 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: SL2 3.9-5ft Project: KURIO0122
Sample ID: 595762010 Client ID: KURI001
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Notes:
Column headers are defined as follows:
DF:Dilution Factor Lc/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 22 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: SL2 2-3.9ft Project: KURIO0122
Sample ID: 595762011 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22 10:30
Receive Date: 06-OCT-22
Collector: Client
Moisture: 3.57%
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Semi-Volatiles-HERB
SW846 8151A Herbicides,Solid"Dry Weight Corrected"
Pentachlorophenol 2.46 0.0858 0.259 mg/kg 0.199 50 YS1 10/19/22 1154 2327654 1
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 8151A 8151A Herbicides Prep in Soil Si 10/14/22 0754 2327652
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 8151A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW846 8151A Herbicides,Solid"Dry Weight 0.0409 mg/kg 0.103 40 (34%-149%)
Corrected"
Notes:
Column headers are defined as follows:
DF:Dilution Factor Lc/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 23 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: SL BLANK Project: KURIO0122
Sample ID: 595762012 Client ID: KURI001
Matrix: Water
Collect Date: 05-OCT-22 10:30
Receive Date: 06-OCT-22
Collector: Client
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Mercury Analysis-CVAA
7470 Cold Vapor Mercury,Liquid"As Received"
Mercury U ND 0.0670 0.200 ug/L 1.00 1 JP2 10/14/22 1139 2328370 1
Metals Analysis-ICP
SW846 3005A/6010D Metals Scan Liquid"As Received"
Arsenic U ND 5.00 30.0 ug/L 1.00 1 LS 10/10/22 1030 2325848 2
Barium U ND 1.00 5.00 ug/L 1.00 1
Cadmium U ND 1.00 5.00 ug/L 1.00 1
Chromium U ND 1.00 10.0 ug/L 1.00 1
Copper U ND 3.00 20.0 ug/L 1.00 1
Lead U ND 3.30 20.0 ug/L 1.00 1
Selenium J 8.69 6.00 30.0 ug/L 1.00 1
Silver U ND 1.00 5.00 ug/L 1.00 1
Semi-Volatiles-HERB
SW 3535A/8151A Herbicides Liquid"As Received"
Pentachlorophenol U ND 0.417 1.25 ug/L 0.0500 1 YSl 10/10/22 1405 2325943 3
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 3005A SW846 3005A for 6010D CD3 10/07/22 1635 2325847
SW846 3535A SW3535A Herbicides SPE Extraction LWl 10/07/22 0536 2325942
SW846 7470A Prep EPA 7470A Mercury Prep Liquid RM4 10/13/22 1157 2328363
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 7470A
2 SW846 3005A/6010D
3 SW846 3535A/8151A
4 SW846 3535A/8151A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW 3535A/8151A Herbicides Liquid"As 24.3 ug/L 25.0 97 (46%-144%)
Received"
Notes:
Page 24 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: SL BLANK Project: KURIO0122
Sample ID: 595762012 Client ID: KURI001
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Column headers are defined as follows:
DF:Dilution Factor Lc/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 25 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Company: Koppers Utility and Industrial
Address : Products(KUIP)
P.O.Box 1124
Orangeburg,South Carolina 29116 Report Date: October 27,2022
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-1 Project: KURI00122
Sample ID: 595762001 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22
Receive Date: 06-OCT-22
Collector: Client
Moisture: 8.11%
Parameter Qualifier Result Uncertainty MDC TPU RL Units PIT DF Analyst Date Time Batch Mtd.
Gravimetric Solids
"As Received"
The following Analytical Methods were performed
Method Description
1 ASTM D 2216(Modified)
Surrogate/Tracer Recovery Test Batch ID Recovery% Acceptable Limits
Notes:
The MDC is a sample specific MDC.
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
Column headers are defined as follows:
DF:Dilution Factor Mtd.:Method
DL:Detection Limit PF:Prep Factor
Lc/LC: Critical Level RL:Reporting Limit
MDA:Minimum Detectable Activity TPU:Total Propagated Uncertainty
MDC:Minimum Detectable Concentration
Page 26 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Company: Koppers Utility and Industrial
Address : Products(KUIP)
P.O.Box 1124
Orangeburg,South Carolina 29116 Report Date: October 27,2022
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-2 Project: KURIO0122
Sample ID: 595762002 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22
Receive Date: 06-OCT-22
Collector: Client
Moisture: 21.8%
Parameter Qualifier Result Uncertainty MDC TPU RL Units PF DF Analyst Date Time Batch Mtd.
Gravimetric Solids
'As Received"
The following Analytical Methods were performed
Method Description
1 ASTM D 2216(Modified)
Surrogate/Tracer Recovery Test Batch ID Recovery% Acceptable Limits
Notes:
The MDC is a sample specific MDC.
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
Column headers are defined as follows:
DF:Dilution Factor Mtd.:Method
DL:Detection Limit PF: Prep Factor
Lc/LC: Critical Level RL:Reporting Limit
MDA:Minimum Detectable Activity TPU:Total Propagated Uncertainty
MDC: Minimum Detectable Concentration
Page 27 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Company: Koppers Utility and Industrial
Address : Products(KUIP)
P.O.Box 1124
Orangeburg,South Carolina 29116 Report Date: October 27,2022
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-3 Project: KURIO0122
Sample ID: 595762003 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22
Receive Date: 06-OCT-22
Collector: Client
Moisture: 11.5%
Parameter Qualifier Result Uncertainty MDC TPU RL Units PF DF Analyst Date Time Batch Mtd.
Gravimetric Solids
'As Received"
The following Analytical Methods were performed
Method Description
1 ASTM D 2216(Modified)
Surrogate/Tracer Recovery Test Batch ID Recovery% Acceptable Limits
Notes:
The MDC is a sample specific MDC.
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
Column headers are defined as follows:
DF:Dilution Factor Mtd.:Method
DL:Detection Limit PF: Prep Factor
Lc/LC: Critical Level RL:Reporting Limit
MDA:Minimum Detectable Activity TPU:Total Propagated Uncertainty
MDC: Minimum Detectable Concentration
Page 28 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Company: Koppers Utility and Industrial
Address : Products(KUIP)
P.O.Box 1124
Orangeburg,South Carolina 29116 Report Date: October 27,2022
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-4 Project: KURIO0122
Sample ID: 595762004 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22
Receive Date: 06-OCT-22
Collector: Client
Moisture: 8.81%
Parameter Qualifier Result Uncertainty MDC TPU RL Units PF DF Analyst Date Time Batch Mtd.
Gravimetric Solids
'As Received"
The following Analytical Methods were performed
Method Description
1 ASTM D 2216(Modified)
Surrogate/Tracer Recovery Test Batch ID Recovery% Acceptable Limits
Notes:
The MDC is a sample specific MDC.
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
Column headers are defined as follows:
DF:Dilution Factor Mtd.:Method
DL:Detection Limit PF: Prep Factor
Lc/LC: Critical Level RL:Reporting Limit
MDA:Minimum Detectable Activity TPU:Total Propagated Uncertainty
MDC: Minimum Detectable Concentration
Page 29 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Company: Koppers Utility and Industrial
Address : Products(KUIP)
P.O.Box 1124
Orangeburg,South Carolina 29116 Report Date: October 27,2022
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-5 Project: KURIO0122
Sample ID: 595762005 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22
Receive Date: 06-OCT-22
Collector: Client
Moisture: 14.9%
Parameter Qualifier Result Uncertainty MDC TPU RL Units PF DF Analyst Date Time Batch Mtd.
Gravimetric Solids
'As Received"
The following Analytical Methods were performed
Method Description
1 ASTM D 2216(Modified)
Surrogate/Tracer Recovery Test Batch ID Recovery% Acceptable Limits
Notes:
The MDC is a sample specific MDC.
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
Column headers are defined as follows:
DF:Dilution Factor Mtd.:Method
DL:Detection Limit PF: Prep Factor
Lc/LC: Critical Level RL:Reporting Limit
MDA:Minimum Detectable Activity TPU:Total Propagated Uncertainty
MDC: Minimum Detectable Concentration
Page 30 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Company: Koppers Utility and Industrial
Address : Products(KUIP)
P.O.Box 1124
Orangeburg,South Carolina 29116 Report Date: October 27,2022
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-6 Project: KURIO0122
Sample ID: 595762006 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22
Receive Date: 06-OCT-22
Collector: Client
Moisture: 10.3%
Parameter Qualifier Result Uncertainty MDC TPU RL Units PF DF Analyst Date Time Batch Mtd.
Gravimetric Solids
'As Received"
The following Analytical Methods were performed
Method Description
1 ASTM D 2216(Modified)
Surrogate/Tracer Recovery Test Batch ID Recovery% Acceptable Limits
Notes:
The MDC is a sample specific MDC.
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
Column headers are defined as follows:
DF:Dilution Factor Mtd.:Method
DL:Detection Limit PF: Prep Factor
Lc/LC: Critical Level RL:Reporting Limit
MDA:Minimum Detectable Activity TPU:Total Propagated Uncertainty
MDC: Minimum Detectable Concentration
Page 31 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Company: Koppers Utility and Industrial
Address : Products(KUIP)
P.O.Box 1124
Orangeburg,South Carolina 29116 Report Date: October 27,2022
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-71) Project: KURIO0122
Sample ID: 595762007 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22
Receive Date: 06-OCT-22
Collector: Client
Moisture: 9.71%
Parameter Qualifier Result Uncertainty MDC TPU RL Units PF DF Analyst Date Time Batch Mtd.
Gravimetric Solids
'As Received"
The following Analytical Methods were performed
Method Description
1 ASTM D 2216(Modified)
Surrogate/Tracer Recovery Test Batch ID Recovery% Acceptable Limits
Notes:
The MDC is a sample specific MDC.
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
Column headers are defined as follows:
DF:Dilution Factor Mtd.:Method
DL:Detection Limit PF: Prep Factor
Lc/LC: Critical Level RL:Reporting Limit
MDA:Minimum Detectable Activity TPU:Total Propagated Uncertainty
MDC: Minimum Detectable Concentration
Page 32 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Company: Koppers Utility and Industrial
Address : Products(KUIP)
P.O.Box 1124
Orangeburg,South Carolina 29116 Report Date: October 27,2022
Contact: Jane House
Project: Soil RCRA
Client Sample ID: SL1 2.9-4ft Project: KURIO0122
Sample ID: 595762008 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22
Receive Date: 06-OCT-22
Collector: Client
Moisture: 5.49%
Parameter Qualifier Result Uncertainty MDC TPU RL Units PF DF Analyst Date Time Batch Mtd.
Gravimetric Solids
'As Received"
The following Analytical Methods were performed
Method Description
1 ASTM D 2216(Modified)
Surrogate/Tracer Recovery Test Batch ID Recovery% Acceptable Limits
Notes:
The MDC is a sample specific MDC.
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
Column headers are defined as follows:
DF:Dilution Factor Mtd.:Method
DL:Detection Limit PF: Prep Factor
Lc/LC: Critical Level RL:Reporting Limit
MDA:Minimum Detectable Activity TPU:Total Propagated Uncertainty
MDC: Minimum Detectable Concentration
Page 33 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Company: Koppers Utility and Industrial
Address : Products(KUIP)
P.O.Box 1124
Orangeburg,South Carolina 29116 Report Date: October 27,2022
Contact: Jane House
Project: Soil RCRA
Client Sample ID: SL1 4.5-5ft Project: KURIO0122
Sample ID: 595762009 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22
Receive Date: 06-OCT-22
Collector: Client
Moisture: 9.54%
Parameter Qualifier Result Uncertainty MDC TPU RL Units PF DF Analyst Date Time Batch Mtd.
Gravimetric Solids
'As Received"
The following Analytical Methods were performed
Method Description
1 ASTM D 2216(Modified)
Surrogate/Tracer Recovery Test Batch ID Recovery% Acceptable Limits
Notes:
The MDC is a sample specific MDC.
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
Column headers are defined as follows:
DF:Dilution Factor Mtd.:Method
DL:Detection Limit PF: Prep Factor
Lc/LC: Critical Level RL:Reporting Limit
MDA:Minimum Detectable Activity TPU:Total Propagated Uncertainty
MDC: Minimum Detectable Concentration
Page 34 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Company: Koppers Utility and Industrial
Address : Products(KUIP)
P.O.Box 1124
Orangeburg,South Carolina 29116 Report Date: October 27,2022
Contact: Jane House
Project: Soil RCRA
Client Sample ID: SL2 3.9-5ft Project: KURIO0122
Sample ID: 595762010 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22
Receive Date: 06-OCT-22
Collector: Client
Moisture: 10.8%
Parameter Qualifier Result Uncertainty MDC TPU RL Units PF DF Analyst Date Time Batch Mtd.
Gravimetric Solids
'As Received"
The following Analytical Methods were performed
Method Description
1 ASTM D 2216(Modified)
Surrogate/Tracer Recovery Test Batch ID Recovery% Acceptable Limits
Notes:
The MDC is a sample specific MDC.
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
Column headers are defined as follows:
DF:Dilution Factor Mtd.:Method
DL:Detection Limit PF: Prep Factor
Lc/LC: Critical Level RL:Reporting Limit
MDA:Minimum Detectable Activity TPU:Total Propagated Uncertainty
MDC: Minimum Detectable Concentration
Page 35 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Company: Koppers Utility and Industrial
Address : Products(KUIP)
P.O.Box 1124
Orangeburg,South Carolina 29116 Report Date: October 27,2022
Contact: Jane House
Project: Soil RCRA
Client Sample ID: SL2 2-3.9ft Project: KURI00122
Sample ID: 595762011 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22
Receive Date: 06-OCT-22
Collector: Client
Moisture: 3.57%
Parameter Qualifier Result Uncertainty MDC TPU RL Units PIT DF Analyst Date Time Batch Mtd.
Gravimetric Solids
"As Received"
The following Analytical Methods were performed
Method Description
1 ASTM D 2216(Modified)
Surrogate/Tracer Recovery Test Batch ID Recovery% Acceptable Limits
Notes:
The MDC is a sample specific MDC.
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
Column headers are defined as follows:
DF:Dilution Factor Mtd.:Method
DL:Detection Limit PF:Prep Factor
Lc/LC: Critical Level RL:Reporting Limit
MDA:Minimum Detectable Activity TPU:Total Propagated Uncertainty
MDC:Minimum Detectable Concentration
Page 36 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407-[phone] -www.gel.com
QC Summary
Koppers Utility and Industrial Products(KUIP) Renort Date:October 27,2022
Page 1 of 9
P.O.Box 1124
Orangeburg,South Carolina
Contact: Jane House
Workorder: 595762
Parmname NOM Sample Qual QC Units RPD/D% REC% Range Anlst Date Time
Metals Analysis-ICP
Batch 2325848
QC1205210129 LCS
Arsenic 500 506 ug/L 101 (80%-120%) LS 10/10/2210:24
Barium 500 503 ug/L 101 (80%-120%)
Cadmium 500 513 ug/L 103 (80%-120%)
Chromium 500 510 ug/L 102 (80%-120%)
Copper 500 502 ug/L 100 (80%-120%)
Lead 500 508 ug/L 102 (80%-120%)
Selenium 500 488 ug/L 97.6 (80%-120%)
Silver 100 100 ug/L 100 (80%-120%)
QC1205210130 LCSD
Arsenic 500 501 ug/L 1.15 100 (0%-20%) 10/10/2210:27
Barium 500 509 ug/L 1.01 102 (0%-20%)
Cadmium 500 519 ug/L 1.07 104 (0%-20%)
Chromium 500 522 ug/L 2.46 104 (0%-20%)
Copper 500 522 ug/L 3.89 104 (0%-20%)
Page 37 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407-[phone] -www.gel.com
QC Summary
Workorder: 595762 Page 2 of 9
Parmname NOM Sample Qual QC Units RPD/D% REC% Range Anlst Date Time
Metals Analysis-ICP
Batch 2325848
Lead 500 517 ug/L 1.75 103 (0%-20%) LS 10/10/2210:27
Selenium 500 517 ug/L 5.77 103 (0%-20%)
Silver 100 102 ug/L 1.98 102 (0%-20%)
QC1205210128 MB
Arsenic U ND ug/L 10/10/2210:21
Barium U ND ug/L
Cadmium J 1.03 ug/L
Chromium U ND ug/L
Copper U ND ug/L
Lead U ND ug/L
Selenium U ND ug/L
Silver U ND ug/L
QC1205210131 595762012 SDILT
Arsenic U ND U ND ug/L N/A (0%-20%) 10/10/2210:33
Barium U ND U ND ug/L N/A (0%-20%)
Cadmium U ND J 1.11 ug/L N/A (0%-20%)
Chromium U ND U ND ug/L N/A (0%-20%)
Page 38 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407-[phone] -www.gel.com
QC Summary
Workorder: 595762 Page 3 of 9
Parmname NOM Sample Qual QC Units RPD/D% REC% Range Anlst Date Time
Metals Analysis-ICP
Batch 2325848
Copper U ND U ND ug/L N/A (0%-20%) LS 10/10/2210:33
Lead U ND U ND ug/L N/A (0%-20%)
Selenium J 8.69 J 9.32 ug/L 436 (0%-20%)
Silver U ND U ND ug/L N/A (0%-20%)
Batch 2325850
QC1205210133 LCS
Arsenic 48.9 47.1 mg/kg 96.3 (80%-120%) TXT1 10/13/22 00:50
Barium 48.9 46.0 mg/kg 94 (80%-120%)
Cadmium 48.9 47.2 mg/kg 96.4 (80%-120%)
Chromium 48.9 47.1 mg/kg 96.3 (80%-120%)
Copper 48.9 47.1 mg/kg 96.3 (80%-120%)
Lead 48.9 46.4 mg/kg 94.8 (80%-120%)
Selenium 48.9 46.9 mg/kg 95.8 (80%-120%)
Silver 9.78 9.68 mg/kg 98.9 (80%-120%)
QC1205210132 MB
Arsenic U ND mg/kg 10/13/22 00:46
Barium U ND mg/kg
Page 39 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407-[phone] -www.gel.com
QC Summary
Workorder: 595762 Page 4 of 9
Parmname NOM Sample Qual QC Units RPD/D% REC% Range Anlst Date Time
Metals Analysis-ICP
Batch 2325850
Cadmium U ND mg/kg TXT1 10/13/22 00:46
Chromium U ND mg/kg
Copper 7 0.292 mg/kg
Lead 7 0.310 mg/kg
Selenium U ND mg/kg
Silver U ND mg/kg
QC1205210134 595762001 MS
Arsenic 45.4 117 135 mg/kg 38.1* (75%-125%) 10/13/22 00:56
Barium 45.4 1.11 45.5 mg/kg 97.7 (75%-125%)
Cadmium 45.4 U ND 44.4 mg/kg 97.7 (75%-125%)
Chromium 45.4 237 217 mg/kg N/A (75%-125%)
Copper 45.4 73.4 117 mg/kg 96.9 (75%-125%)
Lead 45.4 7 1.25 44.4 mg/kg 95 (75%-125%)
Selenium 45.4 U ND 45.9 mg/kg 100 (75%-125%)
Silver 9.08 U ND 9.11 mg/kg 100 (75%-125%)
QC1205210135 595762001 MSD
Arsenic 47.4 117 160 mg/kg 17.1 89.8 (0%-20%) 10/13/22 01:02
Page 40 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407-[phone] -www.gel.com
QC Summary
Workorder: 595762 Page 5 of 9
Parmname NOM Sample Qual QC Units RPD/D% REC% Range Anlst Date Time
Metals Analysis-ICP
Batch 2325850
Barium 47.4 1.11 42.7 mg/kg 6.28 87.8 (0%-20%) TXT1 10/13/22 01:02
Cadmium 47.4 U ND 46.9 mg/kg 5.33 98.8 (0%-20%)
Chromium 47.4 237 275 mg/kg 23.6* N/A (0%-20%)
Copper 47.4 73.4 118 mg/kg 0.445 94 (0%-20%)
Lead 47.4 J 1.25 45.3 mg/kg 2.04 93 (0%-20%)
Selenium 47.4 U ND 49.2 mg/kg 6.99 103 (0%-20%)
Silver 9.48 U ND 9.03 mg/kg 0.806 95.3 (0%-20%)
QC1205215884 595762001 PS
Arsenic 500 1210 1690 ug/L 96.3 (75%-125%) 10/13/22 01:02
QC1205210136 595762001 SDILT
Arsenic 1210 240 ug/L .688 (0%-20%) 10/13/22 01:05
Barium 11.4 J 2.05 ug/L 9.73 (0%-20%)
Cadmium U ND U ND ug/L N/A (0%-20%)
Chromium 2430 488 ug/L .214 (0%-20%)
Copper 754 150 ug/L .368 (0%-20%)
Lead 1 12.8 J 3.85 ug/L 49.9 (0%-20%)
Selenium U ND U ND ug/L N/A (0%-20%)
Page 41 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407-[phone] -www.gel.com
QC Summary
Workorder: 595762 Page 6 of 9
Parmname NOM Sample Qual QC Units RPD/D% REC% Range Anlst Date Time
Metals Analysis-ICP
Batch 2325850
Silver U ND U ND ug/L N/A (0%-20%) TXT1 10/13/22 01:05
Metals Analysis-Mercury
Batch 2328370
QC1205215622 594714001 DUP
Mercury U ND U ND ug/L N/A JP2 10/14/2211:20
QC1205215618 LCS
Mercury 2.00 2.10 ug/L 105 (80%-120%) 10/14/2210:59
QC1205215617 MB
Mercury U ND ug/L 10/14/2210:57
QC1205215623 594714001 MS
Mercury 2.00 U ND 2.21 ug/L 109 (75%-125%) 10/14/2211:21
QC1205215624 594714001 SDILT
Mercury U ND U ND ug/L N/A (0%-10%) 10/14/2211:23
Batch 2329118
QC1205217089 595762001 DUP
Mercury J 21.2 J 11.8 ug/kg 57 ^ (+/-23.2) JP2 10/17/22 09:26
QC1205217088 LCS
Mercury 240 247 ug/kg 103 (80%-120%) 10/17/22 09:19
QC1205217087 MB
Mercury U ND ug/kg 10/17/22 09:17
QC1205217090 595762001 MS
Mercury 236 J 21.2 254 ug/kg 98.9 (80%-120%) 10/17/22 09:27
Page 42 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407-[phone] -www.gel.com
QC Summary
Workorder: 595762 Page 7 of 9
Parmname NOM Sample Qual QC Units RPD/D% REC% Range Anlst Date Time
Metals Analysis-Mercury
Batch 2329118
QC1205217091 595762001 SDILT
Mercury J 0.186 U ND ug/L N/A (0%-10%) JP2 10/17/22 09:29
Semi-Volatiles-HERB
Batch 2325943
QC1205210337 LCS
Pentachlorophenol 2.00 1.78 ug/L 89 (51%-122%) YS1 10/10/2210:54
**2,4-Dichlorophenylacetic acid 5.00 5.45 ug/L 109 (46%-144%)
QC1205210336 MB
Pentachlorophenol U ND ug/L 10/10/2210:27
**2,4-Dichlorophenylacetic acid 5.00 4.66 ug/L 93 (46%-144%)
QC1205210338 595756016 MS
Pentachlorophenol 2.00 U ND 1.88 ug/L 94 (20%-142%) 10/10/2211:49
**2,4-Dichlorophenylacetic acid 5.00 5.03 5.45 ug/L 109 (46%-144%)
QC1205210339 595756016 MSD
Pentachlorophenol 2.00 U ND 1.91 ug/L 2 96 (0%-30%) 10/10/2212:16
**2,4-Dichlorophenylacetic acid 5.00 5.03 5.80 ug/L 116 (46%-144%)
Batch 2327654
QC1205214049 LCS
Pentachlorophenol 0.0400 0.0349 mg/kg 87 (58%-123%) LOF 10/18/22 13:03
**2,4-Dichlorophenylacetic acid 0.0999 0.101 mg/kg 101 (34%-149%)
QC1205214048 MB
Pentachlorophenol U ND mg/kg 10/18/2212:44
Page 43 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407-[phone] -www.gel.com
QC Summary
Workorder: 595762 Page 8 of 9
Parmname NOM Sample Qual QC Units RPD/D% REC% Range Anlst Date Time
Semi-Volatiles-HERB
Batch 2327654
**2,4-Dichlorophenylacetic acid 0.100 0.0811 mg/kg 81 (34%-149%) LOF 10/18/22 12:44
QC1205214050 596016001 MS
Pentachlorophenol 0.0463 U ND EP 0.103 mg/kg 224* (29%-129%) 10/18/22 14:17
**2,4-Dichlorophenylacetic acid 0.116 0.0843 0.102 mg/kg 88 (34%-149%)
QC1205214051 596016001 MSD
Pentachlorophenol 0.0465 U ND EP 0.108 mg/kg 4 231* (0%-30%) 10/18/22 14:36
**2,4-Dichlorophenylacetic acid 0.116 0.0843 0.105 mg/kg 90 (34%-149%)
Spectrometric Analysis
Batch 2327899
QC1205214562 595762001 DUP
Hexavalent Chromium U ND U ND mg/kg N/A VH1 10/27/22 14:39
QC1205214564 ILCS
Hexavalent Chromium 5.48 4.65 mg/kg 84.8 (80%-120%) 10/27/22 14:38
QC1205214561 LCS
Hexavalent Chromium 3.31 3.19 mg/kg 96.3 (80%-120%) 10/27/22 14:38
QC1205214560 MB
Hexavalent Chromium U ND mg/kg 10/27/22 14:38
QC1205214563 595762001 MS
Hexavalent Chromium 3.56 U ND 4.20 mg/kg 118 (75%-125%) 10/27/22 14:40
Notes:
The Qualifiers in this report are defined as follows:
** Analyte is a surrogate compound
< Result is less than value reported
Page 44 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407-[phone] -www.gel.com
QC Summary
Workorder: 595762 Page 9 of 9
Parmname NOM Sample Qual QC Units RPD/D% REC% Range Anlst Date Time
> Result is greater than value reported
A The TIC is a suspected aldol-condensation product
B The target analyte was detected in the associated blank.
C Analyte has been confirmed by GC/MS analysis
D Results are reported from a diluted aliquot of the sample
E %difference of sample and SD is>10%. Sample concentration must meet flagging criteria
E Concentration of the target analyte exceeds the instrument calibration range
FB Mercury was found present at quantifiable concentrations in field blanks received with these samples. Data associated with the blank are deemed
invalid for reporting to regulatory agencies
H Analytical holding time was exceeded
J See case narrative for an explanation
J Value is estimated
JNX Non Calibrated Compound
N Metals--The Matrix spike sample recovery is not within specified control limits
N Organics--Presumptive evidence based on mass spectral library search to make a tentative identification of the analyte(TIC). Quantitation is based
on nearest internal standard response factor
N Presumptive evidence based on mass spectral library search to make a tentative identification of the analyte(TIC). Quantitation is based on nearest
internal standard response factor
N/A RPD or%Recovery limits do not apply.
N1 See case narrative
ND Analyte concentration is not detected above the detection limit
NJ Consult Case Narrative,Data Summary package,or Project Manager concerning this qualifier
P Organics--The concentrations between the primary and confirmation columns/detectors is>40%different. For HPLC,the difference is>70%.
Q One or more quality control criteria have not been met.Refer to the applicable narrative or DER.
R Sample results are rejected
U Analyte was analyzed for,but not detected above the MDL,MDA,MDC or LOD.
UJ Compound cannot be extracted
X Consult Case Narrative,Data Summary package,or Project Manager concerning this qualifier
Y Other specific qualifiers were required to properly define the results.Consult case narrative.
Y QC Samples were not spiked with this compound
^ RPD of sample and duplicate evaluated using+/-RL. Concentrations are<5X the RL. Qualifier Not Applicable for Radiochemistry.
h Preparation or preservation holding time was exceeded
N/A indicates that spike recovery limits do not apply when sample concentration exceeds spike conc.by a factor of 4 or more or%RPD not applicable.
^The Relative Percent Difference(RPD)obtained from the sample duplicate (DUP)is evaluated against the acceptance criteria when the sample is greater than
five times(5X)the contract required detection limit(RL).In cases where the duplicate value is less than 5X the RL,a control limit of+/-the RL is used to
evaluate the DUP result.
*Indicates that a Quality Control parameter was not within specifications.
For PS,PSD,and SDILT results,the values listed are the measured amounts,not final concentrations.
Where the analytical method has been performed under NELAP certification,the analysis has met all of the
requirements of the NELAC standard unless qualified on the QC Summary.
Page 45 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
QC Summary
Client: Koppers Utility and Industrial Products(KUIP) Report Date:October 27,2022
P.O.Box 1124 Page 1 of 1
Orangeburg,South Carolina
Contact: Jane House
Workorder: 595762
Parmname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
Notes:
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
The Qualifiers in this report are defined as follows:
** Analyte is a Tracer compound
< Result is less than value reported
> Result is greater than value reported
BD Results are either below the MDC or tracer recovery is low
FA Failed analysis.
H Analytical holding time was exceeded
J See case narrative for an explanation
J Value is estimated
K Analyte present.Reported value may be biased high.Actual value is expected to be lower.
L Analyte present.Reported value may be biased low.Actual value is expected to be higher.
M M if above MDC and less than LLD
M REMP Result>MDC/CL and<RDL
N/A RPD or%Recovery limits do not apply.
Nl See case narrative
ND Analyte concentration is not detected above the detection limit
NJ Consult Case Narrative,Data Summary package,or Project Manager concerning this qualifier
Q One or more quality control criteria have not been met.Refer to the applicable narrative or DER.
R Sample results are rejected
U Analyte was analyzed for,but not detected above the MDL,MDA,MDC or LOD.
UI Gamma Spectroscopy--Uncertain identification
UJ Gamma Spectroscopy--Uncertain identification
UL Not considered detected.The associated number is the reported concentration,which may be inaccurate due to a low bias.
X Consult Case Narrative,Data Summary package,or Project Manager concerning this qualifier
Y Other specific qualifiers were required to properly define the results.Consult case narrative.
^ RPD of sample and duplicate evaluated using+/-RL. Concentrations are<5X the RL. Qualifier Not Applicable for Radiochemistry.
h Preparation or preservation holding time was exceeded
N/A indicates that spike recovery limits do not apply when sample concentration exceeds spike conc.by a factor of 4 or more or%RPD not applicable.
**Indicates analyte is a surrogate/tracer compound.
^The Relative Percent Difference(RPD)obtained from the sample duplicate (DUP)is evaluated against the acceptence criteria when the sample is greater than
five times(5X)the contract required detection limit(RL).In cases where either the sample or duplicate value is less than 5X the RL,a control limit of+/-the
RL is used to evaluate the DUP result.
For PS,PSD,and SDILT results,the values listed are the measured amounts,not final concentrations.
Where the analytical method has been performed under NELAP certification,the analysis has met all of the requirements of the NELAC
standard unless qualified on the QC Summary.
Page 46 of 58 SDG: 595762

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® Lakilall.t' ES_L
SAMPLE RECEIPT&REVIEW FORM
Client: S➢GIARICOCIWurk Order:
Received By:MUH Date Received:
Cinlc Appinahl,
dEx Expf�s FedEx Ground UPS Field Services Courier Other
Carrier and Tracking Number
Suspected Hazard Information °' Z° Net Counts>L00cpm on samples not marked"radioactive",contact the Radlati0n Safety Group fur huther investigation.
Y
Hazard Class Shipped: UN#:
A)Shid as a DOT Hazmtlous?
If UN2910,Is the Radioactive Shipment Survey Compliant?Yes_No_
B)Did the client designate the samples are to be COC notation or radioactive stickers on containers equal client designation.
received as radioactive? -:N, J,
Maximum Net Counts Observed*(Observed Counts-Area Background Counts): CPM I mR/Hr
0 Did the RSO classify the samples as Classified as: Rad I Rad 2 Rad 3
radioactive?
00,
COC notation or hazanrd labels on containers equal client designation.
D)Did the client designate sam les are hazardous?
off D or E is ycs,select Hazards below.
E)Did the RSO identifyossihle hazards? PCBs Flammable Foreign Soil RCRA Asbestos Beryllium Other:
Sample Receipt Criteria Z Z CommentslOualiCers(Required for Non-Conforming Items)
I Shipping containers received intact and Circle Applicable_ Seal harken Damaged container Leddageantainer other(describeq
scaled?
2
Chain of custody documents included Circle Applicable: Client contacted and provided COC COC created upon receipt
with shipment?
Preservation Meda : Wet Ice)Ice Packs Dry ice None Other:
3 Samples requiring cold preservation =;ill temperature vne rec ed in Celsius TEMP:
within(0<6 deg,CM
Daily check performed and passed on IR Temperature Device Serial#:IR2-21
4 temperature gun? Secondary Temperature Device Serial#(If Applicable):
Circle Applicable: SeaLc broken Damaged container Leaking container Other(describe)
5 Sample containers intact and sealed? /A
6
Samples requiring chemical preservation, Sample Us and Containers Aftccred:
at H?
proper P IF Presery bon added,Lurk:
If Yes,are Encores or Soil Kits present for solids?Yes_No NA_(If yes,take to VOA Freezer)
Do any samples require Volatile 'Do liquid VGA vials contain acid preservation?Yes_ No NA—(If unknown,select No)
7 Analysis? Are liquid VOA vials free of headspace?Yes_No_ NA_
Sample Ill's and containen alfccted:
TM and tests affected:
S Samples received within holding time'?
Sample ID's on COC match ID's on ID's and containers affected:
9 bottles?
Date&time on COC match date&time Circle Applicable: No dates on containers No times on containers COC missing info Other(describe)
1p on bottles?
Number of containers received match le Applicable: No container count on COC Other(descrihe
11 )
number indicated on COC? C.
Are sample containers identifiable as
12 GEL providcd by use of GEL labels? f
13 COC Form is properly signed in Circle A licable Nor relin9dished Other(describe)
relinquishedireceived sections?
Curnments(Use Continuation Form if needed):
PM(or PM A)review:Initials Date Page of
GL-CHL SR-001 Rev 7
Page 49 of 58 SDG: 595762

List of current GEL Certifications as of 27 October 2022
State Certification
Alabama 42200
Alaska 17018
Alaska Drinking Water SC00012
Arkansas 880651
CLIA 42DO904046
California 2940
Colorado SC00012
Connecticut PHO 169
DoD ELAP/ISO17025 A2LA 2567.01
Florida NELAP E87156
Foreign Soils Permit P330+500283,P330+500253
Georgia SC00012
Georgia SDWA 967
Hawaii SC00012
Idaho SC00012
Illinois NELAP 200029
Indiana CSC91
Kansas NELAP E+0332
Kentucky SDWA 90129
Kentucky Wastewater 90129
Louisiana Drinking Water LA024
Louisiana NELAP 03046(AI33904)
Maine 2019020
Maryland 270
Massachusetts MSCO12
Massachusetts PFAS Approv Letter
Michigan 9976
Mississippi SC00012
Nebraska NEOS26+3
Nevada SC0001220233-
New Hampshire NELAP 2054
New Jersey NELAP SCO02
New Mexico SC00012
New York NELAP 11501
North Carolina 233
North Carolina SDWA 45709
North Dakota R+58
Oklahoma 2022+60
Pennsylvania NELAP 6800485
Puerto Rico SC00012
S.Carolina Radiochem 10120002
Sanitation Districts of L 9255651
South Carolina Chemistry 10120001
Tennessee TN 02934
Texas NELAP T104704235222-0
Utah NELAP SC0001220213-6
Vermont VT87156
Virginia NELAP 460202
Washington C780
Page 50 of 58 SDG: 595762

Technical Case Narrative
KUIP Carolina Pole Leland
SDG#: 595762
GC Semivolatile Herbicide
Product:Analysis of Chlorophenoxy Acid Herbicides by ECD
Analytical Method: SW846 3535A/8151A
Analytical Procedure: GL-OA-E-011 REV#26
Analytical Batch: 2325943
Preparation Method: SW846 3535A
Preparation Procedure: GL-OA-E-079 REV#2
Preparation Batch:2325942
The following samples were analyzed using the above methods and analytical procedure(s).
GEL Sample ID# Client Sample Identification
595762012 SL BLANK
1205210336 Method Blank(MB)
1205210337 Laboratory Control Sample(LCS)
1205210338 595756016(NonSDG)Matrix Spike(MS)
1205210339 595756016(NonSDG)Matrix Spike Duplicate(MSD)
The samples in this SDG were analyzed on an"as received"basis.
Data Summary:
All sample data provided in this report met the acceptance criteria specified in the analytical methods and
procedures for initial calibration,continuing calibration,instrument controls and process controls where
applicable,with the following exceptions.
Miscellaneous Information
Manual Integrations
Sample 1205210336(MB)required manual integration to correctly position the baseline as set in the calibration
standard injections.
Product:Analysis of Chlorophenoxy Acid Herbicides by ECD
Analytical Method: SW846 8151A
Analytical Procedure: GL-OA-E-011 REV#26
Analytical Batch:2327654
Preparation Method: SW846 8151A
Preparation Procedure: GL-OA-E-027 REV# 18
Preparation Batch:2327652
The following samples were analyzed using the above methods and analytical procedure(s).
GEL Sample ID# Client Sample Identification
Page 51 of 58 SDG: 595762

595762001 TD-1
595762002 TD-2
595762003 TD-3
595762004 TD-4
595762005 TD-5
595762006 TD-6
595762007 TD-7D
595762008 SL1 2.9-4ft
595762009 SL1 4.5-5ft
595762010 SL2 3.9-5ft
595762011 SL2 2-3.9ft
1205214048 Method Blank(MB)
1205214049 Laboratory Control Sample(LCS)
1205214050 596016001(5-13E)Matrix Spike(MS)
1205214051 596016001(5-13E)Matrix Spike Duplicate(MSD)
The samples in this SDG were analyzed on a"dry weight"basis.
Data Summary:
All sample data provided in this report met the acceptance criteria specified in the analytical methods and
procedures for initial calibration,continuing calibration,instrument controls and process controls where
applicable,with the following exceptions.
Calibration Information
Continuing Calibration Verification(CCV)Requirements
The calibration verification standards(CCV)did not meet acceptance criteria.One or more target analytes failed
acceptance criteria with a positive bias on one or both analytical columns in the standards bracketing samples
and associated QC.The positive bias for the analytical data is a result of instrument response increasing after the
initial calibration.As there were no target analytes detected in the associated samples,the data were reported.All
analytes were within the established retention time windows for this method.
Quality Control(QQ Information
Surrogate Recoveries
Sample(See Below)did not meet surrogate recovery acceptance criteria.The sample was analyzed at a dilution.
As a result,the surrogate was diluted out of the acceptance criteria and the data were reported.
Sample Analyte Value
595762008(SL1 2.9-4ft) 2,4-Dichlorophenylacetic acid 0* (34%-149%)
Spike Recovery Statement
The MS and/or MSD(See Below)did not meet spike recovery acceptance limits. Since there were no target
analytes detected in the parent sample above the reporting limits,the biased high recoveries had no adverse
impact on the reported data.
Sample Analyte Value
1205214050(5-13EMS) Pentachlorophenol 224*(29%-129%)
1205214051 (5-13EMSD) Pentachlorophenol 231* (29%-129%)
Page 52 of 58 SDG: 595762

Technical Information
Sample Dilutions
Samples 595762001 (TD-1),595762002(TD-2),595762003 (TD-3),595762005 (TD-5),595762008(SL1
2.9-4ft),595762010(SL2 3.9-5ft)and 595762011 (SL2 2-3.9ft)were diluted due to target analyte concentrations
exceeding the calibration range. Sample 595762011 (SL2 2-3.9ft)was analyzed at a dilution due to the extract
being very dirty and cloudy.
Sample Re-extraction/Re-analysis
Samples 595762001 (TD-1),595762002(TD-2),595762003 (TD-3),595762004(TD-4),595762005(TD-5),
595762006(TD-6),595762007(TD-7D),595762008(SL1 2.9-4ft),595762009(SL1 4.5-5ft),595762010(SL2
3.9-5ft)and 595762011 (SL2 2-3.9ft)were re-analyzed due to failing bracketing CCV.The re-analyzed data
were reported.
Miscellaneous Information
Manual Integrations
Samples 1205214048(MB), 1205214049(LCS), 1205214050(5-13EMS)and 1205214051 (5-13EMSD)
required manual integration to correctly position the baseline as set in the calibration standard injections.
Metals
Product: Determination of Metals by ICP
Analytical Method: SW846 3005A/6010D
Analytical Procedure: GL-MA-E-013 REV#32
Analytical Batch:2325848
Preparation Method: SW846 3005A
Preparation Procedure: GL-MA-E-006 REV# 14
Preparation Batch:2325847
The following samples were analyzed using the above methods and analytical procedure(s).
GEL Sample ID# Client Sample Identification
595762012 SL BLANK
1205210128 Method Blank(MB)ICP
1205210129 Laboratory Control Sample(LCS)
1205210130 Laboratory Control Sample Duplicate(LCSD)
1205210131 595762012(SL BLANKL)Serial Dilution(SD)
The samples in this SDG were analyzed on an"as received"basis.
Data Summary
All sample data provided in this report met the acceptance criteria specified in the analytical methods and
procedures for initial calibration,continuing calibration,instrument controls and process controls where
applicable,with the following exceptions.
Quality Control(QC)Information
Laboratory Control Sample Duplicate(LCSD)
Page 53 of 58 SDG: 595762

An LCSD was used in place of matrix QC due to the designation of field QC.
Product: Determination of Metals by ICP
Analytical Method: SW846 3050B/6010D
Analytical Procedure: GL-MA-E-013 REV#32
Analytical Batch: 2325850
Preparation Method: SW846 3050B
Preparation Procedure: GL-MA-E-009 REV#29
Preparation Batch:2325849
The following samples were analyzed using the above methods and analytical procedure(s).
GEL Sample ID# Client Sample Identification
595762001 TD-1
595762002 TD-2
595762003 TD-3
595762004 TD-4
595762005 TD-5
595762006 TD-6
595762007 TD-7D
595762008 SL1 2.9-4ft
595762009 SL1 4.5-5ft
595762010 SL2 3.9-5ft
1205210132 Method Blank(MB)ICP
1205210133 Laboratory Control Sample(LCS)
1205210136 595762001(TD-lL) Serial Dilution(SD)
1205210134 595762001(TD-1S)Matrix Spike(MS)
1205210135 595762001(TD-1SD)Matrix Spike Duplicate(MSD)
1205215884 595762001(TD-1PS)Post Spike(PS)
The samples in this SDG were analyzed on a"dry weight"basis.
Data Summary
All sample data provided in this report met the acceptance criteria specified in the analytical methods and
procedures for initial calibration,continuing calibration,instrument controls and process controls where
applicable,with the following exceptions.
Quality Control(QQ Information
Matrix Spike(MS/MSD)Recovery Statement
The percent recoveries(%R)obtained from the MS/MSD analyses are evaluated when the sample concentration
is less than four times(4X)the spike concentration added. The MS/MSD(See Below)did not meet the
recommended quality control acceptance criteria for percent recoveries for the following applicable analyte.The
post spike recovery was within the required control limits.This verifies the absence of a matrix interference in
the post-spike digested sample. The recovery may be attributed to possible sample matrix interference and/or
non-homogeneity.
Sample Analyte Value
1205210134(TD-1MS) Arsenic 38.1* (75%-125%)
Page 54 of 58 SDG: 595762

MS/MSD Relative Percent Difference(RPD)Statement
The RPD values between qualifying analyte results in the MS and MSD were not within the acceptance limits.
Sample non-homogeneity and/or possible matrix interferences may be suspected.
Sample Analyte Value
1205210134MS and 1205210135MSD(TD-1) Chromium RPD 23.6* (0%-20%)
Technical Information
Preparation/Analytical Method Verification
Method SW-846 3050B is not a total digestion technique for most samples.It is a very strong acid digestion that
will dissolve almost all elements that could become environmentally available.By design,elements bound in
silicate structures are not normally dissolved by this procedure as they are not usually mobile in the environment.
Sample Dilutions
Dilutions may be required for many reasons,including to minimize matrix interferences or to bring over range
target analyte concentrations into the linear calibration range. Sample was diluted in order to bring raw values
within the linear range of the instrument for calcium,and for the analytes interfered with,in order to ensure that
the inter-element correction factors were valid. 595762005(TD-5).
595762
Analyte
005
Chromium 5X
Silver 5X
Product: Mercury Analysis Using the Perkin Elmer Automated Mercury Analyzer
Analvtical Method: SW846 7470A
Analvtical Procedure: GL-MA-E-010 REV#38
Analvtical Batch: 2328370
Preparation Method: SW846 7470A Prep
Preparation Procedure: GL-MA-E-010 REV#38
Preparation Batch:2328363
The following samples were analyzed using the above methods and analytical procedure(s).
GEL Sample ID# Client Sample Identification
595762012 SL BLANK
1205215617 Method Blank(MB)CVAA
1205215618 Laboratory Control Sample(LCS)
1205215624 594714001(NonSDGL)Serial Dilution(SD)
1205215622 594714001(NonSDGD)Sample Duplicate(DUP)
1205215623 594714001(NonSDGS)Matrix Spike(MS)
The samples in this SDG were analyzed on an"as received"basis.
Page 55 of 58 SDG: 595762

Data Summary
There are no exceptions,anomalies or deviations from the specified methods.All sample data provided in this
report met the acceptance criteria specified in the analytical methods and procedures for initial calibration,
continuing calibration,instrument controls and process controls where applicable.
Product: Mercury Analysis Using the Perkin Elmer Automated Mercury Analyzer
Analytical Method: SW846 7471B
Analytical Procedure: GL-MA-E-010 REV#38
Analytical Batch: 2329118
Preparation Method: SW846 7471B Prep
Preparation Procedure: GL-MA-E-010 REV#38
Preparation Batch:2329110
The following samples were analyzed using the above methods and analytical procedure(s).
GEL Sample ID# Client Sample Identification
595762001 TD-1
595762002 TD-2
595762003 TD-3
595762004 TD-4
595762005 TD-5
595762006 TD-6
595762007 TD-7D
595762008 SL1 2.9-4ft
595762009 SL1 4.5-5ft
595762010 SL2 3.9-5ft
1205217087 Method Blank(MB)CVAA
1205217088 Laboratory Control Sample(LCS)
1205217091 595762001(TD-1L) Serial Dilution(SD)
1205217089 595762001(TD-1D)Sample Duplicate(DUP)
1205217090 595762001(TD-IS)Matrix Spike(MS)
The samples in this SDG were analyzed on a"dry weight"basis.
Data Summary
There are no exceptions,anomalies or deviations from the specified methods.All sample data provided in this
report met the acceptance criteria specified in the analytical methods and procedures for initial calibration,
continuing calibration,instrument controls and process controls where applicable.
General Chemistry
Product: Hexavalent Chromium
Analytical Method: SW846 7196A
Analytical Procedure: GL-GC-E-044 REV#23
Analytical Batch: 2327899
Page 56 of 58 SDG: 595762

Preparation Method: SW846 3060A
Preparation Procedure: GL-GC-E-044 REV#23
Preparation Batch:2327898
The following samples were analyzed using the above methods and analytical procedure(s).
GEL Sample ID# Client Sample Identification
595762001 TD-1
595762002 TD-2
595762003 TD-3
595762004 TD-4
595762005 TD-5
595762006 TD-6
595762007 TD-71)
595762008 SU 2.9-4ft
595762009 SU 4.5-5ft
595762010 SL2 3.9-5ft
1205214560 Method Blank(MB)
1205214561 Laboratory Control Sample(LCS)
1205214562 595762001(TD-1)Sample Duplicate(DUP)
1205214563 595762001(TD-1)Matrix Spike(MS)
1205214564 Insoluble Lab Control Sample(ILCS)
The samples in this SDG were analyzed on a"dry weight"basis.
Data Summary
There are no exceptions,anomalies or deviations from the specified methods.All sample data provided in this
report met the acceptance criteria specified in the analytical methods and procedures for initial calibration,
continuing calibration,instrument controls and process controls where applicable.
Radiochemistry
Product: Dry Weight
Preparation Method:ASTM D 2216(Modified)
Preparation Procedure: GL-OA-E-020 REV# 13
Preparation Batch:2326049
The following samples were analyzed using the above methods and analytical procedure(s).
GEL Sample ID# Client Sample Identification
595762001 TD-1
595762002 TD-2
595762003 TD-3
595762004 TD-4
595762005 TD-5
595762006 TD-6
595762007 TD-7D
595762008 SL1 2.9-4ft
595762009 SL1 4.5-5ft
595762010 SL2 3.9-5ft
595762011 SL2 2-3.9ft
1205210578 595809001(NonSDG)Sample Duplicate(DUP)
Page 57 of 58 SDG: 595762

The samples in this SDG were analyzed on an"as received"basis.
Data Summary:
There are no exceptions,anomalies or deviations from the specified methods.All sample data provided in this
report met the acceptance criteria specified in the analytical methods and procedures for initial calibration,
continuing calibration,instrument controls and process controls where applicable.
Certification Statement
Where the analytical method has been performed under NELAP certification,the analysis has met all of the
requirements of the NELAC standard unless otherwise noted in the analytical case narrative.
Page 58 of 58 SDG: 595762

® LaboratorieS LLc
PU Box N712 Charleston_SC 29417
a member of The GEL Group ivc 2040 Savage Road Chad"on.8C 2N07
P 843.556.8171
F 843.766.1178
gel.com
October 28,2022
Jane House
Koppers Utility and Industrial Products(KUIP)
P. O.Box 1124
Orangeburg, South Carolina 29116
Re: Soil RCRA
Work Order: 596016
Dear Jane House:
GEL Laboratories,LLC(GEL)appreciates the opportunity to provide the enclosed analytical results for the
sample(s)we received on October 07,2022.This original data report has been prepared and reviewed in
accordance with GEL's standard operating procedures.
Test results for NELAP or ISO 17025 accredited tests are verified to meet the requirements of those standards,
with any exceptions noted. The results reported relate only to the items tested and to the sample as received by
the laboratory.These results may not be reproduced except as full reports without approval by the laboratory.
Copies of GEL's accreditations and certifications can be found on our website at www.gel.com.
Our policy is to provide high quality,personalized analytical services to enable you to meet your analytical needs
on time every time.We trust that you will find everything in order and to your satisfaction.If you have any
questions,please do not hesitate to call me at(843)556-8171,ext. 1648.
Sincerely,
Tn"� tia"
Meredith Boddiford
Project Manager
Purchase Order:TBD
Enclosures
Page 1 of 17 SDG: 596016

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407 - [phone] -www.gel.com
Certificate of Analysis Report
for
KURI001 KUIP Carolina Pole Leland
Client SDG: 596016 GEL Work Order: 596016
The Qualifiers in this report are defined as follows:
* A quality control analyte recovery is outside of specified acceptance criteria
** Analyte is a Tracer compound
** Analyte is a surrogate compound
E Concentration of the target analyte exceeds the instrument calibration range
J See case narrative for an explanation
J Value is estimated
P OrganicsThe concentrations between the primary and confirmation columns/detectors is>40%different. For
HPLC,the difference is>70%.
U Analyte was analyzed for,but not detected above the MDL,MDA,MDC or LOD.
Where the analytical method has been performed under NELAP certification,the analysis has met all of the
requirements of the NELAC standard unless qualified on the Certificate of Analysis.
The designation ND,if present,appears in the result column when the analyte concentration is not detected above
the limit as defined in the 'U' qualifier above.
This data report has been prepared and reviewed in accordance with GEL Laboratories LLC
standard operating procedures.Please direct any questions to your Project Manager,Meredith Boddiford.
wLt't'� sr&"
Reviewed by
Page 2 of 17 SDG: 596016

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 28,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: 5-13E Project: KURIO0122
Sample ID: 596016001 Client ID: KURI001
Matrix: Soil
Collect Date: 04-OCT-22 15:50
Receive Date: 07-OCT-22
Collector: Client
Moisture: 14.2%
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Metals Analysis-ICP
SW846 305013/60101)Metals, Solid"Dry Weight Corrected"
Arsenic 82.3 0.489 2.93 mg/kg 83.9 1 LS 10/12/22 1047 2326600 1
Semi-Volatiles-HERB
SW846 8151A Herbicides,Solid"Dry Weight Corrected"
Pentachlorophenol U ND 0.00192 0.00578 mg/kg 0.198 1 LOF 10/18/22 1359 2327654 2
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 3050B SW846 3050B Prep CD3 10/11/22 1650 2326599
SW846 8151A 8151A Herbicides Prep in Soil Si 10/14/22 0754 2327652
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 3050B/6010D
2 SW846 8151A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW846 8151A Herbicides,Solid"Dry Weight 0.0843 mg/kg 0.116 73 (34%-149%)
Corrected"
Notes:
Column headers are defined as follows:
DF: Dilution Factor Lc/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 3 of 17 SDG: 596016

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 28,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: 5-14W Project: KURIO0122
Sample ID: 596016002 Client ID: KURI001
Matrix: Soil
Collect Date: 04-OCT-22 15:15
Receive Date: 07-OCT-22
Collector: Client
Moisture: 7.27%
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Metals Analysis-ICP
SW846 305013/60101)Metals, Solid"Dry Weight Corrected"
Arsenic 19.4 0.481 2.88 mg/kg 89.1 1 LS 10/12/22 1057 2326600 1
Semi-Volatiles-HERB
SW846 8151A Herbicides,Solid"Dry Weight Corrected"
Pentachlorophenol J 0.00344 0.00178 0.00537 mg/kg 0.199 1 YS1 10/19/22 1218 2327654 3
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 3050B SW846 3050B Prep CD3 10/11/22 1650 2326599
SW846 8151A 8151A Herbicides Prep in Soil Si 10/14/22 0754 2327652
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 3050B/6010D
2 SW846 8151A
3 SW846 8151A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW846 8151A Herbicides,Solid"Dry Weight 0.0904 mg/kg 0.107 84 (34%-149%)
Corrected"
Notes:
Column headers are defined as follows:
DF: Dilution Factor Lc/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 4 of 17 SDG: 596016

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Company: Koppers Utility and Industrial
Address : Products(KUIP)
P.O.Box 1124
Orangeburg,South Carolina 29116 Report Date: October 28,2022
Contact: Jane House
Project: Soil RCRA
Client Sample ID: 5-13E Project: KURI00122
Sample ID: 596016001 Client ID: KURI001
Matrix: Soil
Collect Date: 04-OCT-22
Receive Date: 07-OCT-22
Collector: Client
Moisture: 14.2%
Parameter Qualifier Result Uncertainty MDC TPU RL Units PIT DF Analyst Date Time Batch Mtd.
Gravimetric Solids
"As Received"
The following Analytical Methods were performed
Method Description
1 ASTM D 2216(Modified)
Surrogate/Tracer Recovery Test Batch ID Recovery% Acceptable Limits
Notes:
The MDC is a sample specific MDC.
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
Column headers are defined as follows:
DF:Dilution Factor Mtd.:Method
DL:Detection Limit PF:Prep Factor
Lc/LC: Critical Level RL:Reporting Limit
MDA:Minimum Detectable Activity TPU:Total Propagated Uncertainty
MDC:Minimum Detectable Concentration
Page 5 of 17 SDG: 596016

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Company: Koppers Utility and Industrial
Address : Products(KUIP)
P.O.Box 1124
Orangeburg,South Carolina 29116 Report Date: October 28,2022
Contact: Jane House
Project: Soil RCRA
Client Sample ID: 5-14W Project: KURIO0122
Sample ID: 596016002 Client ID: KURI001
Matrix: Soil
Collect Date: 04-OCT-22
Receive Date: 07-OCT-22
Collector: Client
Moisture: 7.27%
Parameter Qualifier Result Uncertainty MDC TPU RL Units PF DF Analyst Date Time Batch Mtd.
Gravimetric Solids
'As Received"
The following Analytical Methods were performed
Method Description
1 ASTM D 2216(Modified)
Surrogate/Tracer Recovery Test Batch ID Recovery% Acceptable Limits
Notes:
The MDC is a sample specific MDC.
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
Column headers are defined as follows:
DF:Dilution Factor Mtd.:Method
DL:Detection Limit PF: Prep Factor
Lc/LC: Critical Level RL:Reporting Limit
MDA:Minimum Detectable Activity TPU:Total Propagated Uncertainty
MDC: Minimum Detectable Concentration
Page 6 of 17 SDG: 596016

GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407-[phone] -www.gel.com
QC Summary
Koppers Utility and Industrial Products(KUIP) Renort Date:October 28,2022
Page 1 of 3
P.O.Box 1124
Orangeburg,South Carolina
Contact: Jane House
Workorder: 596016
Parmname NOM Sample Qual QC Units RPD/D% REC% Range Anlst Date Time
Metals Analysis-ICP
Batch 2326600
QC1205211685 LCS
Arsenic 42.2 39.5 mg/kg 93.6 (80%-120%) LS 10/12/2210:44
QC1205211684 MB
Arsenic U ND mg/kg 10/12/2210:40
QC1205211686 596016001 MS
Arsenic 53.4 82.3 85.5 mg/kg 6.1* (75%-125%) 10/12/22 10:50
QC1205211687 596016001 MSD
Arsenic 50.9 82.3 103 mg/kg 18.8 41.3* (0%-20%) 10/12/22 10:52
QC1205216169 596016001 PS
Arsenic 500 842 1430 ug/L 118 (75%-125%) 10/13/22 13:31
QC1205211688 596016001 SDILT
Arsenic 842 167 ug/L .589 (0%-20%) 10/12/2210:54
Semi-Volatiles-HERB
Batch 2327654
QC1205214049 LCS
Pentachlorophenol 0.0400 0.0349 mg/kg 87 (58%-123%) LOF 10/18/22 13:03
**2,4-Dichlorophenylacetic acid 0.0999 0.101 mg/kg 101 (34%-149%)
QC1205214048 MB
Pentachlorophenol U ND mg/kg 10/18/2212:44
**2,4-Dichlorophenylacetic acid 0.100 0.0811 mg/kg 81 (34%-149%)
Page 7 of 17 SDG: 596016

GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407-[phone] -www.gel.com
QC Summary
Workorder: 596016 Page 2 of 3
Parmname NOM Sample Qual QC Units RPD/D% REC% Range Anlst Date Time
Semi-Volatiles-HERB
Batch 2327654
QC1205214050 596016001 MS
Pentachlorophenol 0.0463 U ND EP 0.103 mg/kg 224* (29%-129%) LOF 10/18/2214:17
**2,4-Dichlorophenylacetic acid 0.116 0.0843 0.102 mg/kg 88 (34%-149%)
QC1205214051 596016001 MSD
Pentachlorophenol 0.0465 U ND EP 0.108 mg/kg 4 231* (0%-30%) 10/18/22 14:36
**2,4-Dichlorophenylacetic acid 0.116 0.0843 0.105 mg/kg 90 (34%-149%)
Notes:
The Qualifiers in this report are defined as follows:
** Analyte is a surrogate compound
< Result is less than value reported
> Result is greater than value reported
A The TIC is a suspected aldol-condensation product
B The target analyte was detected in the associated blank.
C Analyte has been confirmed by GUMS analysis
D Results are reported from a diluted aliquot of the sample
E %difference of sample and SD is>10%. Sample concentration must meet flagging criteria
E Concentration of the target analyte exceeds the instrument calibration range
FB Mercury was found present at quantifiable concentrations in field blanks received with these samples. Data associated with the blank are deemed
invalid for reporting to regulatory agencies
H Analytical holding time was exceeded
J See case narrative for an explanation
J Value is estimated
JNX Non Calibrated Compound
N Metals--The Matrix spike sample recovery is not within specified control limits
N Organics--Presumptive evidence based on mass spectral library search to make a tentative identification of the analyte(TIC). Quantitation is based
on nearest internal standard response factor
N Presumptive evidence based on mass spectral library search to make a tentative identification of the analyte(TIC). Quantitation is based on nearest
internal standard response factor
N/A RPD or%Recovery limits do not apply.
N1 See case narrative
ND Analyte concentration is not detected above the detection limit
NJ Consult Case Narrative,Data Summary package,or Project Manager concerning this qualifier
Page 8 of 17 SDG: 596016

GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407-[phone] -www.gel.com
QC Summary
Workorder: 596016 Page 3 of 3
Parmname NOM Sample Qual QC Units RPD/D% REC% Range Anlst Date Time
P Organics--The concentrations between the primary and confirmation columns/detectors is>40%different. For HPLC,the difference is>70%.
Q One or more quality control criteria have not been met.Refer to the applicable narrative or DER.
R Sample results are rejected
U Analyte was analyzed for,but not detected above the MDL,MDA,MDC or LOD.
UJ Compound cannot be extracted
X Consult Case Narrative,Data Summary package,or Project Manager concerning this qualifier
Y Other specific qualifiers were required to properly define the results.Consult case narrative.
Y QC Samples were not spiked with this compound
^ RPD of sample and duplicate evaluated using+/-RL. Concentrations are<5X the RL. Qualifier Not Applicable for Radiochemistry.
h Preparation or preservation holding time was exceeded
N/A indicates that spike recovery limits do not apply when sample concentration exceeds spike conc.by a factor of 4 or more or%RPD not applicable.
The Relative Percent Difference(RPD)obtained from the sample duplicate (DUP)is evaluated against the acceptance criteria when the sample is greater than
five times(5X)the contract required detection limit(RL).In cases where the duplicate value is less than 5X the RL,a control limit of+/-the RL is used to
evaluate the DUP result.
*Indicates that a Quality Control parameter was not within specifications.
For PS,PSD,and SDILT results,the values listed are the measured amounts,not final concentrations.
Where the analytical method has been performed under NELAP certification,the analysis has met all of the
requirements of the NELAC standard unless qualified on the QC Summary.
Page 9 of 17 SDG: 596016

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
QC Summary
Client: Koppers Utility and Industrial Products(KUIP) Report Date:October 28,2022
P.O.Box 1124 Page 1 of 1
Orangeburg,South Carolina
Contact: Jane House
Workorder: 596016
Parmname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
Notes:
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
The Qualifiers in this report are defined as follows:
** Analyte is a Tracer compound
< Result is less than value reported
> Result is greater than value reported
BD Results are either below the MDC or tracer recovery is low
FA Failed analysis.
H Analytical holding time was exceeded
J See case narrative for an explanation
J Value is estimated
K Analyte present.Reported value may be biased high.Actual value is expected to be lower.
L Analyte present.Reported value may be biased low.Actual value is expected to be higher.
M M if above MDC and less than LLD
M REMP Result>MDC/CL and<RDL
N/A RPD or%Recovery limits do not apply.
Nl See case narrative
ND Analyte concentration is not detected above the detection limit
NJ Consult Case Narrative,Data Summary package,or Project Manager concerning this qualifier
Q One or more quality control criteria have not been met.Refer to the applicable narrative or DER.
R Sample results are rejected
U Analyte was analyzed for,but not detected above the MDL,MDA,MDC or LOD.
UI Gamma Spectroscopy--Uncertain identification
UJ Gamma Spectroscopy--Uncertain identification
UL Not considered detected.The associated number is the reported concentration,which may be inaccurate due to a low bias.
X Consult Case Narrative,Data Summary package,or Project Manager concerning this qualifier
Y Other specific qualifiers were required to properly define the results.Consult case narrative.
^ RPD of sample and duplicate evaluated using+/-RL. Concentrations are<5X the RL. Qualifier Not Applicable for Radiochemistry.
h Preparation or preservation holding time was exceeded
N/A indicates that spike recovery limits do not apply when sample concentration exceeds spike conc.by a factor of 4 or more or%RPD not applicable.
**Indicates analyte is a surrogate/tracer compound.
^The Relative Percent Difference(RPD)obtained from the sample duplicate (DUP)is evaluated against the acceptence criteria when the sample is greater than
five times(5X)the contract required detection limit(RL).In cases where either the sample or duplicate value is less than 5X the RL,a control limit of+/-the
RL is used to evaluate the DUP result.
For PS,PSD,and SDILT results,the values listed are the measured amounts,not final concentrations.
Where the analytical method has been performed under NELAP certification,the analysis has met all of the requirements of the NELAC
standard unless qualified on the QC Summary.
Page 10 of 17 SDG: 596016

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Laboratories E..(..c
SAMPLE RECEIPT&REVIEW FORM
Client. SDGIARICOCIWork Older: 4LP
Received>3 ;Thyasia Tatum Date Received: I6 +
Cin;lc Applirnhlc:
1 edSx Expres. FedEx Ground UPS Field Services Courier Other
Carrier and Tracidng Number
Suspected Hazard information Z *If Net Counts>10(}cpm on samples not m IAMI"radionetive",contact the Radiation Safety Omup for fiinher investigation.
azartl Class Shipped: UN#:
A)Shied as a DOT Hazurxlous?
If p y es UN2910,Is the Radioactive Shipment Survey Compleant?Y No
8)Did the client designate the samples r e to be COC notation ornrlluactive clickers on containers equal-chum&stioati"
received as radioactive?
C)Did the RSO classify the samples as Maximum Net Counts Observed`(Observed Counts-Area Background Counts): CPM 1 mR/Hr
radioactive? Clnssilled as: Rod 1 Rod 2 Rod 3
,QG no4atroo or hazard labels on contariicis equal clicnt'desr auon
D)Did the client designate samples are hazardous?
YD or E is yes,select Hazards below.
B)Did the R50 identify possible hazards? PCBs Flammable Foreign Soil RCRA Asbestos Beryllium Other:
Sample Receipt Criteria ° ContmentslQualifiers(Requir(d for Non-Conforming Items)
1 Shipping containers received intact and Cinde Applicable: Seats broken Danmged container Leaking container Other(describe)
scaled?
2 Chain of custody documents included Circle Applicable; Client [acted and provided COC COC created upon receipt
with shipment?
preservation tvlethod: Wet Ic• Ice Packs Dry ice None Other:
3 Samples requiring cold preservation *all temperatures ortled in Celsius TEMP:
within(0<6 deg.C)?*
Daily check performed and passed on IIZ Temperature Device Serial#:1R2-2a
4 temperature gun? Secondary Temperature Device Serial S(if Applicable):
Circle Applicabte: Seats hroken Damaged container lxuking container Other(describe)
S Sample containers intact and sealed?
6
Samples requiring chemical preservation Sample IDs and Containers Affected:
at proper pH?
If P .ervntion added,Lot#:
es,are Encores or Soil Kits present for solids?Yes Nc NA (if yes,take to VOA Freezer)
Do any samples require Volatile Do liquid VOA vials contain acid preservation?Yes No— NA_(ff unknown,select No)
7 Analysis? Am liquid VOA vials fine of headspace?Yes No NA_
Sample ID's and containers alfacled:
ID's and tests affected:
8 Samples received within holding time?
Sample ID's on COC match ID's on ID's and containers affected!
9 bottles?
ltl Date&time on COC match date&(inre Circle Applicable: No dales on containers No times oil containers COC missing into Other(describe)
on battles?
11 Number of containers received match Circle Applicable: No container count on COC Other(descdbe)
number indicated on COC?
Are sample containers identifiable as
12 GEL provided b use of GFL labels?
13 COC form is properly signed in Circle Applicable: Not relinquished Other(describe)
relinquislredlreceived sections?
Comments(Use Continuation Fumy if needed):
Ptvl(or PtNA)review:Initials Date]RW, Page�of
GL-CHL-SR-001 Rev 7
Page 13 of 17 SDG: 596016

List of current GEL Certifications as of 28 October 2022
State Certification
Alabama 42200
Alaska 17018
Alaska Drinking Water SC00012
Arkansas 880651
CLIA 42DO904046
California 2940
Colorado SC00012
Connecticut PHO 169
DoD ELAP/ISO17025 A2LA 2567.01
Florida NELAP E87156
Foreign Soils Permit P330+500283,P330+500253
Georgia SC00012
Georgia SDWA 967
Hawaii SC00012
Idaho SC00012
Illinois NELAP 200029
Indiana CSC91
Kansas NELAP E+0332
Kentucky SDWA 90129
Kentucky Wastewater 90129
Louisiana Drinking Water LA024
Louisiana NELAP 03046(AI33904)
Maine 2019020
Maryland 270
Massachusetts MSCO12
Massachusetts PFAS Approv Letter
Michigan 9976
Mississippi SC00012
Nebraska NEOS26+3
Nevada SC0001220233-
New Hampshire NELAP 2054
New Jersey NELAP SCO02
New Mexico SC00012
New York NELAP 11501
North Carolina 233
North Carolina SDWA 45709
North Dakota R+58
Oklahoma 2022+60
Pennsylvania NELAP 6800485
Puerto Rico SC00012
S.Carolina Radiochem 10120002
Sanitation Districts of L 9255651
South Carolina Chemistry 10120001
Tennessee TN 02934
Texas NELAP T104704235222-0
Utah NELAP SC0001220213-6
Vermont VT87156
Virginia NELAP 460202
Washington C780
Page 14 of 17 SDG: 596016

Technical Case Narrative
KUIP Carolina Pole Leland
SDG#: 596016
GC Semivolatile Herbicide
Product:Analysis of Chlorophenoxy Acid Herbicides by ECD
Analytical Method: SW846 8151A
Analytical Procedure: GL-OA-E-011 REV#26
Analytical Batch: 2327654
Preparation Method: SW846 8151A
Preparation Procedure: GL-OA-E-027 REV# 18
Preparation Batch:2327652
The following samples were analyzed using the above methods and analytical procedure(s).
GEL Sample ID# Client Sample Identification
596016001 5-13E
596016002 5-14W
1205214048 Method Blank(MB)
1205214049 Laboratory Control Sample(LCS)
1205214050 596016001(5-13E)Matrix Spike(MS)
1205214051 596016001(5-13E)Matrix Spike Duplicate(MSD)
The samples in this SDG were analyzed on a"dry weight"basis.
Data Summary:
All sample data provided in this report met the acceptance criteria specified in the analytical methods and
procedures for initial calibration,continuing calibration,instrument controls and process controls where
applicable,with the following exceptions.
Calibration Information
Continuing Calibration Verification(CCV)Requirements
The calibration verification standards(CCV)did not meet acceptance criteria.One or more target analytes failed
acceptance criteria with a positive bias on one or both analytical columns in the standards bracketing samples
and associated QC.The positive bias for the analytical data is a result of instrument response increasing after the
initial calibration.As there were no target analytes detected in the associated samples,the data were reported.All
analytes were within the established retention time windows for this method.
Quality Control(QQ Information
Spike Recovery Statement
The MS and/or MSD(See Below)did not meet spike recovery acceptance limits. Since there were no target
analytes detected in the parent sample above the reporting limits,the biased high recoveries had no adverse
impact on the reported data.
Sample Analyte Value
Page 15 of 17 SDG: 596016

1205214050(5-13EMS) Pentachlorophenol 224* (29%-129%)
1205214051 (5-13EMSD) Pentachlorophenol 231* (29%-129%)
Technical Information
Sample Re-extraction/Re-analysis
Sample 596016002(5-14W)was re-analyzed due to failing bracketing CCV. The re-analyzed data were
reported.
Miscellaneous Information
Manual Integrations
Samples 1205214048(MB), 1205214049(LCS), 1205214050(5-13EMS), 1205214051 (5-13EMSD)and
596016001 (5-13E)required manual integration to correctly position the baseline as set in the calibration
standard injections.
Metals
Product: Determination of Metals by ICP
Analytical Method: SW846 3050B/6010D
Analytical Procedure: GL-MA-E-013 REV#32
Analytical Batch: 2326600
Preparation Method: SW846 3050B
Preparation Procedure: GL-MA-E-009 REV#29
Preparation Batch:2326599
The following samples were analyzed using the above methods and analytical procedure(s).
GEL Sample ID# Client Sample Identification
596016001 5-13E
596016002 5-14W
1205211684 Method Blank(MB)ICP
1205211685 Laboratory Control Sample(LCS)
1205211688 596016001(5-13EL)Serial Dilution(SD)
1205211686 596016001(5-13ES)Matrix Spike(MS)
1205211687 596016001(5-13ESD)Matrix Spike Duplicate(MSD)
1205216169 596016001(5-13EPS)Post Spike(PS)
The samples in this SDG were analyzed on a"dry weight"basis.
Data Summary•
All sample data provided in this report met the acceptance criteria specified in the analytical methods and
procedures for initial calibration,continuing calibration,instrument controls and process controls where
applicable,with the following exceptions.
Quality Control(QQ Information
Matrix Spike(MS/MSD)Recovery Statement
The percent recoveries(%R)obtained from the MS/MSD analyses are evaluated when the sample concentration
Page 16 of 17 SDG: 596016

is less than four times(4X)the spike concentration added. The MS/MSD(See Below)did not meet the
recommended quality control acceptance criteria for percent recoveries for the following applicable analytes.
The post spike recoveries were within the required control limits. This verifies the absence of a matrix
interference in the post-spike digested sample.The recoveries may be attributed to possible sample matrix
interference and/or non-homogeneity.
Sample Analyte Value
1205211686(5-13EMS) Arsenic 6.1* (75%-125%)
1205211687(5-13EMSD) Arsenic 41.3*(75%-125%)
Technical Information
Preparation/Analytical Method Verification
Method SW-846 3050B is not a total digestion technique for most samples.It is a very strong acid digestion that
will dissolve almost all elements that could become environmentally available.By design,elements bound in
silicate structures are not normally dissolved by this procedure as they are not usually mobile in the environment.
Radiochemistry
Product: Dry Weight
Preparation Method:ASTM D 2216(Modified)
Preparation Procedure: GL-OA-E-020 REV# 13
Preparation Batch:2326768
The following samples were analyzed using the above methods and analytical procedure(s).
GEL Sample ID# Client Sample Identification
596016001 5-13E
596016002 5-14W
1205212117 595914012(NonSDG)Sample Duplicate(DUP)
The samples in this SDG were analyzed on an"as received"basis.
Data Summary•
There are no exceptions,anomalies or deviations from the specified methods.All sample data provided in this
report met the acceptance criteria specified in the analytical methods and procedures for initial calibration,
continuing calibration,instrument controls and process controls where applicable.
Certification Statement
Where the analytical method has been performed under NELAP certification,the analysis has met all of the
requirements of the NELAC standard unless otherwise noted in the analytical case narrative.
Page 17 of 17 SDG: 596016

Young, Brianna A
From: Hanks,Joshua M
Sent: Monday,January 29, 2024 5:29 PM
To: Young, Brianna A
Cc: Watson, Samuel; Peacock, David; Burch, Brent; Concepcion, Richard C
Subject: RE: Carolina Pole Leland, Inc. in Brunswick County
Hi Brianna,
I'm the Compliance Branch hydrogeologist for the HWS and just wanted to follow up with you regarding your
information request for the Carolina Pole site in Leland, NC. I understand that the BFS has provided some feedback but I
wanted to follow up with some of my notes on the site and a summary of recent activities.You are correct that there are
2 areas capped and dioxins are present on site. For a detailed report on the history of the site,the signed BFA for the
2
site has documented the history of the site fairly well which is linked here: P°F 07003 General Wood recorded
NBP 20051015.pdf
Historical contaminants at the site include arsenic, organics including PAHs, chromium, copper, pentachlorophenol, and
dioxins.The HWS oversaw the post-closure work done at the facility starting in 1992 which included excavating and
backfilling of the 4 HW Management Units named junk pile, old impoundment, burn pile, and drying kiln ditch.The
drying kiln ditch was capped as vehicular traffic was expected to continue in this area and groundwater was monitored
around these units as part of the post-closure care requirements.The responsible party for this work declared
bankruptcy in 2000. In 2006 the property was purchased by Leland LLC and received a BFA. While pursuing a BFA, the
developer installed a permanent cap over an area on the property called the Pole Storage Hot Spot where free phase
hydrocarbons were identified.The signed BFA requires the property owner to maintain the existing caps and to continue
to monitor groundwater conditions annually for VOCs,SVOCs, and metals and monitor soil every 5 years for dioxins,
arsenic, and pentachlorophenol.
The recent work conducted at the site has been in response to a HWS issued IA-NOV for releases of pentachlorophenol
and copper chromated arsenic to uncoated concrete in multiple areas of their facility. The HWS required a soil
assessment around the transfer deck concrete slab and the sub-slab area adjacent to the inactive steam line/filter press
which found exceedances for arsenic and pentachlorophenol in all samples collected and hexavalent chromium in some
rn
of the samples (Ell NCD093137636 Carolina Pole COR 20221129 Romanski.pdf).The HWS has approved a workplan
to characterize groundwater in these areas but have not received a start date due to several delays.They are currently
working on some facility upgrades which are operated under a BFS approved Environmental Management Plan. In
addition to construction activities, they recently had a release of copper chromated arsenate product in December 2022
rn
which was addressed under IHSB (impacted soil excavated and removed: P°F SRR Emergency Response Response Report
by Terracon -Carolina Pole Leland.pdf) and a fire in the kiln building(no releases associated with the fire) around April
2023.
Hope this helps but please feel free to contact me if you have any questions or would like to discuss any of the recent
HWS work. Samuel/David, please feel free to correct any details surrounding the BFA I did not get correct or may have
left out. Thanks everyone!
Joshua M. Hanks, LG
Hydrogeologist,Compliance Branch
Hazardous Waste Section
Division of Waste Management, NCDEQ
Joshua.Hankskdeq.nc.gov 984.270.0618 (Mobile)
i

From: Romanski, Autumn R<Autumn.Roma [e-mail]>
Sent:Tuesday,January 23, 2024 5:13 PM
To: Hanks,Joshua M <[e-mail]>; Concepcion, Richard C<[e-mail]>
Cc:Watson, Samuel <[e-mail]>; Peacock, David <[e-mail]>; Burch, Brent
<[e-mail]>
Subject: FW: Carolina Pole Leland, Inc. in Brunswick County
Hi Josh and Richard,
I received the email below regarding Carolina Pole/Koppers Site Leland, NC.
We have a pending approved Groundwater well install and sampling plan that is approved for implementation regarding
IA-NOV issued.
However, Dioxins were not part of the recent releases reviewed by the HWS, but rather historical, already monitored in
groundwater under Brownfield Agreement.
Just wanted to clarify.Josh Hanks will have a copy of the approved sample plan that had been reviewed by the Chemist
Group and a copy will also be in S:Drive/CB/Staff Folders/a Former Employee Folder/Autumn Romanski/Folder
2023/ChemistActiveSites2023/IANOV/KoppersFolder
I am having trouble getting the folders to copy, so let me know if you do not see any Koppers files you may need, I have
a backup copy on my desktop.
Sincerely,
Autumn
Autumn Romanski
Environmental Senior Specialist
Division of Waste Management—Solid Waste Section
North Carolina Division of Environmental Quality
Cell: [phone]
[e-mail]
D- E-
�
NORTH CAROLINA kJ110)
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Watson, Samuel <[e-mail]>
Sent:Tuesday,January 23, 2024 3:09 PM
To:Young, Brianna A<[e-mail]>
Cc: Peacock, David <david.peacock@ deg.nc.gov>; Romanski,Autumn R<Autumn.Roma [e-mail]>
Subject: RE: Carolina Pole Leland, Inc. in Brunswick County
Brianna,
2

The site is still considered a Brownfields site and will likely remain a Brownfields site for a very long time. The
Brownfields Redevelopment Section (BRS) does not remediate sites, but mitigates the risks in order to make it safe to
use. The capping of the dioxins and any remedial work that was done at the site was done under the supervision and
direction of the Hazardous Waste Section(HWS) of DWM, and thus mitigated the risks at the site to acceptable
levels. Autumn Romanski, with HWS, should be able to answer some of your questions more completely, if needed. I
have copied her on this response.
The bottom line, however,from a Brownfields standpoint is that anything currently present at the site is either being
contained at levels that do not present a risk(historical releases), or is currently being addressed by the HWS(resent
issues, including a fire at the site). If your required monitoring reporting has not shown any exceedances of any of your
requirements/restrictions/standards, or presented any other red flags for you,then containment would appear to
successful at the site.And as such would not be an issue with the BRS.
However, if there have been any red flags, or violations, we would like to be aware of those. Part of the requirements
for the Brownfields Agreement is that they must remain compliant with the rules/regulations of all other agencies.
Let me know if you have any questions or wish to discuss further.
Thanks,
Samuel P. Watson
Project Manager, Brownfields Property Management Branch
Brownfields Redevelopment Section
Division of Waste Management
North Carolina Department of Environmental Quality
Wilmington Regional Office
910-796-7408 (office), 910-508-2214 (cell)
[e-mail]
E-mail correspondence to and from this address may
be subject to the North Carolina Public Records Law
and may be disclosed to third parties.
From:Young, Brianna A<[e-mail]>
Sent:Tuesday,January 23, 2024 1:54 PM
To: Watson, Samuel <[e-mail]>; Peacock, David <d avid.peacock@d eq.nc.gov>
Subject: Carolina Pole Leland, Inc. in Brunswick County
Good afternoon,
I am reviewing the stormwater permit renewal for the Carolina Pole Leland, Inc. facility(located at 1901 Wood
Treatment Road NE, Leland, NC in Brunswick County) and it has come to our attention that this site has a history of being
a brownfield. Our permit file history states that dioxins were discovered at the site and that two areas would be capped.
Can you provide an update on whether this site is still considered a brownfield, and what, if any, clean-up operations
occurred onsite? Is DWM still concerned about the presence of dioxins (or any other pollutants) onsite?
Thank you,
3

Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647(office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
4

Young, Brianna A
From: Lambe, Brian
Sent: Friday, July 14, 2023 3:38 PM
To: Young, Brianna A
Subject: RE: Carolina Pole Leland, Inc. (NCS000222)
I am not an expert on dioxins and the special study portion of the permit.
I did discuss with them the request for removal of copper and substituting Chromium III. 1 told them that typically if
Chromium is included, we want to see total, IV, and III. 1 reassured them that the copper hurdle is not insurmountable
and we can work through the tier system as long as they communicate with me.
Brian Lambe
Environmental Specialist
910-796-7313
919-268-1678 cell
State of North Carolina I Environmental Quality I Energy,Mineral and Land Resources
127 Cardinal Drive Extension I Wilmington,NC 28405
910 796 7215 T 1 910 350 2004 F I luto://portal.nedenr.orghveb/Id
From:Young, Brianna A<[e-mail]>
Sent: Friday,July 14, 2023 3:33 PM
To: Lambe, Brian <[e-mail]>
Subject: RE: Carolina Pole Leland, Inc. (NCS000222)
Thanks, Brian.
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
INC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
**DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th. Employee email addresses may look
different, but email performance will not be impacted.
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From: Lambe, Brian <[e-mail]>
Sent: Friday,July 14, 2023 3:29 PM
To:Young, Brianna A<[e-mail]>
Subject: RE: Carolina Pole Leland, Inc. (NCS000222)

Please find the attached inspection report. I did not mail this as I do not want to contradict any pending decisions you
make.
Brian Lambe
Environmental Specialist
910-796-7313
919-268-1678 cell
State of North Carolina I Environmental Quality I Energy,Mineral and Land Resources
127 Cardinal Drive Extension I Wilmington,NC 28405
910 796 7215 T 1 910 350 2004 F I httn://poml.ncdenr.or web/ir/
From: Lambe, Brian
Sent: Friday,July 7, 2023 11:45 AM
To:Young, Brianna A<[e-mail]>
Cc:Sams, Dan <[e-mail]>
Subject: RE: Carolina Pole Leland, Inc. (NCS000222)
I can get there next week, probably tues or wed
Brian Lambe
Environmental Specialist
910-796-7313
919-268-1678 cell
State of North Carolina I Environmental Quality I Energy,Mineral and Land Resources
127 Cardinal Drive Extension I Wilmington,NC 28405
910 796 7215 T 1 910 350 2004 F I httn://Vonal.ncdenr.or web/lr/
From:Young, Brianna A<[e-mail]>
Sent: Friday,July 7, 2023 10:50 AM
To: Lambe, Brian <[e-mail]>
Cc:Sams, Dan <[e-mail]>
Subject: RE: Carolina Pole Leland, Inc. (NCS000222)
Good morning,
I am following up on the inspection for NCS000222. I have not received the inspection report and do not see one in
BIMS. Has an inspection been conducted on this site? If so, please send me the report and add it to BIMS and Laserfiche.
If not, do you have an updated timeframe of when this might be completed?
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
**DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th. Employee email addresses may look
different, but email performance will not be impacted.
919-707-3647 (office)
2

Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From:Young, Brianna A
Sent: Friday, May 26, 2023 12:08 PM
To: Lambe, Brian <brian.lam [e-mail]>
Cc:Sams, Dan <[e-mail]>
Subject: RE: Carolina Pole Leland, Inc. (NCS000222)
Thank you for the update.
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL
DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th. Employee email addresses may look
different, but email performance will not be impacted.
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: Lambe, Brian <[e-mail]>
Sent: Friday, May 26, 2023 12:06 PM
To:Young, Brianna A<[e-mail]>
Cc:Sams, Dan <[e-mail]>
Subject: RE: Carolina Pole Leland, Inc. (NCS000222)
I will be catching up on all NPDES NOls next month. Sorry my attention has been delegated elsewhere for some time.
Brian Lambe
Environmental Specialist
910-796-7313
919-268-1678 cell
State of North Carolina I Environmental Quality I Energy,Mineral and Land Resources
127 Cardinal Drive Extension I Wilmington,NC 28405
910 796 7215 T 1 910 350 2004 F I httn://nor[al.ncdenr.org/web/Ir,
3

From:Young, Brianna A<[e-mail]>
Sent:Thursday, May 25, 2023 4:00 PM
To: Lambe, Brian <[e-mail]>
Cc:Sams, Dan <[e-mail]>
Subject: RE: Carolina Pole Leland, Inc. (NCS000222)
Good afternoon,
I am following up on my previous email. Please let me know if/when an inspection report is available.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL
DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th. Employee email addresses may look
different, but email performance will not be impacted.
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From:Young, Brianna A
Sent:Thursday,April 6, 2023 1:36 PM
To: Lambe, Brian <[e-mail]>
Cc:Sams, Dan <[e-mail]>
Subject: Carolina Pole Leland, Inc. (NCS000222)
Hello Brian,
I have started working on the permit renewal application for Carolina Pole Leland, Inc. (NCS000222). Please perform a
site visit and let me know if there are any concerns that need to be addressed during the renewal.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
4

919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
,�: D E '�7'`
NORTH CAROLINA ki ;
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
5

Compliance Inspection Report
Permit:NCS000222 Effective: 09/18/18 Expiration: 08/31/21 Owner: Leland Land LLC
SOC: Effective: Expiration: Facility: Carolina Pole Leland Inc
County: Brunswick 1901 Wood Treatment Rd NE
Region: Wilmington
Leland NC 28451
Contact Person:Michele Reams Title: Phone: [phone]
Directions to Facility:
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 07/14/2023 Entry Time 10:15AM Exit Time: 11:35AM
Primary Inspector:Brian P Lambe Phone:
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCS000222 Owner-Facility:Leland Land LLC
Inspection Date: 07/14/2023 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Met with Mike Rouse, Plant Manager, and Michelle Reams, SH&E Cordinator.
Reviewed the SPPP. The SPPP included all required elements updated and documented in a timely manner.
Reviewed the monitoring data. The results did not warrant any current tier response.
The facility has changed methods from oil based application to water based application. The facility keeps less inventory on
site than previously. The treated poles are kept onsite no more than a week before shipped out.
The facility was very clean and organized. Oil products were maintained under cover and within secondary containment. No
odd hydraulic fluid buckets were laying around. No odd pollution sources were found during inspection. The site appeared to
be intentionally maintained.
Application requests removal of the dioxin special study. I did not have knowledge of dioxins or an answer for the request.
Application requests removal of copper and substitute Chromium III.We discussed the small benchmark value for the copper
and the typical tier process in relation to NCG190000 (Marinas). Discussed possible ramifications of Chromium and
sampling for total, III, and IV found in other permits. I suggested that it may be best left alone, especially considering the
pattern of diminishing presence in the samples. I said that if they ever reach Tier ll, they should contact me to evaluate.
Discussed possiblity of going to quarterly sampling.
Page 2 of 3

Permit: NCS000222 Owner-Facility:Leland Land LLC
Inspection Date: 07/14/2023 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan? ❑ ❑ ❑
#Does the Plan include a General Location (USGS) map? ❑ ❑ ❑
#Does the Plan include a"Narrative Description of Practices"? ❑ ❑ ❑
#Does the Plan include a detailed site map including outfall locations and drainage areas? ❑ ❑ ❑
#Does the Plan include a list of significant spills occurring during the past 3 years? ❑ ❑ ❑
#Has the facility evaluated feasible alternatives to current practices? ❑ ❑ ❑
#Does the facility provide all necessary secondary containment? ❑ ❑ ❑
#Does the Plan include a BMP summary? ❑ ❑ ❑
#Does the Plan include a Spill Prevention and Response Plan (SPRP)? ❑ ❑ ❑
#Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ❑ ❑ ❑
#Does the facility provide and document Employee Training? 0 ❑ ❑ ❑
#Does the Plan include a list of Responsible Party(s)? 0 ❑ ❑ ❑
# Is the Plan reviewed and updated annually? 0 ❑ ❑ ❑
#Does the Plan include a Stormwater Facility Inspection Program? 0 ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented? 0 ❑ ❑ ❑
Comment:
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring? ❑ ❑ ❑ ❑
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑
#Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? 0 ❑ ❑ ❑
Comment:
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? 0 ❑ ❑ ❑
#Were all outfalls observed during the inspection? ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑
#Has the facility evaluated all illicit(non stormwater)discharges? 0 ❑ ❑ ❑
Comment: Outfall was not observed due to snakes, mosquitos and excessive heat. The site drains into a
moat that is outletted to the south of the site.
Page 3 of 3

Young, Brianna A
From: Reams, Michele B <[e-mail]>
Sent: Tuesday, April 25, 2023 8:41 AM
To: Young, Brianna A
Cc: Wiseman, Kevin W; Rouse, Michael T; House, Sarah J
Subject: RE: [External] RE: Carolina Pole Leland, Inc. facility(NCS000222)
Attachments: Historical Data for DEQ.pdf
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Brianna—
Please find responses to your questions below.
1. The previous permit required semi-annual sampling in 2020 for xylene,toluene, and benzene, however, I did not
see this monitoring data in the information provided. Please provide this data as soon as possible. I apologize I
didn't got capture those columns but please find the updated information attached.
2. The renewal application indicated pentachlorophenol was going to be replaced with another preservative
system. Did this transition occur, and if so, what is the new chemical/process? We are no longer treating with
Penta and are only treating with Chromated Copper Arsenate (CCA).
Please let me know if you have any further questions.Thanks.
Respectfully,
C�-Wichele
Michele Reams
SH&E Coordinator
Koppers Utility& Industrial Products I P.O.Box 370 1 Leland, NC 28451 1 United States
T: [phone] M: [phone]
reamsmb(ftoppers.com
OPPERS
Responsible Care I A member of the American Chemistry Council
Learn more about Koppers: http://www.koppers.com
The contents of this a-mail are intended for the use of the intended addressee(s)only and maybe confidential.If you are not an intended addressee,note that any disclosure,copying,distribution or use
of this e-mail message or the contents hereof is prohibited.
From:Young, Brianna A<[e-mail]>
Sent: Monday,April 24, 2023 4:10 PM
To: Reams, Michele B<[e-mail]>
Cc:Wiseman, Kevin W<[e-mail]>; Rouse, Michael T<[e-mail]>; House, Sarah J
<[e-mail]>
Subject: RE: [External] RE: Carolina Pole Leland, Inc. facility(NCS000222)
WARNING: External Sender
1

Leland
ra �
di l c
iJ� •� Q G (� � � o � w
H 6- 0 C3 a
Q o
Benchmrk 100 0.34 0.01 0.919 120 6.0-9.0 15 ANY 6.7 0.955 6.7
mgll mgll mgll mgll mgll su mgll mgfl mgll mgll mgll
Jun-18 26 0.140 0.023 BDL 80 7.30 BDL 2.06E-07 BDL BDL BDL
Nov-18 BDL 0.037 BDL BDL 25 7.50 BDL 2.71E-08 NS NS NS
Jul-19 66 0.089 0.018 0.0044 65 4.60 BDL 2.17E-07 NS NS NS
Dec-19 5 0.022 BDL BDL 31 7.30 <5.0 1.70E-08 NS NS NS
Jun-20 110 0.140 0.073 0.049 87 7.60 <5_6 2.00E-06 <5.0 <5.0 <5.0
Jul-20 22 0.150 <0.01 <0.004 NS 6.60 NS 9.83E-08 <0.001 <0.001 <0.001
Jun-21 10 0.091 BDL BDL 38 7.7 BDL 3.10E-08 N5 NS NS
Ju!-22 I 1 8 10.0491 BDL I BDL 1 31 1 6.7 1 BDL I 1.11E-08 I N5 I NS I NS

Good afternoon,
After reviewing all the information provided, I have a couple follow up questions.
1. The previous permit required semi-annual sampling in 2020 for xylene,toluene, and benzene, however, I did not
see this monitoring data in the information provided. Please provide this data as soon as possible.
2. The renewal application indicated pentachlorophenol was going to be replacedwith another preservative
system. Did this transition occur, and if so, what is the new chemical/process?
Thank you,
Brianna Young, MS(she/her hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: Reams, Michele B<[e-mail]>
Sent:Wednesday,April 19, 2023 1:13 PM
To:Young, Brianna A<[e-mail]>
Cc:Wiseman, Kevin W<[e-mail]>; Rouse, Michael T<[e-mail]>; House, Sarah J
<[e-mail]>
Subject: RE: [External] RE: Carolina Pole Leland, Inc. facility(NCS000222)
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Brianna—
Thank you. I have also been able to get the forms for the changes needed. I will get that completed as soon as possible.
Thanks
Respectfully,
C�-Wichele
Michele Reams
SH&E Coordinator
Koppers Utility& Industrial Products I P.O.Box 370 1 Leland, NC 28451 1 United States
2

T: [phone] M: [phone]
reamsmb(ftoppers.com
OPPERS
Responsible Care I A member of the American Chemistry Council
Learn more about Koppers: http://www.koppers.com
The contents of this a-mail are intended for the use of the intended addressee(s)only and maybe confidential.If you are not an intended addressee,note that any disclosure,copying,distribution or use
of this e-mail message or the contents hereof is prohibited.
From:Young, Brianna A<[e-mail]>
Sent: Wednesday,April 19, 2023 12:32 PM
To: Reams, Michele B<[e-mail]>
Cc:Wiseman, Kevin W<[e-mail]>; Rouse, Michael T<[e-mail]>; House, Sarah J
<[e-mail]>
Subject: RE: [External] RE: Carolina Pole Leland, Inc. facility(NCS000222)
WARNING: External Sender
Good afternoon,
Thank you for providing this information. I will reach out if I have any further questions once I've had a chance to review
everything.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: Reams, Michele B<[e-mail]>
Sent:Tuesday, April 11, 2023 10:40 AM
To:Young, Brianna A<[e-mail]>
Cc:Wiseman, Kevin W<[e-mail]>; Rouse, Michael T<[e-mail]>; House, Sarah J
<[e-mail]>
Subject: RE: [External] RE: Carolina Pole Leland, Inc. facility(NCS000222)
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
3

Brianna—
Please find the responses to the additional information you requested in regards to our application for the renewal of
our stormwater permit dated February 26, 2021.
• Description of industrial activity occurring onsite;
o The facility treats utility poles utilizing a water borne preservative known as chromated copper
arsenate (CCA)or an oil borne preservative known as pentachlorophenol (penta). As of April 2022
pentachlorophenol usage was removed from the process so the facility only treats with CCA. At
specific customer requests,the site will also add a water soluble oil treatment to keep the poles soft
for climbing. As part of the process,the site brings in unpeeled material and peels them on site then
dries the untreated poles utilizing kilns and a wood-fired boiler.
• Confirmation on the number of outfalls and associated coordinates;
o Our facility only has one (1) outfall located at Latitude:34.245560& Longitude:-78.071390
• Description of industrial activity and chemicals in each drainage area;
o Potential chemicals would be the CCA chemical,wood chips, bark,diesel and oil from vehicle
operation.
• SIC (NAICS) code;
o SIC#-2491
o NAICS#- Primary—3213.14, Secondary—32111
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the effective
date of the current permit;
o Please see attached copy of the historical data.
• Verification that the information in the renewal application is still complete and correct; and
o There are changes that are needed. However, per your email this morning the forms are located on a
server that is down and unattainable at this time.
• An explanation of any operational changes since the renewal application was submitted.
o As of April 2022, our facility only treats with a water borne preservative know as chromated copper
arsenate (CCA).
As soon as the server is back up I can get the forms completed to update the information for the renewal application. If
you have any further questions please let me know.Thanks.
Respectfully,
Icchele
Michele Reams
SH&E Coordinator
Koppers Utility& Industrial Products I P.O.Box 370 1 Leland, NC 28451 1 United States
T: [phone] M: [phone]
reamsmb(o koppers.com
KOPPERS
Responsible Care I A member of the American Chemistry Council
Learn more about Koppers: http://www.koppers.com
The contents of this a-mail are intended for the use of the intended addressee(s)only and maybe confidential.If you are not an intended addressee,note that any disclosure,copying,distribution or use
of this e-mail message or the contents hereof is prohibited.
4

From:Young, Brianna A<[e-mail]>
Sent: Monday,April 10, 2023 10:04 AM
To: Reams, Michele B<[e-mail]>
Cc:Wiseman, Kevin W<[e-mail]>; Rouse, Michael T<[e-mail]>; House, Sarah J
<[e-mail]>
Subject: RE: [External] RE: Carolina Pole Leland, Inc. facility(NCS000222)
WARNING: External Sender
Michele,
The database that holds these forms is currently down. We are working to get the database up and running again, but
do not have a timeframe on when that will be. I apologize for the inconvenience.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: Reams, Michele B<[e-mail]>
Sent: Monday,April 10, 2023 9:59 AM
To:Young, Brianna A<[e-mail]>
Cc:Wiseman, Kevin W<[e-mail]>; Rouse, Michael T<[e-mail]>; House, Sarah J
<[e-mail]>
Subject: [External] RE: Carolina Pole Leland, Inc.facility(NCS000222)
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Brianna—
The links to the change forms listed below do not work and I can't pull them from the website either. Can you please
send me copies of the change forms listed? I was able to get a copy of the permit summary and I do need to make some
changes.Thanks
Respectfully,
5

C>Wichele
Michele Reams
SH&E Coordinator
Koppers Utility&Industrial Products I P.O.Box 370 1 Leland, NC 28451 1 United States
T: [phone] M: [phone]
reamsmb(ftoppers.com
KOPPERS
Responsible Care I A member of the American Chemistry Council
Learn more about Koppers: http://www.koppers.com
The contents of this e-mail are intended for the use of the intended addressee(s)only and may be confidential.If you are not an intended addressee,note that any disclosure,copying,distribution or use
of this e-mail message or the contents hereof is prohibited.
From: Young, Brianna A<[e-mail]>
Sent:Thursday,April 6, 2023 1:31 PM
To: ([e-mail]
Cc: House, Sarah J <[e-mail]>; [e-mail]; Reams, Michele B<[e-mail]>
Subject: Carolina Pole Leland, Inc. facility (NCS000222)
WARNING: External Sender
Good afternoon,
The Division of Energy, Mineral, and Land Resources (DEMLR) Stormwater Permitting Program
acknowledges receipt of your renewal application for coverage under NPDES Permit Number NCS000222.
Please continue to comply with all conditions and monitoring requirements in your current NPDES stormwater
permit. As long as you have submitted a complete renewal request package and maintain compliance with those
permit conditions, stormwater discharges from this facility are authorized by that permit until the Division
issues a renewal permit or notifies you of an alternative action.
I am working on renewing the individual stormwater permit for the Carolina Pole Leland, Inc. facility
(NCS000222). I need additional information in order to 1) confirm that the information I have is correct and 2)
make sure the permit adequately serves the needs of the facility. Please provide the following:
• Description of industrial activity occurring onsite;
• Confirmation on the number of outfalls and associated coordinates;
• Description of industrial activity and chemicals in each drainage area;
• SIC (NAICS) code;
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit;
• Verification that the information in the renewal application is still complete and correct; and
• An explanation of any operational changes since the renewal application was submitted.
Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that
includes the address of the facility,contact information for the permit, and the regulated stormwater outfall(s)for the
facility. Please review the facility information to make sure it is correct. Information can be updated using the links
provided below,where applicable:
• Facility/Company name or ownership: Name/Ownership Change Form
6

• Owner Affiliation (Legally responsible person; i.e., someone with the company who is designated to
represent the company per signatory requirements or another authorized representative): Permit Contact
Update Request Form
• Delegation of Signature Authority (DOSA): Permit Contact Update Request Form
• Billing contact: Permit Contact Update Request Form
• Permit contact: Permit Contact Update Request Form
• Facility contact: Permit Contact Update Request Form
• Facility address only: Email Bethany Georgoulias
• Stormwater outfall information: Email Bethany Geor_og ulias
• Visit the eDMR Six Steps website and complete Steps 1 and 2.
• Pay outstanding permit fees: Stormwater ePayment website
Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day
comment period. During this time we will be able to address any comments or concerns you have. During the
same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public
notice. Once all comments and concerns are addressed, you may be issued a final permit.
Please contact me if you have any questions.
Thank you,
Brianna Young, MS (she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
,�: D_ E "7'�
t4p�
NORTH CAROLINA
Department of Environmental Duality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
7

Leland
t� i
C/)
N d Q. O = 06 o
H 0 a U O o
Q tU
Benchmrk 100 0.34 0.01 0.019 120 6.0-9.0 15 ANY
mg/I mg/I mg/I mg/I mg/I su mg/I mg/I
Jun-18 26 0.140 0.023 BDL 80 7.30 BDL 2.06E-07
Nov-18 BDL 0.037 BDL BDL 25 7.50 BDL 2.71E-08
Jul-19 66 0.089 0.018 0.0044 65 4.60 BDL 2.17E-07
Dec-19 5 0.022 BDL BDL 31 7.30 <5.0 1.70E-08
Jun-20 110 0.140 0.073 0.049 87 7.60 <5.6 2.00E-06
Jul-20 22 0.150 <0.01 <0.004 NS 6.60 NS 9.83E-08
Jun-21 10 0.091 BDL BDL 38 7.7 BDL 3.10E-08
Jul-22 8 0.049 BDL BDL 31 6.7 BDL 1.11E-08

Young, Brianna A
From: Reams, Michele B <[e-mail]>
Sent: Tuesday, April 11, 2023 10:40 AM
To: Young, Brianna A
Cc: Wiseman, Kevin W; Rouse, Michael T; House, Sarah J
Subject: RE: [External] RE: Carolina Pole Leland, Inc. facility(NCS000222)
Attachments: Historical Data for DEQ.pdf
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Brianna—
Please find the responses to the additional information you requested in regards to our application for the renewal of
our stormwater permit dated February 26, 2021.
• Description of industrial activity occurring onsite;
o The facility treats utility poles utilizing a water borne preservative known as chromated copper
arsenate (CCA)or an oil borne preservative known as pentachlorophenol (penta). As of April 2022
pentachlorophenol usage was removed from the process so the facility only treats with CCA. At
specific customer requests,the site will also add a water soluble oil treatment to keep the poles soft
for climbing. As part of the process,the site brings in unpeeled material and peels them on site then
dries the untreated poles utilizing kilns and a wood-fired boiler.
• Confirmation on the number of outfalls and associated coordinates;
o Our facility only has one (1)outfall located at Latitude: 34.245560 & Longitude:-78.071390
• Description of industrial activity and chemicals in each drainage area;
o Potential chemicals would be the CCA chemical,wood chips, bark, diesel and oil from vehicle
operation.
• SIC (NAICS) code;
o SIC#-2491
o NAICS#- Primary—321114,Secondary—32111
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the effective
date of the current permit;
o Please see attached copy of the historical data.
• Verification that the information in the renewal application is still complete and correct; and
o There are changes that are needed. However, per your email this morning the forms are located on a
server that is down and unattainable at this time.
• An explanation of any operational changes since the renewal application was submitted.
o As of April 2022, our facility only treats with a water borne preservative know as chromated copper
arsenate (CCA).
As soon as the server is back up I can get the forms completed to update the information for the renewal application. If
you have any further questions please let me know.Thanks.
Respectfully,
CMchele

Michele Reams
SH&E Coordinator
Koppers Utility& Industrial Products I P.O.Box 370 1 Leland, NC 28451 United States
T: [phone] M: [phone]
reamsmb(ftoppers.com
PPER
Responsible Care I A member of the American Chemistry Council
Learn more about Koppers: http://www.koppers.com
The contents of this a-mail are intended for the use of the intended addressee(s)only and maybe confidential.If you are not an intended addressee,note that any disclosure,copying,distribution or use
of this e-mail message or the contents hereof is prohibited.
From:Young, Brianna A<[e-mail]>
Sent: Monday,April 10, 2023 10:04 AM
To: Reams, Michele B<[e-mail]>
Cc:Wiseman, Kevin W<[e-mail]>; Rouse, Michael T<[e-mail]>; House, Sarah J
<[e-mail]>
Subject: RE: [External] RE: Carolina Pole Leland, Inc. facility(NCS000222)
WARNING: External Sender
Michele,
The database that holds these forms is currently down. We are working to get the database up and running again, but
do not have a timeframe on when that will be. I apologize for the inconvenience.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
INC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: Reams, Michele B<[e-mail]>
Sent: Monday,April 10, 2023 9:59 AM
To:Young, Brianna A<[e-mail]>
Cc:Wiseman, Kevin W<[e-mail]>; Rouse, Michael T<[e-mail]>; House, Sarah J
<[e-mail]>
Subject: [External] RE: Carolina Pole Leland, Inc. facility(NCS000222)
2

CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Brianna—
The links to the change forms listed below do not work and I can't pull them from the website either. Can you please
send me copies of the change forms listed? I was able to get a copy of the permit summary and I do need to make some
changes. Thanks
Respectfully,
IcMchele
Michele Reams
SH&E Coordinator
Koppers Utility& Industrial Products I P.O.Box 370 1 Leland, NC 28451 1 United States
T: [phone] M: [phone]
reamsmb()koppers.com
IPA)
Responsible Care I A member of the American Chemistry Council
Learn more about Koppers:htti)://www.koppers.com
The contents of this e-mail are intended for the use of the intended addressee(s)only and may be confidential.If you are not an intended addressee,note that any disclosure,copying,distribution or use
of this e-mail message or the contents hereof is prohibited.
From: Young, Brianna A<[e-mail]>
Sent:Thursday,April 6, 2023 1:31 PM
To: [e-mail]
Cc: House, Sarah J <[e-mail]>; [e-mail]; Reams, Michele B<[e-mail]>
Subject: Carolina Pole Leland, Inc. facility(NCS000222)
WARNING: External Sender
Good afternoon,
The Division of Energy, Mineral, and Land Resources (DEMLR) Stormwater Permitting Program
acknowledges receipt of your renewal application for coverage under NPDES Permit Number NCS000222.
Please continue to comply with all conditions and monitoring requirements in your current NPDES stormwater
permit. As long as you have submitted a complete renewal request package and maintain compliance with those
permit conditions, stormwater discharges from this facility are authorized by that permit until the Division
issues a renewal permit or notifies you of an alternative action.
I am working on renewing the individual stormwater permit for the Carolina Pole Leland, Inc. facility
(NCS000222). I need additional information in order to 1) confirm that the information I have is correct and 2)
make sure the permit adequately serves the needs of the facility. Please provide the following:
• Description of industrial activity occurring onsite;
• Confirmation on the number of outfalls and associated coordinates;
• Description of industrial activity and chemicals in each drainage area;
• SIC (NAICS) code;
3

• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit;
• Verification that the information in the renewal application is still complete and correct; and
• An explanation of any operational changes since the renewal application was submitted.
Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that
includes the address of the facility, contact information for the permit, and the regulated stormwater outfall(s)for the
facility. Please review the facility information to make sure it is correct. Information can be updated using the links
provided below, where applicable:
• Facility/Company name or ownership: Name/Ownership Change Form
• Owner Affiliation (Legally responsible person; i.e., someone with the company who is designated to
represent the company per signatory requirements or another authorized representative): Permit Contact
Update Request Form
• Delegation of Signature Authority (DOSA): Permit Contact Update Request Form
• Billing contact: Permit Contact Update Request Form
• Permit contact: Permit Contact Update Request Form
• Facility contact: Permit Contact Update Request Form
• Facility address only: Email Bethany Geor og ulias
• Stormwater outfall information: Email Bethany Geor og ulias
• Visit the eDMR Six Steps website and complete Steps 1 and 2.
• Pay outstanding permit fees: Stormwater ePayment website
Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day
comment period. During this time we will be able to address any comments or concerns you have. During the
same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public
notice. Once all comments and concerns are addressed, you may be issued a final permit.
Please contact me if you have any questions.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
4

D- E-
cl ;
NORTH CAROLINA 7.AM Q
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
5

4/4/23, 12:45 PM North Carolina Secretary of State Search Results
• File an Annual Report/Amend an Annual Report • Upload a PDF Filing • Order a Document Online -
Add Entity to My Email Notification List • View Filings • Print a Pre-Populated Annual Report form • Print
an Amended a Annual Report form
Limited Liability Company
Legal Name
Leland Land LLC
Information
Sosld: 0618641
Status: Current-Active O
Date Formed: 1/31/2002
Citizenship: Domestic
Annual Report Due Date: April 15th
Currentgnnual Report Status:
Registered Agent: Corporation Service Company
Addresses
Reg Office Reg Mailing Mailing
2625 Glenwood Avenue, Suite 550 2625 Glenwood Avenue, Suite 550 436 7th Avenue
Raleigh, NC 27608 Raleigh, NC 27608 Pittsburgh, PA 15219
Principal Office
436 7th Avenue
Pittsburgh, PA 15219
Company Officials
All LLCs are managed by their managers pursuant to N.C.G.S. 57D-3-20.
Manager Manager Manager
Stephanie L. Apostolou James J. Healey Jimmi Sue Smith
436 7th Avenue 436 7th Avenue 436 7th Avenue
Pittsburgh PA 15219 Pittsburgh PA 15219 Pittsburgh PA 15219
https://www.sosnc.gov/online_services/search/Business_Registration_ResuIts 1/1

Roy Cooper,Governor
■ ■■■
■■ 0 INC DEPARTMENT OF D.Reid Wilson,Secretary
E ■
■■u■■ NATURAL AND CULTURAL RESOURCES
■ ■■■ Misty Buchanan
Deputy Director,Natural Heritage Program
NCNHDE-21503
April 4, 2023
Brianna Young
NCDEQ
512 North Salisbury Street
Raleigh, NC 27604
RE: NCS000222; NCS000222
Dear Brianna Young:
The North Carolina Natural Heritage Program (NCNHP) appreciates the opportunity to provide
information about natural heritage resources for the project referenced above.
A query of the NCNHP database indicates that there are records for rare species, important natural
communities, natural areas, and/or conservation/managed areas within the proposed project
boundary. These results are presented in the attached 'Documented Occurrences' tables and map.
The attached 'Potential Occurrences' table summarizes rare species and natural communities that
have been documented within a one-mile radius of the property boundary. The proximity of these
records suggests that these natural heritage elements may potentially be present in the project area
if suitable habitat exists. Tables of natural areas and conservation/managed areas within a one-mile
radius of the project area, if any, are also included in this report.
If a Federally-listed species is documented within the project area or indicated within a one-mile
radius of the project area, the NCNHP recommends contacting the US Fish and Wildlife Service
(USFWS) for guidance. Contact information for USFWS offices in North Carolina is found here:
https://www.fws.gov/offices/Di rectory_/ListOffices.cfm?statecode=37.
Please note that natural heritage element data are maintained for the purposes of conservation
planning, project review, and scientific research, and are not intended for use as the primary criteria
for regulatory decisions. Information provided by the NCNHP database may not be published
without prior written notification to the NCNHP, and the NCNHP must be credited as an information
source in these publications. Maps of NCNHP data may not be redistributed without permission.
Also please note that the NC Natural Heritage Program may follow this letter with additional
correspondence if a Dedicated Nature Preserve, Registered Heritage Area, Land and Water Fund
easement, or an occurrence of a Federally-listed species is documented near the project area.
If you have questions regarding the information provided in this letter or need additional assistance,
please contact Rodney A. Butler at rod ney.butler(a)ncdcr.gov or 919-707-8603.
Sincerely,
NC Natural Heritage Program
DEPAR71MEN7 OF NATURAL AND CULTURAL RESOURCES
fl 121 W.JONES STREET.RALEIGH.NC 27603 • 16S1 MAIL SERVICE CENTER,RALEIGH.Nc 27699
OFC 919.707.9120 • FAX 919.707,9121

Natural Heritage Element Occurrences, Natural Areas, and Managed Areas Intersecting the Project Area
NCS000222
Project No. NCS000222
April 4, 2023
NCNHDE-21503
Element Occurrences Documented Within Project Area
Taxonomic EO ID Scientific Name mmon Name element Accuracy Federal State Global State
Group Obsery Fation Occurrence Status Status Rank Rank
Date Rank
Vascular Plant 11755 Helenium brevifolium Littleleaf Sneezeweed 1950-05 H 3-Medium --- Endangered G4 S1
No Natural Areas are Documented within the Project Area
No Managed Areas Documented within the Project Area
Definitions and an explanation of status designations and codes can be found at https://ncnhde.natureserve.org/help. Data query generated on April 4,2023;source: NCNHP, Q4,Winter(January)2023.
Please resubmit your information request if more than one year elapses before project initiation as new information is continually added to the NCNHP database.
Page 2 of 5

Natural Heritage Element Occurrences, Natural Areas, and Managed Areas Within a One-mile Radius of the Project Area
NCS000222
Project No. NCS000222
April 4, 2023
NCNHDE-21503
Element Occurrences Documented Within a One-mile Radius of the Project Area
Taxonomic EO ID Scientific Name Common Name Last Element Accuracy Federal State Global State
Group Observation Occurrence Status Status Rank Rank
mmmm=iM= Date Rank ME
Dragonfly or 33738 Somatochlora Coppery Emerald 2004-Pre H? 5-Very --- Significantly G3G4 Sl?
Damselfly georgiana Low Rare
Natural 1240 Pine/Scrub Oak --- 2012 C 3-Medium --- --- G3? S3
Community Sandhill (Mixed Oak
Subtype)
Vascular Plant 13635 Amorpha confusa Savanna Indigo-bush 2002-08-05 D 3-Medium --- Threatened G3T3 S3
Vascular Plant 1262 Amorpha confusa Savanna Indigo-bush 2019-10-21 C 3-Medium --- Threatened G3T3 S3
Vascular Plant 224SS Dichanthelium Hidden-flowered 1937-06-02 H 4-Low --- Significantly GUQ S2
cryptanthum Witchgrass Rare
Throughout
Vascular Plant 15773 Dionaea muscipula Venus Flytrap 2002-06-26 D 2-High --- Threatened G2 S2
Vascular Plant 11755 Helenium brevifolium Littleleaf Sneezeweed 1950-05 H 3-Medium --- Endangered G4 S1
Vascular Plant 2724 Lysimachia Rough-leaf Loosestrife 2002-08-02 C 3-Medium Endangered Endangered G3 S3
asperulifolia
Vascular Plant 40274 Quercus elliottii Running Oak 2019-10-21 C 6-Unkno --- Endangered G3G5 S2
wn
Vascular Plant 40266 Scleria verticillata Savanna Nutrush 2019-08-15 D 2-High --- Significantly G5 S2
Rare
Peripheral
Vascular Plant 40275 Solidago tortifolia Twisted-leaf 2019-10-21 C 2-High --- Endangered G4G5 S1
Goldenrod
Natural Areas Documented Within a One-mile Radius of the Project Area
Site Name Representational Rating Collective Rating
Alligator Branch Sandhill and Flatwoods R5 (General) C5 (General)
Managed Areas Documented Within a One-mile Radius of the Project Area
Managed Area wner Owner Type
Military Ocean Terminal Sunny Point US Army Federal
NC Department of Transportation Mitigation Site NC Department of Transportation State
Page 3 of 5

Managed Areas Documented Within a One-mile Radius of the Project Area
Managed Area Nam Owner -
North Carolina Agricultural Foundation Preserve The North Carolina Agricultural Foundation,Private
Inc.
North American Land Trust Easement North American Land Trust Private
Definitions and an explanation of status designations and codes can be found at httos://ncnhde.natureserve.ora/helr). Data query generated on April 4,2023;source: NCNHP, Q4,Winter(January)2023.
Please resubmit your information request if more than one year elapses before project initiation as new information is continually added to the NCNHP database.
Page 4 of 5

Permit Coverage
Renewal Application Form
National Pollutant Discharge Elimination System NPDES Permit Number
Environmental Stormwater Individual Permit NCS 000222
Quality
lease provide your permit number in box in the upper right hand corner, complete the information in the space provided
below and return the completed renewal form along with the required supplemental information to the address indicated.
Owner Information * Address to which permit correspondence will be mailed
Owner/Organization Name: Leland Land
Owner Contact: Jim Healey
Mailing Address: Orangeburg,SC 29116
Orangeburg,SC 29116
Phone Number: 803-747-0044
Fax Number:
E-mail address: healeyj @koppers.com
Facility Information
Facility Name: Carolina Pole Leland,Inc.
Facility Physical Address: 1901 Wood Treatment Road NE
Leland,NC 28451
Facility Contact: Mike Rouse
Mailing Address: P.o.Box 370
Leland,NC 28451
Phone Number: 910-371-3131
Fax Number: 910-371-3137
E-mail address: [e-mail]
Petinit Information
Permit Contact: Jane House
Mailing Address: P.o.Box 124
Orangeburg,SC 29116
Cr hone Number: 803-664-4014
3x Number: NA
E-mail address: [e-mail]
Discharge Information
Receiving Stream: Sturgeon Creek
Stream Class: C
Basin: Cape Fear River Basein
Sub-Basin:
Number of Outfalls: 1
Facility/Activity Changes Please describe below any changes to your facility or activities since issuance of your permit. Attached a
separate sheet if necessary.
See attached
CERTIFICATjammiliar
I certify that I wi the nfor ton contained in the application and that to the best of my knowledge and belief
such informatie, co ete e.
Signature Date March 1,2021
Jane House Corporate EHS
Print or type nam f person signing above Title
Please return this completed application form DEMLR- Stormwater ProgramDept. of Environmental Quality
and requested supplemental information to: 1612 Mail Service Center
Raleigh, North Carolina 27699-1612

Sarah Jane House aPPERS
Director,SHE
Koppers Utility and Industrial Products
P. O. Box 1124
Orangeburg, SC 29116
Tel [phone]
March 1, 2021 Fax [phone]
[e-mail]
PRIORITY MAIL 9405 5036 9930 0290 2104 92 www.koppers.com
DEMLR — Stormwater Program
Dept. of Environmental quality
1612 Mail Service Center
Raleigh, NC 27699-1612 RECEIVED
Subject: Carolina Pole Leland, Inc. MAR 16 2D21
Stormwater NPDES Permit NCS 000222 Renewal GENR-LAND QUALI-W
STORMVVATER RERN,11-1-TING
Dear Sir:
Enclosed are two copies of the renewal application for the above referenced permit. This
submittal constitutes a timely application for renewal.
"I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fines and imprisonment for knowing violations."
This a li ation is seeking some minor changes in the permit. If you have questions or require
more i fo mation, please contact me at [phone] or by email at housesiC�koppers.com.
Sinc rel ,
C O INA PO L LAND, IN
ne House, C M
Director, SHE
Enclosure
cc: H. M. Rollins Company, Inc.

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources— Stormwater Program
Facility Warne: Carolina Pole Leland,Inc.
Permit Number: NCS000222
Location ;address: 1901 Wood Treatment Road NE
Leland.NC 28451
County:
Brunswick
"I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all
attachments were developed and implemented under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gather and evaluate the information required by the SPPP.
Based on my inquiry of the person or persons who manage the system, or those persons directly responsible
for gathering the information, the information gathered is, to the best of my knowledge and belief, true,
accurate and complete."
And
"I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP
has been fully implemented at this facility location in accordance with the terms and conditions of the
Stormwater discharge permit."
And
"I am aware that there are significant penalties for falsifying information, including the possibility of fines and
imprisonment for knowing violations."
P g
Sign (according t ermit signatory requirements) and return this Certification. DO NOT
SEND STORM TER POLLU ION PREV ION PLAN WITH THIS CERTIFICATION.
Signature A Date March 1,2021
Jane ouse Corporate EHS
Print or type name of Vrson signing above Title
I
SPPP Certification 10/13

SUPPLEMENTAL INFORMATION REQUIRED FOR RENEWAL OF INDIVIDUAL
NPDES STORMWATER PERMIT
Two copies of each of the following shall accompany this submittal in order for the application
to be considered complete:
(Do not submit the site Stormwater Pollution Prevention Plan)
Initials
J H 1. A current Site Map from the Stormwater Pollution Prevention Plan. The location of
industrial activities (including storage of materials, disposal areas,process areas and
loading and unloading areas), drainage structures, drainage areas for each outfall,
building locations and impervious surfaces should be clearly noted.
JH 2. A summary of Analytical Monitoring results during the term of the existing permit
(if your permit required analytical sampling). Do not submit individual lab reports.
The summary can consist of a table including such items as outfall number,
parameters sampled, lab results, date sampled, and storm event data.
J H 3. A summary of the Visual Monitoring results. Do not submit individual monitoring
reports. The summary can consist of a table including such items as outfall number,
parameters surveyed, observations, and date monitoring conducted.
JH
4. A summary of the Best Management Practices utilized at the permitted facility.
Summary should consist of a short narrative description of each BMP's in place at
the facility. If the implementation of any BMP's is planned,please include
information on these BMP's.
J H 5. A short narrative describing any significant changes in industrial activities at the
permitted facility. Significant changes could include the addition or deletion of
work processes,changes in material handling practices, changes in material storage
practices, and/or changes in the raw materials used by the facility.
JH 6. Certification of the development and implementation of a Stormwater Pollution
Prevention Plan for the permitted facility (Sign and return attached form).
If the final year analytical monitoring of the existing permit term has not been completed
prior to filing the renewal submittal,then the last years monitoring results should be submitted
within 30 days of receipt of the laboratory reports. (i.e. do not withhold renewal submittal
waiting on lab results)

CAROLINA POLE LELAND, INC.
LELAND, NORTH CAROLINA
Stormwater NPDES Permit Renewal
NCS 000222
Prepared By:
H. M. Rollins Company, Inc.
P. O. Box 3471
Gulfport, Mississippi 39505
[phone]
RE CFly
MAR 16 2021
DENR-LAND QUAUT`;'
STORD/f IVATER PERN,11 ING
February 26, 2021

CAROLINA POLE LELAND,INC.
Stormwater NPDES Permit Renewal-NCS 000222 February 26,2021
TABLE OF CONTENTS
1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
2.0 PERMIT RENEWAL APPLICATION NARRATIVE AND
SUPPLEMENTAL INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
2.1 Special Provisions in the Existing Permit. . . . . . . . . . . . . . . . . . . . . . . . . . . 2
2.2 Supplemental Information Items . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
2.3 Requested Changes in the NPDES Stormwater Permit Conditions . . . . . . . 4
3.0 SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
Prepared by: H.M.Rollins Company,Inc.
Gulfport,MS Page i

C AROLINA POLE LELAND,INC.
Stormwater NPDES Permit Renewal-NCS 000222 February 26,2021
r.
LIST OF EXHIBITS
EXHIBIT 1 Stormwater Permit Renewal Forms
EXHIBIT 2 Supplemental Information Item 2, Table of Stormwater
Monitoring Results
EXHIBIT 3 Dioxin Reduction Feasibility Study
EXHIBIT 4 Supplement Information Item 1, Site Aerial Photograph
EXHIBIT 5 Supplement Information Item 3, Summary of Qualitative
Monitoring Results
EXHIBIT 6 Supplement Information Item 4, Summary of Best
Management Practices
EXHIBIT 7 Table of Dioxin Solubilities
Prepared by: H.M.Rollins Company,Inc.
Gulfport,MS Page ii

CAROLINA POLE LELAND,INC.
Stormwater NPDES Permit Renewal-NCS 000222 February 26,2021
1.0 INTRODUCTION
Carolina Pole Leland, Inc. (Carolina Pole) operates a wood treatment facility at 1901
Wood Treatment Road NE in Leland, Brunswick County, North Carolina. The facility
operates under a stormwater NPDES Permit#NCS 000222. That permit expires on
August 31, 2021, and this submittal constitutes a timely submittal for renewal of this
permit.
The Carolina Pole facility treats utility poles utilizing either a water borne preservative
known as chromated copper arsenate (CCA) or an oil borne preservative known as
pentachlorophenol (penta).
The manufacturer of penta has announced that they will cease production no later than
December 31, 2021, so Carolina Pole will have to change its present production to a
different preservative system soon after this permit is renewed. Carolina Pole will seek
some changes to its required monitoring parameters in the renewal permit as a result of
the cessation of the use of penta.
2.0 PERMIT RENEWAL APPLICATION NARRATIVE AND
SUPPLEMENTAL INFORMATION
The renewal process in North Carolina consists of the completion of the required forms
and the provision of certain supplemental information found on a separate checklist. The
Renewal Application Form, the Stormwater Pollution Prevention Plan Development and
Certification, and the Supplemental Information Required for Renewal of Individual
NPDES Stormwater Permit Checklist (Checklist) are found in Exhibit 1 of this
application.
Prepared by: H.M.Rollins Company,Inc.
Gulfport,MS Page 1

CAROLINA POLE LELAND,INC.
Stormwater NPDES Permit Renewal-NCS 000222 February 26,2021
This renewal application has been discussed with Ms. Aana Gamble of the North
Carolina Department of Environmental Quality (NCDEQ), and the information in this
application reflects her guidance. The balance of this narrative will discuss some specific
requirements in the present permit, some changes being requested by Carolina Pole, and
the Checklist information requested with all stormwater renewal applications.
2.1 Special Provisions in the Existing Permit
The existing permit contains two special provisions. One provision required
monitoring for the gasoline constituents, benzene, toluene, and total xylene, in the
monitoring conducted in 2020. That sampling was conducted and the results were
ND for all constituents at both sampling events. The results are included in the
s
Table in Exhibit 2, which also contains the monitoring results required by Item 2
of the Checklist.
The second special provision was the requirement to conduct a feasibility study
for pollution reduction methods for chlorinated dioxins and dioxin-like
compounds (dioxins). This study was previously provided to the NCDEQ, but a
copy is found in Exhibit 3 of this renewal application at the request of Ms.
Gamble. This study confirmed, as expected, that other anthropogenic sources of
dioxins existed and that significant levels of dioxins were contained in stormwater
that entered the Carolina Pole stormwater conveyance system from off-site
stormwater conveyance systems. Virtually all dioxins found in stormwater are in
particulate form due to the very low water solubilities of dioxins, as confirmed by
the data that shows some of the congeners present at orders of magnitude higher
than their aqueous solubilities. Therefore, best management practices that reduce
particulate loading in stormwater are the best practices for reducing the dioxin
Prepared by: H.M.Rollins Company,Inc.
Gulfport,MS Page 2

CAROLINA POLE LELAND, INC.
Stormwater NPDES Permit Renewal-NCS 000222 February 26 2021
f
concentration in stormwater. The Carolina Pole SWPPP already focuses on
methods to reduce suspended solids in its discharge. Carolina Pole will discuss its
request to remove dioxins from the list of required monitoring parameters in a
later section of this renewal application.
2.2 Supplemental Information Items
An overhead photograph of the site showing the information requested in Item 1
of the Checklist is found in Exhibit 4.
A summary of the analytical monitoring results requested in Item 2 of the
Checklist is found in Exhibit 2.
A summary of the Visual Monitoring results requested by Item 3 of the Checklist
is found in Exhibit 5.
A summary of Best Management Practices requested by Item 4 of the Checklist is
found in Exhibit 6.
Item 5 of the Checklist requests a narrative description of any significant changes
that have taken place at the facility. There have been no significant changes of
processes, work practices, material handling practices, material storage practices,
or raw materials used by the facility during the previous permit cycle. However,
there will be some possible changes during the next permit cycle due to the
removal of pentachlorophenol from the marketplace. Carolina Pole will either
change to another oil borne preservative, such as copper naphthenate or dichloro-
octyl-isothiazolin-one (DCOI), or will simply increase its production with CCA to
Prepared by: H.M.Rollins Company,Inc.
Gulfport,MS Page 3

CAROLINA POLE LELAND,INC.
Stonnwater NPDES Permit Renewal-NCS 000222 February 26,2021
meet the market demand. Neither of these options would represent a significant
change in facility operations.
Item 6 of the Checklist concerns certification of the development and
implementation of a Storm Water Pollution Prevention Plan (SWPPP). Carolina
Pole has a detailed and effective SWPPP and the signed certification form is
found in Exhibit 1.
2.3 Requested Changes in the NPDES Stormwater Permit Conditions
As mentioned earlier in this application narrative, Carolina Pole is requesting the
removal of dioxins as a required monitoring parameter. This request and the
supporting reasons have been discussed with NCDEQ representative Aana
Gamble. This request is supported by the following points.
1. Very few Stormwater NPDES Permits have monitoring
requirements for dioxins because the very low aqueous solubility of
the dioxin congeners is such that most of the dioxins found in
stormwater are in the particulate form, so the monitoring would not
actually reflect a water concentration. This can be confirmed by
looking at the analytical results in the feasibility study in Exhibit 3
which in many cases report dioxin levels orders of magnitude higher
than the aqueous solubility limits found in Exhibit 7.
2. North Carolina has no published surface water quality standards for
dioxins.
Prepared by: H.M.Rollins Company,Inc.
Gulfport,MS Page 4

CAROLINA POLE LELAND,INC.
Stormwater NPDES Permit Renewal-NCS 000222 February 26,2021
3. All stormwater runoff from both urban and rural areas contains
dioxins due to atmospheric deposition.
4. Urban runoff contains elevated levels of dioxins due to
anthropogenic sources such as automobile exhaust, boilers,
manufacturing heat sources, and residential combustion sources.
The dioxin study in Exhibit 3 shows that significant levels of
dioxins are found in stormwater from off-site sources that enters the
Carolina Pole stormwater conveyance system on the west side of the
facility.
5. The microcontaminant dioxins associated with pentachlorophenol
t
are not the human health and environmental risk drivers from the
use of the product. The primary dioxins associated with penta are
the highly chlorinated congeners which have low toxicity. When
EPA published the F032 hazardous waste listing, it specifically
considered the microcontaminants in penta and determined that
penta itself was the primary risk driver and that regulatory actions
that protected human health and the environment from the potential
effects of penta would provide protection from the
microcontaminants with a higher margin of safety. Based on this,
monitoring for pentachlorophenol should be adequate to assess the
potential environmental impact from the use of penta, including its
microcontaminants.
t�
Prepared by: H.M.Rollins Company,Inc.
Gulfport,MS Page 5

CAROLINA POLE LELAND,INC.
Stormwater NPDES Permit Renewal-NCS 000222 February 26,2021
6. Carolina Pole must transition to another preservative system in 2021
or 2022, and the need to monitor for penta should no longer be
required.
Carolina Pole requests that the requirement to monitor for dioxins be removed
from the permit when it is renewed and that the requirement to monitor for
pentachlorophenol only be continued for calendar year 2022.
Carolina Pole would like to discuss one other permit condition that is problematic
for the facility and that is the screening value for copper of 0.010 mg/l, or 10 parts
per billion. Carolina Pole suspects that any facility having a permit that contains
that copper benchmark has frequent reported exceedances of the benchmark.
These exceedances can lead to additional monitoring requirements and additional
response actions. For the reasons discussed below, Carolina Pole would request
the substitution of chromium III as a routine monitoring parameter in place of
copper. Chromium contained in stormwater that contacts CCA-treated wood is
dominantly in the tri-valent state.
1. Of the three constituents of CCA, copper is by far the least toxic to
vertebrate species. In CCA formulations, copper represents only
approximately 26% of the total metal mass while chromium and
arsenic represent the balance.
2. Stormwater from off-site flows that enter the Carolina Pole
stormwater conveyance system already contain copper at levels
exceeding the benchmark of 10 ppb as indicated by sampling
Prepared by: H.M.Rollins Company,Inc.
Gulfport,MS Page 6

�AROLINA POLE LELAND,INC.
Stormwater NPDES Permit Renewal-NCS 000222 February 26,2021
conducted in conjunction with the dioxin feasibility study found in
Exhibit 3.
3. Copper is a ubiquitous metal. It can be present in drinking water in
houses with copper piping at levels exceeding 1,000 ppb.
Information available on the internet indicates that copper levels in
runoff from parking lots and streets can be as high as 280 ppb, in
urban creeks as high as 50 ppb, and from retention ponds, over 40
ppb.
4. The National Stormwater Quality Database, available at
www.bmpdatabase.org/nsq-d.html contains data on copper levels in
stormwater runoff. This database contains data from 5,179 samples
for copper from locations across the U.S., and reports an average
value of 33.16 ppb and a maximum value of 7,270 ppb. For the
1,002 samples for which both total recoverable copper and soluble
copper were analyzed, the total recoverable to soluble ratio for
copper was 3.329. The copper benchmark of 10 ppb is based on
toxicity for soluble copper not total recoverable copper, yet site
monitoring is required for total recoverable copper.
5. Monitoring for arsenic and chromium III provides more useful and
meaningful data for evaluation of the effectiveness of the facility's
SWPPP than monitoring for copper which is found at levels
exceeding the 10 ppb screening value in stormwater flow from off-
site drainage where it enters the Carolina Pole stormwater
conveyance system.
Prepared by: H.M.Rollins Company,Inc.
Gulfport,MS Page 7

CAROLINA POLE LELAND,INC.
Stormwater NPDES Permit Renewal-NCS 000222 February 26,2021
3.0 SUMMARY
This application for renewal of the Carolina Pole Stormwater NPDES Permit, NCS
000222, reflects the fact that there have been no significant changes in facility
operations. However, the application does seek to make some changes in monitoring
parameters in order to eliminate data production that is of limited value in terms of
protection of surface water quality and assessment of the effectiveness of the facility
S WPPP.
a
i
Prepared by: H.M.Rollins Company,Inc.
Gulfport,MS Page 8

Berk Bounty_Register of feed
Robert 3. Robinson
Inst #330867 Book 2390Page 1386
05/17/2006 01:09:53 Rec 11-1 at l
t, a
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CASH REF BY
Property Owner: Leland Land,LLC Prepared-By: North Carolina
Recorded in Book 2383 Pages 162 and 165 Department of
Associated plat recorded in Plat Book-55 , Page l owl Environment and
flail To: Kilpatrick Stockton LLP, 3737 Glenwood Avenue,
Natural Resources
Suite 400 NOTICE OF BROWNFIELDS PROPERTY
Raleigh, NC 27612
This documentary component of a Notice of Brownfields Property("Notice"),as well as
the plat component, have been filed this 17th day of May , 2006 by Leland
Land, LLC (hereinafter"Prospective Developer").
The Notice concerns contaminated property.
A copy of this Notice certified by the North Carolina Department of Environment and
Natural Resources (hereinafter "DENR") is required to be filed in the Register of Deeds'
Office in the county or counties in which the land is located, pursuant to North Carolina
General Statutes (hereinafter"NCGS"),Section (hereinafter"§") 130A-310.35(b).
This Notice is required by NCGS § 130A-310.35(a),in order to reduce or eliminate the
danger to public health or the environment posed by environmental contamination at a
property (hereinafter the "Brownfields Property") being addressed under the Brownfields
Property Reuse Act of 1997,NCGS § 130A,Article 9, Part 5 (hereinafter the"Act").
Pursuant to NCGS § 130A-310.35(b), the Prospective Developer must file a certified
copy of this Notice within 15 days of Prospective Developer's receipt of DENR's approval of
the Notice or Prospective Developer's entry into the Brownfields Agreement required by the
Act,whichever is later. Pursuant to NCGS § 130A-310.35(c),the copy of the Notice certified
by DENR must be recorded in the grantor index under the names of the owners of the land
and, if Prospective Developer is not the owner, also under Prospective Developer's name.
The Brownfields Property is located at 1901 Wood Treatment Road in Leland, Brunswick
County,North Carolina, and consists of approximately 120 acres. The site has been used for wood
treatment since 1979;before that time it was undeveloped land. The intended use of the Brownfields
Property is for continuation of wood treatment activities, although other industrial uses may be
approved by DENR.
1

Inst # 330867 Book 2390Page: 1387
The Brownfields Agreement between Prospective Developer and DENR is attached
hereto as Exhibit A. It sets forth the use that may be made of the Brownfields Property and
the measures to be taken to protect public health and the environment, and is required by
NCGS § 130A-310.32.
Attached hereto as Exhibit B is a reduction, to 8 1/2" x 11", of the survey plat required by
NCGS § 130A-310.35(a). It is a plat of areas designated by DENR that has been prepared and
certified by a professional land surveyor and that meets the requirements of NCGS § 47-30. That
plat contains the following information required by NCGS § 130A-310.35(a):
(1)The location and dimensions of the areas ofpotential environmental concern with respect
to permanently surveyed benchmarks.
(2)The type,location and quantity of regulated substances and contaminants known to exist
on the Brownfields Property. The following table also sets forth the type and quantity of such
substances:
GROUNDWATER CONTAMINANTS (in µg/L or parts per billion)
Concentration
Date of Max. Max. Date of at most Recent Standard
Groundwater Sample Concentration Most Recent
Concentration Sampling
Contaminant Location Sampling above Std. Sampling Event(µg/L) (µgo")
(µg2)
B-4s 12/19/01 479 06/21/02 13.8
B-4d 12/19/01 20 03/04/04 <10
POC-4 06/21/02 1,460 03/04/04 482
B-7s 03/91 650 03/92 150
B-7d 03/91 20 12/91 <10
B-8s 03/04/04 1,300 03/04/04 1,300
B-8d 12/19/01 459 03/04/04 <10
B-8m 2/93 2,100 03/04/04 923
B-8n 12/19/01 330 03/04/04 52.7
POC-8 11/11/99 70.9 03/04/04 25.9
Arsenic B-9s 6/91 1,000 07/10/03 162 10
B-9d 3/96 458 03/04/04 <10
B-9m 12/19/01 227 03/04/04 <10
POC-9 11/11/99 322 03/04/04 60.5
B-10s 9/92 560 03/04/04 130
B-10d 12/19/01 32.5 03/04/04 <10
B-10m 12/19/01 71.8 03/04/04 <10
POC-10 11/11/99 243 03/04/04 164
G-2 01/04/01 120
2

Inst # 330867 Book 2390Page.- 1388
GROUNDWATER CONTAMINANTS (in µg/L or parts per billion)
Max. Date of Concentration
Groundwater Sample Concentration Most Recent
Date of Max. at most Recent Standard
Concentration Sampling
Contaminant Location Sampling above Std. Sampling Event(µg/L) (µme-)
(µgo-)
G-7 01/05/01 394
G-8 01/05/01 1,440
Arsenic G-9 01/05/01 390 * * 10
MW-C4 05/18/04 250
MW-05 05/18/04 36
G-7 01/05/01 2.5
Benzene G-8 01/05/01 105 * * 1
G-9 01/05/01 1,050
WS-3 02/09/04 1.9
Benzo[a]anthracene G-7 01/05/01 7.2 * * 0.0479
G-3 01/04/01 12
Benzo[a]pyrene G-4 01/04/01 4.71 * * 0.00479
G-7 01/05/01 4.59
Benzo[b]fluoranthene G-7 01/05/01 7.4 * * 0.0479
Benzo[k]fluoranthene G-7 01/05/01 5.66 * * 0.479
B-6 12/92 90 03/04/04 <10
B-7s 8/89 100 12/91 <10
B-8s 12/89 90 03/04/04 41.3
B-8m 12/98 288 03/04/04 14.7
Chromium B-8n 12/93 70 03/04/04 <10 50
B-9s 12/89 90 03/04/04 <10
B-9m 2/93 160 03/04/04 <10
B-10s 8/89 60 03/04/04 <10
G-9 01/05/01 123
Chrysene G-7 01/05/01 9.41 * * 4.79
Ethylbenzene G-9 01/05/01 255 * * 29
Indeno[1,2,3-cd] G-7 01/05/01 2.85 * * 0.0479
pyrene
4-isopropyltoluene POC-10 11/11/99 5 03/04/04 <10 No 2L
Std.
Lead MW-C2 05/18/04 21 * * 15
2-methyl phenol B-8s 8/89 59 03/04/04 <10
(o-cresol) B-10s 12/19/01 27 03/04/04 <10 No 2L
Std.
POC-10 06/21/02 14 03/04/04 <10
3

nst # 330867 Book 2390Page: 1389
GROUNDWATER CONTAMINANTS (in µg/L or parts per billion)
Concentration
Date of Max. Max. Date of at most Recent
Groundwater Sample Concentration Most Recent Standard
Contaminant Location Concentration above Std. Sampling Sampling (µg/L)
Sampling (µg/L) Event(µg/L)
B-8s 8/89 110 3/4/04 <10
4-methyl phenol B-8m 6/97 35 3/4/04 <10
(p-creosol) B-8n 9/97 38 3/4/04 <10 3.5
B-10m 9/92 32 3/4/04 <10
B-10s 12/19/01 43 3/4/04 <10
4-methyl phenol POC-10 6/21/02 26 3/4/04 <10 3.5
Methyl-tert-butyl ether G-9 01-05-01 232 01/05/01 232 200
(MTBE)
B-10s 06/11/01 71 03/04/04 <1
POC-10 06/21/02 97 03/04/04 <1
G-6 01/05/01 23.6
G-7 01/05/01 50
Naphthalene G-8 01/05/01 52 * * 21
G-9 01/05/01 112
WS-1 02/09/04 33
PM-2 12/98 99
B-8s 3/94 850 03/04/04 <10
Pentatchlorophenol B-8m 03/12/98 120 03/04/04 <10 0.3
G-4 01/04/01 102 * * 0.3
1,2,4- G-9 01/05/01 402 * * 350
Trimethylbenzene
Xylenes G-9 01/05/01 1,030 * * 530
*Only one sample was taken from subject locations, some of which are single sample Geoprobe points and some of
which are recently installed monitoring wells,or the most recent sample was also the maximum concentration.
SOIL CONTAMINANTS in mg/kg or parts per million
Soil Sample Depth Date of Max. Max. Conc. Unrestricted
Contaminant Location Concentration above Std. Use Levels
Sampling (mg/kg) (mg/kg)
1-5 0-2" 05/10/04 6.1
1-15 0-2" 05/10/04 64
Arsenic 1-33 0-2" 05/10/04 110 4.4
2-6 0-2" 05/10/04 16
3-22 0-2" 05/10/04 42
3-34 0-2" 05/11/04 20
4

Inst # 330867 Book 2390Page: 1390
SOIL CONTAMINANTS in mg/kg or parts per million
Soil Sample Depth Date of Max. Max. Conc. Unrestricted
Contaminant Location Concentration above Std. Use Levels
Sampling (mg/kg) (mg/kg)
4-5 0-2" 05/10/04 18
5-2 0-2" 05/11/04 43
5-8 0-2" 05/10/04 19
5-11 0-2" 05/10/04 26
2-9 0-2" 09/29/04 14
2-8 0-2" 09/29/04 9.8
1-10 0-2" 09/29/04 16
6-2 0-2" 09/29/04 15
6-4 0-2" 09/29/04 32 ,
1-20 0-2" 09/29/04 51
Arsenic 1-35 0-2" 09/29/04 12 4.4
3-25 0-2" 09/29/04 36
3-32 0-2" 09/29/04 16
3-8 0-2" 09/29/04 11
3-5 0-2" 09/29/04 89
6-36 0-2" 09/29/04 5.2
6-28 0-2" 09/29/04 10
6-23 0-2" 09/29/04 12
6-22 0-2" 09/29/04 12
S-2 2' 12/19/00 9.86
S-3 2' 12/19/00 6.04
S-4 2' 12/19/00 • 4.63
C9-C10 Aromatics HS-SW-30 2.5' 06/28/04 660 469
HS-SW-50 3.5' 04/20/04 1,100
HS-NW-28 3.0' 06/28/04 1,300
C11-C22 Aromatics HS-SW-30 2.5' 06/28/04 1,000 469
HS-SW-60 3.0' 06/28/04 790
HS-SW-36 3.0 06/28/04 470
HS-SE-28 2.5' 06/28/04 520
1-15 0-2" 05/10/04 140
1-33 0-2" 05/10/04 150
Chromium 2-6 0-2" 05/10/04 37 30
3-22 0-2" 05/10/04 52
3-34 0-2" 05/11/04 36
5

inst # 330867 Book 2390Page: 1391
SOIL CONTAMINANTS in mg/kg or parts per million
Soil Sample Depth Date of Max. Max. Conc. Unrestricted
Contaminant Location Concentration above Std. Use Levels
Sampling (mg/kg) (mg/kg)
4-5 0-2" 05/10/04 43
5-2 0-2" 05/11/04 76
Chromium 5-8 0-2" 05/10/04 30 30
5-11 0-2" 05/10/04 47
1-33 0-2" 05/10/04 56
2-6 0-2" 05/10/04 17
1-3 0-2" 05/10/04 56
2-6 0-2" 05/10/04 17
Pentachlorophenol 3-34 0-2" 05/11/04 3.4 3
4-5 0-2" 05/10/04 42
5-2 0-2" 05/10/04 41
5-2 0-2" 05/10/04 41
HS-N-10 0.5-l' 02/29/04 53
HS-N-20 0.5 - l' 02/29/04 220
HS-N-20 3 - 3.5' 02/29/04 51
HS-W-10 1 - 1.5' 02/29/04 390
HS-W-10 1.5 - 2' 02/29/04 960
HS-W-10 3 - 3.5' 02/29/04 1,600
HS-W-20 1 - 1.5' 02/29/04 1,000
Total Petroleum HS-W-20 1.5 -2' 02/29/04 480
Hydrocarbons - HS-W-20 3-3.5' 02/29/04 140 10
Gasoline Range * HS-S-10 1-1.5' 02/29/04 1,800
HS-S-10 1.5-2' 02/29/04 19400
HS-S-10 3-3.5' 02/29/04 710
HS-S-20 1-1.5' 02/29/04 120
HS-S-20 1.5-2' 02/29/04 660
HS-S-20 3-3.5' 02/29/04 510
HS-E-10 1-1.5' 02/29/04 37
HS-E-10 1.5-2' 02/29/04 3,900
HS-E-10 3-3.5' 02/29/04 1,300
Total Petroleum HS-N-10 0.5 - 1' 02/29/04 260
Hydrocarbons - HS-N-10 1-2' 02/29/04 700 40
Diesel Range* HS-N-10 3.5-4' 02/29/04 4,500
HS-N-20 0.5 - 1' 02/29/04 3,800
6

Inst # 330867 Book 2390Page: 1392
SOIL CONTAMINANTS in mg/kg or parts per million
Soil Sample Depth Date of Max. Max. Conc. Unrestricted
Contaminant Location Concentration above Std. Use Levels
Sampling (mg/kg) (mg&g)
HS-N-20 1.5-2' 02/29/04 170
HS-N-20 3-3.5' 02/29/04 2,000
HS-W-10 1-1.5' 02/29/04 1,500
HS-W-10 1.5-2' 02/29/04 3,900
HS-W-10 3-3.5' 02/29/04 8,200
HS-W-20 1 - 1.5' 02/29/04 4,600
HS-W-20 1.5 - 2' 02/29/04 3,700
HS-W-20 3-3.5' 02/29/04 18,000
Total Petroleum HS-S-10 1-1.5' 02/29/04 5,500
Hydrocarbons - HS-S-10 1.5-2' 02/29/04 4,900 40
Diesel Range* HS-S-10 3-3.5' 02/29/04 3,200
HS-S-20 1-1.5' 02/29/04 1,800
HS-S-20 1.5-2' 02/29/04 7,100
HS-S-20 3-3.5' 02/29/04 4,700
HS-E-10 0.5 - 1' 02/29/04 1,500
HS-E-10 1.5-2' 02/29/04 4,900
HS-E-10 3-3.5' 02/29/04 3,200
HS-E-20 1-1.5' 02/29/04 3,000
HS-E-20 1.5-2' 02/29/04 760
HS-E-20 3-3.5' 02/29/04 140
S-5 2' 12/19/00 5,490
*The TPH-contaminated soil will be remediated through excavation per paragraph 14 of this agreement.
SOIL CONTAMINANTS in ng/kg or parts per trillion
Soil Sample Depth Date of Max. Maximum Unrestricted
Contaminant Location Concentration Conc. Use Levels
Sampling above Std. (ng/kg)
n
1-5 0-2" 05/10/04 574
1-15 0-2" 05/10/04 709
2,3,7,8-TCDD TEQ 1-33 0-2" 05/10/04 819 4
(total dioxins) 2-6 0-2" 05/10/04 6,050+
3-22 0-2" 05/10/04 118
3-34 0-2" 05/11/04 1,020
7

Inst # 330867 Book 2390Page: 1393
SOIL CONTAMINANTS in ng/kg or parts per trillion
Soil Sample Depth Date of Max. Maximum Unrestricted
Contaminant Location Concentration Conc. Use Levels
Sampling above Std. (ng/kg)
(ng/kg)
4-5 0-2" 05/10/04 1,180
5-2 0-2" 05/11/04 1,720
5-8 0-2" 05/10/04 167
5-11 0-2" 05/10/04 96.5
6-19 0-2" 09/29/04 41.8
6-22 0-2" 09/29/04 60.5
6-9 0-2" 09/29/04 72.9
2-9 0-2" 09/29/04 3,260+
2-8 0-2" 09/29/04 138
1-10 0-2" 09/29/04 1,610
6-2 0-2" 09/29/04 162
2,3,7,8-TCDD TEQ 6-4 0-2" 09/29/04 520 4
(total dioxins) * 1-20 0-2" 09/29/04 835
1-35 0-2" 09/29/04 229
3-25 0-2" 09/29/04 396
3-32 0-2" 09/29/04 225
3-8 0-2" 09/29/04 142
3-5 0-2" 09/29/04 458
6-36 0-2" 09/29/04 45.1
6-28 0-2" 09/29/04 117
6-23 0-2" 09/29/04 40.8
6-32 0-2" 09/29/04 34.4
6-30 0-2" 09/29/04 53.8
6-14 0-2" 09/29/04 44.9
* Analytical results of 17 congeners of dioxins/furans are multiplied by the applicable TEF,then totaled,to
obtain the 2,3,7,8-TCDD TEQ or total dioxin value
+Grids to be capped per paragraph 12 of this Agreement
8

inst # 330867 Book 2390Page: 1394
SURFACE WATER CONTAMINATION in ug/L or parts per billion
Surface Water Sample Date of Maximum Maximum Standard
Contaminant Location* Concentration Concentration above (µg/L)
Sampling Standard(µ/L
W-1 12/19/00 348
Arsenic W-2 12/19/00 164 10
Outfall 09/10/02 106
Chromium W-1 12/19/00 256 50
Outfall 02/12/01 119
Copper W-1 12/19/00 172 7
Outfall 02/12/01 66
* W-1 and W-2 were sampled in on-site ditches. The outfall data(from a NPDES stormwater
outfall) are reported separately as they are considered representative of surface water leaving the
site; the outfall is regulated under stormwater discharge permit#NCS000222 issued by DENR's
the Division of Water Quality.
Attached hereto as Exhibit C is a legal description of the Brownfields Property that would
be sufficient as a description of the property in an instrument of conveyance.
LAND USE RESTRICTIONS
NCGS 130A-310.35(a)also requires that the Notice identify any restrictions on the current
and future use of the Brownfields Property that are necessary or useful to maintain the level of
protection appropriate for the designated current or future use of the Brownfields Property and that
are designated in the Brownfields Agreement. The restrictions shall remain in force in perpetuity
unless canceled by the Secretary of DENR(or its successor in function), or his/her designee,
after the hazards have been eliminated,pursuant to NCGS§130A-310.35(e). All references to
DENR shall be understood to include any successor in function. The restrictions are hereby
imposed on the Brownfields Property, and are as follows:
1. No use may be made of the Brownfields Property other than for industrial wood
treatment,in the area designated"PROCESS AND STORAGE AREA"on the plat component
of this Notice (Exhibit B hereto),without the prior written approval of DENR. No use may
occur of any part of the Brownfields Property outside the "PROCESS AND STORAGE
AREA" without the prior written approval of DENR. In deciding whether to approve
proposed other uses of any part of the Brownfields Property,DENR may consider the risks to
public health and the environment presented by such proposed uses and may require
additional information relating to such risks, including without limitation a worker-related
risk assessment and environmental sampling results, to be provided. The"PROCESS AND
STORAGE AREA"shall remain configured as it is as of the date of recordation of this Notice,
unless DENR issues prior written approval to configure it otherwise. For purposes of this
restriction,the following definitions apply:
a. "Industrial"refers to manufacturing and processing operations that may
produce greater than average levels of noise,vibration,dust,smoke or emissions,and that may
include outdoor storage.
9

Inst # 330867 Book 2390ge: 1395
b. "Wood treatment"refers to the pressure treating,by use of chemicals,ut
lumber, poles and other wood products for outdoor use. Creosote may not be employed for
wood treatment or any other purpose at the Brownfields Property without the express prior
written approval of DENR.
2.a. No naturally occurring water on or under the Brownfields Property may be
used for any purpose,and no activities that encounter,expose or remove naturally occurring
water on or under the Brownfields Property may occur, except that water from any of the
Brownfields Property's three(3)water supply wells,denominated"WS-1,""WS-2"and"WS-
3"on the plat component of this Notice(Exhibit B hereto),or any well approved by DENR to
replace an existing water supply well and depicted on an amended plat, may be used for
process water, rinsing off equipment, flushing toilets, washing hands and any other use
approved in advance in writing by DENR,under the following conditions:
i. no less frequently than every three (3) years, unless the requirements or
frequency of such sampling are modified in writing in advance by DENR,the water in the well
has been sampled for volatile organic compounds("VOCs"),semi-volatile organic compounds
("SVOCs") and metals regulated by RCRA (arsenic, barium, cadmium, chromium, lead,
mercury, selenium and silver), pursuant to the most current version of U.S. Environmental
Protection Agency Method SW-846;
I analysis of said sampling,by a laboratory certified by the Laboratory Section
of DENR's Division of Water Quality, has been submitted to DENR;
iii. that analysis reflects concentrations of benzene (a (VOC) below 0.106
milligrams per liter and concentrations of naphthalene(a SVOC) below 7.49 milligrams per
liter;
iv. sampling results reflect benzene concentrations that remain below the safe
use standard of 0.106 milligrams per liter and naphthalene concentrations that remain below
the safe use standard of 7.49 milligrams per liter, if sampling of a well reflects concentrations
of either contaminant that exceed those levels,water from that well may not be used for hand-
washing or any other activity that involves bodily contact with the water unless and until
concentrations of both contaminants are below the required levels; if sampling of a well
reflects concentrations of any other VOC, SVOC or RCRA metal that exceed the applicable
standard in Title 15A of the North Carolina Administrative Code, Subtitle 2L, Rule .0202
("2L"), water from that well may not be used for hand-washing or any other activity that
involves bodily contact with the water unless and until a safe use standard for such VOC,
SVOC or RCRA metal has been proposed to, and approved in writing by, DENR and the
concentration of such VOC, SVOC or RCRA metal is below the safe use standard.,
v. Signs in English and Spanish that state, "THIS WATER MAY NOT BE
USED FOR DRINKING AND MAY ONLY BE USED FOR ,"with the use(s)
approved by DENR stated in the blank,are prominently displayed in close proximity to points
where water is available from any of the wells whose use is approved by DENR;the owner of
any part of the Brownfields Property containing any of the wells with no approved uses shall
10

Inst 0 330867 Book 2390Page: 1396
ensure that signs that state"DO NOT USE THIS WATER"are prominently displayed in close
Proximity to points where water is available from such well(s).
A If groundwater in a well exceeds a safe use standard established in or
pursuant to subparagraph 2.a.iii. above (or, in the absence of a safe use standard, a 2L
standard),and DENR determines that abandonment of the well is necessary to protect public
health and the environment, DENR may require the owner of the part of the Brownfields
Property containing that well to abandon the well and document said abandonment to DENR
b. Any replacement wells installed pursuant to this subparagraph 19.b. shall be
sampled in accordance with subparagraph 19.b.i. above no more than one year prior to their
being placed in use.
3. Soil underlying buildings and impervious surfaces,including paved areas,at the
Brownfields Property,as identified on the plat component of this Notice(Exhibit B hereto),soil
underlying the area denominated"PETROLEUM HOTSPOT"on the plat component of this
Notice (unless DENR has issued written approval of the remediation of said area), and soil
proposed to be exposed in connection with any construction on the Brownfields Property,may
not be exposed unless DENR has been provided a minimum of ten(10)business days advance
written notice and has given prior written approval to a plan to protect public health and the
environment during the activities that would expose such soil. DENR may inspect,and require
screening or sampling for contaminants in, the exposed soil. If such screening or sampling
discloses contamination that DENR determines may pose an unacceptable level of risk to
public health or the environment, as much soil as DENR requires shall be removed and
disposed of in accordance with applicable law, and any other actions DENR requires for
protection of public health and the environment in view of the permitted uses of the
Brownfields Property shall be taken. If DENR determines that the exposed soil is
contaminated at levels that would not pose an unacceptable risk to public health or the r
environment if capped,DENR may require the soil to be capped,with perpetual maintenance
of the cap,to the satisfaction of DENR.
4. None of the four areas designated"HWMU"on the plat component of the Notice
(Exhibit B hereto) may be disturbed without the prior written approval of DENR on such
conditions as DENR deems appropriate.
5. Soil, landscaping and contours at the Brownfields Property may not be
disturbed without the approval of DENR, except for mowing and pruning of above-ground
vegetation, and, notwithstanding Land Use Restriction number 3 above, routine surface
grading with flat-bladed equipment that does not significantly alter surface contours or
involve excavation.
6. No mining may be conducted on or under the Brownfields Property,including,
without limitation,extraction of coal,oil,gas or any other minerals or non-mineral substances.
7. The Brownfields Property may not be used as a park or for sports of any kind,
including, but not limited to, golf, football, soccer and baseball, without the prior written
approval of DENR.
11

tnst # 330867 Book 2390Page: 1397
8. The Brownfields Property may not be used for agriculture, grazing or
silviculture.
9. The Brownfields Property may not be used as a playground, or for child care
centers or schools.
10. The Brownfields Property may not be used for kennels,private animal pens or
horse-riding.
11. No basements may be constructed on the Brownfields Property.
12. No party conducting environmental assessment or remediation at the
Brownfields Property at the direction of DENR,or pursuant to this Agreement or a permit or
order issued by DENR, and no party installing capital improvements required by this
Agreement,may be denied access to the Brownfields Property for purposes of conducting such
assessment or remediation, or installing such improvements.
13. During January of each year after this Agreement becomes effective,the then
current owner of any part of the Brownfields Property shall submit a notarized Land Use
Restrictions Update("LURU")to DENR that includes a certification that this Notice remains
recorded at the Brunswick County Register of Deeds office and that these Land Use
Restrictions are being complied with,and that is accompanied by copies of the previous year's
pages from the log book required by paragraph 13 of Exhibit A hereto. Depending on the
year, and the portion of the Brownfields Property, the LURU shall also include (the
paragraphs referenced are in Exhibit A hereto):
a. a perimeter monitoring/sentry well analytical report (subparagraph
16.d.
b. analysis of water supply well sampling(subparagraph 19.b.ii.);
C. soil sampling results (paragraph 15),
d. an update on work with DENR's Aquifer Protection Section(paragraph
11) until documentation of"No Further Action" status is received; and
e. inspection and maintenance log/photographs for the previous calendar
year(paragraph 13).
For purposes of the land use restrictions set forth above,the DENR point of contact shall be
the DENR official referenced in paragraph 42.a. of Exhibit A hereto, at the address stated
therein.
ENFORCEMENT
12

Inst # 330867 ]Book 2390Page: 1.398
The above land use restrictions shall be enforceable without regard to lack ofprivity of estate
or contract,lack of benefit to particular land,or lack of any property interest in particular land. The
land use restrictions shall be enforced by any owner of the Brownfields Property. The land use
restrictions may also be enforced by DENR through the remedies provided in NCGS 130A,Article 1,
Part 2 or by means of a civil action;by any unit of local government having jurisdiction over any part
of the Brownfields Property;and by any person eligible for liability protection under the Brownfields
Property Reuse Act who will lose liability protection if the restrictions are violated.Any attempt to
cancel any or all of this Notice without the approval of the Secretary of DENR(or its successor in
function),or his/her delegate,shall be subject to enforcement by DENR to the full extent of the law.
Failure by any party required or authorized to enforce any of the above restrictions shall in no event
be deemed a waiver of the right to do so thereafter as to the same violation or as to one occurring
prior or subsequent thereto.
FUTURE SALES,LEASES, CONVEYANCES AND TRANSFERS
When any portion of the Brownfields Property is sold, leased, conveyed or transferred,
pursuant to NCGS § 130A-310.35(d) the deed or other instrument of transfer shall contain in the
description section, in no smaller type than that used in the body of the deed or instrument, a
statement that the Brownfields Property has been classified and, if appropriate, cleaned up as a
brownfields property under the Brownfields Property Reuse Act.
IN WITNESS WHEREOF, Prospective Developer has caused this instrument to be duly
executed this ,ten
day of ,► 1Q _, 2006.
Leland Lfan�d,, LLC
By: t'-
Name typed or printe : . Michael Johnson
Member/Manager
NORTH
COUNTY
eve h
I, U • J O rAh, a Notary Public of the county and state aforesaid,certify
that R. Michael Johnson personally came before me this day and acknowledged that he/she is a
Member of Leland Land,LLC,a North Carolina limited liability corporation,and its Manager,and
that by authority duly given and as the act of the corporation, the foregoing Notice of Brownfields
Property was signed in its name by him/her.
es"Moda"Re�
WITNESS ��'�J stamp or s al, this c� day of Y►� t 2006.
T a is
Name typed or prin : t4t(*,,, 6• ;:))r06 a,
!C Notary Public
m
Isaps.

Inst # 330867 Book 2390Page: 1399
My Commission expires:
[Stamp/Seal]
APPROVAL AND CERTIFICATION OF NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
The foregoing Notice of Brownfields Property is hereby approved and certified.
North Carolina Department of Environment and Natural Resources
By: x ��riF� �, oIOIJ�Q
Linda M. Culpepper Date
Deputy Director, Division of Waste Management
CERTIFICATION OF REGISTER OF DEEDS
The foregoing documentary component of the Notice of Brownfields Property, and the
associated plat, are certified to be duly recorded at the date and time, and in the Books and Pages,
shown on the first page hereof.
Register of Deeds for Brunswick County
By:
Date
Name typed or printed:
Deputy/Assistant Register of Deeds
14

Inst # 330867 Boos 2390Page: 1400
EXHIBIT A
NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
IN THE MATTER OF: Leland Land LLC
UNDER THE AUTHORITY OF THE ) BROWNFIELDS AGREEMENT re:
BROWNFIELDS PROPERTY REUSE ACT OF ) General Wood Site
1997, N.C.G.S. 130A-310.30, et seq. ) 1901 Wood Treatment Road
BF Project Number 07003-03-10 ) Leland, Brunswick County
I. INTRODUCTION
This Brownfields Agreement ("Agreement") is entered into by the North Carolina
Department of Environment and Natural Resources' Brownfields Program("DENR") and Leland
Land LLC (collectively the"Parties")pursuant to the Brownfields Property Reuse Act of 1997,
N.C.G.S. § 130A-310.30, et Le . (the "Act").
Leland Land LLC is a member-managed North Carolina limited liability company that
was formed on January 31, 2002. Its member-manager is Carolina Pole, Inc., a wholly owned
subsidiary of Cox Industries, Inc. Its registered agent is Steven J. Levitas,whose registered
address is 3737 Glenwood Avenue, Suite 400,Raleigh,NC, 27612. This Agreement concerns an
approximately 120-acre property in Leland, Brunswick County,North Carolina, that has been the
site of wood treatment operations since 1979. A map showing the location of that property is
attached hereto as Exhibit 1.
The Parties agree to undertake all actions required by the terms and conditions of this
Agreement. The purpose of this Agreement is to settle and resolve, subject to reservations and
limitations contained in Section VIII(Certification), Section IX(DENR's Covenant Not to Sue
and Reservation of Rights) and Section X(Prospective Developer's Covenant Not to Sue),the
potential liability of Leland Land LLC for contaminants at the property which is the subject of
this Agreement.
Gen.Wood BFA

InstF # 330867 Book 2390Page: 1401
The Parties agree that Leland Land LLC's entry into this Agreement, and the actions
undertaken by Leland Land LLC in accordance with the Agreement, do not constitute an
admission of any liability by Leland Land LLC.
The resolution of this potential liability, in exchange for the benefit Leland Land LLC
shall provide to DENR by addressing the contamination at the subject property, is in the public
interest.
H. DEFINITIONS
Unless otherwise expressly provided herein,terms used in this Agreement which are defined
in the Act or elsewhere in N.C.G.S. 130A,Article 9 shall have the meaning assigned to them in those
statutory provisions, including any amendments thereto.
1. "Property" shall mean the Brownfields Property which is the subject of this
Agreement, and which is depicted in Exhibit 1 of the Agreement.
2. "Prospective Developer" shall mean Leland Land LLC.
III. STATEMENT OF FACTS
3. The Property consists of approximately 120 acres; its address is 1901 Wood
Treatment Road, Leland, North Carolina 28451. Prospective Developer has committed itself to
its redevelopment only for uses that comply with paragraph 19.a. below.
4. The Property is bordered to the north by tracks of the Seaboard Coast Line
Railroad, across which lie properties zoned industrial (though, in the small wedge of land
between the Seaboard railroad and U.S. Highway 74-76, only a parcel occupied by"Industrial
Pump Service"is developed); to the south by undeveloped property owned by Hugh Morton and,
along the Sunny Point Railroad, the United States; to the east by tracks of the Sunny Point
Gen.Wood BFA 2

Inst # 330867 Book 2390Page: 1402
Railroad, across which lies property in industrial use (by"Coatings and Adhesives
Manufacturing") and undeveloped property owned by the N.C. Agricultural Foundation; and to
the west by property used industrially by Pressure Chemical Company and undeveloped property.
5. Prospective Developer obtained or commissioned the following reports, referred
to hereinafter as the`Environmental Reports,"regarding the Property:
Title Prepared by Date of Report
Permit Application for Post-Closure Care, Babb &Associates, P.A. February 1996,revised
General Wood Preserving Company, Inc. January 1998
EPA ID#NCD 093 13 7 636
Phase I and Phase II Environmental Site GEL Environmental January 22, 2001
Assessment, General Wood Preserving Consulting, Inc.
-Company, Inc., Leland, North Carolina
Supplemental Information, General Wood GEL Environmental January 22, 2003
-Preserving Company, Inc. Consulting, Inc.
Project Workplan for Resolution of MACTEC Engineering and December 15, 2003,
Brownfields Issues at the General Wood Consulting, Inc. revised February 17,
Preserving Site, Leland, North Carolina 2004
Assessment Report of Resolution of MACTEC Engineering and December 7, 2004,
Brownfields Issues at the General Wood Consulting, Inc. revised February 23,
-Preserving Site, Leland, North Carolina 2005
6. For purposes of this Agreement,DENR relies on the following representations by
Prospective Developer as to use, ownership and environmental regulation, assessment and
remediation of the Property:
a. The Property is currently owned by General Wood Preserving Company,
Inc. ("General Wood"), which has been in Chapter 11 bankruptcy since December 8, 2000 and
which remains in operation due to the financial support of Carolina Pole, Inc. (A forty(40)-foot
strip along the Property's southern boundary that is owned by Hugh Morton will become part of
the Property if Prospective Developer acquires it upon acquiring the rest of the Property; it is
dealt with in Exhibit 1 hereto, as well as in the plat component, and Exhibit C to the
Gen.Wood BFA 3

Inst # 330867 Book 2390Page: 1403
documentary component, of the Notice referenced below in paragraph 28 below. See
subparagraph 16.b.below.) The Property is currently regulated as a treatment, storage and
disposal facility by DENR's Hazardous Waste Section(with EPA identification number NCD
093 137 636), and is currently covered by a Consent Order issued by that Section.
b. Four hazardous waste management units ("HWMUs")were closed in
1992; they appear as "Junk Pile,""Old Impoundment,""Burn Pile" and"Drying Kiln Ditch"on
the plat component of the Notice referenced below in paragraph 28. The first three HWMUs
were excavated to the water table, filled with clean soil, compacted such that the soil met a
hydraulic conductivity range of 10-5 to 10"6 centimeters per second, vegetated with grass and
surrounded with barbed wire fencing. "Drying Kiln Ditch"was also excavated to the
groundwater table and backfilled with clean soil to the same hydraulic conductivity range; it was
then covered with a cap consisting of a geotextile, 12 inches of#57 stone and 10 inches of
concrete, and modified to allow vehicular traffic. The HWMUs are currently managed under a
post-closure care plan approved by DENR's Hazardous Waste Section("HWS').
C. Groundwater monitoring is currently being conducted on the Property
under a post-closure care plan approved in 1992 by the HWS. Seven solid waste management
units ("SWMUs")were identified in a"RCRA Facility Assessment" ("RFA"), i.e., an assessment
pursuant to the Resource Conservation and Recovery Act("RCRA"), 42 U.S.C. §6901, et seq.
However,the HWS has agreed that the treated pole storage areas,which were not identified as a
SWMU in the RFA, are the primary areas of concern on the Property. Environmental assessment
of the treated pole storage area has indicated the need for the cap required by paragraph 12
below.
Gen.Wood BFA 4

Inst # 330867 Book 2390Page: 1404
d. Free-phase petroleum hydrocarbons have been identified in groundwater in
the immediate vicinity of the Property's"pole mill." This contamination has been assigned
Incident# 16624 by DENR's Aquifer Protection Section. An assessment indicated that the area
of free-phase and dissolved petroleum product is limited. The most likely source is a hydraulic
belt system formerly located below grade. The belt system has been moved above grade where it
can be visually inspected. General Wood is currently removing free product,which is collected
and transported off-site for disposal, with an automatic skimmer in the well denominated"PM-
IA" on the plat component of the Notice referenced below in paragraph 28.
e. Due to the financial status of the Property's current owner, the HWS has
not issued a RCRA post-closure permit.
f. Prior to 1979, the Property was a wooded lot. The Burke-Parsons-Bowlby
Corporation purchased the Property in 1978 and developed it into a wood treatment facility in
1979, since which time wood treatment has continued there. General Wood purchased the
Property in 1984.
g. The wood treatment facility consists of a drying kiln, steam kiln, drip pad,
boiler building, office building and treatment building that includes pressure treatment cylinders,
a drip pad and above-ground storage tanks. The operational portions of the site are not vegetated,
while the borders of the property are wooded, covered with grass or otherwise vegetated.
h. Currently pentachlorophenol ("PCP") and chromated copper
arsenate("CCA") are the chemicals used in the treatment process that wooden utility poles,
foundation piles and piers, inter alia, undergo. Until approximately 1994, Creosote was used at
the Property for treatment of poles, railroad ties and other products.
Gen.Wood BFA 5

Inst # 330867 Book 2390Page: 1405
7. The most recent environmental sampling at the Property reported in the
Environmental Reports occurred on December 7, 2004; revisions of the data reported were
submitted on February 23, 2005. The following tables set forth, for contaminants present at the
Property above unrestricted use standards,the maximum concentration found at each sample
location and the applicable standard:
a. Groundwater contaminants (in micrograms per liter, the equivalent of parts
per billion), the standards for which are in Title 15A of the North Carolina Administrative Code,
Subchapter 2L,Rule .0202:
Max. Date of Concentration
Groundwater Sample Date of Max. Concentration Most Recent at most Recent Standard
Contaminant Location Concentration above Std. Sampling Sampling (µg/L)
Sampling (µg/L) Event(µg/L)
B-4s 12/19/01 479 06/21/02 13.8
B-4d 12/19/01 20 03/04/04 <10
POC-4 06/21/02 1,460 03/04/04 482
B-7s 03/91 650 03/92 150
B-7d 03/91 20 12/91 <10
B-8s 03/04/04 1,300 03/04/04 1,300
B-8d 12/19/01 459 03/04/04 <10
B-8m 2/93 2,100 03/04/04 923
Arsenic B-8n 12/19/01 330 03/04/04 52.7 10
POC-8 11/11/99 70.9 03/04/04 25.9
B-9s 6/91 1,000 07/10/03 162
B-9d 3/96 458 03/04/04 <10
B-9m 12/19/01 227 03/04/04 <10
POC-9 11/11/99 322 03/04/04 60.5
B-10s 9/92 560 03/04/04 130
B-10d 12/19/01 32.5 03/04/04 <10
B-10m 12/19/01 71.8 03/04/04 <10
POC-10 11/11/99 243 03/04/04 164
G-2 01/04/01 120
Gen.Wood BFA 6

Inst # 330867 Bc>ok 2390Page: 1406
Concentration
Date of Max. Max. Date of at most Recent Standard
Groundwater Sample Concentration Most Recent
Contaminant Location Concentration above Std. Sampling
Sampling (µgo-) Sampling Event(µg/L) (µme)
G-7 01/05/01 394
G-8 01/05/01 1,440
Arsenic G-9 01/05/01 390 * * 10
MW-C4 05/18/04 250
MW-05 05/18/04 36
G-7 01/05/01 2.5
Benzene G-8 01/05/01 105 * * 1
G-9 01/05/01 1,050
WS-3 02/09/04 1.9
Benzo[a]anthracene G-7 01/05/01 7.2 * * 0.0479
G-3 01/04/01 12
Benzo[a]pyrene G-4 01/04/01 4.71 * * 0.00479
G-7 01/05/01 4.59
Benzo[b]fluoranthene G-7 01/05/01 7.4 * * 0.0479
Benzo[k]fluoranthene G-7 01/05/01 5.66 * * 0.479
B-6 12/92 90 03/04/04 <10
B-7s 8/89 100 12/91 <10
B-8s 12/89 90 03/04/04 41.3
B-8m 12/98 288 03/04/04 14.7
Chromium B-8n 12/93 70 03/04/04 <10 50
B-9s 12/89 90 03/04/04 <10
B-9m 2/93 160 03/04/04 <10
B-10s 8/89 60 03/04/04 <10
G-9 01/05/01 123
Chrysene G-7 01/05/01 9.41 * * 4.79
Ethylbenzene G-9 01/05/01 255 * * 29
Indeno[1,2,3-cd] G-7 01/05/01 2.85 * * 0.0479
pyrene
4-isopropyltoluene POC-10 11/11/99 5 03/04/04 <10 No 2L
Std.
Lead MW-C2 05/18/04 21 * * 15
2-methyl phenol B-8s 8/89 59 03/04/04 <10 No 2L
(o-cresol) B-10s 12/19/01 27 03/04/04 <10 Std.
Gen.Wood BFA 7

Inst # 330867 Book 2390Pacge: 1407
ConcentratiW
Date of Max. Max. Date of at most Recent Standard
Groundwater Sample Concentration Most Recent
Concentration Sampling
Contaminant Location Sampling above Std. Sampling Event(µg/L) (µg2')
(µgo-)
2-methyl phenol POC-10 06/21/02 14 03/04/04 <10 No 2L Std.
B-8s 8/89 110 3/4/04 <10
4-methyl phenol B-8m 6/97 35 3/4/04 <10
(p-creosol) B-8n 9/97 38 3/4/04 <10 3.5
B-10m 9/92 32 3/4/04 <10
B-10s 12/19/01 43 3/4/04 <10
POC-10 6/21/02 26 3/4/04 <10
Methyl-tert-butyl ether G-9 01-05-01 232 01/05/01 232 200
(MTBE)
B-10s 06/11/01 71 03/04/04 <1
POC-10 06/21/02 97 03/04/04 <1
G-6 01/05/01 23.6
G-7 01/05/01 50
Naphthalene G-8 01/05/01 52 * * 21
G-9 01/05/01 112
WS-1 02/09/04 33
PM-2 12/98 99
B-8s 3/94 850 03/04/04 <10
Pentatchlorophenol B-8m 03/12/98 120 03/04/04 <10 0.3
G-4 01/04/01 102 * * 0.3
1,2,4- G-9 01/05/01 402 * * 350
Trimethylbenzene
Xylenes G-9 01/05/01 1,030 * * 530
*Only one sample was taken from subject locations, some of which are single sample Geoprobe points and some of
which are recently installed monitoring wells,or the most recent sample was also the maximum concentration.
b. Soil contaminants (except those referenced in subparagraph 7.c. below) in
milligrams per kilogram, the equivalent of parts per million, the standards for which
contaminants are derived using the Guidelines of the Inactive Hazardous Sites Branch of
DENR's Superfund Section:
Gen.Wood BFA 8

Inst # 330867 Book 2390Page„ 14Q8
Soil Sample Depth Date of Max. Max. Conc. Unrestnc
Contaminant Location Concentration above Std. ted Use
Sampling (mg/kg) Levels
(mg/kg)
1-5 0-2" 05/10/04 6.1
1-15 0-2" 05/10/04 64
1-33 0-2" 05/10/04 110
2-6 0-2" 05/10/04 16
3-22 0-2" 05/10/04 42
3-34 0-2" 05/11/04 20
4-5 0-2" 05/10/04 18
5-2 0-2" 05/11/04 43
5-8 0-2" 05/10/04 19
5-11 0-2" 05/10/04 26
2-9 0-2" 09/29/04 14
2-8 0-2" 09/29/04 9.8
1-10 0-2" 09/29/04 16
6-2 0-2" 09/29/04 15
6-4 0-2" 09/29/04 32
Arsenic 1-20 0-2" 09/29/04 51 4.4
1-35 0-2" 09/29/04 12
3-25 0-2" 09/29/04 36
3-32 0-2" 09/29/04 16
3-8 0-2" 09/29/04 11
3-5 0-2" 09/29/04 89
6-36 0-2" 09/29/04 5.2
6-28 0-2" 09/29/04 10
6-23 0-2" 09/29/04 12
6-22 0-2" 09/29/04 12
S-2 2' 12/19/00 9.86
S-3 2' 12/19/00 6.04
S-4 2' 12/19/00 4.63
C9-C10 Aromatics HS-SW-30 2.5' 06/28/04 660 469
C11-C22 Aromatics HS-SW-50 3.5' 04/20/04 1,100 469
HS-NW-28 3.0' 06/28/04 1,300
Gen.Wood BFA 9

tort # 330867 Book 2390Page: 1409
Soil Sample Depth Date of Max. Max. Conc. Unrestric
Contaminant Location Concentration above Std. ted Use
Sampling (mg/kg) Levels
(M&9)
HS-SW-30 2.5' 06/28/04 1,000
C11-C22 Aromatics HS-SW-60 3.0' 06/28/04 790 469
HS-SW-36 3.0 06/28/04 470
HS-SE-28 2.5' 06/28/04 520
1-15 0-2" 05/10/04 140
1-33 0-2" 05/10/04 150
2-6 0-2" 05/10/04 37
3-22 0-2" 05/10/04 52
3-34 0-2" 05/11/04 36
Chromium 4-5 0-2" 05/10/04 43 30
5-2 0-2" 05/11/04 76
5-8 0-2" 05/10/04 30
5-11 0-2" 05/10/04 47
1-33 0-2" 05/10/04 56
2-6 0-2" 05/10/04 17
1-3 0-2" 05/10/04 56
2-6 0-2" 05/10/04 17
Pentachlorophenol 3-34 0-2" 05/11/04 3.4 3
4-5 0-2" 05/10/04 42
5-2 0-2" 05/10/04 41
5-2 0-2" 05/10/04 41
HS-N-10 0.5-l' 02/29/04 53
HS-N-20 0.5 - 1' 02/29/04 220
HS-N-20 3 - 3.5' 02/29/04 51
HS-W-10 1 - 1.5' 02/29/04 390
Total Petroleum HS-W-10 1.5 - 2' 02/29/04 960
Hydrocarbons - HS-W-10 3 - 3.5' 02/29/04 1,600 10
Gasoline Range * HS-W-20 1 - 1.5' 02/29/04 1,000
HS-W-20 1.5 - 2' 02/29/04 480
HS-W-20 3-3.5' 02/29/04 140
HS-S-10 1-1.5' 02/29/04 1,800
Gen.Wood BFA 10

Inst # 330867 Book 2390Page: 1410
Soil Sample Depth Date of Max. Max. Conc. Unrestric
Contaminant Location Concentration above Std. ted Use
Sampling (mg/kg) Levels
(mg/kg)
HS-S-10 1.5-2' 02/29/04 1,400
HS-S-10 3-3.5' 02/29/04 710
HS-S-20 1-1.5' 02/29/04 120
TPH—Gasoline HS-S-20 1.5-2' 02/29/04 660 10
Range * HS-S-20 3-3.5' 02/29/04 510
HS-E-10 1-1.5' 02/29/04 37
HS-E-10 1.5-2' 02/29/04 3,900
HS-E-10 3-3.5' 02/29/04 1,300
HS-N-10 0.5 - l' 02/29/04 260
HS-N-10 1-2' 02/29/04 700
HS-N-10 3.5-4' 02/29/04 4,500
HS-N-20 0.5 - l' 02/29/04 3,800
HS-N-20 1.5-2' 02/29/04 170
HS-N-20 3-3.5' 02/29/04 2,000
HS-W-10 1-1.5' 02/29/04 1,500
HS-W-10 1.5-2' 02/29/04 3,900
Total Petroleum HS-W-10 3-3.5' 02/29/04 8,200
Hydrocarbons- HS-W-20 1 - 1.5' 02/29/04 4,600 40
Diesel Range* HS-W-20 1.5 - 2' 02/29/04 3,700
HS-W-20 3-3.5' 02/29/04 18,000
HS-S-10 1-1.5' 02/29/04 5,500
HS-S-10 1.5-2' 02/29/04 4,900
HS-S-10 3-3.5' 02/29/04 3,200
HS-S-20 1-1.5' 02/29/04 1,800
HS-S-20 1.5-2' 02/29/04 7,100
HS-S-20 3-3.5' 02/29/04 4,700
HS-E-10 0.5 - 1' 02/29/04 1,500
HS-E-10 1.5-2' 02/29/04 4,900
HS-E-10 3-3.5' 02/29/04 3,200
HS-E-20 1-1.5' 02/29/04 3,000
HS-E-20 1.5-2' 02/29/04 760
Gen.Wood BFA 11

Inst # 330867 Book 2390Page: 1411
Soil Sample Depth Date of Max. Max. Conc. Unrestric
Contaminant Location Concentration above Std. ted Use
Sampling (mg/kg) Levels
(mg/kg)
TPH HS-E-20 3-3.5' 02/29/04 140 40
Diesel Range* S-5 2' 12/19/00 5,490
*The TPH-contaminated soil will be remediated through excavation per paragraph 14 of this agreement.
C. Dioxins/furans in soil(in nanograms per kilogram, the equivalent of parts
per trillion),the standards for which are derived using the Guidelines of the Inactive Hazardous
Sites Branch of DENR's Superfund Section, and which were measured using toxicity equivalent
factors ("TEFs")to calculate the toxic equivalency("TEQ") for 2,3,7,8-tetrachlorodibenzo-p-
dioxin("TCDD"):
Soil Sample Depth Date of Max. Maximum Unrestricted
Contaminant Location Concentration Conc. above Use Levels
Sampling Std. (ng/kg) (ng/kg)
1-5 0-2" 05/10/04 574
1-15 0-2" 05/10/04 709
1-33 0-2" 05/10/04 819
2-6 0-2" 05/10/04 6,050 +
3-22 0-2" 05/10/04 118
3-34 0-2" 05/11/04 1,020
4-5 0-2" 05/10/04 1,180
2,3,7,8-TCDD TEQ 5-2 0-2" 05/11/04 1,720 4
(total dioxins) * 5-8 0-2" 05/10/04 167
5-11 0-2" 05/10/04 96.5
6-19 0-2" 09/29/04 41.8
6-22 0-2" 09/29/04 60.5
6-9 0-2" 09/29/04 72.9
2-9 0-2" 09/29/04 3,260 +
2-8 0-2" 09/29/04 138
1-10 0-2" 09/29/04 1,610
Gen.Wood BFA 12

Inst # 330867 Book 2390Page: 1412
Soil Sample Depth Date of Max. Maximum Unrestricted
Contaminant Location Concentration Conc. above Use Levels
Sampling Std. (ng/kg) (ng/kg)
6-2 0-2" 09/29/04 162
6-4 0-2" 09/29/04 520
1-20 0-2" 09/29/04 835
1-35 0-2" 09/29/04 229
3-25 0-2" 09/29/04 396
2,3,7,8-TCDD TEQ 3-32 0-2" 09/29/04 225 4
(total dioxins) * 3-8 0-2" 09/29/04 142
3-5 0-2" 09/29/04 458
6-36 0-2" 09/29/04 45.1
6-28 0-2" 09/29/04 117
6-23 0-2" 09/29/04 40.8
6-32 0-2" 09/29/04 34.4
6-30 0-2" 09/29/04 53.8
6-14 0-2" 09/29/04 44.9
* Analytical results of 17 congeners of dioxins/furans are multiplied by the applicable TEF,then totaled,
to obtain the 2,3,7,8-TCDD TEQ or total dioxin value
+Grids to be capped per paragraph 12 of this Agreement
d. Surface water contaminants (in micrograms per liter, the equivalent of
parts per billion),the standards for which are in Title 15A of the North Carolina Administrative
Code, Subchapter 2B, Section .0200:
Surface Water Sample Date of Maximum Maximum Standard
Contaminant Location* Concentration Concentration above (µg/L)
Sampling Standard(µ/L)
W-1 12/19/00 348
Arsenic W-2 12/19/00 164 10
Outfall 09/10/02 106
Chromium W-1 12/19/00 256 50
Outfall 02/12/01 119
Copper W-1 12/19/00 172 7
Outfall 02/12/01 66
*W-1 and W-2 were sampled in on-site ditches. The outfall data(from a NPDES stormwater outfall)are reported
separately as they are considered representative of surface water leaving the site;the outfall is regulated under
stormwater discharge permit#NCS000222 issued by DENR's the Division of Water Quality.
Gen.Wood BFA 13

Znst # 330867 Book 2390Page: 1413
8. For purposes of this Agreement DENR relies on Prospective Developer's
representations that Prospective Developer's involvement with the Property has been limited to
obtaining or commissioning the Environmental Reports,preparing and submitting to DENR a
Brownfields Letter of Intent dated February 11, 2003, and, on December 23, 2002,contracting to
purchase the Property.
9. Prospective Developer has provided DENR with information, or sworn
certifications regarding that information on which DENR relies for purposes of this Agreement,
sufficient to demonstrate that:
a. Prospective Developer and any parent, subsidiary, or other affiliate has
substantially complied with federal and state laws,regulations and rules for protection of the
environment, and with the other agreements and requirements cited at N.C.G.S. § 130A-
310.32(a)(1);
b. as a result of the implementation of this Agreement, the Property will be
suitable for the uses specified in the Agreement while fully protecting public health and the
environment;
C. Prospective Developer's reuse of the Property will produce a public benefit
commensurate with the liability protection provided Prospective Developer hereunder;
d. Prospective Developer has or can obtain the financial, managerial and
technical means to fully implement this Agreement and assure the safe use of the Property; and
e. Prospective Developer has complied with all applicable procedural
requirements.
Gen.Wood BFA 14

Inst # 330867 Book 2390Pa e: 1414
IV. BENEFIT TO COMMUNITY
10. The redevelopment of the Property proposed herein would provide the following
public benefits:
a. continued productive use of the Property with controls in place to ensure
worker safety in regard to historical soil contamination;
b. preservation of approximately 47 permanent and 7 temporary jobs, and the
addition of 5-10 new jobs, given sufficient production.
C. preservation of, and possibly growth in, tax revenue for affected
jurisdictions;
d. $1,750,000 of capital improvements, consisting of treating plant upgrades,
site work, and new equipment purchases, of which approximately$500,000 is expected to be
expended within ninety(90) days) of Prospective Developer's acquisition of the Property, with
the remainder to be expended within twenty-four(24)months after the effective date of this
Agreement.
e. "smart growth"through use of land in an already developed area,which
avoids moving the wood treatment equipment and reopening the facility in a pristine
"greenfields"area.
V. WORK TO BE PERFORMED
11. Prospective Developer acknowledges that it is obligated to cooperate with
DENR's Aquifer Protection Section regarding the above-referenced"Groundwater Incident" (#
16624) in the Property's pole mill area in pursuit of the granting of"no further action" status by
DENR.
Gen.Wood BFA 15

Inst # 330867 Book 2390Page: 1415
12. On September 6, 2005, Prospective Developer transmitted to DENR a plan for
installation of a permanent cap over the area in the northern portion of the Property designated
"Pole Storage Hot Spot'on the plat component of the Notice referenced below in paragraph 28
(and as grids 2-6 and 2-9 in the Environmental Report dated December 7, 2004). DENR
approved the plan by letter dated February 9, 2006. Within sixty(60) days after the effective date
of this Agreement, Prospective Developer shall implement the plan to DENR's written
satisfaction.
13. Inspections and maintenance:
a. Prospective Developer shall maintain in good repair everything at the
Property that serves a function related to protection of public health and the environment,
including without limitation the places and things referenced in this paragraph, and shall inspect
said places and things no less frequently than quarterly. If this Agreement's effective date is no
later than ten(10)business days prior to the end of a calendar year quarter, Prospective
Developer shall commence the inspections this paragraph requires in that quarter. If this
Agreement's effective date is later than ten(10)business days prior to the end of a calendar year
quarter, Prospective Developer may await the following quarter to commence the inspections.
b. Prospective Developer shall take any measures necessary to maintain in
good repair the following places and things, including without limitation the measures set forth
below,within ten(10)business days after inspection or discovery of deficiencies other than by
inspection,whichever occurs first.
i. Caps: As to the caps referenced in subparagraph 6.b. above
Prospective Developer shall maintain the concrete one such that the clean backfill beneath it does
Gen.Wood BFA 16

Inst # 330867 Book 2390Page: 1416
not erode, and the three (3) vegetated ones by mowing and reseeding as required to prevent
erosion and water ponding from affecting their integrity. As to the cap over the"Pole Storage
Hot Spot"that paragraph 12 above requires Prospective Developer to install pursuant to a plan
approved by DENR, Prospective Developer shall maintain it pursuant to said plan.
ii. Fencing and locks on vehicular gates around the Junk Pile, Old
Impoundment Unit and Burn Pile units: Prospective Developer shall replace any broken or
inoperative fencing or locks.
iii. Perimeter, sentry and DENR's Aquifer Protection Section
monitoring well network: Prospective Developer shall maintain said wells such that they operate
as intended, and, more specifically, shall:
A. replace any broken, inoperative or missing security cap or
lock on any well;
B. fill cracks in any well's concrete seal and grout with a neat
cement mix; and
C. ensure the integrity of surveyed benchmarks:
C. Prospective Developer shall log the date, inspector's name, illustrative
date-stamped photographs and findings regarding all inspections, as well as the dates and
descriptions of all repairs, in a log book that shall be kept in the plant manager's office, and shall
include copies of all log book pages relating to the preceding year's inspections with the annual
Land Use Restrictions Update required by paragraph 19.m. below.
d. Unless DENR requires otherwise as a condition of a change in use of the
Property, Prospective Developer's obligations under this paragraph 13 shall terminate five years
Gen.Wood BFA 17

In,t # 330867 Book 2390Page: 1417
after the date of completion of facility closure (shut down) activities, as determined by the HWS,
or five years after the effective date of this Agreement,whichever is later.
14. On September 6, 2005,Prospective Developer transmitted to DENR a plan for
excavation of the petroleum-contaminated soil, east of the wood treatment area at the Property,
that is delineated in the Environmental Report that paragraph 5 above notes was revised on
February 23, 2005. DENR approved the plan by letter dated February 9, 2006. Within sixty(60)
days after the effective date of this Agreement, Prospective Developer shall implement the plan
to DENR's written satisfaction.
15. Prospective Developer shall effect the sampling required by this paragraph no
sooner than one hundred twenty(120) days prior to ceasing wood treating operations,transferring
the Property or filing for bankruptcy, and in any event within thirty(30) days before or after
every fifth anniversary of the effective date of this Agreement for as long as it owns the Property.
Notwithstanding the foregoing, and except as otherwise provided in this paragraph, if twice the
mean of the results for each of the contaminants sampled for in any fifth anniversary sampling
event(i) does not exceed that contaminant's "DENR-approved worker risk standard"(see tables
in subparagraphs a. and b. of this paragraph), and (ii) does not, as determined by DENR,
represent a statistically significant increase over the prior values, so long as wood treating
operations continue on the Property Prospective Developer shall not be required to perform the
sampling required by this paragraph until the period within thirty(30) days before or after the
tenth anniversary of the prior sampling event. At the same locations sampled in connection with
the most recent Environmental Report referenced in paragraph 5 above, and to DENR's written
satisfaction, Prospective Developer shall sample soil for total dioxins, arsenic and PCP.
Gen.Wood BFA 18

Inst # 330867 Book 2390Page: 1418
Prospective Developer shall effect analysis of the samples by a laboratory certified by the
Laboratory Section of DENR's Water Quality Section, and shall effect submittal of the results to
DENR within a time period established by DENR. If twice the mean of the results for any of the
contaminants sampled for exceeds that contaminant's "DENR-approved worker risk standard"
(see tables in subparagraphs a. and b. of this paragraph),within sixty(60) days after Prospective
Developer receives the results it shall submit to DENR a written plan to bring the twice-the-mean
value of the contaminant(s) in question within the DENR-approved worker risk standard. The
plan shall include a schedule and require a post-implementation written report, and may propose
engineering controls as well as, or in lieu of, active remediation. Prospective Developer shall
implement the plan in the form in which it is approved by DENR. In addition, if soil sampling
results trigger submittal of a plan as described above,the sampling required by this paragraph
shall be performed no less frequently than every five years.
a. The contaminants below are reported in nanograms per kilogram,the
equivalent of parts per trillion.
Maximum Mean after Maximum DENR-
Current Concentration known approved
Concentration 2-6 and 2-9 (ng/kg) capping Contaminant Reported Mean capping grids 2 x mean at site after ca worker risk
g
(ng/kg) (ng/kg) (ng/kg) pole storage hotspot standard
n n
2,3,7,8-TCDD TEQ 6,046 698 415 830 1,720 1,000
total dioxins)* '
* Analytical results of 17 congeners of dioxins/furans are multiplied by their toxicity equivalency factor,
then totaled, to obtain the 2,3,7,8-TCDD toxicity equivalent or total dioxin value.
Gen.Wood BFA 19

Ins . # 330867 Book 2390Page: 1419
b. The contaminants below are reported in milligrams per kilogram, the
equivalent of parts per million:
Maximum Mean
Contaminant Reported (mg/kg) 2 x mean DENR-approved
Concentration (mpg) worker risk standard
(mpg) (mpg)
Arsenic 110 25.6 51.2 100
Pentachlorophenol 56 5.66 11.3 280
16. Other Work
a. No later than when Prospective Developer submits to DENR a copy of the
recorded Notice referenced in paragraph 28 below, Prospective Developer shall submit to the
HWS Part A of the application for a RCRA permit, signed. Prospective Developer shall submit a
copy of the transmittal letter it submits with the foregoing material to the DENR official
identified in paragraph 42 below.
b. Based on DENR's determinations regarding the existing and predicted
extent of contamination originating at the Property, and on a schedule approved by DENR,
Prospective Developer shall determine what area, in addition to the Property, should have
appropriate Land Use Restrictions, as determined by DENR, imposed(hereinafter known as the
"Off-Property LUR Area"). Prospective Developer shall thereafter:
i. in time for timely filing pursuant to N.C.G.S. § 130A-310.35(b) of
the Notice referenced in paragraph 28, acquire fee simple as to the Off-Property LUR Area;
ii. take whatever actions DENR requires in connection with obtaining
written consent to imposition of the subject Land Use Restrictions from all owners of the Off-
Gen.Wood BFA 20

i
Inst # 330867 Book 2390Page: 1420
Property LUR Area; Prospective Developer acknowledges that, in any event, this Agreement will
have no force and effect if Prospective Developer does not timely file,pursuant to N.C.G.S. §
130A-310.35(b),the subject Land Use Restrictions for recordation as part of the Notice
referenced in paragraph 28 below; or
iii. through a combination of the actions described in the foregoing
subparagraphs i. and ii., effect imposition of the subject Land Use Restrictions on the entire Off-
Property LUR Area.
C. After gaining the written permission of affected landowners or fee simple
to the land in question, and in compliance with a schedule approved in writing by DENR,
Prospective Developer shall install sentry wells at locations approved in advance in writing by
DENR that are one year's travel time (based on groundwater velocity)hydraulically upgradient
of the downgradient Land Use Restrictions boundary.
d. During the first calendar quarter after Prospective Developer purchases the
Property, and annually thereafter no sooner than seven(7) days prior to, nor later than seven(7)
days after, the anniversary of the last sampling event, Prospective Developer shall sample for
VOCs, SVOCs and metals regulated by RCRA, the perimeter monitoring wells denominated as
C-1, C-2, C-3, C-4, C-5, B-6 and B-10M on the plat component of the Notice referenced below
in paragraph 28 and the sentry wells required by subparagraph 16.c. above. Prospective
Developer shall effect analysis of said samples using the most current version of U.S.
Environmental Protection Agency Method SW-846. If Prospective Developer satisfies DENR
that particular sentry wells outside the Property are downgradient of particular perimeter
monitoring wells, Prospective Developer may sample said well(s)in lieu of the monitoring
Gen.Wood BFA 21

inst # 330867 Boob 2390Page: 3421
well(s) in question, assuming Prospective Developer ootams iegai access to the property
containing said well(s). Prospective Developer shall transmit to DENR the analyses of the
sampling required by this paragraph with its Land Use Restrictions Updates required by
subparagraph 19.m. below. If Prospective Developer believes that the contaminant
concentrations measured by the sampling required by this paragraph are decreasing, it may
propose to DENR, at any time after the first five (5) sampling events, a statistical method for
ascertaining that. If DENR approves the method and determines that the concentrations are
decreasing, it may approve in writing sampling at intervals no less frequent than every three(3)
years. Unless DENR requires otherwise as a condition of a change in use of the Property,
Prospective Developer's obligations under this paragraph 16.d. shall terminate five years after the
date of completion of facility closure(shut down) activities, as determined by the HWS, or five
years after the effective date of this Agreement,whichever is later.
e. Within three (3)months after Prospective Developer's receipt of any
written determination by DENR that any well referenced in this paragraph 16 reflects
contamination at or from the Property at levels above one or more standards in Title 15A of the
North Carolina Administrative Code, Subchapter 2L,Rule .0202, and above the levels of such
contaminant(s) detected most recently prior to the effective date of this Agreement,Prospective
Developer shall increase the frequency of that well's sampling to quarterly, and shall submit to
DENR a plan involving response actions to reduce said contamination to levels below the subject
standard(s). In the event, Prospective Developer shall provide all sampling results to DENR
within seven(7) days of receiving them and shall correct any deficiencies DENR identifies in the
plan on a timetable established by DENR. Prospective Developer shall implement the plan in the
Gen.Wood BFA 22

Inst # 330867 Book 239OPage: 1422
form in which it is approved in writing by DENR. In the event DENR determines that
Prospective Developer has not achieved compliance with the standards within twenty-four(24)
months,DENR may require Prospective Developer to apply for and obtain a RCRA Part B
permit.
17. a. Within thirty(30) days after the effective date of this Agreement,Prospective
Developer shall notify DENR that it is ready to effect the abandonment of all groundwater
monitoring wells, injection wells,recovery wells,piezometers and other man-made points of
groundwater access at the Property in accordance with Subchapter 2C of Title 15A of the North
Carolina Administrative Code, other than wells associated with groundwater"Incident# 16624"
referenced in paragraph 6.d. above (PM-lB,PM-2 and PM-3 and PM-lA), the perimeter
monitoring wells (C-1, C-2, C-3, C-4, C-5, B-5,B-6 and B-1 OM) and the water supply wells
(WS-1, WS-2 and WS-3, the abandonment of which may be ordered pursuant to subparagraph
19.b.vii. below), all as denominated on the plat component of the Notice referenced below in
paragraph 28, and any sentry wells Prospective Developer installs pursuant to paragraph 16.c.
above. Unless DENR notifies Prospective Developer within ten(10) days of receiving such
notification to refrain from such abandonment,Prospective Developer shall effect said
abandonment and shall,within thirty(30) days after concluding such abandonment,provide
DENR a report setting forth the procedures and results.
b. Unless otherwise approved in writing by DENR, Prospective Developer
shall, in accordance with Subchapter 2C of Title 15A of the North Carolina Administrative Code,
abandon all wells not abandoned pursuant to subparagraph 17.a. of this Agreement within thirty
(30) days following Prospective Developer's completion of its obligations under subparagraph
Gen.Wood BFA 23

16.d. above.
Znst 1# 330867 Book 2390Page: 1423
18. Prospective Developer shall be responsible for completion of the capital
improvements referenced in paragraph 10.d. above within twenty-four(24) months after the
effective date of this Agreement. Until the improvements are complete, every ninety days
following the effective date of this Agreement Prospective Developer shall report in writing the
improvements made since the last report,their cost and their date of installation.
19. By way of the Notice of Brownfields Property referenced below in paragraph 28,
Prospective Developer shall impose the following land use restrictions under the Act,running
with the land, to make the Property safe for the uses specified in this Agreement while fully
protecting public health and the environment. All references to DENR shall be understood to
include any successor in function; use of"her"includes "his and"its."
a. No use may be made of the Property other than for industrial wood
treatment, in the area designated"PROCESS AND STORAGE AREA" on the plat component of
the Notice referenced in paragraph 28 below,without the prior written approval of DENR. No
use may occur of any part of the Property outside the"PROCESS AND STORAGE AREA"
without the prior written approval of DENR. In deciding whether to approve proposed other uses
of any part of the Property, DENR may consider the risks to public health and the environment
presented by such proposed uses and may require additional information relating to such risks,
including without limitation a worker-related risk assessment and environmental sampling
results,to be provided. The"PROCESS AND STORAGE AREA" shall remain configured as it
is as of the date of recordation of the Notice referenced in paragraph 28 below,unless DENR
issues prior written approval to configure it otherwise. For purposes of this restriction, the
Gen.Wood BFA 24

following definitions apply: bast # 330867 Book 2390Page s 142
i. "Industrial"refers to manufacturing and processing operations that
may produce greater than average levels of noise, vibration, dust, smoke or emissions, and that
may include outdoor storage.
ii. "Wood treatment"refers to the pressure treating,by use of
chemicals, of lumber,poles and other wood products for outdoor use. Creosote may not be
employed for wood treatment or any other purpose at the Property without the express prior
written approval of DENR.
b.i. No naturally occurring water on or under the Property may be used
for any purpose, and no activities that encounter, expose or remove naturally occurring water on
or under the Property may occur, except that water from any of the Property's three(3)water
supply wells, denominated"WS-1,""WS-2" and"WS-3"on the plat component of the Notice
referenced in paragraph 28 below, or any well approved by DENR to replace an existing water
supply well and depicted on an amended plat, may be used for process water, rinsing off
equipment, flushing toilets, washing hands and any other use approved in advance in writing by
DENR, under the following conditions:
A. no less frequently than every three (3) years, unless the
requirements or frequency of such sampling are modified in writing in advance by DENR,the
water in the well has been sampled for volatile organic compounds ("VOCs"), semi-volatile
organic compounds ("SVOCs") and metals regulated by RCRA(arsenic, barium, cadmium,
Gen.Wood BFA 25

Inst # 330867 Book 2390age. 125
chromium, lead,mercury, selenium and silver),pursuant to the most current version of U.S.
Environmental Protection Agency Method SW-846;
B. analysis of said sampling,by a laboratory certified by the
Laboratory Section of DENR's Division of Water Quality,has been submitted to DENR;
C. that analysis reflects concentrations of benzene (a(VOC)
below 0.106 milligrams per liter and concentrations of naphthalene (a SVOC)below 7.49
milligrams per liter;
D. sampling results reflect benzene concentrations that remain
below the safe use standard of 0.106 milligrams per liter and naphthalene concentrations that
remain below the safe use standard of 7.49 milligrams per liter; if sampling of a well reflects
concentrations of either contaminant that exceed those levels, water from that well may not be
used for hand-washing or any other activity that involves bodily contact with the water unless
and until concentrations of both contaminants are below the required levels; if sampling of a well
reflects concentrations of any other VOC, SVOC or RCRA metal that exceed the applicable
standard in Title 15A of the North Carolina Administrative Code, Subtitle 2L, Rule .0202 ("21,"),
water from that well may not be used for hand-washing or any other activity that involves bodily
contact with the water unless and until a safe use standard for such VOC, SVOC or RCRA metal
has been proposed to, and approved in writing by, DENR and the concentration of such VOC,
SVOC or RCRA metal is below the safe use standard;
E. Signs in English and Spanish that state, "THIS WATER
MAY NOT BE USED FOR DRINKING AND MAY ONLY BE USED FOR
Gen.Wood BFA 26

8
Inst # 330867 Book 2390Page: 1426
with the use(s) approved by DENR stated in the blank, are prominently displayed in close
proximity to points where water is available from any of the wells whose use is approved by
DENR; the owner of any part of the Property containing any of the wells with no approved uses
shall ensure that signs that state"DO NOT USE THIS WATER"are prominently displayed in
close proximity to points where water is available from such well(s).
F. If groundwater in a well exceeds a safe use standard
established in or pursuant to subparagraph 19.b.i.C. of this Agreement(or, in the absence of a
safe use standard, a 2L standard), and DENR determines that abandonment of the well is
necessary to protect public health and the environment, DENR may require the owner of the part
of the Property containing that well to abandon the well and document said abandonment to
DENR.
ii. Any replacement wells installed pursuant to this subparagraph
19.b. shall be sampled in accordance with subparagraph 19.b.i. above no more than one year
prior to their being placed in use.
C. Soil underlying buildings and impervious surfaces, including paved areas,
at the Property, as identified on the plat component of the Notice referenced in paragraph 28
below, soil underlying the area denominated"PETROLEUM HOTSPOT"on the plat component
of said Notice (unless DENR has issued written approval of the remediation of said area), and
soil proposed to be exposed in connection with any construction on the Property,may not be
exposed unless DENR has been provided a minimum of ten(10)business days advance written
notice and has given prior written approval to a plan to protect public health and the environment
Gen.Wood BFA 27

inst #1 330867 Book 2390Page: 1427
during the activities that would expose such soil. DENR may inspect, and require screening or
sampling for contaminants in, the exposed soil. If such screening or sampling discloses
contamination that DENR determines may pose an unacceptable level of risk to public health or
the environment, as much soil as DENR requires shall be removed and disposed of in accordance
with applicable law, and any other actions DENR requires for protection of public health and the
environment in view of the permitted uses of the property shall be taken. If DENR determines
that the exposed soil is contaminated at levels that would not pose an unacceptable risk to public
health or the environment if capped,DENR may require the soil to be capped, with perpetual
maintenance of the cap, to the satisfaction of DENR.
d. None of the four areas designated"HWMU" on the plat component of the
Notice referenced in paragraph 28 below may be disturbed without the prior written approval of
DENR on such conditions as DENR deems appropriate.
e. Soil, landscaping and contours at the Property may not be disturbed
without the approval of DENR, except for mowing and pruning of above-ground vegetation, and,
notwithstanding subparagraph 19.c. above,routine surface grading with flat-bladed equipment
that does not significantly alter surface contours or involve excavation.
f. No mining may be conducted on or under the Property, including,without
limitation, extraction of coal, oil, gas or any other minerals or non-mineral substances.
g. The Property may not be used as a park or for sports of any kind,
including,but not limited to, golf, football, soccer and baseball, without the prior written approval
of DENR.
h. The Property may not be used for agriculture, grazing or silviculture.
Gen.Wood BFA 28

Inst # 330867 Book 390Page: 1428
i. The Property may not be used as a playground, or for child care centers or
schools.
j. The Property may not be used for kennels,private animal pens or horse-
riding.
k. No basements may be constructed on the Property.
1. No party conducting environmental assessment or remediation at the
Property at the direction of DENR, or pursuant to this Agreement or a permit or order issued by
DENR, and no party installing capital improvements required by this Agreement,may be denied
access to the Property for purposes of conducting such assessment or remediation, or installing
such improvements.
M. During January of each year after this Agreement becomes effective,the
then current owner of any part of the Property shall submit a notarized Land Use Restrictions
Update ("LURU")to DENR that includes a certification that the Notice of Brownfields Property
containing these land use restrictions remains recorded at the Brunswick County Register of
Deeds office and that the land use restrictions are being complied with, and that is accompanied
by copies of the previous year's pages from the log book required by paragraph 13 of this
Agreement. Depending on the year, and the portion of the Property,the LURU shall also include
(the paragraphs referenced are in this Agreement):
i. a perimeter monitoring/sentry well analytical report(subparagraph
16.d.);
ii. analysis of water supply well sampling(subparagraph 19.b.ii.);
iii. soil sampling results (paragraph 15);
Gen.Wood BFA 29

Inst # 330867 Book 239OPagem 1429
iv. an update on work with DENR's Aquifer Protection Section
(paragraph 11)until documentation of"No Further Action" status is received; and
V. inspection and maintenance log/photographs for the previous
calendar year(paragraph 13).
20. The desired result of the above-referenced remediation, engineering controls and
land use restrictions is to make the Property suitable for the uses specified in the Agreement
while fully protecting public health and the environment,while allowing the State of North
Carolina, consistent with N.C.G.S. § 130A-310.37(a)(7), to maintain its commitments to the
federal government in connection with DENR's hazardous waste program.
21. Except as otherwise provided herein, the guidelines, including parameters,
principles and policies within which the desired results are to be accomplished are the Guidelines
of the Inactive Hazardous Sites Branch of DENR's Superfund Section, as embodied in their most
current version, and those compliance with which is necessary to maintain the State of North
Carolina's commitments to the federal government in connection with DENR's hazardous waste
program.
22. The consequences of achieving or not achieving the desired results will be that the
Property is or is not suitable for the uses specified in the Agreement while fully protecting public
health and the environment.
VI. FINANCIAL MATTERS
23. Prospective Developer has paid the $2,000 fee to seek a brownfields agreement
required by N.C.G.S. § 130A-310.39(a)(1). Given that the full cost to DENR and the North
Carolina Department of Justice ("DOJ") of all activities related to this Agreement is provided
Gen.Wood BFA 30

Inst # 330867 Book 2390Page: 1430
for, there is no need for Prospective Developer and DENR to establish,pursuant to N.C.G.S. §
130A-310.39(a)(2), a procedure by which said cost is determined.
24. This Agreement constitutes DENR's consent for Prospective Developer to enter
into an agreement with General Wood whereby the trust General Wood established on April 20,
1993 with Branch Banking and Trust Company, for the benefit of the HWS (the"General Wood
Trust"),would be terminated and all funds currently held in trust would be transferred to the trust
or account to be established pursuant to paragraph 26 below.
25. Prospective Developer has submitted, and DENR has approved, a written estimate
of the cost of each of the following, so that DENR can determine how much money Prospective
Developer shall, for performance of same, convey to the trust or deposit in the account
established pursuant to paragraph 26 below.
a. one round of sampling of pentachlorophenol, arsenic and total TCDD in
the same thirty grids the sampling of which was reported in the December 7, 2004 Environmental
Report(revised, as noted in paragraph 5 above, on February 23, 2005), and analysis of said
sampling.
b. removal of all permanent structures and capital equipment(above-ground
storage tanks, drying ovens,kilns, treatment cylinders, etc.) at the Property, excluding the office
building, if desired, and concrete flooring,based on written approval DENR has issued of a plan
that includes cost estimates for cleaning and sampling of said flooring;
C. abandonment of all wells referenced in this Agreement that will remain
after abandonment of the wells referenced in paragraph 17.a.;
d. addition of soil conditioners, seed and fertilizer sufficient to establish a
Gen.Wood BFA 31

Inst # 330867 Book 2390Pa e: 1431
stable vegetative cover over the area of the Property devoid of vegetation;
e. capping of two 100-foot by 100-foot grids if necessary to keep the
Property's contaminant average below worker safety-related risk levels in the event future
operations cause contamination;
f. inspection and maintenance in accordance with paragraph 13 above for
five (5)years;
g. groundwater monitoring in accordance with subparagraph 16.d. above for
five (5) years.
26. By way of a written agreement approved by DENR in writing, Prospective
Developer shall establish a trust for the benefit of DENR(the "Leland Land Trust"or the
"Trust"),to be administered by an institution regulated by the Federal Deposit Insurance
Corporation("FDIC"). Within thirty(30) days after Prospective Developer's receipt of DENR's
written approval of the cost estimates required by the preceding paragraph,with or without
changes required by DENR, Prospective Developer shall, if the Leland Land Trust is established
by that date, convey to the Leland Land Trust principal in the amount of the total approved cost
estimates,plus fifty(50)percent to account for factors such as inflation and possible
unanticipated future costs, less the amount of any funds transferred from the General Wood
Trust. If the Leland Land Trust is not established within the subject thirty(30)-day period,
Prospective Developer shall,by the thirtieth day, deposit the subject amount in an account(the
"Account") at an institution regulated by the FDIC, and shall transfer all funds in said account to
the Leland Land Trust within three(3) days after the trust's establishment. The following
conditions shall apply to the Leland Land Trust and the Account.
Gen.Wood BFA 32

inst # 330867 Book 2390Page: 1432
a. DENR may require the Trustee or Prospective Developer to disburse funds
from the Account or Trust,respectively, as DENR deems necessary, if DENR determines
Prospective Developer is not satisfactorily conducting the work for which the contingency account
is being established.
b. Neither the Account nor the Trust shall be considered part of the
bankruptcy estate if Prospective Developer files for bankruptcy, nor may the funds in the Account
or Trust be used for any purpose other than the work for which the Account and/or the Trust are/is
being established.
C. If funds remain in the Account or Trust after the work for which the
Account and/or the Trust are/is being established has been conducted, said remaining funds shall
be the property of Prospective Developer. If Prospective Developer no longer exists,those funds
shall escheat to DENR.
VII. ACCESS/NOTICE TO SUCCESSORS IN INTEREST
27. Commencing upon the date that it acquires title to the Property, Prospective
Developer agrees to provide to DENR, its authorized officers, employees,representatives, and all
other persons performing response actions under DENR oversight, an irrevocable right of access
at all reasonable times to the Property and to any other property to which access is required for
the implementation of response actions at the Property,to the extent access to such other property
is controlled by the Prospective Developer, for the purposes of performing or overseeing
response actions at the Property under applicable law. DENR agrees to provide reasonable
notice to the Prospective Developer of the timing of response actions to be undertaken at the
Gen.Wood BFA 33

inst # 330867 Book 2390Page: 1.433
Property. Notwithstanding any provision of this Agreement, DENR retains all of its authorities
and rights, including enforcement authorities related thereto, under the Act and any other
applicable statute or regulation, including any amendments thereto.
28. DENR has approved,pursuant to N.C.G.S. § 130A-310.35, a Notice of
Brownfields Property for the Property containing, inter alia, the land use restrictions set forth in
Section V (Work to Be Performed) of this Agreement and a survey plat of the Property. Pursuant
to N.C.G.S. § 130A-310.35(b), within 15 days of the effective date of this Agreement
Prospective Developer shall file the Notice of Brownfields Property in the Brunswick County,
North Carolina register of deeds' office. Within three days thereafter,Prospective Developer
shall furnish DENR a copy of the documentary component of the Notice containing a
certification by the register of deeds as to the Book and Page numbers where both the
documentary and plat components of the Notice are recorded, and a copy of the plat with
notations indicating its recordation.
29. This Agreement shall be attached as Exhibit A to the Notice of Brownfields
Property. Subsequent to recordation of said Notice, any deed or other instrument conveying an
interest in the Property shall contain the following notice: "The property which is the subject of
this instrument is subject to the Brownfields Agreement attached as Exhibit A to the Notice of
Brownfields Property recorded in the Brunswick County land records, Book , Page "
A copy of any such instrument shall be sent to the persons listed in Section XV (Notices and
Submissions), though financial figures related to the conveyance may be redacted.
30. The Prospective Developer shall ensure that assignees, successors in interest,
lessees and sublessees of the Property shall provide the same access and cooperation. The
Gen.Wood BFA 34

Inst # 330867 Book 2390Page: 1.434
Prospective Developer shall ensure that a copy of this Agreement is provided to any current
lessee or sublessee on the Property as of the effective date of this Agreement and shall ensure
that any subsequent leases, subleases, assignments or transfers of the Property or an interest in
the Property are consistent with this Section, Section V(Work to be Performed) and Section XI
(Parties Bound/Transfer of Covenant) of this Agreement.
VIR. DUE CARE/COOPERATION
31. The Prospective Developer shall exercise due care at the Property with respect to
regulated substances and shall comply with all applicable local, State, and federal laws and
regulations. The Prospective Developer agrees to cooperate fully with any remediation of the
Property by DENR and further agrees not to interfere with any such remediation. DENR agrees,
consistent with its responsibilities under applicable law,to use reasonable efforts to minimize
any interference with the Prospective Developer's operations by any such remediation. In the
event the Prospective Developer becomes aware of any action or occurrence which causes or
threatens a release of contaminants at or from the Property, the Prospective Developer shall
immediately take all appropriate action to prevent, abate, or minimize such release or threat of
release, and shall, in addition to complying with any applicable notification requirements under
N.C.G.S. 130A-310.1 and 143-215.84, and Section 103 of CERCLA, 42 U.S.C. § 9603, or any
other law, immediately notify DENR of such release or threatened release.
IX. CERTIFICATION
32. By entering into this agreement,the Prospective Developer certifies that,without
DENR approval, it will make no use of the Property other than that committed to in the
Brownfields Letter of Intent dated February 11, 2003 by which it applied for this Agreement:
Gen.Wood BFA 35

Inst # 330867 Book 2390 age: 1435
that use is an industrial wood treatment facility. Prospective Developer also certifies that to the
best of its knowledge and belief it has fully and accurately disclosed to DENR all information
known to Prospective Developer and all information in the possession or control of its officers,
directors, employees, contractors and agents which relates in any way to any regulated substances
at the Property and to its qualification for this Agreement, including the requirement that it not
have caused or contributed to the contamination at the Property.
X. DENR'S COVENANT NOT TO SUE AND RESERVATION OF RIGHTS
33. Unless any of the following apply, Prospective Developer shall not be liable to
DENR, and DENR covenants not to sue Prospective Developer, for remediation of the Property
except as specified in this Agreement:
a. The Prospective Developer fails to comply with this Agreement.
b. The activities conducted on the Property by or under the control or
direction of the Prospective Developer increase the risk of harm to public health or the
environment, in which case Prospective Developer shall be liable for remediation of the areas of
the Property, remediation of which is required by this Agreement, to the extent necessary to
eliminate such risk of harm to public health or the environment.
C. A land use restriction set out in the Notice of Brownfields Property
required under N.C.G.S. 130A-310.35 is violated while the Prospective Developer owns the
Property, in which case the Prospective Developer shall be responsible for remediation of the
Property to unrestricted use standards.
d. The Prospective Developer knowingly or recklessly provided false
information that formed a basis for this Agreement or knowingly or recklessly offers false
Gen.Wood BFA 36

Inst # 330867 Book 2390Page: 1436
information to demonstrate compliance with this Agreement or fails to disclose relevant
information about contamination at the Property.
e. New information indicates the existence of previously unreported
contaminants or an area of previously unreported contamination on or associated with the
Property that has not been remediated to unrestricted use standards, unless this Agreement is
amended to include any previously unreported contaminants and any additional areas of
contamination. If this Agreement sets maximum concentrations for contaminants, and new
information indicates the existence of previously unreported areas of these contaminants, further
remediation shall be required only if the areas of previously unreported contaminants raise the
risk of the contamination to public health or the environment to a level less protective of public
health and the environment than that required by this Agreement.
f. The level of risk to public health or the environment from contaminants is
unacceptable at or in the vicinity of the Property due to changes in exposure conditions, including
(i) a change in land use that increases the probability of exposure to contaminants at or in the
vicinity of the Property or(ii) the failure of remediation to mitigate risks to the extent required to
make the Property fully protective of public health and the environment as planned in this
Agreement.
g. The Department obtains new information about a contaminant associated
with the Property or exposures at or around the Property that raises the risk to public health or the
environment associated with the Property beyond an acceptable range and in a manner or to a
degree not anticipated in this Agreement.
Gen.Wood BFA 37

Inst; # 330867 Book 2390Page: 1437
h. The Prospective Developer fails to file a timely and proper Notice of
Brownfields Property under N.C.G.S. 130A-310.35.
34. Except as may be provided herein, the State of North Carolina reserves its rights
against Prospective Developer as to liabilities beyond the scope of the Act, including those
regarding petroleum underground storage tanks pursuant to Part 2A, Article 21A of Chapter 143
of the General Statutes. Further, this Agreement does not waive any applicable requirement to
obtain a permit, license or certification, including without limitation a stormwater permit from
DENR's Water Quality Section in connection with the allowed uses of the Property, or to comply
with any and all other applicable law, including the North Carolina Environmental Policy Act,
N.C.G.S. § 113A-1, et seq., and nothing in this Agreement releases Prospective Developer, or
any successor, transferee or assignee of Prospective Developer, from regulation by the HWS
under RCRA for generation, treatment, storage or disposal of hazardous waste on the Property;
however,neither Prospective Developer nor any successor,transferee or assignee of Prospective
Developer shall be required to apply for or obtain a RCRA Part B permit unless (i)this
Agreement is no longer in effect, (ii)Prospective Developer fails to implement to DENR's
satisfaction any plan required by subparagraph 16.e. of this Agreement, or(iii) Prospective
Developer engages in any new activities that would require a RCRA Part B permit.
XI. PROSPECTIVE DEVELOPER'S COVENANT NOT TO SUE
35. In consideration of DENR's Covenant Not To Sue in Section IX of this
Agreement and in recognition of the absolute State immunity provided in N.C.G.S. § 130A-
310.37(b), the Prospective Developer hereby covenants not to sue and not to assert any claims or
causes of action against DENR, its authorized officers, employees, or representatives with
Gen.Wood BFA 38

Inst # 330867 Book 239OPage. 1438
respect to any action implementing the Act, including negotiating, entering, monitoring or
enforcing this Agreement or the above-referenced Notice of Brownfields Property.
XH. PARTIES BOUND & TRANSFER/ASSIGNMENT NOTICE
36. This Agreement shall apply to and be binding upon DENR, and on the
Prospective Developer, its officers, directors, employees, and agents. Each Party's signatory to
this Agreement represents that she or he is fully authorized to enter into the terms and conditions
of this Agreement and to legally bind the Party for whom she or he signs.
37. No less than sixty(60) days' prior to its purchase of the Property, Prospective
Developer shall transmit to the HWS, with a copy provided to the DENR official identified in
paragraph 42 below, written notice of, said purchase pursuant to 40 C.F.R. § 270.40(b).
38. No later than fourteen(14) days prior to any transfer or assignment by Prospective
Developer of any interest in the Property, Prospective Developer shall provide in writing to
DENR the transferee or assignee's name,mailing address,telephone and facsimile numbers, and
e-mail address.
XIH. DISCLAIMER
39. This Agreement in no way constitutes a finding by DENR as to the risks to public
health and the environment which may be posed by regulated substances at the Property, a
representation by DENR that the Property is fit for any particular purpose, nor, except as
otherwise provided in this Agreement, a waiver of Prospective Developer's duty to seek
applicable permits or of the provisions of N.C.G.S. § 130A-310.37.
XIV. DOCUMENT RETENTION
40. The Prospective Developer agrees to retain and make available to DENR all
Gen.Wood BFA 39

Inst # 330867 Book 2390Page: 1439
business and operating records, contracts, site studies and investigations, and documents relating
to operations at the Property, for ten years following the effective date of this Agreement,unless
otherwise agreed to in writing by the Parties. At the end of ten years, the Prospective Developer
shall notify DENR of the location of such documents and shall provide DENR with an
opportunity to copy any documents at the expense of DENR.
XV. PAYMENT OF ENFORCEMENT COSTS
41. If the Prospective Developer fails to comply with the terms of this Agreement,
including,but not limited to,the provisions of Section V (Work to be Performed), it shall be
liable for all litigation and other enforcement costs incurred by DENR to enforce this Agreement
or otherwise obtain compliance.
XVI. NOTICES AND SUBMISSIONS
42. Unless otherwise required by DENR or a Party notifies the other Party in writing
of a change in contact information, all notices and submissions pursuant to this Agreement shall
be sent by prepaid first class U.S. mail, as follows:
a. for DENR:
Daphne Olszewski
N.C. Division of Waste Management
Brownfields Program
401 Oberlin Road, Suite 150
Raleigh,NC 27605
b. for Prospective Developer:
Steven J. Levitas
Kilpatrick Stockton LLP
3737 Glenwood Avenue, Suite 400
Raleigh,NC 27612
Gen.Wood BFA 40

Inst 4 330867 Book 2390Page: 1440
Notices and submissions sent by prepaid first class U.S. mail shall be effective on the third day
following postmarking. Notices and submissions sent by hand or by other means affording
written evidence of date of receipt shall be effective on such date.
XVII. EFFECTIVE DATE
43. Subject to paragraph 16.b.ii., this Agreement shall become effective on the date
the Prospective Developer signs it, after receiving it, signed, from DENR. Prospective
Developer shall sign the Agreement within seven(7) days following such receipt.
XVIII. TERMINATION OF CERTAIN PROVISIONS
44. If any.Party believes that any or all of the obligations under Section VI
(Access/Notice to Successors in Interest) are no longer necessary to ensure compliance with the
requirements of the Agreement, that Party may request in writing that the other Party agree to
terminate the provision(s) establishing such obligations;provided, however, that the provision(s)
in question shall continue in force unless and until the Party requesting such termination receives
written agreement from the other Party to terminate such provision(s).
XIX. CONTRIBUTION PROTECTION
45. With regard to claims for contribution against Prospective Developer in relation to
the subject matter of this Agreement, Prospective Developer is entitled to protection from such
claims to the extent provided by N.C.G.S. § 130A-310.37(a)(5)-(6). The subject matter of this
Agreement is all remediation taken or to be taken and response costs incurred or to be incurred
by DENR or any other person in relation to the Property.
46. The Prospective Developer agrees that,with respect to any suit or claim for
contribution brought by it in relation to the subject matter of this Agreement, it will notify DENR
Gen.Wood BFA 41

Inst # 330867 Book 2390Page: 144
in writing no later than 60 days prior to the initiation of such suit or claim.
47. The Prospective Developer also agrees that,with respect to any suit or claim for
contribution brought against it in relation to the subject matter of this Agreement, it will notify
DENR in writing within 10 days of service of the complaint on it.
XX. PUBLIC COMMENT
48. This Agreement was subject to a public comment period of at least sixty days that
started the day after publication of the approved summary of the Notice of Intent to Redevelop a
Brownfields Property required by N.C.G.S. § 130A-310.34 in the North Carolina Register. In
DENR's discretion pursuant to N.C.G.S. § 130A-310.34(c), no public meeting was necessary.
IT IS SO AGREED:
NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
By:
Lmda M. Culpepper Date
Deputy Director,Division of Waste Management
IT IS SO AGREED:
Leland Land LLC
By:
Qb 4-'� Z _
R. Michael Johnson Date
Managing Member
Gen.Wood BFA 42

last # 330867 Book 2390Page: 1,442
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11 A DATE REVI910N INITIAL. PROJECT i i 02094-0001
- 4UMN&CREED
SURVEY PLAT PDRA BY3 MRS
FIELD B.:9A-IN
C 3967 BI25d.Hsyc 17 Edx2t �t geJa� QKr �E•VBI I 020940001
BoIW North Cordino 25422 I.dA1D LNDt�
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CnIvisaDATE OCT.15.2005 SCALE: it-200'
IntdleMt Site httIx//s9wwmd dmaood.=n NORTHWEST TOMN9W BRUNSWICK COUNTY NORTH CAR4pA DWM#:VMM-020940001

Inst # 330867 Book 2390Pae: 1446
EXHIBIT C
LEGAL DESCRIPTION
General Wood Preserving Company, Inc.
That certain Tract of land being in Northwest Township, Brunswick County,North Carolina, said
Tract being the Tract described in Deed Book 572 Page 949 of the Brunswick County Register of Deeds
and being more fully described as follows:
Commencing from a concrete monument found, NCGS Monument "Crossover", said monument
having North Carolina NAD 83 grid coordinates of N. 188860.751 E. 2272592.302, South 63°16'34"
East, a distance of 5164.13 feet to a concrete monument found, NCGS Monument "Culvert", said
monument having North Carolina NAD 83 grid coordinates of N. 186538.587 E. 2277204.812; thence
South 59°40'38" East,a distance of 1740.62 feet to an iron rod set in the center of the Motsu Railroad 130
foot right of way,the Point of Beginning.
Thence from the Point of Beginning along the centerline of Motsu Railroad the following
Eighteen (18) courses and distances: (1) South 63°2654" East, a distance of 1082.74 feet to a point; (2)
South 26°33'06" West, a distance of 14.94 feet to a point; (3) South 63°26'54" East, a distance of 33.16
feet to a point; (4) South 62°58'54" East, a distance of 64.10 feet to a point; (5) South 61°14'54" East, a
distance of 100.80 feet to a point; (6) South 57°49'54" East, a distance of 101.50 feet to a point; (7) South
53°27'54" East, a distance of 101.00 feet to a point; (8) South 49°20'54" East, a distance of 100.60 feet to
a point; (9) South 45°28'54" East, a distance of 100.80 feet to a point; (10) South 41°27'54" East, a
distance of 101.00 feet to a point; (11) South 37°19'54" East, a distance of 100.40 feet to a point; (12)
South 33°14'54" East,a distance of 100.90 feet to a point; (13) South 29°30'54" East,a distance of 100.30
feet to a point; (14) South 25°22'54" East, a distance of 100.60 feet to a point; (15) South 21°19'54" East,
a distance of 100.10 feet to a point; (16) South 1713'54" East, a distance of 101.00 feet to a point; (17)
South 13°56'54" East, a distance of 134.53 feet to a point; and (18) South 12°53'54" East, a distance of
2326.10 feet to an iron rod set; thence South 77°09'06" West, a distance of 100.00 feet to an iron rod set;
thence South 77°09'06" West, a distance of 147.70 feet to a concrete monument found; thence South
62°09'06" West, a distance of 113.40 feet to an iron rod set; thence South 61°51'17" West, a distance of
51.59 feet to an iron rod set; thence North 67°18'54" West, a distance of 102.54 feet to an iron rod set;
thence North 65°14'54" West, a distance of 253.14 feet to an iron rod set; thence North 55°36'54" West, a
distance of 198.09 feet to an iron rod set; thence North 41033'54" West, a distance of 230.40 feet to an
iron rod set; thence North 53°2354" West, a distance of 112.27 feet to an iron rod set; thence North
60°46'54" West, a distance of 288.44 feet to an iron rod set; thence North 52°50'54" West, a distance of
375.23 feet to an iron rod set; thence North 56°49'54" West, a distance of 422.73 feet to an iron rod set;
thence North 49°26'30" West, a distance of 771.03 feet to an iron rod set; thence North 28°02'47" East, a
distance of 40.97 feet to an iron pipe found; thence North 28°10'06" East, a distance of 18.08 feet to an
iron rod found; thence North 28°10'06" East, a distance of 590.90 feet to a concrete monument found;
thence North 01°23'31" West, a distance of 1809.06 feet to the Point of Beginning, containing 128.65
acres and 2.54 acres,more or less as shown on a plat prepared by McKim& Creed,PA. entitled "Exhibit
B to the Notice of Brownfields Property Survey Plat, General Wood Preserving Company, Inc., Owner"
and dated October 5,2005.
1

LASERFICHE FILE TRANSMITTAL FORM
DIVISION OF WASTE MANAGEMENT
HAZARDOUS WASTE SECTION
Your Name: Autumn Romanski
Document Category: Facility
Document Group: General (G)
Document Type: Correspondence (C)
EPA ID: NCD093137636
Facility Name/Subject: Koppers Carolina Pole, Inc.
Document Date: 11/29/2022
(or Inspection Date)
Description: In-situ Soil Sampling Report of Findings
Author: David R.Kerschner,KU Resources, Inc.
Branch/Unit: Compliance Branch-Eastern Region
Facility/Site Address: 1901 Wood Treatment Rd
Facility/Site City: Leland
Facility/Site State: North Carolina
Facility/Site Zipcode: 28451
Facility/Site County: Brunswick
File Room Use Only
Month Day Year yl
Date Received
by File Room
Date Scanned I

III
_ ----- _ ----- --, www.l(uresources.com
November 29, 2022
Autumn Romanski
Environmental Chemist
North Carolina Department of Environmental Quality
Division of Waste Management
217 West Jones Street
1646 Mail Service Center
Raleigh, North Carolina 27699-1646
VIA EMAIL
Subject: Letter Report of Findings— Sampling and Analysis Plan Implementation
Immediate Action Notice of Violation
Docket#2022-037
Koppers—Carolina Pole Leland, Inc.
1901 Wood Treatment Road
Leland, NC 28451
Site EPA ID# NCR093137636
Brunswick County
Dear Ms. Romanski:
This Letter Report of Findings presents the results of soil sampling and analysis performed at the
Koppers—Carolina Pole Leland, Inc. facility in Leland, North Carolina. Work was generally performed
pursuant to the September 2022 Sampling and Analysis Plan (SAP) that was approved by NCDEQ on
September 16, 2022, and consisted of the collection and analysis of discrete soil samples collected from
multiple locations. Deviations from the SAP protocols were either recommended to NCDEQ
representatives or requested by NCDEQ representatives during the implementation of field activities.
Two areas of the facility were subject to the SAP investigation activities:
• The areas immediately adjacent to the east and west sides of the Transfer Deck concrete slab,
for the purpose of evaluating soil quality conditions that may be the result of precipitation runoff
from that concrete slab; and
• The sub-slab area adjacent to an inactive steam line/filter press, for the purpose of evaluating the
potential that constituents associated with observed staining on the concrete had migrated to the
subsurface via cracks and gaps in the concrete slab.
In addition to the SAP-directed activities, grid-based composite soil samples were collected and analyzed
from the east and west sides of the Transfer Deck following the protocols established for the facility's
NCDEQ Brownfields Agreement activities.
The soil sample locations are shown on Figure 1. Soil samples were collected using direct-push
sampling equipment. Notes regarding field sampling activities are included as Attachment A. A NCDEQ
RCRA Inspection Report also describing the field sampling activities is included as Attachment B.
The laboratory analytical results for the SAP and grid-based samples are summarized on Table 1.
Laboratory analytical reports are included as Attachment C. As shown on Table 1, and pursuant to the
SAP, the analytical results for the SAP samples were compared with the NCDEQ Preliminary Soil
Remediation Goals (PSRGs) for data evaluation purposes. Site-specific concentration-based worker risk
standards have also been established under the Brownfields Agreement; these standards were also used
as comparison values. Both sets of comparison values are also shown on Table 1.
22 South Linden Street I Duquesne, PA 15110 1 412.469.9331 1 412.469.9336 fax

Autumn Romanski
November 29,2022
Page 2
SUMMARY OF RESULTS
The following summarizes the results for each area investigated.
Transfer Deck Area— East Side: The samples from the east side of the Transfer Deck (locations TD-3,
TD-5, and TD-6) all had arsenic and pentachlorophenol concentrations that were above the PSRG. The
arsenic concentrations were above the Brownfields Agreement risk-based standard of 100 mg/kg in TD-3
(113 mg/kg) and TD-5 (220 mg/kg). The pentachlorophenol concentrations were all notably below the
Brownfields Agreement risk-based standard.
A sample-by-sample comparison of total chromium and hexavalent chromium concentrations indicates
that the chromium detected in the soil samples is primarily trivalent in form. No total chromium
concentrations exceeded the PSRG; TD-3 and TD-5 had hexavalent chromium concentrations that were
above the PSRG (0.99 mg/kg and 3.85 mg/kg, respectively versus a 0.31 mg/kg PSRG). The facility's
Brownfields Agreement has not established a site-specific worker risk standard for total or hexavalent
chromium.
No other constituents were detected at concentrations that exceeded their respective PSRGs.
The Brownfields Agreement protocol grid-based sampling results for arsenic and pentachlorophenol did
not exceed their respective Brownfields Agreement risk-based standards.
Transfer Deck Area— West Side: The samples from the west side of the Transfer Deck (locations TD-
1/TD-7D (duplicate), TD-2, and TD-4) all had arsenic and pentachlorophenol concentrations that were
above the PSRG. The arsenic concentration was above the Brownfield Program standard of 100 mg/kg
in TD-1 (117 mg/kg). The pentachlorophenol concentrations were all notably below the Brownfield
Program standard.
A sample-by-sample comparison of total chromium and hexavalent chromium concentrations indicates
that the chromium detected in the soil samples is primarily trivalent in form. No total chromium
concentrations exceeded the PSRG; TD-4 had a hexavalent chromium concentration that was above the
PSRG (0.814 mg/kg versus a 0.31 mg/kg PSRG). The Brownfield Program has not established a site-
specific worker risk standard for total or hexavalent chromium.
No other constituents were detected at concentrations that exceeded their respective PSRGs.
The Brownfields Agreement protocol grid-based sampling results for arsenic and pentachlorophenol did
not exceed their respective Brownfields Agreement risk-based standards.
Inactive Steam Line/Filter Press Area: Soil samples were collected from two borings, in close proximity
to each other, from a cracked area in the concrete slab. Samples were collected from two depth intervals
at location SL1 (2.9—4 feet and 4.5—5 feet, and from 3.9—5 feet at SL2. The samples all had arsenic
concentrations that were above the PSRG, and the SL1 2.9—4 feet sample had an arsenic concentration
(113 mg/kg) that exceeded the Brownfields Agreement risk-based standard of 100 mg/kg. The
pentachlorophenol concentrations in SL1 2.9—4 feet and SL2 3.9 —5 feet exceeded the PSRG, but did
not exceed the Brownfields Agreement risk-based standard.
No other constituents were detected at concentrations that exceeded their respective PSRGs.
v

Autumn Romanski
November 29, 2022
Page 2
CONCLUSIONS
It is important to note that the facility has entered into a Brownfields Agreement with NCDEQ. This
Brownfields Agreement developed risk-based soil quality criteria, and required extensive soil sampling at
the facility as well as routine ongoing soil sampling into the future. The presence of historical releases of
wood preserving constituents to the ground at the facility has been documented and addressed via the
Brownfields Agreement. Given the facility's long history of treating wood and handling treated wood, it
would therefore not be unexpected to detect wood preserving constituents in the soil surrounding the
wood treating process area, and virtually impossible to identify the specific source of and timing of the
release of those constituents to the soil.
Although concentrations of arsenic, chromium, and pentachlorophenol exceeded PSRGs in samples
collected immediately adjacent to the east and west sides of the Transfer Deck concrete slab, the
magnitudes of these concentrations are not suggestive of a release of a wood preservative product— in
such a case, the constituent concentrations would be expected to be at least several orders of magnitude
higher. As noted above, it is not possible to determine whether these concentrations are the result of
precipitation runoff from the Transfer Deck slab given the Transfer Deck slab conditions noted in the
NCDEQ inspection, the result of long-term wood preserving operations and the management of treated
wood products in and around the operations area (as has been addressed via the Brownfields
Agreement), or both. Further, the concentrations in the discrete samples are predominantly below the
Brownfields Agreement risk-based standards. Where arsenic concentrations exceed the Brownfields
Agreement risk-based standard, the exceedances are not notable. Finally, the Brownfields Agreement
protocol grid-based sampling results do not exceed the Brownfields Agreement standards on either the
east or west side of the Transfer Deck slab.
Similarly, the magnitudes of the arsenic and pentachlorophenol concentrations in the soil samples
collected in the Inactive Steam Line/Filter Press area are not suggestive of a release of wood
preservative product. Further, the results indicate that concentrations of arsenic and pentachlorophenol
decrease with depth. The presence of the roof and concrete slab mitigate the potential for lateral or
vertical migration of these constituents.
In consideration of the above, we believe that the areas of interest have been fully characterized, and that
the results do not represent a potential adverse risk to human health or the environment, and that the
results demonstrate that no further soil remediation activities beyond those that have been previously
conducted under the Brownfields Agreement are warranted.
Sincerely,
David R. Kerschner, CPG
Principal
[e-mail]
cc: Wes Hare (NCDEQ)
Jane House(Koppers)
Michael Rouse(Carolina Pole Leland)

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SOIL SAMPLING LOCATIONS
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DATED 2021. 0 40 SAMPLING AND ANALYSIS PLAN IMPLEMENTATION
-
APPROVED DIRK 11/28/2022 TOWN OF LELAND
KU Resources,Inc. BRUNSWICK COUNTY, NORTH CAROLINA
CHECKED DIRK 11/28/2022 22 South Linden Street
/ DRAWN RAM 11/28/2022 Duquesne,PA 15110 PREPARED FOR
CAD FILE N0. 22253A004 412.469.9331 KOPPERS - CAROLINA POLE LELAND, INC
412.469.9336 fax
kuresource LELAND, NORTH CAROLINA
x PROJECT N0. KI22253LEL www.kuresources.com

TABLE 1
SOIL QUALITY SUMMARY
OCTOBER 2022
Koppers - Carolina Pole Leland, Inc.
Leland, North Carolina
SAP (DISCRETE) SAMPLES GRID SAMPLES
CONSTITUENT PSRG BRN STD TD-1 TD-2 TD-3 TD-4 TD-5 TD-6 TD-7D SL1 2.9-4ft SL1 4.5-5ft SL2 3.9-5ft SL Blank* 5-13E 5-14W
Arsenic 0.68 100 117 18.6 113 22.9 220 40.6 4.04 113 41.9 52.1 <5.00 82.3 19.4
Barium 580 NS 1.11 9.97 3.66 2.99 2.31 3.10 0.256 J 1.81 1.12 1.12 <1.00 NA NA
Cadmium 3 NS <0.0973 <0.116 0.197 J 0.113 J 0.243 J <0.1 <0.102 <0.0895 <0.102 <0.0968 <1.00 NA NA
Chromium (Total) 23000 NS 237 13.5 125 34.8 534 84.8 38.7 125 0.304 J 32.9 <1.00 NA NA
Chromium (Hexavalent) 0.31 NS <0.180 <0.193 0.99 0.814 3.85 <0.211 <0.219 <0.162 <0.163 <0.147 NA NA NA
Copper 700 NS 73.4 14 74.7 11.4 389 65.0 1.46 J 84.4 0.424 J 22.6 <3.00 NA NA
Lead 270 NS 1.25 J 1.26 J 2.58 0.733 J 1.41 J 1.8 J 0.527 J 2.34 0.488 J 1.31 J <3.30 NA NA
Mercury 1 NS 0.0212 J <0.00978 0.00927 J 0.0138 J <0.00829 0.00884 J 0.0274 0.154 <0.00751 <0.00799 <0.0670 NA NA
Selenium 2.1 NS <0.487 <0.581 <0.536 <0.527 <0.528 <0.502 <0.512 <0.448 <0.508 <0.484 8.69 J NA NA
Silver 3.4 NS <0.0973 <0.116 0.137 J <0.105 1.52 J <0.100 <0.102 <0.0895 <0.102 <0.0968 <1.00 NA NA
Pentachlorophenol 1 0.0083 1 280 1 0.236 1 0.107 1 0.19 1 0.0202 1 0.203 1 0.0138 P 1 0.0229 1 28.2 1 0.00815 1 1.87 1 <0.417 1 <0.00192 1 0.00344 J
NOTES:
Values are in mg/kg. *Values for SL Blank are in µg/L
"PSRG" Denotes NCDEQ Preliminary Soi Remediation Goal
"BRN STD" Denotes the Brownfields Program NCDEQ Approved Worker Risk Standard
"NS" Denotes No Standard
"NA" Denotes Not Analyzed
"J" Denotes an Estimated Value
"P" Denotes the Concentrations Between the Primary and Confirmation Columns/Detectors is>40% Different. For HPLC,the difference is >70%.

ATTACHMENT A
FIELD NOTES

y 5
Ah
mmftftft A
a
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TD-1= 13'from start of transfer deck concrete Filter press—under cover Approx. 34.251045 DEG,-78.076173 DEG
TD-2=68'from start of transfer deck S1 34.251041,-78.076157
TD-4= 125' from start of transfer deck S2 34.251034,-78.076112
TD-3= 19'from start of transfer deck TDl 34.250589,-78.076434
TD-5=46'from start of transfer deck TD2 34.250433,-78.076454
TD-6=90'from start of transfer deck TD4 34.250288,-78.076470
TD-71) TD6 34.250323,-78.076074= 16' from start of transfer deck TD5 34.250434,-78.076059
TD3 34.250523,-78.076039
STEAM LINE NOTES
• Overhead power line—Determined by probe operator(Mike Tynan with IET)that it will not interfere
• Concrete approximately 6 inches with gravel under
• Due to water table between 4-5 feet, compression of sand in sleeve 2 was not enough sample to collect both
metals and pentachlorophenol for the shallow (2 to 3.9 feet) sample. It was determined to collect only the
pentachlorophenol for that one.
• Sample below 5 feet was"wet" and unusable.
c: SL 1 = 2.9.4 feet&4.5-5 feet samples
■ Dark Brown, loose sand
c: SL-2 = 2-3.9 feet- Pentachlorophenol only/3.9-f feet—Penta and metals
■ Dark Brown, loose sand. Very fine grain to silt.
Sleeve 3—Saturated— Not used
• Autumn suggested a "Blank" so this was taken as water running through a clean sleeve. Analytical for RCRA
Meta ls/Cu/Pentachlorophenol.

L
8
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F
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TRANSFER DECK NOTES—It was determined to use the probe for sampling around the transfer deck
• TD-3—Light gray/tan,very fine grain, unconsolidated,well sorted sand (light odor)
• TD-5—0-1.9 feet looked like fill sand and was not used for sampling
o A= Metal sampling 1.9-2.4 feet
o B= Penta sampling 2.4-3 feet
• TD-6-0-1.4 feet looked like fill sand and was not used for sampling
o A= Penta sampling 1.4-2.2 feet
o B= Metals sampling 2.2-2.9 feet (Wet and light odor)
• TD-4—Light tan/gray/light tan
o A= Metal sampling 0-0.9 feet
o B= Penta sampling 0.9-1.9 feet
• TD-2—Light gray, almost white at bottom
o A= Metal sampling 0-0.9 feet
o B= Penta sampling 1-1.10 feet
• TD-1—Gray/tan/orange/bottom marble tan. Gravel to .6 feet
o A= Metal sampling 0.6-1.4 feet
o B = Penta sampling 1.4-2.6 feet
• TD-7D—Pulled by TD-1. Light gray/tan/marble orange
o A= Metal sampling 0.5-1.2 feet
o B= Penta sampling 1.2-2 feet

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IMAGE BYDATED 202toocLF EARTH SAMPLING AND ANALYSIS PLAN
0 40
APPROVED 0RK 09/08/2022 TOWN OF LELAND
CHECKED DRK Ds 0s/2022 KU Resoumes.Inc. BRUNSWICK COUNTY, NORTH CAROLINA
/ 22 South linden Street PREPARED FOR
N DRACAD FILE
RAM 022253A 03 41DILI2469.933A 1511i) KOPPERS --� CAROLINA POLE LELAND, INC
CAD FILE N0. 22253AOD3
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ATTACHMENT B
NCDEQ RCRA INSPECTION REPORT

NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL
QUALITY DIVISION OF WASTE MANAGEMENT
HAZARDOUS WASTE SECTION (HWS) / COMPLIANCE BRANCH
RCRA INSPECTION REPORT
1) Facility Information: Koppers Carolina Pole Leland,Inc.
1901 Wood Treatment Road
Leland NC,28451
Brunswick County
EPA ID Number: NCR093137636
2) Property Owner: Leland Land, LLC
436 7TH AVE STE 1750
Pittsburgh,PA 15219-1886
3) Facility Address: 1901 Wood Treatment Rd
Leland,NC
Brunswick County
4) Facility/Owner Contact: Michael Rouse,Plant Manager
RouseMTkkoppers.com
Sarah House, SH&E Manager
HouseSJkkoppers.com
Michelle Reams, SH&E Coordinator
ReamsMB(kkoppers.com
5) Facility Consultant Contact: Dave Kerschner, CPG
KU Resources,Inc.
Duquesne,PA
dkerschner&kuresources.com
6) Inspector(s): Autumn Romanski,Eastern Region Environmental Chemist,
NCDEQ/HWS
Wes Hare, Environmental Specialist 11,NCDEQ/HWS
7) Sampling Consultant: Ron Yarborough, Geologist
ERM
Mount Pleasant, SC
ron.yarborou ghkoutlook.com
Mike Tynan, Southeast Drilling Manager
IET,Inc.
infokiet-inc.net
8) Date/Time of Inspection: October 5,2022—Arrived: —08:15 am,Departed: —02:30 pm
1

9) Date of Report: October 31, 2022—Prepared by: Autumn Romanski
10) Purpose of Inspection: Remedial Action Oversight(SPL)
11) Facility Description:
Carolina Pole Leland, Inc. is a wood treating facility that specializes in the pressure treatment
of utility poles and pilings primarily for the home construction industry. Timber is bought from
off-site,de-barked,then loaded into pressure chambers for chemical treatment.After treatment,
the trams are rolled onto a transfer deck,which directs the trams into one of multiple drip bays
for initial drying and capture of liquid chemical run-off.At the time of the inspection,treatment
chemicals included chromated copper arsenate (CCA) and pentachlorophenol (penta).
The drip bays consist of metal pans incorporated into rails, onto which trams laden with
newly treated wood are rolled and allowed to drip. The drip pan/rail assemblies are affixed to
an uncoated concrete floor. These pans are designed to direct drippage into one of two metal
troughs located along the front edge of the concrete floor,which lead to a sump and treatment
system where the liquid is processed for reuse.
In addition to wood treatment,the facility accepts wastewater containing pentachlorophenol
from similar Koppers,Inc. facilities in Alabama and Georgia. This wastewater is processed
though the on-site non-discharge treatment system regulated by the NCDEQ Division of
Water Resources.Additionally,there is a Brownfields agreement in place which addresses
specific areas on the site grounds.
On February 25, 2021, Wes Hare and Heather Goldman with the Hazardous Waste Section
(HWS) visited Koppers Carolina Pole Leland, Inc. at 1901 Wood Treatment Road in Leland,
NC to conduct a Large Quantity Generator Comprehensive Evaluation Inspection. Following
the inspection an Immediate Action Notice of Violation (IA-NOV) Docket # 2022-037 was
issued on February 21, 2022 that required the facility to perform a comprehensive assessment
of any areas impacted by releases to uncoated concrete in the copper chromated arsenic and
pentachlorophenol Drip Pad areas (AOC 1, AOC 2, and AOC 3); the uncoated concrete
secondary containment areas for the copper chromated arsenic and pentachlorophenol
hazardous waste tanks (AOC 3 and AOC 4); as well as spills of listed hazardous waste to the
uncoated concrete in (AOC 5). This assessment was required to determine the extent of
hazardous waste releases. A hazardous waste determination and appropriate disposal was
required for any contaminated media or contaminated debris excavated or removed during the
assessment by using representative analytical sampling or generator knowledge.
Prior to initiating the corrective actions or sampling activities,a site meeting was conducted on
June 20. 2022 at Koppers Carolina Pole, Inc. with facility personnel, Mike Rouse, Plant
Manager, Sarah House, Safety, Health, & Environmental Manager, and Michelle Reams,
Safety and Health Environmental Coordinator, and DWM staff, Autumn Romanski, Eastern
Environmental Chemist. Wes Hare, Environmental Specialist II/Inspector, Heather Goldman,
Eastern Unit Compliance Branch Supervisor,Kim Caulk,Compliance Branch Hydrogeologist,
and Samuel Watson,Brownfields Project Manager.
On September 9, 2022,Mr. Dave Kerschner, CPG,with KU Resources on behalf of Koppers
Carolina Pole Leland, Inc, submitted an initial draft of the first phase of an In-situ Soil
Characterization Sampling Plan, and a second phase (as/if needed)would require submittal of
an ISSP plan to address underlying soil and or background sampling(as/if needed). Comments
and recommendations by the Eastern Environmental Chemist NCDEQ-HWS were provided by
email on September 16, 2022, as part of the plan review, and the plan dated September 2022
2

was approved on September 16, 2022, prior to commencing with the In-situ Soil
Characterization.
12) Remedial Action Oversight of In-situ Soil Characterization/Waste Determination
Sampling Event:
On October 5, 2022, a remediation oversight visit at Koppers Carolina Pole Leland, Inc.,
located in Leland, NC (Brunswick County) was conducted of the phase 1, In-situ Soil
Characterization Sampling Event. The purpose of the visit was to observe the in-situ soil
sampling of the soil underlying the Wastewater Treatment System Filter Press containment pad
where cracks and staining had been observed during prior Compliance Evaluation Inspection
conducted and to investigate the steam line conduit located within the containment area and
observed at a subsequent site visit to confirm impacted areas of possible releases through
cracks, and or under the pad near the filter press (AOC-5).
Sampling of two (2) areas near the steam line conduit by the filter press and cracked cement
pad per Figure 2.1 and 6.1 of the approved In-situ Soil Characterization Sampling Plan was
conducted. The facility hired Mike Tynan of IET, Inc. to conduct the drilling of sample
locations using a Geoprobe to facilitate representative collection of multiple unmixed soil
samples per core from the surface to below 6 inches. The facility also hired Ron Yarborough,
geologist with ERM to complete the sampling. It was noted that use of the Geoprobe was a
change from the original sampling plan to accommodate sampling at depth. Originally, auger
sampling had been proposed,which in sandy soils below 6 inches of depth proves difficult, so
the Geoprobe use was approved. Also, noted was the two borings that were drilled for soil
sample collection were as close to the inactive steam line/filter press as possible given
Geoprobe clearance of overhead power lines. The soil sample locations were noted by phone
GPS. See Sampling event photos section of this report. Depths of soil samples collected for
analysis were noted and varied dependent upon depth of fill/gravel layer on top of the soil layer.
Sampling of both sides of the transfer deck incorporated(6) sample locations per figure 6.1 in
the approved In-situ Soil Characterization Sampling Plan. Each side of the transfer deck area
was gridded into 3 sections,with soil sample location noted by phone GPS, and the Geoprobe
was used to collect multiple unmixed soil samples per core from the surface to below 6 inches.
It was noted that the length of the transfer deck provided in the initial sampling plan
correspondence of 150 feet was inaccurate based on field measurement,so the sample locations
were adjusted based on actual length of the deck encountered in the field and measured the day
of the sampling event. The original intent of sampling three equal distant areas of each side of
the transfer deck closest to the deck was accomplished,however,one side of the deck contained
underground and overhead power lines,and one sample location was moved to avoid any issues
with the Geoprobe and minimize risk to the power source and lines. Also, there was a slight
shift in sample location placement to avoid Geoprobe drill encounter with the transfer deck
anchoring cables.
Soil samples were collected in clean clear glass containers and amber glass containers provided
by the facility and one water sample container preserved with nitric acid (for metals water
analysis)provided by the laboratory was used to complete one equipment blank near the filter
press area.
Soil cuttings and PPE waste were collected in a 55-gallon container labeled hazardous
waste pending analysis.
No Background soil samples were collected during this sampling event.
Sampling protocols outlined in the first phase of an In-situ Soil Characterization Sampling
Plan, except otherwise noted in this Sampling Event Report were observed followed and were
3

in general accordance with the Guidelines and/or EPA Standard Operating Procedures
(SOP) Manual. Michelle Reams completed field notes and photos of the sampling
event. Ron Yarbrough and Sarah House completed the Chain of Custody and samples were
shipped to Gel Laboratories for analysis.
13) Sampling Event Photo's:
Photo of the AOC- Cement containment ad and steam line conduit at Filter Press _
Photo of Sampling Location May—sample locations approximated from GAIA GPS
and Goo-le Earth
7 jl
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n
/* (�
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4

Photo of IET Inc. Geo robe used for borings.
ti
'r
1
S 1
T•' I ��rJk.. rt�__�'titi _
.r�. �*r•T' .
r �_� v �t•• •�.. •,I •tip Iti'+}'`_• �r7i• 'ti �.�+iF
L
_ � r•�• 1 _ _ L
�L•'.P i � T3�r i��i .r �.•r � r r 5'.���•r'7���rimer �� � ~�
Photo of overhead and underground power pole and lines at the transfer deck
near TD6 samplin2 Location
01!
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Y
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a
Photo of soil cuttings and waste collected for waste determination and disposal
14) Findings and Recommendations:
No recommendations are associated with this report at this time.
Thank you for your time and cooperation to complete phase one of the sampling required by IA-
NOV Docket#2022-037 regarding the(AOC-5 )Filter press/inactive steam line conduit and the
Transfer Deck(AOC-2)where cracks, open conduits, and staining had been observed during an
inspection at the site. The phase one In-situ Soil Characterization Sampling Event was
necessary to verify if contaminant levels are present in the soil over preliminary soil
remediation goals and to determine if cleanup actions are necessary.
In the meantime,if you have any questions about this activity report,please contact Autumn
Romanski at 919.2 80.15 10.
Eastern Region
Environmental Chemist
ec: Mr.Mike Rouse
RouseMTkkoppers.com
Ms. Michelle Reams
ReamsMB(a,koFpers.com
Mr. Dave Kerschner,KU Resources,Inc.
dkerschner(a,kuresources.com
Ms. Heather Goldman,HWS CB Eastern Region
Supervisor Heather.Goldman(kncdenr.gov
Mr. Wes Hare,HWS Environmental Specialist II
Wes.Harekncdenr.gov
Mr. Samuel Watson
S amuel.Watsonkncdenr.gov
DWM Central files
6

ATTACHMENT C
LABORATORY ANALYTICAL REPORTS

® LaboratorieS LLc
PU Box N712 Charleston_SC 29417
a member of The GEL Group ivc 2040 Savage Road Chad"on.8C 2N07
P 843.556.8171
F 843.766.1178
gel.com
October 27,2022
Jane House
Koppers Utility and Industrial Products(KUIP)
P. O.Box 1124
Orangeburg, South Carolina 29116
Re: Soil RCRA
Work Order: 595762
Dear Jane House:
GEL Laboratories,LLC(GEL)appreciates the opportunity to provide the enclosed analytical results for the
sample(s)we received on October 06,2022.This original data report has been prepared and reviewed in
accordance with GEL's standard operating procedures.
Test results for NELAP or ISO 17025 accredited tests are verified to meet the requirements of those standards,
with any exceptions noted. The results reported relate only to the items tested and to the sample as received by
the laboratory.These results may not be reproduced except as full reports without approval by the laboratory.
Copies of GEL's accreditations and certifications can be found on our website at www.gel.com.
Our policy is to provide high quality,personalized analytical services to enable you to meet your analytical needs
on time every time.We trust that you will find everything in order and to your satisfaction.If you have any
questions,please do not hesitate to call me at(843)556-8171,ext. 1648.
Sincerely,
Tn"� tia"
Meredith Boddiford
Project Manager
Purchase Order:TBD
Enclosures
Page 1 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407 - [phone] -www.gel.com
Certificate of Analysis Report
for
KURI00I KUIP Carolina Pole Leland
Client SDG: 595762 GEL Work Order: 595762
The Qualifiers in this report are defined as follows:
* A quality control analyte recovery is outside of specified acceptance criteria
** Analyte is a Tracer compound
** Analyte is a surrogate compound
E Concentration of the target analyte exceeds the instrument calibration range
J See case narrative for an explanation
J Value is estimated
P OrganicsThe concentrations between the primary and confirmation columns/detectors is>40%different. For
HPLC,the difference is>70%.
U Analyte was analyzed for,but not detected above the MDL,MDA,MDC or LOD.
Where the analytical method has been performed under NELAP certification,the analysis has met all of the
requirements of the NELAC standard unless qualified on the Certificate of Analysis.
The designation ND,if present,appears in the result column when the analyte concentration is not detected above
the limit as defined in the 'U' qualifier above.
This data report has been prepared and reviewed in accordance with GEL Laboratories LLC
standard operating procedures.Please direct any questions to your Project Manager,Meredith Boddiford.
wLt't'� sr&"
Reviewed by
Page 2 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-1 Project: KURIO0122
Sample ID: 595762001 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22 12:39
Receive Date: 06-OCT-22
Collector: Client
Moisture: 8.11%
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Mercury Analysis-CVAA
SW846 7471B Mercury, Solid"Dry Weight Corrected"
Mercury J 21.2 7.65 22.8 ug/kg 105 1 JP2 10/17/22 0924 2329118 1
Metals Analysis-ICP
SW846 3050B/6010D Metals, Solid"Dry Weight Corrected"
Arsenic 117 0.487 2.92 mg/kg 89.4 1 TXT1 10/13/22 0052 2325850 2
Barium 1.11 0.0973 0.487 mg/kg 89.4 1
Cadmium U ND 0.0973 0.487 mg/kg 89.4 1
Chromium 237 0.146 0.973 mg/kg 89.4 1
Copper 73.4 0.292 1.95 mg/kg 89.4 1
Lead J 1.25 0.321 1.95 mg/kg 89.4 1
Selenium U ND 0.487 2.92 mg/kg 89.4 1
Silver U ND 0.0973 0.487 mg/kg 89.4 1
Semi-Volatiles-HERB
SW846 8151A Herbicides,Solid"Dry Weight Corrected"
Pentachlorophenol 0.236 0.00902 0.0272 mg/kg 0.200 5 YS1 10/19/22 0635 2327654 4
Spectrometric Analysis
SW846 7196A Hexavalent Chromium"Dry Weight Corrected"
Hexavalent Chromium U ND 0.180 0.449 mg/kg 41.3 1 VHl 10/27/22 1439 2327899 5
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 3050B SW846 3050B Prep CD3 10/11/22 1650 2325849
SW846 3060A SW846_7196A Hexavalent Chromium in Soil HH2 10/27/22 1105 2327898
SW846 7471B Prep SW846 7471B Mercury Prep Soil RM4 10/14/22 1147 2329110
SW846 8151A 8151A Herbicides Prep in Soil Si 10/14/22 0754 2327652
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 7471B
2 SW846 3050B/6010D
3 SW846 8151A
4 SW846 8151A
5 SW846 7196A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW846 8151A Herbicides,Solid"Dry Weight 0.0484 mg/kg 0.109 45 (34%-149%)
Page 3 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-1 Project: KURIO0122
Sample ID: 595762001 Client ID: KURI001
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
Corrected"
Notes:
Column headers are defined as follows:
DF: Dilution Factor LC/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 4 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-2 Project: KURIO0122
Sample ID: 595762002 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22 12:30
Receive Date: 06-OCT-22
Collector: Client
Moisture: 21.8%
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Mercury Analysis-CVAA
SW846 7471B Mercury, Solid"Dry Weight Corrected"
Mercury U ND 9.78 29.2 ug/kg 114 1 JP2 10/17/22 0932 2329118 1
Metals Analysis-ICP
SW846 3050B/6010D Metals, Solid"Dry Weight Corrected"
Arsenic 18.6 0.581 3.49 mg/kg 90.9 1 TXT1 10/13/22 0115 2325850 2
Barium 9.97 0.116 0.581 mg/kg 90.9 1
Cadmium U ND 0.116 0.581 mg/kg 90.9 1
Chromium 13.5 0.174 1.16 mg/kg 90.9 1
Copper 14.0 0.349 2.33 mg/kg 90.9 1
Lead J 1.26 0.384 2.33 mg/kg 90.9 1
Selenium U ND 0.581 3.49 mg/kg 90.9 1
Silver U ND 0.116 0.581 mg/kg 90.9 1
Semi-Volatiles-HERB
SW846 8151A Herbicides,Solid"Dry Weight Corrected"
Pentachlorophenol 0.107 0.00424 0.0128 mg/kg 0.200 2 YS1 10/19/22 0658 2327654 4
Spectrometric Analysis
SW846 7196A Hexavalent Chromium"Dry Weight Corrected"
Hexavalent Chromium U ND 0.193 0.482 mg/kg 37.7 1 VHl 10/27/22 1440 2327899 5
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 3050B SW846 3050B Prep CD3 10/11/22 1650 2325849
SW846 3060A SW846_7196A Hexavalent Chromium in Soil HH2 10/27/22 1105 2327898
SW846 7471B Prep SW846 7471B Mercury Prep Soil RM4 10/14/22 1147 2329110
SW846 8151A 8151A Herbicides Prep in Soil Si 10/14/22 0754 2327652
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 7471B
2 SW846 3050B/6010D
3 SW846 8151A
4 SW846 8151A
5 SW846 7196A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW846 8151A Herbicides,Solid"Dry Weight 0.105 mg/kg 0.128 82 (34%-149%)
Page 5 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-2 Project: KURIO0122
Sample ID: 595762002 Client ID: KURI001
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
Corrected"
Notes:
Column headers are defined as follows:
DF: Dilution Factor LC/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 6 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-3 Project: KURIO0122
Sample ID: 595762003 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22 11:40
Receive Date: 06-OCT-22
Collector: Client
Moisture: 11.5%
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Mercury Analysis-CVAA
SW846 7471B Mercury, Solid"Dry Weight Corrected"
Mercury J 9.27 7.97 23.8 ug/kg 105 1 JP2 10/17/22 0934 2329118 1
Metals Analysis-ICP
SW846 3050B/6010D Metals, Solid"Dry Weight Corrected"
Arsenic 113 0.536 3.22 mg/kg 94.9 1 TXT1 10/13/22 0118 2325850 2
Barium 3.66 0.107 0.536 mg/kg 94.9 1
Cadmium J 0.197 0.107 0.536 mg/kg 94.9 1
Chromium 125 0.161 1.07 mg/kg 94.9 1
Copper 74.7 0.322 2.14 mg/kg 94.9 1
Lead 2.58 0.354 2.14 mg/kg 94.9 1
Selenium U ND 0.536 3.22 mg/kg 94.9 1
Silver J 0.137 0.107 0.536 mg/kg 94.9 1
Semi-Volatiles-HERB
SW846 8151A Herbicides,Solid"Dry Weight Corrected"
Pentachlorophenol 0.190 0.00933 0.0281 mg/kg 0.199 5 YS1 10/19/22 0722 2327654 3
Spectrometric Analysis
SW846 7196A Hexavalent Chromium"Dry Weight Corrected"
Hexavalent Chromium 0.990 0.160 0.401 mg/kg 35.5 1 VHl 10/27/22 1440 2327899 4
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 3050B SW846 3050B Prep CD3 10/11/22 1650 2325849
SW846 3060A SW846_7196A Hexavalent Chromium in Soil HH2 10/27/22 1105 2327898
SW846 7471B Prep SW846 7471B Mercury Prep Soil RM4 10/14/22 1147 2329110
SW846 8151A 8151A Herbicides Prep in Soil Si 10/14/22 0754 2327652
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 7471B
2 SW846 3050B/6010D
3 SW846 8151A
4 SW846 7196A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW846 8151A Herbicides,Solid"Dry Weight 0.0801 mg/kg 0.112 71 (34%-149%)
Corrected"
Page 7 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-3 Project: KURIO0122
Sample ID: 595762003 Client ID: KURI001
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Notes:
Column headers are defined as follows:
DF:Dilution Factor Lc/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 8 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-4 Project: KURIO0122
Sample ID: 595762004 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22 12:21
Receive Date: 06-OCT-22
Collector: Client
Moisture: 8.81%
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Mercury Analysis-CVAA
SW846 7471B Mercury, Solid"Dry Weight Corrected"
Mercury J 13.8 8.04 24.0 ug/kg 109 1 JP2 10/17/22 0936 2329118 1
Metals Analysis-ICP
SW846 3050B/6010D Metals, Solid"Dry Weight Corrected"
Arsenic 22.9 0.527 3.16 mg/kg 96.2 1 TXT1 10/13/22 0121 2325850 2
Barium 2.99 0.105 0.527 mg/kg 96.2 1
Cadmium J 0.113 0.105 0.527 mg/kg 96.2 1
Chromium 34.8 0.158 1.05 mg/kg 96.2 1
Copper 11.4 0.316 2.11 mg/kg 96.2 1
Lead J 0.733 0.348 2.11 mg/kg 96.2 1
Selenium U ND 0.527 3.16 mg/kg 96.2 1
Silver U ND 0.105 0.527 mg/kg 96.2 1
Semi-Volatiles-HERB
SW846 8151A Herbicides,Solid"Dry Weight Corrected"
Pentachlorophenol 0.0202 0.00182 0.00548 mg/kg 0.200 1 YS1 10/19/22 0745 2327654 4
Spectrometric Analysis
SW846 7196A Hexavalent Chromium"Dry Weight Corrected"
Hexavalent Chromium 0.814 0.176 0.441 mg/kg 40.2 1 VHl 10/27/22 1441 2327899 5
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 3050B SW846 3050B Prep CD3 10/11/22 1650 2325849
SW846 3060A SW846_7196A Hexavalent Chromium in Soil HH2 10/27/22 1105 2327898
SW846 7471B Prep SW846 7471B Mercury Prep Soil RM4 10/14/22 1147 2329110
SW846 8151A 8151A Herbicides Prep in Soil Si 10/14/22 0754 2327652
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 7471B
2 SW846 3050B/6010D
3 SW846 8151A
4 SW846 8151A
5 SW846 7196A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW846 8151A Herbicides,Solid"Dry Weight 0.0692 mg/kg 0.110 63 (34%-149%)
Page 9 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-4 Project: KURIO0122
Sample ID: 595762004 Client ID: KURI001
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
Corrected"
Notes:
Column headers are defined as follows:
DF: Dilution Factor LC/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 10 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-5 Project: KURIO0122
Sample ID: 595762005 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22 11:55
Receive Date: 06-OCT-22
Collector: Client
Moisture: 14.9%
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Mercury Analysis-CVAA
SW846 7471B Mercury, Solid"Dry Weight Corrected"
Mercury U ND 8.29 24.7 ug/kg 105 1 JP2 10/17/22 0937 2329118 1
Metals Analysis-ICP
SW846 3050B/6010D Metals, Solid"Dry Weight Corrected"
Arsenic 220 0.528 3.17 mg/kg 89.9 1 TXT1 10/13/22 0124 2325850 2
Barium 2.31 0.106 0.528 mg/kg 89.9 1
Cadmium J 0.243 0.106 0.528 mg/kg 89.9 1
Copper 389 0.317 2.11 mg/kg 89.9 1
Lead J 1.41 0.349 2.11 mg/kg 89.9 1
Selenium U ND 0.528 3.17 mg/kg 89.9 1
Chromium 534 0.793 5.28 mg/kg 89.9 5 TXTl 10/13/22 1441 2325850 3
Silver J 1.52 0.528 2.64 mg/kg 89.9 5
Semi-Volatiles-HERB
SW846 8151A Herbicides,Solid"Dry Weight Corrected"
Pentachtorophenot 0.203 0.00971 0.0292 mg/kg 0.199 5 YS1 10/19/22 0809 2327654 4
Spectrometric Analysis
SW846 7196A Hexavalent Chromium"Dry Weight Corrected"
Hexavalent Chromium 3.85 0.191 0.477 mg/kg 40.6 1 VHl 10/27/22 1441 2327899 5
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 3050B SW846 3050B Prep CD3 10/11/22 1650 2325849
SW846 3060A SW846_7196A Hexavalent Chromium in Soil HH2 10/27/22 1105 2327898
SW846 7471B Prep SW846 7471B Mercury Prep Soil RM4 10/14/22 1147 2329110
SW846 8151A 8151A Herbicides Prep in Soil Si 10/14/22 0754 2327652
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 7471B
2 SW846 3050B/6010D
3 SW846 3050B/6010D
4 SW846 8151A
5 SW846 7196A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW846 8151A Herbicides,Solid"Dry Weight 0.0864 mg/kg 0.117 74 (34%-149%)
Page 11 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-5 Project: KURIO0122
Sample ID: 595762005 Client ID: KURI001
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
Corrected"
Notes:
Column headers are defined as follows:
DF: Dilution Factor LC/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 12 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-6 Project: KURIO0122
Sample ID: 595762006 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22 12:07
Receive Date: 06-OCT-22
Collector: Client
Moisture: 10.3%
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Mercury Analysis-CVAA
SW846 7471B Mercury, Solid"Dry Weight Corrected"
Mercury J 8.84 8.46 25.2 ug/kg 113 1 JP2 10/17/22 0939 2329118 1
Metals Analysis-ICP
SW846 3050B/6010D Metals, Solid"Dry Weight Corrected"
Arsenic 40.6 0.502 3.01 mg/kg 90.1 1 TXT1 10/13/22 0127 2325850 2
Barium 3.10 0.100 0.502 mg/kg 90.1 1
Cadmium U ND 0.100 0.502 mg/kg 90.1 1
Chromium 84.8 0.151 1.00 mg/kg 90.1 1
Copper 65.0 0.301 2.01 mg/kg 90.1 1
Lead J 1.80 0.332 2.01 mg/kg 90.1 1
Selenium U ND 0.502 3.01 mg/kg 90.1 1
Silver U ND 0.100 0.502 mg/kg 90.1 1
Semi-Volatiles-HERB
SW846 8151A Herbicides,Solid"Dry Weight Corrected"
Pentachlorophenol P 0.0138 0.00184 0.00554 mg/kg 0.199 1 YS1 10/19/22 0832 2327654 3
Spectrometric Analysis
SW846 7196A Hexavalent Chromium"Dry Weight Corrected"
Hexavalent Chromium U ND 0.211 0.528 mg/kg 47.3 1 VHl 10/27/22 1442 2327899 4
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 3050B SW846 3050B Prep CD3 10/11/22 1650 2325849
SW846 3060A SW846_7196A Hexavalent Chromium in Soil HH2 10/27/22 1105 2327898
SW846 7471B Prep SW846 7471B Mercury Prep Soil RM4 10/14/22 1147 2329110
SW846 8151A 8151A Herbicides Prep in Soil Si 10/14/22 0754 2327652
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 7471B
2 SW846 3050B/6010D
3 SW846 8151A
4 SW846 7196A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW846 8151A Herbicides,Solid"Dry Weight 0.0834 mg/kg 0.111 75 (34%-149%)
Corrected"
Page 13 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-6 Project: KURIO0122
Sample ID: 595762006 Client ID: KURI001
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Notes:
Column headers are defined as follows:
DF:Dilution Factor Lc/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 14 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-71) Project: KURIO0122
Sample ID: 595762007 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22 12:51
Receive Date: 06-OCT-22
Collector: Client
Moisture: 9.71%
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Mercury Analysis-CVAA
SW846 7471B Mercury, Solid"Dry Weight Corrected"
Mercury 27.4 7.92 23.6 ug/kg 107 1 JP2 10/17/22 0944 2329118 1
Metals Analysis-ICP
SW846 3050B/6010D Metals, Solid"Dry Weight Corrected"
Arsenic 4.04 0.512 3.07 mg/kg 92.4 1 TXT1 10/13/22 0130 2325850 2
Barium J 0.256 0.102 0.512 mg/kg 92.4 1
Cadmium U ND 0.102 0.512 mg/kg 92.4 1
Chromium 38.7 0.154 1.02 mg/kg 92.4 1
Copper J 1.46 0.307 2.05 mg/kg 92.4 1
Lead J 0.527 0.338 2.05 mg/kg 92.4 1
Selenium U ND 0.512 3.07 mg/kg 92.4 1
Silver U ND 0.102 0.512 mg/kg 92.4 1
Semi-Volatiles-HERB
SW846 8151A Herbicides,Solid"Dry Weight Corrected"
Pentachlorophenol 0.0229 0.00184 0.00553 mg/kg 0.200 1 YS1 10/19/22 0856 2327654 3
Spectrometric Analysis
SW846 7196A Hexavalent Chromium"Dry Weight Corrected"
Hexavalent Chromium U ND 0.219 0.548 mg/kg 49.5 1 VHl 10/27/22 1442 2327899 4
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 3050B SW846 3050B Prep CD3 10/11/22 1650 2325849
SW846 3060A SW846_7196A Hexavalent Chromium in Soil HH2 10/27/22 1105 2327898
SW846 7471B Prep SW846 7471B Mercury Prep Soil RM4 10/14/22 1147 2329110
SW846 8151A 8151A Herbicides Prep in Soil Si 10/14/22 0754 2327652
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 7471B
2 SW846 3050B/6010D
3 SW846 8151A
4 SW846 7196A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW846 8151A Herbicides,Solid"Dry Weight 0.0763 mg/kg 0.111 69 (34%-149%)
Corrected"
Page 15 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-71) Project: KURIO0122
Sample ID: 595762007 Client ID: KURI001
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Notes:
Column headers are defined as follows:
DF:Dilution Factor Lc/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 16 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: SL1 2.9-4ft Project: KURIO0122
Sample ID: 595762008 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22 09:50
Receive Date: 06-OCT-22
Collector: Client
Moisture: 5.49%
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Mercury Analysis-CVAA
SW846 7471B Mercury, Solid"Dry Weight Corrected"
Mercury 154 8.12 24.2 ug/kg 115 1 JP2 10/17/22 0946 2329118 1
Metals Analysis-ICP
SW846 3050B/6010D Metals, Solid"Dry Weight Corrected"
Arsenic 113 0.448 2.69 mg/kg 84.6 1 TXT1 10/13/22 0134 2325850 2
Barium 1.81 0.0895 0.448 mg/kg 84.6 1
Cadmium U ND 0.0895 0.448 mg/kg 84.6 1
Chromium 125 0.134 0.895 mg/kg 84.6 1
Copper 84.4 0.269 1.79 mg/kg 84.6 1
Lead 2.34 0.295 1.79 mg/kg 84.6 1
Selenium U ND 0.448 2.69 mg/kg 84.6 1
Silver U ND 0.0895 0.448 mg/kg 84.6 1
Semi-Volatiles-HERB
SW846 8151A Herbicides,Solid"Dry Weight Corrected"
Pentachlorophenol 28.2 1.75 5.27 mg/kg 0.199 1000 YS1 10/19/22 1241 2327654 4
Spectrometric Analysis
SW846 7196A Hexavalent Chromium"Dry Weight Corrected"
Hexavalent Chromium U ND 0.162 0.405 mg/kg 38.3 1 VHl 10/27/22 1443 2327899 5
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 3050B SW846 3050B Prep CD3 10/11/22 1650 2325849
SW846 3060A SW846_7196A Hexavalent Chromium in Soil HH2 10/27/22 1105 2327898
SW846 7471B Prep SW846 7471B Mercury Prep Soil RM4 10/14/22 1147 2329110
SW846 8151A 8151A Herbicides Prep in Soil Si 10/14/22 0754 2327652
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 7471B
2 SW846 3050B/6010D
3 SW846 8151A
4 SW846 8151A
5 SW846 7196A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW846 8151A Herbicides,Solid"Dry Weight 0.000 mg/kg 0.105 0* (34%-149%)
Page 17 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: SL1 2.9-4ft Project: KURIO0122
Sample ID: 595762008 Client ID: KURI001
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
Corrected"
Notes:
Column headers are defined as follows:
DF: Dilution Factor LC/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 18 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: SL1 4.5-5ft Project: KURIO0122
Sample ID: 595762009 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22 09:50
Receive Date: 06-OCT-22
Collector: Client
Moisture: 9.54%
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Mercury Analysis-CVAA
SW846 7471B Mercury, Solid"Dry Weight Corrected"
Mercury U ND 7.51 22.4 ug/kg 101 1 JP2 10/17/22 0948 2329118 1
Metals Analysis-ICP
SW846 3050B/6010D Metals, Solid"Dry Weight Corrected"
Arsenic 41.9 0.508 3.05 mg/kg 91.9 1 TXT1 10/13/22 0138 2325850 2
Barium 1.12 0.102 0.508 mg/kg 91.9 1
Cadmium U ND 0.102 0.508 mg/kg 91.9 1
Chromium J 0.304 0.152 1.02 mg/kg 91.9 1
Copper J 0.424 0.305 2.03 mg/kg 91.9 1
Lead J 0.488 0.335 2.03 mg/kg 91.9 1
Selenium U ND 0.508 3.05 mg/kg 91.9 1
Silver U ND 0.102 0.508 mg/kg 91.9 1
Semi-Volatiles-HERB
SW846 8151A Herbicides,Solid"Dry Weight Corrected"
Pentachlorophenol 0.00815 0.00182 0.00549 mg/kg 0.199 1 YS1 10/19/22 1005 2327654 3
Spectrometric Analysis
SW846 7196A Hexavalent Chromium"Dry Weight Corrected"
Hexavalent Chromium U ND 0.163 0.408 mg/kg 36.9 1 VHl 10/27/22 1443 2327899 5
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 3050B SW846 3050B Prep CD3 10/11/22 1650 2325849
SW846 3060A SW846_7196A Hexavalent Chromium in Soil HH2 10/27/22 1105 2327898
SW846 7471B Prep SW846 7471B Mercury Prep Soil RM4 10/14/22 1147 2329110
SW846 8151A 8151A Herbicides Prep in Soil Si 10/14/22 0754 2327652
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 7471B
2 SW846 3050B/6010D
3 SW846 8151A
4 SW846 8151A
5 SW846 7196A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW846 8151A Herbicides,Solid"Dry Weight 0.0514 mg/kg 0.110 47 (34%-149%)
Page 19 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: SL1 4.5-5ft Project: KURIO0122
Sample ID: 595762009 Client ID: KURI001
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
Corrected"
Notes:
Column headers are defined as follows:
DF: Dilution Factor LC/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 20 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: SL2 3.9-5ft Project: KURIO0122
Sample ID: 595762010 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22 10:30
Receive Date: 06-OCT-22
Collector: Client
Moisture: 10.8%
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Mercury Analysis-CVAA
SW846 7471B Mercury, Solid"Dry Weight Corrected"
Mercury U ND 7.99 23.9 ug/kg 106 1 JP2 10/17/22 0949 2329118 1
Metals Analysis-ICP
SW846 3050B/6010D Metals, Solid"Dry Weight Corrected"
Arsenic 52.1 0.484 2.90 mg/kg 86.4 1 TXT1 10/13/22 0142 2325850 2
Barium 1.12 0.0968 0.484 mg/kg 86.4 1
Cadmium U ND 0.0968 0.484 mg/kg 86.4 1
Chromium 32.9 0.145 0.968 mg/kg 86.4 1
Copper 22.6 0.290 1.94 mg/kg 86.4 1
Lead J 1.31 0.320 1.94 mg/kg 86.4 1
Selenium U ND 0.484 2.90 mg/kg 86.4 1
Silver U ND 0.0968 0.484 mg/kg 86.4 1
Semi-Volatiles-HERB
SW846 8151A Herbicides,Solid"Dry Weight Corrected"
Pentachlorophenol 1.87 0.0923 0.278 mg/kg 0.198 50 YS1 10/19/22 1130 2327654 3
Spectrometric Analysis
SW846 7196A Hexavalent Chromium"Dry Weight Corrected"
Hexavalent Chromium U ND 0.147 0.368 mg/kg 32.8 1 VHl 10/27/22 1443 2327899 4
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 3050B SW846 3050B Prep CD3 10/11/22 1650 2325849
SW846 3060A SW846_7196A Hexavalent Chromium in Soil HH2 10/27/22 1105 2327898
SW846 7471B Prep SW846 7471B Mercury Prep Soil RM4 10/14/22 1147 2329110
SW846 8151A 8151A Herbicides Prep in Soil Si 10/14/22 0754 2327652
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 7471B
2 SW846 3050B/6010D
3 SW846 8151A
4 SW846 7196A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW846 8151A Herbicides,Solid"Dry Weight 0.0829 mg/kg 0.111 75 (34%-149%)
Corrected"
Page 21 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: SL2 3.9-5ft Project: KURIO0122
Sample ID: 595762010 Client ID: KURI001
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Notes:
Column headers are defined as follows:
DF:Dilution Factor Lc/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 22 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: SL2 2-3.9ft Project: KURIO0122
Sample ID: 595762011 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22 10:30
Receive Date: 06-OCT-22
Collector: Client
Moisture: 3.57%
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Semi-Volatiles-HERB
SW846 8151A Herbicides,Solid"Dry Weight Corrected"
Pentachlorophenol 2.46 0.0858 0.259 mg/kg 0.199 50 YS1 10/19/22 1154 2327654 1
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 8151A 8151A Herbicides Prep in Soil Si 10/14/22 0754 2327652
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 8151A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW846 8151A Herbicides,Solid"Dry Weight 0.0409 mg/kg 0.103 40 (34%-149%)
Corrected"
Notes:
Column headers are defined as follows:
DF:Dilution Factor Lc/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 23 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: SL BLANK Project: KURIO0122
Sample ID: 595762012 Client ID: KURI001
Matrix: Water
Collect Date: 05-OCT-22 10:30
Receive Date: 06-OCT-22
Collector: Client
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Mercury Analysis-CVAA
7470 Cold Vapor Mercury,Liquid"As Received"
Mercury U ND 0.0670 0.200 ug/L 1.00 1 JP2 10/14/22 1139 2328370 1
Metals Analysis-ICP
SW846 3005A/6010D Metals Scan Liquid"As Received"
Arsenic U ND 5.00 30.0 ug/L 1.00 1 LS 10/10/22 1030 2325848 2
Barium U ND 1.00 5.00 ug/L 1.00 1
Cadmium U ND 1.00 5.00 ug/L 1.00 1
Chromium U ND 1.00 10.0 ug/L 1.00 1
Copper U ND 3.00 20.0 ug/L 1.00 1
Lead U ND 3.30 20.0 ug/L 1.00 1
Selenium J 8.69 6.00 30.0 ug/L 1.00 1
Silver U ND 1.00 5.00 ug/L 1.00 1
Semi-Volatiles-HERB
SW 3535A/8151A Herbicides Liquid"As Received"
Pentachlorophenol U ND 0.417 1.25 ug/L 0.0500 1 YSl 10/10/22 1405 2325943 3
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 3005A SW846 3005A for 6010D CD3 10/07/22 1635 2325847
SW846 3535A SW3535A Herbicides SPE Extraction LWl 10/07/22 0536 2325942
SW846 7470A Prep EPA 7470A Mercury Prep Liquid RM4 10/13/22 1157 2328363
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 7470A
2 SW846 3005A/6010D
3 SW846 3535A/8151A
4 SW846 3535A/8151A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW 3535A/8151A Herbicides Liquid"As 24.3 ug/L 25.0 97 (46%-144%)
Received"
Notes:
Page 24 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 27,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: SL BLANK Project: KURIO0122
Sample ID: 595762012 Client ID: KURI001
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Column headers are defined as follows:
DF:Dilution Factor Lc/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 25 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Company: Koppers Utility and Industrial
Address : Products(KUIP)
P.O.Box 1124
Orangeburg,South Carolina 29116 Report Date: October 27,2022
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-1 Project: KURI00122
Sample ID: 595762001 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22
Receive Date: 06-OCT-22
Collector: Client
Moisture: 8.11%
Parameter Qualifier Result Uncertainty MDC TPU RL Units PIT DF Analyst Date Time Batch Mtd.
Gravimetric Solids
"As Received"
The following Analytical Methods were performed
Method Description
1 ASTM D 2216(Modified)
Surrogate/Tracer Recovery Test Batch ID Recovery% Acceptable Limits
Notes:
The MDC is a sample specific MDC.
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
Column headers are defined as follows:
DF:Dilution Factor Mtd.:Method
DL:Detection Limit PF:Prep Factor
Lc/LC: Critical Level RL:Reporting Limit
MDA:Minimum Detectable Activity TPU:Total Propagated Uncertainty
MDC:Minimum Detectable Concentration
Page 26 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Company: Koppers Utility and Industrial
Address : Products(KUIP)
P.O.Box 1124
Orangeburg,South Carolina 29116 Report Date: October 27,2022
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-2 Project: KURIO0122
Sample ID: 595762002 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22
Receive Date: 06-OCT-22
Collector: Client
Moisture: 21.8%
Parameter Qualifier Result Uncertainty MDC TPU RL Units PF DF Analyst Date Time Batch Mtd.
Gravimetric Solids
'As Received"
The following Analytical Methods were performed
Method Description
1 ASTM D 2216(Modified)
Surrogate/Tracer Recovery Test Batch ID Recovery% Acceptable Limits
Notes:
The MDC is a sample specific MDC.
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
Column headers are defined as follows:
DF:Dilution Factor Mtd.:Method
DL:Detection Limit PF: Prep Factor
Lc/LC: Critical Level RL:Reporting Limit
MDA:Minimum Detectable Activity TPU:Total Propagated Uncertainty
MDC: Minimum Detectable Concentration
Page 27 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Company: Koppers Utility and Industrial
Address : Products(KUIP)
P.O.Box 1124
Orangeburg,South Carolina 29116 Report Date: October 27,2022
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-3 Project: KURIO0122
Sample ID: 595762003 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22
Receive Date: 06-OCT-22
Collector: Client
Moisture: 11.5%
Parameter Qualifier Result Uncertainty MDC TPU RL Units PF DF Analyst Date Time Batch Mtd.
Gravimetric Solids
'As Received"
The following Analytical Methods were performed
Method Description
1 ASTM D 2216(Modified)
Surrogate/Tracer Recovery Test Batch ID Recovery% Acceptable Limits
Notes:
The MDC is a sample specific MDC.
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
Column headers are defined as follows:
DF:Dilution Factor Mtd.:Method
DL:Detection Limit PF: Prep Factor
Lc/LC: Critical Level RL:Reporting Limit
MDA:Minimum Detectable Activity TPU:Total Propagated Uncertainty
MDC: Minimum Detectable Concentration
Page 28 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Company: Koppers Utility and Industrial
Address : Products(KUIP)
P.O.Box 1124
Orangeburg,South Carolina 29116 Report Date: October 27,2022
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-4 Project: KURIO0122
Sample ID: 595762004 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22
Receive Date: 06-OCT-22
Collector: Client
Moisture: 8.81%
Parameter Qualifier Result Uncertainty MDC TPU RL Units PF DF Analyst Date Time Batch Mtd.
Gravimetric Solids
'As Received"
The following Analytical Methods were performed
Method Description
1 ASTM D 2216(Modified)
Surrogate/Tracer Recovery Test Batch ID Recovery% Acceptable Limits
Notes:
The MDC is a sample specific MDC.
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
Column headers are defined as follows:
DF:Dilution Factor Mtd.:Method
DL:Detection Limit PF: Prep Factor
Lc/LC: Critical Level RL:Reporting Limit
MDA:Minimum Detectable Activity TPU:Total Propagated Uncertainty
MDC: Minimum Detectable Concentration
Page 29 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Company: Koppers Utility and Industrial
Address : Products(KUIP)
P.O.Box 1124
Orangeburg,South Carolina 29116 Report Date: October 27,2022
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-5 Project: KURIO0122
Sample ID: 595762005 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22
Receive Date: 06-OCT-22
Collector: Client
Moisture: 14.9%
Parameter Qualifier Result Uncertainty MDC TPU RL Units PF DF Analyst Date Time Batch Mtd.
Gravimetric Solids
'As Received"
The following Analytical Methods were performed
Method Description
1 ASTM D 2216(Modified)
Surrogate/Tracer Recovery Test Batch ID Recovery% Acceptable Limits
Notes:
The MDC is a sample specific MDC.
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
Column headers are defined as follows:
DF:Dilution Factor Mtd.:Method
DL:Detection Limit PF: Prep Factor
Lc/LC: Critical Level RL:Reporting Limit
MDA:Minimum Detectable Activity TPU:Total Propagated Uncertainty
MDC: Minimum Detectable Concentration
Page 30 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Company: Koppers Utility and Industrial
Address : Products(KUIP)
P.O.Box 1124
Orangeburg,South Carolina 29116 Report Date: October 27,2022
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-6 Project: KURIO0122
Sample ID: 595762006 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22
Receive Date: 06-OCT-22
Collector: Client
Moisture: 10.3%
Parameter Qualifier Result Uncertainty MDC TPU RL Units PF DF Analyst Date Time Batch Mtd.
Gravimetric Solids
'As Received"
The following Analytical Methods were performed
Method Description
1 ASTM D 2216(Modified)
Surrogate/Tracer Recovery Test Batch ID Recovery% Acceptable Limits
Notes:
The MDC is a sample specific MDC.
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
Column headers are defined as follows:
DF:Dilution Factor Mtd.:Method
DL:Detection Limit PF: Prep Factor
Lc/LC: Critical Level RL:Reporting Limit
MDA:Minimum Detectable Activity TPU:Total Propagated Uncertainty
MDC: Minimum Detectable Concentration
Page 31 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Company: Koppers Utility and Industrial
Address : Products(KUIP)
P.O.Box 1124
Orangeburg,South Carolina 29116 Report Date: October 27,2022
Contact: Jane House
Project: Soil RCRA
Client Sample ID: TD-71) Project: KURIO0122
Sample ID: 595762007 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22
Receive Date: 06-OCT-22
Collector: Client
Moisture: 9.71%
Parameter Qualifier Result Uncertainty MDC TPU RL Units PF DF Analyst Date Time Batch Mtd.
Gravimetric Solids
'As Received"
The following Analytical Methods were performed
Method Description
1 ASTM D 2216(Modified)
Surrogate/Tracer Recovery Test Batch ID Recovery% Acceptable Limits
Notes:
The MDC is a sample specific MDC.
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
Column headers are defined as follows:
DF:Dilution Factor Mtd.:Method
DL:Detection Limit PF: Prep Factor
Lc/LC: Critical Level RL:Reporting Limit
MDA:Minimum Detectable Activity TPU:Total Propagated Uncertainty
MDC: Minimum Detectable Concentration
Page 32 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Company: Koppers Utility and Industrial
Address : Products(KUIP)
P.O.Box 1124
Orangeburg,South Carolina 29116 Report Date: October 27,2022
Contact: Jane House
Project: Soil RCRA
Client Sample ID: SL1 2.9-4ft Project: KURIO0122
Sample ID: 595762008 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22
Receive Date: 06-OCT-22
Collector: Client
Moisture: 5.49%
Parameter Qualifier Result Uncertainty MDC TPU RL Units PF DF Analyst Date Time Batch Mtd.
Gravimetric Solids
'As Received"
The following Analytical Methods were performed
Method Description
1 ASTM D 2216(Modified)
Surrogate/Tracer Recovery Test Batch ID Recovery% Acceptable Limits
Notes:
The MDC is a sample specific MDC.
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
Column headers are defined as follows:
DF:Dilution Factor Mtd.:Method
DL:Detection Limit PF: Prep Factor
Lc/LC: Critical Level RL:Reporting Limit
MDA:Minimum Detectable Activity TPU:Total Propagated Uncertainty
MDC: Minimum Detectable Concentration
Page 33 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Company: Koppers Utility and Industrial
Address : Products(KUIP)
P.O.Box 1124
Orangeburg,South Carolina 29116 Report Date: October 27,2022
Contact: Jane House
Project: Soil RCRA
Client Sample ID: SL1 4.5-5ft Project: KURIO0122
Sample ID: 595762009 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22
Receive Date: 06-OCT-22
Collector: Client
Moisture: 9.54%
Parameter Qualifier Result Uncertainty MDC TPU RL Units PF DF Analyst Date Time Batch Mtd.
Gravimetric Solids
'As Received"
The following Analytical Methods were performed
Method Description
1 ASTM D 2216(Modified)
Surrogate/Tracer Recovery Test Batch ID Recovery% Acceptable Limits
Notes:
The MDC is a sample specific MDC.
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
Column headers are defined as follows:
DF:Dilution Factor Mtd.:Method
DL:Detection Limit PF: Prep Factor
Lc/LC: Critical Level RL:Reporting Limit
MDA:Minimum Detectable Activity TPU:Total Propagated Uncertainty
MDC: Minimum Detectable Concentration
Page 34 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Company: Koppers Utility and Industrial
Address : Products(KUIP)
P.O.Box 1124
Orangeburg,South Carolina 29116 Report Date: October 27,2022
Contact: Jane House
Project: Soil RCRA
Client Sample ID: SL2 3.9-5ft Project: KURIO0122
Sample ID: 595762010 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22
Receive Date: 06-OCT-22
Collector: Client
Moisture: 10.8%
Parameter Qualifier Result Uncertainty MDC TPU RL Units PF DF Analyst Date Time Batch Mtd.
Gravimetric Solids
'As Received"
The following Analytical Methods were performed
Method Description
1 ASTM D 2216(Modified)
Surrogate/Tracer Recovery Test Batch ID Recovery% Acceptable Limits
Notes:
The MDC is a sample specific MDC.
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
Column headers are defined as follows:
DF:Dilution Factor Mtd.:Method
DL:Detection Limit PF: Prep Factor
Lc/LC: Critical Level RL:Reporting Limit
MDA:Minimum Detectable Activity TPU:Total Propagated Uncertainty
MDC: Minimum Detectable Concentration
Page 35 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Company: Koppers Utility and Industrial
Address : Products(KUIP)
P.O.Box 1124
Orangeburg,South Carolina 29116 Report Date: October 27,2022
Contact: Jane House
Project: Soil RCRA
Client Sample ID: SL2 2-3.9ft Project: KURI00122
Sample ID: 595762011 Client ID: KURI001
Matrix: Soil
Collect Date: 05-OCT-22
Receive Date: 06-OCT-22
Collector: Client
Moisture: 3.57%
Parameter Qualifier Result Uncertainty MDC TPU RL Units PIT DF Analyst Date Time Batch Mtd.
Gravimetric Solids
"As Received"
The following Analytical Methods were performed
Method Description
1 ASTM D 2216(Modified)
Surrogate/Tracer Recovery Test Batch ID Recovery% Acceptable Limits
Notes:
The MDC is a sample specific MDC.
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
Column headers are defined as follows:
DF:Dilution Factor Mtd.:Method
DL:Detection Limit PF:Prep Factor
Lc/LC: Critical Level RL:Reporting Limit
MDA:Minimum Detectable Activity TPU:Total Propagated Uncertainty
MDC:Minimum Detectable Concentration
Page 36 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407-[phone] -www.gel.com
QC Summary
Koppers Utility and Industrial Products(KUIP) Renort Date:October 27,2022
Page 1 of 9
P.O.Box 1124
Orangeburg,South Carolina
Contact: Jane House
Workorder: 595762
Parmname NOM Sample Qual QC Units RPD/D% REC% Range Anlst Date Time
Metals Analysis-ICP
Batch 2325848
QC1205210129 LCS
Arsenic 500 506 ug/L 101 (80%-120%) LS 10/10/2210:24
Barium 500 503 ug/L 101 (80%-120%)
Cadmium 500 513 ug/L 103 (80%-120%)
Chromium 500 510 ug/L 102 (80%-120%)
Copper 500 502 ug/L 100 (80%-120%)
Lead 500 508 ug/L 102 (80%-120%)
Selenium 500 488 ug/L 97.6 (80%-120%)
Silver 100 100 ug/L 100 (80%-120%)
QC1205210130 LCSD
Arsenic 500 501 ug/L 1.15 100 (0%-20%) 10/10/2210:27
Barium 500 509 ug/L 1.01 102 (0%-20%)
Cadmium 500 519 ug/L 1.07 104 (0%-20%)
Chromium 500 522 ug/L 2.46 104 (0%-20%)
Copper 500 522 ug/L 3.89 104 (0%-20%)
Page 37 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407-[phone] -www.gel.com
QC Summary
Workorder: 595762 Page 2 of 9
Parmname NOM Sample Qual QC Units RPD/D% REC% Range Anlst Date Time
Metals Analysis-ICP
Batch 2325848
Lead 500 517 ug/L 1.75 103 (0%-20%) LS 10/10/2210:27
Selenium 500 517 ug/L 5.77 103 (0%-20%)
Silver 100 102 ug/L 1.98 102 (0%-20%)
QC1205210128 MB
Arsenic U ND ug/L 10/10/2210:21
Barium U ND ug/L
Cadmium J 1.03 ug/L
Chromium U ND ug/L
Copper U ND ug/L
Lead U ND ug/L
Selenium U ND ug/L
Silver U ND ug/L
QC1205210131 595762012 SDILT
Arsenic U ND U ND ug/L N/A (0%-20%) 10/10/2210:33
Barium U ND U ND ug/L N/A (0%-20%)
Cadmium U ND J 1.11 ug/L N/A (0%-20%)
Chromium U ND U ND ug/L N/A (0%-20%)
Page 38 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407-[phone] -www.gel.com
QC Summary
Workorder: 595762 Page 3 of 9
Parmname NOM Sample Qual QC Units RPD/D% REC% Range Anlst Date Time
Metals Analysis-ICP
Batch 2325848
Copper U ND U ND ug/L N/A (0%-20%) LS 10/10/2210:33
Lead U ND U ND ug/L N/A (0%-20%)
Selenium J 8.69 J 9.32 ug/L 436 (0%-20%)
Silver U ND U ND ug/L N/A (0%-20%)
Batch 2325850
QC1205210133 LCS
Arsenic 48.9 47.1 mg/kg 96.3 (80%-120%) TXT1 10/13/22 00:50
Barium 48.9 46.0 mg/kg 94 (80%-120%)
Cadmium 48.9 47.2 mg/kg 96.4 (80%-120%)
Chromium 48.9 47.1 mg/kg 96.3 (80%-120%)
Copper 48.9 47.1 mg/kg 96.3 (80%-120%)
Lead 48.9 46.4 mg/kg 94.8 (80%-120%)
Selenium 48.9 46.9 mg/kg 95.8 (80%-120%)
Silver 9.78 9.68 mg/kg 98.9 (80%-120%)
QC1205210132 MB
Arsenic U ND mg/kg 10/13/22 00:46
Barium U ND mg/kg
Page 39 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407-[phone] -www.gel.com
QC Summary
Workorder: 595762 Page 4 of 9
Parmname NOM Sample Qual QC Units RPD/D% REC% Range Anlst Date Time
Metals Analysis-ICP
Batch 2325850
Cadmium U ND mg/kg TXT1 10/13/22 00:46
Chromium U ND mg/kg
Copper 7 0.292 mg/kg
Lead 7 0.310 mg/kg
Selenium U ND mg/kg
Silver U ND mg/kg
QC1205210134 595762001 MS
Arsenic 45.4 117 135 mg/kg 38.1* (75%-125%) 10/13/22 00:56
Barium 45.4 1.11 45.5 mg/kg 97.7 (75%-125%)
Cadmium 45.4 U ND 44.4 mg/kg 97.7 (75%-125%)
Chromium 45.4 237 217 mg/kg N/A (75%-125%)
Copper 45.4 73.4 117 mg/kg 96.9 (75%-125%)
Lead 45.4 7 1.25 44.4 mg/kg 95 (75%-125%)
Selenium 45.4 U ND 45.9 mg/kg 100 (75%-125%)
Silver 9.08 U ND 9.11 mg/kg 100 (75%-125%)
QC1205210135 595762001 MSD
Arsenic 47.4 117 160 mg/kg 17.1 89.8 (0%-20%) 10/13/22 01:02
Page 40 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407-[phone] -www.gel.com
QC Summary
Workorder: 595762 Page 5 of 9
Parmname NOM Sample Qual QC Units RPD/D% REC% Range Anlst Date Time
Metals Analysis-ICP
Batch 2325850
Barium 47.4 1.11 42.7 mg/kg 6.28 87.8 (0%-20%) TXT1 10/13/22 01:02
Cadmium 47.4 U ND 46.9 mg/kg 5.33 98.8 (0%-20%)
Chromium 47.4 237 275 mg/kg 23.6* N/A (0%-20%)
Copper 47.4 73.4 118 mg/kg 0.445 94 (0%-20%)
Lead 47.4 J 1.25 45.3 mg/kg 2.04 93 (0%-20%)
Selenium 47.4 U ND 49.2 mg/kg 6.99 103 (0%-20%)
Silver 9.48 U ND 9.03 mg/kg 0.806 95.3 (0%-20%)
QC1205215884 595762001 PS
Arsenic 500 1210 1690 ug/L 96.3 (75%-125%) 10/13/22 01:02
QC1205210136 595762001 SDILT
Arsenic 1210 240 ug/L .688 (0%-20%) 10/13/22 01:05
Barium 11.4 J 2.05 ug/L 9.73 (0%-20%)
Cadmium U ND U ND ug/L N/A (0%-20%)
Chromium 2430 488 ug/L .214 (0%-20%)
Copper 754 150 ug/L .368 (0%-20%)
Lead 1 12.8 J 3.85 ug/L 49.9 (0%-20%)
Selenium U ND U ND ug/L N/A (0%-20%)
Page 41 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407-[phone] -www.gel.com
QC Summary
Workorder: 595762 Page 6 of 9
Parmname NOM Sample Qual QC Units RPD/D% REC% Range Anlst Date Time
Metals Analysis-ICP
Batch 2325850
Silver U ND U ND ug/L N/A (0%-20%) TXT1 10/13/22 01:05
Metals Analysis-Mercury
Batch 2328370
QC1205215622 594714001 DUP
Mercury U ND U ND ug/L N/A JP2 10/14/2211:20
QC1205215618 LCS
Mercury 2.00 2.10 ug/L 105 (80%-120%) 10/14/2210:59
QC1205215617 MB
Mercury U ND ug/L 10/14/2210:57
QC1205215623 594714001 MS
Mercury 2.00 U ND 2.21 ug/L 109 (75%-125%) 10/14/2211:21
QC1205215624 594714001 SDILT
Mercury U ND U ND ug/L N/A (0%-10%) 10/14/2211:23
Batch 2329118
QC1205217089 595762001 DUP
Mercury J 21.2 J 11.8 ug/kg 57 ^ (+/-23.2) JP2 10/17/22 09:26
QC1205217088 LCS
Mercury 240 247 ug/kg 103 (80%-120%) 10/17/22 09:19
QC1205217087 MB
Mercury U ND ug/kg 10/17/22 09:17
QC1205217090 595762001 MS
Mercury 236 J 21.2 254 ug/kg 98.9 (80%-120%) 10/17/22 09:27
Page 42 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407-[phone] -www.gel.com
QC Summary
Workorder: 595762 Page 7 of 9
Parmname NOM Sample Qual QC Units RPD/D% REC% Range Anlst Date Time
Metals Analysis-Mercury
Batch 2329118
QC1205217091 595762001 SDILT
Mercury J 0.186 U ND ug/L N/A (0%-10%) JP2 10/17/22 09:29
Semi-Volatiles-HERB
Batch 2325943
QC1205210337 LCS
Pentachlorophenol 2.00 1.78 ug/L 89 (51%-122%) YS1 10/10/2210:54
**2,4-Dichlorophenylacetic acid 5.00 5.45 ug/L 109 (46%-144%)
QC1205210336 MB
Pentachlorophenol U ND ug/L 10/10/2210:27
**2,4-Dichlorophenylacetic acid 5.00 4.66 ug/L 93 (46%-144%)
QC1205210338 595756016 MS
Pentachlorophenol 2.00 U ND 1.88 ug/L 94 (20%-142%) 10/10/2211:49
**2,4-Dichlorophenylacetic acid 5.00 5.03 5.45 ug/L 109 (46%-144%)
QC1205210339 595756016 MSD
Pentachlorophenol 2.00 U ND 1.91 ug/L 2 96 (0%-30%) 10/10/2212:16
**2,4-Dichlorophenylacetic acid 5.00 5.03 5.80 ug/L 116 (46%-144%)
Batch 2327654
QC1205214049 LCS
Pentachlorophenol 0.0400 0.0349 mg/kg 87 (58%-123%) LOF 10/18/22 13:03
**2,4-Dichlorophenylacetic acid 0.0999 0.101 mg/kg 101 (34%-149%)
QC1205214048 MB
Pentachlorophenol U ND mg/kg 10/18/2212:44
Page 43 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407-[phone] -www.gel.com
QC Summary
Workorder: 595762 Page 8 of 9
Parmname NOM Sample Qual QC Units RPD/D% REC% Range Anlst Date Time
Semi-Volatiles-HERB
Batch 2327654
**2,4-Dichlorophenylacetic acid 0.100 0.0811 mg/kg 81 (34%-149%) LOF 10/18/22 12:44
QC1205214050 596016001 MS
Pentachlorophenol 0.0463 U ND EP 0.103 mg/kg 224* (29%-129%) 10/18/22 14:17
**2,4-Dichlorophenylacetic acid 0.116 0.0843 0.102 mg/kg 88 (34%-149%)
QC1205214051 596016001 MSD
Pentachlorophenol 0.0465 U ND EP 0.108 mg/kg 4 231* (0%-30%) 10/18/22 14:36
**2,4-Dichlorophenylacetic acid 0.116 0.0843 0.105 mg/kg 90 (34%-149%)
Spectrometric Analysis
Batch 2327899
QC1205214562 595762001 DUP
Hexavalent Chromium U ND U ND mg/kg N/A VH1 10/27/22 14:39
QC1205214564 ILCS
Hexavalent Chromium 5.48 4.65 mg/kg 84.8 (80%-120%) 10/27/22 14:38
QC1205214561 LCS
Hexavalent Chromium 3.31 3.19 mg/kg 96.3 (80%-120%) 10/27/22 14:38
QC1205214560 MB
Hexavalent Chromium U ND mg/kg 10/27/22 14:38
QC1205214563 595762001 MS
Hexavalent Chromium 3.56 U ND 4.20 mg/kg 118 (75%-125%) 10/27/22 14:40
Notes:
The Qualifiers in this report are defined as follows:
** Analyte is a surrogate compound
< Result is less than value reported
Page 44 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407-[phone] -www.gel.com
QC Summary
Workorder: 595762 Page 9 of 9
Parmname NOM Sample Qual QC Units RPD/D% REC% Range Anlst Date Time
> Result is greater than value reported
A The TIC is a suspected aldol-condensation product
B The target analyte was detected in the associated blank.
C Analyte has been confirmed by GC/MS analysis
D Results are reported from a diluted aliquot of the sample
E %difference of sample and SD is>10%. Sample concentration must meet flagging criteria
E Concentration of the target analyte exceeds the instrument calibration range
FB Mercury was found present at quantifiable concentrations in field blanks received with these samples. Data associated with the blank are deemed
invalid for reporting to regulatory agencies
H Analytical holding time was exceeded
J See case narrative for an explanation
J Value is estimated
JNX Non Calibrated Compound
N Metals--The Matrix spike sample recovery is not within specified control limits
N Organics--Presumptive evidence based on mass spectral library search to make a tentative identification of the analyte(TIC). Quantitation is based
on nearest internal standard response factor
N Presumptive evidence based on mass spectral library search to make a tentative identification of the analyte(TIC). Quantitation is based on nearest
internal standard response factor
N/A RPD or%Recovery limits do not apply.
N1 See case narrative
ND Analyte concentration is not detected above the detection limit
NJ Consult Case Narrative,Data Summary package,or Project Manager concerning this qualifier
P Organics--The concentrations between the primary and confirmation columns/detectors is>40%different. For HPLC,the difference is>70%.
Q One or more quality control criteria have not been met.Refer to the applicable narrative or DER.
R Sample results are rejected
U Analyte was analyzed for,but not detected above the MDL,MDA,MDC or LOD.
UJ Compound cannot be extracted
X Consult Case Narrative,Data Summary package,or Project Manager concerning this qualifier
Y Other specific qualifiers were required to properly define the results.Consult case narrative.
Y QC Samples were not spiked with this compound
^ RPD of sample and duplicate evaluated using+/-RL. Concentrations are<5X the RL. Qualifier Not Applicable for Radiochemistry.
h Preparation or preservation holding time was exceeded
N/A indicates that spike recovery limits do not apply when sample concentration exceeds spike conc.by a factor of 4 or more or%RPD not applicable.
^The Relative Percent Difference(RPD)obtained from the sample duplicate (DUP)is evaluated against the acceptance criteria when the sample is greater than
five times(5X)the contract required detection limit(RL).In cases where the duplicate value is less than 5X the RL,a control limit of+/-the RL is used to
evaluate the DUP result.
*Indicates that a Quality Control parameter was not within specifications.
For PS,PSD,and SDILT results,the values listed are the measured amounts,not final concentrations.
Where the analytical method has been performed under NELAP certification,the analysis has met all of the
requirements of the NELAC standard unless qualified on the QC Summary.
Page 45 of 58 SDG: 595762

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
QC Summary
Client: Koppers Utility and Industrial Products(KUIP) Report Date:October 27,2022
P.O.Box 1124 Page 1 of 1
Orangeburg,South Carolina
Contact: Jane House
Workorder: 595762
Parmname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
Notes:
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
The Qualifiers in this report are defined as follows:
** Analyte is a Tracer compound
< Result is less than value reported
> Result is greater than value reported
BD Results are either below the MDC or tracer recovery is low
FA Failed analysis.
H Analytical holding time was exceeded
J See case narrative for an explanation
J Value is estimated
K Analyte present.Reported value may be biased high.Actual value is expected to be lower.
L Analyte present.Reported value may be biased low.Actual value is expected to be higher.
M M if above MDC and less than LLD
M REMP Result>MDC/CL and<RDL
N/A RPD or%Recovery limits do not apply.
Nl See case narrative
ND Analyte concentration is not detected above the detection limit
NJ Consult Case Narrative,Data Summary package,or Project Manager concerning this qualifier
Q One or more quality control criteria have not been met.Refer to the applicable narrative or DER.
R Sample results are rejected
U Analyte was analyzed for,but not detected above the MDL,MDA,MDC or LOD.
UI Gamma Spectroscopy--Uncertain identification
UJ Gamma Spectroscopy--Uncertain identification
UL Not considered detected.The associated number is the reported concentration,which may be inaccurate due to a low bias.
X Consult Case Narrative,Data Summary package,or Project Manager concerning this qualifier
Y Other specific qualifiers were required to properly define the results.Consult case narrative.
^ RPD of sample and duplicate evaluated using+/-RL. Concentrations are<5X the RL. Qualifier Not Applicable for Radiochemistry.
h Preparation or preservation holding time was exceeded
N/A indicates that spike recovery limits do not apply when sample concentration exceeds spike conc.by a factor of 4 or more or%RPD not applicable.
**Indicates analyte is a surrogate/tracer compound.
^The Relative Percent Difference(RPD)obtained from the sample duplicate (DUP)is evaluated against the acceptence criteria when the sample is greater than
five times(5X)the contract required detection limit(RL).In cases where either the sample or duplicate value is less than 5X the RL,a control limit of+/-the
RL is used to evaluate the DUP result.
For PS,PSD,and SDILT results,the values listed are the measured amounts,not final concentrations.
Where the analytical method has been performed under NELAP certification,the analysis has met all of the requirements of the NELAC
standard unless qualified on the QC Summary.
Page 46 of 58 SDG: 595762

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® Lakilall.t' ES_L
SAMPLE RECEIPT&REVIEW FORM
Client: S➢GIARICOCIWurk Order:
Received By:MUH Date Received:
Cinlc Appinahl,
dEx Expf�s FedEx Ground UPS Field Services Courier Other
Carrier and Tracking Number
Suspected Hazard Information °' Z° Net Counts>L00cpm on samples not marked"radioactive",contact the Radlati0n Safety Group fur huther investigation.
Y
Hazard Class Shipped: UN#:
A)Shid as a DOT Hazmtlous?
If UN2910,Is the Radioactive Shipment Survey Compliant?Yes_No_
B)Did the client designate the samples are to be COC notation or radioactive stickers on containers equal client designation.
received as radioactive? -:N, J,
Maximum Net Counts Observed*(Observed Counts-Area Background Counts): CPM I mR/Hr
0 Did the RSO classify the samples as Classified as: Rad I Rad 2 Rad 3
radioactive?
00,
COC notation or hazanrd labels on containers equal client designation.
D)Did the client designate sam les are hazardous?
off D or E is ycs,select Hazards below.
E)Did the RSO identifyossihle hazards? PCBs Flammable Foreign Soil RCRA Asbestos Beryllium Other:
Sample Receipt Criteria Z Z CommentslOualiCers(Required for Non-Conforming Items)
I Shipping containers received intact and Circle Applicable_ Seal harken Damaged container Leddageantainer other(describeq
scaled?
2
Chain of custody documents included Circle Applicable: Client contacted and provided COC COC created upon receipt
with shipment?
Preservation Meda : Wet Ice)Ice Packs Dry ice None Other:
3 Samples requiring cold preservation =;ill temperature vne rec ed in Celsius TEMP:
within(0<6 deg,CM
Daily check performed and passed on IR Temperature Device Serial#:IR2-21
4 temperature gun? Secondary Temperature Device Serial#(If Applicable):
Circle Applicable: SeaLc broken Damaged container Leaking container Other(describe)
5 Sample containers intact and sealed? /A
6
Samples requiring chemical preservation, Sample Us and Containers Aftccred:
at H?
proper P IF Presery bon added,Lurk:
If Yes,are Encores or Soil Kits present for solids?Yes_No NA_(If yes,take to VOA Freezer)
Do any samples require Volatile 'Do liquid VGA vials contain acid preservation?Yes_ No NA—(If unknown,select No)
7 Analysis? Are liquid VOA vials free of headspace?Yes_No_ NA_
Sample Ill's and containen alfccted:
TM and tests affected:
S Samples received within holding time'?
Sample ID's on COC match ID's on ID's and containers affected:
9 bottles?
Date&time on COC match date&time Circle Applicable: No dates on containers No times on containers COC missing info Other(describe)
1p on bottles?
Number of containers received match le Applicable: No container count on COC Other(descrihe
11 )
number indicated on COC? C.
Are sample containers identifiable as
12 GEL providcd by use of GEL labels? f
13 COC Form is properly signed in Circle A licable Nor relin9dished Other(describe)
relinquishedireceived sections?
Curnments(Use Continuation Form if needed):
PM(or PM A)review:Initials Date Page of
GL-CHL SR-001 Rev 7
Page 49 of 58 SDG: 595762

List of current GEL Certifications as of 27 October 2022
State Certification
Alabama 42200
Alaska 17018
Alaska Drinking Water SC00012
Arkansas 880651
CLIA 42DO904046
California 2940
Colorado SC00012
Connecticut PHO 169
DoD ELAP/ISO17025 A2LA 2567.01
Florida NELAP E87156
Foreign Soils Permit P330+500283,P330+500253
Georgia SC00012
Georgia SDWA 967
Hawaii SC00012
Idaho SC00012
Illinois NELAP 200029
Indiana CSC91
Kansas NELAP E+0332
Kentucky SDWA 90129
Kentucky Wastewater 90129
Louisiana Drinking Water LA024
Louisiana NELAP 03046(AI33904)
Maine 2019020
Maryland 270
Massachusetts MSCO12
Massachusetts PFAS Approv Letter
Michigan 9976
Mississippi SC00012
Nebraska NEOS26+3
Nevada SC0001220233-
New Hampshire NELAP 2054
New Jersey NELAP SCO02
New Mexico SC00012
New York NELAP 11501
North Carolina 233
North Carolina SDWA 45709
North Dakota R+58
Oklahoma 2022+60
Pennsylvania NELAP 6800485
Puerto Rico SC00012
S.Carolina Radiochem 10120002
Sanitation Districts of L 9255651
South Carolina Chemistry 10120001
Tennessee TN 02934
Texas NELAP T104704235222-0
Utah NELAP SC0001220213-6
Vermont VT87156
Virginia NELAP 460202
Washington C780
Page 50 of 58 SDG: 595762

Technical Case Narrative
KUIP Carolina Pole Leland
SDG#: 595762
GC Semivolatile Herbicide
Product:Analysis of Chlorophenoxy Acid Herbicides by ECD
Analytical Method: SW846 3535A/8151A
Analytical Procedure: GL-OA-E-011 REV#26
Analytical Batch: 2325943
Preparation Method: SW846 3535A
Preparation Procedure: GL-OA-E-079 REV#2
Preparation Batch:2325942
The following samples were analyzed using the above methods and analytical procedure(s).
GEL Sample ID# Client Sample Identification
595762012 SL BLANK
1205210336 Method Blank(MB)
1205210337 Laboratory Control Sample(LCS)
1205210338 595756016(NonSDG)Matrix Spike(MS)
1205210339 595756016(NonSDG)Matrix Spike Duplicate(MSD)
The samples in this SDG were analyzed on an"as received"basis.
Data Summary:
All sample data provided in this report met the acceptance criteria specified in the analytical methods and
procedures for initial calibration,continuing calibration,instrument controls and process controls where
applicable,with the following exceptions.
Miscellaneous Information
Manual Integrations
Sample 1205210336(MB)required manual integration to correctly position the baseline as set in the calibration
standard injections.
Product:Analysis of Chlorophenoxy Acid Herbicides by ECD
Analytical Method: SW846 8151A
Analytical Procedure: GL-OA-E-011 REV#26
Analytical Batch:2327654
Preparation Method: SW846 8151A
Preparation Procedure: GL-OA-E-027 REV# 18
Preparation Batch:2327652
The following samples were analyzed using the above methods and analytical procedure(s).
GEL Sample ID# Client Sample Identification
Page 51 of 58 SDG: 595762

595762001 TD-1
595762002 TD-2
595762003 TD-3
595762004 TD-4
595762005 TD-5
595762006 TD-6
595762007 TD-7D
595762008 SL1 2.9-4ft
595762009 SL1 4.5-5ft
595762010 SL2 3.9-5ft
595762011 SL2 2-3.9ft
1205214048 Method Blank(MB)
1205214049 Laboratory Control Sample(LCS)
1205214050 596016001(5-13E)Matrix Spike(MS)
1205214051 596016001(5-13E)Matrix Spike Duplicate(MSD)
The samples in this SDG were analyzed on a"dry weight"basis.
Data Summary:
All sample data provided in this report met the acceptance criteria specified in the analytical methods and
procedures for initial calibration,continuing calibration,instrument controls and process controls where
applicable,with the following exceptions.
Calibration Information
Continuing Calibration Verification(CCV)Requirements
The calibration verification standards(CCV)did not meet acceptance criteria.One or more target analytes failed
acceptance criteria with a positive bias on one or both analytical columns in the standards bracketing samples
and associated QC.The positive bias for the analytical data is a result of instrument response increasing after the
initial calibration.As there were no target analytes detected in the associated samples,the data were reported.All
analytes were within the established retention time windows for this method.
Quality Control(QQ Information
Surrogate Recoveries
Sample(See Below)did not meet surrogate recovery acceptance criteria.The sample was analyzed at a dilution.
As a result,the surrogate was diluted out of the acceptance criteria and the data were reported.
Sample Analyte Value
595762008(SL1 2.9-4ft) 2,4-Dichlorophenylacetic acid 0* (34%-149%)
Spike Recovery Statement
The MS and/or MSD(See Below)did not meet spike recovery acceptance limits. Since there were no target
analytes detected in the parent sample above the reporting limits,the biased high recoveries had no adverse
impact on the reported data.
Sample Analyte Value
1205214050(5-13EMS) Pentachlorophenol 224*(29%-129%)
1205214051 (5-13EMSD) Pentachlorophenol 231* (29%-129%)
Page 52 of 58 SDG: 595762

Technical Information
Sample Dilutions
Samples 595762001 (TD-1),595762002(TD-2),595762003 (TD-3),595762005 (TD-5),595762008(SL1
2.9-4ft),595762010(SL2 3.9-5ft)and 595762011 (SL2 2-3.9ft)were diluted due to target analyte concentrations
exceeding the calibration range. Sample 595762011 (SL2 2-3.9ft)was analyzed at a dilution due to the extract
being very dirty and cloudy.
Sample Re-extraction/Re-analysis
Samples 595762001 (TD-1),595762002(TD-2),595762003 (TD-3),595762004(TD-4),595762005(TD-5),
595762006(TD-6),595762007(TD-7D),595762008(SL1 2.9-4ft),595762009(SL1 4.5-5ft),595762010(SL2
3.9-5ft)and 595762011 (SL2 2-3.9ft)were re-analyzed due to failing bracketing CCV.The re-analyzed data
were reported.
Miscellaneous Information
Manual Integrations
Samples 1205214048(MB), 1205214049(LCS), 1205214050(5-13EMS)and 1205214051 (5-13EMSD)
required manual integration to correctly position the baseline as set in the calibration standard injections.
Metals
Product: Determination of Metals by ICP
Analytical Method: SW846 3005A/6010D
Analytical Procedure: GL-MA-E-013 REV#32
Analytical Batch:2325848
Preparation Method: SW846 3005A
Preparation Procedure: GL-MA-E-006 REV# 14
Preparation Batch:2325847
The following samples were analyzed using the above methods and analytical procedure(s).
GEL Sample ID# Client Sample Identification
595762012 SL BLANK
1205210128 Method Blank(MB)ICP
1205210129 Laboratory Control Sample(LCS)
1205210130 Laboratory Control Sample Duplicate(LCSD)
1205210131 595762012(SL BLANKL)Serial Dilution(SD)
The samples in this SDG were analyzed on an"as received"basis.
Data Summary
All sample data provided in this report met the acceptance criteria specified in the analytical methods and
procedures for initial calibration,continuing calibration,instrument controls and process controls where
applicable,with the following exceptions.
Quality Control(QC)Information
Laboratory Control Sample Duplicate(LCSD)
Page 53 of 58 SDG: 595762

An LCSD was used in place of matrix QC due to the designation of field QC.
Product: Determination of Metals by ICP
Analytical Method: SW846 3050B/6010D
Analytical Procedure: GL-MA-E-013 REV#32
Analytical Batch: 2325850
Preparation Method: SW846 3050B
Preparation Procedure: GL-MA-E-009 REV#29
Preparation Batch:2325849
The following samples were analyzed using the above methods and analytical procedure(s).
GEL Sample ID# Client Sample Identification
595762001 TD-1
595762002 TD-2
595762003 TD-3
595762004 TD-4
595762005 TD-5
595762006 TD-6
595762007 TD-7D
595762008 SL1 2.9-4ft
595762009 SL1 4.5-5ft
595762010 SL2 3.9-5ft
1205210132 Method Blank(MB)ICP
1205210133 Laboratory Control Sample(LCS)
1205210136 595762001(TD-lL) Serial Dilution(SD)
1205210134 595762001(TD-1S)Matrix Spike(MS)
1205210135 595762001(TD-1SD)Matrix Spike Duplicate(MSD)
1205215884 595762001(TD-1PS)Post Spike(PS)
The samples in this SDG were analyzed on a"dry weight"basis.
Data Summary
All sample data provided in this report met the acceptance criteria specified in the analytical methods and
procedures for initial calibration,continuing calibration,instrument controls and process controls where
applicable,with the following exceptions.
Quality Control(QQ Information
Matrix Spike(MS/MSD)Recovery Statement
The percent recoveries(%R)obtained from the MS/MSD analyses are evaluated when the sample concentration
is less than four times(4X)the spike concentration added. The MS/MSD(See Below)did not meet the
recommended quality control acceptance criteria for percent recoveries for the following applicable analyte.The
post spike recovery was within the required control limits.This verifies the absence of a matrix interference in
the post-spike digested sample. The recovery may be attributed to possible sample matrix interference and/or
non-homogeneity.
Sample Analyte Value
1205210134(TD-1MS) Arsenic 38.1* (75%-125%)
Page 54 of 58 SDG: 595762

MS/MSD Relative Percent Difference(RPD)Statement
The RPD values between qualifying analyte results in the MS and MSD were not within the acceptance limits.
Sample non-homogeneity and/or possible matrix interferences may be suspected.
Sample Analyte Value
1205210134MS and 1205210135MSD(TD-1) Chromium RPD 23.6* (0%-20%)
Technical Information
Preparation/Analytical Method Verification
Method SW-846 3050B is not a total digestion technique for most samples.It is a very strong acid digestion that
will dissolve almost all elements that could become environmentally available.By design,elements bound in
silicate structures are not normally dissolved by this procedure as they are not usually mobile in the environment.
Sample Dilutions
Dilutions may be required for many reasons,including to minimize matrix interferences or to bring over range
target analyte concentrations into the linear calibration range. Sample was diluted in order to bring raw values
within the linear range of the instrument for calcium,and for the analytes interfered with,in order to ensure that
the inter-element correction factors were valid. 595762005(TD-5).
595762
Analyte
005
Chromium 5X
Silver 5X
Product: Mercury Analysis Using the Perkin Elmer Automated Mercury Analyzer
Analvtical Method: SW846 7470A
Analvtical Procedure: GL-MA-E-010 REV#38
Analvtical Batch: 2328370
Preparation Method: SW846 7470A Prep
Preparation Procedure: GL-MA-E-010 REV#38
Preparation Batch:2328363
The following samples were analyzed using the above methods and analytical procedure(s).
GEL Sample ID# Client Sample Identification
595762012 SL BLANK
1205215617 Method Blank(MB)CVAA
1205215618 Laboratory Control Sample(LCS)
1205215624 594714001(NonSDGL)Serial Dilution(SD)
1205215622 594714001(NonSDGD)Sample Duplicate(DUP)
1205215623 594714001(NonSDGS)Matrix Spike(MS)
The samples in this SDG were analyzed on an"as received"basis.
Page 55 of 58 SDG: 595762

Data Summary
There are no exceptions,anomalies or deviations from the specified methods.All sample data provided in this
report met the acceptance criteria specified in the analytical methods and procedures for initial calibration,
continuing calibration,instrument controls and process controls where applicable.
Product: Mercury Analysis Using the Perkin Elmer Automated Mercury Analyzer
Analytical Method: SW846 7471B
Analytical Procedure: GL-MA-E-010 REV#38
Analytical Batch: 2329118
Preparation Method: SW846 7471B Prep
Preparation Procedure: GL-MA-E-010 REV#38
Preparation Batch:2329110
The following samples were analyzed using the above methods and analytical procedure(s).
GEL Sample ID# Client Sample Identification
595762001 TD-1
595762002 TD-2
595762003 TD-3
595762004 TD-4
595762005 TD-5
595762006 TD-6
595762007 TD-7D
595762008 SL1 2.9-4ft
595762009 SL1 4.5-5ft
595762010 SL2 3.9-5ft
1205217087 Method Blank(MB)CVAA
1205217088 Laboratory Control Sample(LCS)
1205217091 595762001(TD-1L) Serial Dilution(SD)
1205217089 595762001(TD-1D)Sample Duplicate(DUP)
1205217090 595762001(TD-IS)Matrix Spike(MS)
The samples in this SDG were analyzed on a"dry weight"basis.
Data Summary
There are no exceptions,anomalies or deviations from the specified methods.All sample data provided in this
report met the acceptance criteria specified in the analytical methods and procedures for initial calibration,
continuing calibration,instrument controls and process controls where applicable.
General Chemistry
Product: Hexavalent Chromium
Analytical Method: SW846 7196A
Analytical Procedure: GL-GC-E-044 REV#23
Analytical Batch: 2327899
Page 56 of 58 SDG: 595762

Preparation Method: SW846 3060A
Preparation Procedure: GL-GC-E-044 REV#23
Preparation Batch:2327898
The following samples were analyzed using the above methods and analytical procedure(s).
GEL Sample ID# Client Sample Identification
595762001 TD-1
595762002 TD-2
595762003 TD-3
595762004 TD-4
595762005 TD-5
595762006 TD-6
595762007 TD-71)
595762008 SU 2.9-4ft
595762009 SU 4.5-5ft
595762010 SL2 3.9-5ft
1205214560 Method Blank(MB)
1205214561 Laboratory Control Sample(LCS)
1205214562 595762001(TD-1)Sample Duplicate(DUP)
1205214563 595762001(TD-1)Matrix Spike(MS)
1205214564 Insoluble Lab Control Sample(ILCS)
The samples in this SDG were analyzed on a"dry weight"basis.
Data Summary
There are no exceptions,anomalies or deviations from the specified methods.All sample data provided in this
report met the acceptance criteria specified in the analytical methods and procedures for initial calibration,
continuing calibration,instrument controls and process controls where applicable.
Radiochemistry
Product: Dry Weight
Preparation Method:ASTM D 2216(Modified)
Preparation Procedure: GL-OA-E-020 REV# 13
Preparation Batch:2326049
The following samples were analyzed using the above methods and analytical procedure(s).
GEL Sample ID# Client Sample Identification
595762001 TD-1
595762002 TD-2
595762003 TD-3
595762004 TD-4
595762005 TD-5
595762006 TD-6
595762007 TD-7D
595762008 SL1 2.9-4ft
595762009 SL1 4.5-5ft
595762010 SL2 3.9-5ft
595762011 SL2 2-3.9ft
1205210578 595809001(NonSDG)Sample Duplicate(DUP)
Page 57 of 58 SDG: 595762

The samples in this SDG were analyzed on an"as received"basis.
Data Summary:
There are no exceptions,anomalies or deviations from the specified methods.All sample data provided in this
report met the acceptance criteria specified in the analytical methods and procedures for initial calibration,
continuing calibration,instrument controls and process controls where applicable.
Certification Statement
Where the analytical method has been performed under NELAP certification,the analysis has met all of the
requirements of the NELAC standard unless otherwise noted in the analytical case narrative.
Page 58 of 58 SDG: 595762

® LaboratorieS LLc
PU Box N712 Charleston_SC 29417
a member of The GEL Group ivc 2040 Savage Road Chad"on.8C 2N07
P 843.556.8171
F 843.766.1178
gel.com
October 28,2022
Jane House
Koppers Utility and Industrial Products(KUIP)
P. O.Box 1124
Orangeburg, South Carolina 29116
Re: Soil RCRA
Work Order: 596016
Dear Jane House:
GEL Laboratories,LLC(GEL)appreciates the opportunity to provide the enclosed analytical results for the
sample(s)we received on October 07,2022.This original data report has been prepared and reviewed in
accordance with GEL's standard operating procedures.
Test results for NELAP or ISO 17025 accredited tests are verified to meet the requirements of those standards,
with any exceptions noted. The results reported relate only to the items tested and to the sample as received by
the laboratory.These results may not be reproduced except as full reports without approval by the laboratory.
Copies of GEL's accreditations and certifications can be found on our website at www.gel.com.
Our policy is to provide high quality,personalized analytical services to enable you to meet your analytical needs
on time every time.We trust that you will find everything in order and to your satisfaction.If you have any
questions,please do not hesitate to call me at(843)556-8171,ext. 1648.
Sincerely,
Tn"� tia"
Meredith Boddiford
Project Manager
Purchase Order:TBD
Enclosures
Page 1 of 17 SDG: 596016

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407 - [phone] -www.gel.com
Certificate of Analysis Report
for
KURI001 KUIP Carolina Pole Leland
Client SDG: 596016 GEL Work Order: 596016
The Qualifiers in this report are defined as follows:
* A quality control analyte recovery is outside of specified acceptance criteria
** Analyte is a Tracer compound
** Analyte is a surrogate compound
E Concentration of the target analyte exceeds the instrument calibration range
J See case narrative for an explanation
J Value is estimated
P OrganicsThe concentrations between the primary and confirmation columns/detectors is>40%different. For
HPLC,the difference is>70%.
U Analyte was analyzed for,but not detected above the MDL,MDA,MDC or LOD.
Where the analytical method has been performed under NELAP certification,the analysis has met all of the
requirements of the NELAC standard unless qualified on the Certificate of Analysis.
The designation ND,if present,appears in the result column when the analyte concentration is not detected above
the limit as defined in the 'U' qualifier above.
This data report has been prepared and reviewed in accordance with GEL Laboratories LLC
standard operating procedures.Please direct any questions to your Project Manager,Meredith Boddiford.
wLt't'� sr&"
Reviewed by
Page 2 of 17 SDG: 596016

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 28,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: 5-13E Project: KURIO0122
Sample ID: 596016001 Client ID: KURI001
Matrix: Soil
Collect Date: 04-OCT-22 15:50
Receive Date: 07-OCT-22
Collector: Client
Moisture: 14.2%
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Metals Analysis-ICP
SW846 305013/60101)Metals, Solid"Dry Weight Corrected"
Arsenic 82.3 0.489 2.93 mg/kg 83.9 1 LS 10/12/22 1047 2326600 1
Semi-Volatiles-HERB
SW846 8151A Herbicides,Solid"Dry Weight Corrected"
Pentachlorophenol U ND 0.00192 0.00578 mg/kg 0.198 1 LOF 10/18/22 1359 2327654 2
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 3050B SW846 3050B Prep CD3 10/11/22 1650 2326599
SW846 8151A 8151A Herbicides Prep in Soil Si 10/14/22 0754 2327652
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 3050B/6010D
2 SW846 8151A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW846 8151A Herbicides,Solid"Dry Weight 0.0843 mg/kg 0.116 73 (34%-149%)
Corrected"
Notes:
Column headers are defined as follows:
DF: Dilution Factor Lc/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 3 of 17 SDG: 596016

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Report Date: October 28,2022
Company: Koppers Utility and Industrial Products(KUIP)
Address : P.O.Box 1124
Orangeburg, South Carolina 29116
Contact: Jane House
Project: Soil RCRA
Client Sample ID: 5-14W Project: KURIO0122
Sample ID: 596016002 Client ID: KURI001
Matrix: Soil
Collect Date: 04-OCT-22 15:15
Receive Date: 07-OCT-22
Collector: Client
Moisture: 7.27%
Parameter Qualifier Result DL RL Units PF DF Analyst Date Time Batch Method
Metals Analysis-ICP
SW846 305013/60101)Metals, Solid"Dry Weight Corrected"
Arsenic 19.4 0.481 2.88 mg/kg 89.1 1 LS 10/12/22 1057 2326600 1
Semi-Volatiles-HERB
SW846 8151A Herbicides,Solid"Dry Weight Corrected"
Pentachlorophenol J 0.00344 0.00178 0.00537 mg/kg 0.199 1 YS1 10/19/22 1218 2327654 3
The following Prep Methods were performed:
Method Description Analyst Date Time Prep Batch
SW846 3050B SW846 3050B Prep CD3 10/11/22 1650 2326599
SW846 8151A 8151A Herbicides Prep in Soil Si 10/14/22 0754 2327652
The following Analytical Methods were performed:
Method Description Analyst Comments
1 SW846 3050B/6010D
2 SW846 8151A
3 SW846 8151A
Surrogate/Tracer Recovery Test Result Nominal Recovery% Acceptable Limits
2,4-Dichlorophenylacetic acid SW846 8151A Herbicides,Solid"Dry Weight 0.0904 mg/kg 0.107 84 (34%-149%)
Corrected"
Notes:
Column headers are defined as follows:
DF: Dilution Factor Lc/LC:Critical Level
DL:Detection Limit PF:Prep Factor
MDA:Minimum Detectable Activity RL:Reporting Limit
MDC:Minimum Detectable Concentration SQL: Sample Quantitation Limit
Page 4 of 17 SDG: 596016

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Company: Koppers Utility and Industrial
Address : Products(KUIP)
P.O.Box 1124
Orangeburg,South Carolina 29116 Report Date: October 28,2022
Contact: Jane House
Project: Soil RCRA
Client Sample ID: 5-13E Project: KURI00122
Sample ID: 596016001 Client ID: KURI001
Matrix: Soil
Collect Date: 04-OCT-22
Receive Date: 07-OCT-22
Collector: Client
Moisture: 14.2%
Parameter Qualifier Result Uncertainty MDC TPU RL Units PIT DF Analyst Date Time Batch Mtd.
Gravimetric Solids
"As Received"
The following Analytical Methods were performed
Method Description
1 ASTM D 2216(Modified)
Surrogate/Tracer Recovery Test Batch ID Recovery% Acceptable Limits
Notes:
The MDC is a sample specific MDC.
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
Column headers are defined as follows:
DF:Dilution Factor Mtd.:Method
DL:Detection Limit PF:Prep Factor
Lc/LC: Critical Level RL:Reporting Limit
MDA:Minimum Detectable Activity TPU:Total Propagated Uncertainty
MDC:Minimum Detectable Concentration
Page 5 of 17 SDG: 596016

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
Certificate of Analysis
Company: Koppers Utility and Industrial
Address : Products(KUIP)
P.O.Box 1124
Orangeburg,South Carolina 29116 Report Date: October 28,2022
Contact: Jane House
Project: Soil RCRA
Client Sample ID: 5-14W Project: KURIO0122
Sample ID: 596016002 Client ID: KURI001
Matrix: Soil
Collect Date: 04-OCT-22
Receive Date: 07-OCT-22
Collector: Client
Moisture: 7.27%
Parameter Qualifier Result Uncertainty MDC TPU RL Units PF DF Analyst Date Time Batch Mtd.
Gravimetric Solids
'As Received"
The following Analytical Methods were performed
Method Description
1 ASTM D 2216(Modified)
Surrogate/Tracer Recovery Test Batch ID Recovery% Acceptable Limits
Notes:
The MDC is a sample specific MDC.
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
Column headers are defined as follows:
DF:Dilution Factor Mtd.:Method
DL:Detection Limit PF: Prep Factor
Lc/LC: Critical Level RL:Reporting Limit
MDA:Minimum Detectable Activity TPU:Total Propagated Uncertainty
MDC: Minimum Detectable Concentration
Page 6 of 17 SDG: 596016

GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407-[phone] -www.gel.com
QC Summary
Koppers Utility and Industrial Products(KUIP) Renort Date:October 28,2022
Page 1 of 3
P.O.Box 1124
Orangeburg,South Carolina
Contact: Jane House
Workorder: 596016
Parmname NOM Sample Qual QC Units RPD/D% REC% Range Anlst Date Time
Metals Analysis-ICP
Batch 2326600
QC1205211685 LCS
Arsenic 42.2 39.5 mg/kg 93.6 (80%-120%) LS 10/12/2210:44
QC1205211684 MB
Arsenic U ND mg/kg 10/12/2210:40
QC1205211686 596016001 MS
Arsenic 53.4 82.3 85.5 mg/kg 6.1* (75%-125%) 10/12/22 10:50
QC1205211687 596016001 MSD
Arsenic 50.9 82.3 103 mg/kg 18.8 41.3* (0%-20%) 10/12/22 10:52
QC1205216169 596016001 PS
Arsenic 500 842 1430 ug/L 118 (75%-125%) 10/13/22 13:31
QC1205211688 596016001 SDILT
Arsenic 842 167 ug/L .589 (0%-20%) 10/12/2210:54
Semi-Volatiles-HERB
Batch 2327654
QC1205214049 LCS
Pentachlorophenol 0.0400 0.0349 mg/kg 87 (58%-123%) LOF 10/18/22 13:03
**2,4-Dichlorophenylacetic acid 0.0999 0.101 mg/kg 101 (34%-149%)
QC1205214048 MB
Pentachlorophenol U ND mg/kg 10/18/2212:44
**2,4-Dichlorophenylacetic acid 0.100 0.0811 mg/kg 81 (34%-149%)
Page 7 of 17 SDG: 596016

GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407-[phone] -www.gel.com
QC Summary
Workorder: 596016 Page 2 of 3
Parmname NOM Sample Qual QC Units RPD/D% REC% Range Anlst Date Time
Semi-Volatiles-HERB
Batch 2327654
QC1205214050 596016001 MS
Pentachlorophenol 0.0463 U ND EP 0.103 mg/kg 224* (29%-129%) LOF 10/18/2214:17
**2,4-Dichlorophenylacetic acid 0.116 0.0843 0.102 mg/kg 88 (34%-149%)
QC1205214051 596016001 MSD
Pentachlorophenol 0.0465 U ND EP 0.108 mg/kg 4 231* (0%-30%) 10/18/22 14:36
**2,4-Dichlorophenylacetic acid 0.116 0.0843 0.105 mg/kg 90 (34%-149%)
Notes:
The Qualifiers in this report are defined as follows:
** Analyte is a surrogate compound
< Result is less than value reported
> Result is greater than value reported
A The TIC is a suspected aldol-condensation product
B The target analyte was detected in the associated blank.
C Analyte has been confirmed by GUMS analysis
D Results are reported from a diluted aliquot of the sample
E %difference of sample and SD is>10%. Sample concentration must meet flagging criteria
E Concentration of the target analyte exceeds the instrument calibration range
FB Mercury was found present at quantifiable concentrations in field blanks received with these samples. Data associated with the blank are deemed
invalid for reporting to regulatory agencies
H Analytical holding time was exceeded
J See case narrative for an explanation
J Value is estimated
JNX Non Calibrated Compound
N Metals--The Matrix spike sample recovery is not within specified control limits
N Organics--Presumptive evidence based on mass spectral library search to make a tentative identification of the analyte(TIC). Quantitation is based
on nearest internal standard response factor
N Presumptive evidence based on mass spectral library search to make a tentative identification of the analyte(TIC). Quantitation is based on nearest
internal standard response factor
N/A RPD or%Recovery limits do not apply.
N1 See case narrative
ND Analyte concentration is not detected above the detection limit
NJ Consult Case Narrative,Data Summary package,or Project Manager concerning this qualifier
Page 8 of 17 SDG: 596016

GEL LABORATORIES LLC
2040 Savage Road Charleston, SC 29407-[phone] -www.gel.com
QC Summary
Workorder: 596016 Page 3 of 3
Parmname NOM Sample Qual QC Units RPD/D% REC% Range Anlst Date Time
P Organics--The concentrations between the primary and confirmation columns/detectors is>40%different. For HPLC,the difference is>70%.
Q One or more quality control criteria have not been met.Refer to the applicable narrative or DER.
R Sample results are rejected
U Analyte was analyzed for,but not detected above the MDL,MDA,MDC or LOD.
UJ Compound cannot be extracted
X Consult Case Narrative,Data Summary package,or Project Manager concerning this qualifier
Y Other specific qualifiers were required to properly define the results.Consult case narrative.
Y QC Samples were not spiked with this compound
^ RPD of sample and duplicate evaluated using+/-RL. Concentrations are<5X the RL. Qualifier Not Applicable for Radiochemistry.
h Preparation or preservation holding time was exceeded
N/A indicates that spike recovery limits do not apply when sample concentration exceeds spike conc.by a factor of 4 or more or%RPD not applicable.
The Relative Percent Difference(RPD)obtained from the sample duplicate (DUP)is evaluated against the acceptance criteria when the sample is greater than
five times(5X)the contract required detection limit(RL).In cases where the duplicate value is less than 5X the RL,a control limit of+/-the RL is used to
evaluate the DUP result.
*Indicates that a Quality Control parameter was not within specifications.
For PS,PSD,and SDILT results,the values listed are the measured amounts,not final concentrations.
Where the analytical method has been performed under NELAP certification,the analysis has met all of the
requirements of the NELAC standard unless qualified on the QC Summary.
Page 9 of 17 SDG: 596016

GEL LABORATORIES LLC
2040 Savage Road Charleston SC 29407-[phone] -www.gel.com
QC Summary
Client: Koppers Utility and Industrial Products(KUIP) Report Date:October 28,2022
P.O.Box 1124 Page 1 of 1
Orangeburg,South Carolina
Contact: Jane House
Workorder: 596016
Parmname NOM Sample Qual QC Units RPD% REC% Range Anlst Date Time
Notes:
TPU and Counting Uncertainty are calculated at the 95%confidence level(1.96-sigma).
The Qualifiers in this report are defined as follows:
** Analyte is a Tracer compound
< Result is less than value reported
> Result is greater than value reported
BD Results are either below the MDC or tracer recovery is low
FA Failed analysis.
H Analytical holding time was exceeded
J See case narrative for an explanation
J Value is estimated
K Analyte present.Reported value may be biased high.Actual value is expected to be lower.
L Analyte present.Reported value may be biased low.Actual value is expected to be higher.
M M if above MDC and less than LLD
M REMP Result>MDC/CL and<RDL
N/A RPD or%Recovery limits do not apply.
Nl See case narrative
ND Analyte concentration is not detected above the detection limit
NJ Consult Case Narrative,Data Summary package,or Project Manager concerning this qualifier
Q One or more quality control criteria have not been met.Refer to the applicable narrative or DER.
R Sample results are rejected
U Analyte was analyzed for,but not detected above the MDL,MDA,MDC or LOD.
UI Gamma Spectroscopy--Uncertain identification
UJ Gamma Spectroscopy--Uncertain identification
UL Not considered detected.The associated number is the reported concentration,which may be inaccurate due to a low bias.
X Consult Case Narrative,Data Summary package,or Project Manager concerning this qualifier
Y Other specific qualifiers were required to properly define the results.Consult case narrative.
^ RPD of sample and duplicate evaluated using+/-RL. Concentrations are<5X the RL. Qualifier Not Applicable for Radiochemistry.
h Preparation or preservation holding time was exceeded
N/A indicates that spike recovery limits do not apply when sample concentration exceeds spike conc.by a factor of 4 or more or%RPD not applicable.
**Indicates analyte is a surrogate/tracer compound.
^The Relative Percent Difference(RPD)obtained from the sample duplicate (DUP)is evaluated against the acceptence criteria when the sample is greater than
five times(5X)the contract required detection limit(RL).In cases where either the sample or duplicate value is less than 5X the RL,a control limit of+/-the
RL is used to evaluate the DUP result.
For PS,PSD,and SDILT results,the values listed are the measured amounts,not final concentrations.
Where the analytical method has been performed under NELAP certification,the analysis has met all of the requirements of the NELAC
standard unless qualified on the QC Summary.
Page 10 of 17 SDG: 596016

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age 101 of rS G: 6-0 _ = V

Laboratories E..(..c
SAMPLE RECEIPT&REVIEW FORM
Client. SDGIARICOCIWork Older: 4LP
Received>3 ;Thyasia Tatum Date Received: I6 +
Cin;lc Applirnhlc:
1 edSx Expres. FedEx Ground UPS Field Services Courier Other
Carrier and Tracidng Number
Suspected Hazard information Z *If Net Counts>10(}cpm on samples not m IAMI"radionetive",contact the Radiation Safety Omup for fiinher investigation.
azartl Class Shipped: UN#:
A)Shied as a DOT Hazurxlous?
If p y es UN2910,Is the Radioactive Shipment Survey Compleant?Y No
8)Did the client designate the samples r e to be COC notation ornrlluactive clickers on containers equal-chum&stioati"
received as radioactive?
C)Did the RSO classify the samples as Maximum Net Counts Observed`(Observed Counts-Area Background Counts): CPM 1 mR/Hr
radioactive? Clnssilled as: Rod 1 Rod 2 Rod 3
,QG no4atroo or hazard labels on contariicis equal clicnt'desr auon
D)Did the client designate samples are hazardous?
YD or E is yes,select Hazards below.
B)Did the R50 identify possible hazards? PCBs Flammable Foreign Soil RCRA Asbestos Beryllium Other:
Sample Receipt Criteria ° ContmentslQualifiers(Requir(d for Non-Conforming Items)
1 Shipping containers received intact and Cinde Applicable: Seats broken Danmged container Leaking container Other(describe)
scaled?
2 Chain of custody documents included Circle Applicable; Client [acted and provided COC COC created upon receipt
with shipment?
preservation tvlethod: Wet Ic• Ice Packs Dry ice None Other:
3 Samples requiring cold preservation *all temperatures ortled in Celsius TEMP:
within(0<6 deg.C)?*
Daily check performed and passed on IIZ Temperature Device Serial#:1R2-2a
4 temperature gun? Secondary Temperature Device Serial S(if Applicable):
Circle Applicabte: Seats hroken Damaged container lxuking container Other(describe)
S Sample containers intact and sealed?
6
Samples requiring chemical preservation Sample IDs and Containers Affected:
at proper pH?
If P .ervntion added,Lot#:
es,are Encores or Soil Kits present for solids?Yes Nc NA (if yes,take to VOA Freezer)
Do any samples require Volatile Do liquid VOA vials contain acid preservation?Yes No— NA_(ff unknown,select No)
7 Analysis? Am liquid VOA vials fine of headspace?Yes No NA_
Sample ID's and containers alfacled:
ID's and tests affected:
8 Samples received within holding time?
Sample ID's on COC match ID's on ID's and containers affected!
9 bottles?
ltl Date&time on COC match date&(inre Circle Applicable: No dales on containers No times oil containers COC missing into Other(describe)
on battles?
11 Number of containers received match Circle Applicable: No container count on COC Other(descdbe)
number indicated on COC?
Are sample containers identifiable as
12 GEL provided b use of GFL labels?
13 COC form is properly signed in Circle Applicable: Not relinquished Other(describe)
relinquislredlreceived sections?
Comments(Use Continuation Fumy if needed):
Ptvl(or PtNA)review:Initials Date]RW, Page�of
GL-CHL-SR-001 Rev 7
Page 13 of 17 SDG: 596016

List of current GEL Certifications as of 28 October 2022
State Certification
Alabama 42200
Alaska 17018
Alaska Drinking Water SC00012
Arkansas 880651
CLIA 42DO904046
California 2940
Colorado SC00012
Connecticut PHO 169
DoD ELAP/ISO17025 A2LA 2567.01
Florida NELAP E87156
Foreign Soils Permit P330+500283,P330+500253
Georgia SC00012
Georgia SDWA 967
Hawaii SC00012
Idaho SC00012
Illinois NELAP 200029
Indiana CSC91
Kansas NELAP E+0332
Kentucky SDWA 90129
Kentucky Wastewater 90129
Louisiana Drinking Water LA024
Louisiana NELAP 03046(AI33904)
Maine 2019020
Maryland 270
Massachusetts MSCO12
Massachusetts PFAS Approv Letter
Michigan 9976
Mississippi SC00012
Nebraska NEOS26+3
Nevada SC0001220233-
New Hampshire NELAP 2054
New Jersey NELAP SCO02
New Mexico SC00012
New York NELAP 11501
North Carolina 233
North Carolina SDWA 45709
North Dakota R+58
Oklahoma 2022+60
Pennsylvania NELAP 6800485
Puerto Rico SC00012
S.Carolina Radiochem 10120002
Sanitation Districts of L 9255651
South Carolina Chemistry 10120001
Tennessee TN 02934
Texas NELAP T104704235222-0
Utah NELAP SC0001220213-6
Vermont VT87156
Virginia NELAP 460202
Washington C780
Page 14 of 17 SDG: 596016

Technical Case Narrative
KUIP Carolina Pole Leland
SDG#: 596016
GC Semivolatile Herbicide
Product:Analysis of Chlorophenoxy Acid Herbicides by ECD
Analytical Method: SW846 8151A
Analytical Procedure: GL-OA-E-011 REV#26
Analytical Batch: 2327654
Preparation Method: SW846 8151A
Preparation Procedure: GL-OA-E-027 REV# 18
Preparation Batch:2327652
The following samples were analyzed using the above methods and analytical procedure(s).
GEL Sample ID# Client Sample Identification
596016001 5-13E
596016002 5-14W
1205214048 Method Blank(MB)
1205214049 Laboratory Control Sample(LCS)
1205214050 596016001(5-13E)Matrix Spike(MS)
1205214051 596016001(5-13E)Matrix Spike Duplicate(MSD)
The samples in this SDG were analyzed on a"dry weight"basis.
Data Summary:
All sample data provided in this report met the acceptance criteria specified in the analytical methods and
procedures for initial calibration,continuing calibration,instrument controls and process controls where
applicable,with the following exceptions.
Calibration Information
Continuing Calibration Verification(CCV)Requirements
The calibration verification standards(CCV)did not meet acceptance criteria.One or more target analytes failed
acceptance criteria with a positive bias on one or both analytical columns in the standards bracketing samples
and associated QC.The positive bias for the analytical data is a result of instrument response increasing after the
initial calibration.As there were no target analytes detected in the associated samples,the data were reported.All
analytes were within the established retention time windows for this method.
Quality Control(QQ Information
Spike Recovery Statement
The MS and/or MSD(See Below)did not meet spike recovery acceptance limits. Since there were no target
analytes detected in the parent sample above the reporting limits,the biased high recoveries had no adverse
impact on the reported data.
Sample Analyte Value
Page 15 of 17 SDG: 596016

1205214050(5-13EMS) Pentachlorophenol 224* (29%-129%)
1205214051 (5-13EMSD) Pentachlorophenol 231* (29%-129%)
Technical Information
Sample Re-extraction/Re-analysis
Sample 596016002(5-14W)was re-analyzed due to failing bracketing CCV. The re-analyzed data were
reported.
Miscellaneous Information
Manual Integrations
Samples 1205214048(MB), 1205214049(LCS), 1205214050(5-13EMS), 1205214051 (5-13EMSD)and
596016001 (5-13E)required manual integration to correctly position the baseline as set in the calibration
standard injections.
Metals
Product: Determination of Metals by ICP
Analytical Method: SW846 3050B/6010D
Analytical Procedure: GL-MA-E-013 REV#32
Analytical Batch: 2326600
Preparation Method: SW846 3050B
Preparation Procedure: GL-MA-E-009 REV#29
Preparation Batch:2326599
The following samples were analyzed using the above methods and analytical procedure(s).
GEL Sample ID# Client Sample Identification
596016001 5-13E
596016002 5-14W
1205211684 Method Blank(MB)ICP
1205211685 Laboratory Control Sample(LCS)
1205211688 596016001(5-13EL)Serial Dilution(SD)
1205211686 596016001(5-13ES)Matrix Spike(MS)
1205211687 596016001(5-13ESD)Matrix Spike Duplicate(MSD)
1205216169 596016001(5-13EPS)Post Spike(PS)
The samples in this SDG were analyzed on a"dry weight"basis.
Data Summary•
All sample data provided in this report met the acceptance criteria specified in the analytical methods and
procedures for initial calibration,continuing calibration,instrument controls and process controls where
applicable,with the following exceptions.
Quality Control(QQ Information
Matrix Spike(MS/MSD)Recovery Statement
The percent recoveries(%R)obtained from the MS/MSD analyses are evaluated when the sample concentration
Page 16 of 17 SDG: 596016

is less than four times(4X)the spike concentration added. The MS/MSD(See Below)did not meet the
recommended quality control acceptance criteria for percent recoveries for the following applicable analytes.
The post spike recoveries were within the required control limits. This verifies the absence of a matrix
interference in the post-spike digested sample.The recoveries may be attributed to possible sample matrix
interference and/or non-homogeneity.
Sample Analyte Value
1205211686(5-13EMS) Arsenic 6.1* (75%-125%)
1205211687(5-13EMSD) Arsenic 41.3*(75%-125%)
Technical Information
Preparation/Analytical Method Verification
Method SW-846 3050B is not a total digestion technique for most samples.It is a very strong acid digestion that
will dissolve almost all elements that could become environmentally available.By design,elements bound in
silicate structures are not normally dissolved by this procedure as they are not usually mobile in the environment.
Radiochemistry
Product: Dry Weight
Preparation Method:ASTM D 2216(Modified)
Preparation Procedure: GL-OA-E-020 REV# 13
Preparation Batch:2326768
The following samples were analyzed using the above methods and analytical procedure(s).
GEL Sample ID# Client Sample Identification
596016001 5-13E
596016002 5-14W
1205212117 595914012(NonSDG)Sample Duplicate(DUP)
The samples in this SDG were analyzed on an"as received"basis.
Data Summary•
There are no exceptions,anomalies or deviations from the specified methods.All sample data provided in this
report met the acceptance criteria specified in the analytical methods and procedures for initial calibration,
continuing calibration,instrument controls and process controls where applicable.
Certification Statement
Where the analytical method has been performed under NELAP certification,the analysis has met all of the
requirements of the NELAC standard unless otherwise noted in the analytical case narrative.
Page 17 of 17 SDG: 596016