NCD024900987_20230201_Holcomb Creosote Company_UFP-QAPP for RA Sampling

FINAL
UNIFORM FEDERAL POLICY
QUALITY ASSURANCE PROJECT PLAN

HOLCOMB CREOSOTE COMPANY SITE
YADKINVILLE, YADKIN COUNTY, NORTH CAROLINA

Prepared for:

U.S. Environmental Protection Agency Region 4
Atlanta Federal Center
61 Forsyth Street, SW
Atlanta, GA 30303-3104

Design and Engineering Services (DES) Contract 68HE0318D0006
Task Order 68HE0422F0071

Prepared by:

HydroGeoLogic, Inc.
DES CLIN 2
HGL Region 4 Office
1745 Phoenix Boulevard, Suite 200
Atlanta, GA 30349

February 2023
TABLE OF CONTENTS
Page
U.S. EPA Region 4
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INTRODUCTION .......................................................................................................................... 1
Worksheets #1 and #2 Title and Approval Page ............................................................................. 3
Worksheets #3 and #5 Project Organization and QAPP Distribution ............................................ 5
Worksheets #4, #7, and #8 Project Personnel Qualifications and Sign-Off Sheet ......................... 7
Worksheet #6 Communication Pathways ....................................................................................... 8
Worksheet #9 Project Planning Session Summary ......................................................................... 9
Worksheet #10 Conceptual Site Model ........................................................................................ 11
Worksheet #11 Project/Data Quality Objectives .......................................................................... 24
Worksheet #12 Measurement Performance Criteria ..................................................................... 26
Worksheet #13 Secondary Data Uses and Limitations ................................................................. 29
Worksheets #14 and #16 Project Tasks and Schedule .................................................................. 30
Worksheet #15 Project Action Limits and Laboratory-Specific Quantitation Limits6 Table –
PAHs SIM in Soil/Sediment ............................................................................................. 32
Worksheet #17 Sampling Design and Rationale .......................................................................... 33
Worksheet #18 Sampling Locations and Methods ....................................................................... 35
Worksheets #19 and #30 Sample Containers, Preservation, and Hold Times .............................. 36
Worksheet #20 Field QC Summary .............................................................................................. 37
Worksheet #21 Field SOPs ........................................................................................................... 38
Worksheet #22 Field Equipment Calibration, Maintenance, Testing, and Inspection ................. 39
Worksheet #23 Analytical SOPs ................................................................................................... 40
Worksheet #24 Analytical Instrument Calibration ....................................................................... 41
Worksheet #25 Analytical Instrument and Equipment Maintenance, Testing, and Inspection ... 42
Worksheets #26 and #27 Sample Handling, Custody, and Disposal ............................................ 43
Worksheet #28 Analytical QC and CA ......................................................................................... 47
Worksheet #29 Project Documents and Records .......................................................................... 48
Worksheets #31, #32, and #33 Assessments and CA ................................................................... 51
Worksheet #34 Data Verification and Validation Inputs .............................................................. 53
Worksheet #35 Data Verification Procedures............................................................................... 54
Worksheet #36 Data Validation Procedures ................................................................................. 55
Worksheet #37 Data Usability Assessment .................................................................................. 56
REFERENCES ............................................................................................................................. 57

LIST OF APPENDICES

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Appendix A Field Sampling Plan
Appendix B Data Management Plan
Appendix C EPA Laboratory Services Branch Laboratory Operations and Quality Assurance
Manual
Appendix D HGL Standard Operating Procedures
Appendix E EPA Region 4 Standard Operating Procedures

LIST OF TABLES

Table 1 Cleanup Levels

LIST OF FIGURES

Figure 1 Site Location
Figure 2 Site Facility Plan
Figure 3 Excavated Depths and Soil Confirmation
Figure 4 Soil and Sediment Extent of Contamination
Figure 5 Extent of Naphthalene in Saprolite Groundwater
Figure 6 Extent of Naphthalene in Partially Weathered Rock Groundwater
Figure 7a Soil and Sediment, Northern Proposed Soil Boring Locations
Figure 7b Soil and Sediment, Southern Proposed Soil Boring Locations

LIST OF ACRONYMS AND ABBREVIATIONS

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° degrees
°C degrees Celsius
% percent

µg/kg micrograms per kilogram
µg/L micrograms per liter
mg/kg milligrams per kilogram

ACM asbestos-containing material

B.A. Bachelor of Arts
bgs below ground surface
B.S. Bachelor of Science

CA corrective action
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CIH Certified Industrial Hygienist
CLIN contract line item number
CLP Contract Laboratory Program
CoC chain of custody
COC contaminant of concern
CQA Certified Quality Auditor
CRQL Contract Required Quantitation Limit
CSP Certified Safety Professional

DES Design and Engineering Services
DMP Data Management Plan
DPT direct-push technology
DQI data quality indicator
DQO data quality objective

EB equipment rinsate blank
EDD electronic data deliverable
EPA U.S. Environmental Protection Agency
EQuIS Environmental Quality Information System
ER Environmental Restoration, LLC
ERRS Emergency and Rapid Response Services

FSP Field Sampling Plan
ft feet
ft/day feet per day
FTL Field Team Leader

GIS geographic information system
GPS global positioning system

LIST OF ACRONYMS AND ABBREVIATIONS (Continued)

U.S. EPA Region 4
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HASP Health and Safety Plan
HCC Holcomb Creosote Company
HGL HydroGeoLogic, Inc.
H&S health and safety

ID identification
IDQTF Intergovernmental Data Quality Task Force
ISCO in situ chemical oxidation
ISEB in situ enhanced bioremediation
ISGS in situ geochemical stabilization
ISS in situ solidification/stabilization

LOQ level of quantitation
LOQAM Laboratory Operations and Quality Assurance Manual
LSASD Laboratory Services and Applied Science Division

M.S. Master of Science
MS matrix spike
MSD matrix spike duplicate

NA not applicable
NAPL non-aqueous phase liquid
NAVD88 North American Vertical Datum of 1988
NCDEQ North Carolina Department of Environmental Quality
NOV notices of violation

PAH polynuclear aromatic hydrocarbon
PAL project action limit
P.E. Professional Engineer
P.G. Professional Geologist
Ph.D. Doctor of Philosophy
PM project manager
PWR partially weathered rock

QA quality assurance
QAPP Quality Assurance Project Plan
QC quality control
QL quantitation limit

RA Remedial Action
RCRA Resource Conservation and Recovery Act
RD Remedial Design
RI Remedial Investigation
ROD Record of Decision
RPD relative percent difference
RSCC Regional Sample Control Coordinator
LIST OF ACRONYMS AND ABBREVIATIONS (Continued)

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SIM Selected Ion Monitoring
SOP standard operating procedure
SOW statement of work
S/S solidification/stabilization
SSHO Site Safety and Health Officer

TarGOST® Tar-specific Green Optical Screening Tool
TBD to be determined
TO task order
TOCO Task Order Contracting Officer
TOCOR Task Order Contracting Officer’s Representative

UCS unconfined compressive strength
UFP Uniform Federal Policy

U.S. EPA Region 4
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UNIFORM FEDERAL POLICY-QUALITY ASSURANCE PROJECT PLAN
HOLCOMB CREOSOTE COMPANY SITE
YADKINVILLE, YADKIN COUNTY, NORTH CAROLINA

INTRODUCTION
This Uniform Federal Policy (UFP)-Quality Assurance Project Plan (QAPP) has been prepared by
HydroGeoLogic, Inc. (HGL) to describe the sampling objectives, project schedule, and quality
assurance (QA) and quality control (QC) requirements for Remedial Action (RA) Oversight
sampling and analysis activities at the Holcomb Creosote Company (HCC) Site located in
Yadkinville, Yadkin County, North Carolina. The purpose of the field investigation activities is to
collect data to support the Site’s separate soil and groundwater RAs. This work will be completed
in accordance with the requirements of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA). This project is being conducted for the U.S.
Environmental Protection Agency (EPA) Region 4 under Design and Engineering Services (DES)
Contract 68HE0318D0006, Task Order (TO) 68HE0422F0071.
This plan is specific to the HCC Site and meets the requirements and elements set forth in the EPA
guidance document entitled Uniform Federal Policy for Quality Assurance Project Plans prepared
by the Intergovernmental Data Quality Task Force (IDQTF) in 2005 with the optimized
worksheets developed by IDQTF in 2012. It also includes supplemental information and
requirements, as necessary, to support Site-specific objectives.
The UFP-QAPP is the primary planning document for TO activities. It includes the project
organization, planned activities, and QA/QC procedures necessary to complete this work. The
UFP-QAPP will be implemented to ensure that the data collected are valid for the intended end
use and that data meet the requirements of the data quality objectives (DQOs). Several other
planning documents prepared by HGL complement the UFP-QAPP and should be used in
conjunction with this document:
 A Field Sampling Plan (FSP) (Appendix A of this UFP-QAPP) that describes the
sampling objectives and activities for completing the RA data collection. The FSP
includes guidance for all field work by defining, in detail, the sampling and data-gathering
methods to be used during sampling activities.
 A Data Management Plan (DMP) (Appendix B of this UFP-QAPP) that provides
procedures for managing field and laboratory data generated by the field investigations.
 A Waste Management Plan, included as part of the FSP that describes procedures for safe
storage and disposal of wastes that will be generated during fieldwork.
 A Site Management Plan that addresses the coordination and control of Site activities
during the field investigation.
HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina

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• A Site-specific Health and Safety Plan (HASP), submitted as a separate deliverable, that
defines the preventative and protective procedures that will be implemented during the
field activities to ensure the safety of the field team.
Newly acquired data obtained from the field activities proposed in this UFP-QAPP will be used
along with existing data from previous Site investigation and remediation activities to support the
soil and groundwater RAs.
HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina
U.S. EPA Region 4
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WORKSHEETS #1 AND #2
TITLE AND APPROVAL PAGE
UFP-QAPP, HCC Site, Yadkinville, North Carolina
Document Title
EPA Region 4 Superfund Program
Lead Organization
Todd Harbage, HGL
Preparer’s Name and Organizational Affiliation
1745 Phoenix Blvd., Suite 200, Atlanta, GA,30349; [phone]; [e-mail]
Preparer’s Address, Telephone Number, and Email Address
-DQXDU\202
Preparation Date
EPA TO Contracting
Officer’s Representative (TOCOR):
Signature
Joydeb Majumder/EPA Region 4
Printed Name/Organization
Lead Contractor’s Project Manager (PM):
Signature
Todd Harbage/HGL
Printed Name/Organization
Lead Contractor’s Project QA/QC Manager:
Signature
Chris Williams/HGL
Printed Name/Organization
1/30/2023
Williams, Chris Digitally signed by Williams, Chris
Date: 2023.01.30 14:03:30 -06'00'
HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina

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WORKSHEETS #1 AND #2 (CONTINUED)
TITLE AND APPROVAL PAGE
Site Name/Project Name: HCC Site RA Oversight
Site Location: Yadkinville, Yadkin County, North Carolina
Contractor Name: HGL
Contract Number: 68HE0318D0006
Contract Title: DES
TO Number (optional): 68HE0422F0071

3. Identify guidance used to prepare the QAPP:
Uniform Federal Policy for Quality Assurance Plans (IDQTF, 2005), Uniform Federal Policy
for Quality Assurance Plans Optimized UFP-QAPP Worksheets (IDQTF, 2012), and EPA
Guidance for Quality Assurance Project Plans, EPA QA/R-5 (EPA, 2001).
2. Identify regulatory program:
National Oil and Hazardous Substances Pollution Contingency Plan; CERCLA.
3. Identify approval entities:
EPA Region 4.
4. The UFP-QAPP is: programmatic or project-specific
5. List dates of scoping sessions that were held:
A kickoff meeting was held by teleconference on November 9, 2022.
6. List dates and titles of UFP-QAPP documents written for previous site work, if
applicable: None
7. List organizational partners (stakeholders):
EPA Region 4, North Carolina Department of Environmental Quality (NCDEQ) (state
regulatory agency).
8. List data users:
HGL, EPA Region 4, NCDEQ, RA Contractor.
9. For this UFP-QAPP, some required elements or information are not applicable to the
project or are provided elsewhere; these are noted below with an explanation for their
exclusion:
All UFP-QAPP worksheets are applicable.

U.S. EPA Region 4 5 HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina WORKSHEETS #3 AND #5
PROJECT ORGANIZATION AND QAPP DISTRIBUTION
Distribution:
The following is the distribution list for this UFP-QAPP.
QAPP Recipients Title Organization Telephone Number Email Address
Document
Control
Number
Joydeb Majumder TOCOR EPA Region 4 404-562-9121 [e-mail]
Alan Rittgers DES CLIN 2 Program Manager HGL 913-317-8860 [e-mail]
Todd Harbage PM HGL 470-571-3274 [e-mail]
Chris Williams DES QA/QC Manager HGL 913-647-2536 [e-mail]
TBD Field Team Leader (FTL) HGL TBD TBD
Denise Rivers Project Chemist HGL 910-233-8460 [e-mail]
Linda Nyland Data Manager HGL 770-713-1993 [e-mail]
CLIN = contract line item number
TBD = to be determined

U.S. EPA Region 4 6 HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina WORKSHEETS #3 AND #5 (CONTINUED)
PROJECT ORGANIZATION AND QAPP DISTRIBUTION
Project Organization:
The Site-specific organizational chart for this project is presented below.

CIH = Certified Industrial Hygienist CSP = Certified Safety Professional Ph.D. = Doctor of Philosophy
CLP = Contract Laboratory Program P.E. = Professional Engineer SSHO = Site Safety and Health Officer
CQA = Certified Quality Auditor P.G. = Professional Geologist TOCO = Task Order Contracting Officer

U.S. EPA Region 4 7 HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina WORKSHEETS #4, #7, AND #8
PROJECT PERSONNEL QUALIFICATIONS AND SIGN-OFF SHEET
Site personnel, including the FTL and sampling personnel, are required to read this UFP-QAPP and sign off that they have done so
before initiating field activities.
Organization: HGL
Name Project Title/Role Education/Experience Specialized Training/Certifications Signature/Date
Todd Harbage PM
M.S., Environmental
Engineering
B.S., Environmental
Engineering
Experience: 21 years
P.E., 40-hour Hazardous Waste
Operations and Emergency Response

Chris Williams QA/QC Manager B.S., Geology
Experience: 36 years
P.G., Occupational Safety and Health
Administration 10-Hour Construction
Safety, Internal Quality Auditing
Fundamentals Training,
Manage and Supervise On-Site
Hazardous Waste Operations,
HGL Project QC Improvement Training

Denise Rivers, Ph.D. Project Chemist
Ph.D., Environmental
Chemistry
B.A., Chemistry
Experience: 19 years

TBD FTL
TBD SSHO
TBD Field Sampling Personnel
B.A. = Bachelor of Arts
B.S. = Bachelor of Science
M.S. = Master of Science

HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina U.S. EPA Region 4 8 WORKSHEET #6
COMMUNICATION PATHWAYS
Communication
Driver Organization Name Contact Information Procedure
Point of contact with
EPA
HGL Todd Harbage
(PM)
470-571-3274
[e-mail]

Project-related issues, including changes in schedule, changes in scope of
fieldwork or delays, and recommendations to stop work will be communicated
to the EPA TOCOR by phone or email.
Project information will be reported to the EPA TOCOR through monthly
progress reports, email updates, teleconferences, and meetings. The HGL PM
will document deviations from the UFP-QAPP and any corrective actions
(CAs) and will report them to the TOCOR.
UFP-QAPP changes,
modifications, or
amendments prior to
fieldwork.
HGL Denise Rivers
(Project Chemist)
910-233-8460
[e-mail]

If errors or changed conditions require modification or amendment of the
UFP-QAPP prior to fieldwork, the Project Chemist will prepare revised text.
All changes to the UFP-QAPP will require final approval from EPA.
UFP-QAPP changes
during project
execution
HGL TBD
(FTL)
TBD The FTL will notify the PM and Project Chemist of any planned field
deviations from the UFP-QAPP before implementing the changes. The
changes will be documented on a field change form and in the Site logbook.
The PM will notify the TOCOR and obtain approval for the changes.
Field CAs HGL TBD
(FTL)
TBD A CA resulting from either failure to follow UFP-QAPP requirements or
changes in Site conditions will be documented by the FTL; the FTL will
communicate the need for a CA to the PM prior to the change or at a minimum
on the same business day. The FTL may initiate an interim CA in the field
subject to final approval by the PM and QA/QC Manager.
Analytical Services
Support
HGL Linda Nyland
(Data Manager)
770-713-1993
[e-mail]
Act as a liaison with Regional Sample Control Coordinator (RSCC) for EPA
Region 4 and CLP laboratories. Generates and sends laboratory analytical
request forms.
Analytical Program
Oversight
HGL Denise Rivers
(Project Chemist)
910-233-8460
[e-mail]
Provide guidance field staff to ensure that data of required quality are
obtained. Identifies UFP-QAPP non-conformances and recommends CAs to
the PM.
Analytical Data
Quality Issues
HGL Denise Rivers
(Project Chemist)
910-233-8460
[e-mail]
Project Chemist will immediately notify the PM and work with the laboratory
to resolve the issue. PM will notify the TOCOR within 24 hours.
Overall Project
QA/QC
HGL Chris Williams
(QA/QC
Manager)
913-647-2536
[e-mail]
Communicate program QA/QC requirements to the PM and Project Chemist.
Determine need to develop procedural changes to address QA/QC
deficiencies.
Laboratory Project
Management
EPA Region 4 Nardina Turner
(RSCC)
404-562-8650
[e-mail]
Coordinate interaction of the laboratory manager, laboratory QA/QC manager,
and analytical staff with HGL, as needed, to resolve QA/QC issues.
HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina

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WORKSHEET #9
PROJECT PLANNING SESSION SUMMARY
Date of planning session: November 9, 2022
Location: EPA Region 4 Office and Teleconference
Purpose: Project Kickoff and Scoping Meeting
Participants:
Name Organization Title/Role Email
Joydeb Majumder EPA Region 4 TOCOR and Remedial Project Manager [e-mail]
Samuel Richardson EPA Region 4 TOCO [e-mail]
Keisha Dawkins EPA Region 4 Deputy TOCO [e-mail]
Dora Ann Johnson EPA Region 4 ERRS Officer [e-mail]
Luis Flores EPA Region 4 DES Officer [e-mail]
Rusty Kestle EPA Region 4 Remedial PM [e-mail]
Jasmin Jeffries EPA Region 4 Deputy Remedial PM [e-mail]
Jim Ferreira EPA Region 4 Hydrogeologist [e-mail]
Angela Moore NCDEQ Hydrogeologist [e-mail]
David Brinkmeyer ER Vice President of EPA Contracts [e-mail]
Rebecca Laramie ER Vice President of Quality [e-mail]
Andrew Grimmke ER Region 4 ERRS Program Manager [e-mail]
John Klein ER ERRS Response Manager [e-mail]
Nick Michailides ER Health and Safety (H&S) Officer [e-mail]
Alan Rittgers HGL DES CLIN 2 Program Manager [e-mail]
Todd Harbage HGL PM [e-mail]
Joyce Pankowicz
Slovenz
HGL Contracts Administrator [e-mail]
Larry Braman HGL Contracting Specialist [e-mail]
ER = Environmental Restoration, LLC
ERRS = Emergency and Rapid Response Services

Notes/Comments:
Mr. Richardson and Ms. Johnson reviewed contract procedures including key personnel and
contract modification for both HGL and ER. Ms. Johnson indicated that ER’s contract expires on
May 30, 2023, and will likely need an extension.

Mr. Majumder discussed the preparation and submittal dates of HGL and ER planning documents
with Mr. Harbage and Mr. Grimmke. Mr. Grimmke requested clarification on the list of planning
documents included in the final Remedial Design (RD) documents. Mr. Majumder requested that
ER’s planning documents be stand alone. Site visit dates, mobilization dates, pre-RA sampling,
and weekly schedules were discussed.

Mr. Majumder emphasized the need for knowledgeable, experienced staff, including subcontractor
staff. He also emphasized the importance of safety. He requested that decisions be made as a team
and that open communication be maintained. Communication documentation and file sharing were
discussed.
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Consensus decisions made:
• ER can visit the Site before the official Site visit to support preparation of the RA Work
Plan.
• ER can combine its planning documents into two deliverables: the RA Work Plan and the
Construction HASP.
• ER’s contract will need an extension.
Action Items:
• EPA will arrange the Site Visit.
• EPA will check with Laboratory Services and Applied Science Division (LSASD) for the
baseline groundwater sampling schedule.
• EPA will arrange a Community Involvement meeting with NCDEQ.
• ER will set the RA mobilization date and provide a work schedule.
• HGL will set up the file sharing website.

HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina

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WORKSHEET #10
CONCEPTUAL SITE MODEL
Environmental Problem

Soil, groundwater, and sediment at the HCC Site have been impacted by creosote-related
contaminants from former wood treating operations on the property, as documented in the Final
Remedial Investigation Report (Versar, 2017), the Final Groundwater Data Evaluation and
Conceptual Site Model Update Technical Memorandum (HGL, 2020a), the Final Soil Data
Evaluation and Conceptual Site Model Update Technical Memorandum (HGL, 2020b), and the
Final (100%) Soil Remedial Design (HGL, 2021). Additional soil, groundwater, and sediment data
are needed to fully define the extent of contamination above cleanup goals and support the separate
soil and groundwater RAs in accordance with the Site’s Record of Decision (ROD).

Site Location and History

The HCC Site is located at 5016 U.S. Highway 601, just north of Yadkinville in Yadkin County,
North Carolina (Figure 1). The geographic coordinates of the Site, as measured near the former
concrete storage pit, are latitude 36.1579 degrees (°) North and longitude 80.6752° West.

The office building and storage building, located on the western portion of the property along
U.S. Highway 601 are the only structures remaining at the Site. Structures formerly located on
HCC include the creosote storage tanks, pressure treatment vessel, drip pad and sump, canopy
covering the drip pad, concrete storage pit, steel settling tank, distillation evaporator, and untreated
and treated wood storage areas. The location of these Site features within the former operations
area is shown in Figure 2.

HCC conducted wood treating operations on the property from 1951 to 2009. In 2011, HCC was
referred to EPA’s Superfund program to address known and potentially hazardous waste
contamination under CERCLA. The Site was placed on the National Priorities List in 2012.

From 1951 to 2009, HCC operated a wood treating facility on the Site property. HCC
manufactured pressure-treated posts and lumber using creosote coal tar solutions. During facility
operations, wood products were placed in a pressurized treatment vessel and heated with steam to
open the pores of the wood and remove sap and resin. After an allotted time, the vessel was vented
to decrease the interior pressure, and a vacuum was drawn to remove moisture. Following
application of the vacuum, creosote was forced into the pores of the wood. The vapor stream from
the treatment vessel was passed through a condenser, where the water and creosote mixture was
liquefied. After treatment, condensate from the condenser and from depressurization of the
treatment vessel was pumped to a concrete-lined settling tank (i.e., the concrete storage pit). This
liquid was pumped from the concrete storage pit to a steel settling tank, where the solids settled to
the bottom. The liquids were then pumped to an unlined surface impoundment for storage and
evaporation.

After treatment, the wood was transported to a drip pad immediately south of the treatment vessel,
where it was allowed to drip dry. In the early 1990s, HCC reportedly ceased using the drip pad;
instead, the wood was allowed to dry inside the treatment vessel and was then moved to a transfer
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area located at the end of the treatment vessel. The transfer area measured approximately 25 feet
(ft) by 100 ft and consisted of soil and gravel over a plastic liner and covered by a metal roof. One
55-gallon sump was located at each end of the treatment vessel to contain any spills that occurred
when the treatment vessel doors were opened. Spilled creosote was pumped back into the treatment
vessel. A catch basin was also located at the end of the treatment vessel where the treated lumber
was removed. The treatment vessel was cleaned from time to time due to buildup of creosote and
solids. This sludge-like waste was removed and placed in 55-gallon containers that were stored in
the drum storage area until they were shipped off Site for disposal.

The surface impoundment, located at the southeastern corner of the facility, reportedly was 30 ft
by 60 ft by 6 ft deep (approximately 80,000-gallon capacity) and was used by HCC to store liquid
wastes until 1983. The surface impoundment contained waste classified as EPA hazardous waste
K001: “bottom sediment sludge from the treatment of wastewaters from wood preserving
processes that use creosote and/or pentachlorophenol.”

Before 1981, HCC constructed a 0.587-acre landfarm on the east side of an unnamed tributary of
North Deep Creek across from the operations area. Residual liquids from the surface impoundment
were pumped to the landfarm, where an irrigation system was used to spray liquids onto the land
surface. The landfarm was utilized when weather conditions did not allow for evaporation in the
surface impoundment and when the surface impoundment was near its storage capacity. From
1982 to 1983, the landfarm was used as a remediation unit for disposal of K001-contaminated
sludge and wastewater removed during closure of the surface impoundment.

Key Physical Aspects of the Site

Yadkin County lies within the northwestern portion of the Piedmont physiographic province just
east of the Blue Ridge physiographic province. The Blue Ridge and Piedmont geologic provinces
are large composite thrust sheets of folded and faulted rocks that were transported tens to hundreds
of miles to the northwest during three Paleozoic mountain-building events. The exposed rocks now
are, for the most part, the roots of an ancient mountain chain that consist of primarily igneous and
metamorphic rocks with lesser amounts of sedimentary rocks.

Lithologies identified during previous soil boring and monitoring well installation at the Site are
non-native/remolded fill, alluvium, saprolite, partially weathered rock (PWR), and metamorphic
bedrock. These lithologic features are discussed below:

• Non-native/remolded fill. Fill material in the form of a thin (approximately 1 to 2 ft
thick), orange-brown silty clay was deposited on the Site following an EPA-led removal
of contaminated soils during 2011. This surface “cap” covers HCC from Highway 601 to
the west to within approximately 10 ft of an unnamed tributary of North Deep Creek to
the east. A similar clay covers the hilltop near the closed Resource Conservation and
Recovery Act landfarm to the east of the unnamed tributary. Additional remolded soils
are present near the process buildings, likely remnants of Site construction and grading.
• Alluvium. Alluvial sediments/soil are present flanking the present stream channel of the
unnamed tributary of North Deep Creek. Alluvial materials consist of graded beds of clay,
silt, quartz, lithic and mica sands/gravels, and entrained organic/vegetative matter. The
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historic stream channel appears to have been broader than its present course, extending
west toward the facility buildings. Reduction in the stream channel breadth is the result
of backfill with remolded soil. Such fill materials cover the western margin of the
unnamed tributary channel to a depth of approximately 5 ft.
• Saprolite. Saprolitic soil at the Site was derived from in-place chemical weathering of
the native metamorphic bedrock. Site-specific geology descriptions from the Remedial
Investigation (RI) and Feasibility Study reports describe the saprolite as a predominantly
clay matrix with abundant vermiculite and other silt to sand-sized micaceous phases and
angular quartzite sand lenses. Soil descriptions from the pre-RD soil borings indicate
higher than expected content of silt, sand, and gravel in the saprolite. Pre-RD saprolite
soil samples submitted for geotechnical laboratory analysis were classified as either silty
sand or sandy silt.
• PWR. The saprolite transitions to an underlying weathered gneiss unit, identified in
previous site reports as PWR. The transition from saprolite to PWR occurs at relatively
consistent elevations of between 835 to 845 ft North American Vertical Datum of 1988
(NAVD88) over most of the western portion of the Site, generally west of the unnamed
tributary. The upper portion of the PWR is highly weathered gneiss that consists of
moderately dense, fine to coarse-grained silty sand that is gray, white, and black in color.
The PWR becomes increasingly dense with depth until it transitions to the underlying
competent metamorphic bedrock.
• Metamorphic bedrock. Bedrock identified at the Site consists of biotite and amphibolite
gneisses with varying concentrations of purple garnet. Foliation dips from near horizontal
to approximately 20°, with localized foliation discontinuities at small-scale folds and
faults. Only a limited number of previous Site borings have been advanced into the
bedrock. Review of the previous boring logs indicates that the top of competent rock is
generally found at elevations of between 820 to 830 ft NAVD88.

A characteristic feature of the region is the prevailing mantle of residual soil and saprolite that
covers the bedrock in most places. This mantle of weathered bedrock comprises chiefly sandy
clay, although fragments of solid rock are common near the bedrock surface. The thickness of this
mantle frequently ranges from about 6 ft to 60 ft, though it is absent in many places and thicker
than 60 ft in others. The mantle provides a recharge and discharge zone of water from the
underlying fractured bedrock. Igneous and metamorphic rocks and consolidated sedimentary
deposits of the region tend to be fractured to some extent, and these fractures are the chief avenues
for water movement.

Water level measurements collected during the RI and pre-RD investigation indicate that
groundwater flow direction within the saprolite zone is generally toward the southeast. The flow
direction is slightly more to the east-southeast in the PWR, and more eastward in the bedrock.
Water levels measured during the RI and pre-RD investigation ranged from 0 to 25.14 ft below
ground surface (bgs), mainly driven by changes in Site topography. Slug tests conducted during
the RI produced average geometric mean hydraulic conductivities of 10.29 feet per day (ft/day)
for the saprolite and 0.69 ft/day for the PWR. Packer testing of fracture zones in the bedrock
resulted in relatively low permeabilities ranging from 0.05 to 0.35 ft/day.

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An unnamed tributary of North Deep Creek flows from north to south through the Site. The
unnamed tributary begins north of the HCC property, flows in a southerly direction, and enters the
Site along the northern property boundary. The stream continues to flow south along the eastern
edge of the former HCC operations area and closed surface impoundment, then turns to the east
before discharging into Dobbins Pond via a wetland.
Dobbins Pond extends to the east and south of the Site for approximately 0.5 mile, where the
unnamed tributary exits the eastern side of the pond via a rock weir. After exiting Dobbins Pond,
the flow of the unnamed tributary continues for approximately 1 mile, where it discharges into
North Deep Creek.
Previous Investigations and Remedial Actions
Surface Impoundment Closure
Environmental activities were initiated in October 1982, when HCC notified the North Carolina
Solid and Hazardous Waste Branch (currently known as the NCDEQ) of its intent to close the
surface impoundment. From December 1982 to January 1983, HCC conducted closure activities
for the surface impoundment, in accordance with a closure plan approved by the NCDEQ. Closure
activities included the following:
• Removing approximately 70,000 gallons of wastewater and spraying it onto the landfarm;
• Excavating approximately 250 cubic yards of K001 sludge and contaminated soil and
emplacing it within the landfarm;
• Backfilling the former surface impoundment with clean soil; and
• Re-grading and vegetating the surface of the impoundment.
Closure of the surface impoundment was certified in April 1984. According to the closure plan,
the surface impoundment was covered with a 2-ft clay cap and 1-ft vegetative cover (clean soil
with grass). In July 2011, EPA excavated the vegetative cover over the surface impoundment down
to the cap, disposed of the excavated material off-Site, and replaced it with clean soil because of
confirmed contamination in the impoundment cover. The cap was verified to be present; however,
the thickness and permeability was not confirmed.
Landfarm Closure
HCC initiated closure of the landfarm in 1983. During closure activities, soil samples were
collected periodically at the landfarm to monitor the phenol degradation process. The closure plan
outlined sampling and waste tillage procedures until sample analysis met the 15 parts per million
phenol criterion. These procedures were followed until December 1983, when the samples met the
phenol criterion, and a closure certification application was filed with the NCDEQ. However,
NCDEQ’s review of the closure certification application raised concerns regarding chemical
constituents other than phenol potentially present in the K001 waste stream. Samples subsequently
collected from the landfarm contained creosote constituents, and NCDEQ ruled that these
compounds had to be reduced to nondetectable levels prior to issuing a certification of closure for
the landfarm.
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In August 1985, HCC was notified that additional landfarming would be required due to the
presence of creosote constituents in soil. HCC and NCDEQ entered into a Consent Order and
initiated a compliance schedule to further reduce creosote constituents. The consent order was
voided by the NCDEQ in October 1985. In June 1986, HCC and NCDEQ entered into a revised
Consent Order that allowed for continued landfarming of the K001 waste to achieve additional
biodegradation of creosote and other regulated constituents. In April 1988, HCC notified NCDEQ
that final analytical testing of the landfarm soil indicated that the performance standard for
polynuclear aromatic hydrocarbons (PAHs) had not been met, and thus, the landfarm could not be
certified as closed. As a result, the landfarm was closed as a landfill (hazardous waste in place), in
accordance with a closure plan approved by NCDEQ. A 2-ft thick clay cap was placed over the
landfarm and installed to extend a minimum of 3 ft beyond the known boundary of the landfarm.
A ditch was constructed around the landfarm area to control stormwater runon and runoff. A 1-ft
thick vegetative cover (topsoil and grass) was installed above the clay cap. The landfarm was
certified closed in September 1989.
EPA sampling activities conducted in 2011 and between 2012 and 2014 found that the landfarm
cap consists of approximately 2 ft of red, clay-like material and that the 1-ft vegetative cover is
not present. The permeability of the cap material has not been evaluated.
Groundwater Assessment
Groundwater monitoring at HCC began in 1982 with installation of three monitoring wells in the
shallow saprolite aquifer near the operations area and surface impoundment. Following closure of
the surface impoundment and construction of the landfarm, additional wells were installed in the
suspected downgradient (southeast) corner of the surface impoundment and around the landfarm
perimeter. By 2002, the groundwater monitoring network consisted of 16 monitoring wells
completed in the saprolite, PWR, and bedrock aquifers beneath the facility. The monitoring wells
were sampled annually from 1995 to 2005. Monitoring wells located within and near the backfilled
surface impoundment contained the highest concentrations of Site-related contaminants
throughout the 10-year sampling history. The primary constituents detected were PAHs and
petroleum volatile organic compounds, potentially originating from creosote and/or diesel oil used
and stored at HCC in the past (diesel oil was used to dilute the creosote mixtures).
Violations and Post-Closure Permit
From 1992 to 2002, HCC was issued several notices of violation (NOVs) including the following:
• Failure to control runon in the area of the closed surface impoundment;
• Failure to follow its post-closure Sampling and Analysis Plan;
• Failure to determine whether solid waste generated at HCC was a hazardous waste;
• Failure to obtain a permit for storage and disposal of waste creosote; and
• Failure to treat, store, and dispose of hazardous waste in compliance with state and federal
regulations.
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Around 1994, HCC stopped generating K001 waste and began generating EPA hazardous waste
F034 defined as “wastewaters, process residuals, preservative drippage, and spent formulations
from wood preserving processes generated at plants that use creosote formulations.” HCC was
issued a Post-closure Hazardous Waste Management Permit by NCDEQ in September 1995. The
permit required HCC to maintain post-closure care of the closed surface impoundment and
landfarm and to conduct groundwater monitoring and remedial activities at the facility including
installation of a wastewater treatment system. In 2005, HCC submitted a renewal application for
the Post-closure Hazardous Waste Management Permit; however, the permit was not granted due
to numerous deficiencies. In 2007, NCDEQ issued a Post-closure Hazardous Waste Management
Renewal Permit to HCC. The permit included requirements for continued post-closure care of the
surface impoundment and landfarm, and also identified eight solid waste management units
requiring a Resource Conservation and Recovery Act (RCRA) Facility Investigation.
NCDEQ Inspection
HCC ceased wood treating operations on the property in February 2009. In November 2009,
NCDEQ conducted an inspection of the facility and noted several areas of concern including the
treatment vessel, 55-gallon sump, catch basin, transfer area and underlying soils, concrete storage
pit, aboveground storage tanks, and approximately thirty 55-gallon containers. As a result, several
NOVs were issued by NCDEQ to HCC, including:
• Failure to determine whether solid waste generated at HCC was a hazardous waste;
• Failure to obtain a permit for storage and disposal of waste creosote; and
• Failure to treat, store, and dispose of hazardous waste in compliance with state and federal
regulations.
EPA Site Inspection and Removal Actions
In January 2011, EPA conducted a removal site evaluation at the request of NCDEQ. EPA noted
the following:
• Heavily stained soil throughout the process area;
• Waste creosote and process sludge in the concrete storage pit;
• A leaking 1,000-gallon aboveground storage tank;
• Two 10,000-gallon creosote tanks containing approximately 5,600 and 8,500 gallons of
creosote; and
• A visible sheen in the unnamed tributary of North Deep Creek.
As a result, EPA initiated an emergency response to mitigate the ongoing release of hazardous
substances. Response activities were conducted between January and September 2011 and
included the following:
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• Installation of a sorbent boom across the unnamed tributary of North Deep Creek to
capture visible sheen;
• Disposal of approximately 120 cubic yards of creosote-treated lumber;
• Excavation and off-Site disposal of approximately 1,600 tons of contaminated soil; and
• Removal of six facility process units (process area structures) containing creosote sludge.
EPA also conducted investigation activities in January 2011 during the emergency response and
between May and August 2011 as part of a Site Inspection. The sampling activities included
collection of soil and sediment samples along the unnamed tributary of North Deep Creek and
within the wetlands at the confluence of the tributary and Dobbins Pond, surface soil samples from
the vegetative cover of the former surface impoundment, subsurface soil samples in the vicinity of
the closed landfarm, and groundwater samples from all Site monitoring wells. EPA also completed
a wetlands delineation study at HCC in August 2011.
As a result of the sampling activities and observations during the emergency response activities,
additional Removal Actions were completed at HCC, including the following:
• Excavation and off-Site disposal of the vegetative cover of the closed surface
impoundment down to the clay cap. The clay cap was confirmed to be present, but its
thickness and permeability were not evaluated. The area was backfilled with clean soil.
• Removal and off-Site disposal of soil along the unnamed tributary of North Deep Creek.
• Removal and off-Site disposal of approximately 2 inches of sediment from 300 linear ft
of the channel bottom and sidewalls of the unnamed tributary of North Deep Creek.
• Installation of fencing to limit trespassing and contact with contamination associated with
the backfilled surface impoundment and surficial sediments in the unnamed tributary of
North Deep Creek.
• Excavation of the upper 1 ft of soil from the northern portion of the former process area.
• Removal and backfill of the concrete storage pit.
Figure 3 summarizes the extent of the removal action activities including the extent of the
excavated depths and confirmation sample locations.
Remedial Investigation
An EPA-led RI was conducted for the HCC Site between 2012 and 2017. A complete discussion
of nature and extent can be found in the Final Remedial Investigation Report (Versar, 2017).
Selected Remedy
EPA issued a ROD in August 2018 that established cleanup goals for soil, sediment, and
groundwater, and selected a remedy for the Site. The Site cleanup goals are summarized in Table 1.
The selected remedy includes the following components:
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• Excavation of contaminated soil outside of the previously closed and capped landfarm
and surface impoundment areas, and proposed containment area, as required, to mitigate
human exposure and additional leaching of contaminants into the surficial aquifer. The
excavated areas will be backfilled with uncontaminated soil obtained from an off-Site
borrow source. The excavated wetlands will be restored.
• Disposal of excavated soil in an on-Site capped containment cell, which is proposed to
be located within the former operations area. Excavated soils/sediments impacted with
non-aqueous phase liquid (NAPL) will be treated within the containment area using in
situ solidification/stabilization technology to reduce the mobility of contaminants of
concern (COCs) by eliminating free liquids and to stabilize the containment cell. The
proposed containment cell will be capped using a RCRA-type multi-layered cap that
meets the RCRA Subtitle C landfill requirements for a final cover.
• Maintenance of the existing RCRA caps over the closed landfarm and surface
impoundment including regrading, repair, and revegetation. These areas also will be
fenced to restrict access. A review of Site conditions and risks will be conducted every 5
years as long as contamination remains on Site above levels that allow for unlimited use
and unrestricted exposure. The caps will be inspected at least annually, and repairs will
be made when needed.
• In situ groundwater treatment of groundwater using in situ geochemical stabilization
(ISGS) and/or in situ chemical oxidation (ISCO) to reduce concentrations of COCs to
below cleanup levels. Bench-scale and pilot-scale tests were conducted during the RD to
confirm the effectiveness of the treatment technologies and to determine appropriate
injection rates, injection concentrations, activator selection, and injection well spacing.
The collection of post-treatment groundwater samples will be needed to assess the
effectiveness of the ISGS and ISCO treatment.
• In situ enhanced bioremediation (ISEB) using a reagent such as slow release calcium
peroxide will be implemented after the ISCO/ISGS treatment in remaining areas with
elevated groundwater COC concentrations. A pilot-scale test was performed during the
RD to select the appropriate ISEB reagents. The goal of the in situ treatments is the
restoration of groundwater throughout the plume beyond the waste management areas to
attain federal as well as more stringent state drinking water standards based on the
designated beneficial use of the aquifer as a potential drinking water source.
• Groundwater monitoring will be implemented to verify the effectiveness of the
containment system, soil stabilization, and groundwater treatment. Data collected from
the monitoring wells will be evaluated to determine if additional injections of treatment
reagents are required to treat the groundwater. The monitoring well network will be
expanded to include additional wells downgradient of the containment cell, as necessary.
Groundwater monitoring wells will be added, as needed, outside of the containment unit
boundary to assess if there are any releases from the unit.
• Institutional controls and engineering controls will be implemented to preserve the
integrity of the remedy and restrict land use to eliminate or reduce the potential for
unacceptable human health risks from exposure to contamination. Institutional controls
will be used to restrict future use of the property to industrial/commercial uses in areas
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that do not allow for unrestricted access and use, prohibit excavation and construction
over the capped area, prohibit the installation of new water supply wells within the plume
area, and prohibit the use of groundwater for drinking water supply within the plume area.
Engineering controls, such as fencing, will be placed around the containment cell, closed
landfarm, and closed surface impoundment. Regular inspections will be performed to
verify the continued implementation of the groundwater use restrictions and the integrity
of the engineering controls and RCRA caps.

The results of the ISGS/ISCO and ISEB pilot-scale tests indicated that ISGS/ISCO is less effective
than ISEB. Accordingly, the Final (100%) Groundwater Remedial Design included only ISEB as
the groundwater remedy (HGL, 2022). However, since ISGS would not be used treat NAPL below
the water table, in situ solidification/ stabilization (ISS) was added to the Final (100%) Soil
Remedial Design (HGL, 2021).
Pre-RD Investigation
In February 2020, a North Carolina-licensed professional land surveyor (Donaldson, Garrett &
Associates, Inc.) performed a topographic survey to document Site topography, existing
conditions, property boundaries, and Site features. The survey was referenced horizontally to the
North Carolina State Plane Coordinate System, North American Datum of 1983, and vertically to
the NAVD88. Horizontal accuracy was within ±0.1 ft; vertical accuracy was within ±0.01 ft.
In February 2020, 47 existing Site groundwater monitoring wells were sampled to provide
groundwater concentration data for the selection of new monitoring well locations. In March 2020,
two permanent saprolite monitoring wells, five permanent PWR monitoring wells, and one
temporary PWR monitoring well were installed. The temporary PWR monitoring well was
abandoned so it would not interfere with the agricultural usage of the field where it was located.
Results from the groundwater investigation were used to further delineate the horizontal extent of
naphthalene contamination greater than the North Carolina groundwater standard of 6 micrograms
per liter (µg/L) and to assist in defining the groundwater treatment areas.
In February, August, and October 2020, a total of 50 surface soil samples and 129 subsurface soil
samples were collected. Results from the soil investigation were used to define the extent of
naphthalene concentrations greater than the Site-specific groundwater protection value of 180
micrograms per kilogram (µg/kg) in unsaturated soils above the water table and to evaluate the
presence and extent of NAPL.
In August and October 2020, a total of five sediment samples were collected. Results from the
sediment investigation were used to define the extent of PAH concentrations greater than the
maximum acceptable toxicant concentration of 198 milligrams per kilogram (mg/kg) total PAHs.
In February 2020, a source area NAPL investigation was conducted to evaluate the presence and
extent of NAPL in the Site source areas using Tar-specific Green Optical Screening Tool
(TarGOST®) laser-induced fluorescence soil logging technology. In total, 40 TarGOST® borings
were advanced via direct-push technology (DPT) to refusal, at the 38 locations. At two locations,
duplicate offset borings were performed for field quality control purposes. The TarGOST® borings
included 23 initial locations selected based on historical Site operations and previous analytical
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results and 15 step-out locations selected in the field to delineate potential NAPL. After field
review of TarGOST® logs, locations were selected for offset exploratory borings to visually
confirm potential TarGOST® NAPL detections. Exploratory borings were advanced to DPT refusal
at nine locations adjacent to TarGOST® locations
In March 2020, nine geotechnical soil borings were drilled to collect geotechnical data needed to
design the soil excavations and containment cell. The nine borings were drilled by hollow stem
auger with continuous standard penetration testing from ground surface to the top of the PWR.
The boring locations were selected along three transects with three borings in each transect, as
follows:
• Transect 1 was located directly behind the Site building and extended to the east toward
the unnamed tributary.
• Transect 2 was located between the closed landfarm and the unnamed tributary and was
north-south trending.
• Transect 3 was also located between the closed landfarm and the unnamed tributary and
was northwest-southeast trending.
Along each transect, one boring was drilled near the top of the slope, one was drilled mid-slope,
and one was drilled near the bottom of the slope. One composite bulk sample of soils above the
water table was collected from each transect and submitted to a subcontracted geotechnical
laboratory for analysis by the following test methods:
• Unified Soil Classification System soil classification by ASTM D2487,
• Moisture content by ASTM D2216,
• Atterberg limits by ASTM D4318,
• Moisture-density relationship by ASTM D698, and
• Unconfined compressive strength by ASTM D2166.
In addition, two saturated soil samples from below the water table were collected within the
potential groundwater treatment areas for laboratory measurement of bulk density. The saturated
soil samples were collected from the borehole of monitoring well MW-49 (located in the
impoundment area co-located with TarGOST® boring HCTG06) and from the top of slope
geotechnical boring HCGT-1A, located within Transect 1.
In March 2020, an asbestos and lead-based paint inspection and assessment was performed by a
certified North Carolina inspector. The existing Site building was inspected, and samples were
collected, as needed, by the inspector to determine the presence of asbestos-containing material
(ACM) (including friable and Category I and Category II nonfriable ACM), lead pipes, and/or
lead-based paint.
The results of the inspection indicated that the following items tested positive for the presence of
ACM:
• Window putty on four steel windows,
• Roofing materials on the flat roof portion of the building,
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• Grey-black tar placed around the chimney on the flat roof,
• Grey-black tar placed around pipe intrusions through the lower metal roof, and
• Tar located under part of the flat roof.

Lead was found in ceramic tile glaze surrounding cabinets in one of the rooms of the building.
Lead-containing paint was found on several interior and exterior painted surfaces throughout the
building.
The following subsections present a summary of the nature and extent of contamination at the Site
as evaluated during the RI and pre-RD investigation.

Sources of Known or Suspected Hazardous Waste

Sources of contamination at HCC are related to the former operations areas and landfarm areas.
Specific source areas based on the historical data include the following: former concrete storage
pit, former surface impoundment, underground storage tanks, 55-gallon sump, and catch basin.
Figure 2 provides a layout of the historical site features.

Known or Suspected Contaminants or Classes of Contaminants

Semivolatile organic compounds, mainly PAHs, are present in soils throughout the former
operations area, the landfarm, and the southern portion of the unnamed tributary before entering
the wetlands. Naphthalene is the main COC in the groundwater; however, there are co-mingled
plumes of other COCs including dibenzofuran, cobalt, manganese, iron, and 2-methylnaphthalene.

Primary Release Mechanisms

Creosote stored and used at the Site either leaked or was spilled on the ground during HCC
operations. Waste liquids containing creosote and dissolved COCs from the wood treating process
were contained in on-Site sumps and a concrete storage pit and discharged an unlined surface
impoundment. Water from the surface impoundment was sprayed onto the landfarm area; the
landfarm area was also used for disposal of sludge excavated from the surface impoundment
during its closure.

Secondary Contaminant Migration

Contaminants in soils and sediment can migrate through overland flow in rainwater runoff and
surface water flow when contaminants are adsorbed to suspended sediment. Dissolved COCs
directly discharged to the groundwater from the former unlined surface impoundment or which
enter groundwater through desorption from soil will flow in the direction of groundwater as a
function of the local horizontal and vertical gradient.

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Land Use Considerations

Land uses surrounding the HCC property are predominantly agricultural, residential, and light
industrial. The Site property is currently vacant. Future uses of the Site property are expected to
be restricted to industrial/commercial.

Potential Receptors and Exposure Pathways

Potential receptor populations could include trespassers, anglers fishing in Dobbins Pond, and
potential future on-Site workers. Potentially complete exposure pathways include incidental
ingestion of soil, dermal contact with soil, inhalation of particulates released from soil, ingestion
of groundwater, inhalation of vapors released from groundwater, and ingestion of fish.
Current Interpretation of the Nature and Extent of the Contamination

An EPA-led RI was conducted for the HCC Site between 2012 and 2017. An EPA-led pre-RD
investigation was conducted in 2020. The following subsections present a summary of the nature
and extent of contamination at the Site as evaluated during the RI. A complete discussion of nature
and extent can be found in the Final Remedial Investigation Report (Versar, 2017), the Final
Groundwater Data Evaluation and Conceptual Site Model Update Technical Memorandum (HGL,
2020a), the Final Soil Data Evaluation and Conceptual Site Model Update Technical
Memorandum (HGL, 2020b), and the Final 100% Soil Remedial Design (HGL, 2021).

Suspected Source Areas

Sources of contamination at HCC are related to the former operations areas and landfarm areas.
Specific source areas based on the historical data include the following: former concrete storage
pit, former surface impoundment, underground storage tanks, 55-gallon sump, and catch basin.
Figure 2 provides a layout of the historical Site features.

Soil Contamination

Semivolatile organic compounds, mainly PAHs, are present in soils throughout the former
operations area, the landfarm, and the southern portion of the unnamed tributary before entering
the wetlands. Benzo(a)pyrene and naphthalene are the main COCs in soil. The extent of soil
contamination is generally defined by the extent of naphthalene exceeding its Site-specific
groundwater protection value of 180 µg/kg. Figure 4 depicts the RI and pre-RD investigation soil
sampling locations and identifies locations where naphthalene was detected above 180 µg/kg.

Sediment

Sediment samples were collected during the RI and pre-RD investigation from Dobbins Pond, the
unnamed tributary, and the wetlands. The only COC identified in sediment was total PAHs. Only
one sediment sample, HCSD47 located in the wetlands just south of the landfarm, exceeded the
maximum acceptable toxicant concentration of 198 mg/kg total PAHs calculated from Site-
specific soil invertebrate toxicity testing (shown on Figure 4).

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Groundwater

Naphthalene is the main COC in the groundwater; however, there are co-mingled plumes of other
COCs including dibenzofuran, cobalt, manganese, iron, and 2-methylnaphthalene. Groundwater
contamination is most prevalent in the saprolite and PWR in the area between the east and
southeast sides of the main building and west side of the unnamed tributary. There is very little
groundwater contamination near the landfarm or in the bedrock. The extent of groundwater
contamination is generally defined by the extent of naphthalene exceeding its North Carolina
groundwater standard of 6 µg/L. Figures 5 and 6 depict the RI and pre-RD investigation
groundwater sampling locations and identifies locations where naphthalene was detected above 6
µg/L in the saprolite and PWR, respectively.
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WORKSHEET #11
PROJECT/DATA QUALITY OBJECTIVES
This worksheet develops the DQO for the HCC Site using a systematic planning process in
accordance with EPA QA/G-4, Guidance on Systematic Planning Using the Data Quality
Objectives Process (EPA, 2006). The DQOs are developed separately below.
1. State the Problem. As described in Worksheet #10, soil, sediment, and groundwater at the
Site are contaminated with naphthalene, PAHs, and other creosote-related compounds from
past wood treating operations at the Site. Additional soil data are needed to fully define the
extent of contamination above cleanup levels and to support separate soil and groundwater
RAs in accordance with the Site’s ROD. Soil/sediment concentrations above the Site cleanup
levels will be included in the RA excavation areas; however, soil/sediment concentrations
below cleanup levels will not. Similarly, groundwater concentrations above the Site’s cleanup
levels will be included in the RA groundwater treatment zones; however, groundwater
concentrations below the cleanup levels will not. In addition, geotechnical data are needed to
evaluate the quality control of the soil RA solidification/stabilization (S/S) and ISS.
2. Identify the Goals of the Project. The goals of the soil field investigation are as follows:
1) Define the extent of naphthalene concentrations greater than 180 µg/kg in surface and
subsurface soils above the water table in the following locations:
i. Near the unnamed tributary
ii. Near Excavation Area 5
iii. At and around soil boring HCSB113
iv. At and around soil boring HCSB141
v. At and around soil boring HCSB175
2) Perform quality control of the soil RA S/S and ISS.
3. Identify Information Inputs. The information inputs will consist of previous Site data
collected during the RI and pre-RD investigation and data from new soil samples that will be
collected from the Site during the pre-RA investigation. Data from the RI and pre-RD
investigation is considered acceptable for use because it was collected and analyzed in
accordance with the EPA’s standard operating procedures (SOPs) and meets the DQOs. Soil
samples will be collected from the 17 proposed locations shown on Figures 7a and 7b and
submitted to a designated CLP laboratory for analysis of PAHs with Selected Ion Monitoring
(SIM), unless NAPL or gross contamination is present. Samples exhibiting the presence of
NAPL or gross contamination will be submitted to the EPA Region 4 laboratory for analysis
of PAHs without SIM.
Quality control samples will be submitted to a geotechnical laboratory for testing of unconfined
compressive strength (UCS) of soil-cement by ASTM D 1633 and flexible wall permeability
by ASTM D 5084.
Tasks required to collect, evaluate, and manage project data are summarized on Worksheets
#14 and #16.
4. Define the Boundaries of the Study. The boundaries of the HCC Site (Figure 2) will be the
study limits.
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5. Develop the Analytic Approach. Sampling and analysis tasks are outlined in Worksheets #14
and #16. HGL will perform technical review and evaluation of the analytical data and reports
to support the RA. Point data obtained from the sample results will be compared to the Site
cleanup levels that were established by the ROD and identified as the project action limits
(PALs) on Worksheet #15. Statistical averaging will not be used to compare the Site data to
the PALs.
6. Specify Performance or Acceptance Criteria. Analytical QC data associated with project
sample results will be compared to the measurement performance criteria of each data quality
indicator (DQI) listed on Worksheet #12 to determine data quality and whether sample results
are acceptable based on the established DQOs. The PALs and quantitation limits (QL) are
specified on Worksheet #15. Analytical data will be compared to these limits.
7. Develop the Detailed Plan for Obtaining Data. The specific project tasks and schedule for
data collection are located in Worksheet #14 and 16. Details on the sampling locations and
field sampling procedures are presented in Section 3.0 of the Volume 1 FSP (Appendix A).
HGL will be responsible for all sample collection, shipment, and management and will
coordinate with the EPA RSCC to obtain the laboratory assignments. Samples will be
submitted to the laboratory assigned by the RSCC, and validated data will be provided by EPA.
Validation criteria is included in Worksheets #34, #35, and #36, and data usability is included
in Worksheet #37. Definitive data will be required for all data that will be used for comparison
to PALs.

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WORKSHEET #12
MEASUREMENT PERFORMANCE CRITERIA
Measurement performance criteria are expressed in terms of data DQIs. DQIs are qualitative and
quantitative descriptors used to interpret the degree of acceptability or usability of data. The
principal DQIs are precision, accuracy (or bias), representativeness, completeness, and
comparability. Of the five DQIs, precision and accuracy are the quantitative measures,
representativeness and comparability are the qualitative measures, and completeness is a
combination of quantitative and qualitative measures.

For this investigation, sample analyses for definitive-level data requirements will be performed by
the EPA Region 4 and/or CLP laboratories. CLP laboratories are required to comply with the (1)
CLP methods specified in Organic Superfund Methods, Multi-Media, Multi-Concentrations
(SOM02.4) prepared by the EPA in October 2016 (EPA, 2016); (2) Superfund Analytical Methods,
Multi-Media, Multi-Concentration (SFAM01.1) prepared by EPA in November 2020 (EPA,
2020a); and (3) High Resolution Superfund Methods, Multi-Media, Multi-Concentration
(HRSM02.1) prepared by the EPA in November 2020 (EPA, 2020b) that include stringent QA/QC
requirements to ensure data reported by the laboratory meets measurement quality objectives
(EPA, 2016; 2020a; and 2020b). The EPA Region 4 laboratory is required to comply with its
Laboratory Operations and Quality Assurance Manual (LOQAM) (EPA, 2021) as well as internal
SOPs. The EPA Region 4 LOQAM is included as Appendix C.

The assessment of laboratory-related DQIs is performed by the laboratories and during data
validation. For this RA field investigation, the EPA Region 4 will perform data validation. The
data validators will review the laboratory’s QC measures required by the Region 4 LOQAM or
CLP statement of work (SOW) and the analytical method, including method procedures, internal
spikes, calibrations, matrix spikes (MS), matrix spike duplicates (MSD), and performance
evaluation samples, and place qualifiers on the data as appropriate. The narratives included in the
data deliverable reports will identify and discuss any qualifiers placed on the data during the data
validation process.

Evaluation of field-related DQIs is performed by the sampling contractor after receipt of the
validated data from EPA. The sampling contractor evaluates field precision, completeness, and
representativeness, as discussed below.

Field Precision

Field precision is assessed by collecting and measuring field duplicates at a rate of 1 duplicate per
20 environmental samples. Precision will be assessed through calculation of relative percent
difference (RPD). The formula for calculating RPD is as follows:

𝑅𝑃𝐷=|𝑅−𝐷|
(𝑅+𝐷)
2
𝑥100
where:
S = first sample value (original sample value); and
D = second sample value (duplicate sample value).
HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina

U.S. EPA Region 4
27
RPDs of less than 50% for soil sample duplicates will be the field precision objectives for this
investigation. Sample duplicate RPD failures are implications of sample collection errors and
should warrant a review of sample collection.

Field Completeness

Field completeness is defined as the percentage of analytical results obtained compared with the
projected number of analytical results that would be obtained from all planned sample locations.
The formula for calculating sampling completeness is as follows:

Field Completeness = Number of Data Points Obtained X 100%
Number of Planned Data Points

The field completeness objective for this project will be greater than 90%.

Field Representativeness

Representativeness is the degree to which data accurately and precisely expresses a characteristic
of a population, parameter variations at a sampling point, or an environmental condition.
Representativeness will be qualitatively assessed using the results of field blank samples, such as
equipment rinsate blanks (EBs), that will be collected to assess potential contamination due to field
conditions. The assessment of blank samples will evaluate if compounds detected in the
environmental samples are Site-related or have been introduced through shipping, storage, or field
procedures.

HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina U.S. EPA Region 4 28 HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina WORKSHEET #12.1
MEASUREMENT PERFORMANCE CRITERIA TABLE – PAH ANALYSES IN SOIL

Matrix: Groundwater/Soil
Analytical Group or Method: PAHs (SIM)/8270C SIM or equivalent
Concentration Level: Low to Medium
DQI
QC Sample
or Measurement Performance Activity Measurement Performance Criteria
Overall Precision Field Duplicates RPD ≤ 30% (water) ≤ 50% (soil) when PAHs are detected in
both samples ≥ sample specific level of quantitation (LOQ)
Analytical Precision (laboratory) Laboratory Control Sample Duplicates Per Laboratory Limits1
Analytical Accuracy/Bias (laboratory) Laboratory Control Samples Analyte-specific (Per Lab1)
Analytical Accuracy/Bias (matrix
interference) MSDs Analyte-specific (Per Lab1)
Overall accuracy/bias (contamination) Equipment Blanks No target analyte concentrations ≥ 1/2 LOQ
Sensitivity LOQ verification sample (spiked at LOQ) Recovery within ±25% of LOQ
Completeness See Worksheet #34 See Worksheet #34
1 Laboratory measurement performance criteria will be determined by the EPA Region 4 laboratory or CLP designee in accordance with the EPA Region 4 Laboratory Services
Branch LOQAM (EPA, 2021) and EPA CLP SOW for Organic Superfund Methods, Multi-Media, Multi-Concentrations (SOM02.4) (EPA, 2016) or most recent versions.

HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina U.S. EPA Region 4 29 WORKSHEET #13
SECONDARY DATA USES AND LIMITATIONS
The secondary data that will be used for the HCC RA are presented below.
Data Type Source1 Data Uses Relative to Current Project
Factors Affecting the Reliability of
Data and Limitations on Data Use
RI/Feasibility
Study soil
analytical
data
Versar, Inc.; Final Remedial Investigation
Report, Holcomb Creosote Company Site
dated May 2017.
Data from the RI will be used in conjunction
with newly collected data to define the extent
of contamination and areas for remediation.
None
Pre-RD soil
analytical
data
HGL; Final Soil Data Evaluation and
Conceptual Site Model Update Technical
Memorandum dated August 2020.
HGL; Final Soil Remedial Design dated
December 2021.
1 Include originating organization, report title, and date.

HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina U.S. EPA Region 4 30 WORKSHEETS #14 AND #16
PROJECT TASKS AND SCHEDULE
Project Tasks: The tasks for the pre-RA field investigation are described below.
Sampling Tasks:
A summarized list of sampling tasks is provided below; for more details per task refer to Worksheet #17, Worksheet #18, Worksheets #19 and
30, Worksheet #20, and Worksheets #26 and 27.
• Soil samples from DPT or hand auger boreholes.
o Approximately 28 soil samples will be collected from the soil boring locations depicted on Figures 7a and 7b of this UFP-QAPP and
Figures 3.1A and 3.1B of the FSP.
• Twelve (12) QC samples will be submitted to a geotechnical laboratory for testing of UCS and permeability. The RA Contractor will
prepare the minimum number of replicate sample molds (coupons) for UCS testing at 7, 14, and 28 days, and reserve samples for
permeability testing at 14 and 28 days.
• Sample submission will be coordinated through the Region 4 EPA RSCC.
Analysis Tasks:
The following analyses will be performed as part of this project:
• Soil and sediment samples will be analyzed for PAHs with SIM, unless NAPL or gross contamination is encountered in a sample. Samples
with NAPL or gross contamination will be analyzed for routine PAHs without SIM.
• QC samples will be analyzed for UCS of soil-cement by ASTM D 1633 and flexible wall permeability by ASTM D 5084.
QC Tasks: A complete list of QC samples per matrix and analysis is provided in Worksheet #20.
• Implement field SOPs for sample collection, packaging, and transportation to the laboratory (see Worksheet #21 and Appendix D for
more details).
• The EPA or CLP laboratory will implement laboratory SOPs for sample preparation and analysis.
WORKSHEETS #14 AND #16 (CONTINUED)
PROJECT TASKS AND SCHEDULE
HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina U.S. EPA Region 4 31 Data Management Tasks:
 All sample collection data and chain of custody (CoC) information will be managed electronically by the data manager using EPA’s
Scribe software. Scribe will be used to print labels for collected samples, generate CoC documentation, and electronically transmit CoC
reports and sample collection information to the EPA Region 4 or CLP laboratory.
 Validated EPA Region 4 and CLP laboratory analytical results will be provided to HGL as electronic data deliverables (EDDs), uploaded
into the regional Environmental Quality Information System (EQuIS) database, and in electronic laboratory reports.
 Region 4 format EDDs of field data will be prepared by HGL and checked through the EQuIS Data Processor prior to submittal to EPA
via upload to the Region 4 EQuIS database. A summary of the required EDDs is provided in the DMP (Appendix B).
 All laboratory data will be archived in the project file.
Documentation and Records: All field observations and sampling records will be entered into bound logbooks or on bound sampling data sheets.
CoC forms, air bills, and field instrument calibration logs will be prepared and retained. Scribe software will be used for preparing CoC forms
and to electronically transmit CoC reports and sample collection information to the EPA Region 4 or CLP laboratory.
Assessment/Audit Tasks: Assessment/audit tasks will not be required for this project as all samples will be submitted to the Region 4 laboratory
or a CLP laboratory.
Data Review Tasks:
 Validated data and all related field notes, logbooks, and records will be reviewed to assess total measurement error and determine overall
usability of the data for project purposes. Data limitations will be determined, and data will be compared to project DQOs and PALs. CA
will be initiated, if necessary. Final data will be placed in the project database, with any necessary qualifiers, and tables, charts, and figures
generated.
 Field measurement results will be reviewed by the FTL to verify that results were obtained using properly conducted procedures.
Project Schedule:
The anticipated project schedule for the HCC RAs is as follows:
Description Start Date Duration (Working Days) Finish Date
Procurement 12/20/2022 65 2/19/2023
Mobilization and Site Preparation 2/20/2023 40 5/14/2023
Groundwater Injection Event 4/25/2023 30 6/4/2023
Excavation and On-site Consolidation 5/29/2023 45 8/1/2023
S/S 6/26/2023 20 7/22/2023
Rough Grading of the Cap 7/10/2023 35 8/27/2023
Construction of Engineered Cap 8/21/2023 54 11/2/2023
Site Restoration 10/29/2023 55 1/10/2024

HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina U.S. EPA Region 4 32 WORKSHEET #15
PROJECT ACTION LIMITS AND LABORATORY-SPECIFIC QUANTITATION LIMITS6 TABLE – PAHS SIM IN
SOIL/SEDIMENT
Analyte Primary PAL (µg/kg) PAL Source 1 QL2 (µg/kg) CRQL3 (µg/kg)
Naphthalene 1804 ROD 3.33 3.3
1-Methylnaphthalene NA NA 3.33 3.3
2-Methylnaphthalene NA NA 3.33 3.3
Acenaphthene NA NA 3.33 3.3
Acenaphthylene NA NA 3.33 3.3
Anthracene NA NA 3.33 3.3
Benzo[a]anthracene NA NA 3.33 3.3
Benzo[a]pyrene 198,0005 NA 3.33 3.3
Benzo[b]fluoranthene NA NA 3.33 3.3
Benzo[k]fluoranthene NA NA 3.33 3.3
Benzo[g,h,i]perylene NA NA 3.33 3.3
Carbazole NA NA 3.33 3.3
Chrysene NA NA 3.33 3.3
Dibenz(a,h)anthracene NA NA 3.33 3.3
Fluoranthene NA NA 3.33 3.3
Fluorene NA NA 3.33 3.3
Indeno[1,2,3-cd]pyrene NA NA 3.33 3.3
Naphthalene NA NA 3.33 3.3
Pentachlorophenol NA NA 33.3 6.7
Phenanthrene NA NA 3.33 3.3
Pyrene NA NA 3.33 3.3
1 ROD for the HCC Site, September 2018.
2 QL values are from the EPA Region 4 LOQAM.
3 Contract Required Quantitation Limits (CRQL) values are trace water CRQLs from SOM02.4, Exhibit C Table 1
4 Soil PAL value.
5 Sediment PAL value (198 mg/kg total PAHs).
6 Detection and quantitative limits vary by laboratory. Detection and quantitative limit procedures for the EPA Region 4 laboratory or CLP designee will be performed
in accordance with the EPA Region 4 Laboratory Services Branch LOQAM (EPA, 2021) and EPA CLP SOW for Organic Superfund Methods, Multi-Media, Multi-
Concentrations (SOM02.4) (EPA, 2016) or most recent versions.
NA = not applicable
HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina

U.S. EPA Region 4
33
WORKSHEET #17
SAMPLING DESIGN AND RATIONALE
The sampling design is a fundamental part of data collection for scientifically based decision
making. A well-developed sampling design plays a critical role in ensuring that data are sufficient
to draw the conclusions needed. A complete sampling design indicates the number of samples,
identifies their locations, and includes an explanation and justification (rationale) for the number
and the locations of the samples. There are two main categories of sampling designs: probability-
based designs and judgmental designs. Probability-based sampling designs apply statistical theory
and involve random selection of sampling locations. When a probability-based design is used,
statistical inferences may be made about the entire study area using the data obtained from the
randomly selected sampling locations. Judgmental sampling designs involve the selection of
sampling locations based on site knowledge or professional judgment and are most applicable
where existing site knowledge or data are available to guide and inform the sampling design, as
presented in Guidance on Choosing a Sampling Design for Environmental Data Collection for
Use in Developing a Quality Assurance Project Plan (EPA, 2002). At the HCC Site, a judgmental
sampling design will be used to accomplish the sampling objectives. Sufficient Site knowledge
and data are available from previous investigations including the known locations of
contamination, as needed, to develop a judgmental sampling approach to evaluate the extent of
contamination.
The design and rationale for the field sampling activities is provided below. Refer to Section 3.0
of the FSP (Appendix A) for further details on field sampling procedures.
The sampling process was designed to ensure that the sampling objectives are fulfilled in support
of the RA. The objective of the RA field investigation is to further characterize the extent Site-
related soil contamination above ROD cleanup in surface and subsurface soil. In addition,
geotechnical data are needed to evaluate the quality control of the soil RA S/S and ISS.
To accomplish these objectives, HGL will perform sampling activities in the following areas:
• Near the unnamed tributary,
• Near Excavation Area 5,
• At and around soil boring HCSB113,
• At and around soil boring HCSB141, and
• At and around soil boring HCSB175.
Soil samples for laboratory analyses and quality control samples for geotechnical testing will be
collected under this UFP-QAPP. The sampling design and rationale for each matrix to be sampled
is discussed below.
The sampling design that follows has been developed based on the results of previous Site
investigations and input from EPA. The design describes the sampling rationale and approach and
includes the number, types, and locations of samples to be collected and the methods of analyses
to be performed. Refer to Worksheet #18 and Table 3.1 of the FSP (Appendix A) for a summary
of proposed soil samples, rationale for each sample location, and associated chemical analyses for
this investigation.
HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina

U.S. EPA Region 4
34
Soil Sampling
The Conceptual Site Model presented in Worksheet #10 identifies data gaps that need to be
addressed to further delineate Site-related soil contamination. Soil sampling will be conducted in
the following areas of the Site:
• Near the unnamed tributary: Soil samples will be collected to delineate soil contamination
east of HCSB102 and HCSB172. Soil samples will be collected from 0 to 0.5 ft bgs at
three locations just west of the unnamed tributary.
• Near Excavation Area 5: Soil samples will be collected to delineate soil contamination
south of HCSB134. Soil samples will be collected from 0 to 0.5 ft bgs at two locations,
southeast and southwest of HCSB134.
• HCSB113: As part of the ISS plan, naphthalene-contaminated overburden soil above the
water table will be excavated and placed in the Site containment cell. However, at ISS
Area F, north of the surface impoundment, the elevated naphthalene concentrations
detected at soil boring HCSB113 at 4 to 8 ft bgs are possibly the result of NAPL in the
sample. Overburden soil above the water table at Area F will be re-sampled to determine
whether a portion of it can be segregated as clean backfill. Soil samples will be collected
at 2 to 4 ft bgs and 4 to 6 ft bgs at HCSB113. Four additional soil samples will also be
collected at 2 to 4 ft bgs and 4 to 6 ft bgs from two step-out soil borings north and west
of HCSB113.
• HCSB141: One soil sample will be collected at 8 to 10 ft bgs to confirm the soil
contamination at HCSB141, near US Highway 601. Additionally, cutline soil sampling
will be conducted around HCSB141. Eight additional soil samples will also be collected
at 8 to 10 ft bgs and 10 to 12 ft bgs from four step-out soil borings north, south, east, and
west of HCSB141.
• HCSB175: Cutline soil sampling will be conducted around HCSB175. Eight additional
soil samples will also be collected at 2 to 5 ft bgs and 5 to 7 ft bgs from four step-out soil
borings north, south, east, and west of HCSB175.
The rationale for the boring locations is presented on Table 3.1 of the FSP.
The soil samples will be collected using DPT or decontaminated hand augers in accordance with
the procedures presented in the FSP (Appendix A). All soil samples will be analyzed for PAHs
with SIM.
Geotechnical QC Testing
QC samples for laboratory testing of UCS will be performed on mixed and cured samples at a
frequency of two samples per mixing zone. There are 6 zones: Area A; Area B; Areas C & D; Area
E; Areas F & G; and the stabilization pit, for a total of 12 samples for the total volume of soils to
be treated with S/S of 1,678 bank cubic yards (approximately 1 sample per every 140 bank cubic
yards). For each sampling event, the RA Contractor will prepare the minimum number of replicate
sample molds (coupons) for UCS testing at 7, 14, and 28 days, and reserve samples for
permeability testing at 14 and 28 days. Information on sampling requirements is located in
Specification 02 55 00 in the soil RD (HGL, 2021).

U.S. EPA Region 4 35 HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina WORKSHEET #18
SAMPLING LOCATIONS AND METHODS
Matrix
Sampling
Location/
ID Number
Depth
(ft bgs)
Analytical
Methods1
Number of
Samples2
Sampling SOP
References3
Anticipated
Concentrations
Rationale for
Sampling
Location
Surface/Subsurface
Soil
17 soil borings
illustrated on Figures
7a and 7b and
Figures 3.1A and
3.1B of the FSP.
Station IDs, Sample
IDs and coordinates
are listed on Table
3.1 of the FSP
(Appendix A).
0 – 0.5,
2 – 4, 2 – 5,
4 – 6, 5 – 7,
8 – 10, and
10 – 12
SIM PAHs/or
PAHs without
SIM4
Up to 28 S S-1, S-2, S-3, S-4,
S-5, S-6, S-7, S-8,
S-9, S-10, S-11,
S-12, S-13
Low Define the extent
of naphthalene
greater than 180
µg/kg. Potentially
reduce the size of
the area requiring
excavation, and
potentially
establish cut lines
for use during RA
implementation.
1 See Worksheet #23.
2 Number of samples does not include QC samples, which are listed in Worksheet #20.
3 See Worksheet #21.
4 Samples exhibiting presence of NAPL or gross contamination will be submitted for analysis of PAHs without SIM, to be determined in the field.
ID = identification

U.S. EPA Region 4 36 HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina WORKSHEETS #19 AND #30
SAMPLE CONTAINERS, PRESERVATION, AND HOLD TIMES
Matrix Parameter
Analytical and
Preparation Method/
SOP Reference Containers
Preservation
Requirements
Maximum
Preparation
Holding
Time
Maximum
Analysis
Holding
Time
Data
Package
Turnaround
Time
EPA Region 4 or CLP laboratory
Soil PAH SW8270D/ SW8270D-SIM
or equivalent
1 x 8-ounce
glass jar Cool to ≤6°C 40 days 14 days 35 days
Soil Rinsate
Blanks PAHs SW8270D/ SW8270D-SIM
or equivalent
2 x 1 liter amber
glass bottles Cool to ≤6°C NA 7 days 35 days
Sample locations and ID numbers are located in Worksheet #18.
Expected concentration levels are shown on Worksheet #18.
°C = degrees Celsius

HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina

U.S. EPA Region 4
37
WORKSHEET #20
FIELD QC SUMMARY
Field QC samples will consist of field duplicates, EBs, MS/MSDs, and temperature blanks. Each
type of field QC sample undergoes the same preservation, analysis, and reporting procedures as
the related environmental samples.
Field Duplicates
Field duplicates will be collected and analyzed for the identical chemical constituent list as the
corresponding parent samples to measure the cumulative uncertainty (i.e., precision) of the sample
collection, handling, storage, preparation, and analysis operations. Field duplicates are labeled as
individual environmental samples and are not identified to the laboratory as duplicate samples.
Field duplicates will be collected at a frequency of 1 per 20 investigative samples collected.
Matrix Spikes
MS samples are environmental samples to which known quantities of analytes are added by the
laboratory before sample preparation (digestion or extraction). These are laboratory QC samples
that provide information about the heterogeneity of the field samples as well as the effect of the
sample matrix on the sample digestion and measurement methodology. MS samples will be
collected at a frequency of 1 per 20 investigative samples collected.
Matrix Spike Duplicates
MSD samples are duplicates of MS samples and are used for estimating laboratory precision of
target analyte analyses. An MSD sample will be collected for every MS sample collected.
Temperature Blanks
Temperature blanks are vials of water inserted into each sample cooler prior to being shipped from
the field to the laboratory. The temperature of the temperature blank is measured upon receipt at
the laboratory to assess whether samples were properly cooled during transit. One temperature
blank will be included in every cooler shipped to the laboratory.
Equipment Rinsate Blanks
EBs will be collected at a frequency of one per day. For the HCC Site, EBs will be collected from
the DPT tooling and sampling equipment (auger buckets, bowels, spoons, trowels) used for soil
and sediment sampling. EBs, collected by routing deionized water (for inorganic analyses) or
organic-free water (for organic analyses) through decontaminated sampling equipment, will be
analyzed to check procedural decontamination, ambient conditions, and/or sample container
contamination. EB descriptions will be recorded in field logbooks or sample log forms and will
state what equipment was used to prepare the rinsate.
The ID of field QC samples will follow the sample nomenclature presented in Worksheets #26 and
#27. MS and MSD samples will be documented as “extra volume of laboratory QC” on the
CoC form.
1 Samples with observed NAPL or gross contamination will be analyzed for routine PAHs without SIM.
Matrix
Analysis/ SOP
Reference
Field
Samples
Field
Duplicates MSs MSDs EB
Total #
Samples
Soil SIM PAHs1 28 2 2 2 2 36

U.S. EPA Region 4 38 HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina WORKSHEET #21
FIELD SOPS
All necessary HGL and EPA Region 4 SOPs are located in Appendices D and E, respectively, and will be available to the field sampling
team. In instances where HGL and EPA Region 4 SOPs differ, the EPA Region 4 procedures will be followed.
Reference
Number Title, Revision Date, and/or Number
Originating
Organization Equipment Type
Modified for
Project
Work? Comments
S-1 SOP 411.02: Sampling Equipment Cleaning
and Decontamination, Rev. 5 HGL All non-disposal sampling
equipment No Decontamination
procedure
S-2 SOP 02.05 DPT Soil Sampling HGL DPT drilling rig No Subsurface soil samples
S-3 SOP 02.13 Surface and Shallow Depth Soil
Sampling HGL Trowel/hand auger No Surface soil sampling
S-4 SOP 300.04: Field Logbook Use and
Maintenance, Rev. 3 HGL Field logbooks, permanent
markers No Record all fieldwork in
logbook
S-5 SOP 403.07 Borehole Logging, Rev. 2 HGL Boring log forms, permanent
markers No
Log soil borings and
monitoring well
boreholes
S-6 LSASDPROC-300-R4 Soil Sampling EPA Region 4 Trowel/hand auger No Surface soil sampling
S-7 LSASDPROC-110-R5 GPS EPA Region 4 GPS unit No Measure horizontal
coordinates
S-8 SESDPROC-005-R3 Sample and Evidence
Management EPA Region 4 Sample custody supplies No Sample custody
S-9
LSASDPROC-209-R4 Packing, Marking,
Labeling, and Shipping of Environmental and
Waste Samples
EPA Region 4 Coolers, sample packing
supplies No Pack and ship samples to
the laboratory
S-10 LSASDPROC-205-R4 Field Equipment
Cleaning and Decontamination EPA Region 4 All non-disposal sampling
equipment No Decontamination
procedure.
S-11 SESDPROC-1002-R0 Logbooks EPA Region 4 Field logbooks, permanent
markers No Record all fieldwork in
logbook
S-12 LSASDPROC-202-R4 Management of
Investigation-Derived Waste EPA Region 4 Drums and other waste
containers No
Investigation-derived
waste handling
procedures
S-13 SEMDPROC-009-R0 Environmental Data
Submission EPA Region 4 Computer and required
software No EDD preparation and
submittal procedures

U.S. EPA Region 4 39 HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina WORKSHEET #22
FIELD EQUIPMENT CALIBRATION, MAINTENANCE, TESTING, AND INSPECTION
Field
Equipment
Calibration
Activity
Maintenance
Activity
Testing
Activity
Inspection
Activity Frequency
Acceptance
Criteria
Corrective
Action1
Responsible
Person
SOP
Reference2
Photoionization
Detector
Calibration check
with ambient air
and 100 parts per
million
isobutylene
User Manual
H&S
monitoring
and field
screening for
soil sampling
Visual and
calibration
Daily, before
sampling
Response
within 10% of
expected value
Adjust
instrument
settings,
recheck
Field
sampling
team
NA
1 If CA does not solve the problem, the equipment will be removed from service and replaced until it has been repaired.
HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina

U.S. EPA Region 4
40
WORKSHEET #23
ANALYTICAL SOPS
Samples for definitive analyses will be submitted for the requested analyses, and the appropriate
analytical SOPs will be used by the EPA Region 4 laboratory or CLP designee in accordance with
the EPA Region 4 Laboratory Services Branch LOQAM (EPA, 2021); EPA CLP SOW for
Superfund Analytical Methods, Multi-Media, Multi-Concentration (SFAM01.1) (EPA, 2020a);
and EPA CLP SOW for High Resolution Superfund Methods, Multi-Media, Multi-Concentration
(HRSM02.1) (EPA, 2020b) or the most recent versions.
HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina

U.S. EPA Region 4
41
WORKSHEET #24
ANALYTICAL INSTRUMENT CALIBRATION
Analytical instruments will be calibrated by the EPA Region 4 laboratory or CLP designee in
accordance with the EPA Region 4 Laboratory Services Branch LOQAM (EPA, 2021); EPA CLP
SOW for Superfund Analytical Methods, Multi-Media, Multi-Concentration (SFAM01.1) (EPA,
2020a); and EPA CLP SOW for High Resolution Superfund Methods, Multi-Media, Multi-
Concentration (HRSM02.1) (EPA, 2020b) or the most recent versions.
.
HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina

U.S. EPA Region 4
42
WORKSHEET #25
ANALYTICAL INSTRUMENT AND EQUIPMENT MAINTENANCE, TESTING,
AND INSPECTION
Analytical instrument maintenance, testing, and inspection will be performed by the EPA Region 4
or CLP laboratory in accordance with the EPA Region 4 Laboratory Services Branch LOQAM
(EPA, 2021); EPA CLP SOW for Superfund Analytical Methods, Multi-Media, Multi-
Concentration (SFAM01.1b) (EPA, 2020a); and EPA CLP SOW for High Resolution Superfund
Methods, Multi-Media, Multi-Concentration (HRSM02.1) (EPA, 2020b) or the most recent
versions.

HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina

U.S. EPA Region 4
43
WORKSHEETS #26 AND #27
SAMPLE HANDLING, CUSTODY, AND DISPOSAL
Sample shipment procedures will include overnight shipment by commercial courier to the EPA
Region 4 laboratory and/or CLP laboratory. If samples designated for a CLP laboratory must be
collected on a Friday, HGL will coordinate with the RSCC to ensure that the samples can be
received at the laboratory on Saturday. The EPA Region 4 laboratory is unavailable for Saturday
delivery; therefore, samples bound for the EPA Region 4 laboratory should be collected on a
schedule accommodating the laboratory’s receiving hours and minimize hold time in the field.
Sample handling, custody, and disposal will be performed in accordance with the EPA Region 4
SOP LSASDPROC-209-R4 Packing, Marking, Labeling, and Shipping of Environmental and
Waste Samples, EPA Region 4 Laboratory Services Branch LOQAM (EPA, 2021); EPA CLP
SOW for Superfund Analytical Methods, Multi-Media, Multi-Concentration (SFAM01.1) (EPA,
2020a); and EPA CLP SOW for High Resolution Superfund Methods, Multi-Media, Multi-
Concentration (HRSM02.1) (EPA, 2020b) or the most recent versions.
Sample Collection, Packaging, and Shipment (Reference subsequent pages of this worksheet and
field SOP1)
Sample Collection (Personnel/Organization): Site Staff/HGL
Sample Packaging (Personnel/Organization): Site Staff/HGL
Coordination of Shipment (Personnel/Organization): FTL/HGL will coordinate sample shipment with the RSCC
using Field and Analytical Services Teaming Action Committee protocol.
Type of Shipment/Carrier: Overnight courier or hand delivery.
Field Sample Storage (number of days from sample collection): Samples will be held in the field no longer than
overnight unless prior arrangements have been made with the laboratory. Holding times must not be compromised
by holding samples in the field.
Special Sample Shipment Considerations: See introductory text regarding Saturday delivery.
Sample Receipt and Analysis
Sample Receipt (Personnel/Organization): Sample Management Staff/EPA Region 4 and/or CLP laboratory
Sample Custody and Storage (Personnel/Organization): Sample Management Staff/EPA Region 4 and/or CLP
laboratory
Sample Preparation (Personnel/Organization): Organic Preparation Staff, Inorganic Preparation Staff, and Bench
Chemists/EPA Region 4 and/or CLP laboratory
Sample Determinative Analysis (Personnel/Organization): Bench Chemists/EPA Region 4 and/or CLP laboratory
Sample Archiving (Reference Laboratory SOP)
Sample Extract/Digestate Storage (number of days from extraction/digestion): For 60 days from data report release
or as required on a site-specific basis
Biological Sample Storage (number of days from sample collection): No biological samples are planned.
Sample Disposal (Reference Laboratory SOP)
Personnel/Organization: Sample Management Staff/ EPA Region 4 laboratory and CLP laboratory
Number of Days from Analysis: 60 from data report release; unless otherwise requested.
1 Worksheet #21, Field SOPs.

Sample Handling
Sample handling includes the field-related considerations connected with selecting sample
containers, preservatives, allowable holding times, and analyses requested. Samples may be
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unstable and therefore require preservation to prevent changes in either the concentration or the
physical condition of the constituent(s) requiring analysis.
Field Sample Preservation and Containers
Samples collected for routine analytical services will be contained and preserved in accordance
with the EPA Region 4 laboratory’s LOQAM (EPA, 2021). An outline of the necessary sample
containers and preservation requirements can be found in Worksheets #19 and #30 and in Table
3.2 of the FSP (Appendix A).
All sample containers used to collect samples will be procured from a supplier by HGL. The
sampling containers will be purchased pre-preserved, where applicable. For chemical analyses,
sample containers will be new and pre-cleaned, and certificates of cleanness will be required with
each lot of containers. All sample containers will be prepared according to the procedures
contained in Specifications and Guidance for Obtaining Contaminant-Free Sample Containers
prepared by EPA in December 1992 (EPA, 1992). This document specifies the acceptable types
of containers, the specific cleaning procedures to be used before samples are collected, and QA/QC
requirements relevant to the containers and cleaning procedures.
Field Sample Identification, Tracking, and Labeling
Each collected sample will be assigned a unique sample ID number and will be collected from a
unique station location. Previous sample locations that are being resampled must use the existing
station location.
Sample Identification
Each sample collected will be assigned a unique sample ID number. Any other pertinent
information regarding sample ID will be recorded in the field logbooks and/or sample log sheets.
MS/MSD, blanks, and field duplicate samples will be designated on the field documentation forms,
including the CoC.
Station location identifies the sampling locations with an associated geographic coordinate. The
well ID will be used as the station ID. The sample ID identifies each individual sample collected.
Sample IDs will be assigned as follows:
Re-sampling locations: RI samples being re-collected for confirmation of previous
results will use the same station IDs as the original samples.
Soil boring locations: HCSB2## where HC represents Holcomb Creosote, SB
indicates a soil boring location, 2 indicates the pre-RD field
investigation (to differentiate from RI locations), and ## is a
sequential number beginning with 01.
The sample ID identifies each individual sample collected. Sample IDs will be assigned as follows:
Re-sampling locations: Samples being re-collected for confirmation of previous
results will use the same sample IDs as the original samples.
Soil borings – surface soil: SF will be added to the end of the station location (e.g,.
HCSB201SF).
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Soil borings – subsurface soil: -TDBD will be added to the end of the station location, where
TD is the top depth of the sample in feet and BD is the bottom
depth of the sample in feet [e.g., HCSB201-0810 for a
sample collected from 8 to 10 ft at HCSB201]).
Field duplicate samples will be identified by adding an “X” at the end of the sample ID. For
example, a field duplicate of sample HCSB201-0810 would be identified as HCSB201-0810X.
Other field QC samples collected during the investigation will be assigned sample IDs based on
the following format:
• Equipment Rinsate Blank: HCRBMMDDYY
Where: HC = Holcomb Creosote
RB = Equipment Rinsate Blank
MMDDYY = the month (MM) day (DD) and year (DD) the sample was collected
For example, an EB collected on December 10, 2022, would be identified as HCRB121022. QC
samples, such as blanks and rinsates, will be given a station ID of #R4DART#.
Sample Tracking and Management
Samples will be tracked in the field using Scribe sample tracking software. Scribe will be used to
manage sample collection, documentation, and submission of all relevant reports, including the
CoC. Scribe will also be used to export the data to the EPA Region 4 EQuIS database, the EPA
Region 4 Laboratory Information Management System, and the CLP Sample Management Office.
Sample Labeling
Sample labels will be generated with Scribe software. Sample labels will include the unique sample
ID, collection date and time, sample type, matrix, analysis, and preservation method. The labels
will be prepared using waterproof, non-erasable ink, as specified in the EPA Region 4 LSASD
SOP SESDPROC-005-R3 Sample and Evidence Management. Sample labels will be prepared and
affixed to each sample container sent to the designated EPA or CLP laboratory.
Custody Seals
The samples collected and containerized will be sealed as soon as possible following collection,
as specified in EPA Region 4 LSASD Operating Procedure SESDPROC-005-R3 Sample and
Evidence Management. The sample custodian will write the date and their signature or initials on
the seal.
Field Sample Packaging and Shipping
Samples will be packaged and shipped in accordance the EPA Region 4 LSASD SOP
LSASDPROC-209-R4 Packing, Marking, Labeling, and Shipping of Environmental and Waste
Samples. In general, the following procedures will be followed when shipping samples for
laboratory analysis:
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• All samples require cooling to 4°C +/- 2°C and will be promptly chilled with ice and
packaged in an insulated cooler for transport. Each cooler shipped to the laboratory will
include a temperature blank. Ice will be sealed in containers to prevent water leakage.
Samples will not be frozen.
• The samples will be packed by placing cushioning/absorbent material in the bottom of
the cooler and then placing the containers in the cooler with sufficient space to allow for
the addition of cushioning between the containers.
• Only shipping containers that meet all applicable federal standards for safe shipment will
be used.
• Shipping containers will be sealed with shipping tape, and custody seals will be signed,
dated, and affixed in a manner that will allow the receiver to quickly identify any
tampering that may have occurred during transport to the laboratory.
• The field CoC document will be taped to the top inside cover of the shipping container in
a sealed plastic envelope.
• Shipment will be made as soon as practical or hand-delivered to the designated laboratory.
The FTL will be responsible for ensuring the completion of the following forms: sample labels,
CoC forms, custody seals for samples and coolers, shipping labels for coolers, and public courier
air bills.
Custody Procedures
Documented sample custody is one of several factors that are necessary for the admissibility of
environmental data as evidence in a court of law. Custody procedures help to satisfy the two major
requirements for admissibility: relevance and authenticity. Sample custody is addressed in three
parts: field sample collection, laboratory analysis, and final evidence files. A sample file is under
custody when any one of the following conditions is satisfied:
• The item is in the actual physical possession of an authorized person.
• The item is in view of the person after being in his or her possession.
• The item was placed in a secure area to prevent tampering.
• The item is in a designated and identified secure area with access restricted to authorized
personnel only.
The FTL (or designee) is responsible for the care and custody of the samples collected until they
are relinquished to the laboratory or entrusted to a commercial courier. Custody procedures apply
to all environmental and associated field QC samples obtained as part of the data collection system.
All of these samples will be accompanied by a CoC form, completed, and maintained in
accordance with EPA Region 4 LSASD SOP SESDPROC-005-R3 Sample and Evidence
Management. The designated laboratory will be responsible for custody procedures and ensure
that sample integrity is not compromised from the time of receipt at the laboratory until the final
data are reported.

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WORKSHEET #28
ANALYTICAL QC AND CA
The EPA Region 4 laboratory and the CLP laboratories will perform analytical QC and CA in
accordance with the EPA Region 4 Laboratory Services Branch LOQAM (EPA, 2021), EPA CLP
SOW for Superfund Analytical Methods, Multi-Media, Multi-Concentration (SFAM01.1) (EPA,
2020a), and EPA CLP SOW for High Resolution Superfund Methods, Multi-Media, Multi-
Concentration (HRSM02.1) (EPA, 2020b) or the most recent versions. The number of QC samples
per matrix and analytical method are discussed in Worksheet #20.
.
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WORKSHEET #29
PROJECT DOCUMENTS AND RECORDS
The following is a list of the kinds of Site records that should be used and maintained for the
project as well as of the personnel responsible for generating and verifying each record. All records
should be maintained in the project files for a minimum of 5 years or longer, as required by the
contract. Project documents and records will be maintained in accordance with the EPA Region 4
SOPs SESDPROC-005-R3 Sample and Evidence Management; LSASDPROC-209-R4 Packing,
Marking, Labeling, and Shipping of Environmental and Waste Samples; SESDPROC-1002-R0
Logbooks; SEMDPROC-009-R0 Environmental Data Submission; EPA Region 4 Laboratory
Services Branch LOQAM (EPA, 2021); EPA CLP SOW for Superfund Analytical Methods,
Multi-Media, Multi-Concentration (SFAM01.1) (EPA, 2020a); and EPA CLP SOW for High
Resolution Superfund Methods, Multi-Media, Multi-Concentration (HRSM02.1) (EPA, 2020b) or
the most recent versions.

Record Generation Verification
Sample Collection Documents and Records
Field notes (bound logbook)
Sample documentation forms
CoC records
Airbills
Custody seals
CA forms
Photographs
GIS data
Field staff
Field staff
Field staff
Field staff
Field staff
PM
Field staff
Field staff
FTL
FTL
FTL / Data Manager
FTL
FTL
QA/QC Manager
PM
Database Manager / GIS staff
On-Site Analysis Documents and Records
Equipment calibration logs
Field sampling data sheets
Waste disposal records
Field Staff
Field Staff
FTL
FTL
FTL
PM
Off-Site Analysis Documents and Records
Sample receipt, custody, and tracking
records
Standard traceability logs
Equipment calibration logs
Sample preparation logs
Analytical run logs
Equipment maintenance, testing, and
inspection logs
Analytical discrepancy forms
Sample Receipt Staff

Analytical Staff
Analytical Staff
Analytical Staff
Analytical Staff
Analytical Staff

Analytical Staff
Laboratory PM

Laboratory Section Manager/QA Manager
Laboratory Section Manager/QA Manager
Laboratory Section Manager/QA Manager
Laboratory Section Manager/QA Manager
Laboratory Section Manager/QA Manager

Laboratory Section Manager/QA Manager
Reported analytical results
Reported results for standards, QC
checks, and QC samples
Data package completeness checklists

Sample disposal records

Extraction and cleanup records
Raw data (stored electronically)
EDDs

Telephone logs, emails, faxes, and
correspondence
Analytical Staff
Analytical Staff

Analytical Staff/Section
Manager
Assigned Laboratory Staff

Analytical Staff
Analytical Staff
Laboratory Database
Manager
Laboratory PM
Laboratory Section Manager/QA Manager
Laboratory Section Manager/QA Manager

Laboratory PM/QA Manager

Laboratory Operations Manager/QA
Manager
Laboratory Section Manager/QA Manager
Laboratory Database Manager/QA Manager
Database Manager

Laboratory Operations Manager
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WORKSHEET #29 (CONTINUED)
PROJECT DOCUMENTS AND RECORDS
Record Generation Verification
Data Assessment Documents and Records
Data validation reports
Automated data review reports
Database QC spreadsheets
Data usability assessments
Data Validator
Data Validator
Project Staff
Project Chemist
Project Chemist
Project Chemist
Database Manager / Project Chemist
PM
Deliverables
Project planning documents, including
Site Management Plan,
UFP-QAPP, and HASP
Project deliverables, including data
evaluation reports and design
reports
Site maps
Design documents
EDD submittals (in Region 4 format;
through EQuIS Data Processor
checker)
Project Staff

Project Staff

GIS Staff
Design Staff
Data Manager
PM / QA/QC Manager

PM / QA/QC Manager

PM
PM
Database Manager / Project Chemist
This worksheet defines the specific records and data that must be maintained for each field activity
to ensure that samples and data are traceable and defensible. At a minimum, data will be collected
to meet EPA Region 4 requirements for EDDs including specific data needs and reporting for
EQuIS. The specific requirements are discussed in the DMP located in Appendix B.
Field documentation will include a combination of sample log sheets and logbooks. A bound,
weatherproof logbook will be maintained by the FTL in accordance with HGL SOP 300.04 Field
Logbook Use and Maintenance and EPA Region 4 LSASD SOP SESDPROC-1002-R0 Logbooks.
All information related to sampling or field activities will be recorded in the field logbook only
when activity-specific data sheets are not used. All entries into the logbook or activity-specific
data sheets will be performed using a blue or black pen with indelible ink. Any changes to field
documents will be indicated using a single strikeout, initialed and dated, with the correct
information entered in proximity to the erroneous entry.
Information recorded in field logbooks or data sheets will include, but not be limited to, sampling
time, weather conditions, unusual events, and field measurements. Field notebooks should also
contain qualitative or semi-quantitative information on sample conditions such as odor and color.
All deviations from SOPs or guidance documents will be recorded in the field logbook.
In addition to the field notes, activity-specific forms for activities such as groundwater sampling,
borehole logging, well construction, well development, and water level measurements will be
completed and bound into paginated books. Examples of these forms are included in the applicable
HGL SOPs and in the FSP (Appendix A).
Completion of a sample collection form for each sample is the responsibility of the appropriate
field sampling personnel. The information recorded for each sample includes the following, as
appropriate:
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• Unique sample ID number and description,
• Date and time of collection,
• ID of person who collected the sample,
• ID of person recording field data (if different than the collector),
• Sample location (latitude/longitude or State Plane Coordinate System),
• Sample equipment type,
• Sampling procedures, sample volume and receiving container, and
• Storage conditions from sampling to shipment.
Copies of the field logbooks and activity data sheets will be supplied to the field team leader at
the end of the sampling event and will be maintained at HGL’s Atlanta office in the central file.

U.S. EPA Region 4 51 HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina WORKSHEETS #31, #32, AND #33
ASSESSMENTS AND CA
Assessments and CA will be performed in accordance with EPA Region 4 SOPs SESDPROC-005-R3 Sample and Evidence
Management and SESDPROC-1002-R0 Logbooks; the EPA Region 4 Laboratory Services Branch LOQAM (EPA, 2021); EPA CLP
SOW for Superfund Analytical Methods, Multi-Media, Multi-Concentration (SFAM01.1) (EPA, 2020a); and EPA CLP SOW for High
Resolution Superfund Methods, Multi-Media, Multi-Concentration (HRSM02.1) (EPA, 2020b) or the most recent versions.

Assessments:
Assessment Type
Responsible
Personnel and
Organization
Internal or
External
Assessment
Number and
Frequency Assessment Deliverable Deliverable Due Date
Review of QAPP, SOPs, and
Health and Safety Plan with
Field Staff (a field audit will not
be performed)
HGL FTL Internal Prior to sampling
startup and with
all new field staff
prior to
assignment
Completed acknowledgment
signature pages
48 hours following
review.
Ongoing Review to Ensure
Work is Being Performed in
Accordance with QAPP
HGL FTL Internal Ongoing during
all phases of
fieldwork
None NA
Logbook and Field Form Review HGL FTL Internal Daily NA: corrections will be
made directly to reviewed
documents
NA
Tailgate Safety Meeting HGL FTL Internal Daily Verbal debriefing. If a safety
incident occurs, a
Supervisor Injury Employee
Report is completed.
Any safety incidents will
be reported to the PM and
Corporate H&S Manager
immediately.
Field Sampling and CoC Form
Review Against QAPP
Requirements
HGL Sample
Coordinator
Internal Daily Corrections will be made
directly to reviewed
documents; communication
may be in the form of email.
24 hours following
assessment, if necessary.

U.S. EPA Region 4 52 HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina WORKSHEETS #31, #32, AND #33 (CONTINUED)
ASSESSMENTS AND CA
Assessment Response and CA:
Assessment Type
Individual(s)
Notified of
Findings
Assessment
Response
Documentation
Nature of the
Deficiencies
Documentation
Time Frame
for Response
Responsibility
for
Implementing
CA
Responsibility
for Monitoring
CA
Review of QAPP, SOPs,
and HASP with Field
Staff
HGL FTL Completed
acknowledgement
signature pages
None 48 hours
following
assessment
HGL FTL HGL FTL
Ongoing Review to
Ensure that Work is
Performed in
Accordance with QAPPs
HGL PM Interim CA
documented pending
final approval
Document in
logbook
By close of
same business
day
HGL FTL HGL PM and
QA/QC Manager
Logbook and Field Form
Review
HGL FTL Corrections will be
made directly to
reviewed documents
Document in
logbook
NA HGL FTL HGL FTL
H&S audit HGL Corporate
H&S Officer
H&S audit report CA Report Within 2 weeks HGL PM HGL PM

QA Management Reports:
Type of Report
Frequency (daily, weekly
monthly, quarterly,
annually, etc.) Projected Delivery Date(s)
Person(s) Responsible for
Report Preparation
(Title and Organizational
Affiliation)
Report Recipient(s)
(Title and
Organizational
Affiliation)
EPA Region 4 Database
Submission
Annually, 30 days after Final
report issued. (HGL
generated data only)
Prior to TO closeout HGL Database Manager EPA Region 4

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WORKSHEET #34
DATA VERIFICATION AND VALIDATION INPUTS
This worksheet lists the inputs that will be used during data verification and validation. Inputs
include planning documents, field records, and laboratory records. Data verification is a check that
all specified activities involved in collecting and analyzing samples have been completed and
documented, and that the necessary records (objective evidence) are available to proceed to data
validation. Data validation is the evaluation of conformance to stated requirements, including those
in the contract, methods, SOPs, and QAPP. Data verification and validation inputs will be in
accordance with EPA Region 4 SOPs SESDPROC-005-R3 Sample and Evidence Management
and SESDPROC-1002-R0 Logbooks; SEMDPROC-009-R0 Environmental Data Submission;
EPA Region 4 Laboratory Services Branch LOQAM (EPA, 2021); EPA CLP SOW for Superfund
Analytical Methods, Multi-Media, Multi-Concentration (SFAM01.1) (EPA, 2020a); and EPA
CLP SOW for High Resolution Superfund Methods, Multi-Media, Multi-Concentration
(HRSM02.1) (EPA, 2020b) or the most recent versions.
Item Description
Data
Generated
Internally or
Externally
Verification
(completeness)
Validation
(conformance to
specifications)
Planning Documents/Records
1 Approved QAPP Internally X
2 Contract Internally X
4 Field SOPs Internally X
5 Laboratory SOPs Internally X
Field Records
6 Field logbooks Internally X X
7 Equipment calibration records Internally X X
8 CoC forms Internally X X
9 Relevant correspondence Internally X X
10 Change orders/deviations Internally X X
11 Field audit reports Internally X X
12 Field CA reports Internally X X
Analytical Data Package
13 Laboratory analytical data packages Externally X X
14 Communication Records Externally X X
15 EDD fields Externally X X
16 Outputs of the EQuIS database Externally X X
17 Data validation and audit reports, QAPP
and Field Change Requests Externally X X

U.S. EPA Region 4 54 HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina WORKSHEET #35
DATA VERIFICATION PROCEDURES
Data verification procedures will be performed in accordance with EPA Region 4 SOPs SESDPROC-005-R3 Sample and Evidence
Management and SESDPROC-1002-R0 Logbooks; SEMDPROC-009-R0 Environmental Data Submission, EPA Region 4 Laboratory
Services Branch LOQAM (EPA, 2021); EPA CLP SOW for Superfund Analytical Methods, Multi-Media, Multi-Concentration
(SFAM01.1) (EPA, 2020a); and EPA CLP SOW for High Resolution Superfund Methods, Multi-Media, Multi-Concentration
(HRSM02.1) (EPA, 2020b) or the most recent versions.
Verification
Input Description Responsible for Verification
CoC (shipping) CoC forms will be reviewed upon completion and verified against the packed sample coolers
and site sampling requirements. This QC check will be verified by initialing the CoC form next
to the shipper’s signature. A copy of the CoC form will be retained in the project file and the
original and one copy will be taped inside the cooler in a waterproof bag.
HGL FTL
Log review Log reviews will be performed on a daily basis. This review will be performed to verify that all
field monitoring equipment was maintained, calibrated, and operated properly. In addition, the
review will verify that all required information has been correctly documented in the field
logbooks and sample documentation sheets.
HGL FTL
CoC (receipt) CoC forms will be reviewed and compared to cooler contents. Any discrepancies (sample
bottles, sample IDs, requested methods) will be communicated to the Laboratory PM for
resolution with the HGL Data Manager or Project Chemist.
EPA Region 4/CLP Receipt Manager
Laboratory PM
Sample Receipt
Login
A review will be conducted to ensure that the appropriate analytical samples have been
collected, appropriate site IDs have been used, and the correct analytical methods have been
applied.
HGL Data Manager and Project
Chemist
Analytical data
package (before
submission to HGL)
All data used to prepare analytical data packages will be reviewed at multiple levels throughout
the laboratory. The requirements for this review process are described in the laboratory’s quality
manual.
Laboratory QA/QC Manager
Analytical data
package1
Analytical reports will be reviewed to ensure that all required forms, case narratives, samples,
CoC forms, logbooks, and raw data have been included.
EPA Region 4 Data Validator / HGL
Data Manager and Project Chemist
EDD (import) Any EDD nonconformances from the laboratory will be reviewed and addressed before the data
is processed further. The EDD will also be reviewed to ensure that it is in the correct format and
that it contains the correct standard values. Any errors or warnings are addressed before
processing the data further.
HGL Database Manager and Data
Manager
1 This verification step is performed as part of the data validation process described in Worksheet #36.

U.S. EPA Region 4 55 HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina WORKSHEET #36
DATA VALIDATION PROCEDURES
All definitive data generated by the EPA Region 4 and/or CLP laboratory from the collected soil and sediment samples will be validated
by EPA.
Validation
Stage Matrix
Analytical
SOP1 Validation Criteria2 Data Validator
2B Solid (soil) Organics
EPA National Functional Guidelines for Organic Superfund
Methods Data Review (SOM02.4)
Office of Land and Emergency Management 9355.0-136
EPA 540-R-2017-002
January 2017 or most recent version

EPA Region 4 Data Validation SOPs for CLP Routine
Analytical Services:
QAS-SOP-0025, Revision 0.0: Data Validation Standard
Operating Procedures for Organic Analysis (February 2016)
EPA Region 4 personnel
1 Refer to Worksheet #23.
2 Data for samples analyzed by the EPA Region 4 or CLP laboratory will be validated by EPA Region 4 and tabulated validated results will be provided to HGL. EPA Region 4
will provide validated data in electronic format and in analytical reports with case narratives describing any qualifiers placed on the data.

HGL, UFP-QAPP, Holcomb Creosote Company Site, Yadkinville, North Carolina
U.S. EPA Region 4
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WORKSHEET #37
DATA USABILITY ASSESSMENT
Summarize the usability assessment process and all procedures, including interim steps and
any statistics, equations, and computer algorithms that will be used:
Definitive data will be received as validated from EPA Region 4. HGL will assess the usability of
the definitive data by evaluation of DQIs as described in Worksheet #12 and determining if the
project-required QLs listed in Worksheet #15 were achieved for nondetected Site contaminants of
concern. In addition, data usability will be assessed as follows:

1) If no detectable results were reported and data are acceptable from the verification and
validation steps, then the data are usable;
2) If detectable concentrations are reported and the verification and validation steps are
acceptable, the data are usable; and
3) If verification and validation are not acceptable, the data are qualified during data validation.
The data that are estimated (J, UJ) for minor QC deviations generally do not affect the data
usability. Data that are rejected for major QC deviations affect usability. The impact of rejected
data will be assessed in the Data Evaluation Report, and re-sampling may be necessary.
Describe the evaluative procedures used to assess overall measurement error associated with
the project:
The validation of definitive data will follow the requirements of EPA Region 4 data validation
SOPs to assess conformance with the requirements of the methods, SOPs, and objectives stated in
this UFP-QAPP. The findings of the data validation will generate qualifiers applied to the data
considered in context to assess overall usability of the data. A Data Evaluation Report will be
prepared after the field sampling event by HGL that will include the results of the usability
assessment review performed by the project data management team.

Identify the personnel responsible for performing the usability assessment:
HGL PM, project chemist, and data manager.

Describe the documentation that will be generated during usability assessment and how
usability assessment results will be presented so that they identify trends, relationships
(correlations), and anomalies:
An overall assessment of the impact of data usability issues will be presented in the Data
Evaluation Report.

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REFERENCES
HydroGeoLogic, Inc. (HGL), 2020a. Final Groundwater Data Evaluation and Conceptual Site
Model Update Technical Memorandum, Holcomb Creosote Company Site. August.

HGL, 2020b. Final Soil Data Evaluation and Conceptual Site Model Update Technical
Memorandum, Holcomb Creosote Company Site. August.

HGL, 2021. Final (100%) Soil Remedial Design, Holcomb Creosote Company Site. December.

HGL, 2022. Final (100%) Groundwater Remedial Design, Holcomb Creosote Company Site.
August.

Intergovernmental Data Quality Task Force (IDQTF), 2005. Uniform Federal Policy Quality
Assurance Project Plans, Part 1: UFP-QAPP Manual. March.

IDQTF, 2012. Uniform Federal Policy for Quality Assurance Project Plans. Optimized UFP-
QAPP Worksheets. March.

U.S. Environmental Protection Agency (EPA), 1992. Specifications and Guidance for
Contaminant-Free Sample Containers (EPA 540/R-93/051). U.S. Environmental
Protection Agency. December.

EPA, 2001. EPA Requirements for Quality Assurance Project Plans (EPA QA/R-5). March.

EPA, 2002. Guidance on Choosing a Sampling Design for Environmental Data Collection for Use
in Developing a Quality Assurance Project Plan (EPA QA/G-5S). December.

EPA, 2006. Guidance on Systematic Planning Using the Data Quality Objectives Process (EPA
QA/G-4). February.

EPA, 2016. EPA Contract Laboratory Program Statement of Work for Organic Superfund
Methods Multi-Media, Multi-Concentration SOM02.4. October.

EPA, 2018. Record of Decision, Holcomb Creosote Company Superfund Site. August.

EPA, 2020a. EPA Contract Laboratory Program Statement of Work for Superfund Analytical
Methods (Multi-Media, Multi-Concentration) SFAM01.1. U.S. Environmental Protection
Agency. November.

EPA, 2020b. EPA Contract Laboratory Program Statement of Work for High Resolution
Superfund Methods (Multi-Media, Multi-Concentration) HRSM02.1. U.S. Environmental
Protection Agency. November.

EPA, 2021. Laboratory Operations and Quality Assurance Manual. U.S. Environmental
Protection Agency. Region 4 Laboratory Services and Applied Sciences Division. May.

Versar, 2017. Final Remedial Investigation Report, Holcomb Creosote Company Site. May.

TABLE
Table 1
Cleanup Levels
Holcomb Creosote Site
Yadkinville, Yadkin County, North Carolina
Contaminant of
Concern
Groundwater
Cleanup Level
(µg/L)
Soil Cleanup
Level
(µg/kg)
Sediment
Cleanup Level
(mg/kg)Basis
Cobalt 9 NA NA Noncancer Hazard Quotient = 1
Iron 20,256 NA NA North Carolina Groundwater Standard
Manganese 694 NA NA Noncancer Hazard Quotient = 1
1,1-Biphenyl 400 NA NA
North Carolina Interim Maximum
Allowable Concentration
2-Methylnaphthalene 30 NA NA
Acenaphthalene 1,736 NA NA
Dibenzofuran 28 NA NA
Naphthalene 6 180 NA
Benzo(a)pyrene TEQ 0.005 NA NA
Ethylbenzene 600 NA NA
Total PAHs NA NA 198
Maximum Acceptable Toxicant
Concentration
Notes:
µg/kg = micrograms per kilogram
mg/kg = milligrams per kilogram
µg/L = micrograms per liter
NA = not applicable
PAH = polynuclear aromatic hydrocarbons
TEQ = toxic equivalency
North Carolina Groundwater Standards
(groundwater) / Site-specific
groundwater protection calculation
(soil)
Page 1 of 1

FIGURES
DobbinsPondHaire RoadS hugart's M ill R oad£¤601Lake Hill DriveLas Brisas DriveLakewood TrailDobbins Mill RoadFigure 1Site LocationLegendHGL—Quality Assurance Project PlanHolcomb Creosote Site—Yadkinville, North Carolina0450900225Feet³\\srv-gst-01\HGLGIS\Holcomb_Creosote_E2412X\UFP-QAPP\HolcombCreosote_Fig01_SiteLocation_20221206.mxd12/6/2022 JGSource: HGL, JMWaller, Versar ArcGIS Online Imagery/Streets Map^_HolcombCreosote SiteNORTHCAROLINAStatewide Location£¤601£¤421HolcombCreosote SiteGeneral Location021MilesHolcomb Creosote Property Boundary
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£¤601U nam ed T ributaryFigure 3Excavated Depths andSoil ConfirmationLegendHGL—Quality Assurance Project PlanHolcomb Creosote Site—Yadkinville, North Carolina07014035Feet³\\Srv-gst-01\hglgis\Holcomb_Creosote_E2412X\UFP-QAPP\HolcombCreosote_Fig03_Excavations_20221215.mxd12/15/2022 JGSource: HGL, JMWaller, Versar ArcGIS Online Imagery (Clarity)WetlandsSurface Water CourseSoil Sampling GridExcavation Depth, 24 inchesExcavation Depth, 18-24 inchesExcavation Depth, 4-12 inchesExcavation Depth, >24 inchesSediments Removed byHigh Volume Guzzler
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APPENDIX A

FIELD SAMPLING PLAN

FINAL
FIELD SAMPLING PLAN

HOLCOMB CREOSOTE COMPANY SITE
YADKINVILLE, YADKIN COUNTY, NORTH CAROLINA

Prepared for:

U.S. Environmental Protection Agency Region 4
Atlanta Federal Center
61 Forsyth Street, SW
Atlanta, GA 30303-3104

Design and Engineering Services (DES) Contract 68HE0318D0006
Task Order 68HE0422F0071

Prepared by:

HydroGeoLogic, Inc.
DES CLIN 2
HGL Region 4 Office
1745 Phoenix Boulevard, Suite 200
Atlanta, GA 30349

February 2023
TABLE OF CONTENTS
Section Page
U.S. EPA Region 4 i
1.0 INTRODUCTION ........................................................................................................... 1-1
2.0 SITE BACKGROUND .................................................................................................... 2-1
3.0 FIELD SAMPLING ACTIVITIES .................................................................................. 3-1 3.1 SOIL SAMPLING ............................................................................................... 3-1 3.2 GEOTECHNICAL QUALITY CONTROL TESTING ...................................... 3-3 3.3 FIELD QUALITY CONTROL SAMPLES......................................................... 3-3
3.4 SAMPLE HANDLING AND CUSTODY .......................................................... 3-3
3.5 DECONTAMINATION PROCEDURES ........................................................... 3-3 3.5.1 Drilling Equipment Decontamination ...................................................... 3-3 3.5.2 Sampling Equipment Decontamination ................................................... 3-4 3.6 FIELD DOCUMENTATION REQUIREMENTS .............................................. 3-4
4.0 WASTE MANAGEMENT PLAN .................................................................................. 4-1
5.0 REFERENCES ................................................................................................................ 5-1

LIST OF ATTACHMENTS

U.S. EPA Region 4 ii
Attachment 1 Field Sampling Forms
Attachment 2 Contained-In Determination Tables

LIST OF TABLES

Table 3.1 Proposed Soil Sampling Locations and Rationales
Table 3.2 Proposed Analytical Methods and Sample Summary
LIST OF FIGURES
Figure 1.1 Site Location Figure 1.2 Site Facility Plan Figure 3.1a Soil and Sediment, Northern Proposed Soil Boring Locations
Figure 3.1b Soil and Sediment, Southern Proposed Soil Boring Locations
LIST OF ACRONYMS AND ABBREVIATIONS

U.S. EPA Region 4 iii
µg/kg micrograms per kilogram

ASTM ASTM International bcy bank cubic yards bgs below ground surface

CFR Code of Federal Regulations CLIN contract line item number DES Design and Engineering Services

EPA U.S. Environmental Protection Agency FSP Field Sampling Plan ft feet

GPS global positioning system HCC Holcomb Creosote Company HGL HydroGeoLogic, Inc.

ID identification IDW investigation-derived waste ISS in situ solidification/ stabilization
LSASD Laboratory Services and Applied Science Division
NAPL non-aqueous phase liquid NCDEQ North Carolina Department of Environmental Quality
PAH polynuclear aromatic hydrocarbon
QAPP Quality Assurance Project Plan QC quality control
RA Remedial Action
RCRA Resource Conservation and Recovery Act RI Remedial Investigation SESD Science and Ecosystem Support Division
SIM Selected Ion Monitoring
SOP standard operating procedure S/S solidification/stabilization TCLP Toxicity Characteristic Leaching Procedure
LIST OF ACRONYMS AND ABBREVIATIONS (Continued)
UCS unconfined compressive strength UFP Uniform Federal Policy
WMP Waste Management Plan

U.S. EPA Region 4 1-1
FIELD SAMPLING PLAN
HOLCOMB CREOSOTE COMPANY SITE YADKINVILLE, YADKIN COUNTY, NORTH CAROLINA
1.0 INTRODUCTION
This Field Sampling Plan (FSP) details field sampling activities to be conducted by HydroGeoLogic, Inc. (HGL) at the Holcomb Creosote Company (HCC) Site located in
Yadkinville, Yadkin County, North Carolina. The overall Site location is shown on Figure 1.1. The Site facility plan is shown on Figure 1.2. These activities are being conducted by HGL for the U.S. Environmental Protection Agency (EPA) Region 4 under Design and Engineering Services (DES) Contract 68HE0318D0006, Task Order 68HE0422F0071. The purpose of this task order is to oversee the Remedial Action (RA) for soil and groundwater in accordance with the Record of
Decision (EPA, 2018).
Several planning documents have been prepared by HGL to describe and detail the sampling activities, data quality objectives for field and laboratory data, data management practices, and investigation-derived waste (IDW) handling procedures to be followed during field activities. Other planning documents include the following:
• A Uniform Federal Policy (UFP)-Quality Assurance Project Plan (QAPP), which is the primary planning document, and includes the project organization, planned activities, and quality assurance/quality control (QC) procedures necessary to complete the field work. The UFP-QAPP will be implemented to ensure that the data collected are valid for the
intended end use, and that data meet the requirements of the data quality objectives. The UFP-QAPP includes the following documents as appendices:
o A FSP (this document) (Appendix A of the UFP-QAPP) that describes the sampling objectives and activities for completing the RA data collection efforts to address data gaps and support the RA.
o A Data Management Plan (Appendix B of the UFP-QAPP) that provides procedures for managing field and laboratory data generated by the field investigations.
• A Site Management Plan that addresses the coordination and control of Site activities
during the field investigation.
• A Site Health and Safety Plan that defines the preventative and protective procedures that will be implemented during the field activities to ensure the safety of the field team.
This FSP (Appendix A of the UFP-QAPP) describes the sampling objectives and activities for
completing the additional data collection activities needed to support the RA. This FSP includes
guidance for all fieldwork by defining in detail the sampling and data-gathering methods to be used during sampling activities. The FSP also includes a Waste Management Plan (WMP) as Section 4.0 that describes the procedures for safe storage and disposal of wastes that will be generated during fieldwork. As an Appendix to the primary planning document, the UFP-QAPP,
HGL, Field Sampling Plan, Holcomb Creosote Company Site, Yadkinville, North Carolina

U.S. EPA Region 4 1-2
the FSP includes only information needed by HGL’s field sampling teams to execute the fieldwork. Information presented elsewhere in the UFP-QAPP is incorporated into the FSP by reference to
the appropriate UFP-QAPP worksheet(s).
HGL, Field Sampling Plan, Holcomb Creosote Company Site, Yadkinville, North Carolina

U.S. EPA Region 4 2-1
2.0 SITE BACKGROUND
See Worksheet #10 of the UFP-QAPP.
HGL, Field Sampling Plan, Holcomb Creosote Company Site, Yadkinville, North Carolina

U.S. EPA Region 4 3-1
3.0 FIELD SAMPLING ACTIVITIES
The sampling process was designed to ensure that the sampling objectives are fulfilled for the RA. The objective of the field investigation is to define the extent of naphthalene concentrations greater than 180 micrograms per kilogram (µg/kg) in unsaturated soils above the water table. To
accomplish this objective, surface and subsurface soil samples will be collected using a direct-push technology drilling rig or hand auger. In addition, geotechnical data are needed to evaluate the QC of the soil RA solidification/stabilization (S/S) and in situ solidification/ stabilization (ISS).
The sampling design presented in the following sections has been developed based on the results of previous Site investigations and input from the EPA. These subsections describe the sampling
rationale and approach, and include number, types, and locations of samples to be collected and the methods of analyses to be performed.
All field sampling activities will be performed in accordance with HGL’s standard operating procedures (SOPs) included in Appendix D of the UFP-QAPP and applicable EPA Region 4 Laboratory Services and Applied Science Division (LSASD) SOPs included in Appendix E of the
UFP-QAPP. All SOPs to be used in field effort are listed in Worksheet #21 of the UFP-QAPP. Standardized forms to be used for recording field data and documentation are included in Attachment 1 of this FSP. In instances where HGL and EPA Region 4 SOPs differ, the EPA Region 4 procedures will be followed.
3.1 SOIL SAMPLING
HGL will conduct soil sampling activities to define the extent of naphthalene greater than 180 µg/kg. A secondary objective of the soil sampling will be to reduce the size of the area requiring excavation and potentially establish cut lines for use during RA implementation to eliminate the need for post-excavation confirmation sampling.
HGL has identified 17 proposed soil boring locations, shown in Figures 3.1a and 3.1b. To support
the rationale for the boring locations (presented on Table 3.1), Figures 3.1a and 3.1b also depict the remedial investigation (RI) soil sampling locations and indicate the previous soil sampling locations where naphthalene exceeded 180 µg/kg. Additional soil boring locations may be added in the field in consultation with and approval from the EPA Remedial Project Manager if field observations such as odor, staining, elevated organic vapors, or non-aqueous phase liquid (NAPL)
indicate that the proposed boring locations may not fully delineate the extent of contamination.
Personnel will conduct field screening of the soil cores using a photoionization detector and also note any visual or olfactory observations (e.g., stained soil). All soil borings will be logged in accordance with HGL SOP 403.07 Borehole Logging.
Soil samples will be collected from the following locations and depth intervals:
• Near the unnamed tributary: Soil samples will be collected to delineate soil contamination east of HCSB102 and HCSB172. The samples will be collected from 0 to 0.5 feet (ft) below ground surface (bgs) at three locations just west of the unnamed tributary.
HGL, Field Sampling Plan, Holcomb Creosote Company Site, Yadkinville, North Carolina

U.S. EPA Region 4 3-2
• Near Excavation Area 5: Soil samples will be collected to delineate soil contamination
south of HCSB134. The samples will be collected from 0 to 0.5 ft bgs at two locations,
southeast and southwest of HCSB134.
• HCSB113: As part of the ISS plan, naphthalene-contaminated overburden soil above the water table will be excavated and placed in the Site containment cell. However, at ISS Area F, north of the surface impoundment, the elevated naphthalene concentrations
detected at soil boring HCSB113 at 4 to 8 ft bgs are possibly the result of NAPL in the sample. Therefore, overburden soil above the water table at Area F will be re-sampled to determine whether a portion of it can be segregated as clean backfill. Soil samples will be collected at 2 to 4 ft bgs and 4 to 6 ft bgs at HCSB113. Four additional soil samples will also be collected at 2 to 4 ft bgs and 4 to 6 ft bgs from two step-out soil borings north
and west of HCSB113.
• HCSB141: One soil sample will be collected at 8 to 10 ft bgs to confirm the soil contamination at HCSB141, near US Highway 601. Additionally, cutline soil sampling will be conducted around HCSB141. Eight additional soil samples will also be collected
at 8 to 10 ft bgs and 10 to 12 ft bgs from four step-out soil borings north, south, east, and
west of HCSB141.
• HCSB175: Cutline soil sampling will be conducted around HCSB175. Eight additional soil samples will also be collected at 2 to 5 ft bgs and 5 to 7 ft bgs from four step-out soil borings north, south, east, and west of HCSB175.
The rationale for the boring locations is presented on Table 3.1. Soil sampling will be conducted in accordance with HGL SOP 02.13 Surface and Shallow Depth Soil Sampling and the EPA Region 4 SOP LSASDPROC-300-R4 Soil Sampling. For each depth interval, the soil from the interval will be composited, and a sample collected for analysis of polynuclear aromatic
hydrocarbons (PAHs) with Selected Ion Monitoring (SIM), unless NAPL or gross contamination
is encountered. Samples with NAPL or gross contamination will be analyzed for routine PAHs without SIM. The soil samples will be submitted to either a designated Contract Laboratory Program laboratory or the EPA Region 4 laboratory.
After sampling is completed, each boring will be abandoned in accordance with the
decommissioning procedure presented in EPA Region 4 LSASD SOP LSASDPROC-300-R4 Soil
Sampling. Boreholes less than 10 ft deep that remain open and do not approach the water table may be decommissioned by pouring 30% solids bentonite grout from the surface or pouring bentonite pellets from the surface and hydrating the pellets in lifts. Boreholes deeper than 10 ft, or any borehole that intercepts groundwater, must be decommissioned by pressure grouting with 30%
solids bentonite grout, either through a re-entry tool string or through a tremie pipe introduced to
within several feet of the borehole bottom. The geographic coordinates of each soil boring will be measured and recorded using a handheld global positioning system (GPS) unit. GPS measurements will be collected in accordance with EPA Region 4 SOP LSASDPROC-110-R5 Global Positioning System.
HGL, Field Sampling Plan, Holcomb Creosote Company Site, Yadkinville, North Carolina

U.S. EPA Region 4 3-3
3.2 GEOTECHNICAL QUALITY CONTROL TESTING
QC samples for laboratory testing of unconfined compressive strength (UCS) will be performed
on mixed and cured samples at a frequency of 2 samples per mixing zone (6 zones: Area A; Area
B; Areas C & D; Area E; Areas F & G; and the stabilization pit), for a total of 12 samples for the total volume of soils to be treated with S/S of 1,678 bank cubic yards (bcy) (approximately 1 sample per every 140 bcy). For each sampling event, the RA Contractor will prepare the minimum number of replicate sample molds (coupons) for UCS of soil-cement testing by ASTM
International (ASTM) D 1633 testing at 7, 14, and 28 days, and reserve samples for flexible wall
permeability testing by ASTM D 5084 at 14 and 28 days. Information on sampling requirements is located in Specification 02 55 00 in the Final (100%) Soil Remedial Design (HGL, 2021).
3.3 FIELD QUALITY CONTROL SAMPLES
Field QC samples will consist of field duplicates, equipment rinsate blanks, field blanks, and
temperature blanks. Requirements for field QC samples are discussed in UFP-QAPP Worksheet
#20. Table 3.2 provides a summary of the QC samples, analyses, preservatives, and containers necessary to complete the sampling activities.
3.4 SAMPLE HANDLING AND CUSTODY
Sample handling and custody includes the field-related considerations connected with selecting
sample containers, preservatives, allowable holding times, and analyses requested. Requirements
for sample handling including sample labeling, tracking and management, field sample packaging and shipping, and custody procedures are discussed in UFP-QAPP Worksheets #26 and #27. Table 3.1 provides a summary of samples required along with the assigned station identifications (IDs) and sample IDs. Table 3.2 provides a summary of the parent samples, QC samples, analyses,
preservatives, and containers necessary to complete the sampling activities.
3.5 DECONTAMINATION PROCEDURES
Procedures for decontamination will be implemented to avoid cross contamination of samples that are submitted for chemical analyses. Decontamination procedures will meet the requirements contained in HGL SOP 411.02 Sampling Equipment Cleaning and Decontamination and EPA
Region 4 Science and Ecosystem Support Division (SESD) SOP SESDPROC-205-R3 Field
Equipment Cleaning and Decontamination.
Final decontamination of all equipment used to collect the samples will be required prior to equipment demobilization from the Site. This decontamination step is required to prevent contaminants from being transported off Site. The same procedures used for decontamination
between sample locations will be used during final decontamination.
3.5.1 Drilling Equipment Decontamination
The following is the standard procedure for field cleaning augers, drill stems, rods, tools, and associated equipment.
HGL, Field Sampling Plan, Holcomb Creosote Company Site, Yadkinville, North Carolina

U.S. EPA Region 4 3-4
1. Wash with tap water and soap, using a brush if necessary, to remove particulate matter and surface films. Steam cleaning (high-pressure hot water with soap) may be necessary
to remove matter that is difficult to remove with the brush. Drilling equipment that is
steam cleaned will be placed on racks or sawhorses at least 2 ft above the floor of the decontamination pad. Drill rods, etc., that are hollow or have holes that transmit water or drilling fluids will be cleaned on the inside with vigorous brushing.
2. Rinse thoroughly with tap water.
3. Remove from the decontamination pad and cover with clean, unused plastic. If stored
overnight, the plastic will be secured to ensure that it stays in place.
3.5.2 Sampling Equipment Decontamination
All non-disposable sampling and testing equipment, which is exposed to the sample medium, will be decontaminated to prevent cross contamination between sampling points. Equipment
decontamination procedures will follow the HGL SOP 411.02 Sampling Equipment Cleaning and
Decontamination and the EPA Region 4 SOP LSASDPROC-205-R4 Field Equipment Cleaning and Decontamination.
3.6 FIELD DOCUMENTATION REQUIREMENTS
Specific records and data must be maintained for each field activity to ensure that samples and
data are traceable and defensible. Requirements for field documentation are discussed in UFP-
QAPP Worksheet #29.
HGL, Field Sampling Plan, Holcomb Creosote Company Site, Yadkinville, North Carolina

U.S. EPA Region 4 4-1
4.0 WASTE MANAGEMENT PLAN
The RA contractor is responsible for the final disposition of all waste generated from field investigation and RA activities. This WMP describes the procedures for safe storage and disposal of wastes that will be generated during HGL’s pre-RA field work at HCC. IDW is expected to
consist of soil cuttings from soil sampling, decontamination water, and general refuse including discarded personal protective equipment and disposable sampling equipment.
IDW will be characterized under the “contained-in” policy, which states that environmental media are considered to contain Resource Conservation and Recovery Act (RCRA) hazardous waste: (1) when media is contaminated with characteristic hazardous waste and exhibits a characteristic
of hazardous waste; or (2) when the media is contaminated with hazardous constituents from RCRA-listed hazardous waste. Some IDW generated at HCC is expected to be contaminated with K001 and F034 listed waste. The “contained-in” policy states that environmental media contaminated with a hazardous waste must be managed as if they are hazardous wastes until they no longer contain the listed waste, no longer exhibit a characteristic, or are delisted. In order for
environmental media contaminated with a listed waste to no longer be considered hazardous, the handler of the media must demonstrate to the EPA's or the authorized state's satisfaction that the media no longer poses a sufficient health threat to merit RCRA regulation.
HGL prepared a "contained-in" determination (HGL, 2020) for environmental media at the Site contaminated with RCRA-listed K001 and F034 wastes for the purpose of characterizing
remediation waste for off-Site disposal. The “contained-in” determination considered protection of human health and the environment for the expected management of the contaminated media under the Comprehensive Environmental Response, Compensation, and Liability Act and applicable State of North Carolina policy. The “contained-in” determination calculated conservative, health-based concentrations of the hazardous constituents of K001 and F034 wastes
using a reasonable maximum exposure scenario to determine levels at which remediation wastes would be deemed to no longer contain K001 and/or F034 waste. The calculated concentrations along with the applicable State of North Carolina “contained-out” levels are included in Tables 1 and 2 of the "contained-in" determination (HGL, 2020). These tables are included in Attachment 2 of this FSP. The “contained-out” levels were selected as the lower of the risk-based
concentrations protective of an outdoor worker receptor with a non-cancer hazard index of 1.0 and an excess cancer risk of 1x10-5 or the applicable North Carolina Department of Environmental Quality (NCDEQ) “contained-out” level. For soil, the Toxicity Characteristic Leaching Procedure (TCLP) should also be considered as required under 40 Code of Federal Regulations (CFR) §261.24. It should be noted for soil that under NCDEQ policy, the NCDEQ “contained-out” TCLP
limits can be used instead of the “contained-out” total soil levels for constituents with established “contained-out” TCLP limits. The “contained-out” total soil levels must be achieved for constituents without “contained-out” TCLP limits, or if TCLP is not analyzed. The selected “contained-out” levels also comply with the RCRA Land Disposal Restriction treatment standards for hazardous wastes as required under 40 CFR §268.40 and 40 CFR §268.49. The levels shaded
in Tables 1 and 2 of the "contained-in" determination should be used for classifying remediation wastes generated at the Site as hazardous or non-hazardous for off-Site disposal (HGL, 2020).
HGL, Field Sampling Plan, Holcomb Creosote Company Site, Yadkinville, North Carolina

U.S. EPA Region 4 4-2
Any solid or liquid wastes generated will be evaluated as a potentially hazardous waste in accordance with RCRA rules. All IDW will be managed in accordance with the EPA Region 4
SOP LSASDPROC-202-R4 Management of IDW.
The following bullets summarize IDW control and disposal practices:
• The RA Contractor, HGL, and their subcontractors will be responsible for handling waste generated during this investigation. The RA Contractor and EPA will be responsible for
hazardous waste characterization and disposal arrangements.
• Contaminated safety equipment, sampling equipment, soils, and decontamination fluids generated during the field investigation will be containerized in labeled Department of Transportation-approved 55-gallon drums and stored at a designated storage area determined by the RA Contractor on the HCC property for characterization and disposal.
• Personal protective equipment waste generated during work will be decontaminated, stored in plastic bags, and disposed of at the end of each workday in an industrial dumpster at a location to be determined by the HGL field representative.
The following assumptions have been made in the preparation of the WMP:
• RCRA, Toxic Substances Control Act, and other regulatory (federal, State of North Carolina, and local equivalent) storage requirements may apply to the storage and staging of wastes at the HCC property.
• The presence of creosote constituents in IDW will indicate that the media potentially
contains K001- or F034-listed wastes and triggers RCRA regulation under the “contained-in” policy. The calculated concentrations along with the applicable State of North Carolina “contained-out” levels are included in Tables 1 and 2 of the "contained-in" determination (HGL, 2020).
• Soil IDW will be placed under the cap (if it has not been constructed yet). Soil IDW
produced after the cap will be segregated by the expected level of contamination to the extent practicable based on field observations and historical analytical results, as applicable, and containerized in 55-gallon drums.
• Manifests will be completed for disposing of all hazardous wastes off-Site, signed by the
RA Contractor “On Behalf of EPA.”
The field team leader or designee, on a daily basis, will document the generation of IDW during the field investigation to ensure that the IDW is properly containerized and stored. Information will be recorded in a bound field logbook and will include the information listed below.
• Drum number
• Type of environmental media containerized
• Date first accumulated
• Source of the IDW (soil boring or monitoring well numbers)
• Volume of soil or purge/decontamination water
HGL, Field Sampling Plan, Holcomb Creosote Company Site, Yadkinville, North Carolina

U.S. EPA Region 4 4-3
HGL will collect a sufficient number of liquid and solid waste samples for proper characterization of the IDW for off-Site transportation and disposal. The number and type (discrete versus
composite) of samples collected to characterize the IDW will be based on the requirements of the
disposal facility. Additionally, a determination will be made as to whether use of the TCLP is appropriate. The requirements of the waste disposal facility and any applicable federal, state, or local discharge permits or other requirements will be consulted for this purpose, along with the “Rule of 20.” HGL expects that TCLP analyses for organic constituents or constituents in K001
and F034 wastes will be required. The IDW sample analytical results will be compared to the
requirements of the waste disposal facility and with reference to any applicable federal, state, or local requirements to determine the appropriate disposal method. The containers will then be appropriately relabeled with the IDW characterization as either nonhazardous or hazardous. If material is found to be hazardous, arrangements will be made within 30 days with the IDW
disposal subcontractor to have it moved to an off-Site disposal facility. No hazardous waste will
remain on the Site for over 90 days. All off-Site transportation activities will be performed in accordance with U.S. Department of Transportation and State of North Carolina regulations.
A goal of this WMP is to minimize, to the extent practical, the volume of IDW generated and removed from the Site for disposal. To minimize the volume of IDW generated, the following
general rules will be applied:
• Do not contaminate materials unnecessarily.
• Plan work ahead of time based on the work procedure to be utilized.
• Decontaminate and reuse material and equipment when practical.
• Take to the work location only the materials needed to perform the work activity. Additional materials can be brought to the worksite if necessary. Materials can be stored in large containers, but the smallest container reasonable should be used to transport a
material to the work location where it is needed.
• Maintain cleaning supplies outside of any potentially contaminated area to keep them clean and to minimize the generation of additional waste.
• Perform mixing of detergents or decontamination solutions outside of potentially
contaminated areas.
• Use drop cloths or other absorbent material to contain small spills or leaks.
• Avoid a “bellows” effect (that is, ensure that air is removed from bags or other containers
carrying waste materials) when bagging contaminated materials.
• Use containers to minimize the spread of contamination (for example, use a bucket to contain an oil leak from equipment).
• Do not place contaminated materials with clean materials.
• Employ volume reduction techniques when practicable.
• Verify that waste containers are solidly packed to minimize the number of containers.
HGL, Field Sampling Plan, Holcomb Creosote Company Site, Yadkinville, North Carolina

U.S. EPA Region 4 4-4
• Use containers that are large enough to meet the needs of a specific work task, but not
larger than necessary.
• Use nonhazardous decontamination substances whenever possible.
HGL, Field Sampling Plan, Holcomb Creosote Company Site, Yadkinville, North Carolina

U.S. EPA Region 4 5-1
5.0 REFERENCES
HydroGeoLogic, Inc. (HGL), 2020. Final “Contained-In” Determination for Investigation-Derived Waste, Holcomb Creosote Company Site. August.
HGL, 2021. Final (100%) Soil Remedial Design, Holcomb Creosote Company Site. December.
U.S. Environmental Protection Agency (EPA), 2018. Record of Decision, Holcomb Creosote
Company Superfund Site. August.

TABLES
Table 3.1Proposed Sampling Locations and RationalesHolcomb Creosote SiteYadkinville, Yadkin County, North CarolinaLatitude LongitudeHCSB141 HCSB141-0810 36.157570 -80.675614Resample RI subsurface soil location where exceedance was detected.HCSB258HCSB258-0810 and HCSB258-101236.157543 -80.675612HCSB259HCSB259-0810 and HCSB259-101236.157572 -80.675632HCSB260HCSB260-0810 and HCSB260-101236.157597 -80.675614HCSB261HCSB261-0810 and HCSB261-101236.157569 -80.675580HCSB262HCSB262-0205 and HCSB262-050736.157635 -80.674759HCSB263HCSB263-0205 and HCSB263-050736.157662 -80.674796HCSB264HCSB264-0205 and HCSB264-050736.157689 -80.674763HCSB265HCSB265-0205 and HCSB265-050736.157662 -80.674728HCSB113HCSB113-0204 and HCSB113-040636.157520 -80.675034Resample RI subsurface soil location above NAPL depth interval.HCSB266HCSB266-0204 and HCSB266-040636.157550 -80.675079HCSB267HCSB267-0204 and HCSB267-040636.157568 -80.675024HCSB268 HCSB268SF 36.157371 -80.673979HCSB269 HCSB269SF 36.157357 -80.674096HCSB270 HCSB270SF 36.157778 -80.674923HCSB271 HCSB271SF 36.157853 -80.674965HCSB272 HCSB272SF 36.157923 -80.674997Notes:* Any samples that exhibit the presence of NAPL or gross contamination will be analyzed for routine PAHs without SIM.µg/kg = microgram per kilogram RI = Remedial InvestigationNAPL = non-aqeous phase liquid SIM = selected ion monitoringPAH = polynuclear aromatic hydrocarbonSoil BoringsStation LocationSample IdentificationCoordinatesRationale Chemical AnalysesSIM PAHs, unless NAPL or gross contamination is present*Delineate the extent of naphthalene greater than 180 µg/kg; reduce size of excavation area; provide data for cut lines.Delineate the extent of naphthalene greater than 180 µg/kg; determine whether NAPL overburden can be segregated as clean fill.Delineate the extent of naphthalene greater than 180 µg/kg; reduce size of excavation area.SIM PAHs, unless NAPL or gross contamination is present*Page 1 of 1
Table 3.2Proposed Analytical Methods and Sample SummaryHolcomb Creosote SiteYadkinville, Yadkin County, North CarolinaField Dup.Rinsate BlanksTrip BlankMS/ MSDNumber of ContainersType of ContainerMinimum Sample Volume PreservationHolding TimeSoil PID SIM PAHs* EPA 8270D 28 2 2** NA 2 30Region 4 or CLP18 oz glassFill to CapacityCool to <6°C 14 daysWater (Soil/ Sediment Rinsate Blanks)None PAHs EPA 8270D 0 0 2 NA 0 2Region 4 or CLP11 L AmberFill to CapacityCool to <6°C 7 daysNotes:* Any samples that exhibit the presence of non-aqeous phase liquid or gross contamination will be analyzed for routine PAHs without SIM by the EPA Region 4 laboratory.** Soil rinsate blanks are aqueous samples accounted for on the last line of the table.°C = degrees Celsius NA = not applicableCLP = Contract Laboratory Program oz.= ounceDup. = duplicate PAH = polynuclear aromatic hydrocarbonEPA = U.S. Environmental Protection Agency PID = photoionization detector L = liter QA = quality assuranceMS/MSD = matrix spike/ matrix spike duplicate QC = quality controlNA = not applicable SIM = selected ion monitoring TotalAssigned LaboratoryBottleware and Preservative RequirementsSample MatrixField ParametersLaboratory ParametersAnalytical MethodNo. of SamplesQA/QC SamplesPage 1 of 1

FIGURES
DobbinsPondHaire RoadS hugart's M ill R oad£¤601Lake Hill DriveLas Brisas DriveLakewood TrailDobbins Mill RoadFigure 1.1Site LocationLegendHGL—Field Sampling PlanHolcomb Creosote Site—Yadkinville, North Carolina0450900225Feet³\\srv-gst-01\HGLGIS\Holcomb_Creosote_E2412X\FSP\HolcombCreosote_Fig101_SiteLocation_20221206.mxd12/6/2022 JGSource: HGL, JMWaller, Versar ArcGIS Online Imagery/Streets Map^_HolcombCreosote SiteNORTHCAROLINAStatewide Location£¤601£¤421HolcombCreosote SiteGeneral Location021MilesHolcomb Creosote Property Boundary
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D DDDDDDDDDDDDDD£¤601Drip Pad(removed)StorageOfficeTreatment Vessel(removed)Distillation Evaporator(removed)FormerDrum Storage AreaConcrete Pit(removed)Creosote Work Tank(removed)Creosote Storage Tank(removed)Gasoline UST(removed)Steel Settling Tank(removed)Overflow CreosoteStorage Tank(removed)Diesel TankU nam ed TributaryFigure 1.2Site Facility PlanLegendHGL—Field Sampling PlanHolcomb Creosote Site—Yadkinville, North Carolina08016040Feet³\\srv-gst-01\HGLGIS\Holcomb_Creosote_E2412X\FSP\HolcombCreosote_Fig102_SiteFacility_20221028.mxd10/28/2022 JGSource: HGL, JMWaller, Versar ArcGIS Online Imagery (Clarity)Note:UST=underground storage tankFenceDSurface Water CourseWetlandsSite BoundaryLandfarm (closed)Surface ImpoundmentExisting StructureFormer StructureFormer Holcomb Creosote Operations Area
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HCSB99 HCSB98 HCSB89 HCSB87 HCSB84 HCSB72 HCSB64 HCSB189 HCSB176 HCSB175 HCSB174 HCSB173 HCSB172 HCSB171 HCSB164 HCSB163 HCSB162 HCSB161 HCSB160 HCSB159 HCSB158 HCSB157 HCSB153 HCSB152 HCSB151 HCSB150 HCSB149 HCSB148 HCSB147 HCSB146 HCSB145 HCSB144 HCSB142 HCSB141 HCSB140 HCSB139 HCSB138 HCSB137 HCSB131 HCSB113 HCSB104 HCSB103 HCSB156 HCSB102 HCSB252HCSB220HCSB218HCSB253HCSB251HCSB250HCSB247HCSB223HCSB222HCSB219HCSB217HCSB216HCSB215HCSB214HCSB212HCSB211HCSB210HCSB207HCSB206HCSB204HCSB203HCSB201HCSB249HCSB248HCSB246HCSB213HCSB209HCSB208HCSB205HCSB202HCSB221HCSD11HCSB272HCSB271HCSB270HCSB261HCSB260HCSB259HCSB258HCSB264HCSB263HCSB262HCSB267HCSB26618K(5-7)>20K(2-5)510(5-7)>20K(7-9)>20K(4-8)14K(24-28)820(0.5-2)>20K(6-8)>20K(10-12)290(0-2)20K(8-12)11K(16-20)>20K(6-7)630(12-16)280(20-24)1,100(20-24)210 J(28-32)390(8-10)6,300 U(2-4)240(8-10)25K(11-13)630(8-10)>20K(4-8)18K J(2-5)3,400(4-6)710(0-2)1,700(2-5)Figure 3.1aSoil and SedimentNorthern Proposed Soil BoringLocationsLegend0306015Feet³\\srv-gst-01\HGLGIS\Holcomb_Creosote_E2412X\FSP\HolcombCreosote_Fig301a_NorthSB_20221028.mxd10/28/2022 JGSource: HGL, Versar ArcGIS Online Imagery (Clarity)Notes:Top of bank sediment samples, HCSD202 and HCSD204, used for delineation of surface soil contamination.µg/kg=micrograms per kilogrammg/kg=milligrams per kilogrambgs=below ground surfacePAH=polynuclear aromatic hydrocarbonUFP-QAPP=Uniform Federal Policy Quality Assurance Project Plan820(0.5-2)=Napthalene result above 180 µg/kg (depth in feet bgs)HGL—Field Sampling PlanHolcomb Creosote Site—Yadkinville, North CarolinaWetlandsLandfarm (closed)Surface Impoundment (closed)Extent of Napthalene in Soil Greater than180 µg/kg (dashed where inferred)Surface Water CourseExtent of Total PAHs in Sediment Greater than198 mg/kgFenceDSediment Sample withTotal PAH Less than 198 mg/kg#ISediment Sample withTotal PAH Greater than 198 mg/kg#ISoil Boring with Naphthalene Less than 180 µg/kg!HSoil Boring with Naphthalene Greater than 180 µg/kg. Maximum NaphthaleneConcentration (depth interval), and DeepestExceedance Value and Depth Interval Indicated!HProposed Soil Boring!H
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HCSB99 HCSB98 HCSB31 HCSB194 HCSB193 HCSB191 HCSB190 HCSB188 HCSB187 HCSB186 HCSB184 HCSB183 HCSB180 HCSB179 HCSB178 HCSB177 HCSB176 HCSB175 HCSB174 HCSB166 HCSB165 HCSB164 HCSB134 HCSB133 HCSB132 HCSB131 HCSB113 HCSB104 HCSB103 HCSB192 HCSB116 HCSB102 HCSB245HCSB220HCSB257HCSB256HCSB247HCSB244HCSB242HCSB241HCSB237HCSB236HCSB235HCSB234HCSB233HCSB232HCSB231HCSB230HCSB229HCSB228HCSB227HCSB226HCSB225HCSB224HCSB223HCSB222HCSB249HCSB248HCSB246HCSB243HCSB221HCSB135HCSB136HCSB254HCSB255HCSB239HCSB240HCSD47HCSD10HCSD54HCSD55HCSD203HCSD201HCSD204HCSD202HCSB270HCSB264HCSB263HCSB262HCSB267HCSB266HCSB265HCSB269HCSB26820K(8-12)11K(16-20)>20K(6-7)630(12-16)280(20-24)>20K(4-8)18K J(2-5)3,400(4-6)710(0-2)1,700(2-5)240(2-5)890 J(0-2)330 J(0-0.5)360(0-0.5)660(0-0.5)350(0-2)3,400(0-0.5)3,500(5-7)1,100(2-5)520(8-10)4,700(2-4)5,000(2-4)3,100(4-6)780(2-5)8,300 J(0.5-2)5,900 J(0.5-2)1,100(2-5)Figure 3.1bSoil and SedimentSouthern Proposed Soil BoringLocationsLegend0306015Feet³\\srv-gst-01\HGLGIS\Holcomb_Creosote_E2412X\FSP\HolcombCreosote_Fig301b_SouthSB_20221028.mxd10/28/2022 JGSource: HGL, Versar ArcGIS Online Imagery (Clarity)Notes:Top of bank sediment samples, HCSD202 and HCSD204, used for delineation of surface soil contamination.µg/kg=micrograms per kilogrammg/kg=milligrams per kilogrambgs=below ground surfacePAH=polynuclear aromatic hydrocarbonUFP-QAPP=Uniform Federal Policy Quality Assurance Project Plan360(0-0.5)=Napthalene result above 180 µg/kg (depth in feet bgs)HGL—Field Sampling PlanHolcomb Creosote Site—Yadkinville, North CarolinaWetlandsLandfarm (closed)Surface Impoundment (closed)Extent of Napthalene in Soil Greater than180 µg/kg (dashed where inferred)Surface Water CourseExtent of Total PAHs in Sediment Greater than198 mg/kgFenceDSediment Sample withTotal PAH Less than 198 mg/kg#ISediment Sample withTotal PAH Greater than 198 mg/kg#ISoil Boring with Naphthalene Less than 180 µg/kg!HSoil Boring with Naphthalene Greater than 180 µg/kg. Maximum NaphthaleneConcentration (depth interval), and DeepestExceedance Value and Depth Interval Indicated!HProposed Soil Boring!H

ATTACHMENT 1

FIELD SAMPLING FORMS

• Instrument Calibration Log
• Soil Boring Log
SignatureCalibration Date TimeCalibrationEnd of Day TestStandard Lot Number ManufacturerSerial Number Calibration by:INSTRUMENT CALIBRATION LOGPROJECT NAME / LOCATION: Former Custom Cleaners Superfund Site, Operable Unit 2 / Memphis, TennesseeInstrument ReadingsInstrumentParameter1 OF 1
PROJECT :LOCATION :
U.S. Environmental Protection Agency
ELEVATION:
DRILLING METHOD AND EQUIPMENT :
START : FINISH :
SOIL DESCRIPTION COMMENTS
SOIL NAME, USCS GROUP SYMBOL, COLOR, MOISTURE
CONTENT, RELATIVE DENSITY, OR CONSISTENCY, SOIL
STRUCTURE, MINERALOGY.
Such as: PID READINGS, DEPTH OF
CASING, DRILLING RATE, DRILLING
FLUID LOSS, TESTS, AND
INSTRUMENTATION.
WATER LEVEL :LOGGED BY :DEPTH BELOW SURFACE (FT)SAMPLE LENGTH (FT)RECOVERY (FT)SAMPLE # / TYPELITHOLOGY (USCS)CLIENT :DRILLING CONTRACTOR :
BORING LOCATION :
PROJECT NUMBER BORING NUMBER WELL NUMBER
SOIL BORING LOG
Page ____ of _____

ATTACHMENT 2 CONTAINED-IN DETERMINATION TABLES
Table 1 Site-Specific "Contained-Out" Levels for Soil
Constituent
Total Soil Concentrations TCLP Concentrations Risk-Based Levels 1
(mg/kg) NCDEQ "Contained-out" Level 2 (mg/kg)
EPA TCLP Limit 3 (mg/L)
NCDEQ "Contained-out" TCLP Level 2, 4 (mg/L) 1E-06 1E-05 1E-04 HI=1.0
Acenaphthene -- -- -- 47,900 34 -- -- Anthracene -- -- -- 240,000 4,200 -- 210 Arsenic 47.5 475 4,750 -- 100 5 5 Benzo(a)anthracene 321 3,210 32,100 -- 2 -- -- Benzo(a)pyrene 35 350 3,500 -- 0.21 -- -- Benzo(b)fluoranthene 350 3,500 35,000 -- 2.1 -- -- Benzo(k)fluoranthene 3,500 35,000 350,000 -- 21 -- -- Chromium (total) 99.1 991 9,910 1,700 100 5 5 Chrysene 35,000 350,000 3,500,000 -- 210 -- -- Dibenz(a,h)anthracene 35 350 3,500 -- 0.21 -- -- Fluorene -- -- -- 95,800 560 -- 28 Indeno(1,2,3-cd)pyrene 350 3,500 35,000 -- 2.1 -- -- Lead 1,300 5 100 5 5 Naphthalene 58 580 5,800 144,000 42 -- 2.1 Pentachlorophenol 68.8 688 6,880 942 2,000 100 100 Phenanthrene -- -- -- -- 420 -- 21 Pyrene -- -- -- 71,900 420 -- 21 Toluene -- -- -- 7,590 100 -- -- Xylenes (total) -- -- -- 831 300 -- --
1 Calculated using EPA's Regional Screening Level (RSL) calculator. The construction worker (soil - unpaved road traffic) receptor was used to calculate soil RSLs. An exposure frequency of 125 days/year, exposure duration of 1 year, and exposure time of 8 hours/day were used. See the attached RSL calculator output files for a full list of exposure assumptions used. 2 Levels for disposal in a municipal solid waste landfill from NCDEQ "Contained-in" Policy for Soil Contaminated with Listed Hazardous Waste (June 28, 2016) 3 From 40 CFR §261.24 Table 1 - Maximum Concentration of Contaminants for the Toxicity Characteristic 4 NCDEQ policy states that for constituents with published “contained-out” TCLP limits, those limits can be used instead of the total soil levels. 5 Potential risks associated with exposure to lead are not based on cancer risks or non-cancer hazards, but instead on modeled blood lead levels. A protective soil concentration for the construction worker of 1,300 mg/kg was calculated using the Adult Lead Model and a target blood lead concentration of 8 µg/dL. See the attached Adult Lead Model output file for the exposure assumptions used. -- No risk-based level or TCLP limit available mg/kg = milligrams per kilogram mg/L = milligrams per liter
Selected "contained-out" level

Table 2 Site-Specific "Contained-Out" Levels for Water
Analyte
Risk-Based Levels 1 (µg/L) NCDEQ Groundwater Standard 2
(µg/L) 1E-06 1E-05 1E-04 HI=1.0
Acenaphthene -- -- -- 19,700 80
Anthracene -- -- -- 58,400 2,000
Arsenic 298 2,980 29,800 -- 10
Benzo(a)anthracene 31,900 319,000 3,190,000 -- 0.05
Benzo(a)pyrene 3,190 31,900 319,000 -- 0.005
Benzo(b)fluoranthene 31,900 319,000 3,190,000 -- 0.05
Benzo(k)fluoranthene 319,000 3,190,000 31,900,000 -- 0.5
Chromium (total) 14.5 145 1,450 516 10
Chrysene 3,190,000 31,900,000 319,000,000 -- 5
Dibenz(a,h)anthracene 3,190 31,900 319,000 -- 0.005
Fluorene -- -- -- 30,700 300
Indeno(1,2,3-cd)pyrene 31900 319,000 3,190,000 -- 0.05
Lead 15 3 15
Naphthalene 103 1,030 10,300 106,000 6
Pentachlorophenol 7.17 71.7 717 205 0.3
Phenanthrene -- -- -- -- 200
Pyrene -- -- -- 11,000 200
Toluene -- -- -- 213,000 600
Xylenes (total) -- -- -- 68,700 500
1 Calculated using EPA's RSL calculator. The recreator receptor was used to calculate water RSLs. An exposure frequency of 125 days/year, exposure duration of 1 year, and exposure time of 8 hours/day were used. See the attached RSL calculator output files for a full list of exposure assumptions used. 2 From 15A NCAC 02L .0202 (Effective April 1, 2013) 3 Potential risks associated with exposure to lead are not based on cancer risks or non-cancer hazards, but instead on modeled blood lead levels. Lead data should be compared to the Maximum Contaminant Level of 15 µg/L. -- No risk-based level available µg/L = micrograms per liter
Selected "contained-out" level

APPENDIX B

DATA MANAGEMENT PLAN

FINAL
DATA MANAGEMENT PLAN

HOLCOMB CREOSOTE COMPANY SITE
YADKINVILLE, YADKIN COUNTY, NORTH CAROLINA

Prepared for:

U.S. Environmental Protection Agency Region 4
Atlanta Federal Center
61 Forsyth Street, SW
Atlanta, GA 30303-3104

Design and Engineering Services (DES) Contract 68HE0318D0006
Task Order 68HE0422F0071

Prepared by:

HydroGeoLogic, Inc.
DES CLIN 2
HGL Region 4 Office
1745 Phoenix Boulevard, Suite 200
Atlanta, GA 30349

February 2023
TABLE OF CONTENTS

Section Page
U.S. EPA Region 4
i
1.0 INTRODUCTION .............................................................................................................. 1
2.0 FIELD DATA ..................................................................................................................... 2
3.0 LABORATORY DATA ..................................................................................................... 2
4.0 ELECTRONIC DATA DELIVERABLES ......................................................................... 2
5.0 REFERENCES ................................................................................................................... 3

LIST OF TABLES

Table 4.1 Required EDD Files
LIST OF ACRONYMS AND ABBREVIATIONS

U.S. EPA Region 4
ii
CLIN contract line item number
CLP Contract Laboratory Program
CoC chain of custody

DES Design and Engineering Services
DMP Data Management Plan

EDD electronic data deliverable
EPA U.S. Environmental Protection Agency
EQuIS Environmental Quality Information System

FSP Field Sampling Plan

GIS geographic information system

HASP Health and Safety Plan
HCC Holcomb Creosote Company
HGL HydroGeoLogic, Inc.

LSASD Laboratory Services and Applied Science Division

QAPP Quality Assurance Project Plan

R4LIMS Region 4 Laboratory Information Management System
RES chemistry result

SOP standard operating procedure

TO task order
TST chemistry test

UFP Uniform Federal Policy

U.S. EPA Region 4
1
DATA MANAGEMENT PLAN
HOLCOMB CREOSOTE COMPANY SITE
YADKINVILLE, YADKIN COUNTY, NORTH CAROLINA

1.0 INTRODUCTION
This Data Management Plan (DMP) details data management activities to be conducted by
HydroGeoLogic, Inc. (HGL) at the Holcomb Creosote Company (HCC) Site located in
Yadkinville, Yadkin County, North Carolina. These activities are being conducted by HGL for the
U.S. Environmental Protection Agency (EPA) Region 4 under Design and Engineering Services
(DES) Contract 68HE0318D0006, task order (TO) 68HE0422F0071. The purpose of this TO is to
prepare the Remedial Action for soil and groundwater in accordance with the Record of Decision
(EPA, 2018).

Several planning documents have been prepared by HGL to provide details regarding sampling
activities, data quality objectives for field and laboratory data, data management practices, and
investigation-derived waste handling procedures to be followed during field activities. Other
planning documents include the following:

• A Uniform Federal Policy (UFP)-Quality Assurance Project Plan (QAPP). The UFP-
QAPP is the primary planning document for the TO and covers the project’s organization,
planned activities, and quality assurance/quality control procedures necessary to
complete the work. The UFP-QAPP will be implemented to ensure that the data collected
are valid for the intended end use and that data meet the requirements of the data quality
objectives. The UFP-QAPP includes the following documents as appendices:
o A Field Sampling Plan (FSP) (Appendix A of the UFP-QAPP). The FSP describes
the sampling objectives and activities for completing the Remedial Action data
collection. The FSP includes guidance for all field work by detailing the sampling
and data-gathering methods to be used during sampling activities. The FSP also
includes a Waste Management Plan that describes the procedures for safe storage
and disposal of wastes that will be generated during fieldwork.
o The Data Management Plan (DMP) (This document) (Appendix B of the UFP-
QAPP). The DMP details procedures to be used for managing field and laboratory
data generated by the field investigations.
• A Site Management Plan that addresses the coordination and control of Site activities
during the field investigation.
• A Site Health and Safety Plan (HASP). The HASP defines the preventative and protective
procedures that will be implemented during the field activities to ensure the safety of the
field team.
As an appendix to the primary planning document, the UFP-QAPP, the DMP does not repeat
information already presented in the UFP-QAPP. Accordingly, the information presented
HGL, Data Management Plan, Holcomb Creosote Company Site, Yadkinville, North Carolina

U.S. EPA Region 4
2
elsewhere in the UFP-QAPP is incorporated into the DMP by reference to the appropriate UFP-
QAPP worksheet(s).
2.0 FIELD DATA
Site conditions during sampling and the care with which samples are collected and handled in the
field may factor into their representativeness. This, in turn, could affect the ability of decision
makers to make accurate and timely decisions concerning the contamination status of the Site. As
appropriate, logbooks will be assigned to, and maintained by, key field team personnel. The
logbooks will be used to record daily conditions/activities such as weather conditions, dates/times
of significant events, level of personal protection equipment used, drilling activities, actual sample
collection locations, photographs taken, problems encountered, and corrective actions taken to
overcome problems. Additionally, the names of Site visitors and the purposes of their visits will
be recorded. Finally, all logbooks will be maintained in accordance with HGL standard operating
procedure (SOP) 300.04 Field Logbook Use and Maintenance and EPA Region 4 Laboratory
Services and Applied Science Division (LSASD) SOP SESDPROC-1002-R0 Logbooks.

Field logbooks and sample documentation, including chain of custody (CoC) forms and field
sampling forms, provide a record that should allow a technically qualified individual to reconstruct
significant field activities without resorting to memory. The field team leader is responsible for
the maintenance and security of all field records at the end of each workday during field activities.
At the completion of field activities, the field team leader will forward all field records to the HGL
project manager. Field logbooks and field forms will be scanned into a legible PDF and retained
in both electronic and printed versions for inclusion into Site reports as appendices. In addition,
all logbooks and forms will be kept in the project file until project closeout, where they will be
returned to EPA for permanent storage (if requested).
3.0 LABORATORY DATA
Data management for analytical data generated is dictated by which laboratories perform analyses.
Data resulting from analyses performed by the EPA Region 4 laboratory and the resulting data
results are managed by EPA internally using Region 4 Laboratory Information Management
System (R4LIMS) and EPA Region 4’s Environmental Quality Information System (EQuIS) data
management software. Contract Laboratory Program (CLP) laboratory data is transmitted
electronically to the EPA Region 4 LSASD Quality Assurance Section for data validation, and
subsequently, the data and qualifiers are uploaded into the R4LIMS and EQuIS. Laboratory data
generated during the Post and Lumber soil and sediment sampling investigation is planned to be
from either the EPA Region 4 or a CLP laboratory.
4.0 ELECTRONIC DATA DELIVERABLES
All field data and CoC information will be managed electronically using Scribe, which is a
software tool developed by the EPA to assist in the process of managing environmental data. Scribe
will be used to capture sampling, observational, and monitoring field data; print labels for collected
samples; generate CoC documentation; and electronically transmit CoC reports and sample
collection information to the EPA Region 4 or CLP laboratory. At the completion of field
activities, electronic data deliverables (EDDs) of field data will be prepared as part of the data
HGL, Data Management Plan, Holcomb Creosote Company Site, Yadkinville, North Carolina

U.S. EPA Region 4
3
tabulation and evaluation process and will be provided to EPA in EQuIS format for upload to the
regional EQuIS database, in accordance with the EPA Region 4 Superfund and Emergency
Management guidance document SEMDPROC-009-R0 Environmental Data Submission. The
EDD files presented in Table 4.1 below are expected to be required for this investigation.

Table 4.1
Required EDD Files
EDDs/Tables/ Format
Sections
Soil
(Surface and
Subsurface)
Soil
Borings/Cores
Land
Access1
EPAR4 Location ✓ ✓ ✓
EPAR4 Location Parameter x x ✓
EPAR4 Lithology ✓ ✓ x
EPAR4 Field Results ✓ ✓ x
EPAR4 Fsample ✓ ✓ x
EPAR4 TST ✓ ✓ x
EPAR4 RES ✓ ✓ x
Notes:
1Attach PDF file of land access agreement
✓ = Required
x = not required
Fsample = field sample
TST = chemistry test
RES = chemistry result

EPA Region 4 and CLP laboratory analytical results are prepared as EDDs through R4LIMS and
uploaded into the regional EQuIS database by EPA. HGL will be notified of analytical upload via
email from [e-mail]. Full analytical reports are provided to HGL via email in PDF
and .data files containing analytical EDD files from [e-mail]. HGL also has secure
access to the Region 4 EQuIS database to query and retrieve data for import to Microsoft Excel
for preparation of data summary tables or for use in geographic information system (GIS) software
for generation of figures. As part of TO closeout activities, HGL will provide EPA with a
comprehensive, electronic final archive of sampling and monitoring data and data deliverables,
including GIS files. All GIS files will be in standard Environmental Systems Research Institute
format and have spatial reference information that describes the projection, datum, and where
applicable, the collection methods.
5.0 REFERENCES
U.S. Environmental Protection Agency (EPA), 2018. Record of Decision, Holcomb Creosote
Company Superfund Site. August.

APPENDIX C

EPA LABORATORY SERVICES BRANCH LABORATORY OPERATIONS AND QUALITY
ASSURANCE MANUAL

APPENDIX D

HGL STANDARD OPERATING PROCEDURES

APPENDIX E

EPA REGION 4 STANDARD OPERATING PROCEDURES
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Revision History

The top row of this table shows the most recent changes to this controlled document. For
previous revision history information, archived versions of this document are maintained
by the SESD Document Control Coordinator on the SESD local area network (LAN).

History Effective Date
SESDPROC-005-R3, Sample and Evidence Management,
replaces SESDPROC-005-R2

General: Corrected any typographical, grammatical, and/or editorial errors.
Cover Page: SESD’s reorganization was reflected in the authorization section by making John Deatrick the Chief of the Field Services Branch.
The FQM was changed from Bobby Lewis to Hunter Johnson.
Revision History: Changes were made to reflect the current practice of only including the most recent changes in the revision history.
Section 2.2.2: Revised to clarify accreditation and agency requirements
for digital images. Also, language was added to accommodate new storage techniques.
May 25, 2016
SESDPROC-005-R2, Sample and Evidence Management, replaces SESDPROC-005-R1 January 29, 2013
SESDPROC-005-R1, Sample and Evidence Management,
replaces SESDPROC-005-R0
November 1, 2007
SESDPROC-005-R0, Sample and Evidence Management,
Original Issue February 05, 2007

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TABLE OF CONTENTS
1 General Information ................................................................................................. 4 1.1 Purpose ................................................................................................................ 4 1.2 Scope/Application ............................................................................................... 4
1.3 Documentation/Verification .............................................................................. 4
1.4 References ........................................................................................................... 4
2 Sample and Evidence Identification ........................................................................ 5 2.1 Introduction ....................................................................................................... 5 2.2 Sample and Evidence Identification Procedures ............................................. 6
2.2.1 Sample Identification .................................................................................... 6
2.2.2 Digital Images – Photographs and Videos ................................................... 7
2.2.3 Identification of Physical Evidence .............................................................. 8
3 Chain-of-Custody Procedures ................................................................................. 9 3.1 Introduction ........................................................................................................ 9
3.2 Sample Custody .................................................................................................. 9
3.3 Documentation of Chain-of-Custody ................................................................ 9
3.4 Transfer of Custody with Shipment ............................................................... 11
4 Receipt for Samples Form (CERCLA/RCRA/TSCA) ......................................... 13 4.1 Introduction ...................................................................................................... 13
4.2 Receipt for Samples Form ............................................................................... 13
5 Sample Custody Management Software ............................................................... 15

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1 General Information
1.1 Purpose This document describes general and specific procedures, methods and considerations to
be used and observed by SESD field investigators when handling and managing samples
and other types of evidence after their collection and during delivery to the laboratory.
1.2 Scope/Application
The procedures contained in this document are to be used by field investigators when
handling and managing samples and other evidence collected to support SESD field investigations. On the occasion that SESD field investigators determine that any of the
procedures described in this section are either inappropriate, inadequate or impractical and
that another procedure must be used, the variant procedure will be documented in the field
log book, along with a description of the circumstances requiring its use. Mention of trade
names or commercial products in this operating procedure does not constitute endorsement or recommendation for use.

1.3 Documentation/Verification

This procedure was prepared by persons deemed technically competent by SESD management, based on their knowledge, skills and abilities and have been tested in practice
and reviewed in print by a subject matter expert. The official copy of this procedure resides
on the SESD Local Area Network (LAN). The Document Control Coordinator is
responsible for ensuring the most recent version of the procedure is placed on the LAN and
for maintaining records of review conducted prior to its issuance. 1.4 References
SESD Operating Procedure for Control of Records, SESDPROC-002, Most Recent
Version
SESD Operating Procedure for Packing, Marking, Labeling and Shipping of
Environmental and Waste Samples, SESDPROC-209, Most Recent Version

USEPA Region 4 Environmental Investigations Standard Operating Procedures and Quality Assurance Manual (EISOPQAM), November 2001

USEPA Digital Camera Guidance for EPA Civil Inspections and Investigations, July 2006

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2 Sample and Evidence Identification
2.1 Introduction Sample identification, chain-of-custody records, receipt for sample records and other field records will be legibly recorded with waterproof, non-erasable ink, unless otherwise specified. If errors are made in any of these documents, corrections will be made by crossing a single line through the error and entering the correct information. All corrections must be initialed and dated. If possible, all corrections should be made by the individual making the error. Following are definitions of terms used in this section: Field Investigator Any individual who performs or conducts field sampling, observation and/or measurement activities in support of field investigations Project Leader The individual with overall responsibility for conducting a specific field investigation in accordance with this procedure Field Sample Custodian Individual responsible for identifying the sample containers and maintaining custody of the samples and the Chain-of-Custody Record Sample Team Leader An individual designated by the project leader to be present during and responsible for all activities related to the collection of samples by a specific sampling team Sampler The individual responsible for the actual collection of a sample Transferee Any individual who receives custody of samples subsequent to release by the field sample custodian Laboratory Sample Custodian Individual responsible for accepting custody of samples from the field sample custodian or a transferee One individual may fulfill more than one of the roles described above.
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2.2 Sample and Evidence Identification Procedures
2.2.1 Sample Identification
The method of sample identification used depends on the type of sample collected. Field measurement samples are those collected for specific field analysis or
measurement where the data are recorded directly in bound field logbooks or on the Chain-of-Custody Record. Examples of field measurements and analyses include
XRF, pH, temperature, dissolved oxygen and conductivity. Samples collected for laboratory analysis will be identified by using a stick-on label or a tag which is
attached to the sample container. In some cases such as biological samples, the label or tag may have to be affixed to a bag containing the sample. If a sample tag is used, the sample should be placed in a bag, then the sample and the tag will be placed in a second bag.
The following information will be included on the sample label or tag using
waterproof, non-erasable ink:
• Project number;
• Field identification or sample station number;

• Date and time of sample collection;
• Designation of the sample as a grab or composite;
• Whether the sample is preserved or unpreserved;
• The general types of analyses to be performed.

Other information such as readily detectable or identifiable odor, color, or known
toxic properties may be added as deemed necessary by the project leader or sample custodian.

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2.2.2 Digital Images – Photographs and Videos

When digital images, which include but are not limited to photographs, digital
still images and videos, are taken for purposes of documenting and supporting a
field investigation, a record, containing relevant information, will be kept in a
field logbook. The following information will be recorded in the log:

• Digital Image Location or Station Identification
• Description of what the digital image shows
• Date and time the digital image was taken
• Name of the individual that took the digital image
• Digital file name (assigned by camera)
• Orientation, if applicable
• Other pertinent information
When digital images are obtained during a field investigation, the permanent record for the official project file, will be stored on a project dedicated data
storage device, which includes but is not limited to Secure Digital (SD) card,
Compact Discs (CD), or Flash Drives. A new data storage device will be utilized
for each project and once the project is completed the device, containing the
unaltered investigation-related images, will be labeled with the project’s unique identification number and placed in the official file. Photographs taken for
educational or other purposes should be stored on an additional storage device and
should not be included in the official project file.
It is SESD’s policy that, during a field investigation, official project specific
digital images should be obtained using SESD issued electronics but in the event that the only option field personnel have is to utilize their own electronic
equipment the following steps should be taken:

• Record all required digital image information, as described above
• Record devices make, model and owner’s name
• Transfer all digital images to a project specific data storage device and
adhere to requirements outlined in the EPA Records Management Policy
(CIO 2155.3).

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2.2.3 Identification of Physical Evidence
Physical evidence, other than samples, will be identified, when possible, by recording the necessary information on the evidence. When samples are collected from vessels or containers which can be moved (drums for example), the vessel or
container should be marked with the field identification or sample station number for future identification. The vessel or container may be labeled with an indelible
marker (e.g., paint stick or spray paint). The vessel or container need not be marked if it already has a unique marking; however, these markings will be recorded in the
bound field logbooks. In addition, it is suggested that photographs of any physical evidence (markings, etc.) be taken and the necessary information recorded in the
field logbook. Occasionally, it is necessary to obtain copies of recorder and/or instrument charts from facility owned analytical equipment, flow recorders, etc., during field investigations and inspections. A unique identifier will be recorded on the
document with that information as well as the following recorded in the logbook:
• Starting and ending time(s) and date(s) for the chart;
• An instantaneous measurement of the media being measured by the recorder
will be taken and entered at the appropriate location on the chart along with the date and time of the measurement; and

• A description of the location being monitored and other information required to interpret the data such as type of flow device, chart units, factors, etc.
The field investigator will indicate who the chart (or copy of the chart) was received from and enter the date and time, as well as the field investigator's initials.
Documents such as technical reports, laboratory reports, etc., should be marked
with the field investigator's signature, the date, the number of pages and from whom they were received. Documents that are claimed by a facility to be “confidential”
and, therefore, potentially subject to the Confidential Business Information requirements, will be handled in accordance with SESD Operating Procedure for Control of Records (SESDPROC-002).
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3 Chain-of-Custody Procedures
3.1 Introduction Chain-of-custody procedures are comprised of the following elements: 1) maintaining custody of samples or other evidence, and 2) documentation of the chain-of-custody for evidence. To document chain-of-custody, an accurate record must be maintained to trace the possession of each sample, or other evidence, from the moment of collection to its introduction into evidence.
3.2 Sample Custody A sample or other physical evidence is in custody if:

• It is in the actual possession of an investigator;
• It is in the view of an investigator, after being in their physical possession;
• It was in the physical possession of an investigator and then they secured it to prevent tampering; and/or
• It is placed in a designated secure area. 3.3 Documentation of Chain-of-Custody The following are used to identify and demonstrate how sample integrity is maintained and custody is ensured. Sample Identification A stick-on sample label or a tag should be completed for each sample container using waterproof, non-erasable ink as specified in Section 2.2.1. Sample Seals If appropriate, samples should be sealed as soon as possible following collection
using a custody seal with EPA identification. The sample custodian or project leader will write the date and their initials on the seal. The use of custody seals may be waived if field investigators keep the samples in their custody as defined in Section 3.2, from the time of collection until the samples are delivered to the laboratory analyzing the samples. Field Sample Custodian The field sample custodian is the person designated by the project leader to receive and manage custody of samples while in the field, including labeling and custody sealing.

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Chain-of-Custody Record The field Chain-Of-Custody record is used to document the custody of all samples or other physical evidence collected and maintained by investigators. All physical
evidence or samples will be accompanied by a Chain-Of-Custody Record. This form may be generated by sample custody management software (Section 5) or it
may be a pre-printed multi-sheet carbonless form for hand entry of required information. The Chain-Of-Custody Record documents transfer of custody of samples from the sample custodian to another person, to the laboratory or other organizational elements. The Chain-of-Custody Record will not be used to document the collection of split samples where there is a legal requirement to
provide a receipt for samples (see Section 4, Receipt for Samples Form (CERCLA/RCRA/TSCA)). The Chain-Of-Custody Record also serves as a sample
logging mechanism for the laboratory sample custodian. A separate Chain-of-Custody Record should be used for each final destination or laboratory used during
the investigation.
All information necessary to fully and completely document the sample collection and required analyses must be recorded in the appropriate spaces to complete the field Chain-Of-Custody Record. The following requirements apply to Chain-Of-Custody records generated by either sample custody management software or by hand entry on pre-printed forms:
• All sampling team leaders must sign in the designated signature block.

• One sample should be entered on each line and not be split among multiple lines.

• If multiple sampling teams are collecting samples, the sampling team
leader's name should be clearly indicated for each sample.
• The total number of sample containers for each sample must be listed in the
appropriate column. Required analyses should be entered in the appropriate location on the Chain-of-Custody Record.

• The field sample custodian, project leader or other designee, and subsequent transferee(s) should document the transfer of the samples listed on the Chain-of-Custody Record. Both the person relinquishing the samples and the person receiving them must sign the form. The date and time that this
occurs should be documented in the proper space on the Chain-of-Custody Record. The exception to this requirement would be when packaged
samples are shipped with a common carrier. Even though the common carrier accepts the samples for shipment, they do not sign the Chain-of-
Custody Record as having received the samples.
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• The last person receiving the samples or evidence will be the laboratory sample custodian or their designee(s).
The Chain-of-Custody Record is a uniquely identified document. Once the Record
is completed, it becomes an accountable document and must be maintained in the project file. The suitability of any other form for chain-of-custody should be
evaluated based upon its inclusion of all of the above information in a legible format.
If chain-of-custody is required for documents received during investigations, the documents should be placed in large envelopes, and the contents should be noted on the envelope. The envelope will be sealed and an EPA custody seal placed on the envelope such that it cannot be opened without breaking the seal. A Chain-Of-Custody Record will be maintained for the envelope. Any time the EPA seal is broken, that fact will be noted on the Chain-Of-Custody Record and a new seal
affixed, as previously described in this section.
Physical evidence such as video tapes or other small items will be placed in an evidence bag or envelope and an EPA custody seal should be affixed so that they
cannot be opened without breaking the seal. A Chain-Of-Custody Record will be maintained for these items. Any time the EPA seal is broken, that fact will be noted
on the Chain-of-Custody Record and a new seal affixed. EPA custody seals can be used to maintain custody of other items when necessary by using similar procedures as those previously outlined in this section.
Samples should not be accepted from other sources unless the sample collection procedures used are known to be acceptable, can be documented and the sample
chain-of-custody can be established. If such samples are accepted, a standard sample label containing all relevant information and the Chain-Of-Custody Record
will be completed for each set of samples.
3.4 Transfer of Custody with Shipment Transfer of custody is accomplished by the following:

• Samples will be properly packaged for shipment in accordance with the procedures
outlined in SESD Operating Procedure for Packing, Marking, Labeling and Shipping of Environmental and Waste Samples (SESDPROC-209).

• All samples will be accompanied by the laboratory copy of the Chain-Of-Custody Record. If pre-printed forms are used, the white and pink sheets will be sent. If
sample custody management software is used to generate the Chain-Of-Custody Record, the laboratory copy is identified with an “L” in the upper right corner. If
multiple coolers are needed for shipment to a particular laboratory, the laboratory
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copy of the Chain-Of-Custody Record for the entire shipment is placed in a sealed
plastic bag in one of the coolers. When shipping samples via common carrier, the "Relinquished By" box should be filled in; however, the "Received By" box should be left blank. The laboratory sample custodian is responsible for receiving custody
of the samples and will fill in the "Received By" section of the Chain-of-Custody Record. One copy of the Record will be provided to and retained by the project
leader. After samples have been received and accepted by the laboratory, a copy of the Chain-of-Custody Record, with ASB sample identification numbers, will be
transmitted to the project leader. This copy will become a part of the project file.
• If sent by mail, the package will be registered with return receipt requested. If sent by common carrier, an Air Bill should be used. The Air Bill number, shipment tracking number or registered mail serial number will be recorded in the remarks section of the Chain-Of-Custody Record.
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4 Receipt for Samples Form (CERCLA/RCRA/TSCA)
4.1 Introduction
Section 3007 of the Resource Conservation and Recovery Act (RCRA) of 1976 and Section
104 of the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA or Superfund) of 1980 require that a "receipt" for all facility samples collected during inspections and investigations be given to the owner/operator of each facility before
the field investigator departs the premises. The Toxic Substances Control Act (TSCA)
contains similar provisions. The laws do not require that homeowners or other off-site
property owners be given this form.
4.2 Receipt for Samples Form
If necessary, a Receipt for Samples form, using either the pre-printed form or one generated
by sample custody management software, is to be used to satisfy the receipt for samples
provisions of RCRA, CERCLA and TSCA. The form also documents that split samples were offered and either "Received" or "Declined" by the owner/operator of the facility or
site being investigated (if a sample is split with a facility, state regulatory agency or other
party representative, the recipient should be provided (if enough sample is available) with
an equal weight or volume of sample). All information must be supplied in the indicated
spaces to complete the Receipt for Samples form.
• The sampler(s) must sign the form in the indicated location

• Each sample collected from the facility or site must be documented in the sample record portion of the form. The sample station number, date and time of sample
collection, composite or grab sample designation, whether or not split samples were
collected (yes or no should be entered under the split sample column), a brief
description of each sampling location and the total number of sample containers for each sample must be entered.
• The bottom of the form is used to document the site operator's acceptance or
rejection of split samples. The project leader must sign and complete the
information in the "Split Samples Transferred By" section (date and time must be entered). If split samples were not collected, the project leader should initial and place a single line through "Split Samples Transferred By" in this section. The
operator of the site must indicate whether split samples were received or declined
and sign the form. The operator must give their title, telephone number and the date and time they signed the form. If the operator refuses to sign the form, the sampler(s) should note this fact in the operator's signature block and initial this
entry.

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The Receipt for Samples form is an accountable document after it is completed. A copy
of the form is to be given to the facility or site owner/operator. The original form must be
maintained in the project files.
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5 Sample Custody Management Software
The container labels and the Chain-of-Custody record should be generated using a sample
custody management software to streamline the documentation required by SESD and/or
the Contract Laboratory Program (CLP) for sample identification and chain-of-custody.
When possible, the sample custody management software should be used during all field
investigations. Once the appropriate information is entered into the computer, the software will generate stick-on labels for the sample containers and will generate sample receipt
forms and chain-of-custody records for the appropriate laboratory. The advantages to this
system include faster processing of samples and increased accuracy. Accuracy is increased
because the information is entered only once, and consequently, consistent for the bottle
labels, sample receipt forms and chain-of-custody records. .

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Logbooks
SESDPROC-1002-R0
Effective Date: October 1, 2017
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Region 4
U.S. Environmental Protection Agency
Science and Ecosystem Support Division
Athens, Georgia
Operating Procedure
Title: Logbooks ID: SESDPROC-1002-R0
Issuing Authority: Deputy Director, SESD
Effective Date: October 1, 2017
Purpose
This procedure is specific to the Region 4 Science and Ecosystem Support Division (SESD) to
maintain conformance to technical and quality system requirements. This procedure defines the
process for documenting direct observations in logbooks or other record formats related to
laboratory analyses, field investigations, or assessments of field sampling processes and laboratory
operations of external entities.
Scope/Application
The requirements of this procedure apply to all personnel who perform work under SESD’s quality
system. This procedure contains requirements for documenting activities related to laboratory
analyses, field investigations, or assessments of field sampling processes and laboratory operations of external entities and serves as a supplement to the overarching requirements for SESD records,
outlined in the SESD Operating Procedure for Control of Records (SESDPROC-1001). While this
SOP may be informative, it is not intended for and may not be directly applicable to operations in
other organizations. Mention of trade names or commercial products in this operating procedure
does not constitute endorsement or recommendation for use.
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Table of Contents
1.0 Procedure ............................................................................................................................ 3
1.1 General Requirements ................................................................................................... 3
1.2 Laboratory Logbooks .................................................................................................... 4
1.2.1 Instrument Maintenance Logbooks ........................................................................... 4
1.2.2 Instrument Logbooks .................................................................................................. 4
1.2.3 Preparation Logbooks ................................................................................................. 4
1.2.4 Analysis Logbooks ....................................................................................................... 5
1.2.5 Laboratory Equipment Logbooks .............................................................................. 5
1.3 Field Operation Logbooks ............................................................................................. 6
1.3.1 General Information Required in All Field Operations Logbooks .................... 6
1.3.2 Information Required for Sample Collection....................................................... 6
1.3.3 Information Required for Field Measurements ................................................... 7
1.3.4 Additional Information for Inclusion in Field Activity Logbooks ........................... 8
1.4 Quality Assurance Field Documentation ..................................................................... 8
1.5 Other Logbooks and Documentation ........................................................................... 8
2.0 Definitions ........................................................................................................................... 9
3.0 Related Documents and Forms ......................................................................................... 9
4.0 References ........................................................................................................................... 9
5.0 Revision History ............................................................................................................... 10

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1.0 Procedure

1.1 General Requirements
General requirements for SESD logbook or other record format entries related to laboratory
analyses, field investigations, or assessments of field sampling processes and laboratory
operations of external entities:
1. Observations, data and calculations will be recorded at the time they are made.
2. Dedicated bound logbooks will be used.
3. Entries will be legible, containing pertinent, accurate, and inclusive documentation of
project activities, free of personal feelings or other terminology which might prove inappropriate.
4. Unless prohibited by environmental conditions, pens with permanent ink will be used to
record all data. When environmental conditions do not make it feasible to use permanent
ink, entries should be made using a non-smear lead pencil (e.g., 2H or 3H). Upon returning
from the field, the project leader will photocopy the penciled section of the logbook and certify, in writing, that the photocopied record is a true copy of the original logbook entry.
The photocopy will be included in the project file.
5. Entries in logbooks shall be dated and signed or initialed by staff.
6. Data or other information that has been entered incorrectly shall only be corrected using a
single strike-through, date and initials of the person making the correction. Under no circumstances should the incorrect material be erased, made illegible or obscured so that it
cannot be read.
7. To demonstrate continuity of the work and maintain the integrity of the data collection
process, pages should not be removed from any bound logbook.
8. Blank pages or spaces should not be present in logbooks. Blank areas should be lined through and initialed and dated to prevent the opportunity for back-filling.
9. Logbook pages and books shall be numbered. The numbering format will consist of “page
x of y”, where “x” is the current page number and “y” is the total number of pages of the
logbook.
10. To facilitate accurate and complete documentation of activities, SESD-generated forms may be used. In order to be utilized, SESD-generated forms must be bound prior to use
and adhere to all requirements outlined in this procedure. In cases where unbound
pages/forms are necessary due to project requirements or practicality, the appropriate
Section Chief and System Manager will determine the best course of action.
11. If pre-printed adhesive labels are used in logbooks or bound forms to facilitate organization of information entry, the SESD staff responsible for taking notes will sign the label with
the signature beginning on the label and ending on the page of the logbook such that the
label cannot be removed without detection.
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1.2 Laboratory Logbooks
The following are requirements for laboratory logbooks, in addition to those established in
Section 1.1. Each sample preparation, analysis or equipment check is maintained using logbooks in the appropriate laboratory. Active logbooks are maintained within the laboratory where the instrument or equipment is located and should be maintained with the instrument
throughout its useful life. At such time the instrument is removed from service, the logbook
is transferred with the appropriate form to the LQM, and then to the SESD Records Room.

1.2.1 Instrument Maintenance Logbooks
Each major instrument shall have a maintenance logbook. At a minimum the
following information will be included:

1. Instrument serial number 2. Instrument’s unique name
3. Software version
4. In-service date (if known)

In addition, maintenance, service and repair records are maintained in these logbooks. Preventive maintenance schedules should be noted in the log, or in a
separate maintenance log. When a service or maintenance call is completed by
the vendor, the analyst should place a copy of the documentation or transcribe the
details for the work that was performed on the instrument in the logbook. The
original work order invoice should be provided to the Office of Program Support for payment. Instrument Maintenance logbooks are purchased as bound record
books that contain pre-numbered pages. The numbering convention does not
account for the number of pages per book.

1.2.2 Instrument Logbooks
Instrument logs shall include:

1. Instrument serial number 2. Date of analysis 3. Analyst and samples which have been analyzed
4. A reference or a record of which options or analytical conditions were
used for analysis
5. Where appropriate, instrument acceptance criteria (e.g., tune criteria, sensitivity checks)
1.2.3 Preparation Logbooks

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Preparation logs shall document all information to reconstruct the preparation of samples, reagents, and standards, and should include, but not limited to:

1. Analyst’s name
2. Weights 3. Volumes 4. Lot number of digestion tubes
5. ID of any preparation equipment used
6. Certification dates of equipment, if applicable
7. Reagents/standards used 8. Preservation checks 9. Units
10. Any cleanup procedures used
11. Project Number/Name and Workorder Number will be included on each
page. Electronic traceability via Element® is an acceptable option for documenting
standard preparation. If Element® is used as the standard prep log, it is subject to
all the requirements of this section.

1.2.4 Analysis Logbooks
Electronic records, including spreadsheets which contain original measurements,
may be used to create logbooks if all the required information can be captured by
the instrumental software; however, a sequential analysis log must still be created and maintained. This is accomplished by printing a copy of the electronic record and including it in a notebook. These sequential logs must also include failed
runs, or sequences which were abandoned prior to completion. When a pre-
determined number of pages has been accumulated (e.g., 50 pages), the individual
records are combined into a single bound logbook and retained as specified in the SESD Operating Procedure for Records Management (SESDPROC-1001). Any electronic records must accurately reflect actual analytical information. For
analyses with holding times < 72 hours, or when time-critical or method-specified
times are included in the analysis, the time of analysis must also be recorded.

1.2.5 Laboratory Equipment Logbooks
Equipment Logbooks, such as balance logs, are maintained in the lab in close
proximity to the equipment. At a minimum the following information must be
included: 1. Equipment serial number
2. Equipment unique name
3. Vendor name
4. In-service date (if known)
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In addition, calibration check, maintenance, service and repair information may
also be recorded and/or maintained in the logbook.

1.3 Field Operation Logbooks The following are requirements for field logbooks, in addition to those established in Section
1.1
1.3.1 General Information Required in All Field Operations Logbooks
The following information shall be included either on the front cover or the first page of all field logbooks:

1. Project name
2. Project location 3. Project identification number 4. Project leader (full name)
5. Sample team leader (full name) and initials
6. Sample team member(s) (full names) and initials
In addition, the project’s unique identifier (unique identification number(s)) will be included on each page.

Any deviations from the quality assurance project plan (QAPP) that occur while in
the field shall be noted in the logbook(s). Field logbook entries that may be considered privileged or confidential information shall be handled in accordance with the relevant sections of SESD Operating Procedure for Control of Records
(SESDPROC-1001). The logbooks will be placed in the SESD project file upon
transmittal of the final report to the project requestor.

1.3.2 Information Required for Sample Collection
In addition to previously listed requirements, the following information will be
included in all field logbooks when samples are collected:
1. Applicable SESD Operating Procedures for field sampling. 2. Date and time of collection.
3. Station identification, including GPS coordinates (non-logging GPS
units), if applicable.
4. Sample identification. 5. Method of collection. 6. Number and type of containers (describe, as needed).
7. Sample collection equipment.
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8. SESD equipment identification number, if applicable. 9. Matrix sampled.
10. Physical description of sample.
11. Sample team member duties (calibration, collection, deployment, etc.).
12. Sample preservation method (e.g., indirect contact with ice), if applicable. 13. Environmental conditions such as rain, wind, smoke, dust, extreme
temperature, etc., which may adversely impact quality of samples, if
applicable.
14. Location of electronic data file backups, if applicable. 15. Monitoring of condition of ice in coolers or sampler, if applicable. 16. Date and time of sample arrival to SESD. Storage room for samples,
even if it is for initial, temporary purposes.
17. Sample team member duties (e.g., calibration, equipment deployment,
collection, sample preservation, sample preservation monitoring, etc.). 18. Other pertinent information.

1.3.3 Information Required for Field Measurements

In addition to previously listed requirements, the following information will be included in all logbooks when measurements are conducted:
1. Applicable SESD Operating Procedures for field measurement.
2. Date and time of measurement or instrument/equipment deployment.
3. Sample identification, if appropriate. 4. Station identification, including GPS coordinates (non-logging GPS units), if applicable.
5. Sample measurement equipment.
6. SESD sample measurement equipment identification number.
7. Manufacturer name, lot number and expiration date of all pH buffers and chemical standards.* 8. Calibration information, including before and after calibration
readings.*
9. Meter and check information.
10. Equipment deployment depth and total depth, if applicable. 11. Pinger identification number and frequency for deployed equipment, if applicable.
12. Date and time of retrieval for deployed equipment, if applicable.
13. Matrix measured.
14. Physical description of matrix. 15. Measurement values for non-logging equipment. 16. Ambient air temperature, where applicable.
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17. Environmental conditions that may adversely impact quality of measurement (e.g., rain, wind, smoke, dust, extreme temperatures), if
applicable.
18. Equipment or instrument maintenance performed, if applicable.
19. Meter malfunctions, troubleshooting efforts and final status, if applicable. 20. Location of electronic data file backups, if applicable.
21. Measurement team member duties (e.g., calibration, equipment
deployment, measurement, maintenance, troubleshooting, etc.).
22. Other pertinent information. * Entry of calibration information in logbooks is only required for
calibrations conducted in the field. All calibrations conducted at the SESD
Field Equipment Center or laboratory will be recorded in the appropriate
equipment tracking logbook.

1.3.4 Additional Information for Inclusion in Field Activity Logbooks

The following visual information may be included in field logbooks, as appropriate:
1. Maps/sketches. 2. Photographic or video-graphic log.
3. Process diagrams.

1.4 Quality Assurance Field Documentation The following are requirements for Quality Assurance (QA) field documentation, in
addition to those established in Section 1.1. The following information shall be included
either on the front cover or the first page of all QA field documentation:
1. Audit/facility name 2. Audit/facility location
3. Audit leader
4. Audit team members
5. Audit dates 6. Audit Identification Number
In addition to logbooks, QA uses checklists to document audits of methods and
procedures during the onsite evaluation of laboratories and facilities. These checklists
are printed and/or used electronically to document field observations. These electronic checklists are located on the SESD LAN and updated periodically as changes are needed.
1.5 Other Logbooks and Documentation
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Some methods and measurements do not use instrumentation to generate a result. For these
methods, SESD relies on spreadsheets or other calculating software for
recording/documenting original observations made (e.g., weights). All spreadsheets or
other calculating software used as logbooks or used in support of data generation will be validated and controlled. All cells, except informational input cells, will be locked to prevent alteration of a formula or essential static information, such as the unique identifier.
All calculations in electronic spreadsheets and calculating software files will be
hand-validated by the responsible party and submitted through the Section Chief to the
appropriate System Manager for approval and posting. The entire spreadsheet or software-generated electronic file will be password protected, which will be assigned by the System Manager at the time of posting on the LAN.

2.0 Definitions
None

3.0 Related Documents and Forms

U.S. EPA, Region 4, SESD, Analytical Services Branch, Logbook Transfer Form.

4.0 References

U.S. EPA, Region 4, SESD, SESD Field Branches Quality Management Plan, SESDPLAN-001, most recent version.

U.S. EPA, Region 4, SESD, ASB, Laboratory Operations and Quality Assurance Manual, most
recent version.
U.S. EPA, Region 4, SESD, Records Management Standard Operating Procedures, most recent
version.

U.S. EPA, Region 4, SESD, Quality Management Plan, most recent version.
U.S. EPA, Region 4, SESD, SESD Operating Procedure for Control of Records, SESDPROC-002,
most recent version.

ISO/IEC 17025: General Testing for the Competence of Testing and Calibration Laboratories, 2nd
Ed., 2005, 05/15/2015, Switzerland.
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ANAB, ISO/IEC 17025: Accreditation Requirements for Forensic Testing Laboratories, pp. 49, Document Number MA 3011, Effective Date: 02/02/2015.

5.0 Revision History

This table shows changes to this controlled document over time. The most recent version is
presented in the top row of the table. Previous versions of the document are maintained by the SESD Document Control Coordinator.

History Effective Date

SESDPROC-1002-R0, Logbooks, Original Issue

October 1, 2017

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LSASDPROC-202-R4 Management of Investigated Derived Waste Effective Date: May 8, 2020
______________________________________________________________________________________ Page 1 of 8

Purpose
This document describes general and specific procedures and considerations to be used and observed when managing investigation derived waste (IDW) generated during the course of hazardous waste site investigations. Scope/Application The procedures and management options for the different categories of IDW described in this document are to be used by LSASD field personnel to manage IDW generated during site investigations. On the occasion that LSASD field personnel determine that any of the procedures described in this section are inappropriate, inadequate or impractical and
that another procedure must be used to manage IDW generated at a particular site, the variant procedure will be documented in the field logbook, along with a description of the circumstances requiring its use. Mention of trade names or commercial products does not constitute endorsement or recommendation for use.

Region 4 U.S. Environmental Protection Agency Laboratory Services and Applied Science Division Athens, Georgia
Operating Procedure
Title: Management of Investigation Derived Waste ID: LSASDPROC-202-R4
Issuing Authority: LSASD Field Branch Chief
Effective Date: May 8, 2020 Review Date: May 8, 2024
LSASDPROC-202-R4 Management of Investigated Derived Waste Effective Date: May 8, 2020
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TABLE OF CONTENTS
Purpose ............................................................................................................................ 1 Scope/Application ........................................................................................................... 1 1 General Information .................................................................................................... 3 1.1 Documentation/Verification ................................................................................. 3
1.2 General Precautions.............................................................................................. 3
1.2.1 Safety ................................................................................................................. 3 1.2.2 Procedural Precautions....................................................................................... 3 2 Types of Investigation Derived Waste ........................................................................ 3 3 Management of Non-Hazardous IDW ........................................................................ 4
4 Management of Hazardous IDW ................................................................................ 5
5 References ................................................................................................................... 6 TABLES

Table 1: Disposal of IDW .................................................................................................. 8

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1 General Information

1.1 Documentation/Verification This procedure was prepared by persons deemed technically competent by LSASD management, based on their knowledge, skills and abilities and have been tested in practice and reviewed in print by a subject matter expert. The official copy of this procedure resides
on the LSASD Local Area Network (LAN). The Document Control Coordinator (DCC)
is responsible for ensuring the most recent version of the procedure is placed on the LAN and for maintaining records of review conducted prior to its issuance. 1.2 General Precautions
1.2.1 Safety Proper safety precautions must be observed when managing IDW. Refer to the LSASD Safety, Health and Environmental Management Program (SHEMP)
Procedures and Policy Manual and any pertinent site-specific Health and Safety
Plans (HASP) for guidelines on safety precautions. These guidelines, however, should only be used to complement the judgment of an experienced professional. Address chemicals that pose specific toxicity or safety concerns and follow any other relevant requirements, as appropriate.
1.2.2 Procedural Precautions The following precautions should be considered when managing IDW:
• Due to time limitations and restrictions posed by RCRA regulations on storage of hazardous waste, accumulation start dates should be identified on all drums, buckets or other containers used to hold IDW so that it can be managed in a timely manner.
• During generation of both non-hazardous and hazardous IDW, keep hazardous IDW segregated from non-hazardous IDW to minimize the volume of hazardous IDW that must be properly managed. 2 Types of Investigation Derived Waste

Materials which may become IDW include, but are not limited to:

• Personal protective equipment (PPE) - This includes disposable coveralls, gloves, booties, respirator canisters, splash suits, etc.
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• Disposable equipment and items - This includes plastic ground and equipment covers, aluminum foil, conduit pipe, composite liquid waste samplers (COLIWASAs), Teflon® tubing, broken or unused sample containers, sample container boxes, tape, etc.
• Soil cuttings from drilling or hand augering.
• Drilling mud or water used for mud or water rotary drilling.
• Groundwater obtained through well development or well purging.
• Cleaning fluids such as spent solvents and wash water.
• Packing and shipping materials. Table 1, found at the end of this procedure, lists the types of IDW commonly generated during field investigations and the current disposal practices for these materials. For the purpose of determining the ultimate disposition of IDW, it is typically distinguished as being either hazardous or non-hazardous. This determination is based on either clear
regulatory guidance or by subsequent analysis. This determination and subsequent
management is the responsibility of the program site manager. 3 Management of Non-Hazardous IDW
Disposal of non-hazardous IDW should be addressed in the Sampling and Analysis Plan (SAP) or QAPP for the investigation. To reduce the volume of any IDW transported back to the Field Equipment Center (FEC), it may be necessary to compact the waste into a reusable container, such as a 55-gallon drum.

If the waste is from an active facility, permission should be sought from the operator of the facility to place the non-hazardous PPE, disposable equipment, and/or paper/cardboard into the facility’s dumpsters. If necessary, these materials may be placed into municipal dumpsters, with the permission of the owner. These materials may also be taken to a nearby
permitted landfill. On larger studies, waste hauling services may be obtained and a
dumpster located at the study site. Disposal of non-hazardous IDW such as drill cuttings, drilling mud, purge or development
water, decontamination wash water, etc., should be specified in the approved SAP or
QAPP. It is recommended that these materials be placed into a unit with an environmental permit, such as a landfill or sanitary sewer. These materials must not be placed into dumpsters. If the facility at which the study is being conducted is active, permission should be sought to place these types of IDW into the facility’s treatment system. It may be
feasible to spread drill cuttings around the borehole, or, if the well is temporary, to place
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the cuttings back into the borehole. Non-hazardous monitoring well purge or development water may also be poured onto the ground down gradient of the monitoring well when site conditions permit. Purge water from private potable wells which are in service may be discharged directly onto the ground surface.
The minimum requirements for this subsection are:
• Non-hazardous liquid and soil/sediment IDW may be placed on the ground or returned to the source if doing so does not endanger human health or the environment or violate federal or state regulations. Under no circumstances, however, should monitoring well purge water be placed back into the well from which it came.
• Soap and water decontamination fluids and rinses of such cannot be placed in any water bodies and must be collected and returned to the FEC for disposition.
• The collection, handling and proposed disposal method must be specified in the approved SAP or QAPP. 4 Management of Hazardous IDW Disposal of hazardous or suspected hazardous IDW must be specified in the approved SAP or QAPP for the study or investigation. Hazardous IDW must be disposed as specified in USEPA regulations. If appropriate, these wastes may be placed back in an active facility waste treatment system. These wastes may also be disposed in the source area from which they originated if doing so does not endanger human health or the environment. If on-site disposal is not feasible, and if the wastes are suspected to be hazardous, appropriate tests must be conducted to make that determination. If they are determined to be hazardous wastes, they must be properly contained and labeled. They may be stored on the site for a maximum of 90 days before they must be manifested and shipped to a permitted treatment or disposal facility. Generation of hazardous IDW must be anticipated, if possible, to allow arrangements for proper containerization, labeling, transportation and disposal/treatment in accordance with USEPA regulations. The generation of hazardous IDW should be minimized to conserve Division resources. Most routine studies should not produce any hazardous IDW, with the possible exception of spent solvents and, possibly, purged groundwater. The use of solvents during field cleaning of equipment should be minimized by using solvent-free cleaning procedures for routine cleaning and decontamination (see SESD Operating Procedure for Field Equipment Cleaning and Decontamination, SESDPROC-205). If solvents are needed, the volume should be minimized by using only the amount necessary and by capturing the residual solvent separately from the aqueous decontamination fluids (detergent/wash water mixes and water rinses). At a minimum, the requirements of the management of hazardous IDW are as follows:
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• Spent solvents must be left on-site with the permission of site operator and proper disposal arranged.
• All hazardous IDW must be containerized. Proper handling and disposal should be arranged prior to commencement of field activities. 5 References LSASD Operating Procedure for Field Equipment Cleaning and Decontamination, LSASDPROC-205, Most Recent Version

United States Environmental Protection Agency (US EPA). 2001. Environmental Investigations Standard Operating Procedures and Quality Assurance Manual. Region 4 Science and Ecosystem Support Division (SESD), Athens, GA
US EPA. Safety, Health and Environmental Management Program Procedures and Policy
Manual. Region 4 SESD, Athens, GA, Most Recent Version
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6 Revision History The top row of this table shows the most recent changes to this controlled document. For previous revision history information, archived versions of this document are maintained by the SESD Document Control Coordinator on the SESD local area network (LAN).
History Effective Date
LSASDPROC-202-R4, Management of Investigation Derived Waste, replaces SESDPROC-202-R3
General: Corrected typographical, grammatical and/or editorial errors.
Updated format and naming convention, updated references from SESD to LSASD and FSB to LSB.
May 8, 2020
SESDPROC-202-R3, Management of Investigation Derived Waste, replaces SESDPROC-202-R2. General: Corrected typographical, grammatical and/or editorial errors. Cover Page: The Enforcement and Investigations Branch Chief was
changed from Archie Lee to Acting Chief John Deatrick. The Ecological Assessment Branch Chief was changed from Bill Cosgrove to Acting
Chief Mike Bowden. The FQM was changed from Liza Montalvo to Bobby Lewis. Revision History: Changes were made to reflect the current practice of
only including the most recent changes in the revision history.
July 3, 2014
SESDPROC-202-R2, Management of Investigation Derived Waste, replaces SESDPROC-202-R1.

October 15, 2010
SESDPROC-202-R1, Management of Investigation Derived
Waste, replaces SESDPROC-202-R0. November 1, 2007

SESDPROC-202-R0, Management of Investigation Derived Waste, Original Issue

February 05, 2007

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Table 1: Disposal of IDW
TYPE HAZARDOUS NON - HAZARDOUS
PPE-Disposable Containerize in plastic 5-gallon bucket with tight-fitting lid. Identify and leave on-site with permission of site operator, otherwise return to FEC for proper disposal.
Place waste in trash bag. Place in dumpster with permission of site operator, otherwise return to FEC for disposal in dumpster.
PPE-Reusable Decontaminate as per SESD Operating Procedure for Field Equipment Cleaning and Decontamination, SESDPROC-205, if possible. If the equipment cannot be decontaminated, containerize in plastic 5-gallon bucket with tight-fitting lid. Identify and leave on-site with permission of site operator, otherwise return to FEC for proper disposal.
Decontaminate as per SESDPROC-205, and return to FEC.
Spent Solvents Containerize in original containers. Clearly identify contents. Leave on-site with permission of site operator and arrange for proper disposal.
N/A
Soil Cuttings Containerize in DOT-approved container with tight-fitting lid. Identify and leave on-site with permission of site operator, otherwise arrange with program site manager for testing and disposal.
Containerize in a 55-gallon steel drum with tight-fitting lid. Identify and leave on-site with permission of site operator, otherwise arrange with program site manager for testing and disposal. **
Groundwater Containerize in DOT-approved container with tight-fitting lid. Identify and leave on-site with permission of site operator, otherwise arrange with program site manager for testing and disposal.
Containerize in an appropriate container with tight-fitting lid. Identify and leave on-site with permission of site operator, otherwise arrange with program site manager for testing and disposal. ** Decontamination Water Containerize in DOT-approved container with tight-fitting lid. Identify and leave on-site with permission of site operator, otherwise arrange with program site manager for testing and disposal.
Containerize in an appropriate container with tight-fitting lid. Identify and leave on-site with permission of site operator, otherwise arrange with program site manager for testing and disposal. Decontamination water may also be disposed in a sanitary sewer system, with permission from the wastewater treatment plant representative, and if doing so does not endanger human health or the environment, or violate federal or state regulations.
Disposable Equipment Containerize in DOT-approved container or 5-gallon plastic bucket with tight-fitting lid. Identify and leave on-site with permission of site operator, otherwise arrange with program site manager for testing and disposal.
Containerize in an appropriate container with tight-fitting lid. Identify and leave on-site with permission of site operator, otherwise arrange with program site manager for testing and disposal. If unfeasible, return to FEC for disposal in dumpster.
Trash N/A Place waste in trash bag. Place in dumpster with permission of site operator, otherwise return to FEC for disposal in dumpster.
** These materials may be placed on the ground if doing so does not endanger human health or the environment or violate federal or state regulations.
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Revision History

The table below shows changes to this controlled document over time. The most recent version
is presented in the top row of the table and replaces the previous version. Previous versions
of the document are maintained by the EPA Region 4 Superfund and Emergency Management
Division (SEMD) Document Control Coordinator.

History Effective Date
SEMDPROC-009-R0, Environmental Data Submission
General: Corrected any typographical, grammatical, and/or
editorial errors. Throughout the document certain terms were
replaced with their appropriate acronyms. Updated workflow
components.
Section 2.4 and Table 2-1: Updated list of which EDD files are
required based on the type of field activity.
Section 5: New section detailing information required in
Geographic Information System (GIS) submittals
January 9, 2020
SDPROC- SFDPROC-009-R0, Environmental Data Submission January 27, 2017
SESDGUID-106-R0, Environmental Data Submission December 17, 2010

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TABLE OF CONTENTS
1 General Information .............................................................................................................. 5
1.1 Purpose ............................................................................................................................... 5
1.2 Scope/Application ............................................................................................................... 5
1.3 Documentation/Verification ............................................................................................... 5
1.4 Acronyms ............................................................................................................................ 5
1.5 Definitions ........................................................................................................................... 6
1.6 Supporting Reference Documents ...................................................................................... 9
2 Introduction ......................................................................................................................... 10
2.1 Data Sources ..................................................................................................................... 10
2.2 Overview ........................................................................................................................... 10
2.3 EDP Standalone ................................................................................................................. 11
2.3.1 Obtaining EDP Standalone ............................................................................................ 11
2.3.2 Using EDP Standalone ................................................................................................... 11
2.3.3 Valid Values in EDP ....................................................................................................... 12
2.3.4 Data Package ................................................................................................................. 12
2.4 Information Required in EQuIS EDDs ................................................................................ 12
2.5 Common Fields in EDDs .................................................................................................... 14
2.5.1 Data Provider Codes (sampling_company) ................................................................... 14
2.5.2 Project IDs (task_code) ................................................................................................. 14
2.5.3 Project Numbers (task_code2) ..................................................................................... 14
2.5.4 Program/Activity Codes (task_type) ............................................................................. 14
2.5.5 Station IDs (sys_loc_code) ............................................................................................ 15
3 EPA Lead Data Submittals ................................................................................................... 16
3.1 EPA Lead Projects .............................................................................................................. 16
3.2 Software Requirements .................................................................................................... 16
3.2.1 Collect, EDGE, or Scribe ................................................................................................ 16
3.2.2 EQuIS Data Processor .................................................................................................... 16
3.3 Create Site or Waterbody ................................................................................................. 17
3.3.1 Site Creation .................................................................................................................. 17
3.3.2 Waterbody Creation ..................................................................................................... 17
3.3.3 Criminal and Enforcement Confidential ....................................................................... 18
3.4 Project Creation (Project ID) ............................................................................................. 18
3.5 Chain of Custody ............................................................................................................... 19
3.6 DART Reports .................................................................................................................... 19
3.6.1 Sample Information Requests....................................................................................... 19
3.6.2 EDD Requests ................................................................................................................ 20
3.6.3 ‘Overdue’ Reports ......................................................................................................... 20
3.7 Creating EDDs ................................................................................................................... 21
3.7.1 Location EDDs ............................................................................................................... 21
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3.7.2 Field Results EDDs ......................................................................................................... 21
3.7.3 Water Level EDDs .......................................................................................................... 21
3.7.4 Geology EDDs ................................................................................................................ 21
3.7.5 Analytical Data EDDs ..................................................................................................... 21
3.8 Error Checking with EQuIS Data Processor ....................................................................... 22
3.9 Submitting EDDs ............................................................................................................... 22
3.10 Proofing and Corrections .................................................................................................. 23
4 PRP Lead Data Submittals ................................................................................................... 24
4.1 PRP Lead Projects .............................................................................................................. 24
4.2 Software Requirements .................................................................................................... 24
4.3 Site Creation ...................................................................................................................... 24
4.4 Project Creation (Project ID) ............................................................................................. 24
4.5 Data Submittal Summary .................................................................................................. 25
4.6 DART Reports .................................................................................................................... 25
4.6.1 Location EDD Request ................................................................................................... 25
4.6.2 Other EDD Requests ...................................................................................................... 26
4.7 Creating EDDs ................................................................................................................... 26
4.8 EQuIS Data Processor ........................................................................................................ 26
4.9 Submitting EDDs ............................................................................................................... 26
4.10 Proofing and Corrections .................................................................................................. 27
5 Information Required in GIS Submittals ............................................................................. 29

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1 General Information
1.1 Purpose
This document describes the methods to be used in submitting environmental data
electronically to the United States Environmental Protection Agency (the EPA) Region 4
Superfund and Emergency Management Division (SEMD) personnel and their contractors as
well as other EPA personnel working on the EPA Region 4 Superfund Program sites and/or
projects. These methods occur during field activities that result in creating, handling, and
managing field documentation and resulting in the creation of environmental data to be
submitted to the EPA Region 4 data management system. The goal of this SOP for
environmental data submission is to guide the EPA Region 4 SEMD personnel and contractors
to submit the appropriate required electronic data.
1.2 Scope/Application
The methods described in this document are to be used by all data providers when preparing
and submitting environmental data electronically to the EPA Region 4, regardless of the
originating program. The enforcement of such methods is supported by the SEMD Director’s
Memo “Region 4 Data Management and Electronic Data Deliverables” that may be found at:
http://www2.epa.gov/sites/production/files/2015-09/documents/ddeddmemo.pdf

This document does not cover the use of DART, EQuIS™ Professional, or creating maps and
reports. Extensive documentation on the use of EQuIS Professional and EQuIS Enterprise can be
found at: https://help.earthsoft.com.
1.3 Documentation/Verification
This procedure was prepared by persons deemed technically competent by the EPA Region 4
SEMD personnel, based on their knowledge, skills and abilities, and has been tested in practice
and reviewed in print by a subject matter expert. The official copy of this procedure will be
scanned into the EPA’s Superfund Enterprise Management System (SEMS) and published on
EPA’s internet. The Document Control Coordinator (DCC) is responsible for ensuring the most
recent version of the procedure is placed in SEMS and for maintaining records of review
conducted prior to its issuance.
1.4 Acronyms
CAD – Computer-Aided Drafting
CLP – Contract Laboratory Program
DART – Data Archival and ReTrieval
DCC – Document Control Coordinator
EDD – Electronic Data Deliverable
EDGE – EQuIS Data Gathering Engine
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EDP – EQuIS Data Processor
EQuIS™ – Environmental Quality Information System
EPA – United States Environmental Protection Agency
GIS – Geographic Information System
GNIS – Geographic Names Information System
GPS – Global Positioning System
LIMS – Laboratory Information Management System
LSASD – Laboratory Services and Applied Science Division
OSC – EPA’s On Scene Coordinator
NPL – National Priorities List
PRP – Potentially Responsible Party
QAPP – Quality Assurance Project Plan
R4DART – United States Environmental Protection Agency, Region 4 DART
R4LIMS – United States Environmental Protection Agency, Region 4 LIMS
RCRA – Resource Conservation and Recovery Act
RPM – Remedial Project Manager
SEMD – Superfund and Emergency Management Division
SEMS – Superfund Enterprise Management System
SMO – Sample Management Office
URL – Uniform Resource Locator
USGS – United States Geological Survey
XML – Extended Markup Language
1.5 Definitions
Activity Code (task_type) – Descriptive code for the EPA activity (RA - Remedial Action, RI –
Remedial Investigation, etc.) for which the event is required. Activity Code values are a
controlled vocabulary.

Analytical Data – Data reported by a fixed-base laboratory.

Controlled Vocabulary – See Valid Values.

Data Package – A data package is a software archive (.dat format) containing one or more
Electronic Data Deliverables.

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Data Provider – The entity responsible for the electronic submission of environmental data to
the EPA Region 4. Data providers are identified by a code value that is a controlled vocabulary.

Data Submittal Summary – A summary of the data proposed for submittal by the data provider
for the Potentially Responsible Party and fund lead projects not scheduled through R4LIMS.

Electronic Data Deliverable – An archive zip file saved with a “.dat” extension holding one or
more tab-delimited text files containing the environmental data to be submitted. An EDD file
follows a consistent design meant to organize information in a useful format and typically
contains header row(s) that describe what information should be completed in each column.

Element – LIMS system used to report LSASD and CLP analytical data.

EQuIS Collect – A user friendly, mobile field application from EarthSoft, Inc. for collecting
environmental and geotechnical data on a smart phone, tablet, or computer. EQuIS Collect uses
EDP to verify and enforce data quality in real time.

EQuIS Data Gathering Engine – Software from EarthSoft, Inc. that runs on a tablet or computer
to ensure accurate and complete field data collection events. EDGE includes EDP for live, real-
time error checking of data submissions.

EQuIS Data Processor – Software from EarthSoft, Inc. used to check the EDDs for data
completion, referential integrity, and identify and correct errors prior to submission.

EQuIS Professional – Workstation Software from EarthSoft, Inc. used by data managers that
interfaces to the EPA Region 4 database.

Esri – A software development and services company providing Geographic Information System
software.

Field Results Data – Field analytical data such as pH, dissolved oxygen, XRF, etc. These data may
be generated from EDGE, EQuIS Collect, or Scribe.

Format File – The EDP format file is the essence of data checking with EDP and contains the
definitions and restrictions for each individual field in available data tables. The format file
controls data checks, formatting, and enumerations.

Geographic Information System Data – GIS data, as they relate to the Superfund program, may
include point data (latitude/longitude), lines, and/or polygons representing some site-related
area of interest. Computer-aided drafting (CAD), image formatted files, and tabular data are
also acceptable data formats so long as they meet the requirements defined in the
EPA Region 4 Geographic Information System Deliverable Guidance.

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Geographic Names Information System – The naming system was developed by the U.S.
Geological Survey (USGS) in cooperation with the U.S. Board on Geographic Names (BGN), and
contains information about the official names for places, features, and areas in the 50 states,
District of Columbia, and territories and outlying areas of the United States, including
Antarctica.

Geology Data – Specialized data relating to geology, such as lithology, well construction, etc.

LIMS – Software for managing and reporting laboratory analyses.

Media Code (matrix_code) – A two or more character code designating the sample matrix
(i.e., SW is the media code for Surface Water). Media code values are a controlled vocabulary.

Project – A project is defined as the data generated for a report.

Project ID (task_code) – Unique ID associated with a project QAPP or for R4LIMS projects, it is
associated with a single sampling event. For R4LIMS, this value is assigned by the Project
Tracking System for the dataset being submitted. For all other project types, the R4DART will
provide this Project ID.

Project Number (task_code2) – A Project ID may have multiple Project Numbers or be the same
as the Project ID. For R4LIMS, this value is assigned by the Project Tracking System for the Chain
of Custody being submitted. For all other project types, R4DART will provide this Project
Number.

Project Tracking System – The EPA Region 4 LSASD’s project tracking system used for R4LIMS
projects.

Quality Assurance Project Plan – The controlling document for proposed field work. There may
be multiple Project ID numbers assigned to the QAPP and will be used in EDDs generated for
that project to uniquely identify the data to that event.

Reference Value File – The reference value file (RVF) is associated with the EDP format file and
is denoted with an .rvf file extension. This file contains the valid values reference tables that
EDP uses to populate the drop-down menus that control when a specific type of value is
required in an EDD. Example reference values are “mg/kg” (milligrams per kilogram) for a unit
code or “GW” (groundwater) for a media code. These fields limit the type of data permitted in
certain columns of the EDD, and the most recent valid values are in the RVF file. Therefore, it is
extremely important to ensure you are using the most current file. Check the EarthSoft website
to see if your version is current before working on your data. The link for this web site is
provided below within section 2.3.2.

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Scribe – Scribe is a software tool developed by EPA to assist in the process of managing
environmental data. Scribe captures soil, water, air, and biota sampling, observational, and
monitoring field data. Scribe can import EDDs from analytical laboratories, location data from a
global positioning system, and from specific laboratory and exported EQuIS EDDs.

Shapefiles – Map files used by Esri GIS software.

Site (or Waterbody) – The unique site or waterbody in DART for storing project data. Also
sometimes referred to as a facility.

Station ID (sys_loc_code) – Unique designation for a sample location.

Valid Value – All allowable values for the field have been pre-determined. The data provider
must select one of the available choices, or request a new valid value be added.

.xml File – File format of the electronic chain-of-custody for Scribe, Collect, and EDGE.

1.6 Supporting Reference Documents

EPA Region 4 EDD Format File Guide.

The EPA Region 4 EDD Format File Guide provides detailed information for the creation
of the EDD files that are required to be submitted.

EPA Region 4 EQuIS Data Processor Reference Manual.

The EPA Region 4 EQuIS Data Processor Reference Manual provides the information
needed to download, install and maintain the EDP software, as well as how to use the
software to proof EDDs and create data packages.

EPA Region 4 Geographic Information System Deliverable Guidance.

The EPA Region 4 GIS Deliverable Guidance document provides specific requirements
and file delivery formats for all GIS materials developed in support of the program.

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2 Introduction
2.1 Data Sources
Data is submitted electronically to the EPA Region 4 from multiple sources. It should be
emphasized that the differences between the processes for data submittal arise solely from the
inherent efficiencies afforded to EPA lead investigations because the work may be done
‘in-house’. There is no difference in the types of data submitted, or the format of the files being
submitted. Regardless of how EDD files are created (or what organization led the
investigation), the files must meet the specifications of the EPA Region 4 EDD Format File Guide.
All GIS materials developed in support of the program must meet the specific requirements and
file delivery formats specified in the EPA Region 4 Geographic Information System Deliverable
Guidance.
2.2 Overview
The following summary provides a general outline of the process for submitting environmental
data to the EPA Region 4.

Create the Site or Waterbody – If the site or waterbody does not exist in DART, it must be
created. Creating the site or waterbody is the responsibility of the R4DART coordinator.

Create the Project – For R4LIMS projects, before data can be accepted by LSASD, a receiving
project must be created in the R4LIMS System. Creating the project is the responsibility of the
EPA Region 4 Sample Coordinator or EPA LSASD project lead.

Data Submittal Summary – For non R4LIMS, a projects summary of the data must be submitted
to provide a check that all data is received. The data provider is responsible for this task.

DART Reports – For R4LIMS projects, reports are sent out automatically after the chain-of-
custody information is uploaded to the Project Tracking System. The data provider (or EPA
LSASD project leader) is responsible for responding to these reports.

Create EDD(s) – Create EDDs to match the Data Submittal Summary. The data provider (or the
EPA LSASD project leader) is responsible for this task.

Check EDD(s) with EDP – All EDDs must be checked with EDP prior to submittal to the R4DART
coordinator. The data provider (or EPA LSASD project leader) is responsible for this task.

Submit EDD(s) – Submit all EDDs to [e-mail]. Attach the EDD(s) to the
requesting email. The data provider (or EPA LSASD project leader) is responsible for this task.

Proof and Correct as Needed – Notify R4DART of any needed corrections or additions arising
from the EDDs being rejected. It is the EPA Region 4’s responsibility to update or add any
information needed and inform back to the data provider completion or denial of request with
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alternate action. It is then the responsibility of the data provider (or the EPA LSASD project
leader) to proof the data for accuracy and resubmit with any needed corrections.

The system is designed for data to be submitted once (i.e., sample coordinates and screening
intervals for a monitoring well are submitted one time).

The details for successfully completing the above steps can be found in Section 3 for EPA fund
lead data submittals and Section 4 for Potentially Responsible Party (PRP) lead data submittals.

GIS Data Submittal – GIS data deliverables must accompany the submission of a final report to
the EPA Region 4 (see Section 5 for instructions).
2.3 EDP Standalone
If you are a data provider to the EPA Region 4 and do not have access to an EPA workstation,
you will need to download and install the EQuIS Data Processor (EDP) Standalone software.
There is no charge to the user for this software. If you have access to an EPA workstation and
need EDP installed, email [e-mail].
2.3.1 Obtaining EDP Standalone
Instructions for obtaining, installing, registering, and maintaining EDP Standalone can be found
in the EPA Region 4 EQuIS Data Processor Reference Manual.
2.3.2 Using EDP Standalone
EDP Standalone can be used to create smaller EDD files, but its primary function is to check
EDDs for errors and create data packages for submittal.

The structure of the EPA Region 4 EDD files is determined by the format file. If the format of
any of the EDDs must be changed (rarely), then it will be necessary for users of the standalone
version of EDP to obtain the updated format file. Instructions for downloading and installing
updated format files can be found in the EPA Region 4 EQuIS Data Processor Reference Manual.

Likewise, if the valid values used by EPA Region 4 are updated, it will then be necessary for
users of the EDP Standalone to obtain the updated reference value file (.rvf). The current
version of the EPA Region 4 .rvf file is at:
https://www.epa.gov/superfund/region-4-superfund-electronic-data-submission.
This file is updated periodically when the valid values are updated.

The EPA Region 4 will notify all data providers, currently in the database, when it is necessary to
update these files, but it is the responsibility of the data provider to ensure that the most
current version is being used.
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2.3.3 Valid Values in EDP
The EPA Region 4 valid values can be viewed in EDP by starting EDP, then clicking on the
“Reference Values” tab in the lower left corner.

If you need a valid value that is not in the list (rare analyte, new analytical method, etc.), you
may request it be added as outlined in the EPA Region 4 EDD Format File Guide.
2.3.4 Data Package
A data package is created by EDP when the ‘sign and submit’ function is used to save the EDD.
This creates an archive file (.zip) containing all EDDs that were loaded into EDP. The data
package must be properly named, including .dat file extension.
2.4 Information Required in EQuIS EDDs
An EDD is a tab-delimited text file containing environmental data in the EPA Region 4 format.
Detailed information on all EDD formats may be found in the EPA Region 4 EDD Format File
Guide. Table 2-1 is a check list of which EDD files are required based on the type of field activity.
When planning field activities, consider the data requirements to ensure appropriate data
collection and reporting to meet project objectives. Verify with your RPM if you should be
completing other EDDs in addition to the required EDDs for the field activity. A brief summary
of the more commonly used formats can be found below.

Location EDDs – These EDDs provide coordinates for sampling locations, along with a simple
indication of the quality of the information. Because all other EDDs rely upon this information,
the Location EDD is the first EDD that is submitted.

Field Results EDDs – These EDDs provide the results of field analyses (e.g., XRF, pH,
temperature, turbidity, etc.).

Water Level EDDs – These EDDs provide groundwater elevation data. If a water level EDD is
submitted, a Location EDD with the ground surface elevation (measured to top of casing for
wells) is required. In addition, each Water Level EDD must have a matching Well Datum EDD
(EPAR4_WellDatum_v1) to identify the measuring point of the Water Level Depth. The Well
Datum EDD is required when submitting water levels for the first time and any time a well is
modified.

Geology EDDs – These EDDs provide information about well construction, lithology, etc. If
groundwater samples are to be submitted, the screening intervals must have been recorded
using the well construction EDD (EPAR4_WellConstruction_v1).

Analytical Data EDDs – Provide the fixed-base laboratory analytical data. The data is in a three-
file format.
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2.5 Common Fields in EDDs
With few exceptions, the values described below are the first four columns of all the EPA
Region 4 EDDs. See the EPA Region 4 EDD Format File Guide for details on your specific EDD
format.
2.5.1 Data Provider Codes (sampling_company)
Data Provider codes are used to identify the source of the data within DART.

For R4LIMS projects, the data provider code is selected within the Project Tracking System as
the project is created.

For all other projects, the data provider code is determined by R4DART (and is then provided to
the data provider). If a data provider code does not exist in the system, R4DART will create one.
2.5.2 Project IDs (task_code)
The Project ID is a unique identifier for all data collected during an investigation. It allows data
from a given study to be retrieved by the original report with which it was submitted.

For R4LIMS fund lead projects, the Project ID is generated by the R4LIMS Project System when
the project is created. The Project ID is provided to data providers via the LSASD Project
Tracking System email reporting system. For non R4LIMS projects, the data provider requests
the Project ID from the R4DART.When Collect, EDGE or Scribe are used for the project, the
Project ID is entered during the initial setup with the Site Information.
2.5.3 Project Numbers (task_code2)
The Project Number is typically the same as the Project ID. These are unique identifiers for all
data collected during an event for the investigation or when multiple laboratories are needed.
The Project Number allows data from a given study to be retrieved by the original report with
which it was submitted.

For R4LIMS fund lead projects, the Project Numbers are generated by the R4LIMS Project
System when the project is created. The Project Numbers are provided to data providers via the
LSASD Project Log Summary Report email. For non R4LIMS projects, the Project Number may be
the same as the Project ID provided by R4DART. If a unique Project Number is required to track
an individual event, request a new Project Number from R4DART.

When Collect, EDGE or Scribe are used for the project, the Project Number is entered during
the chain-of-custody setup.
2.5.4 Program/Activity Codes (task_type)
The Program/Activity code identifies the program activity associated with the sampling event to
the DART database.
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For R4LIMS lead projects, the Program/Activity code is provided by the person entering project
data into the R4LIMS Project System.

For non R4LIMS lead projects, the Program/Activity code is determined by the site manager
(RPM or OSC) and is then provided to the data provider for entry into the activity_code in the
EDD.

When Collect, EDGE or Scribe are used for the project, the Program/Activity Code is entered
during the initial setup with the Site Information.
2.5.5 Station IDs (sys_loc_code)
A Station ID is the permanent designation for a sample collection point. Once a sampling point
has been established, the Station ID designation will be used for all future sampling events
regardless of the entity leading the investigation. Note that the sampling point is established for
a location, not a sample type.

A Station ID is not a Sample ID. Sample IDs should be distinct from Station IDs to prevent
confusion.

Station ID designations should be simple and easy to remember. Do not use special characters
such as the asterisk, quote, or percent symbol. The Station ID should be kept to 8 or fewer
characters where possible.

For example, two samples are collected from the same location in Sandy Creek, sample SC-001-
SW (a surface water sample) and SC-001-SD (a companion sediment sample). Because they
were collected at the same location, both will have the same Station ID, such as SC001.

Additional example, a soil sample is collected as a part of a monitoring well installation. The
subsurface soil sample is designated RF-007C-SB. The well being installed is being given the
designation MW012. Sample RF-007C-SB (and all other samples collected at that well location)
will have the Station ID MW012.

It may help to think of the Station ID as the permanent name for a sampling location, while any
number of samples (from any media available) may be collected at that given location. A
Station ID is a point on a map, and many samples may be collected from that point during an
investigation (or series of investigations).

All environmental samples must have a Station ID (e.g., surface water, groundwater, sediment,
surface soil, etc.).

Field blanks (trip blanks, equipment rinse blanks, etc.) do not have coordinates, and therefore,
do not have Station IDs. The logic for this is built into EDP—if you try to enter a Station ID for a
sample type (media code) that does not allow it, EDP will display an error. Likewise, if a media
code requires a Station ID that is missing, EDP will again display an error.
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3 EPA Lead Data Submittals
3.1 EPA Lead Projects
Data from all EPA lead projects (LSASD, States and EPA contractor performing organizations)
using EPA laboratory resources (CLP and special purchase laboratories) must be permanently
archived in DART. It is the responsibility of the EPA manager (RPM or OSC) to ensure that the
data provider(s) for the investigation properly prepare and submit all EDDs.

All questions about data submittals for EPA Lead projects should be directed to:
[e-mail].
Procedures for projects that are being conducted by PRPs can be found below (Section 4).
3.2 Software Requirements
The software listed below is required for electronic submittal of data from EPA lead projects in
the EPA Region 4.
3.2.1 Collect, EDGE, or Scribe
EQuIS Collect and EDGE are both EarthSoft developed applications and can create a Scribe like
deliverable. Scribe is an EPA developed and distributed software program that is used in the
EPA Region 4 to generate EDD files of chain-of-custody information.

EDGE is available for free at the EarthSoft website:
https://earthsoft.com/products/edp/edp-format-for-epar4/.
EQuIS Collect Mobile app is available for free from the Google Play Store, Apple App Store, or
Microsoft Store.
Scribe is available for free at: https://www.ertsupport.org/Scribe.

In the EPA Region 4, these programs are used with DART to provide more compatibility
between Element and DART, making EDD creation and submittal easier. If using Scribe, the EPA
Region 4 samplers should obtain the EPA Region 4 template for the necessary customizations
specific for the EPA Region 4 Scribe configuration from:
https://response.epa.gov/site/doc_list.aspx?site_id=ScribeGIS.
Select the Scribe Template from the right-side category listing.
3.2.2 EQuIS Data Processor
EDP is used to check EDDs for errors prior to submission and to create the data package for
submittal. It can also be used to create smaller EDDs. It is available as a free download, if the
data provider does not have access to an EPA workstation. See Section 2.3 for more
information on EDP Standalone.
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3.3 Create Site or Waterbody
3.3.1 Site Creation
Before data can be submitted, the site must be created in DART.

Proper site\waterbody creation is important to success. DART is intended to be a permanent
archive for the data generated by these investigations.

For EPA lead projects conducted by LSASD, the Project Leader has the responsibility for Site or
Waterbody creation. For EPA lead projects not conducted by LSASD, the EPA Region 4 program
office will submit the required information. Site creation requests must be sent to:
[e-mail].
Begin by checking with the R4DART coordinator to see if the site has been created. Internal to
the EPA Region 4, anyone with access to the R4LIMS Project Information may check the
dropdown for R4LIMS projects. If the site is not within DART, it must be created. To create a site
in DART:
• Search for the site at the SEMS website at:
https://cumulis.epa.gov/supercpad/cursites/srchsites.cfm
• Verify the search results, identify if there is an EPA ID recorded, and copy the URL
(website address) from the search results and paste it into an email to
[e-mail] requesting the site be created.
• If the site is not found on the SEMS website or does not have an EPA ID, go to the EPA
EnviroFacts website at: https://enviro.epa.gov/.
• This will utilize a Multisystem query retrieval and may return several related sites. Find
the site matching the address and if the site is found, select the Facility Report icon.
When the page is updated, if there is an EPA Registry ID listed, copy the URL (website
address) from the Facility report feature and paste it into an email to [e-mail]
requesting the site be created.
• If the site is not in these databases, send the following information to
[e-mail]:
Site Name
Address,
City, State, Zip Code
County
RPM/OSC
Lat/Long of Site Centroid
NPL Status
3.3.2 Waterbody Creation
First contact the R4DART coordinator to see if the waterbody already exists in DART. If the
waterbody does not exist in the EQuIS DART database, it must be created.
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To create a waterbody in DART, the project leader must provide the USGS GNIS ID number for
the Waterbody. The GNIS ID numbers for all waterbodies in the US can be found at this
website: http://geonames.usgs.gov/.
• At the website, select ‘Search Domestic Names’.
• In the dialog box that opens, enter the ‘Feature Name’.
• Select your ‘Feature Type’ and ‘State’.
• Click ‘Submit Query’.
• In the dialog box that opens, click the Feature Name for details.
• Copy the URL (website address) of the page that opens and paste it into an email to
[e-mail] requesting the waterbody be created.
If the waterbody does not exist in the USGS database, send the best available name to
[e-mail].
3.3.3 Criminal and Enforcement Confidential
If the field investigation is criminal or enforcement confidential, extra precaution must be taken
to keep the project data confidential.

For these investigations, determine if the site is in DART as outlined above. If found, check the
Facility Code field. If it does not begin with ‘R4SC-‘, copy the name and Facility Code of the site
and forward to [e-mail] with a request to create the site as criminal or enforcement
confidential.

If the site or waterbody does not exist in DART, find the needed information as outlined above
(Sections 3.3.1 and 3.3.2) and forward to [e-mail]. The subject line of the email
should state the site is for criminal or enforcement confidential data.

If the site or waterbody cannot be found in the EPA or USGS databases, send the best available
information to [e-mail]. The subject line of the email should state the site is for
criminal or enforcement confidential data.
3.4 Project Creation (Project ID)
For R4LIMS fund lead projects, after the project has been created but prior to the field
investigation, the data provider will receive an email with the Project Log Summary information
required to successfully submit an electronic chain-of-custody to LSASD. Use the information in
this report to setup your investigation in Collect, EDGE or Scribe.

When a project for the investigation is logged into the R4LIMS System, a Project ID is assigned
and a project is automatically created in the R4LIMS System. The Project ID is then embedded
in the EDDs and is used to tie that data to the original study.
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For non R4LIMS projects, contact R4DART for the assigned Project ID. As part of the project
setup for non R4LIMS projects, information about the types of data that will be collected (and
EDDs submitted) should be sent to R4DART using the Data Submittal Summary Template.
3.5 Chain of Custody
All EPA lead projects in the EPA Region 4 must submit an electronic chain-of-custody to LSASD.
For all soil and sediment type sampling, a copy of the chain-of-custody XML file must also be
sent to [e-mail]. This file can be generated using Collect, EDGE or Scribe.

This EDD file is different in one major aspect from all other EDDs submitted from EPA lead
projects:
These chain-of-custody EDDs must be submitted to [e-mail] and
cc [e-mail].

This submittal does not satisfy the requirement for a signed chain-of-custody to accompany the
samples at all times.
3.6 DART Reports
After your chain-of-custody data is received and the samples are logged into the R4LIMS
(Element) system, you will receive automated reports if additional information or corrections
are required. These emails are sent the night samples are logged into the R4LIMS (Element)
system and each Monday thereafter.

When all needed corrections have been made to Project Log and Element, the project setup in
the Project Tracking System is checked to see what additional EDDs (Location, Field Results,
Geology, or Water Level) are required.

The data provider will receive at least one DART report from the Project Tracking System, even
if no errors are found and no additional data are required. This is to allow for an opportunity to
proof and correct the data in the system.
3.6.1 Sample Information Requests
These email alerts are triggered by missing or incorrect information in Project Log or Element
that will prevent the lab analytical data from loading to DART once reported. These corrections
must be made before the data is reported by the LSASD laboratory. If the corrections are not
made before the data is reported, it will be necessary for the lab to re-report the data.

These emails contain a due date in the subject line. Corrections and missing data must be
submitted prior to the due date.
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3.6.1.1 Corrections to Project Log
For R4LIMS lead projects, if the Project Summary report email shows information missing,
forward the email to [e-mail] and supply the missing information. This portion of the
report checks for:
• Valid site or waterbody selected,
• Valid Project ID selected,
• Valid program\activity selected, and
• Valid data provider selected.
3.6.1.2 Corrections to Element
Errors within Element are not easily corrected when system information conflicts with the
official hardcopy. Changes to Element must be accompanied by supporting information, such as
corrected chain-of-custody, logbook information, and explanation (to attach to official
documents in the file). Information presented in this portion of the email shows your sampling
information as it currently resides in Element.

Station IDs and Media Codes are checked to ensure compliance with business rules. If you have
a missing or incorrect Station ID or Media Code, type the correct value in the appropriate
‘Edited’ column and forward the email to [e-mail] and cc
[e-mail].

Should an error on the chain-of-custody be found after the samples and electronic chain-of-
custody xml file have been sent to [e-mail] (cc [e-mail]), an
updated electronic chain-of-custody needs to be recreated and then sent to
[e-mail] and again cc [e-mail]. Errors of this type may be a
mislabeled sample, the wrong location code used, or a date and time wrongfully entered.
3.6.2 EDD Requests
These emails contain a due date in the subject line. Requested EDDs must be submitted prior to
the due date.
• After any errors in Project Log and Element are corrected, a Location EDD is requested
for Station IDs that cannot be matched in DART. A weekly reminder to submit the
Location EDD will be sent until the data are received.
• Once the Location EDD has been received, requests for any additional EDDs will be sent
based upon the information in the project setup.
3.6.3 ‘Overdue’ Reports
If corrections and EDDs are not submitted before the analytical data is reported by the lab for
R4LIMS lead projects, ‘Overdue’ reports will be generated. These reports will be sent each
Monday morning until the requested data is received.
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3.7 Creating EDDs
EDDs can be created in a number of ways. The best method will depend upon the amount of
data to be submitted, and how the chain-of-custody was generated.

It should be noted that for small amounts of data, any of the EDD(s) listed below can be created
directly in EDP. Detailed instructions for creating EDDs can be found in the EPA Region 4 EDD
Format File Guide and the EPA Region 4 EQuIS Data Processor Reference Manual.
3.7.1 Location EDDs
Each email request for a Location EDD has the list of missing Station IDs within the email body.
Submit the required information via Location EDD as soon as possible and prior to the analytical
data being generated.
3.7.2 Field Results EDDs
Field results should be sent to DART as soon as the locations have been submitted. These are
typically the direct measurements taken during the field event. In place of a CAS-RN, all field
parameters use a FI- prefix for the code. Fields results are not permitted to be entered within
the analytical results EDD.
3.7.3 Water Level EDDs
Required for all groundwater elevation measurements and for all surface water elevation
measurements tied to groundwater elevation. The measuring from datum must be recorded
for the elevation to be calculated using the depth to water.
3.7.4 Geology EDDs
It is recommended that these EDDs be prepared by professionals with experience with this type
data. Details for the various formats are specified in the EPA Region 4 EDD Format File Guide.
3.7.5 Analytical Data EDDs
Preparation of these files should be performed by individuals with experience in understanding
unfiltered laboratory reports. The format is specified in the EPA Region 4 EDD Format File
Guide.

Element – Analytical data reported by the EPA Region 4 LIMS (Element) are formatted for EQuIS
and are automatically loaded upon receipt of a valid Location EDD. This includes any samples
that are shipped to the CLP.

Subcontracts/Interagency Agreements – Any non-Element data must be placed in the EQuIS
format by the data provider. To help ensure accuracy, the performing laboratory should be
requested to report the data in the EPA Region 4 EQuIS format as part of the bid. If the data
provider has been tasked to validate the data, then validation qualifiers, interpreted qualifiers,
and the validation stage are added to the laboratory deliverable prior to error checking and
submittal.
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3.8 Error Checking with EQuIS Data Processor
For information on obtaining, installing, maintaining and using EDP Standalone, refer to the
EPA Region 4 EQuIS Data Processor Reference Manual. If you are using EDP Standalone, be sure
the EPA Region 4 format and reference values are all up to date before using.

If you are using EDP on an EPA workstation, start EDP by logging in to EQuIS Professional and
selecting your site (facility). Once connected to the database, select the EDP icon in the upper
left corner.

Data Providers must use EDP to check all EDDs for errors before submission. EDP contains a
help file to assist with error correction. Let the mouse hover over any cell with a non-white
background to view a detailed error message. Hover the mouse over any column header to
view additional information specific to the field.

Instructions for using EDP can be found in the EPA Region 4 EQuIS Data Processor Reference
Manual.

When you email the EDD to [e-mail] and there are errors, the system will
automatically send the data provider an email that the EDD was rejected and an error log will
be attached. If you are unable to correct the problem, email the EDD’s Error Log along with the
file causing the problem to [e-mail] with your contact information.
3.9 Submitting EDDs
After correcting any errors in your EDD, save the file from EDP using the sign and submit menu
option to save the data package. A user name and password is required to successfully create
the EDD package and upload the data into DART. If you do not have a valid user name and
password for DART, email [e-mail] and provide the Site, RPM, data provider
company, and data provider email address.

After processing with EDP, the submitted file IS REQUIRED to be named according to the
following convention that includes the following elements connected with underscores:
• Task Code
• Site Name
• Data Provider Company Code
• Date Submitting (YY MM DD)
• Type (Loc-Location/Ch-Chemistry/FR-FieldResults/WL-WaterLevel/GEO-Geology/
WC-Well and Well Construction /VI-Vapor Intrusion)
• .FacilityCode.EPAR4.dat
For example:
13-0001_YourSite_ YourCompanyCode_19 01 08_Ch.110001224773.EPAR4.dat
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NOTE: The EPA electronic mail system will reject files with a .zip format due to security
concerns. To match how the EPA Region 4 laboratory submits EDDs, you must rename the EDD
file extension from .zip to .dat before emailing the EDD to the EPA Region 4. Files must be
submitted with the “.dat” extension.

NOTE: The EPA electronic mail system will reject files with more than three (3) periods. Thus, it
is important to connect the file naming elements using underscores rather than periods.

If the EDD contains data for a field that will need to update values already in the database, use
“EPAR4update.dat” rather than “EPAR4.dat”, which only merges the data. An example is
replacing estimated coordinates with surveyed coordinates.

Attach the EDD to the automated email you received requesting the sampling for R4LIMS lead
projects and forward to [e-mail]. If the file is named improperly or not
attached to the requesting email, it will be returned to the data provider.
3.10 Proofing and Corrections
Notify the DART coordinator of any errors you find in the system. Send corrections to
[e-mail].

After the data has been successfully loaded, an automated email will be sent to the data
provider from [e-mail] notifying that the file has been accepted and no errors
were found. If the data are rejected, an automated email will be sent to the data provider from
[e-mail] with the error log attached as a .dat file. To open the error log,
download the .dat file from the email and rename the file extension from .dat to .zip prior to
opening.

Once the errors have been corrected, recreate the EDD package following the same process as
the original sign and submit. The one exception will be the file name, which may not be
identical to any previous submissions. For each resubmittal, add a capital letter suffix (i.e., “A”
then “B”, etc.) to the file name. After the “Type”, insert an underscore followed by the capital
letter suffix (i.e., Type_A.FacilityCode).

For example:
13-0001_YourSite_YourCompanyCode_19 01 08_Ch_A.110001224773.EPAR4.dat

The data provider is responsible for the receipt of all automated emails based on the
information provided when requesting a user name and password. Should the data provider
not receive the automated emails regarding their EDD submission or feel an error was
inaccurately returned, notify the EPA Region 4 at [e-mail] for any errors found.
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4 PRP Lead Data Submittals
4.1 PRP Lead Projects
Responsible Parties conducting environmental investigations in the EPA Region 4 for the
Superfund program must report their data to the EPA Region 4 electronically. The types of data
required to be submitted are outlined in Section 2.4. The responsible party is responsible for
the information contained in the files submitted by the data provider.

Address all data submittals questions to [e-mail].

Procedures for EPA lead projects can be found in Section 3.
4.2 Software Requirements
All data providers are required to use EDP to check their data files for errors prior to submittal.
EDP is software used to check all EDDs for errors prior to submittal and to create properly
formatted data packages. EDP can also be used to create smaller EDDs. EDP is available as a
free download.
4.3 Site Creation
All National Priorities List sites in the EPA Region 4 have been created in DART. If, however, a
site is found to be missing (or a new site is added to the NPL), it must first be created using
information from EPA’s national database as described in Section 3.3.1.

To create the site, the RPM or OSC must email the URL (website address) from their search
results (SEMS or Envirofacts as detailed in Section 3.3.1) to [e-mail].

If the site is not in these databases, the RPM or OSC must send the following information to
[e-mail]:
Site Name
Address,
City, State, Zip Code
County
RPM/OSC
Lat/Long of Site Centroid
NPL Status
4.4 Project Creation (Project ID)
For current and historical data (as defined in the EPA Region 4 EDD Format File Guide), the
project must be created manually (assuming no past fund lead projects are available in the
R4LIMS Project System). The R4DART coordinator will use the DART system to setup the
proposed data submittal, and to get the data provider contact information (email address) in
the system.
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When the project has been successfully established, a report may be sent to the data provider
containing any existing Station IDs and their coordinates. The data provider must review the
report for existing sampling stations. If samples are to be collected (or were collected) at an
existing Station, the established Station ID must be used.
4.5 Data Submittal Summary
After the project is created, the EPA Region 4 will notify the data provider to submit the Data
Submittal Summary for non R4LIMS sampling and email to [e-mail] for tracking.
When this information has been received and accepted by the RPM, the R4DART will be
prepared to receive the project data. Information on the Data Submittal Summary format can
be found in the EPA Region 4 EDD Format File Guide and downloaded from the Superfund
website at: http://www2.epa.gov/superfund/region-4-superfund-electronic-data-submission
4.6 DART Reports
After the information from the Data Submittal Summary is entered into the Project Tracking
System and accepted by the RPM, automated reports detailing any errors or additional
information needed will be sent to the data provider. These emails are sent the night the Data
Submittal Summary is loaded, and each Tuesday thereafter until all data for the given project
has been received.

Note the order for the data submittals below. This order is both dictated by a desire to offer
data providers with the opportunity to review each step in the data submittal process, and by
the database logic of DART.
4.6.1 Location EDD Request
If the Data Submittal Summary contains additional information for an established sampling
station, the data provider MUST use the Station ID(s) provided.

Because the system will begin requesting the remaining EDDs upon receipt of the first Location
EDD file, the data provider may prefer to submit all Station IDs in a single Location EDD file.
Multiple Location EDDs may be submitted if needed.

If the Location EDD is found to contain an error not related to the coordinates, the PRP must
send a spreadsheet with a list of the incorrect and corrected information.

For coordinates with errors (or if better coordinates become available), the original Location
EDD may be edited and re-submitted. Delete the rows in the original Location EDD that do not
need to be updated, edit the coordinates for the remaining rows, and re-submit to
[e-mail]. The phrase ‘Updated coordinates’ should be in the subject line.
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4.6.2 Other EDD Requests
Upon receipt of the Location EDD, the Project Tracking System will make weekly requests for
the remaining EDDs that were specified in the original Data Submittal Summary and accepted
by the PRP. The remaining EDDs will be checked against Station IDs as they are received, and
will be rejected if no matching Station ID can be found.
4.7 Creating EDDs
EDDs can be created using spreadsheet software, directly in EDP, or in a word processor such as
Notepad. More information about the file format can be found in the EPA Region 4 EDD Format
File Guide.

The best method for creating EDDs will depend upon the amount of data to be submitted.
It should be noted that for small amounts of data, any of the EDD(s) listed below can be created
directly in EDP. Detailed instructions for creating EDDs can be found in the EPA Region 4 EDD
Format File Guide and the EPA Region 4 EQuIS Data Processor Reference Manual.
4.8 EQuIS Data Processor
For information on obtaining, installing, maintaining, and using EDP Standalone, refer to the
EPA Region 4 EQuIS Data Processor Reference Manual, and Section 2.3 of this guidance
document.

Use EDP to check all EDDs for errors before submission. EDP contains a help file to assist with
error correction. Hover the mouse over any cell with a non-white background to view a detailed
error message. Hover the mouse over any column header to view additional information
specific to the field.

If you have errors you are unable to correct, email the EDD’s Error Log along with the file(s)
causing the problem to [e-mail] with your contact information. Place the site name
and the Project ID in the subject line.

If you need to update the EDP Standalone appearance options for 508 compliancy, email
[e-mail] for assistance.
4.9 Submitting EDDs
Remember to submit Location EDDs before submitting any other EDDs. The database structure
requires locations to be loaded prior to all other environmental data.

While EDP permits the submittal of combined EDDs, this feature is not fully supported in the
EPA Region 4 implementation. Submit each EDD separately (except for Analytical EDDs, which
are always submitted as a three file set, and first time water levels will need a well datum EDD
together – See the EPA Region 4 EDD Format File Guide).

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When all errors have been corrected, save the EDD(s) using ‘sign and submit’ (see EPA Region 4
EQuIS Data Processor Reference Manual). Name all files as specified below. Improperly named
files will be returned to the data provider. The required names can also be found in the EDD
request reports sent to the data provider.

After processing with EDP, the submitted file IS REQUIRED to be named according to the
following convention that includes the following elements connected with underscores:
• Task Code
• Site Name
• Data Provider Company Code
• Date Submitting (YY MM DD)
• Type (Loc-Location/Ch-Chemistry/FR-FieldResults/WL-WaterLevel/GEO-Geology/
WC-Well and Well Construction /VI-Vapor Intrusion)
• .FacilityCode.EPAR4.dat
For example:
P2013-0001_YourSite_ YourCompanyCode_19 01 08_Ch.110001224773.EPAR4.dat
NOTE: The EPA electronic mail system will reject files with a .zip format due to security
concerns. To match how the EPA Region 4 laboratory submits EDDs, you must rename the EDD
file extension from .zip to .dat before emailing the EDD to the EPA Region 4. Files must be
submitted with the “.dat” extension.

If the EDD contains data for a field that will need to update values already in the database, use
“EPAR4update.dat” rather than “EPAR4.dat”, which only merges the data. An example is
replacing estimated coordinates with surveyed coordinates.

To submit your prepared data package, attach the data package to the EDD request and
forward to [e-mail]. Any time there has been a data request sent, data
packages must be attached to the requesting report.
4.10 Proofing and Corrections
After the data has been successfully loaded, an automated email will be sent to the data
provider from [e-mail] notifying that the file has been accepted and no errors
were found. If the data is rejected, an automated email will be sent to the data provider from
[e-mail] with the error log attached as a .dat file. To open the error log,
download the .dat file from the email and rename the file extensions from .dat to .zip prior to
opening.

Once the errors have been corrected, recreate the EDD package following the same process as
the original sign and submit. The one exception will be the file name, which may not be
identical to any previous submissions. For each resubmittal, add a capital letter suffix (i.e., “A”
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then “B”, etc.) to the file name. After the “Type”, insert an underscore followed by the capital
letter suffix (i.e., Type_A.FacilityCode).

For example:
P2013-0001_YourSite_ YourCompanyCode_19 01 08_Ch_A.110001224773.EPAR4.dat

The data provider is responsible for the receipt of all automated emails based on the
information provided when requesting a user name and password. Should the data provider
not receive the automated emails regarding their EDD submission or feel an error was
inaccurately returned, notify the EPA Region 4 at [e-mail] for any errors found.
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5 Information Required in GIS Submittals
Initial draft submittal and final version of spatially enabled files acquired or developed to
support mapping, spatial analysis, and/or report generation by a data provider are considered
property of the EPA Region 4 SEMD and are required to be submitted to the EPA Region 4. GIS
data submittals must meet the project, metadata, organizational, and delivery requirements in
acceptable GIS data formats as specified in the EPA Region 4 Geographic Information System
Deliverable Guidance.

GIS data and map files will be packaged into zip files and submitted electronically. All electronic
submissions will require the completion of an online GIS Data Submittal form. This form and zip
file(s) should contain all information necessary to understand the data submittal. The EPA
Region 4 will not accept any GIS data that does not have this form completed and
accompanying the submittal.

To submit your GIS data to the EPA Region 4, please zip all files and use the link below to access
the EPA Region 4 online GIS Data Submission form:
https://arcg.is/1aDXya