FINAL PRELIMINARY ASSESSMENT REPORT

FOR THE NORWOOD LANDFILL NORWOOD, DELAWARE COUNTY, PENNSYLVANIA

Prepared for:

U.S. Environmental Protection Agency Region III Hazardous Site Cleanup Division 1650 Arch Street Philadelphia, PA 19103

Prepared by:

Region III Superfund Technical Assessment and Response Team IV Weston Solutions, Inc. 1400 Weston Way West Chester, PA 19380

EPA Contract No.: EP-S3-15-02 Technical Directive Document No.: W503-17-03-001 Document Control No.: W0146.1A.02089

July 2017

(b) (4)

(b) (4)

(b) (4)

(b) (4) Norwood Landfill Final Preliminary Assessment Report

TABLE OF CONTENTS

Section Page

1.0 INTRODUCTION...... 1 2.0 SITE BACKGROUND ...... 1 2.1 LOCATION AND DESCRIPTION ...... 1 2.2 SITE OWNERSHIP ...... 2 2.3 PREVIOUS INVESTIGATIONS ...... 2 3.0 SOURCE DESCRIPTION AND CHARACTERISTICS...... 5 4.0 GROUNDWATER MIGRATION PATHWAY ...... 5 4.1 REGIONAL AND SITE GEOLOGY ...... 5 4.2 REGIONAL AND SITE HYDROGEOLOGY ...... 6 4.3 GROUNDWATER TARGETS ...... 6 4.4 GROUNDWATER CONCLUSIONS ...... 7 5.0 SURFACE WATER MIGRATION PATHWAY ...... 8 5.1 HYDROLOGIC SETTING ...... 8 5.2 SURFACE WATER TARGETS ...... 9 5.3 SURFACE WATER CONCLUSIONS ...... 9 6.0 SOIL EXPOSURE AND AIR MIGRATION PATHWAYS ...... 11 6.1 PHYSICAL CONDITIONS...... 11 6.2 SOIL AND AIR TARGETS ...... 11 6.3 SOIL EXPOSURE AND AIR MIGRATION PATHWAY CONCLUSIONS...... 13 7.0 SUMMARY AND CONCLUSIONS ...... 13 8.0 REFERENCES ...... 16

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LIST OF TABLES

Title Page

TABLE 1 DRINKING WATER WELLS WITHIN A 4-MILE RADIUS OF THE SITE .....7

TABLE 2 ESTIMATED POPULATION WITHIN A 4-MILE RADIUS OF THE SITE ....12

TABLE 3 WETLAND ACREAGE WITHIN A 4-MILE RADIUS OF THE SITE ...... 13

LIST OF APPENDICES

APPENDIX A FIGURES Figure 1 Site Location Map Figure 2 Site Layout Map Figure 3 4-Mile Radius Map with Distance Rings Figure 4 15-Mile Downstream Surface Water Pathway Map

APPENDIX B TABLES Table 1 1999 USFWS Analytical Data – Surface Water Samples Table 2 1999 USFWS Analytical Data – Sediment Samples

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LIST OF ACRONYMS AND ABBREVIATIONS

µg/kg micrograms per kilogram µg/L micrograms per liter 4,4-DDD 4,4-dichlorodiphenyldichloroethane 4,4-DDE 4,4-dichlorodiphenyldichloroethylene 4,4-DDT 4,4-dichlorodiphenyltrichloroethane Aqua Pennsylvania Aqua Pennsylvania Water Company BTAG Biological Technical Assistance Group CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980 EPA U.S. Environmental Protection Agency mg/kg milligrams per kilogram PA preliminary assessment PaGWIS Pennsylvania Groundwater Information System PAH polycyclic aromatic hydrocarbon PCB polychlorinated biphenyl RBC Risk-Based Concentration Ref. Reference START Superfund Technical Assessment and Response Team SVOC semivolatile organic compound TAL Target Analyte List TCL Target Compound List TDD Technical Directive Document TDL target distance limit USFWS U.S. Fish and Wildlife Service VOC volatile organic compound WESTON® Weston Solutions, Inc.

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1.0 INTRODUCTION

Under the Superfund Technical Assessment and Response Team (START) IV Contract No. EP-S3-15-02, Technical Directive Document (TDD) No. W503-17-03-001, the U.S. Environmental Protection Agency (EPA) Region III tasked Weston Solutions, Inc. (WESTON®) to conduct a Preliminary Assessment (PA) at the Norwood Landfill (Site) located in Norwood, Delaware County, Pennsylvania.

The Site PA was conducted in accordance with EPA Guidance for Performing Preliminary Assessments Under CERCLA (Reference [Ref.] 1). The purpose of this PA was to conduct an initial site assessment to determine the need for additional action under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA). The scope of the Site PA included a review of available site information, a compilation and evaluation of potential targets, a site reconnaissance, and an evaluation of reconnaissance information. Samples were not collected as part of the Site PA.

2.0 SITE BACKGROUND

This section presents a description of the Site and its location, provides a discussion of the Site’s ownership and history, and presents a summary of previous site investigation activities.

2.1 LOCATION AND DESCRIPTION

The Site consists of an urban residential neighborhood in lower Norwood, Delaware County, Pennsylvania. The geographic coordinates of the approximate center of the Site are 39°52'55.76" north latitude and 75°17'29.04" west longitude (Ref. 2). Land use at the Site and the surrounding area consists of residential areas. Amosland Park borders the Site to the northeast, wooded areas and Muckinipattis Creek are located to the east, wooded areas and Darby Creek are located to the south, Norwood Elementary School is located to the northwest, and additional residential areas are located north and west of the Site (Figures 1 and 2, Appendix A).

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2.2 SITE OWNERSHIP

The Site consists of a residential area located in a lower Norwood neighborhood and the surrounding property between E. Winona Avenue and Darby Creek. Various individuals own the properties in the residential area. According to the Delaware County Real Estate Parcels and Tax Records System, the folio number for the property surrounding the lower Norwood neighborhood is 310000600903 and the current owner is the Norwood Borough Authority (Ref. 3). No previous owners are listed for this property.

2.3 PREVIOUS INVESTIGATIONS

In 1993, the U.S. Fish and Wildlife Service (USFWS) conducted a Level I Contamination Survey of two tracts of land, Tract 24 and Tract 35, which are located near the Site. Tract 35 appears to be part of folio 310000600903, which is part of the undeveloped portion of the Site (Figure 2, Appendix A). The Level I Contamination Survey noted that the Borough of Norwood historically had used Tract 35 as municipal landfill and that debris was scattered across the property at the time of the survey. Observed debris included glass jars and bottles, automobile frames and parts, aluminum siding, asphalt, concrete, and tires (Ref. 4).

In 1999, Program Management Company conducted a Level II Survey of Tracts 24 and 35 for USFWS, during which test pits were excavated and samples of soil (21 shallow and 17 deep), sediment (7), surface water (6), and groundwater (10) were collected. The samples were analyzed for Target Compound List (TCL) volatile organic compounds (VOCs), TCL semivolatile organic compounds (SVOCs), TCL pesticides, polychlorinated biphenyls (PCBs), chlorinated herbicides, Target Analyte List (TAL) metals (total and dissolved for groundwater samples), and cyanide. Analytical results were compared to EPA Region III Risk-Based Concentrations (RBCs) residential and industrial soil screening levels for surface soils and sediment samples and EPA RBCs for tapwater for the surface water and groundwater samples, where applicable (Ref. 4). Additionally, for this preliminary assessment, the surface water data and sediment data were compared to EPA Biological Technical Assistance Group (BTAG) Screening Values for freshwater and are discussed in Section 5.3 of this report (Ref. 20).

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VOCs were not detected in any of the soil samples above RBCs. Eleven of the 21 shallow soil samples contained benzo(a)pyrene concentrations above the residential RBC of 87 micrograms per kilogram (µg/kg), with results ranging from 160 µg/kg to 2,100 µg/kg, and 8 of the 17 deep samples contained concentrations above the residential RBC, with results ranging from 150 to 3,000 µg/kg. PCBs were detected in four shallow and two deep soil samples at concentrations exceeding the residential RBC of 320 µg/kg with a maximum concentration of 1,100 µg/kg. One pesticide, chlordane, in one deep sample contained a concentration of 4,400 µg/kg, which exceeds the residential RBC of 1,800 µg/kg. Concentrations of arsenic were detected above the residential RBC of 0.43 milligrams per kilogram (mg/kg) in all the shallow and deep soil samples, with the exception of one shallow soil sample. The results ranged from 1.0 mg/kg to 34.3 mg/kg. Concentrations of lead exceeded the action level of 400 mg/kg in 4 of the 21 shallow and 2 of the 17 deep soil samples. The results ranged from 4.2 mg/kg to 1,160 mg/kg (Ref. 4).

Concentrations of benzo(a)anthracene, benzo(b)fluoranthene, and benzo(a)pyrene exceeded the tapwater RBCs in only one surface water sample. These exceedances were detected in sample SW- 4, which was collected from the southwest corner of Tract 35 (Figure 2, Appendix A). Manganese was detected above the RBC in one surface water sample, SW-5, which was also collected near the southwest corner of Tract 35. No other contaminants were detected above the tapwater RBC in the surface water samples (Ref. 4).

Six constituents were detected above their industrial soil RBCs in the sediment samples: benzo(a)pyrene, benzo(a)anthracene, benzo(b)fluoranthene, dibenz(a,h)anthracene, arsenic, and lead. Benzo(a)pyrene was detected above the industrial soil RBC of 780 µg/kg in four of the seven sediment samples, with results ranging from 800 to 13,000 µg/kg. The remaining three SVOCs were detected in one sediment sample, SE-2. Arsenic was detected above the industrial soil RBC of 3.8 mg/kg in six of the seven sediment samples, with results ranging from 9.1 milligrams per kilogram to 32.3 mg/kg. Lead was detected in one sediment sample above the action level of 400 mg/kg at a concentration of 814 mg/kg. Several VOCs, PCBs, and pesticides were detected in the sediment samples; however, the concentrations did not exceed applicable industrial soil RBCs. The concentrations of PCBs in two of the seven samples did exceed the residential soil RBC of 320 µg/kg, with results ranging from 380 µg/kg to 650 µg/kg (Ref. 4). The locations of the collected sediment samples and associated data are unclear in the Level II Survey Report. In

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Section 2.2 of the Level II Survey Report, sediment samples SED-1 through SED-7 are identified as having been collected at co-located surface water sample locations, with the exception of SED- 3, which was a sediment only location. However, in Table 3-7, the sediment sample locations are identified as SE-1 through SE-7. Both sediment designations are shown on Figure 2-1, Sample Location Map, provided in the report with a note indicating locations identified by SE are existing sediment sample locations (Ref. 4).

One VOC, chloroform, was detected in one groundwater sample at a concentration of 1.6 micrograms per liter (µg/L), which exceeds the tapwater RBC of 0.15 µg/L. Concentrations of benzo(a)anthracene exceeding the tapwater RBC of 0.092 µg/L were detected in 5 of the 10 groundwater samples, with results ranging from 0.2 µg/L to 0.6 µg/L. Concentrations of benzo(b)fluoranthene exceeded the tapwater RBC of 0.092 µg/L in 5 of the 10 groundwater samples, with results ranging from 0.3 µg/L to 0.8 µg/L. Concentrations of benzo(a)pyrene exceeded the tapwater RBC of 0.0092 µg/L in 5 of the 10 groundwater samples, with results ranging from 0.2 µg/L to 0.6 µg/L. Concentrations of 1,4-dichlorobenzene exceeded the tapwater RBC of 0.47 µg/L in 3 of the 10 groundwater samples, with results ranging from 0.8 µg/L to 2.2 µg/L. Indeno(1,2,3-cd)pyrene exceeded the tapwater RBC of 0.092 µg/L in 3 of the 10 groundwater samples, with results ranging from 0.3 µg/L to 0.4 µg/L. Bis(2-ethylhexyl)phthalate was detected in one groundwater sample at a concentration of 6.2 µg/L, which exceeds the tapwater RBC of 4.8 µg/L. Concentrations of total arsenic exceeded the tapwater RBC of 0.045 µg/L in 4 of the 10 groundwater samples, with results ranging from 5 µg/L to 32.7 µg/L. Total aluminum in two samples exceeded the tapwater RBC of 37,000 µg/L at concentrations of 52,900 µg/L and 46,700 µg/L. Total iron was detected above the tapwater RBC of 11,000 µg/L in all 10 groundwater samples, ranging in concentrations from 12,300 µg/L to 163,000 µg/L. Concentrations of total lead exceeded the action level of 15 µg/L in 9 of the 10 groundwater samples, with results ranging from 25.2 µg/L to 1,150 µg/L. Concentrations of total manganese exceeded the tapwater RBC of 730 µg/L in 5 of the 10 groundwater samples, with results ranging from 1,450 µg/L to 4,810 µg/L (Ref. 4).

Although constituents were detected in samples collected as part of the Level II Survey, the concentrations of the constituents were attributed to natural conditions in the area, impacts from

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surface water runoff from adjacent properties and streets, and from non-hazardous materials previously disposed on the property (Ref. 4).

No previous investigations have been conducted in the residential portion of the Site. EPA received complaints from concerned citizens regarding the historical use of the surrounding area as a waste dump for landfill material and laboratory equipment, as well as the use of potentially contaminated fill material during construction of the housing development. EPA has been requested to conduct an investigation to determine whether hazardous substances may be present on the Site.

3.0 SOURCE DESCRIPTION AND CHARACTERISTICS

It has been alleged that potentially contaminated material from areas excavated when the Walt Whitman Bridge was constructed was used as fill material during construction of the houses in the lower Norwood neighborhood. Additionally, it has been alleged that the undeveloped areas surrounding the residential neighborhood have been used as a waste dump, potentially for landfill material and laboratory supplies and equipment, and may contain hazardous substances. On April 12, 2017, WESTON personnel conducted a site reconnaissance of the property. Access to the entire Site was limited because of dense brush and limited access points. Miscellaneous trash was observed at various locations throughout the undeveloped portion of the Site.

4.0 GROUNDWATER MIGRATION PATHWAY

This section describes the Site’s geologic and hydrogeologic setting, presents the targets associated with the groundwater migration pathway, and presents conclusions that can be made regarding the groundwater migration pathway.

4.1 REGIONAL AND SITE GEOLOGY

The Site is located in the Lowland and Intermediate Upland Section of the Atlantic Coastal Plain Physiographic Province, which is characterized by a flat upper terrace surface underlain by unconsolidated to poorly consolidated sand and gravel with dendritic drainage patterns. These deposits rest upon bedrock comprising schist, gneiss, and other metamorphic rocks (Ref. 5). The bedrock of the Coastal Plain contains poorly exposed Cretaceous and Tertiary sediments that are interlayered with series of sands, clays, and gravels that range in thickness from 0 feet to over 200

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feet (Ref. 6). The Cretaceous and Tertiary sediments are overlain by Quaternary sediments, which are composed of Pleistocene deposits and Holocene deposits. The Pleistocene deposits are characterized by series of interlayered sands, clays, and gravels ranging in thickness from 0 feet to 80 feet. The Holocene deposits are characterized by organic rich mud, silt, and fine sand that range in thickness from less than 10 feet to approximately 80 feet (Ref. 6). The Lowland and Intermediate Upland Section of the Coastal Plain Province has very low relief, with ground elevations ranging from 0 feet to approximately 200 feet (Ref. 5).

Near the Site, the Holocene deposits are underlain by the Quaternary age Trenton Gravel formation (Ref. 6). The Trenton Gravel formation is primarily composed of gray or pale reddish-brown unconsolidated alluvial sand and clay that is approximately 30 feet thick (Ref. 7). Near the Site, the Trenton Gravel formation overlies the Raritan Formation (Ref. 8).

4.2 REGIONAL AND SITE HYDROGEOLOGY

The yields of wells in the Trenton Gravel formation range from 8.0 to 200 gallons per minute; the median is 50 gallons per minute.

Although this is the highest median yield of any of the water-bearing rock units in the county, the gravel should not be considered a major water source because it is generally too thin and discontinuous in most areas (Ref. 8). The Raritan Formation is approximately 100 feet thick and is a very high-yielding aquifer; however, it thins rapidly to the southwest and is present under a very small area of the county. The Raritan Formation is not tapped by wells in Delaware County (Ref. 8).

4.3 GROUNDWATER TARGETS

Potential groundwater targets include persons who obtain drinking water from private domestic wells within the 4-mile radius target distance limit (TDL) of the Site and persons supplied drinking water from public water suppliers whose water source is from groundwater wells within the 4-mile TDL.

The primary public water supplier serving persons within a 4-mile TDL is Aqua Pennsylvania Water Company (Aqua Pennsylvania). The primary sources of water for Aqua Pennsylvania include 8 surface water intakes and 28 groundwater wells (Refs. 9 and 15). There are no supply

July 2017 Page 6 TDD NO. WS05-17-03-001 DOCUMENT CONTROL NO. W0146.1A.02089 Norwood Landfill Final Preliminary Assessment Report wells for Aqua Pennsylvania located within the 4-mile TDL; therefore, persons served through this supply network will not be considered as targets as part of this PA (Ref. 10).

Based on the Pennsylvania Groundwater Information System (PaGWIS) database search, nine domestic wells were identified within the 4-mile radius TDL, as shown on Figure 3 (Appendix A), 4-Mile Radius Map with Distance Rings (Ref. 10). The majority of the wells appear to be owned by businesses, and one well is owned by Upper Darby Township (Ref. 10). Upper Darby Township is supplied potable water by the Aqua Pennsylvania main system; therefore, the use of the well identified in PaGWIS is not for public supply (Refs. 10 and 11). These wells range in depth from 95 feet to 600 feet, and only one well is completed in the Trenton Gravel formation. The remainder of the wells are completed in the Wissahickon Formation, Pennsauken Formation, or the Gabbro/Gabbroic Gneiss Formation. Using the U.S. Census Bureau persons-per-household value of 2.65 for Delaware County, approximately 24 persons rely on private domestic wells within the 4-mile TDL (Ref. 12). No public supply wells were identified within the 4-mile TDL radius.

Table 1 below provides a summary of domestic wells within 4 miles of the Site and the population served.

TABLE 1 DRINKING WATER WELLS WITHIN A 4-MILE RADIUS OF THE SITE

Radial Domestic Population Population Total Population Distance Public Supply Wells Wells Served Served Served (miles) 0.00 to 0.25 0 0 0 0 0 0.25 to 0.50 0 0 0 0 0 0.50 to 1.0 0 0 0 0 0 1.0 to 2.0 0 0 0 0 0 2.0 to 3.0 4 11 0 0 11 3.0 to 4.0 5 13 0 0 13 Total 9 24 0 0 24

Ref. 10

4.4 GROUNDWATER CONCLUSIONS

Groundwater samples were not collected as part of this PA. Shallow groundwater samples (3 to 6 feet below ground surface) were collected in 1999 from locations within the undeveloped portion

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of the Site. As previously discussed in Section 2.3, one VOC and six SVOCs, primarily polycyclic aromatic hydrocarbons (PAHs), were detected in several of the groundwater samples at concentrations exceeding the EPA RBC for tapwater. Additionally, concentrations of total aluminum, arsenic, iron, lead, and manganese also exceeded the tapwater RBC in several groundwater samples (Ref. 4). A background groundwater sample was not collected as part of that assessment.

Aqua Pennsylvania provides drinking water that is primarily sourced from surface water to residents in Delaware County. However, nine private domestic wells are present within a 4-mile radius of the Site that potentially provide drinking water to approximately 24 persons.

5.0 SURFACE WATER MIGRATION PATHWAY

This section describes the Site’s hydrologic setting, presents targets associated with the surface water migration pathway, and presents conclusions made regarding the surface water migration pathway.

5.1 HYDROLOGIC SETTING

The Site is located on the Lowland and Intermediate Upland Section of the Atlantic Coastal Plain Physiographic Province and is characterized by flat terrain with low relief ranging from 0 to 200 feet high. The surface is well draining in a dendritic pattern (Ref. 5). The Site is bordered by Darby Creek to the south, which flows for approximately 2.25 miles to the west/southwest before converging with the Delaware River. Muckinipattis Creek, which is located approximately 0.11 mile to the east of the Site and flows into Darby Creek at the southeast corner of the Site. The 15-mile downstream TDL is shown on Figure 4 (Appendix A).

The Site is situated in the Darby Creek watershed and is part of the Delaware River Basin (Refs. 13 and 14). Portions of the Site consist of fully developed urban properties surrounded by undeveloped areas that are overgrown with brush and trees. Surface water runoff in the developed portions of the Site would most likely flow to storm drains along E. Winona Avenue and Essex Road. The ground surface is relatively flat near the Site; therefore, surface water runoff in the undeveloped portions of the Site would most likely percolate into the ground or run off into Darby Creek.

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5.2 SURFACE WATER TARGETS

The primary public water supplier near the Site is the Aqua Pennsylvania. Aqua Pennsylvania sources water from 8 surface water intakes and 28 groundwater wells and provides drinking water to approximately 820,000 persons in Montgomery, Chester, and Delaware Counties (Ref. 15). One of the surface water intakes is located (b) (9) therefore, it is not located along the 15-mile TDL. Persons served through this supply network are not potential targets associated with the surface water migration pathway.

Muckinipattis Creek and Darby Creek are state-protected for the maintenance and propagation of fish species and additional flora and fauna that are indigenous to a warm water habitat. The creeks are also protected for the passage, maintenance, and propagation of anadromous and catadromous fishes and other fishes that move to or from flowing waters to complete their life cycle in other waters (Ref. 14).

As shown on Figures 1, 3, and 4 (Appendix A), John Heinz National Wildlife Refuge is located across Darby Creek from the Site. Fourteen state-designated endangered species, 4 state- designated threatened species, 1 federally-designated endangered species, and 1 federally- designated threatened species are known to exist within Delaware County (Ref. 16). According to the Pennsylvania Fish and Boat Commission, there are two access points for boats along the 15- mile TDL (Ref. 17). Additionally, a floating dock was observed on the Muckinipattis Creek during the site visit in April 2017. Based on the presence of several access points to the waterways near the Site, it is assumed that recreational fishing occurs within the 15-mile TDL. Approximately 1.14 miles of wetlands are located along Darby Creek with an additional 7.28 miles of wetland frontage located along the TDL in the Delaware River (Ref. 18).

5.3 SURFACE WATER CONCLUSIONS

Surface water and sediment samples were not collected as part of this PA. Surface water and sediment samples were collected from Darby Creek in 1999 from locations adjacent to and downstream of the Site. As discussed in Section 2.3, several SVOCs, primarily PAHs, were detected in one surface water sample at concentrations above the EPA tapwater RBC, which was

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used to compare the data. PAHs, arsenic, and lead were also detected in sediment samples at concentrations exceeding the EPA RBC for industrial soil (Ref. 4).

For this PA report, the 1999 surface water and sediment sample analytical results were compared to EPA BTAG freshwater screening criteria as shown on Tables 1 and 2 in Appendix B (Ref. 20). As shown in Table 1 in Appendix B, one surface water sample, SW-4, contained a concentration of carbon disulfide of 2.7 µg/L, which exceeds the BTAG screening criteria of 0.92 µg/L. Concentrations of several PAHs, benzo(a)anthracene, benzo(a)pyrene, fluoranthene, phenanthrene, and pyrene, exceeded their respective BTAG screening criteria in sample SW-4. Estimated concentrations of fluoranthene and pyrene also exceeded BTAG screening values in sample SW-5. Concentrations of total aluminum, barium, and iron in all six surface water samples exceeded their respective BTAG screening criteria of 87 µg/L, 4 µg/L, and 300 µg/L at concentrations ranging from 181 µg/L to 2,000 µg/L; 28.6 µg/L to 90.1 µg/L; and 937 µg/L to 7,290 µg/L, respectively. Sample SW-2 also contained concentrations of total calcium (383,000 µg/L), total copper (9.8 µg/L), and total zinc (134 µg/L) exceeding their respective BTAG screening criteria of 116,000 µg/L, 9 µg/L, and 120 µg/L. Concentrations of total lead were detected in five of the six surface water samples ranging from 2.8 µg/L to 11.2 µg/L. The detected concentrations exceeded the lead BTAG screening criterion of 2.5 µg/L.

As shown in Table 2 in Appendix B, carbon disulfide was detected in four of the seven sediment samples exceeding the BTAG freshwater screening criterion of 0.85 µg/kg at concentrations ranging from 3.2 µg/kg to 23 µg/kg. Numerous SVOCs, particularly PAHs, were detected in five of the seven samples at concentrations exceeding the BTAG criteria, with sample SE-2 containing the highest concentrations. PCBs were detected in four of the seven sediment samples at concentrations ranging from 200 µg/kg to 540 µg/kg, which exceed the BTAG criteria of 59.8 µg/kg. Several pesticides, including 4,4-dichlorodiphenyldichloroethane (4,4-DDD), 4,4- dichlorodiphenyltrichloroethane (4,4-DDT), and 4,4-dichlorodiphenyldichloroethylene (4,4- DDE), were detected in four of the seven sediment samples at concentrations exceeding the BTAG criteria. Numerous metals, including arsenic, cadmium, chromium, copper, iron, lead, manganese, mercury, nickel, and zinc were detected in the majority of the samples at concentrations exceeding applicable BTAG criteria.

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As previously discussed in Section 2.3, it is unclear from the 1999 Level II Survey Report the exact locations of the sediment samples; therefore, it is unclear if a suitable background sample was collected as part of this investigation.

Areas of alleged disposal and sediment fill material from the Delaware River directly border Muckinipattis Creek and Darby Creek. There are no drinking water targets associated with the surface water migration pathway. Access to the creeks is unrestricted, with public access for recreational purposes, including fishing along Darby Creek. Potential targets associated with the surface water migration pathway include the Muckinipattis Creek and Darby Creek as fisheries, 14 state-designated endangered species, 4 state-designated threatened species, 1 federally-designated endangered species, and 1 federally-designated threatened species, John Heinz National Wildlife Refuge, and 8.42 miles of wetland frontage located along the 15-mile TDL.

6.0 SOIL EXPOSURE AND AIR MIGRATION PATHWAYS

This section provides information regarding the physical conditions of the Site and targets associated with the soil exposure and air migration pathways.

6.1 PHYSICAL CONDITIONS

The Site consists of a residential area located in a lower Norwood neighborhood and the surrounding property located between E. Winona Avenue and Darby Creek. The residential portion of the Site consists of paved roads and individual residential houses. The portion of the Site surrounding the neighborhood where alleged dumping occurred is undeveloped and overgrown with heavy brush and trees. Access to the undeveloped portion of the Site is limited because it is located behind private property and bordered by Darby Creek to the south. According to the Delaware County Parcel Map, there are two right of way access points to the undeveloped portion of the Site (Ref. 3).

6.2 SOIL AND AIR TARGETS

It has been alleged that potentially contaminated material from areas excavated when the Walt Whitman Bridge was constructed was used as fill material during construction of the houses in the

July 2017 Page 11 TDD NO. WS05-17-03-001 DOCUMENT CONTROL NO. W0146.1A.02089 Norwood Landfill Final Preliminary Assessment Report lower Norwood neighborhood and that the undeveloped areas surrounding the residential neighborhood have been used as a waste dump; therefore, residents who reside in the lower Norwood neighborhood are potential targets located on and within 200 feet of potential contamination. No schools or daycare centers are located on the Site or within 200 feet of potential source areas. Amosland Park is located approximately 1,000 feet to the north of the Site. John Heinz National Wildlife Refuge is approximately 1,130 feet south of the Site, across Darby Creek. Norwood Elementary School is located approximately 1,700 feet to the northwest. The estimated population and wetland acreage within a 4-mile radius of the Site are summarized below in Tables 2 and 3 (Refs. 18 and 19). Fourteen state-designated endangered species, 4 state-designated threatened species, 1 federally-designated endangered species, and 1 federally-designated threatened species are known to exist within Delaware County (Ref. 16).

TABLE 2 ESTIMATED POPULATION WITHIN A 4-MILE RADIUS OF THE SITE

Radial Distance from Site (miles) Population (number of persons) 0.00 - 0.25 764 >0.25 - 0.50 2,521 >0.50 - 1.0 10,667 >1.0 - 2.0 41,090 >2.0 - 3.0 57,454 >3.0 - 4.0 85,818 Total 198,315 Ref. 19

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TABLE 3 WETLAND ACREAGE WITHIN A 4-MILE RADIUS OF THE SITE

Radial Distance from Site (miles) Wetlands (acreage) 0.00 - 0.25 6.13 >0.25 - 0.50 89.68 >0.50 - 1.0 190.19 >1.0 - 2.0 510.62 >2.0 - 3.0 190.33 >3.0 - 4.0 236.41 Total 1,223.36 Ref. 18

6.3 SOIL EXPOSURE AND AIR MIGRATION PATHWAY CONCLUSIONS

Soil samples were not collected as part of this PA; however, 21 surface soil samples were collected as part of the Level II Survey in 1999 from locations on the undeveloped portion of the Site. As discussed in Section 2.3 of this report, 4 constituents, benzo(a)pyrene (11 samples), PCBs (4 samples), arsenic (20 samples), and lead (4 samples), were detected in surface soil samples at concentrations that exceeded EPA residential RBCs and the lead action level (Ref. 4). Background soil samples were not collected as part of that assessment.

Potential targets associated with the soil exposure and air migration pathway include the residents who reside in the lower Norwood neighborhood where potentially contaminated sediment was used for fill prior to building the neighborhood and where portions of the area were allegedly used as a waste dump as well as the entire population located within a 4-mile radius of the Site (198,315 persons) (Ref. 19). Additional targets include the John Heinz National Wildlife Refuge located approximately 1,130 feet south of the Site, across Darby Creek; 14 state-designated endangered species, 4 state-designated threatened species, 1 federally-designated endangered species, and 1 federally-designated threatened species, which are known to exist within Delaware County; and 1,223 acres of wetlands within the 4-mile TDL.

7.0 SUMMARY AND CONCLUSIONS

It has been alleged that potentially contaminated material from areas excavated when the Walt Whitman Bridge was constructed was used as fill material during construction of the houses in the

July 2017 Page 13 TDD NO. WS05-17-03-001 DOCUMENT CONTROL NO. W0146.1A.02089 Norwood Landfill Final Preliminary Assessment Report lower Norwood neighborhood and that the undeveloped areas surrounding the residential neighborhood have been used as a waste dump. An investigation was conducted in 1999 that included the collection of surface and subsurface soil samples from the undeveloped portion of the Site, shallow groundwater samples from monitoring wells, and surface water and sediment samples from Darby Creek. Surface soil samples showed the presence of benzo(a)pyrene, PCBs, arsenic, and lead at concentrations that exceed applicable EPA residential RBCs. However, a background soil sample was not collected. One VOC and six SVOCs, primarily PAHs, were detected in several of the groundwater samples at concentrations exceeding the EPA RBC for tapwater. Additionally, concentrations of total aluminum, arsenic, iron, lead, and manganese also exceeded the tapwater RBC in several groundwater samples. Several PAHs and metals were detected in the surface water samples at concentrations that exceed the EPA BTAG freshwater screening criteria and numerous SVOCs, particularly PAHs, and metals were detected in the sediment samples at concentrations exceeding the BTAG values.

There are limited targets associated with the groundwater migration pathway. The majority of persons within the 4-mile TDL are provided potable water from Aqua Pennsylvania, which draws source water from 8 surface water intakes and 28 groundwater wells, none of which are located within the 4-mile TDL. Approximately 9 domestic wells supply water to approximately 24 persons within the 4-mile TDL.

There are no drinking water targets associated with the surface water migration pathway. The primary water supplier, Aqua Pennsylvania, does not maintain a surface water intake along the 15- mile TDL. Potential targets associated with the surface water migration pathway include the Muckinipattis Creek and Darby Creek as fisheries, 14 state-designated endangered species, 4 state- designated threatened species, 1 federally-designated endangered species, and 1 federally- designated threatened species, the John Heinz National Wildlife Refuge, and the miles of wetland frontage located along the 15-mile TDL. Areas of alleged disposal and sediment fill material from the Delaware River directly border Muckinipattis Creek and Darby Creek. Access to the creeks is unrestricted, with public access for recreational purposes, including fishing along Darby Creek.

Potential targets associated with the soil exposure and air migration pathway include residents of the lower Norwood neighborhood where potentially contaminated sediment was used for fill prior

July 2017 Page 14 TDD NO. WS05-17-03-001 DOCUMENT CONTROL NO. W0146.1A.02089 Norwood Landfill Final Preliminary Assessment Report

to building the neighborhood and where portions of the area were allegedly used as a waste dump, as well as the entire population located within a 4-mile radius of the site (198,315 persons). Additional targets include the John Heinz National Wildlife Refuge located approximately 1,130 feet south of the Site, across Darby Creek; 14 state-designated endangered species, 4 state- designated threatened species, 1 federally-designated endangered species, and 1 federally- designated threatened species known to exist within Delaware County; and 1,223 acres of wetlands within the 4-mile TDL.

July 2017 Page 15 TDD NO. WS05-17-03-001 DOCUMENT CONTROL NO. W0146.1A.02089 Norwood Landfill Final Preliminary Assessment Report

8.0 REFERENCES

1. U.S. Environmental Protection Agency. 1991. Guidance for Performing Site Preliminary Assessments Under CERCLA. Hazardous Site Evaluation Division, Office of Solid Waste and Remedial Response, Washington, DC. September.

2. Google. 2017. Norwood Borough, PA. Google Maps. Available: https://www.google.com/maps/place/39%C2%B052'55.8%22N+75%C2%B017'29.0%22 W/@39.8821556,- 75.2935887,17z/data=!3m1!4b1!4m5!3m4!1s0x0:0x0!8m2!3d39.8821556!4d-75.2914

3. Delaware County, Pennsylvania. 2017. Delaware County Real Estate Parcels & Tax Records System and Homestead Status – Folio# 31-00-00609-03. Available: w01.co.delaware.pa.us/pa/publicaccess.asp?UAYN=Y&real.x=0 Accessed: April 13, 2017 and May 10, 2017.

4. Program Management Company. 1999. Site Sampling Survey John Heinz National Wildlife Refuge, Tinicum, Pennsylvania. Exton, Pennsylvania. June.

5. Pennsylvania Department of Conservation and Natural Resources. 2000. Physiographic Provinces of Pennsylvania. Bureau of Topographic and Geologic Survey. Fourth Edition.

6. Low, Dennis J., Daniel J. Hippe, and Dawna Yannacci. 2002. Geohydrology of Southeastern Pennsylvania. Water-Resources Investigations Report 00-4166. U.S. Geological Survey. New Cumberland, Pennsylvania.

7. Geyer, Alan and Peter J. Wilshusen. 1982. Engineering Characteristics of the Rocks of Pennsylvania. Environmental Geology Report 1. Pennsylvania Department of Environmental Resources Bureau of Topographic and Geologic Survey. Harrisburg, Pennsylvania.

8. Balmer, Wayne T. and Drew K. Davis. 1996. Groundwater Resources of Delaware County, Pennsylvania. Water Resource Report 66. Pennsylvania Geological Survey, Fourth Series. Harrisburg, Pennsylvania.

9. Aqua Pennsylvania, Inc. 2016. 2016 Water Quality Report, Main System, PWSID#: PA1460073.

10. Pennsylvania Department of Conservation and Natural Resources. 2017. Pennsylvania Groundwater Information System Database. Bureau of Topographic and Geological Survey. Available: www.dcnr.state.pa.us/topogeo/groundwater/pagwis/index.htm Accessed: April 26, 2017.

11. Aqua Pennsylvania, Inc. 2017. Available: https://www.aquaamerica.com/customer- service-center/water-quality.aspx?ZpCode=19082&submit=Go+%E2%80%BA Accessed: June 28, 2017.

July 2017 Page 16 TDD NO. WS05-17-03-001 DOCUMENT CONTROL NO. W0146.1A.02089 Norwood Landfill Final Preliminary Assessment Report

12. U.S. Department of Commerce. 2012. State and County Quickfacts. U.S. Census Bureau. Available: https://www.census.gov/quickfacts/fact/table/delawarecountypennsylvania,US/PST04521 6

13. Delaware County Conservation District. 2017. Darby Creek. Available: http://www.delcocd.org/darby-creek/ Accessed: May 30, 2017.

14. Pennsylvania Code. 2017. Delaware River Basin in Pennsylvania. Delaware River. Chapter 93. Section 9g. Drainage List g. Available: http://www.pacode.com/secure/data/025/chapter93/s93.9f.html Accessed: May 30, 2017.

15. Pennsylvania Department of Environmental Protection, Bureau of Water Supply Management. 2005. Source water Assessment Public Summary. Aqua Pennsylvania Water Company – Main System, PWSID #1460073. July.

16. Pennsylvania Natural Heritage Program. 2017. Species of Special Concerns Lists for Delaware County. Available: http://www.naturalheritage.state.pa.us/Species.aspx Accessed: June 2, 2017.

17. Pennsylvania Fish and Boat Commission. 2017. County Guide. Available: http://pfbc.maps.arcgis.com/apps/webappviewer/index.html?id=3292981a1fcf415e9ce4a 4a7a3ce98e2 Accessed: June 2, 2017.

18. (b) (4) 2017. Weston Solutions, Inc. (WESTON®). Project Note to Norwood Landfill file: Wetland Frontage Located Along the 15-Mile Surface Water Pathway Target Distance Limit (TDL). April 26, 2017.

19. (b) (4) 2017. Weston Solutions, Inc. (WESTON®). Project Note to Norwood Landfill file: Population Analysis for Norwood Landfill Site. April 26, 2017.

20. U.S. Environmental Protection Agency. 2006. Biological Technical Assistance Screening Values. July 2006. Available: https://www.epa.gov/risk/biological-technical-assistance- group-btag-screening-values

July 2017 Page 17 TDD NO. WS05-17-03-001 DOCUMENT CONTROL NO. W0146.1A.02089 Norwood Landfill Final Preliminary Assessment Report

APPENDIX A FIGURES

Site Location kj

Norwood Landfill Site Norwood, Delaware County, PA USGS 7.5 Minute Quadrangle Pennsylvania Landsdowne, Pa. 1974.

New Jersey Coordinate System: Figure 1 WGS84 UTM Zone 18N Feet Site Location Map Maryland Delaware ´ 0 2,000 TDD#: W503-17-03-001 Feet Contract: EP-S3-15-02 Prepared: 6/30/2017 File: Y:\EPA_Region_III\Norwood_Landfill\MXD\Site_Location.mxd, 6/30/2017 10:52:30 AM, johna Legend jk Norwood Landfill Site $1 1999 USFWS Level 2 Survey Sample Locations Parcel Boundary

Data Sources Imagery: ESRI, Bing Mapping Service Shapefiles: US Fish and Wildlife Service

Coordinate System: WGS 1984 UTM Zone 18N Linear Unit: Foot US

Datum: WGS 1984

0 150 300 ´ Feet

Norwood Landfill Site Norwood, Delaware County, PA

Figure 2 Site Layout Map

TDD#: W503-17-03-001 Contract: EP-S3-15-02 Prepared: 6/30/2017 File: Y:\EPA_Region_III\Norwood_Landfill\MXD\Level2_Survey.mxd, 6/30/2017 11:19:34 AM, johna !? Legend !?!? jk Norwood Landfill Site !? Domestic Wells !? )" Surface Water Intake NWI Wetlands Distance Buffers 0.25 Miles 0.5 Miles 1 Miles !? !? !? 2 Miles 3 Miles 4 Miles

Notes: NIW- National Wetlands Inventory !? !?

jk (b) (9)

Data Sources Imagery: USGS 7.5-Minute Series Topogrpahic Quadrangles Shapefiles: Weston generated

Coordinate System: WGS 1984 UTM Zone 18N Linear Unit: Foot US

Datum: WGS 1984

0 2,200 4,400 ´ Feet

Norwood Landfill Site Norwood, Delaware County, PA Figure 3 4-Mile Radius Map with Distance Rings TDD#: W503-17-03-001 Contract: EP-S3-15-02 Prepared: 6/30/2017 File: Y:\EPA_Region_III\Norwood_Landfill\MXD\4Mile_distance_rings.mxd, 6/30/2017 2:40:24 PM, johna Norwood Landfill Site

^_^_

*#

Probable Point of Entry

*#2

*#3

*#4

*#5

*#6

*#7

*#8

*#9

*#10

*#11

Figure 4 *#12 15-Mile Downstream Surface Water Pathway Map Norwood Landfill Site Norwood, Delaware County, PA

Legend *#13 ^_ Norwood Landfill Site ^_ Probable Point of Entry *# 15-Mile Marker Fifteen Mile Surface Water Pathway *#14 NWI Wetlands

Note: NWI - National Wetlands Inventory

Wetlands data from the U.S. Fish & Wildlife Service wetlands geodatabase website: *#15 http://www.fws.gov/wetlands/Data/DataDownload.html Reference 49 of the HRS documentation record). ®

0 1,125 2,250 4,500 6,750 9,000

Feet

0 0.275 0.55 1.1

Miles

SOURCE: USGS 7.5 Minute Series (Topographic) Quadrangles: Bridgeport NJ/PA, 1970; Landsdowne, PA, 1974; Marcus Hook, PA/NJ/DE, 1970; Penns Grove, NJ/DE, 1970.

TDD#: W503-17-03-001 Contract: EP-S3-15-02 Date: 6/30/2017 Copyright:© 2013 National Geographic Society, i-cubed

File: Y:\EPA_Region_III\Norwood_Landfill\MXD\15Mile_Rev06302017.mxd, 6/30/2017 3:21:18 PM, johna Norwood Landfill Final Preliminary Assessment Report

APPENDIX B TABLES

Table 1 Norwood Landfill 1999 USFWS Analytical Data Surface Water Samples

EPA BTAG Freshwater (µg/L) Sample Number: SW-1 SW-1 Dis SW-2 SW-4 SW-4 Dis SW-5 SW-5 Dis SW-6 SW-6 Dis SW-7 SW-7 Dis Units: µg/L µg/L µg/L µg/L µg/L µg/L µg/L µg/L µg/L µg/L µg/L VOC/SVOC Result Q Result Q Result Q Result Q Result Q Result Q Result Q Result Q Result Q Result Q Result Q Carbon disulfide 0.92 2.7 J Benzo(a)anthracene 0.018 0.5 J Benzo(a)pyrene 0.015 0.2 J Benzo(b)fluoranthene NL 0.3 J bis(2-ethylhexyl)phthalate 16 2.2 J Chrysene NL 0.3 J Fluoranthene 0.04 0.6 J 0.3 J Phenanthrene 0.4 0.5 J Pyrene 0.025 0.5 J 0.2 J

EPA BTAG Freshwater (µg/L) METALS Result Q Result Q Result Q Result Q Result Q Result Q Result Q Result Q Result Q Result Q Result Q ALUMINUM 87 714 181 J 2000 631 398 708 BARIUM 4 46.9 J 38.1 J 46.5 J 50.6 J 29.8 J 90.1 J 65.8 J 39.9 J 31.9 J 38 J 28.6 J CALCIUM 116000 23400 22600 383000 20100 21200 33200 330000 21200 20600 20800 20600 CHROMIUM, TOTAL 85 1.3 J 4.7 J 1.6 J COBALT 23 2 J 1.7 J 1.4 J 0.99 J COPPER 9 6.1 J 9.8 J 8.5 J 4.1 J IRON 300 1610 210 7220 3760 7290 287 937 49.7 J 1250 LEAD 2.5 5.6 11.2 4.6 2.8 J 4.3 MAGNESIUM 82,000 8850 8380 10100 7610 7600 10600 10500 7730 7400 7580 7350 MANGANESE 120 206 147 569 327 16.4 1010 750 174 30 97.6 1.2 J NICKEL 52 3.1 J 1.5 J 6.3 J 4.6 J 1.6 J 3.6 J 2.7 J 3 J 1.4 J 3.5 J 1.7 J POTASSIUM 53,000 2450 J 2280 J 4820 J 2420 J 2260 J 2850 J 2700 J 2450 J 2290 J 2240 J 2100 J SODIUM 680,000 21400 20700 15100 18700 20600 21100 21400 19400 18700 20200 20000 VANADIUM 20 4.2 J 1.8 J 7 J 3.5 J 2.7 J 4 J ZINC 120 134 64.5 11.4 J 28.9 J 11.7 J 28.7 J 18.6 J 33.1 10.7 J Notes: Data compared to EPA BTAG freshwater screening criteria Bold value indicates exceedance of BTAG criteria Shaded cells indicate compounds not analyzed µg/L = Micrograms per liter Biological Technical Assistance Group J = Reported value is estimated; actual value may be higher or lower NL = No listed value Q = Qualifier Table 2 Norwood Landfill 1999 USFWS Analytical Data Sediment Samples

Sample Number:EPA BTAG SE-1 SE-2 SE-3 SE-4 SE-5 SE-6 SE-7 Units:Freshwater (µg/kg) µg/kg µg/kg µg/kg µg/kg µg/kg µg/kg µg/kg VOC/SVOC Result Q Result Q Result Q Result Q Result Q Result Q Result Q 2-Butanone NL 71 22 130 Acetone NL 98 44 310 140 100 150 780 Carbon disulfide 0.85 3.2 J 6.7 J 11 23 Toluene NL 4.1 J 1,2-Dichlorobenzene 16 56 1,4-Dichlorobenzene 599 17 J 94 J 22 J 2-Methylnaphthalene NL 220 J 280 J 190 J 73 J 58 J 4-Chloroaniline NL 38 J 4-Methylphenol 670 290 J 58 J 120 J 37 J 55 J Acenaphthene 6.7 90 J 2500 77 J 38 J 84 J Acenaphthylene 5.9 310 J 190 J 220 J 49 J 90 J Anthracene 57.2 330 J 6500 260 J 190 J 250 J Benzo(a)anthracene 108 1000 14000 720 480 850 Benzo(a)pyrene 150 1200 13000 800 400 910 Benzo(b)fluoranthene 190 1600 21000 1100 480 1400 Benzo(g,h,i)perylene 170 670 J 3200 510 J 150 J 380 J Benzo(k)fluoranthene 240 700 8100 420 210 600 bis(2-Chloroethyl)ether NL 21 J bis(2-Ethylhexyl)phthalate 180 170 J 610 J 3200 1400 Carbozole NL 150 J 4000 24 J 120 J Chrysene 166 1500 17000 1100 J 530 J 1200 Dibenz(a,h)anthracene 33 200 900 150 62 J 120 Dibenzofuran 415 100 J 1500 J66J73J 47J Fluoranthene 423 1900 39000 1400 J 780 2000 Fluorene 77.4 190 J 3400 130 J 89 J 100 J Indeno(1,2,3-cd)pyrene 17 690 4000 500 180 450 Naphthalene 176 340 J 440 J 210 J 110 J 79 J Phenanthrene 204 850 31000 680 J 410 J 920 Phenol 420 110 J 110 J 57 J Pyrene 195 1900 32000 1700 700 1800

EPA BTAG Pesticides/PCBs Freshwater (µg/kg) µg/kg µg/kg µg/kg µg/kg µg/kg µg/kg µg/kg 4,4-DDD 4.8 77 P* 36 P* 35 4,4-DDE 3.16 220 67 120 140 4,4-DDT 4.16 58 Aroclor-1242 59.8 380 P* Aroclor1248 59.8 200 540 Aroclor-1260 59.8 510 260 270 350 Chlordane 3.24 660 220 240 Dieldrin 1.9 60 +

EPA BTAG METALS Freshwater (mg/Kg) mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg mg/Kg Aluminum NL 18700 2210 16200 16600 14000 10500 22300 Antimony 2 5.4 Arsenic 9.8 32.3 2.3 22 9.1 10 10.8 24.6 Barium NL 209 36 J 197 117 166 335 243 beryllium NL 1.3 0.14 J 1.4 1.1 1 0.71 J 1.8 Cadmium 0.99 1.9 J 0.18 J 3 1.2 J 0.67 J 4.4 Calcium NL 3650 120200 2940 2000 3730 2450 4520 Chromium 43.4 93.5 15.6 132 70.8 58.1 42.6 210 Cobalt 50 18.8 J 2.5 J 14.5 J 16.2 J 12.3 J 10.3 J 30.7 J Copper 31.6 161 44 108 36 84.8 77.8 153 Iron 20,000 27000 13900 33300 27100 34400 54400 41500 Lead 35.8 814 32.8 234 56.9 152 240 360 Magnesium NL 4280 60500 4120 4520 4340 3080 4870 Manganese 460 301 160 407 752 706 630 373 Mercury 0.18 0.97 0.03 J 0.98 0.59 0.39 0.52 0.96 Nickel 22.7 43.5 13.8 49 26.7 29.6 23 145 Potassium NL 1350 J 718 J 1590 J 1750 J 1760 J 1140 J 1630 J Selenium 2 2.8 3.9 J Silver 1 1.9 J 4.3 J Sodium NL 1420 J Vanadium NL 46.6 12.5 J 61.4 37 44.2 34.8 111 Zinc 121 723 126 496 113 354 365 714 Notes: Data compared to EPA BTAG freshwater screening criteria Bold values indicate exceedance of BTAG criteria µg/kg= Micrograms per kilogram BTAG = Biological Technical Assistance Group J = Reported value is estimated; actual value may be higher or lower mg/kg = milligrams per kilogram NL = No listed value P = Fr dual column analysis, the percent difference between the two columns is greater than 40% Q = Qualifier * = For dual column analysis, the lowest concentration is being reported due to interference