five- year review reportfive- year review report second five-year review report for del norte...

SFUND RECORDS CTR

2077070

Five- Year Review Report

Second Five-Year Review Report

for

Del Norte Pesticide Storage Area

Crescent City

Del Norte County, California

September 2005

PREPARED BY:

United States Environmental Protection Agency

Region IX

San Francisco, California

Date:

~ ~~s-

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Table of Contents

List of Acronyms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii

Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iv

Five-Year Review Summary Form . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v

I. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

II. Site Chronology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

III. Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3Physical Characteristics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3Land and Resource Use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3History of Contamination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4Basis for Taking Action . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

IV. Remedial Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5Remedy Selection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5Remedy Implementation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6System Operations/Operation and Maintenance (O&M) . . . . . . . . . . . . . . . . . . . . . . . . . . 7

V. Progress Since the Last Five-Year Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

VI. Five-Year Review Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8Administrative Components . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8Community Notification and Involvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9Document Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9Data Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10Site Inspection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11Interviews . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

VII. Technical Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13Question A: Is the remedy functioning as intended by the decision documents? . . . . . . 13Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedialaction objectives (RAOs) used at the time of the remedy selection still valid? . . . . . . . . 13Question C: Has any other information come to light that could call into questionthe protectiveness of the remedy? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14Technical Assessment Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

VIII. Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

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IX. Recommendations and Follow-up Actions . . . . . . . . . . . . . . . . . . . . . . . . . 15

X. Protectiveness Statement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

XI. Next Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

Tables

Table 1 - Chronology of Site EventsTable 2 - Historical Groundwater ConcentrationsTable 3 - Recent Groundwater Concentrations

Table 4 - IssuesTable 5 - Recommendations and Follow-up Actions

Attachments

Site MapsAttachment 1 - Map of AreaAttachment 2 - Map of Jack McNamara ParcelAttachment 3 - Extent of 1,2-DCP Concentrations > 5 ppbAttachment 4 - List of Documents ReviewedAttachment 5 - Photos Documenting Site ConditionsAttachment 6 - Site Inspection ChecklistAttachment 7 - Interview Documentation FormAttachment 8 - Evaluation of Ecological Risk

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List of Acronyms

1,2-DCP 1,2- Dichloropropane2,4-D 2,4- Dichlorophenoxyacetic acid:g/l micrograms per literAOC Administrative Order on ConsentARARs Applicable or Relevant and Appropriate RequirementsCCR Code of California RegulationsCD Consent DecreeCERCLA Comprehensive Environmental Response, Compensation, and Liability ActCFR Code of Federal RegulationsCIC Community Involvement CoordinatorDHS California Department of Health ServicesDTSC California Department of Toxic Substances ControlEPA Environmental Protection AgencyERCS Emergency Response Contract ServicesESD Explanation of Significant Differencesgpm gallons per minuteIC Institutional ControlMCLs Maximum Contaminant LevelsN/A Not ApplicableNCP National Oil and Hazardous Substances Pollution Contingency PlanNCRWQCB North Coast Regional Water Quality Control BoardNPL National Priorities ListO&M Operations and MaintenanceOSC On Scene CoordinatorOU Operable UnitP&T Pump and TreatPCOR Preliminary Closeout Reportppb parts per billionRA Remedial ActionRCRA Resource Conservation and Recovery ActRD Remedial DesignRI/FS Remedial Investigation/Feasibility StudyROD Record of DecisionSARA Superfund Amendments and Reauthorization Act of 1986RPM Remedial Project ManagerSSC State Superfund ContractTI Technical ImpracticabilityVOCs Volatile Organic Compounds

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Executive Summary

This is the second Five-Year Review of the Del Norte County Pesticide Storage AreaSuperfund site (Site) in Crescent City, Del Norte County, California. The results of the first Five-Year Review completed on September 26, 2000 indicate that although Institutional Controls(ICs) were not in place at the Site, the remedy was protective of human health and theenvironment. The purpose of this Five-Year Review is to assess the nature of any contaminationleft on-site and determine whether or not the remedy is protective of human health and theenvironment.

The August 29, 2000 Amendment to the Record of Decision (ROD Amendment)concluded that the groundwater plume was technically impracticable to remediate to cleanupgoals. A pump and treatment system that had been operating for approximately seven years wasno longer effective at reducing concentrations of the contaminant 1,2-Dichloropropane (1,2-DCP) and that 1,2-DCP levels remained stable whether or not the system was operating.Groundwater monitoring since the first Five-Year Review indicates that residual 1,2-DCP levelsremain above the Maximum Contaminant Level (MCL) of 5 micrograms per liter (:g/l). Exposure to the remaining on-site 1,2-DCP contamination, however, is being adequatelycontrolled by land and well use and development policies of the Del Norte County Department ofHealth and Social Services and Community Development Department. In accordance with aConsent Decree (CD) between EPA, the California Department of Toxic Substances Control(DTSC), and Del Norte County, a Covenant to Restrict Use of Property was recorded with DelNorte County on July 31, 2002 to further limit exposure to 1,2-DCP. This Covenant wasmistakenly recorded on only a portion of the Site area, parcel #120-020-36. The approximatelyone acre Site lies within adjacent parcel #110-010-22. The EPA attorney for this Site is currentlyworking with DTSC counsel and Del Norte County counsel to record the deed restriction asintended against the second of these parcels, parcel #110-010-22. The next Five-Year Reviewshould ensure that the Covenant is recorded on both parcels. The finding of this Five-YearReview is that Del Norte County policies, together with the existing Covenant and the plans torecord deed restrictions against the second parcel, are ensuring that the remedial actions at theSite are protective of human health and the environment.

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Five-Year Review Summary Form

SITE IDENTIFICATION

Site name (from WasteLAN): Del Norte Pesticide Storage Area

EPA ID (from WasteLAN): CAD000626176

Region: IX State: CA City/County: Cresc ent City/De l Norte C ounty

SITE STATUS

NPL status: G Final : Deleted G Other (specify)

Remediation status (choose all that apply): G Under Construction G Operating : Complete

Multiple OUs?* G YES : NO Construction completion date: 06/18/1992

Has Site been put into reuse? G YES : NO

REVIEW STATUS

Lead agen cy: : EPA G State G Tribe G Other Federal Agency

Author name: Yvonne Fong

Author title: Remedial Project Manager Author affiliation: U.S. EP A Reg ion IX

Review period:** 09/26/2000 to 09/08/2005

Dates of Site inspections: 06/13/2005 and 06/20/2005

Type of review: : Statutory

9 Policy (G Post-SARA G Pre-SARA G NPL-Removal onlyG Non-NPL Remedial Action Site G NPL State/Tribe-leadG Regional Discretion)

Review number: G 1 (first) : 2 (second) G 3 (third) G Other (specify)

Triggering action:

G Actual RA On-site Construction at OU #____ G Actual RA Start at OU#____

G Construction Completion : Previous Five-Year Review Report

G Other (specify)

Triggering action date (from WasteLAN): 09/26/2000

Due date (five years after triggering action date): 09/26/2005

* [“OU” refers to operable unit.]** [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN.]

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Five-Year Review Summary Form, cont’d.

Issues:

ICs were p art of the reme dy containe d in the 200 0 ROD Amend ment. Del N orte Cou nty took steps to

implemen t those contro ls by lodging a Covena nt to Restrict U se of Prop erty on July 31 , 2002. T he Cove nant,

however, does not include both parcels of land which comprise the Site. The July 31, 2002 Covenant was

found to apply solely to parcel #120-020-36. The Covenant should be lodged for both parcels #120-020-36

and #110-010-22.

Recommend ations and Follow-up Actions:

The CD between E PA, the Sta te and the C ounty was ente red by the C ourt on M arch 6, 20 02. The specific

controls that were adopted at the Site were to be listed in detail in this document. Del Norte County recorded a

Land U se Coven ant which pla ced restrictio ns on only a p ortion of the p roperty. N o land use re strictions are in

place for p arcel #11 0-010-2 2, which is the p arcel conta ining the Site. T he next Five-Y ear Review should

verify that the Covenant’s applicability has been corrected and that these controls have been put into practice

on both p arcels at the Site . Table 6 establishes a o ne year milesto ne date for a mending th e Coven ant to

Restrict Use. Subsequent to the lodging of a Covenant to Restrict Use on parcel #110-010-22, title searches

should be executed and a plan for the County to monitor compliance with the Covenants on both parcels #120-

020-36 and #11 0-010-2 2 should b e established .

Corrosion of the protective metal casings around the monitoring wells requires maintenance and

possibly replacement of the caps. The thick underbrush has begun to overgrow the footpaths to the wells and

should co ntinue to be c ut back as ne eded.

Protectiveness Statement:

The remedy at the Del Norte Pesticide Storage Area across the single OU currently protects human health and

the environment because there is no current exposure to the contamination that remains at the Site. However,

in order for the remedy to be protective in the long-term, a Land Use Covenant to Restrict Use of Property that

is applicab le to the entire S ite must be pu t in place to en sure long-term protectiven ess.

The plume has been stable since the groundwater treatment system was shut down in October 1997.

The extent of the original plume was believed to be about 12,000 square feet, reaching approximately 300 feet

south of the source. The nearest private well to the Site is over a quarter-mile from the source of the plume.

Due to the source removal, groundwater treatment systems, and subsequent natural attenuation, the plume has

decreased to approximately 5,000 square feet and 120 feet south of the source. Contamination levels have been

in gradual decline and are expected to continue to do so at a slow rate. Site contaminants have never been

detected in the surrounding residential wells, and there is no evidence that contamination has been introduced

since the last sam pling event.

Ecolog ical risks from the contamina ted ground water are co nsidered ins ignificant due to no comp lete

exposure pathways to e cological re ceptors (A ttachment 8 ).

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I. Introduction

The purpose of a Five-Year Review is to determine whether the remedy at a site isprotective of human health and the environment. The methods, findings, and conclusions ofreviews are documented in Five-Year Review Reports. In addition, Five-Year Review Reportsidentify issues found during the review, if any, and recommendations to address them.

The Agency is preparing this Five-Year Review pursuant to the ComprehensiveEnvironmental Response, Compensation, and Liability Act (CERCLA) and the National Oil andHazardous Substances Pollution Contingency Plan (NCP). CERCLA §121 states:

If the President selects a remedial action that results in any hazardous substances, pollutants, orcontaminants remaining at the site, the President shall review such remedial action no less oftenthan each five years after the initiation of such remedial action to assure that human health and theenvironment are being protected by the remedial action being implemented. In addition, if uponsuch review it is the judgment of the President that action is appropriate at such site in accordancewith section [104] or [106], the President shall take or require such action. The President shallreport to the Congress a list of facilities for which such review is required, the results of all suchreviews, and any actions taken as a result of such reviews.

The agency interpreted this requirement further in the NCP; 40 CFR §300.430(f)(4)(ii) states:

If a remedial action is selected that results in hazardous substances, pollutants, or contaminantsremaining at the site above levels that allow for unlimited use and unrestricted exposure, the leadagency shall review such action no less often than every five years after the initiation of the selectedremedial action.

The United States Environmental Protection Agency (EPA) Region IX has conducted aFive-Year Review of the remedial actions implemented at the Del Norte Pesticide Storage AreaSuperfund site (Site) in Crescent City, Del Norte County, California. The entire Site comprisesone Operable Unit (OU). This review was conducted from May 2005 through June 2005. Thisreport documents the results of the review.

The August 29, 2000 Amendment to the Record of Decision (ROD Amendment) alteredthe remedy originally selected in the September 30, 1985 Record of Decision (ROD). As a resultof the ROD Amendment, hazardous substances, pollutants, or contaminants were left on-site atlevels that would prohibit unlimited use and unrestricted exposure. This Five-Year Review istherefore required by statute because the remedy now allows contaminant levels in groundwaterto exceed the Maximum Contaminant Level (MCL) indefinitely. This is the second Five-YearReview for the Site. The triggering action for this statutory review is the signature date of theprevious Five-Year Review Report, as shown in EPA’s WasteLAN database: September 26,2000. The due date for this Five-Year Review Report has been met.

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II. Site Chronology

Table 1 lists the chronology of events for the Site.

Table 1: Chronology of Site Events

Event Date

Operation of the Del Norte Pesticide Storage Area 1970-1981

Initial discovery of problem by NCRWQCB 08/13/1981

EPA inspection reveals RCRA violations 09/25/1981

Cleanup and Abatement Order No. 81.213 issued by NCRWQCB 10/1981

DHS collects on-site soil samples 12/1981

Removal of 1,150 containers from the Site 01/1982

Shipment of 440 contaminated barrels to licensed recycler 04/1982

Final NPL listing 09/21/1984

Remedial Investigation/Feasibility Study complete 05/1985

ROD signature 09/30/1985

Removal of 290 cubic yards of contaminated soil 08/1987

RD complete 04/20/1988

EPA ascertains on-site chromium is naturally occurring 1985-1987

U.S. Army Corps of Engineers contracted to design Pump & Treat (P&T) system 05/1989

ESD (for presence of natural chromium) 09/21/1989

Construction of P&T system begins 10/25/1989

P&T system completed and operational 04/1990

DTSC assumes cost for 50% of RA under SSC 04/23/1990

PCOR/Construction Completion 06/18/1992

P&T system shut of f when contaminant concentra tions stabil ize 10/1997

AOC for cost recovery 05/11/1998

Proposed Plan for first Five-Year Review presented at community meeting 03/09/2000

ROD Amendment signature 08/29/2000

First Five-Year Review 09/26/2000

CD entered by Court 03/06/2002

Final Close-out Report 07/19/2002

Deletion from NPL 09/18/2002

Covenant to Restrict Use of Property Recorded with County 07/31/2002

Second Five-Year Review due 09/26/2005

Table 1: Chronology of Site Events

Event Date

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Third Five-Year Review scheduled 09/2010

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III. Background

Physical Characteristics

The Site, located approximately one mile northwest of Crescent City, California, consistsof less than one acre of land contaminated with a variety of herbicides, pesticides, and othercompounds. The Site is located in a rural area immediately south of McNamara Field, the airportthat serves Del Norte County (See Attachment 1). The Site lies within the 20-acre JackMcNamara parcel, which is comprised of County Assessor parcel #110-010-22 and parcel #120-020-36 (See Attachment 2).

According to the California Department of Finance, the population of Del Norte Countywas 27,507 in 2000. By 2020, the population is expected to increase to 39,000. In 2000, thepopulation of Crescent City was estimated to be 7,347 (including the population of Pelican BayState Prison). In 1999, EPA estimated that 800 persons live within one mile of the Site.

Land and Resource Use

Del Norte County owns the Del Norte Pesticide Storage Area and the land surrounding it.Since its closure in 1981, the Site has been fenced, locked, and posted with a public notice statingthat hazardous substances may be present. The Site is encompassed by approximately 480 acresof County-owned property, predominantly used as a public airport. The County property isbounded by State-owned land which is intended for use as a natural and recreational area to thenorth; by Washington Boulevard and farmland to the south; by Riverside Drive and residences tothe east; and the Pacific Ocean to the west. The Del Norte County Agriculture Department officeand animal quarantine facility are currently co-located with the Site.

The groundwater at the Site is relatively shallow and fluctuates with seasonal and annualprecipitation patterns. During the June 2005 site inspection, the water level in drainage ditches atthe Site indicated the water table was approximately 5 or 6 feet below the grade level of the Site. These ditches are upgradient of the plume area. Since the airport and on-site County AgricultureDepartment facilities are using municipal water, the underlying groundwater aquifer within one-quarter of a mile of the Site is not used as a drinking water source. The nearest residence is asingle-family farmhouse to the south of the site more than one-quarter mile from the plume. Thenearest multi-family residences, the Seawood Apartments, are one mile to the east of the site.

It appears that the land uses of the Site and surrounding area are essentially the same asthey were during the Five-Year Review in 2000. The General Plan and Zoning Maps for the Siteproperty indicate that part of the Site property is zoned for manufacturing and industrial uses andthe remainder of the Site is zoned for resource conservation. The only observed change is therelocation of the sole lessee of County property, the Wild Feline Rescue Society, from theHumane Society building on Washington Boulevard to other non-County property. The HumaneSociety building is in disrepair and is no longer being utilized. With regard to future land use,Del Norte County intends to relocate the County Agriculture Department office and animal

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quarantine facility off of the Jack McNamara parcel at some unspecified point in the future and toutilize the County property solely for airport-related purposes. Condemnation and razing ofseveral residences on Riverside Drive are planned as part of a proposed airport expansion. Asidefrom the possible relocation of County offices and the removal of homes on Riverside Drive, it isanticipated that present land uses of the Site and surrounding area will continue into the future.

History of Contamination

In December 1969, Del Norte County notified the North Coast Regional Water QualityControl Board (NCRWQCB) of the County's intent to operate a pesticide container storage area.The County requested operating advice and approval from the NCRWQCB, and in January 1970,the NCRWQCB responded with suggested operating procedures and additional informationrequests regarding the planned facility. During 1970, the Del Norte Pesticide Storage Area wasdesignated by the NCRWQCB as a Class II-2 disposal site. It was intended to serve as a County-wide collection point for interim or emergency storage of pesticide containers generated by localagricultural and forestry-related industries. The NCRWQCB approved the operation of the DelNorte Pesticide Storage Area provided that all containers were triple rinsed and punctured priorto arrival at the facility.

The Del Norte Pesticide Storage Area operated from 1970-1981. In the fall of 1981, theNCRWQCB and California Department of Health Services (DHS) discovered soil andgroundwater contamination. This discovery indicated that pesticide containers had been rinsedon-site and that the residues and rinseates were improperly disposed of in a bermed, unlinedsump area. Preliminary investigations from 1981-1983 by NCRWQCB and DHS identified soiland groundwater contamination with herbicides, pesticides and volatile and semi-volatile organiccompounds. In January 1982, Del Norte County removed 1,150 containers from the Site anddisposed of them at the Crescent City Landfill. In April 1982, 440 remaining unrinsed drumswere shipped to a licensed recycler, the Rose Cooperage Company, in Montebello, California.Del Norte County's inability to fund further investigations initiated the process of listing the DelNorte Pesticide Storage Area on the National Priorities List (NPL) in the fall of 1983.

Basis for Taking Action

EPA completed Remedial Investigation/ Feasibility Study (RI/FS) activities in 1985. Theresults of those investigations indicated that operations at the Site resulted in contamination ofsoil and groundwater. Contaminants of concern in both soil and groundwater were 1,2-Dichloropropane (1,2-DCP) and 2,4- Dichlorophenoxyacetic acid (2,4-D). Soil contaminationwas detected to a depth of 15 feet but contained to a 15 feet by 20 feet on-site area. At the time,the groundwater contaminant plume was estimated to extend approximately 170 feet to thesoutheast of the Site. Potential use of the contaminated aquifer as a water supply would result ina significant health risk. Ingestion of these contaminants at the levels found on-site during theRI/FS have been linked to increased cancer risk. Investigations also indicated that elevated levelsof chromium were also present in soils at the Site.

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IV. Remedial Actions

Remedy Selection

The Record of Decision (ROD) for the Site was signed on September 30, 1985. RemedialAction Objectives (RAOs) were established based on data collected during the RemedialInvestigation to aid in the development and screening of remedial alternatives that wereconsidered for the ROD.

The general RAOs identified in the 1985 ROD were:- Minimize off-site contamination by migration of contaminated groundwater and- Minimize exposure to contaminated soil.

These RAOs were further specified as:- Prevention of nearby well contamination and- Restoration of contaminated on-site ground water to MCLs and clean-up of on-site soils.

These RAOs resulted in the selection of a remedy with the following major components:- Excavation and off-site disposal of contaminated soils,- Extraction and treatment of groundwater through carbon adsorption andcoagulation/filtration treatments, - Disposal of treated groundwater to the Crescent City Waste Water Treatment Plant, and- Groundwater monitoring.

An Explanation of Significant Differences (ESD) which justified and documented thechange in the groundwater treatment method that was selected in the 1985 ROD was issued onSeptember 21, 1989. Following source removal activities and initial biodegradation and/orvolatilization of on-site contaminants, concentrations of 2,4-D and 1,2-DCP had reachedasymptotic levels, indicating that continuation of the carbon adsorption component of the remedywas no longer appropriate. Furthermore, the discovery of naturally occurring chromium in on-sitebedrock rendered the treatment of groundwater by coagulation/filtration and the remediation ofsoil to remove chromium impracticable and prohibited under Section 104 (a)(3)(A) of CERCLAas amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA). Theselected groundwater remedy was changed by the ESD from carbon adsorption andcoagulation/filtration to aeration. Aeration had been considered in the original ROD as aremedial alternative but was not chosen due to its ineffective removal of 2,4-D and chromium.The cleanup level for l ,2-DCP was not changed by the ESD.

In a ROD Amendment signed on August 29, 2000, EPA concluded that the remedialobjective of restoring the contaminated groundwater to MCLs will not be met because notechnology exists which is capable of reaching drinking water quality standards under theconditions found at the Site.

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The RAOs included in the 2000 ROD Amendment are:- Containment of contaminated groundwater and- Prevention of its use as drinking water as long as contaminant concentrations remainabove drinking water quality standards.

The 2000 ROD Amendment provides for:- Containment of the groundwater plume through natural attenuation,- Semi-annual groundwater monitoring,- Identification of a new Applicable or Relevant and Appropriate Requirement (ARAR) for 1,2-DCP (equivalent to the MCL of 5:g/l),- A Technical Impracticability waiver (TI) of this newly identified ARAR, and - Institutional Controls (ICs) to prevent exposure to contaminated groundwater.

Remedy Implementation

In December 1987, EPA performed the first remedial action at the Site. Approximately290 cubic yards of contaminated soil were excavated and disposed of off-site at a licensedhazardous waste disposal facility. Contracted removal activities were provided by EmergencyResponse Contracting Services (ERCS), Riedel Environmental Services. This removal actioncompleted the soil remedy for the Site.

On July 19, 1988, DHS Toxic Substances Control Division, currently the Department ofToxic Substances Control (DTSC), signed a State Superfund Contract (SSC) with EPA, agreeingto pay for 50% of Remedial Design (RD) and Remedial Action (RA) costs. This contract waslater amended in 1993 to include a 50% cost share of removal, RI/FS, RD, and RA costs. Theauthority for higher and broader cost sharing (exceeding the typical 10% cost share of RA costs)is granted under CERCLA Section 104(c)(3) which provides that States pay at least 50% of allresponse costs for sites where the State, or a political subdivision thereof, is responsible as anoperator.

The RD for the aeration treatment system at the Site was executed by an EPA On SceneCoordinator (OSC). Construction of the treatment system was conducted through ERCS fromSeptember 1989 through April 1990. Extraction and monitoring wells were already in place fromactivities conducted during the RI/FS and RD.

Groundwater monitoring indicated that the extent and levels of 2,4-D and 1,2-DCP ingroundwater were decreasing significantly (See Attachment 3). Between 1985 and 1989, aftersource removal but before installation of the pump and treatment system, the levels of 2,4-D inmonitoring wells at the Site decreased to less than 2 :g/1, well below the 100:g/1 cleanup levelestablished under the ROD. The levels of 1,2-DCP also decreased in the same time period fromapproximately 2000:g/1 to 600:g/1; although the concentrations remained above the 10 :g/lcleanup level established under the ROD. These reductions were likely the result of the sourceremoval and biodegradation and/or volatilization of the contaminants in the groundwater.

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A pump and treatment system was installed in 1990 and began extracting groundwaterfrom one extraction well at the rate of 15 gallons per minute (gpm). The treatment systemoperated continuously from April 1990 to December 1994. During that period it was observedthat 1,2-DCP concentrations in the groundwater monitoring wells located within the plume hadreached asymptotic levels, between approximately 40:g/1 and 15:g/l. In 1994, EPA installed anair sparging system to determine if the injection of air into the aquifer would enhancecontaminant removal. Additional sparge points were added in 1995. No measurable changes inthe levels of 1,2-DCP in groundwater resulted.

The Site achieved construction completion status when the Preliminary Close Out Reportwas signed on June 18, 1992.

In 1994, EPA began a program of turning the groundwater treatment system off forextended periods of time to determine what effect it would have on contaminant concentrations.The system was turned off for approximately six months in 1995, and then restarted. It wasturned off again for six months in 1996. No concentration differences were detected on eitheroccasion. The system has been off since October 1997 and semi-annual groundwater monitoringreports show that contaminant concentrations continue to decline slowly, at the same rate aswhen the treatment system was operating. This trend and subsequent further investigation ofplume behavior led the agency to finalize a ROD Amendment on August 29, 2000, with theidentification of a new ARAR for 1,2-DCP (equivalent to the newly established MCL of 5:g/l)and a TI waiver of this ARAR. Ongoing components of the remedy now include containment ofthe plume through natural attenuation, semi-annual groundwater monitoring, and ICs. The FifthSemi-annual Groundwater Monitoring Report was submitted to EPA on March 14, 2005. ACovenant to Restrict Use of Property which incorporates the ICs necessary to prevent exposure tocontaminated groundwater in this area was recorded for parcel #120-020-36 on July 31, 2002.

System Operations/Operation and Maintenance (O&M)

Operations and Maintenance (O&M) of the treatment system is no longer performedbecause the treatment system has been turned off since October 1997. The remedy has now beenamended to containment, monitoring, land use restrictions and a TI waiver of the remediationgoal. The 2002 Consent Decree requires semi-annual sampling as a component of the O&M.Five Semi-annual Groundwater Monitoring Reports are available since the Consent Decree. Thesampling has been consistent with the previous sampling plan approved under the O&M andSampling Manual prepared in February 1991. Costs for the most part have been within anacceptable range.

O&M was previously handled in-house by EPA. Repairs to the discharge pipeline, dailyinspections and recording instrument readings were performed by employees of Del Norte County.

9

V. Progress Since the Last Review

The first Five-Year Review found that remedial actions taken at the Site were expected tobe protective of human health and the environment. At the time of the first Five-Year Review,the Consent Decree (CD) between EPA and the State was being drafted. The specific ICs thatwould be adopted at the Site were to be detailed in this document. As a result, verification thatthe ICs included in the 2000 ROD Amendment remedy were incorporated into the CD and putinto practice at the Site were listed as follow-up actions of the first Five-Year Review. The CDwas entered by the Court on March 6, 2002. A Covenant to Restrict Use of Property wasrecorded with Del Norte County on July 31, 2002. This Covenant was found to apply only to aportion of the Site area, parcel #120-020-36. The Covenant should also apply to parcel #110-010-22 in order to fully prevent exposure to contaminated groundwater as intended by the 2000 RODAmendment.

VI. Five-Year Review Process

Administrative Components

Del Norte County representatives were notified of the initiation of the Five-Year Reviewprocess on February 17, 2005. The Five-Year Review was led by Yvonne Fong, EPA's RemedialProject Manager (RPM) for the Del Norte Pesticide Storage Area Superfund site. The followingEPA Site team members assisted in the review:

• Kevin Mayer, RPM;• Kim Muratore, Case Developer;• Cameron McDonald, Community Involvement Coordinator (CIC);• Bethany Dreyfus, Attorney; and • Ned Black, Regional Ecologist.

The following County officials were interviewed as part of the Five-Year Review:

• Leon Perreault, Del Norte County Department of Health and Social Services;• James Buckles, Del Norte County Department of Agriculture;• Dave Cavyell, Del Norte County Department of Agriculture; and • Ernie Perry, Del Norte County Department of Planning;

This Five-Year Review consisted of the following activities: community notification andinvolvement, a review of relevant documents and data, site inspections, and interviews with DelNorte County personnel.

10

Community Notification and Involvement

Activities to involve the community in the Five-Year Review were initiated in February2005. A notice regarding the forthcoming Five-Year Review was prepared by CameronMcDonald, CIC, and Kevin Mayer, RPM, both of EPA, and mailed out to the community in May2005. The notice was sent to 63 individuals and organizations, including local politicians, cityand county leaders, local libraries, news organizations and others listed in the EPA CommunityInvolvement Database for the Site. In addition, an article entitled “EPA Reviewing Tests fromContaminated Site” appeared in the June 2, 2005 edition of The Daily Triplicate, the localnewspaper. Both the notice and the article provided background information on the Site,explained the reason for the Five-Year Review, and requested that anyone interested insubmitting comments regarding the performance of the remedy at the Site contact the toll-freephone number provided. No comments were received prior to the closing of the comment periodon June 15, 2005.

A notice will be published in The Daily Triplicate announcing that the Five-Year ReviewReport for the Site is complete and that the results of the review and report are available to thepublic. The completed Five-Year Review Report will be available at the following locations:

- Del Norte County Public Library, 190 Price Mall, Crescent City, CA 95531 and - EPA Records Center, 95 Hawthorne Street, Suite 403S, San Francisco, CA 94105.

Document Review

This Five-Year Review consisted of a review of relevant documents including recordsand monitoring data (See Attachment 4). The following standards were identified as ARARs inthe 1985 ROD and 2000 ROD Amendment. They were reviewed for changes that could affectprotectiveness, and these standards have not changed.:

• National Primary Drinking Water Standards (40 CFR Parts 141):• Title 22 CCR Section 64444: and• Porter-Cologne Water Quality Control Act (California Water code Sections 13140-13147, 13172, 13260, 13262, 13267.

The 2002 CD outlined access and institutional controls critical to the effectiveness of theremedy for the Site. The July 31, 2002 Covenant to Restrict Use of Property was reviewed todetermine if Del Norte County’s responsibilities to control Site access and employ ICs under theCD were fulfilled. The Covenant was made between Del Norte County, the Covenantor, andDTSC, the Covenantee, with EPA as a third party beneficiary. The Covenant prohibits use of theSite as a residence, hospital, school, or daycare; interference with the groundwater monitoringwells and contaminated groundwater; improper handling of any contaminated soils; and anyrestriction of DTSC or EPA’s rights of entry and access. The Covenant further enables DTSCand EPA to enforce the provisions of the Covenant at any time.

11

Data Review

A review of records and monitoring reports through March 2000 indicate that thegroundwater treatment system operated for nearly seven years from April 1990 to October 1997.When operating, the system had a continuous pumping rate of 15 gpm. Since its installation, andaccounting for shut-down periods, the system operated a total of 79 months which representsapproximately 51 million gallons of treated groundwater. The system processed roughly 68 porevolumes of the plume and removed an estimated volume of 3.75 gallons (14.2 liters or 16.4kilograms) of 1,2-DCP. Approximately 95% of that volume was removed within the first fouryears of operation (1990 to 1994). Table 2 summarizes peak contaminant concentrations.

Table 2: Historical Groundwater Concentrations

Contaminant Well

1985 HighestConcentration(Pre-Remedy)

(ppb)

1987 HighestConcentration

(ppb)


(ppb)


(ppb)

Clean-upLevel(ppb)

1,2-DCP 1/108* 2100 – – ND 5

1,2-DCP 25 5 – 8 1.9 5

1,2-DCP 104 – – 130 8.2 5

1,2-DCP 105 – – 23 23 5

2,4-D 1/108* 150 28 – – 100

* Monitoring well #1 was replaced with monitoring well #108 in 1994.ND indicates contaminant was not detected– indicates the well was not sampled on this date

In October 1997, the groundwater treatment system was shut off when no differences incontaminant concentrations could be detected during temporary shut-down periods. The clean-up level for 2,4-D has been achieved. Although the 5 :g/l clean-up level for 1,2-DCP has notbeen achieved, semi-annual groundwater monitoring reports show that 1,2-DCP concentrationscontinue to decline slowly. The influence of seasonal and annual fluctuations in the water tableis likely to be a factor in the variability of 1,2-DCP concentrations in the shallow groundwater. Such year-to-year variation should be considered in assessing whether the RAOs have been fullyachieved. Table 3 summarizes the results of the five Semi-annual Groundwater MonitoringReports prepared by the Del Norte County Department of Health and Social Services to date.

12

Table 3: Recent Groundwater Concentrations

Concentration of 1,2-DCP (µg/l)

Semi-annual Groundwater Monitoring Report Date

Well 10/29/2002 05/28/2003 01/05/2004 08/09/2004 03/14/2005

26 ND ND ND ND ND

104 5 2.4 ND 2.7 1.5

105 11 6.6 9.1 11 7.4

107 ND ND – ND ND

ND indicates contaminant was not detected– indicates the well was not sampled on this date

Site Inspection

This Five-Year Review for the Site included two site inspections performed on June 13and 20, 2005. Yvonne Fong, Kevin Mayer and Cameron McDonald conducted the earlierinspection and the latter was conducted by Kim Muratore, all of EPA. A representative of the DelNorte County Department of Health and Social Services was present at the June 13, 2005inspection. The purpose of the inspections was to assess the protectiveness of the remedy byverifying that Site access and land and groundwater use have been restricted according to the CD. The protectiveness of land use controls was further evaluated through visits to the Del NorteCounty Assessor’s, Recorder’s, and Community Development Department offices where zoningmaps were reviewed and compared to the General Plan, title history was researched, and Countyofficials knowledgeable in future plans for the area were interviewed.

No significant issues have been identified as a result of the site inspections. Perimeterfencing around the Site was in place and in good condition. Signs restricting access were posted. The groundwater treatment system has been shut-off since October of 1997; therefore, themachinery itself was not inspected for proper functioning. No new uses of land or groundwaterand no activities that would have violated the ICs were observed. Attachment 5 contains photosdocumenting the Site conditions.

The four monitoring wells and their protective casings stood several feet above theground surface. The metal casings protecting the monitoring wells suffered from considerablecorrosion. Although the PVC wells themselves were not compromised, corroded metal lids andcorrosion-blocked drain holes allowed rainwater to accumulate around the wellhead. The Countyofficial, Leon Perreault, agreed that the metal casings would be repaired or replaced. Access towells was made difficult by overgrowth of the surrounding vegetation.

The Site Inspection Checklist (See Attachment 6) attached to this document containsmore details on the site inspections.

13

Interviews

Interviews conducted with various parties connected to the Site are summarized below. The attached Interview Documentation Form (See Attachment 7) provides further detailsregarding these interviews.

Leon Perreault, Lead Environmental Scientist for the Del Norte County Department ofHealth and Social Services was interviewed in person on June 13, 2005 at his office. TheDepartment of Health and Social Services is responsible for issuing well permits and Mr.Perreault provided information on wells in the area of the Site. Considerations regarding thelocation of septic systems and the generally dry condition of nearby wells across WashingtonBoulevard and on Napa Street and Riverside Drive create practical and financial limitations tothe development of new wells in the area. While there is no direct evidence that ICs are beingactively enforced, there have been no demands to develop new wells in the area subject to the ICson groundwater well development and operation. Furthermore, the County has adopted a policyto transition from reliance on private groundwater wells to municipal water supplies.

Ernie Perry, Director of the Community Development Department was interviewed inperson on June 21, 2005 at his office. The Community Development Department is responsiblefor ensuring that land use in Del Norte County complies with zoning restrictions contained in theCounty’s General Plan and Zoning Maps. Mr. Perry confirmed that there are no plans fordevelopment on the Site other than the possible expansion of the airport. Currently, the GeneralPlan and Zoning Maps for the Site property indicate that part of the Site property is zoned formanufacturing and industrial uses and the remainder of the Site is zoned for resourceconservation. Although a daycare or school could be permitted under the current zoning allowedon a portion of the Site, Mr. Perry felt confident that a use permit would not be granted for eithera daycare or school because the County intends to relocate the existing on-site office of theDepartment of Agriculture to an off-site location and ultimately restrict all Site uses to airport-related purposes. Despite the lack of a website or other formal tracking system, Mr. Perry feltthat the terms of the CD and deed restriction are being overseen and enforced through acombination of the following: 1) a small County staff with knowledge in special areas like theSite, 2) close communication between different County Departments, 3) an airport master planthat specifies that County property in the area will be used for airport-related uses, and 4) aCounty policy to transition residents from private well water to municipal water. Mr. Perryrecognized that the Covenant to Restrict Use of Property was incorrectly recorded solely forparcel #120-020-36 and that EPA should work with County Counsel, Bob Black, to amend theCovenant to include parcel #110-010-22 in order to fully prevent exposure to contaminatedgroundwater as intended by the 2000 ROD Amendment.

Interviews with Jim Buckles and Dave Cavyell, both of the Del Norte Department ofAgriculture confirm that the only current use of the Site is for the County’s Department ofAgriculture office and that the office is supplied with municipal water.

14

VII. Technical Assessment

A technical assessment of a site’s remedy is based on information gathered during theFive-Year Review in response to the following three questions:

• Question A - Is the remedy functioning as intended by the decision documents?• Question B - Are the exposure assumptions, toxicity data, cleanup levels, and remedialaction objectives (RAOs) used at the time of the remedy selection still valid?• Question C - Has any other information come to light that could call into question theprotectiveness of the remedy?

These questions provide a framework for organizing and evaluating data and information andensure that all relevant issues are considered when determining the protectiveness of the remedy.The following conclusions support the determination that the remedy at the Site is protective ofhuman health and the environment.

Question A: Is the remedy functioning as intended by the decision documents?• Remedial Action Performance: The groundwater treatment system has been shut off sinceOctober 1997. Monitoring shows that the plume is contained and contaminant concentrations arein a slow decline.• System Operations/O&M: Currently, O&M requires semi-annual sampling. Five Semi-annualGroundwater Monitoring Reports are available. The sampling has been consistent with theprevious sampling plan approved under the O&M and Sampling Manual prepared in February1991. Costs for the most part have been within an acceptable range.• Opportunities for Optimization: The groundwater treatment system has been shut off sinceOctober 1997. Optimization is not applicable.• Early Indicators of Potential Issues: No early indicators of potential remedy failurewere noted during the review.• Implementation of Institutional Controls and Other Measures: Fencing and signs limit accessto the Site. A Covenant to Restrict Use of Property was recorded for one of two on-site parcels,parcel #120-020-36. Site use is limited to the Del Norte County Department of Agriculture’soffice. The land is property of the County and, as the owner and sole user, the County has beenable to adequately ensure that no uses of the Site prohibited under the Covenant have occurred.

Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial actionobjectives (RAOs) used at the time of the remedy selection still valid?• Changes in Standards and TBCs (To Be Considered): There were no changes since the RODAmendment was signed on August 29, 2000.• Changes in Exposure Pathways: No changes in Site conditions that affect exposure pathwayswere identified as part of the Five-Year Review. First, there are no current changes in land use.Second, no new contaminants, sources, or routes of exposure were identified as part of this Five-Year Review. Finally, there is no indication that hydrologic/hydrogeologic conditions are notadequately characterized. The rate of decrease in groundwater contaminant levels is consistent

15

with expectations at the time of the ROD Amendment. The groundwater plume has beensuccessfully contained.

There have been no changes in exposure pathways to ecological receptors identifiedduring the review and inspection. Although the water table fluctuates with climatic factors, thecontaminants of concern remain below ground and there are no complete exposure pathways toecological receptors.• Changes in Toxicity and Other Contaminant Characteristics: Toxicity and other factors forcontaminants of concern have not changed.• Changes in Risk Assessment Methods: Changes in risk assessment methodologiessince the time of the ROD Amendment do not call into question the protectiveness of theremedy.• Expected Progress Towards Meeting RAOs: The remedy is progressing as expected.

Question C: Has any other information come to light that could call into question theprotectiveness of the remedy? No additional information has been identified that could call intoquestion the protectiveness of the remedy.

Technical Assessment Summary

According to the review of relevant documents and data, site inspections, and interviewswith Del Norte County personnel, the remedy is functioning as intended by the ROD, as modifiedby the ESD and ROD Amendment. There have been no changes in the physical conditions of theSite that would affect the protectiveness of the remedy. Aside from a TI waiver of the 5 :g/lMCL for 1,2-DCP, all ARARs cited in the 1985 ROD and 2000 ROD Amendment have beenmet. There have been no changes in the toxicity factors for the contaminants of concern andthere have been no changes in the standardized risk assessment methodology that could affect theprotectiveness of the remedy. There is no other information that calls into question theprotectiveness of the remedy.

VIII. Issues

ICs were part of the remedy contained in the 2000 ROD Amendment. Del Norte Countytook steps to implement those controls by lodging a Covenant to Restrict Use of Property on July31, 2002. The Covenant, however, does not include both parcels of land which comprise theSite. The July 31, 2002 Covenant was found to apply solely to parcel #120-020-36. TheCovenant should be lodged for both parcels #120-020-36 and #110-010-22.

The metal casings protecting the monitoring wells were observed during the June 13,2005 site inspection to be considerably corroded. The corroded metal caps and corrosion-blockeddrain holes allowed rainwater to accumulate around the wellhead. Overgrowth of vegetationsurrounding the wells limited access to the monitoring wells.

16

Table 4: Issues

Issue Affects CurrentProtectiveness

(Y/N)

Affects FutureProtectiveness

(Y/N)

1) The July 31, 2002 Covenant to Restrict Use of Property applies to onlyone of two Site parcels

N Y

2) Corrosion of metal well casings/caps N N

3) Limited access to monitoring wells due to overgrown vegetation N N

IX. Recommendations and Follow-up Actions

The CD between EPA, the State and the County was entered by the Court on March 6,2002. The specific controls that were adopted at the Site were to be listed in detail in thisdocument. Del Norte County recorded a Land Use Covenant which placed restrictions on only aportion of the property. No land use restrictions are in place for parcel #110-010-22, which is theparcel containing the Site. The next Five-Year Review should verify that the Covenant’sapplicability has been corrected and that these controls have been put into practice on bothparcels at the Site. Table 5 establishes a one year milestone date for amending the Covenant toRestrict Use. Subsequent to the lodging of a Covenant to Restrict Use on parcel #110-010-22,title searches should be executed and a plan for the County to monitor compliance with theCovenants on both parcels #120-020-36 and #110-010-22 should be established.

Corrosion of the protective metal casings around the monitoring wells requiresmaintenance and possibly replacement of the caps prior to the onset of the winter rains in 2005. The thick underbrush has begun to overgrow the footpaths to the wells. The underbrush shouldbe cleared to allow access during the next sampling event in 2005 and should continue to be cutback as needed. Neither of these follow-up actions affect the protectiveness of the remedy.

17

Table 5: Recommendations and Follow-up Actions

IssueRecommendations and

Follow-up ActionsParty

ResponsibleOversight

AgencyMilestone

Date

Affects Protectiveness(Y/N)

Current Future

1Amend Covenant to Restrict

Use of PropertyDel NorteCounty

EPA 09/26/2006 N Y

1 Conduct Title SearchDel NorteCounty

EPA 09/26/2010 N N

1Establish Covenant

Compliance Monitoring Plan Del NorteCounty

EPA 09/26/2010 N N

2Maintenance/Replacement

of Well Casings/Caps Del NorteCounty

EPA 12/30/2005 N N

3Clearing of Underbrush

Surrounding WellsDel NorteCounty

EPA 11/30/2005 N N

X. Protectiveness Statement

The remedy at the Del Norte Pesticide Storage Area across the single OU currentlyprotects human health and the environment because there is no current exposure to thecontamination that remains at the Site. However, in order for the remedy to be protective in thelong-term, a Land Use Covenant to Restrict Use of Property that is applicable to the entire Sitemust be put in place to ensure long-term protectiveness.

The plume has been stable since the groundwater treatment system was shut down inOctober 1997. The extent of the original plume was believed to be about 12,000 square feet,reaching approximately 300 feet south of the source. The nearest private well to the Site is overone-quarter mile away from the source of the plume. Due to the source removal, groundwatertreatment systems, and subsequent natural attenuation, the plume has decreased to approximately5,000 square feet and 120 feet south of the source. Contamination levels have been in gradualdecline and are expected to continue to do so at a slow rate. Site contaminants have never beendetected in the surrounding residential wells, and there is no evidence that contamination hasbeen introduced since the last sampling event. There are no complete exposure pathways toecological receptors.

XI. Next Review

This Site requires on-going Five-Year Reviews as a matter of statute because the remedydoes not allow for unrestricted use and unrestricted exposure. The next review will be conductedwithin five years of the completion of this Five-Year Review Report. The completion date is thedate of signature shown on the cover of this report.

Site Maps

AREA OF MEREST

,,~ '- ;'i-~=~ "..

N

A10.50.5 0

Miles

Attachment 1

Map of Area

Del Norte Pesticide Storage Area Five-Year ReviewAugust 2005

Attachm

ent 2

Del N

orte P

esticide S

torage A

rea F

ive-Year

Review

August

2005

Map of Jack

McN

amara

Parcel

List of Documents Reviewed

Attachment 4List of Documents Reviewed

EPA Superfund Record of Decision: Summary of Remedial Alternative Selection for the DelNorte County Pesticide Storage Area, Crescent City, CA, (EPA/ROD/R09-85/010), Michele S.Dermer, September 30, 1985.

EPA Superfund Explanation of Significant Differences for Remedial Action at the Del NorteCounty Pesticide Storage Area Superfund Site, Crescent City, CA, (EPA/ESD/R09-89/132), BradShipley, September 21,1989.

Selected Groundwater Monitoring Well Sample Results for the Del Norte County PesticideStorage Area Site, Crescent City, California, US EPA Region IX, Brad Shipley, 1999.

EPA Superfund Record of Decision Amendment and Technical Impracticability Waiver for theDel Norte County Pesticide Storage Area, Crescent City, CA (EPA/AMD/R09-00/113), August29, 2000.

Groundwater Monitoring Plan for Del Norte Pesticide Storage Area, Del Norte County, June 6,2001.

Consent Decree for the Del Norte County Pesticide Storage Area (Civil Action No. C 01 4847)between the USA, California Department of Toxic Substances Control and Del Norte County. US District Court Northern District of California. March 6, 2002.

Covenant between Del Norte County and California Department of Toxic Substances Control toRestrict Use of Property, Del Norte Pesticide Storage Area (parcel #120-020-36) (Document #20024191), July 31, 2002.

Notice of Intent to Delete the Del Norte County Pesticide Storage Area Superfund Site from theNational Priorities List, 67 FR 51528, August 8, 2002.

First through Fifth Semi-annual Groundwater Monitoring Reports dated October 29, 2002; May28, 2003; January 5, 2004, August 9, 2004 and March 14, 2005.

Del Norte County Airport Master Plan Report: Public Review Draft, Mead and Hunt, May 2005.

Photos Documenting Site Conditions


Attachment 5-1Site Entrance


Attachment 5-2Original Sump Area


Attachment 5-3Pumping Well 101


Attachment 5-4Monitoring Well 104


Attachment 5-5Monitoring Well 104 Cap


Attachment 5-9Site Vegetation


Attachment 5-10View toward Airport


Attachment 5-11View toward Site Entrance


Attachment 5-12Drainage Ditch


Attachment 5-13Del Norte County Department of Agriculture Office


Attachment 5-14Del Norte County Animal Quarantine Facility


Attachment 5-15Adjacent McNamara Property


Attachment 5-16Seawood Apartments


Attachment 5-17Seawood Apartments

Site Inspection Checklist

Five-Year Review Site Inspection Checklist

I. SITE INFORMATION

Site name: Del Norte Pesticide Storage Area Date of inspection: 06/13/2005

Location and Region: Crescent City, CA/Region IX EPA ID: CAD000626176

Agency, office, or company leading the five-year

review: EPA Superfund Division

Weather/temperature:

61 degrees F/partly cloudy

Remedy Includes: (Check all tha t apply)

G Landfill cover/containment : Monitored natural attenuation

G Access co ntrols : Groundwater containment

: Institutional con trols G Vertical ba rrier walls

: Groundwater pump and treatment

G Surface water collection and treatment

G Other_______________________________________________________________________

Attachme nts: : Inspection team roster attached : Site map attached

II. INTERVIEWS (Check all tha t apply)

1. O&M site manager _________________________ _________________ ______________

Name Title Date

Interviewed G at site G at office G by phone Phone no. ___________________________________

Problem s, suggestions; G Report attached _________________________________________________

___________________________________________________________________________________

2. O&M staff _______________________________ _________________ ______________

Name Title Date

Interviewed G at site G at office G by phone Phone no. ___________________________________

Problem s, suggestions; G Report attached _________________________________________________

___________________________________________________________________________________

3. Local regulatory authorities and response agencies (i.e., State and Tribal offices, emergency resp onse

office, police department, office of public health or environmental health, zoning office, recorder of

deeds, or other city and c ounty offices, etc .) Fill in all that apply.

Agency County of Del Norte, Department of Health and Social Services

Contact Leon P erreault Lead Environm ental Scientist 06/13/2005 (707) 464-3191 x 341

Name Title Date Phone no.

Problem s; suggestions; : Report attached

______________________________________________________________________________

______________________________________________________________________________

Agency County of Del Norte, Department of Agriculture

Contact Jim Buckles Weights, Measures, Agricultural Inspection 06/20/2005 (707) 464-7235



______________________________________________________________________________

______________________________________________________________________________

Agency County of Del Norte, Department of Agriculture

Contact Dave C avyell Agricultural Aide 06/20/2005 (707) 464-7235


Problem s; suggestions; :Report attached

______________________________________________________________________________

______________________________________________________________________________

Agency County of Del Norte, Community Development Department

Contact Ernie Perry Director 06/21/2005 (707) 464-7254



______________________________________________________________________________

______________________________________________________________________________

4. Other interviews (optional) G Report attached.

III. ON-SITE DOCUMENTS & RECO RDS VERIFIED (Check all tha t apply)

1. O&M Documents

G O&M manual G Readily ava ilable G Up to da te G N/A

G As-built drawings G Readily ava ilable G Up to da te G N/A

G Maintenance logs G Readily ava ilable G Up to da te G N/A

Remarks_______________________________________________________________________

______________________________________________________________________________

2. Site-Specific Health and Safety Plan G Readily ava ilable G Up to da te G N/A

G Contingency plan/emergency response plan G Readily ava ilable G Up to da te G N/A

Remarks_______________________________________________________________________

______________________________________________________________________________

3. O&M and OSHA Training Records G Readily ava ilable G Up to da te G N/A

Remarks_______________________________________________________________________

______________________________________________________________________________

4. Permits and Service Agreem ents

G Air discharg e permit G Readily ava ilable G Up to da te G N/A

G Effluent discharge G Readily ava ilable G Up to da te G N/A

G Waste disposal, POTW G Readily ava ilable G Up to da te G N/A

G Other permits______________________ G Readily ava ilable G Up to da te G N/A

Remarks_______________________________________________________________________

______________________________________________________________________________

5. Gas Generation Records G Readily ava ilable G Up to da te G N/A

Remarks_______________________________________________________________________

______________________________________________________________________________

6. Settlement Monument Records G Readily ava ilable G Up to da te G N/A

Remarks_______________________________________________________________________

______________________________________________________________________________

7. Groundwater Monitoring Records : Readily ava ilable : Up to da te G N/A

Remarks Located in Region IX Office

8. Leachate Extraction Records G Readily ava ilable G Up to da te G N/A

Remarks_______________________________________________________________________

______________________________________________________________________________

9. Discharge C ompliance R ecords

G Air G Readily ava ilable G Up to da te G N/A

G Water (e ffluent) G Readily ava ilable G Up to da te G N/A

Remarks_______________________________________________________________________

______________________________________________________________________________

10. Daily Access/Security Logs G Readily ava ilable G Up to da te G N/A

Remarks_______________________________________________________________________

______________________________________________________________________________

IV. O&M COSTS

1. O&M Organization

G State in-house G Contracto r for State

G PRP in-house G Contractor for PRP

G Federal Facility in-house G Contracto r for Feder al Facility

G Other_______________________________________________________________________

______________________________________________________________________________

2. O&M Cost Reco rds

G Readily ava ilable G Up to da te

G Funding mechanism/agreement in place

Original O&M cost estimate____________________ G Breakdown attached

Total ann ual cost by yea r for review p eriod if availab le

From__________ To__________ __________________ G Breakdown attached

Date Date Total cost









3. Unanticipated or Unusually High O&M Costs During Review Period

Describe costs and reasons: _______________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

V. ACCESS AND INSTITUTIONAL CONTROLS : Applicable G N/A

A. Fencing

1. Fencing damaged G Location shown on site map : Gates secured G N/A

Remarks Fencing is in go od cond ition.

B. Other Access Restrictions

1. Signs and other security measures G Location shown on site map G N/A

Remarks Signs are po sted on fenc ing.

C. Institutional Co ntrols (ICs)

1. Implementation and enforcement

Site conditions imply ICs not properly implemented G Yes : No G N/A

Site conditions imply ICs not being fully enforced G Yes : No G N/A

Type of monitoring (e.g., self-reporting, drive by) ______________________________________

Frequency _____________________________________________________________________

Responsible party/agency _________________________________________________________

Contact

Name Title Date Phone n o.

Reportin g is up-to-date G Yes G No G N/A

Reports are verified by the lead agency G Yes G No G N/A

Specific requirements in deed or decision documents have been met G Yes : No G N/A

Violations have been reported G Yes G No G N/A

Other problem s or suggestions: G Report attached

ICs were part of the remedy contained in the 2000 ROD Amendment. Del Norte County took steps

to impleme nt those con trols by lodgin g a Cove nant to Restric t Use of Pr operty on J uly 31, 200 2.

The Co venant, how ever, doe s not include b oth parce ls of land which comprise the Site. The July

31, 2002 Covenant was found to apply solely to parcel #120-020-36. The Covenant should be

lodged fo r both par cels #120 -020-36 and #11 0-010-2 2.

2. Adequacy : ICs are ad equate G ICs are inad equate G N/A

Remarks________________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

D. General

1. Vandalism/trespassing G Location shown on site map : No vandalism evident

Remarks_________________________________________________________________________

_______________________________________________________________________________

2. Land use changes on site G N/A

Remarks It appears that the land uses of the Site and su rrounding area are essen tially the same as

they were during the Five-Year Review in 2000. The only observed change is the relocation of the

sole lessee of County property, the Wild Feline Rescue Society, from the Humane Society building

on Wa shington B oulevard to other non -County pro perty.

3. Land use changes off site G N/A

Remarks________________________________________________________________________

_______________________________________________________________________________

VI. GENERAL SITE CONDITIONS

A. Roads : Applicable G N/A

1. Roads damaged G Location shown on site map : Roads a dequate G N/A

Remarks Access ro ad is gated a nd in good condition. T he road is c ontrolled b y Del No rte County.

B. Other Site Conditions

Remarks _______________________________________________________________________

_______________________________________________________________________________

_______________________________________________________________________________

VII. LANDFILL COVERS G Applicable : N/A

A. Landfill Surface

1. Settlement (Low spots) G Location shown on site map G Settlement not evident

Areal extent______________ Depth____________

Remarks_____________________________________________________________________________________________________________________________________________

2. Cracks G Location shown on site map G Cracking not evident

Lengths____________ Widths___________ Depths__________

Remarks________________________________________________________________________

_______________________________________________________________________________

3. Erosion G Location shown on site map G Erosion not evident


Remarks________________________________________________________________________

_______________________________________________________________________________

4. Holes G Location shown on site map G Holes not evident


Remarks________________________________________________________________________

_______________________________________________________________________________

5. Vegetative Cover G Grass G Cover properly established G No signs of stress

G Trees/Shrubs (indicate size and locations on a diagram)

Remarks________________________________________________________________________

_______________________________________________________________________________

6. Alterna tive Co ver (arm ored ro ck, concr ete, etc.) G N/A

Remarks________________________________________________________________________

_______________________________________________________________________________

7. Bulges G Location shown on site map G Bulges not evident

Areal extent______________ Height____________

Remarks________________________________________________________________________

_______________________________________________________________________________

8. Wet Areas/Water Damage G Wet areas/water damage not evident

G Wet areas G Location shown on site map Areal extent____________

G Ponding G Location shown on site map Areal extent____________

G Seeps G Location shown on site map Areal extent____________

G Soft subgrade G Location shown on site map Areal extent____________

Remarks________________________________________________________________________

_______________________________________________________________________________

9. Slope Instability G Slides G Location shown on site map G No evid ence of slop e instability

Areal extent______________

Remarks________________________________________________________________________

_______________________________________________________________________________

B. Benches G Applicab le G N/A

(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope

in order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined

channel.)

1. Flows Bypass Bench G Location shown on site map G N/A or okay

Remarks________________________________________________________________________

_______________________________________________________________________________

2. Bench Breached G Location shown on site map G N/A or okay

Remarks________________________________________________________________________

_______________________________________________________________________________

3. Bench Overtopped G Location shown on site map G N/A or okay

Remarks________________________________________________________________________

_______________________________________________________________________________

C. Letd own C hanne ls G Applicab le G N/A

(Channel lined with erosion control mats, riprap, grout bags, or gabions that descend down the steep side

slope of the c over and will allow the runo ff water collected by the benc hes to mov e off of the land fill

cover witho ut creating ero sion gullies.)

1. Settlement G Location shown on site map G No evidence of settlement


Remarks________________________________________________________________________

_______________________________________________________________________________

2. Material Degradation G Location shown on site map G No evidence of degradation

Material type_______________ Areal extent_____________

Remarks________________________________________________________________________

_______________________________________________________________________________

3. Erosion G Location shown on site map G No evidence of erosion


Remarks________________________________________________________________________

_______________________________________________________________________________

4. Undercutting G Location shown on site map G No evidence of undercutting


Remarks________________________________________________________________________

_______________________________________________________________________________

5. Obstructions Type_____________________ G No obstructions

G Location shown on site map Areal extent______________

Size____________

Remarks________________________________________________________________________

_______________________________________________________________________________

6. Excessive Vegetative Grow th Type____________________

G No evid ence of exc essive growth

G Vegetation in channels does not obstruct flow

G Location shown on site map Areal extent______________

Remarks________________________________________________________________________

_______________________________________________________________________________

D. Cover Penetrations G Applicab le G N/A

1. Gas Vents G Active G Passive

G Properly secured/locked G Functioning G Routinely sampled G Good condition

G Evidence of leakage at penetration G Needs Maintenance

G N/A

Remarks________________________________________________________________________

_______________________________________________________________________________

2. Gas Monitoring Probes


G Evidence of leakage at penetration G Needs Maintenance G N/A

Remarks________________________________________________________________________

_______________________________________________________________________________

3. Mon itoring We lls (within surface a rea of landfill)



Remarks________________________________________________________________________

_______________________________________________________________________________

4. Leach ate Extr action W ells



Remarks________________________________________________________________________

_______________________________________________________________________________

5. Settlement Monu ments G Located G Routinely surveyed G N/A

Remarks________________________________________________________________________

_______________________________________________________________________________

E. Gas Collection and TreatmentG Applicable G N/A

1. Gas Treatment Facilities

G Flaring G Thermal destruction G Collection for reuse

G Good condition G Needs Maintenance

Remarks________________________________________________________________________

_______________________________________________________________________________

2. Gas Collection Wells, Manifolds and Piping


Remarks________________________________________________________________________

_______________________________________________________________________________

3. Gas M onitoring Fa cilities (e.g., gas monitoring of adjacen t homes or buildings)

G Good condition G Needs Maintenance G N/A

Remarks________________________________________________________________________

_______________________________________________________________________________

F. Cover Drainage Layer G Applicab le G N/A

1. Outlet Pipes Inspected G Functioning G N/A

Remarks________________________________________________________________________

_______________________________________________________________________________

2. Outlet Rock Inspected G Functioning G N/A

Remarks________________________________________________________________________

_______________________________________________________________________________

G. Detention/Sedimentation Ponds G Applicab le G N/A

1. Siltation Areal extent______________ Depth____________ G N/A

G Siltation not evident

Remarks________________________________________________________________________

_______________________________________________________________________________

2. Erosion Areal extent______________ Depth____________

G Erosion not evident

Remarks________________________________________________________________________

_______________________________________________________________________________

3. Outlet Works G Functioning G N/A

Remarks________________________________________________________________________

_______________________________________________________________________________

4. Dam G Functioning G N/A

Remarks________________________________________________________________________

_______________________________________________________________________________

H. Ret aining W alls G Applicab le G N/A

1. Deformations G Location shown on site map G Deformation not evident

Horizontal displacement____________ Vertical displacement_______________

Rotational displacement____________

Remarks________________________________________________________________________

_______________________________________________________________________________

2. Degradation G Location shown on site map G Degradation not evident

Remarks________________________________________________________________________

_______________________________________________________________________________

I. Perimeter Ditches/Off-Site Discharge G Applicab le G N/A

1. Siltation G Location shown on site map G Siltation not evident


Remarks________________________________________________________________________

_______________________________________________________________________________

2. Vegetative Grow th G Location shown on site map G N/A

G Vegetation does not impede flow

Areal extent______________ Type____________

Remarks________________________________________________________________________

_______________________________________________________________________________

3. Erosion G Location shown on site map G Erosion not evident


Remarks________________________________________________________________________

_______________________________________________________________________________

4. Discharge Structure G Functioning G N/A

Remarks________________________________________________________________________

_______________________________________________________________________________

VIII. VERTICAL BARRIER WALLS G Applicable : N/A

1. Settlement G Location shown on site map G Settlement not evident


Remarks________________________________________________________________________

_______________________________________________________________________________

2. Performance MonitoringType of monitoring__________________________

G Performance not monitored

Frequency_______________________________ G Evidence of breaching

Head differential__________________________

Remarks________________________________________________________________________

_______________________________________________________________________________

IX. GROUNDWATER/SURFACE W ATER REMEDIES : Applicable G N/A

A. Groundwater Extraction Wells, Pumps, and Pipelines G Applicab le G N/A

1. Pumps, Wellhead Plumbing, and Electrical

G Good condition G All required wells properly operating G Needs Maintenance G N/A

Remarks________________________________________________________________________

_______________________________________________________________________________

2. Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances


Remarks________________________________________________________________________

_______________________________________________________________________________

3. Spare Parts and Equipment

G Readily ava ilable G Good condition G Requires upgrade G Needs to be

provided

Remarks________________________________________________________________________

_______________________________________________________________________________

B. Surface Water Collection Structures, Pumps, and Pipelines G Applicab le G N/A

1. Collection Structures, Pumps, and Electrical


Remarks________________________________________________________________________

_______________________________________________________________________________

2. Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances


Remarks________________________________________________________________________

_______________________________________________________________________________

3. Spare Parts and Equipment

G Readily ava ilable G Good condition G Requires upgrade G Needs to be

provided

Remarks________________________________________________________________________

_______________________________________________________________________________

C. Treatment System G Applicab le G N/A

1. Treatment Train (Check c ompon ents that app ly)

G Metals removal G Oil/water separation G Bioremediation

G Air stripping G Carbon adsorbers

G Filters________________________________________________________________________

G Additive (e.g., chelation agent, flocculent)___________________________________________

G Others________________________________________________________________________


G Sampling ports properly marked and functional

G Sampling/m aintenance lo g displayed and up to d ate

G Equipment properly identified

G Quantity of groundwater treated annually________________________

G Quantity of surface water treated annually________________________

Remarks________________________________________________________________________

_______________________________________________________________________________

2. Electrica l Enclosu res and P anels (proper ly rated and fun ctional)

G N/A G Good condition G Needs Maintenance

Remarks________________________________________________________________________

_______________________________________________________________________________

3. Tanks, V aults, Stor age Ve ssels

G N/A G Good condition G Proper secondary containment G Needs Maintenance

Remarks________________________________________________________________________

_______________________________________________________________________________

4. Discharge Structure and Appurtenances

G N/A G Good condition G Needs Maintenance

Remarks________________________________________________________________________

_______________________________________________________________________________

5. Treatmen t Building(s)

G N/A G Good co ndition (esp. roof and do orways) G Needs re pair

G Chemicals and equipment properly stored

Remarks________________________________________________________________________

_______________________________________________________________________________

6. Mo nitoring Wells (pump a nd treatmen t remedy)

: Properly secured/locked : Functioning : Routinely sampled : Good condition

: All required wells located : Needs Maintenance G N/A

Remarks The me tal casings pro tecting the mo nitoring wells suffere d from co nsiderable corrosion .

Although the PVC wells themselve s were not co mprom ised, corro ded meta l lids and cor rosion-

blocked drain holes a llowed rainw ater to accum ulate around the wellhead . The Co unty official,

Leon P erreault, agre ed that the me tal casings wou ld be repa ired or rep laced.

D. Mon itoring Data

1. Monito ring Data

: Is routinely submitted on time : Is of accep table quality

2. Monitoring data sug gests:

: Groundwater plume is effectively contained : Contaminant concentrations are declining

E. Monitored Natural Attenuation

1. Mo nitoring Wells (natural attenua tion remed y)

: Properly secured/locked: Functioning : Routinely sampled : Good condition

: All required wells located : Needs Maintenance G N/A

The monitoring wells appeared to be in good condition and are sufficiently secured. However corrosion

of the metal outer casing of the PVC well has allowed water to accumulate and may compromise the

security of the well if corrosion continues. Del Norte County officials will conduct necessary

maintenance

X. OTHER REMEDIES

If there are remedies applied at the site which are not covered above, attach an inspection sheet describing

the physical na ture and co ndition of any fa cility associated w ith the remed y. An examp le would b e soil

vapor extraction.

XI. OVERALL OBSERVATIONS

A. Implementation of the Remedy

Describe issues and ob servations re lating to whethe r the remed y is effective and fun ctioning as de signed.

Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant plume,

minimize infiltration and gas emission, etc.).

The remedy was designed to reduce the level of 1,2-DCP in the groundwater plume. Groundwater

samples from the Site showe d that by the end of 199 4 the decrease in 1,2-D CP concen trations

resulting from treatment of the groundwater had leveled off. Enhancements in the system were

tried with no significant results. Treatment system shut down also yielded no significant differences

in contaminant concentrations. A TI waiver was issued for the 1,2-DCP MCL. The ROD

Amend ment include d containm ent, a TI wa iver, institutional co ntrols and m onitoring.

B. Adequacy of O&M

Describe issues and observations related to the implementation and scope of O&M procedures. In

particular, disc uss their relations hip to the curr ent and long -term protec tiveness of the re medy.

O&M of the treatmen t system is not an issue because the system has be en turned o ff since Octob er 1997 .

Routine monitoring is occu rring at four wells. As described abo ve, some maintenance is

needed at these wells. Another Five-Year Review will be required because contaminant levels in

the ground water are still abo ve health ba sed levels.

C. Early Indicators of Potential Remedy Problems

Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high

frequency of unscheduled repairs, that suggest that the protectiveness of the remedy may be

compro mised in the futur e.

_______________________________________________________________________________

_______________________________________________________________________________

D. Opportunities for Optimization

Describe possible o pportunities for optimiza tion in monito ring tasks or the o peration o f the remedy.

Active treatm ent systems - bo th Pump & Trea t and Gro undwater S parging - hav e been em ployed at this

site. These treatment systems had reac hed their effective limits and were turned off. The e ffectiveness

of the monitored attenuation in containing and shrinking the plume make it unlikely that active treatment

will be needed in the future. Groundwater monitoring performed by Del Norte County appears to be

sufficient.

Site Inspection Team Roster

• Yvonne Fong, EPA RPM

• Kevin Mayer, EPA RPM

• Kim Muratore, EPA Case Developer

• Cameron McDonald, EPA CIC

• Leon Perreault, Del Norte County Department of Health and Social Services

• James Buckles, Del Norte County Department of Agriculture

• Dave Cavyell, Del Norte County Department of Agriculture

• Ernie Perry, Del Norte County Department of Planning

Interview Documentation Form

INTERVIEW DOCUMENTATION FORM

The following is a list of individuals interviewed for this five-year review. See the attached contact records for a detailed summary of the interviews.

Leon PerreaultLead Environmental

Scientist

County of Del Norte,Department of Healthand Social Services 06/13/2005

Name Title/Position Organization Date

Jim Buckles

Weights, Measures, AgriculturalInspection

County of Del Norte, Department of

Agriculture 06/20/2005


Dave Cavyell Agricultural Aide

County of Del Norte,Department of

Agriculture 06/20/2005


Ernie Perry

Director, CommunityDevelopmentDepartment

County of Del NorteCommunity

DevelopmentDepartment 06/21/2005


INTERVIEW RECORD

Site Name: Del Norte Pesticide Storage Area EPA ID No .: CAD000626176

Subject: Five-Year Review for Del Norte Pesticide Storage Area Time: 1:00 pm Date: 06/13/2005

Type: 9 Telephone : Visit 9 Other

Location of Visit: County of Del Norte, Department of Health and

Social Services, 880 Northcrest Drive, Crescent City, CA 95531

9 Incoming 9 Outgoing

Contact Made By:

Name:

Yvonne Fong

Kevin Mayer

Camero n McD onald

Title:

Remedial Project Manager

Remedial Project Manager

Community Involvement Coordinator

Organization: US EPA R egion IX

Individual Contacted:

Name: Leon P erreault Title: Lead Environm ental Scientist Organization: County of Del Norte,

Department of Health and Social

Services

Telephone No: (707) 464-3191 x 341

Fax No: (707) 465-1783

E-Mail Add ress:

Street Add ress: 880 Northcrest Drive

City, State, Zip: Crescent City, CA

95531

Summary Of Conversation

On June 13, 200 5, Yvon ne Fong, K evin Ma yer, and Ca meron M cDona ld interviewed Mr. Leo n Perreau lt,

Lead Environmental Scientist of the County of Del Norte’s Department of Health and Social Services at his office

located at 880 Northcrest Drive, Crescent City, CA 95531. The in-office interview was followed by further

information gathering and discussion with Mr. Perreault at the Site located at 2650 Washington Boulevard,

Crescent City, CA 95531. The interview focused on the institutional controls (ICs) contained in the remedy

relating to groundwater use and groundwater well installation/operation.

The Department of Health and Social Services is responsible for issuing well permits. Health and Social

Services p rograms w ere not well esta blished prio r to 1990 and Cou nty records r elating to wells o nly date bac k to

1993. Mr. Perreault outlined the process for obtaining new well permits as follows: an application for

construction is submitted to the Planning Department where it undergoes environmental review; the application

goes befo re the Plann ing Comm ission and the Board of Superv isors for app roval; if appr oved, the C ommunity

Development Department will issue a building permit and the Department of Health and Social Services will issue

a well permit. The Co unty has improved co de enforcement o f well construction standards.

Wells in D el Norte C ounty are co mmonly 4 0-60 feet d eep. Som e older han d-dug wells a re still in use.

Mr. Perreault indicated that the area surrounding the Del Norte Pesticide Storage Area site is currently in a

drought cycle and a number of nearby wells have run dry. Wells are closed by a certified C57 well driller. New

wells to replac e dry wells are g enerally allowe d once a b uilding perm it to provide electricity to the new well is

secured and the Co unty has evidence that the well is adequately sepa rated from septic systems.

Page 1 of 2

Summary Of Conversation(Leon Perreault 06/13/2005)

There are four remaining monitoring wells and two pumping wells on the Del Norte Pesticide Storage

Area site. Aro und the Site, o ne new well ha s been loca ted on N apa Stree t and anothe r on W est Jefferson S treet.

Replacement wells have also been installed; one on Riverside Drive and one on West Jefferson Street at Napa

Street. These new and replacement wells are beyond the quarter (1/4) mile radius around the Site where wells of

any type are p rohibited u nder the IC s. No wells in the area prov ide water to m ore than on e single family

residence as prohibited by the ICs. Additionally, the new and replacement wells are generally up-gradient from

the Site, further minimizing the potential to spread contaminated groundwater.

The Del Norte County Department of Health and Social Services’ emphasis on maintaining separation

between water supplies and septic systems is one major factor in ensuring the effectiveness of the IC prohibiting

wells within a qua rter mile. M ost of the land within a quarter mile of the Site is D el Norte C ounty land an d is

either served by municipa l water lines or un develop ed. The r emaining lan d within this radiu s is currently

farmland to the south of the S ite. Mr. Pe rreault noted that subsurface conditions a t this farmland inc lude both

unreliable groundwater and a high water table with seasonally marshy conditions. The practical considerations for

septic system separation on this land would necessitate municipal water and sewage services for any further

development. Mr. Perreault had no indication that any development of the farmland was anticipated.

The ma rshy conditio ns and shallo w ground water have n ecessitated the use of municip al water on C ounty

property in th e area. Th e Del No rte County D epartmen t of Agriculture ’s Office and A nimal Qua rantine Facility

are located at the Site. The Del Norte County Airport is adjacent to the Site. Both the Department of Agriculture

and Airport rely on municipal water. The Department of Health and Social Services is generally moving away

from the pe rmitting and use of private we lls and is advo cating the use o f municipal wa ter.

The ICs also prohibit wells supplying multiple family residences within one mile of the Site. During the

last five years the only multi-family construction within one mile of the Site is at the Seawood Apartments at 1403

Inyo Street and Washington Boulevard. This apartment complex relies on municipal water and sewage, and no

well permit ha s been issued . As with the single fam ily residences, p ractical cons iderations an d evolving C ounty

policy add to the reliability of the protectiveness of the IC s.

Page 2 of 2

INTERVIEW RECORD




Location of Visit: County of Del Norte, Department of Agriculture,

2650 Washington Blvd., Crescent City, CA 95531


Contact Made By:

Name: Kim Muratore Title: Case Developer Organization: US EPA R egion IX


Name: Jim Buckles Title: Weights, M easures,

Agricultural Inspection

Organization: County of Del Norte,

Department of Agriculture

Telephone No: (707) 464-7235

Fax No:

E-Mail Add ress:

Street Add ress: 2650 Washington

Blvd.


95531


Mr. Buckles verified that other than the County Department of Agriculture offices that have been located at

2650 W ashington Blvd. for years (a sign out front indicates that the offices include the Agricultural Commission,

Sealer of Weights & Measures, and the County Poundmaster/dog pound) that there are no other County offices on

the (20-acre Jack McNamara EPA Parcel) Site property, identified as Assessor Parcels #110-010-22 and #120-

020-36 , and no lesse es. The Fe line Rescue Society (aka the Huma ne Society) h as relocated off of the Site

property. I verified this through a drive-by of the old premises which appear to be in disrepair and are no longer

being used by anyone. I drove around the Site property boundary, to the extent that the roadways permitted.

Mr. Buc kles was also a ble to verify that the re are no p lans for deve lopment o f the Site prop erty except a

possible County airport expansion. Offsite, the only recent change is that Ms. McNamara, the elderly owner of

the McN amara R anch locate d across fro m the Cou nty offices on the o ther side of W ashington B lvd., died ab out a

year ago. (This property appears to lie within one half mile of the Site property, and therefore is affected by the

terms of the 2 002 Co nsent Dec ree pertainin g to well installation and water p roduction and use).

Page 1 of 1

INTERVIEW RECORD




Location of Visit: County of Del Norte, Department of Agriculture,

2650 Washington Blvd., Crescent City, CA 95531


Contact Made By:



Name: Dave C avyell Title: Agricultural Aide Organization: County of Del Norte,

Department of Agriculture

Telephone No: (707) 464-7235

Fax No: (707) 464-7231

E-Mail Add ress:

Street Add ress: 2650 Washington

Blvd.


95531


Mr. Cavye ll’s daughter ha s an informal a rrangeme nt with the Cou nty in which she p rovides nigh t-time security

for the County Agricultural offices at the 2650 Washington Blvd. location in exchange for residential use of an

on-site trailer. Mr. Cavyell said that the trailer utilized a public water supply, rather than well water. In a

subsequent interview with Community Development Director Ernie Perry, Mr. Perry verified that the trailer was

hooked up to the pu blic water sup ply that serviced the airport.

Page 1 of 1

INTERVIEW RECORD


Subject: Five-Year Review for Del Norte Pesticide Storage Area Time: 10:30 am Date: 06/21/2005


Location of Visit: County of Del Norte, Community Development

Department, 981 H Street, Crescent City, CA 95531


Contact Made By:



Name: Ernie Perry Title: Director, C ommunity

Development Department

Organization: County of Del Norte,

Community Development Department

Telephone No: (707) 464-7254

Fax No: (707) 465-0340

E-Ma il Address: [email protected]

Street Add ress: 981 H Street, Suite

110


95531


I opened the interview with a short exp lanation as to the purpose o f EPA’s Five-Yea r Review process

(accord ing to Site file note s, Mr. Pe rry had bee n interviewed for the previo us Five-Ye ar Review conducte d in

2000 so this should have been familiar to him). I also provided him with a copy of the recorded restrictive

Covenant since his office did not have one. Mr. Perry verified that the trailer located at the County Agricultural

offices on Washington Blvd. utilized the same public water supply source as the airport, and that there were no

plans for development of the Site property other than a possible airport expansion that would necessitate the

condemnation of several residences along Riverside Street. Mr. Perry said that it was the County’s intention that

any commercial or industrial uses of the property at the airport be limited to airport-related activities. Mr. Perry

was surprised when I inform ed him that m y check into the General P lan and Zo ning Ma ps for the Site p roperty

showed that a portion of the Site property was zoned for manufacturing and industrial uses (the remaining portion

of the Site is zoned for resource conservation [basically open space]); he was under the impression that any

portion of the Site property that was not zoned as resource conservation was zoned purely for airport use. When I

noted that the County Department of Agriculture offices were located on-site, he said that these uses had been

“grandfathered in” but the County’s intention was to relocate the Department of Agriculture offices off-site and

utilize the area around the airport pu rely for aviation purposes.

Mr. Perry was also surprised to learn that a check I made into the permitted uses under the manufacturing and

industrial zon ing designatio n does no t preclude th e use of the Site property fo r a daycare or a schoo l, subject to

obtaining a use permit (although it does preclude a residential or hospital usage). Although there are no written

procedures in place for monitoring and enforcing the terms of the deed restriction and CD which include a

restriction aga inst the use of the S ite proper ty for a daycare or schoo l, Mr. Per ry felt confident tha t a use perm it

would not be granted by the County, since it is the County’s intention to remove the existing Department of

Agriculture offices and use the area around the airport, including the Site property, solely for airport-related

purposes. Mr. Perry indicated that the County’s Planning Department was small and staff were knowledgeable

Page 1 of 2


(Ernie Perry 06/21/2005)

about the Site as it was in the area of the planned airport expansion. Mr. Perry said that since the County-owned

Site parcel was carved out from the rest of the surrounding County airport parcels under different assessor parcel

numbers, that alone would suffice as a reminder to staff that there was something unique about the property and

would cau se them to loo k into any pro posed ne w use of the pr operty.

With regard to the recorded deed restriction, after showing Mr. Perry the recorded deed restriction, I discussed

my concern with him that it appeared that the restriction had been recorded against only one parcel of the subject

property (Parcel #120-020-36) and not Parcel #11 0-010-22. Mr. Perry said that the intention was to record the

deed restriction against the whole McNamara p arcel (both Parcels #110-010-22 and #120 -020-36) and that he

agreed that it appeared that the restriction was mistakenly recorded against only one parcel. Mr. Perry suggested

that EPA work with County Counsel Bob Black to resolve the matter.

There are no formal tra cking systems o r websites for m onitoring an d enforcing ICs. Mr. P erry said that a

combination of being a small County where there is widespread knowledge of special areas like the Superfund

site, a close working relationship between staff of different offices, an airport master plan that specifies that the

County property in that area only be used for airport related uses, and the ongoing push by the County to get folks

off of well water and onto municipal water, would serve to ensure that the terms of the CD and deed restriction

were carried out.

Page 2 of 2

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 9

75 Hawthorne Street San Francisco CA 94105-3901

Memorandum DATE: 26 August 2005 FROM: Ned Black, Ph.D. Regional CERCLA Ecologist/Microbiologist, SFD-8-4 TO: Kevin Mayer, PE, Remedial Project Manager, SFD-7-2 SUBJECT: Evaluation of ecological risk for the five year review of Del Norte

Pesticide Storage (CAD000626176), Crescent City, CA The remedy under five year review for this site is adequately protective of the environment. After a preliminary review of the information for this site, I identified two possible exposure routes by which residual contamination might reach ecological receptors. These were exposure to chromium in site soils and exposure to chlorinated pesticides in surface water expressions of the contaminated ground water plume. However, 1989 Explanation of Significant Difference for the Remedial Action at the Del Norte Pesticide Site determined that the soil chromium is attributable to background geology and so requires no risk management. With regard to the contaminants in ground water, the ground water monitoring program has demonstrated the contaminant plume is shrinking and all surface water expressions of ground water in the area near the site are upgradient of the contaminant plume. As such, it is clear there are no complete exposure pathways to ecological receptors. The details of this evaluation are as follows: Del Norte Pesticide Storage EPA ID# CAD000626176 Location: Crescent City, CA, Del Norte County ROD date: 9/85 ROD, 4/00 ROD Amendment 5 yr review date: 2005/4 Was there an ERA? Yes, environmental impacts were discussed in Risk Assessment Were habitat types/eco-receptors looked at? Yes

What contaminants present at the surface? groundwater - 1,2-Dichloropropane (1,2-DCP), 2,4-dichlorophenoxyacetic acid (2,4-D) soil - chromium Were complete exposure pathways considered? Yes Is a Section 7 (ESA) consultation letter or documentation of informal Section 7 consultation on file? Uncertain. Is there an evaluation of the presence of endangered species on file? Yes Can the statement that the remedy is “protective of the environment” be supported? Yes List of eco-relevant documents (Itx #s): 06-24-1985 Draft preliminary risk assessment - revised w/TL to Dave 6/24/85 0519-00476 06-15-1987 Draft Environmental Assessment 0519-00191 List of documents looked at (Itx #s): 06-24-1985 Draft preliminary risk assessment - revised w/TL to Dave 6/24/85 0519-00476 09-30-1985 51 Record of decision (ROD) for RA, w/marginalia & TL to J Ayres fr H Seraydarian 9/27/85

0519-01805

09-13-1985 Remedial investigation (RI) - final report w/TLs 0519-00438 06-24-1985 Draft preliminary risk assessment - revised w/TL to Dave 6/24/85 0519-00476 06-15-1987 Draft Environmental Assessment 0519-00191 09-21-1989 ESD for the Remedial Action 01-01-2000 Five year review

0519-01512 131091

04-2000 Amendment #1 ROD 0519-01756 Comments: The site, located outside Crescent City immediately south of an airport, is less than one acre is size in a rural area. It is contaminated with herbicides, pesticides, and other compounds. Del Norte County owns the pesticide storage facility and the surrounding land, about 480 acres that extends to the ocean 3/4 of a mile away. The nearest body of water is a small pond 600 ft to the southeast of the site. The ROD selected soil excavation and pumping and treatment of groundwater. In 1997 the pump and treat system was determined to not be making a significant impact on contaminated groundwater, and was discontinued. In 1989 it was discovered that chromium occurred naturally in site soils and therefore did not need remediation. The 2000 ROD Amendment granted a technical impracticability waiver of the cleanup goal for 1,2-DCP. Groundwater and soil are the only media likely to be of concern for ecological receptors. The risk assessment estimated that the potential toxicity at the nearby pond from migrating groundwater did not exceed aquatic toxicity benchmarks. Contaminated groundwater releases into the ocean were considered insignificant due to the dilution potential of the ocean. The soils on the site are a complete exposure pathway, but high concentrations of contaminants are found only on a small area. The potential for exposure and bio-concentration up the food chain were not considered significant at this site, but HQs were not calculated.

An environmental assessment was conducted, in accordance with the California Coastal Commission requirements, to determine the possible effects of the remedial action on neighboring wetlands. No endangered species are expected to use the site. The Marhoffer Creek Wetlands area, identified as a “major” wetland in Del Norte County, lies south of the study area. The surface contaminants probably do not pose a threat to ecological receptors at this site, although hazard quotients were not calculated for the soil exposure pathway.