UntadSMM
Environmental Proxaton
Ofltoof
EPA Superfund
Record of Decision:
Gurley Pit, AR
i-iCTi-.CTiON
ALLA3, TEXAS
IRARY
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40177-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROO/R06-88/016
S. Mdptonf» HcciMlQH Mo.
4. Tttto and Subtitle
SUPERPUND RECORD OF DECISION
Gurley Pit, AR
nd Remedial Action - Final
I, Performing Organization Root No.
9. Performing Organization Name and Address
la Project/Task/Work Unit No.
11. Contract(C) or GramXG) No.
(O
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, O.C. 20460
13. Type of Report * Period Covered
800/000
14.
IS. Supplementary Notes
1C. Abstract (Unite 200 words)
The Gurley Pit site consists of a 3.25-acre pit located approximately one mile north
of Edmondson, Crittenden County, Arkansas. The site lies within the 100-year flood
plain of Fifteen Mile Bayou, which discharges to the Mississippi River. Land in the
vicinity of the site is sparsely populated with five residences located within a 0.5
mile radius. The primary land use is agricultural. Gurley Refining Company (GRC)
leased the site from R.A. Caldwell between 1970 and 1980. During this time the pit was
by levees into three cells and used between 1970 and 1975 as a state permitted
site for secondary oil refining wastes including acids, oil sludges, PCBs,
inorganics and spent diatomaceous wastes. In March 1975, citizen complaints regarding
discharges from the pit led to investigations by the Arkansas Department of Pollution
Control and Ecology (ADPCE), which discovered permit and State environmental statute
violations by GRC. GRC abandoned the site in 1976. In May 1978, EPA and ADPCE received
complaints of chronic overflows from storm runoff. These overflows had an adverse
affect on fish and waterfowl in the Fifteen Mile Bayou. Subsequently, EPA conducted
separate spill cleanup operations in July 1978 and April 1979. EPA completed an
Enforcement Decision Document (EDO) in October 1986, which addressed the source control
operable unit consisting of the waste in the pits and the surface contamination. The
(See Attached Sheet)
17. Document Analysis a. Descriptors
Record of Decision
Gurely Pit, AR
Second Remedial Action - Final
Contaminated Media: not applicable
applicable
c. COSAT1 Held/Group
inability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
24
22. Price
(See ANSI-239.18)
See Instruction* on Reverse
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/R06-88/016
ley Pit, AR
fcond Remedial Action - Final
16. ABSTRACT (continued)
selected source control remedy included treatment and discharge of onsite surface water,
offsite incineration of PCB-contaminated oil, ground water monitoring, and stabilization
and onsite disposal of contaminated sludge, sediment, and soil. This ROD addresses the
ground water operable unit. Investigations have determined that contaminants from the
pit have not migrated through the subsurface into the ground water. Elevated levels of
inorganics (specifically arsenic and manganese) were detected but were consistent with
background levels. No site-related contaminants were identified in the ground water.
The selected remedial action for this site is no further action beyond that already
specified in the source control operable unit EDO. The ground water will be monitored
for at least thirty years to ensure that no migration of the contaminants occurs. There
are no Federal capital or O&M costs associated with this remedial action.
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DECLARATION OF THE RECORD OF DECISION
SITE NAME AND LOCATION
Gurley Pit site, Crittenden County, Arkansas. Groundwater Operable
Unit.
STATEMENT OF PURPOSE
This decision document describes the remedial decision for the Groundwater
Operable Unit of this site. This decision was developed in accordance
with the Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA) as amended by the Superfund Amendments and Reauthor-
ization Act of 1986 (SARA) and the National Contingency Plan (40 CFR
Part 300).
STATEMENT OF BASIS
This decision is based upon the administrative record for the Gurley
Oil Pit Superfund site. An attached index (Appendix C) identifies the
items which comprise the administrative record upon which the selection
of this remedial approach- is based. . .
DESCRIPTION OF REMEDY
The Environmental Protection Agency has decided that no additional
action above that specified in the October 6, 1986, Enforcement Decision
Document on the Source Control Operable Unit is necessary. Activities
recownend'?.), but which are already part of the source control design
include the following:
o Installation of a groundwater monitoring system.
o Monitoring the site for a minimum of 30 years following completion of
the source control remedy.
DECLARATION
This decision is consistent with the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 as amended by the Superfund
Amendments and Reauthorization Act of 1986, and the National Contingency
Plan. It, in light of the previously approved Source Control Remedial
Action, is protective of human health and the environment and attains
Federal and State requirements that are applicable or relevant and
appropriate.
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The Arkansas Department of Pollution Control and Ecology has been consulted
throughout the remedial investigation activities and concurs with this
decision for the Groundwater Operable Unit (Appendix D). The above
described action will be conducted in conjunction with the remedial
activities specified in the October 6, 1986, Enforcement Decision Document
for the Source Control Operable Unit.
Robert E. Lay ton Jr.', P.E. Date'
Regional Administrator
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SUWARY OF REMEDIAL ALTERNATIVE SELECTION
GURLEY PIT SITE
GROUNDWATER OPERABLE UNIT
EDMOND'SON, CRITTENDEN COUNTY-. ARKANSAS-
SEPTEMBER 1988
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TABLE OF CONTENTS
PAGE
I. SITE DESCRIPTION
Site Location 1
Site History 1
II. REMEDIAL INVESTIGATION RESULTS
Hydrogeologlc Setting 2
Nature and Extent of Contamination 3
Potential Risks to Human Health and the Environment .... 5
III. ENFORCEMENT 6
IV. COMMUNITY RELATIONS HISTORY 6
V. SELECTED REMEDIAL APPROACH
Rationale 6
Consistency with the National Contingency Plan and
Super-fund Statutes , 7-
Operation and Maintenance . 8
Future Actions 8
VI. APPENDICES
A. Table 1
B. Table 2
C. Administrative Record Index
D. Letter Regarding States Verbal Support of the
Proposed Record of Decision
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EXECUTIVE SUMMARY
The Gurley Pit Superfund site is located naar Edmondson, Arkansas.
From 1970 until 1975, the Gurley Refining Company used the site for
disposal of secondary oil refining wastes (including PCBs, lead and
zinc). Chronic spills occurred from the pit site when accumulations of
storm runoff exceeded the storage capacity. In 1978, EPA became involved
in the investigation of the site and assumed the lead agency role. A
source control Remedial Investigation/Feasibility Study (RI/FS) was
completed by EPA in April of 1986. The pre-SARA, Source Control
Enforcement Decision Document (October 6, 1986) dealt with the waste in
the pits and the surface contamination at the site. The selected
source control remedy includes incineration of contaminated oil, treat-
ment and discharge of surface water, and stabilization and disposal of
contaminated soil and sludges on-site. This Record of Decision will
address the potential groundwater contamination.
Following the source control operable unit, EPA initiated a two-phased
groundwater operable unit RI. The results of the Phase I sampling
showed elevated levels of inorganics (specifically arsenic and manganese),
but no organic contaminants were attributed to the pit waste. The
results of the Phase I sampling were inconclusive with regard to back-
ground water quality.
* * f * . *
Water quality data.obtained in the Phase II investigation led to the
conclusion that contaminants from the pit have not migrated through
subsurface into the groundwater. The results of the baseline public
health assessment related to the groundwater operable unit showed that
the identified haalth risks were associated with the background water
quality conditions. Background arsenic levels in tire shallow alluvial
aquifers resulted in a lifetime cancer risk of 9 x 10" . Water from
these aquifers is used primarily for irrigation. Following a comprehensive
review of the data, EPA made the decision not to conduct a feasibility
stJdy since no groundwater contamination was present.
EPA's proposed remedial approach is No Further Action beyond that
already specified in the Source Control Operable Unit Enforcement
Decision Document. As part of the Source Control activities, the site
will be monitored for a period of at least thirty years to ensure that
no migration of the contaminants occurs.
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Summary of Remedial Alternative Selection
Groundwater Operable Unit
Gurley Pit Site
Crittenden County, Arkansas
V September 1988
I. SITE DESCRIPTION
Site Location
The Gurley Pit site is located at the northwest corner of the inter-
section of County Roads 175 and 14, approximately 1.2 miles north of
Edmondson, Crittenden County, Arkansas (Figure 1). The site, consists
of a pit divided by levees into three cells. It occupies 3.25 acres in
the 100-year floodplain of Fifteen Mile Bayou. Fifteen Mile Bayou is a
tributary of the St. Francis River, which is a tributary of the Mississippi
River.
The lands in the vicinity of the site are sparsely populated and the
primary land use is agricultural. Five residences are located within
a 0.5 mile radius of the site. The nearest community to the site is
Edmondson, Arkansas, located about 1.2 miles to the south, with a
population of 412. In .1980, the totdl population of Critteaden County .\
was estimated to be 49,097. . '
Site History
The pit was excavated sometime prior to 1970, when the Arkalite Company
re.io/ed the soils for use in aggregate production. Mr. W.A. Caldwell,
the current owner of tha site property, leased the site to the Gurley
Refining Company from July 14, 1970, to July 13, 1980. The Gurley
Refining Company leased the pit area for use as a disposal site for
secondary oil refining wastes.
A waste disposal permit was granted by the Arkansas Department of
Pollution Control and Ecology (ADPCE) on September 25, 1970. Use of
the pit for disposal of secondary oil refining wastes, including acid
oil sludges and spent diatomaceous filter materials, continued until
1975. In March 1975, ADPCE received citizen complaints regarding
discharges from the pit. The subsequent investigation and trial
resulted in the conviction of the Gurley Refining Company on charges of
violation of its waste disposal permit and violation of the Arkansas
Water and Air Pollution Control Act. Sentence was suspended for a
- period of one year to enable the Gurley Refining Company to develop a
plan for site cleanup. In October 1975, the Gurley Refining Company
shut down the part of their refining operation that generated the
wastes disposed of at the site.
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QURLEY
OIL PIT SITE
1 MILE
Source Edmondson
U.S.G.S. 7.5 Minute Topographic Quadrangle
FIGURE 1
LOCATION MAP
GUBJ.EY OIL WT StTE
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After Gurley Refining Company abandoned the site in 1976, EPA and ADPCE
received complaints of chronic overflows occurring at the site. These
overflows, which were reported in May 1978, had an adverse affect on
fish and waterfowl in Fifteen Mile Bayou. In July 1978, and then again
in April 1979, EPA conducted spill cleanup operations undar Section 311
of the Clean Water Act.
ADPCE conducted a program of regular site inspections after the 1979
spill and in August 1981, indicated that conditions at the site were
essentially unchanged. In 1983, the site was evaluated using the Hazard
Ranking System and subsequently listed on the National priorities List.
EPA completed a remedial investigation/feasibility study (RI/FS) on the
source control operable unit in April 1986. The source control operable
unit RI/FS investigated characteristics of the waste contained in the
pits and the contaminated soil and water and evaluated possible remedial
alternatives. EPA's October 1985, Enforcement Decision Document (pre-
SARA) dealing with the sourca selected a reined/ consisting of the following;
o treatment and discharge of onsite surface water,
o retfloval and off-sit3 incinsra'cion of PCB contaminated oil,
o stabilization and disposal of contaminated sludge, sediment, and
soil onsite.
o groundwater monitoring for a period of at least thirty years.
Based on the limited amount^ of groundwatar data developed during the
source control operable uni't, EPA decided to conduct a separate, more
comprehensive, groundwater study. The groundwater study was conducted
from April 1987, to July 1988.
II. REMEDIAL INVESTIGATION RESULTS
Hydrogeologic Setting
There are three major aquifers in Crittenden County: the deep "1,400-
foot sand" of the Wilcox Group, which supplies all municipal wells in
the county; in intermediate "500-foot sand" of the Clairborne Group,
which is comparatively undeveloped; and the shallow alluvial Quaternary
deposits, which supplies the majority of the domestic wells in the county.
A generalized cross-section of the geology under the site is illustrated
in Figure 2. The Wilcox Group is about 300 feet thick and consists of
silts and sands. Overlying the Wilcox Group is the 900- to 1000-foot
thick Clairborne Group made up of a series of interbedded sands and
lignitic clays. Quaternary age alluvial deposits overlie the Clairborne
Group. These surficial, alluvial deposits extend to a depth of about
200 feet and consist of a basal graveliferous unit and an upper non-
gravel iferojs unit. The basal gravel ranges in depth from about 90 to
200 feet and is the principal aquifer used for irrigation in the area.
These alluvial deposits grade irregularly upward from coarse sand and
gravel at the base to progressively finer sands, silt, and clay. Due
to the naturally occurring poor water quality, most domestic wells in
the upper allu/ial deposits ar.j jsad solely fo~ irrigation purposes.
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ALTT
ft
200 -I
100-
MEAN SEA
100-
200 -
300
400
900-
700 '
no
1000<
1100-
1200*
1300*
1400-
1500-
1000
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1900-
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2100-
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TUDE
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^x GROUND SURFACE
ALLUVIUM
CLA1BORNE GROUP
UPPER UNIT
* i^^B^
WILCOX
GROUP 1400-FOOT SAND
LOWER UNIT
PORTERS CREEK CLAY
MIDWAY
GROUP
CLAYTON FORMATION
TOP OF UPPER CRETACEOUS
FIGURE 2
GENERALIZED GEOLOGIC SECTION
GURLEY OIL PITS
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Water from the Quaternary alluvial deposits has high concentrations of
iron and other dissolved metals.
Regionally, groundwater flow is to the southwest. Some variation in
flow from the southwest to the southeast is found near stream boundaries,
depending on stream stage.
Primary groundwater use within 2 miles of the site is for irrigation.
Drinking water supplies are provided by the Midway Water Association.
A 1,585-foot deep well completed in the Wilcox "1,400-foot sand"
provides the Midway Water Association with its water. This well is
located approximately 2.2 miles southeast of the site. The nearest
residential well is located 0.4 miles south of the site, on the south
side of Fifteen Mile Bayou. This well is used for irrigation.
Nature and Extent of Contamination
In 1984, three deep (50-foot) and five shallow (25-foot) wells were
installed along the pit boundaries in the upper portion of the alluvial
deposits (Figure 3). Water level measurements in the deeper alluvial
sand deposits showed an indistinguishable gradient or flat piezometric
surface. Water level measurements did, however, indicate that the deep
and shallow wells were completed in two separate water bearing zones.
The two zones are separated by low permeability clays that range .from
24 to 42 feet in thickness and overlie the deeper alluvial aquifer.
The limited groundwater sampling that took place before the source
control decision showed that maximum concentration levels (MCLs) for
some metals in the groundwater were exceeded. However, data from this
sampling could not adequately define background groundwater quality
near the site, nor adequately determine if a plume of contamination was
present at the site. Therefore, a conclusion as to whether or not pit
wastes were contaminating the groundwater could not be made.
Following the source control study, EPA initiated a two-phased groundwater
study. The purpose of the first phase was to resample the onsite
wells and to research available groundwater data. The purpose of the
second phase was to install additional off-site wells and to further
define background groundwater quality for the upper two alluvial water
bearing zones.
Phase I Results
During the first phase of the groundwater operable unit, the eight
wells installed during the source control operable unit activities
were resampled. Also sampled during Phase I was a private well, located
0.4 miles south of the site. Use of this well, as a reliable background
well, was later ruled out due to the unknown construction methods used
during installation and its location outside the extent of the shallow
alluvial aquifers. Table 1 lists, for all wells sampled, contaminants
that approach or exceed Safe Drinking Water Act and/or Clean Water Act
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OO»-M
OOP-IT 9
000-01
Source Control RI
Monitoring Wells
Phase II Groundwater |!|!?
Operable Unit RI ',', ,','
QOP-I1,
Monitoring Wells-
FIGURE 3
MONITORING WELL LOCATIONS
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criteria. A comprehensive summary of all groundwater data developed
during both Phase I and Phase II can be found in Appendix A of the
Gurley Oil Pit Groundwater Operable Unit RI report (August 1, 1988).
Groundwater data was then compared to maximum contaminant level (MCL)
criteria and Ambient Water Quality Criteria (AWQC). MCLs are criteria
which establish the maximum permissible level of contaminants in a
drinking water supply. AWQC are numerical guidelines from which to
determine whether a surface water quality problem exists. AWQC are
used for comparative purposes when no other water quality criteria
exists. From the Phase I samples, the maximum concentration for total
(unfiltered) arsenic in one deep well exceeded the MCL. All of the
samples analyzed, including the sample from the off-site well located
0.4 miles to the south, contained iron and manganese in concentrations
exceeding their secondary MCLs. Two samples also contained total nickel
concentrations above the Ambient Water Quality Criteria (AWQC). The
organic analyses indicated that no MCLs or AWQC were exceeded in either
the shallow or deep groundwater system. The high metals concentrations
found in the groundwater were thought to be attributable to the background
water quality for the area. In order to more accurately define background
groundwater quality near the site, the decision was made to install
additional off-site wells during the Phase II activities.
Phase II Results . .."..
Since existing site wells covered only a limited area, the background
water quality and the direction of groundwater flow could not be
accurately defined during the Phase I activities. To further define
these parameters, EPA developed a limited groundwater monitoring well
expansion program. Six monitoring wells were installed during the
Phase II investigation (Figure 3).
Samples collected during well installation provided information on the
geology beneath the site. The first 30 feet or so of soils beneath the
Gurley Oil Pit site is very uniform. The clays underlying the site
range in depth from 24 to 42 feet. This clay layer has evidently
served to impede contaminant migration and contain the waste within the
pit-boundaries. Permeability of the clay layer ranges from 10 to
10 centimeters per second. Water production from the shallow wells
was minimal due to the low permeability and limited extent of the water
bearing lenses. Beneath the upper clay layer are fine to medium grain
sands of the lower alluvial aquifer.
Groundwater samples were collected for organic and inorganic analysis
from each of the site monitoring wells. A summary of the inorganic
analysis of the groundwater is presented in Table 2. The concentrations
of inorganic chemical constituents were affected by the presence of
sediments in most of the samples. For this reason, dissolved (filtered)
metals samples were used to provide a reliable indication of the actual
groundwater quality. The results of the dissolved metals analysis
indicated that arsenic, iron, and manganese all exceeded maximum
contaminant level (MCL) requirements set forth by the Safe Drinking
Water Act. However, the presence of arsenic, iron, and manganese
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is not attributable to the pit contaminants. These metals were also
detected in the background wells installed during the Phase II activities
and exist in the water of the shallow alluvial deposits at elevated
concentrations. The source of the arsenic in this area is not known, but
may be due to the historic agricultural use of arsenic-based herbicides,
pesticides and insecticides.
Acetone and methylene chloride were the only organics identified above
detection limits. These compounds are not considered to be site related.
Acetone and methylene chloride are typical laboratory contaminants and
this was confirmed by their presence in the blank samples. No other
pesticides, PCBs, semivolatiles (BNAs), or volatile organics were
identified above the sample detection limits.
The lack of organic constituents identified in the groundwater indicates
that there is no correlation between the pit contaminants and the ground-
water water quality. The lack of organics in all of the wells indicates
that pit contaminants have not migrated from the site. If leakage from
the pit had occurred, mobile organic oil refinery wastes would have
been detected in the monitoring well samples.
After conducting a thorough review of the Phase I and II data, EPA made
the decision not to conduct a feasibility study on the Groundwater
Operable Unit. EPA's decision not to conduct a feasibility study is .
supported by the fact that no site-attributed co'ntaminants were identified
in the groundwater and, therefore, it was not necessary to develop and
evaluate various remedial alternatives.
Potential Impacts of the Site on Human Health and the Environment
Although no site-related contaminants were identified in the groundwater,
potential future health risks do exist from the ingestion of shallow
groundwater at the site. These health risks are due to the poor background
groundwater quality in the vicinity of the site. The appropriate Federal
and State authorities have been notified of the health risks associated
with the groundwater.
It is important to note that there is not, however, an immediate health
risk. The primary use of water from the shallow alluvial deposits is
for irrigation. Drinking water supplies are provided by the Midway
Water Association. The Midway Water Association obtains its water from
a 1,585-foot deep well located 2.2 miles southeast of the site. Water
from the Midway Water Association was tested during the source control
remedial investigation and was found not to exceed any health based
criteria.
The contaminants of primary concern in the background water at the site
are manganese and arsenic. A risk assessment was conducted to evaluate
the health risks associated with the high concentrations of inorganics
found in the groundwater. The results of the analysis showed an excess
lifetime cancer risk of 9 x 10 from exposure to arsenic in the deep
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(50 foot) background well. No organic compounds were found to exceed
water quality criteria in any of the groundwater samples analyzed.
III. ENFORCEMENT HISTORY
On April 15, 1983, EPA sent notice letters to R.A. Caldwell, the
property owner, and to Larry Gurley of Gurley Refining Company, Inc.
and Gurley Refining Company for a commitment to conduct the RI/FS. On
July 19, 1983, letters were sent to the parties setting a final deadline
of July 29, 1983, for receipt of a commitment from the parties to conduct
the RI/FS. Uhen no commitment was received, EPA informed the parties
by letter, dated September 1, 1983, of EPA's decision to do the RI/FS.
Following completion of the Source Control Operable Unit RI/FS, notice
letters were sent to Mr. Caldwell and to Gurley Refining Company, Inc.
on May 7, 1986, asking if they would voluntarily perform the necessary
remedial work. A second set of notice letters were sent in July 1986,
requesting a specific affirmation or refusal to conduct the work. The
parties failed to respond within the specified time. A complaint has
been filed in District Court, Civil Action No. J-C-87-291 in the Eastern
District of Arkansas, for recovery of costs incurred by EPA during
conduct of the RI/FS. The case is in pre-trial status.
IV. COMMUNITY RELATIONS HISTORY
.Community concern beyond the residents in'the immediate site area is
very low. 'During the previous comment period on source control, nearby
residents and the Mayor of Edmondson expressed a desire for action to
clean-up the source of the contamination.
On August 1, 1988, EPA issued a press release and the Proposed Plan
fact sheet. The press release was mailed to all news organizations in
the northeast Arkansas/Memphis, Tennessee area, while the fact sheet was
mailed to interested citizens and elected officials. Extra copies of
the fact sheet were provided to the three local repositories for display
purposes.
Both the press release and the fact sheet announced the comment period
from August 8 through September 8, 1988. Also, the community was given
an opportunity for a public meeting to discuss the proposed plan.
There were no requests for a public meeting and no comments or questions
during the comment period. Since no comments or questions were received,
the Responsiveness Summary to this document has been omitted.
V. SELECTED REMEDIAL APPROACH: No Further Action
Rationale
As mandated by the Comprehensive Environmental Response, Compensation and
Liability Act of 1980 (CERCLA) as amended by the Superfund Amendments
and Reauthorization Act (SARA, 1986) and in accordance with the National
-------
Contingency Plan (NCP) several statutory requirement must be met for
selecting the appropriate remedial approach for a Superfund site:
o Overall protection of Human Health and the Environment
o Consistency with Other Environmental Laws
o Cost Effectiveness
Based on the findings of the remedial investigation and the Public
Health Evaluation, EPA concludes that no active remediation of the
groundwater beyond the remedy for the source of contamination is
warranted or necessary. Activities which are recommended and are
already part of the source control design include installation of a
groundwater monitoring system and monitoring the site for a period of
at least thirty years. Groundwater monitoring will be conducted as
part of the source control activities and will be carried out in
compliance with 49 CFR Part 264. 117 (a), which requires thirty years of
monitoring after closure of a hazardous waste disposal facility. If
however, unanticipated contaminant migration is detected during the
monitoring period, appropriate remedial measures will be taken.
As detailed in the remedial investigation, no site related contamination
was identified in the groundwater. This, along with the finding of the
Health. Evaluation that no health risks are, attributable to the site,
supports' the decision not to conduct any remediation 'of the groundwater.
Furthermore, implementation of 'the source; control renedial action will
prevent any future contaminant migration. The source control remedial
action will protect the groundwater and human health through removal of
the source.
For those contaminants of concern which are not attributed to the
Gurley Pit site, an excess life^im? :i-icer risk of 9 x 10 has been
estimated. This cancer risk assumes that water from the shallow
alluvial aquifers will be used as a potable water supply sometime in
the future. This information is being reviewed by the appropriate
Federal and State authorities. The Agency for Toxic Substances Disease
Registry has been notified of the analytical data results.
Consistency with the National Contingency Plan and the Provisions of
the Superfund Amendments and Rjeauthorizati on Act
This decision, in conjunction with the remedial action approved in the
October 1986 Source Control Enforcement Decision Document, provides for
protection of public health, welfare, and the environment. In addition,
this decision is consistent with the National Contingency Plan (NCP),
40 CFR 300.68(d) which requires the lead agency to gather sufficient
information to determine the necessity for and proposed extent of
reiiedial dcticn. Tsvelop.ie'it jf remedial alternatives was not
warranted in this situation on the following basis:
o Site related contamination was not detected in the groundwater and
thus, no site attributable risk to human health and the environment
pertains to the groundwater.
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8
o Current site related groundwater concentrations do not exceed any
Federal or State standards. The no further action remedial approach
is, therefore, consistent will applicable environmental laws.
o The expenditure of additional funds to implement a groundwater re.nedy
at the Gurley Pit site would not result in any additional protection
of human health and the environment. Therefore, the decision not to
conduct any further action is considered cost effective.
Operation and Maintenance
Future operation and maintenance will center around monitoring the
effectiveness of the remedial activities specified in the October 1986,
Source Control Enforcement Decision Document.
The operation and maintenance of the site will be the responsibility of
the Arkansas Department of Pollution Control and Ecology (ADPCE). EPA
will fund the first year of operation and maintenance, after which time
ADPCE will take full responsibility.
Future Actions
No future renedial actions, beyond those dctivities approved in the
Source Control Enforcement Decision Document, are anticipated.
SARA Section 121(c) states; "If the President selects a remedial action
that results in any hazardous substances, pollutants, or contaminants
regaining at the site, the President shall review such, remedial action
no less than each 5 years after the initiation of such remedial action
to assure that human health and the environment are being protected by
the remedial action being implemented."
Five year reviews will be rsquired at this sita since the source control
activities will dispose of the waste onsite.
Schedule
Approve Remedial Approach (sign ROD) September 1988
* * *
Complete Source Control Remedial Design September 1988
Start Source Control Remedial Action March 1989*
(Sroundwater monitoring system installed
as part of these activities)
Complete Source Control Remedial Action November 1990
(Begin 30 years of monitoring)
* This assumes timely State match
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APPENDIX A
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APPENDIX C
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APPENDIX D
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION VI
4' ""01* 1445 ROSS AVENUE, SUITE 1200
DALLAS, TEXAS 75202
SEP ? 8 198B
Mr. Paul Means
Director
Arkansas Department of Pollution Control
and Ecology
8001 National Drive
Little Rock, Arkansas 72219
Dear Mr. Means:
The purpose of this letter is to summarize agreements we reached at our
September 23, 1988, meeting regarding the Gurley Oil Pit Superfund
site. You indicated that the Arkansas Department of Pollution Control
and Ecology (ADPC&E) would support the Environmental Protection
Agency's (EPA) proposal that no remediation of groundwater is
necessary, if the Record of Decision clarifies:
1. that this decision is based on the precise'that source
contaminants are permanently isolated or removed from the
environment rather than a specific source control technology,
and;
2. that 0 & M costs would be established by the 0 & M plan to be
developed by EPA and ADPC&E at a later date.
In addition, we discussed the State's concerns regarding the source
control remedy (a RCRA vault) selected in EPA's October 5, 1986
Enforcement Decision Document. We agreed that a joint, in house,
assessment of other potential source control remedies would be
completed by November 15, 1988. This assessment would include such
factors as cost, implementability, and whether the alternatives would
need to comply with SARA or CERCLA. Based on this study, the viability
of constructing a vault using 90% Federal and 10& State funds will be
determined.
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If I have miscoast.r,i.-ix1 -jr ouiiUed iiy $igni?ic,n- ;J3> its, please lei .
Viov as soon as possible. Otherwise, we will proceed to sign the
Record of Decision for groundwater at Parley and work with Mike Bates
to frame the in house study parameters.
Sincerely yours,
x<-<'"
1 Cart-E. '-EdTund, Chie
Suparfund Program Braoc'i
::: Mike Bates
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