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 •
1700-
1MO •
1900-
2000 *
2100-
2200 *
2300 -
2400-
2500-1
TUDE
ET
»
.EVEL
»
»
»
K
•

»
»
»
»
»
•
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•1
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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

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 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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         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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