1 ST FIVE-YEAR REVIEW

GURLEY PIT SUPERFUND SITE

EDMONDSON, CRITTENDEN COUNTY, ARKANSAS

January 1997

Prepared by:

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

Region 6

Dallas, Texas

800882

I. PURPOSE

Pursuant to the Comprehensive Environmental Response, Compensation,and Liability Act (CERCIA), as amended by the Superfund Amendmentsand Reauthorization Act of 1986 (SARA), Sections l2l(c) and3 0 0 . 4 3 0 ( f ) ( 4 ) ( i i ) of the National Oil and Hazardous SubstancePollution Contingency Plan (N C P ) , and Office of Solid Waste andEmergency Response (OSWER) Directives 9355.7-02 (May 23, 1 9 9 1 ) , and9355.7-02A (July 26, 1994) a statutory five-year review is requiredfor remedial actions selected on or after October 17, 1986. TheGurley Pit remedy was selected on September 26, 1988. A Five-YearReview has been conducted by the Environmental Protection Agency(EPA) on the Gurley Pit Superfund site. The purpose of this reviewis to ensure that the site remains protective of human health andthe environment.JJ. BACKGROUND

The Gurley Pit is a 3.25-acre site located 1.2 miles north of thecommunity of Edmondson, Arkansas, which has a population of 286residents. It is surrounded on one side by a small residentialcommunity and on three sides by farm land and is located northwestof the intersection of County Road 14, County Road 175, and StateHighway 131 in Crittenden County. The site is located in thefloodplain of 15 Mile Bayou which is approximately 400 feet southof the project and includes five residences within a half-mileradius of the site.The site originally consisted of one large pit which was excavatedfor the clay material contained within this area. Subsequent tothis, Gurley Refining C o . , Inc., leased the property fromRobert Caldwell for use as a disposal area in 1970. The site wasdivided into three cells for disposal of sludges from the refiningof used motor oil with major contaminants being lead, barium, zincand polychlorinated biphenyls (PCBs). Waste disposal operationswere permitted by the Arkansas Department of Pollution Control andEcology (ADPC&E) from 1970 until 1975 when Gurley Refining Company,Inc., notified the State that disposal had stopped and the site wassecure.There are three major ground water aquifers within CrittendenCounty which are found at depths of 40 to 200 feet, 300 to 1125feet, and 1400 to 1700 feet. The deepest aquifer is used for onlymunicipal wells, the middle aquifer is not used, and the shallowaquifer is used for mostly domestic wells. As detailed in theremedial investigation, no site related contamination wasidentified in the groundwater. Furthermore, implementation of thesource control remedial action results on record support the priordecision not to conduct any remediation of the groundwater.

The wells found in the shallow aquifer are used for irrigationpurposes. Poor water quality is evident from the dissolved metalanalysis addressed in Appendix A of the Gurley Oil Pit GroundwaterOperable Unit RI Report, Phase I and Phase II, dated August 1,1988. The report indicates that arsenic, iron, and manganeseexceed the maximum contaminant level (MCL); however, theseexceedances are not attributable to the pit contaminants. Theresidences surrounding the Gurley Pit site are supplied drinkingwater by a 1,585-foot deep well located in the Wilcox aquxi-er andis known as the Midway Water Association. Water from the MidwayWater Association was tested during the source control remedialinvestigation and was found not to exceed any health basedcriteria.JJJ. REMEDIAL PLANNING ACTIVITIES

After Gurley Refining Company abandoned the site in 1976, the EPAand ADPC&E received complaints of chronic overflows occurring atthe site. There were two releases from the pit, one in May 1978and another in April 1979, requiring response actions by the EPA.It is estimated that as many as 500,000 gallons of oil werereleased during the second event. The site was proposed forinclusion on the National Priorities List in December 1982 and waslisted in August 1983. Several attempts were made by the EPA toget the Potentially Responsible Parties (PRPs) to conduct theRemedial Investigation, Feasibility Study, Remedial Design andRemedial Action, however, the PRPs failed to take any action,requiring fund monies to be spent.The EPA completed a Remedial Investigation/Feasibility Study(RI/FS) on the Source Control Operable Unit in April 1986. TheRI/FS for the Source Control Operable Unit included aninvestigation of the characteristics of the waste c< tained in thepits and contaminated soil and water, as well as an evaluation ofpossible remedial alternatives. Based on the limited amount ofground water data developed for the Source Control Operable Unit,the EPA decided to conduct a separate, and more comprehensive,ground water study from April 1987 to July 1988.On March 2 6 , 1992, the Government won a summary judgement againstWilliam Gurley, Larry Gurley, and Gurley Refining C o . , Inc, for allpast and future costs associated with this facility. The EPAproceeded to implement the Remedial Action and signed a SuperfundState Contract with ADPC&E in March 1992.IV. REMEDIAL ACTIVITIES

After reviewing the results of the Remedial Investigations andFeasibility Studies, the EPA issued two separate decision documentsfor the Gurley Pit Superfund Site. The project was divided intoSource Control and Ground Water Operable Units. The Ground WaterOperable Unit (GWOU) investigation culminated into a Record of

Decision (ROD) dated September 26 , 1988, and concluded that nofurther action was necessary provided the source control measurewas implemented. The Enforcement Decision Document signed onOctober 6 , 1986, included the following major components:

• On-site water treatment of contaminated surfacewaters, discharge of these waters to 15 Mile Bayou,and incineration of any recovered oils from thisprocess at an approved off-site PCB facility;

• Solidification of contaminated sludge, sedimentsand soil and placement of the solidified materialin a Resource Conservation and Recovery Act (RCRA)compliant vault located in the center and southcells; and,

• Placement of appropriate monitoring wells, withprovisions for long-term operation and maintenancefor the RCRA vault and related monitoring wells.

During the Remedial Design, it was determined that an insignificantchange to the Enforcement Decision Document was necessary from acost and constructability standpoint. The location of the RCRAvault was moved from the north cell toward the south; this wasdeemed necessary because the north cell contained approximately 85percent (85%) of the contaminated materials. By using the northcell as a temporary holding cell for all contaminated materialsduring construction, it reduced the volume of contaminated materialwhich was required to be handled prior to construction of the RCRAvault. This saved the EPA and ADPC&E costs for unnecessaryhandling and it reduced the potential for spillage during handlingoperations. In addition, this approach allowed the EPA toaccommodate ADPC&E's concerns about the overall height of the RCRAvault by allowing the vault to be spread out over a larger surfacearea.Under the direction of the EPA, the US Army Corps of Engineers(USACE) entered into negotiations with the Small BusinessAdministration, and a contract was awarded to a minority business,Mobley Contractors, Inc., on July 31, 1992. The notice to proceedwas issued on September 9 , 1992. Mobilization occurred onOctober 2 6 , 1992. Full-scale construction commenced onNovember 13, 1992.Remedial activities were conducted as planned, and no additionalareas of contamination were identified. The six new site-monitoring wells were installed on June 21, 1994. The firstsampling was conducted on November 10, 1994.The EPA, ADPC&E, and the USACE conducted a pre-final inspection ofthe site on August 12, 1994, and a final inspection on August 31,1994. A letter from the EPA to the USACE on September 12, 1994,

certified that the Remedial Action activities had been performedaccording to the Remedial Design package.Liquid removal from the detection and collection sumps was found tobe restricted. The site Contractor, Mobley Construction, wasissued a modification in October 1995 to add perforations to theleachate collection and leak detection sump riser piping.

V. RESULTS OF OPERATION OF THE REMEDIAL ACTION AND DATA REVIEW OFOSACE

In September 1995, the end of the first year of operation, it wasnot evident what the volume of liquid was in the detection andcollection systems. Measurements were made which indicated thewater was approximately eight ( 8 ) feet in depth but the totalvolume within the cell was unknown. The State was concerned thatthis water indicated the liner was damaged during landfillconstruction. Based on these measurements and in accordance with40 CFR, Part 300.435 ( f ) ( 2 ) , the one-year operational andfunctional (O&F) period was extended by the EPA. The USACE secureda contractor and installed a permanent electrical supply box forwater pumping operations at the site. The USACE staff beganpumping operations on May 20, 1 9 9 6 , and pumped 52,300 gallons ofleachate through September 13, 1 9 9 6 . Currently, the USACE staffadvised they are pumping 1,200 to 1,500 gallons of water per weekwith depth measurement of around three feet at the beginning ofeach weekly event.The results of the test analysis for contaminant concentrations inthe pumped and tank-stored waters were below the maximum stated inthe Remedial Action Contract, Section 01410 pages 13 through 21 asapplicable for surface discharge. Therefore, the water wasdischarged to surface flow. This water was attributed to heavyrainfall during construction of the cell which evidently saturatedthe sand drainage system in the cell and does not indicate anyproblems with the remedy nor the integrity of the cell.Table 1 represents the submittal by Mobley Contractors, Inc.,delineating the results of five quarterly sampling results throughApril 3 , 1 9 9 6 . An additional sampling result by the USACE, viaAmerican Interplex Corporation Laboratories, on August 30, 19 9 6 , isalso listed. The ground water monitoring results support the factthat no site-attributed contaminants were identified in the groundwater and, therefore, the RCRA-compliant on-site landfill cellprovides adequate protection of the public health and theenvironment.

VI. ARARS SEVIESf

Section 1 2 1 ( d ) ( 2 ) ( A ) of CERCLA, as amended by SARA, requires thatSuperfund remedial actions meet all Federal standards,requirements, criteria or limitations that are determined to belegally applicable or relevant and appropriate requirements(ARARs). This Section also requires that approved State ARARs,which are more stringent than Federal requirements, be met.The Gurley Pit ROD identified the following as having an impact onthe proposed remedy:

Resource Conservation and Recovery Act (RCRA):Applicable to hazardous waste landfill and ground watermonitoring. The hazardous waste landfill was designedand built in accordance with RCRA regulations andguidance. A liner system, leachate collection system,and multi-layer cap meeting the requirements of 40 CFR,Part 264, are components of the disposal cell.

Ground water monitoring system consisting of six wells onsite and two off-site wells: As discussed in Section VI,no significant contamination has been detected in theground water at the site to date that would necessitateimplementation of a corrective action program (Seeattached Table 1 ) . Since the establishment of the ROD,RCRA regulations have not been revised to the extent thatthey call into question the protectiveness of the remedy.Ground water monitoring results are compared to currentstandards listed under 40 CFR, Part 264, Subpart F.

The State of Arkansas has not issued any new applicable regulationssince the remedial action was completed that would require re-examination of the protectiveness of the remedy.

VII. SUMMARY OF THE 0 & F SAMPLING EVENTS

The ROD called for implementation of a ground water monitoring andleachate water sampling and analysis/removal program at the site,as well as maintenance of the sumps, fence, and the site wells. Asreported in August 1, 1988, during Phase II of the GWOU, theconcentrations of inorganic chemical constituents were affected bythe presence of sediments in samples taken in the site-monitoringwells. For this reason, dissolved (filtered) metals samples wereused to provide a reliable indication of the actual groundwaterquality. These metals and the total organic carbon are reflectedin Table 1, Pages 9 , 10, 11, and 12. Six new monitoring wells (MW-A through MW-F) were installed and developed on site duringRemedial Action and two off site existing monitoring wells (MW-30

5

& MW-31) were monitored in each of the six sampling events listed.

TABLE 1GURLEY PIT SUPERFUND SITE

Quarterly Monitoring Results

well

A

B

C

Sample Date

10 NOV 9413 Fob 9525 May 9517 Aug 9509 NOV 9504 Apr 9630 Aug 96Duplicate

10 NOV 9413 Feb 9525 May 9517 Aug 9509 NOV 9504 Apr 9630 Aug 96

10 NOV 9413 Feb 9525 May 9517 Aug 9509 NOV 9504 Apr 9630 Aug 96

Barium

0.2620.3330.2930.2780.3190.2690.2700.270

0.6480.4590.3480.5680.5110.3630.330

0.5940.4210.4100.3730.3770.3430.330

Lead

0.0060.0100.0060.004

<0.000.006

<0.04<0.04

0.02"0.0140.0040.0180.0130.006

<0.04

0.0210.0090.0080.0040.0060.006

<0.04

Zinc

0.0910.0370.0500.1030.0260.0230.0130.012

0.1470.0670.0480.1030.072

<0.020.014

0.1370.0360.0820.0500.046

<J.020.043

TOC

4.24.64.1

<3.04.15.82.01.9

3.55.24.7

<3.04.0

14.72.0

3.75.64.5

<3.04.94.82.3

pH-1

8.307.107.286.507.316.657.00

8.307.007.406.156.886.666.76

8.107.307.607.206.776.996.88

pH-2

8.107.507.306.547.015.756.97

8.107.508.026.746.866.206.79

8.007.507.387.206.796.976.89

pH-3

8.007.507.266.827.045.266.93

8.107.607.416.976.856.816.83

8.007.707.477.106.726.986.89

pH-4

8.007.607.297.036.985.196.96

8.107.607.407.146.826.986.79

8.007.607.357.206.706.996.88

* Obstructed Well** Dry Well10 Nov 94 Incomplete Sampling Event, Not Accepted

TABLE 1 - CONTINUEDGURLEY PIT SUPERFUND SITE

Quarterly Monitoring Results

Well

D

E

Sample Date

10 NOV 9413 Feb 9525 May 95DuplicateTriplicate17 Aug 95DuplicateTriplicate09 Nov 95DuplicateTriplicate04 Apr 9630 Aug 96

10 NOV 9413 Feb 9525 May 9517 Aug 9509 Nov 9504 Apr 9630 Aug 96

Barium

*2.0900.1040.1210.6590.2440.2190.1721.1801.6100.8850.7680.260

*0.8310.5840.3620.6140.4360.380

Lead

*1.2400.0110.0180.2100.0380.027

<0.0300.3440.7200.3060.199

<0.04

*0.0290.013

<0.0030.0160.009

<0.04

Zinc

*0.8860.0280.0310.2530.0760.0610.0450.4540.7390.3350.2600.031

*0.1470.0770.0270.0860.0380.013

TOC

*14.938.034.220.813.611.211.625.418.946.87.82.8

*6.85.1

<3.04.44.61.7

pH-1

*9.90

12.32

11.80

7.65

8.996.97

*7.507.376.816.707.106.98

pH-2

*10.2011.86

11.30

8.09

8.987.05

*7.607.347.026.417.206.76

pH-3

*10.0011.64

10.90

8.33

8.977.06

*7.607.357.235.446.857.00

pH-4

*10.1011.60

9.50

8.15

8.797.05

*7.607.317.144.336.706.99

Units shown are in Parts per Million (PPM)* Obstructed Well** Dry Well10 Nov 94 Incomplete Sampling Event, Not Accepted

7

TABLE 1 - CONTINUEDGURLEY PIT SUPERFUND SITE

Quarterly Monitoring Results

Well

F

BG-30

BG-31

Units

Sample Date

10 NOV 94DuplicateTriplicate13 Feb 95DuplicateTriplicate25 May 9517 Aug 9509 Nov 9504 Apr 9630 Aug 96

10 Nov 9413 Feb 9525 May 9517 Aug 9509 Nov 9504 Apr 9630 Aug 96

10 Nov 9413 Feb 9525 May 9517 Aug 9509 Nov 9504 Apr 9630 Aug 96

shown are in

Barium

1.2101.3200.9570.5890.5620.6120.5360.3440.3800.3210.330

1.4100.0821.0200.1970.2760.1090.140

1.3100.7540.6070.3010.2841.2200.130

Parts pe

Lead

0.0680.068

<0.0500.0300.027

<0.0500.0200.0080.0060.004

<0.04

0.1640.0070.0900.0180.0190.009

<0.04

0.1000.0910.0790.0410.0340.186

<0.04r MilliO

Zinc

0.4130.4550.1880.1380.1260.1660.1230.0510.040

<0.020.015

4.6800.1482.2800.5660.4330.281

'0.340

2.0201.9402.2102.7401.8007.8200.700

n (PPM)

TOO

3.63.3

<1.04.76.91.94.23.13.94.41.5

5.618.625.318.214.043.722.0

14.815.653.48.55.9

31.54.2

pH-1

8.20

7.50

7.507.806.706.266.93

7.107.007.116.886.207.236.42

8.106.407.266.887.206.236.81

pH-2

8.00

7.60

7.347.506.916.446.96

7.407.007.20

**6.766.176.38

8.206.707.137.046.546.786.81

pH-3

8.00

7.70

7.437.406.856.226.91

7.507.207.18

******

6.39

8.107.107.197.156.036.556.77

pH-4

8.00

7.90

7.387.607.226.266.94

7.607.207.17

******

6.37

8.007.207.247.086.536.336.78

Not Accepted

8

TABLE 1 - CONTINUEDGURLEY PIT SUPERFUND SITE

Quarterly Monitoring Results

Well

LeakDet

Sample Date

10 NOV 9413 Feb 9525 May 9517 Aug 9509 Nov 9504 Apr 9630 Aug 96

Barium

0.0610.0340.3510.5341 .4802.2600.200

Lead

0.006<0.003

0.007<0.003

0.0080.008

<0.04

Zinc

<0.020<0.020

0.022<0.020<0.020<0.020

0.007

TOO

<3.0<3.0

9.529.5

131 .067.1

310.0

pH-1

9.90

pH-2

9.50

pH-3

9.30

pH-4

9.10

Units shown are in Parts per Million (PPM)* Obstructed Well** Dry Well10 Nov 94 Incomplete Sampling Event, Not Accepted

VIII. SUMMARY OF SITE RECONNAISSANCE

A site inspection was conducted by the EPA Remedial ProjectManager, Ernest R. Franke, and Devon Hobby of ADPC&E on July 25,1996. Vegetative cover was excellent and the site fencing wassecure and intact. The attached three pages of colored photographs(Five Year Review Photographs) reflect the general site conditionsat the time of this inspection. Monitoring wells were intact andfunctional with protective bollards at each well. Table 1 clearlybears evidence that the site remains protective of human health andthe environment in the vicinity. No evidence or reports of damage,trespassing, or vandalism were observed or noted by Todd Hill, theSite Engineer for USACE. Access is restricted by a seven foot tallchain-link fence with three barbed wires and by locked and secureddouble entrance gates.Since me leachate system still has water present, ADPC&E does notagree that the site is acceptable for State Operation &Maintenance.IX. RECOMMENDATIONS

( 1 ) It is recommended that ADPC&E carry out the scheduledOperation and Maintenance Plan preparation and obtain the EPAapproval of the Plan. The Plan must include an agreed-uponbasis for pumping of the leachate collection and detectionsumps. Upon completion of these current USACE Operationaland Functional activities, the State is contractuallyobligated to assume 100% of the cost of Operation &Maintenance and associated activities.

( 2 ) Signs should be placed and maintained on the site fence at 200foot intervals warning trespassers to stay off the property.

( 3 ) This site will be subject to a second Five-Year Review in FY2002. The EPA, in consultation with ADPC&E, will continue tomonitor the site and assure that human health and theenvironment in the vicinity of the site are protected.

9

( 4 ) Yearly Operation and Maintenance Reports will be prepared andsubmitted to the EPA by ADPC&E.

X. CONCLDSIOSS

Consistent with the requirements of OSWER Directive 9355.7-02(Structure and Components of Five-Year Reviews, May 23, 1991) , thisFive-Year Review at the Gurley Pit Superfund site is appropriate.All of the completion requirements for this site have been met asspecified in OSWER Directive 9320.2-3A. Confirmatory sampling hasverified that the Record of Decision and Enforcement DecisionDocument objectives have been achieved and all cleanup actionsspecified have been implemented.Therefore, no further Superfund response is appropriate in order toprovide protection of human health and the environment. ContinuingO&M has been guaranteed by the State of Arkansas for this sitethrough a Superfund State Contract.A bibliography of reports relevant to the review of this site isattached (ATTACHMENT 1 ) . These documents are available either atthe EPA Regional Office or at the ADPC&E Office. These addressesare shown in ATTACHMENT 2.Based on this Five-Year Review, the EPA, in consultation with theADPC&E, has determined that human health and the environment in thevicinity of the site are continuing to be protected.

" /-" / /, /,-^/*' C-^ ' /._ 7?«^<.,t^____Myrorf 0. Knudson, P.E.Director, Superfund Division

attachments

10

ATTACHMENT 1

Gurley Pit Superfund Site Documentsi

BIBLIOGRAPHY

• SOURCE - RI/F8 WORK PLAN, CH2M Hill, May 1984

• QAPP AND SAMPLING PLAN, CH2M HILL, November 1984

• PUBLIC MEETING, Memphis Reporting Service, May 27, 1986

• GROUND WATER - RI/F8 WORK PLAN, CH2M HILL/BLACK & VEACH, July 23,1987, April 1987, and July 1988

• FINAL REMEDIAL INVESTIGATION REPORT, CH2M HILL/BLACK & VEACH,August 1, 1988

• ENFORCEMENT DECISION DOCUMENT FOR SOURCE CONTROL, September 26, 1988

• RECORD OF DECISION - GROUND WATER, September 26, 1988

• HEALTH ASSESSMENT, ATSDR, 1989

• REMEDIAL ACTION, Mobley Contractors, Inc., July 31, 1992 andSeptember 12, 1994

ATTACHMENT 2

GURLEY PIT SUPERFUND SITE REPOSITORIES

U.S. EPA, Region 6, Library (6MD-11)12th Floor, 1445 Ross AvenueDallas, Texas 75202-2733(214) 665-6424 or 665-6427Hours of Operation: 8:00 a.m. to 4:30 p.m.Monday through Friday, excluding holidays

Arkansas Department of Pollution Control and EcologyAttn: Mr. Devon Hobby8001 National DriveLittle Rock, Arkansas 72219(501) 682-0851Hours of Operation: 8:00 a.m. to 4:30 p.m.Monday through Friday, excluding holidays

Date TakenJuly 25, 1996

Five Year Review PhotographsGurley Pit Superfund Site

Edmondson, Arkansas

LEACHATE PUMPING EQUIPMENTTanks, Riser Piping, and General Site Condition

Page 1 of 3

"%.' f '•• S.'./.'11 . M——w- • -WE.'- • •- --—___________

Looking Northward Across Cap-Showing-Excellent Vegetative Cover, Vehicle, and Pumping Eguipment

( 4 ) Yearly Operation and Maintenance Reports will be prepared andsubmitted to the EPA by ADPC&E.

X. COSCLOSIOSS

Consistent with the requirements of OSWER Directive 9355.7-02(Structure and Components of Five-Year Reviews, May 23, 1991), thisFive-Year Review at the Gurley Pit Superfund site is appropriate.All of the completion requirements for this site have been met asspecified in OSWER Directive 9320.2-3A. Confirmatory sampling hasverified that the Record of Decision and Enforcement DecisionDocument objectives have been achieved and all cleanup actionsspecified have been implemented.Therefore, no further Superfund response is appropriate in order toprovide protection of human health and the environment. ContinuingO&M has been guaranteed by the State of Arkansas for this sitethrough a Superfund State Contract.A bibliography of reports relevant to the review of this site isattached (ATTACHMENT 1 ) . These documents are available either atthe EPA Regional Office or at the ADPC&E Office. These addressesare shown in ATTACHMENT 2.Based on this Five-Year Review, the EPA, in consultation with theADPC&E, has determined that human health and the environment in thevicinity of the site are continuing to be protected.

Myron 0. Knudson, P . E .Director, Superfund Divisionattachments

^A/^7' Date

10