NATURE OF THE CASE: THE GALLAWAY PITS SITE IS LOCATED APPROXIMATELY THIRTY MILES NORTHEAST OF MEMPHIS, TENNESSEE, IN FAYETTE COUNTY. THE SITE WAS INITIALLY USED FOR SAND AND GRAVEL MINING OPERATIONS, WHICH CREATED LARGE OPEN PITS. SINCE ABOUT 1972, THE SITE HAS BEEN USED FOR THE UNREGULATED DUMPING OF ASSORTED HAZARDOUS SUBSTANCES. ABPC HAS SINCE GONE OUT OF BUSINESS. ANALYSIS OF WATER SAMPLES OBTAINED FROM THE PITS ON THE SITE REVEALED HIGH LEVELS OF VARIOUS PESTICIDES. ACCORDING- LY, REMOVAL ACTIONS WERE COMMENCED ON OCTOBER 4, 1983 AT THE PIT WHICH CONTAINED THE MOST SERIOUS CONTAMINATION. CONTAMINATED WATER WAS REMOVED FROM THE PIT, TREATED TO REDUCE THE PESTICIDE CONTAMINATION TO LEVELS CONSISTENT WITH STATE WATER POLLUTION LAW, AND DISCHARGED INTO A NEARBY CREEK. WASTE-FILLED DRUMS AND CONTAMINATED SLUDGE WERE THEN REMOVED FROM THE PIT AND TRANSPORTED TO A DISPOSAL FACILITY. FINALLY, TWO FEET OF FILL WERE PLACED OVER THE BOTTOM OF THE PIT. REMOVAL ACTIVITIES WERE COMPLETED ON OCTOBER 23, 1983. TOTAL REMOVAL COSTS THROUGH APRIL 1985 WERE DOCUMENTED AT $314,244.48. EPA IS CURRENTLY TAKING REMEDIAL ACTION AT THE SITE. THE SITE HAS BEEN ON THE NATIONAL PRIORITIES LIST SINCE DECEMBER 1982. THE SITE IS LOCATED APROXIMATELY 24 MILES NORTHWEST OF MEMPHIS, TENNESSEE, IN SHELBY COUNTY. FROM THE 1950S THROUGH 1978, THE ARLINGTON BLENDING & PACK- AGING COMPANY (ABPC) OPERATED A PESTICIDES BLENDING BUSINESS