THE SOUTH 8TH STREET LANDFILL SITE ( SITE ) IS LOCATED AD- JACENT TO THE MISSISSIPPI RIVER IN WEST MEMPHIS, CRITTENDEN COUNTY, ARKANSAS. THE SITE IS APPROXIMATELY 30 ACRES, SITUA- TED IN THE MISSISSIPPI FLOOD PLAIN BETWEEN THE RIVER AND THE ST. FRANCIS LEVEE AND IS SUB-DIVIDED INTO 3 SEPARATE DISPOS- AL AREAS, INCLUDING ONE AREA CONTAINING AN OILY SLUDGE PIT. AERIAL PHOTOGRAPHS INDICATE THAT THE SITE WAS USED FIRST AS A SERIES OF BORROW PITS AND SUBSEQUENTLY FOR THE DISPOSAL OF WASTE AND/OR OTHER MATERIALS. MOST OF THE EARLY DISPOSAL AC- TIVITIES AT THE SITE APPEAR TO HAVE BEEN CONDUCTED ON AN AP- PROXIMATELY 2.61 ACRE PARCEL. THE WASTE IN THE OILY SLUDGE PIT HAS PHYSICAL AND CHEMICAL PROPERTIES WHICH ARE CONSIST- ENT WITH WASTE ASSOCIATED WITH WASTE OIL RECLAMATION PRO- CESSES. AFFIDAVITS AND DEPOSITIONS TESTIMONY OF FORMER GURLEY REFIN- ING COMPANY (GRC) EMPLOYEES INDICATE THAT GRC USED THE SITE FOR THE DISPOSAL OF WASTE SLUDGES GENERATED DURING THE USED OIL RE-FINING PROCESS CONDUCTED AT THE GRC FACILITY LOCATED ON THE LAND SITE OF THE ST. FRANCIS LEVEE JUST WEST OF THE SITE. GRC'S RE-FINING OPERATION USED WASTE OIL (SOMETIMES MIXED WITH OTHER SUBSTANCES) IT OBTAINED FROM VARIOUS ENTIT- IES LOCATED IN THE TRI-STATE AREA (ARK., MS., & TN). GRC'S RE-FINING PROCESS UTILIZED AN ACID/CLAY RECLAMATION PROCESS THAT INVOLVED ADDING ACID TO THE WASTE OIL BEING RE- FINED. THE ACID CAUSED THE HEAVY EN