THE WHITEWOOD CREEK SUPERFUND SITE ( WMC SITE ) IS LOCATED IN LAWRENCE, MEADE, AND BUTTE COUNTIES, SOUTH DAKOTA. THE WWC SITE ENCOMPASSES ROUGHLY 18 MILES OF THE WHITEWOOD CREEK FLOODPLAIN FROM THE CROOK CITY BRIDGE TO THE CONFLUENCE WITH THE BELLE FOURCHE RIVER. THE PRIMARY PUBLIC HEALTH CONCERNS AT THE WWC SITE ARISE FROM THE POTENTIAL OF HUMAN EXPOSURE TO ARSENIC-RICH MINE TAILINGS AND INGESTION OF SOIL AND GROUNDWATER CONTAMINATED WITH ARSENIC. MINE TAILINGS WERE DISCHARGED INTO WHITEWOOD CREEK FROM UPSTREAM GOLD MINING OPERATIONS FROM THE 1870'S TO 1977. THESE TAILINGS WERE TRANSPORTED AND DEPOSITED BY STREAM ACTION ALONG THE FLOODPLAIN OF WHITEWOOD CREEK. IN 1981, AT THE REQUEST OF GOVERNOR JANKLOW OF SOUTH DAKOTA, THE WWC SITE WAS PLACED ON THE INTERIM NPL. SUBSEQUENTLY, ON SEPTEMBER 08,1983, THE SITE WAS PLACED ON THE NPL. ALMOST IMMEDIATELY FOLLOWING THE NPL LISTING GOVERNOR JANKLOW REQUESTED THAT THE WWC SITE BE REMOVED FROM THE LIST. SEVERAL MONTHS LATER HOMESTAKE MINING COMPANY OF CALIFORNIA ( HOMESTAKE ) ALSO PETITIONED TO DELETE THE SITE FROM THE NPL. IN JULY 1982 FOLLOWING THE PLACEMENT OF THE WWC SITE ON THE INTERM NPL, THE EPA, THE SOUTH DAKOTA DEPARTMENT OF WATER AND NATURAL RESOURCES ( DWNR ), AND HOMESTAKE ENTERED INTO A THREE-PARTY STUDY AGREEMENT TO CONDUCT A COMPREHENSIVE STUDY OF THE SITE. THIS STUDY, FUNDED BY HOMESTAKE AND CONDUCTED BY FOX CONSULTANTS, INC. ( FOX STUDY ), CONCLUDED IN A REPORT PUBLISHED IN 1984, THAT ARSENIC WAS