THE BOFORS NOBEL SITE COMPRISES APPROXIMATELY 85 ACRES, LOCATED 6 MILES EAST OF DOWNTOWN MUSKEGON, MICHIGAN. THE SITE INCLUDES A CURRENTLY OPERATING SPECIALTY CHEMICAL PRODUCTION FACILITY, AND UNUSED LANDFILL, AND 10 ABANDONED SLUDGE LAGOONS. BIG BLACK CREEK BORDERS THE SOUTHERN POR- TION OF THE SITE. LAKEWAY CHEMICALS, INC. ( LAKEWAY ), AND ITS PRINCIPAL, NORMAND PHANEUF, BEGAN PRODUCING INDUSTRIAL CHEMICALS AT THE SITE IN AROUND 1960. IN THE 1970S, LAKEWAY BEGAN ITS TOLLING BUSINESS, MANUFACTURING CHEMICALS FOR, AND TO THE SPECIFICATIONS OF, OTHER COMPANIES. THE TOLLING OPERATION MAY AT TIMES HAVE MADE UP 50% OF LAKEWAY'S SALES. THE PLANT PRODUCED ALCOHOL-BASED DETERGENTS, SACCHARIN, PESTICIDES, HERBICIDES, AND DYE INTERMEDIATES. LAKEWAY USED OPEN, UNLINED LAGOONS FOR WASTEWATER AND SLUDGE DISPOSAL UNTIL APPROXIMATELY 1976. WASTES DISPOSED OF IN THE LAGOONS INCLUDED IRON SLUDGE, IRON SCALE, 3,3'-DICHLOROBENZIDINE ( DCB ) AND OTHER ORGANIC WASTES, ZINC OXIDE WASTE, WASTES GENERATED FROM SPILLS, CALCIUM SULFATE SLUDGE AND DETERGENT WASTES. DCV, WHICH WAS ONE OF LAKEWAY'S MAJOR PRODUCTS, IS THE PRIMARY CONTAMINANT DRIVING THE CLEANUP. IN THE 1970S, THE MICHIGAN DEPARTMENT OF NATURAL RESOURCES ( MDNR , NOW THE MICHIGAN DEPARTMENT OF ENVIRONMENTAL QUALITY OR ( MDEQ ) DISCOVERED MANY OF THESE CONTAMINANTS IN GROUNDWATER AT THE SITE AND IN BIG BLACK CREEK. IN 1976, AS A RESULT OF MNDR ENFORCEMENT ACTION, LAKEWAY INSTALLE