EPA Superfund Record of Decision Amendment: H. Brown Co. Inc. EPA ID: MID017075136 OU 01 Grand Rapids MI


                                   EPA/AMD/R05-98/100
                                   1998
EPA Superfund
     Record of Decision Amendment:
     H. BROWN CO., INC.
     EPA ID: MID017075136
     OU01
     GRAND RAPIDS, MI
     02/25/1998

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EPA 541-R98-100

               United States Environmental Protection Agency
                       Record of Decision Amendment
                                   #2
                          H.  Brown Co.,  Inc.  Site
                             Walker,  Michigan

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Record of Decision Amendment
for the
H. Brown Co., Inc. Site
Walker, Michigan

Site Name

H. Brown Co., Inc. Site 2200 Turner Ave., N.W. Walker, Michigan 49504

Statement of Basis

This decision document amends the September 29, 1995, Record of Decision (ROD) Amendment for the H. Brown
Co., Inc. site, in Walker, Michigan. This decision document presents the selected remedial action for the H.
Brown Site, and was developed in accordance with the requirements of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA) and, to the extent practicable, the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP). Specifically, this decision document has been prepared in compliance with
CERCLA Section 117 and NCP Section 300.435(c) (2) (11). This decision document explains the factual and legal
basis for selecting the remedy for this site. The information supporting this remedial action decision is
contained in the administrative record for this site.

Assessment of the site

Actual or threatened releases of hazardous substances from this site, if not addressed by implementing the
response action selected in this Record of Decision (ROD) Amendment, may present an imminent and substantial
endangerment to public health, welfare, or the environment.

Description of the Selected Remedy

The selected remedy is the final remedy for the site. The remedy addresses the threats posed by principal
threat wastes and contaminated groundwater at the site. Principal threat wastes are defined as those source
materials considered to be highly toxic or highly mobile that generally cannot be reliably contained or would
present significant risk to human health or the environment should exposure occur.

The major components of the selected remedy include the following:

• Consolidating contaminated surface soil and sediment requiring cleanup onto the H. Brown property
(2200 Turner Avenue N.W. ) ;

• Redevelopment of the site, by private parties, with warehousing facilities constructed above the
contaminated soil;

• A cover system comprised of clean fill to develop appropriate grades and elevations, concrete slab
foundations, asphalt parking areas, and landscaped areas;

• Contaminated areas to be covered by concrete slab foundations will at a minimum be covered by,
from top to bottom, six (6) inches of concrete and eighteen (18) inches of clean, compacted
fill;

• Contaminated areas to be covered by asphalt will, at a minimum be covered by, from top to
bottom, three (3) inches of asphalt, eight (8) inches of road gravel, and thirteen (13) inches
of clean, compacted, sub-base material; and,

• Contaminated soils to be covered by landscaping shall be covered by at least 3 feet of clean
fill;

• Long-term maintenance of the cover system to ensure that the cover will continue to prevent direct
contact with contaminated soil and minimize infiltration of precipitation;

• Long-term monitoring of the shallow and intermediate aquifers to monitor the effectiveness of the

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remedy;

• Monitoring and/or treatment of landfill gas;

• Restricting the use of the land and the groundwater;

• Demolishing on-site buildings to accommodate redevelopment;

• Cleanup standards for the soil will remain the same as in the 1992 ROD;

• The purpose of this ROD Amendment is to facilitate the re-development of the H. Brown Co., Inc. Site,
and if re-development does not occur or proves to be unsuccessful then the remedy selected in the
September 29, 1995 ROD Amendment will be implemented. No state or federal Superfund money will be used
to pay for the redevelopment of the Site. If redevelopment of the site by a private party does not
occur, a cap consistent with the closure reguirements of Part 115 of the Michigan Natural Resources
and Environmental Protection Act, 1994 PA 451 (Act 451 Part 115) will be constructed over the
contaminated soil.

Declaration of Statutory Determinations

The selected remedy is protective of human health and the environment, complies with federal and state
reguirements that are legally applicable or relevant and appropriate to the remedial action, except Part 111
of the Natural Resources and Environmental Protection Act, 1994 PA 451 which is being waived by the U.S. EPA
pursuant to Section 121(d)(4) of CERCLA, 42 U.S.C. Section 9621(d)(4). The selected remedy will achieve a
standard of performance eguivalent to the reguirements of Part 111 of the Natural Resources and Environmental
Protection Act, 1994 PA 451. The selected remedy is cost effective. Because treatment of the
principle threats of the site was not found to be practicable, this remedy does not satisfy the statutory
preference for treatment as a principle element.

Because this remedy will result in hazardous substances remaining on-site above health-based levels, a review
will be conducted every five years after commencement of remedial action to ensure that the remedy continues
to provide adeguate protection of human health and the environment.

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Decision Summary for Record of Decision Amendment

I. Introduction and Site Background Information

1. Site Name, Location, and Description

The H. Brown Co., Inc. site is located generally near 2200 Turner Avenue, N.W. in the City of Walker, Kent
County, Michigan. Figure 1 is a site location plan and Figure 2 is a diagram of the site.

The H. Brown site is located in a light industrial area in Walker, in south central Michigan. A Grand Rapids
city park is located east of US-131. Further to the east of the park, approximately 1,000 feet from the site,
lies the Grand River. The site is roughly bounded by US-131 on the east and Turner Avenue on the west, but
includes one area to the west of Turner Avenue. The site also includes Zenith Auto Parts to the north and
Abbott Auto Parts (formerly Turner Auto Parts) to the south. The site includes the following components (see
Figure 2):

• Areas with surface soil contaminated with 500 parts per million (ppm) or more of lead;

• An unnamed drainage ditch east of Zenith Auto Parts;

• A drainage ditch named Cogswell Drain located near the southern boundary of Keizer Equipment
Company;

• The storm sewer on Turner Avenue, between Zenith Auto Parts and Cogswell Drain;

• Approximately the northern half of a marshy area within (1) the current, eastern boundary of H.
Brown, (2) southbound US-131, (3) Cogswell Drain, and (4) the unnamed drain east of Zenith Auto
Parts. This area is referred to as the "wetland" throughout this document.

The general area of the site was once used as a landfill that received unknown types and quantities of waste.
The boundaries of the landfill are not well defined, but they may extend beyond the boundaries of industries
surrounding H, Brown.

On September 30, 1992, a Record of Decision (ROD) addressing the entire site was signed by the Regional
Administrator. It addressed contaminated surface and subsurface soils, surface water and sediments, and
groundwater. The remedy selected in the ROD was a final remedial action and included the following major
components:

• Demolishing buildings to allow cleanup of contaminated soil beneath the structures, and disposal of
the debris on-site or in an appropriate off-site landfill.

• Consolidating contaminated surface soil in the area where subsurface soil cleanup will be required.

• Solidifying/stabilizing, in place, contaminated surface and subsurface soil and sediments in a
cement-like form.

• Placing a multi-layer cap over the solidified/stabilized soil sufficient to meet the requirements of
Michigan's Hazardous Waste Management Act 64 (now known as Part 111 of the Natural Resources and
Environmental Protection Act, 1994 PA 451 fact 451 Part 111)

• Surrounding the solidified/stabilized soil with a containment wall.

• Collecting, treating and discharging to the surface water all groundwater and surface water
associated with construction.

• Installing additional wells to further define the condition of the intermediate and deep aquifers.
This information will be used to determine what, if any, remediation of those aquifers needs to take
place. These wells, along with other wells at the site, will be used to monitor the effectiveness of
the remedy.

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• Restricting the use of the land and the groundwater.

• Maintaining a fence around the site to prevent access.

On September 29, 1995 a ROD Amendment was issued based upon data obtained from the Pre-Design Field
Investigation (PDFI), which showed that both the solidification of the soils and the construction of a slurry
wall are not feasible and are not necessary to achieve protection. The September 1995 ROD Amendment reguired
the implementation of the following components:

• Consolidating contaminated surface soil in the area where subsurface soil cleanup will be reguired;

• Placing a Michigan Act 451 Part 115 Solid Waste multi layer cap over all soils exceeding 500 parts per
million of lead;

• Long-term monitoring of the shallow and intermediate aguifers to monitor the effectiveness of the
remedy;

• Restricting the use of the land and the groundwater;

• Maintaining a fence around the site to prevent access;

The lead agency for the Remedial Design/Remedial Action (RD/RA) at this site is the United States
Environmental Protection Agency (U.S. EPA). The State of Michigan Department of Environmental Quality (MDEQ)
is the support agency. Pursuant to a July 1, 1996 Unilateral Administrative Order (UAO), Docket Number
V-W-'96-C-356, the Potentially Responsible Parties (PRPs) are implemeriting the Remedial Design/Remedial
Action. This ROD Amendment will become part of the Administrative Record in accordance with NCP Section
300.825(a) (2). The Administrative Record is maintained at the U.S. EPA Region V Docket Room in Chicago, and
at Walker City Hall. This ROD Amendment has been prepared in accordance with CERCLA
Section 117 and with NCP Section 300.435(c) (2) (ii) .

2. Post-ROD Enforcement Activities

On November 6, 1992, Special Notice Letters were issued to 115 major PRPs offering them the opportunity to
undertake the Remedial Design/Remedial Action (RD/RA). On March 18, 1993, the 120 day negotiation moratorium
concluded without a settlement. Subseguently, on March 30, 1993, U.S. EPA initiated a fund-lead RD under an
Interagency Agreement with the U.S. ACE. On September 29, 1995 a ROD Amendment was issued by U.S. EPA. On
July 1, 1996 a UAO was issued to 31 PRPs, ordering them to design and implement the new remedy selected in
the ROD Amendment.

3. Highlights of Community Participation

A public comment period on the proposed plan for the ROD Amendment for this Site was held from August 12 to
September 11, 1997. In addition, a public meeting was held on August 19, 1997 at the Walker Community
Building, Walker, Michigan. At this meeting, representatives from U.S. EPA answered guestions about problems
at the Site and the remedial alternatives under consideration. Approximately 5 people attended that meeting.
Comments and guestions from the public were also accepted at the meeting. During the comment period, EPA
received approximately 8 comments concerning the proposed plan. Most concerns raised were in regard to how
the affected properties would be restored after the Remedial Action. Most commentors supported the proposed
cleanup plan. Copies of all documents pertaining to this ROD Amendment can be found at the Kent County Public
Library and Walker City Hall.

II. Rationale for Record of Decision Amendment #2

On April 14, 1997, U.S. EPA received notice that a Buy and Sell agreement had been executed between DBV, Inc.
and H. Brown Company Inc. for the properties comprising the H. Brown Superfund site. The intent of the buyer,
DBV, Inc. is to redevelop the property and bring it back into a beneficial use. The redevelopment plan has
been presented to U.S. EPA in an April 18, 1997 proposal which showed the plan to include 2 to 3 large
buildings with concrete foundations, parking facilities and landscaped areas. When constructed, and as long
as they are properly maintained, the facilities would serve as an impermeable barrier preventing direct
contact with the contaminated soils and would minimize the potential for precipitation to leach through the
contaminated material. Erosion and runoff into the adjacent wetlands would also be prevented.

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Michigan's Act 451 Part 111 is considered applicable for this site because hazardous waste was disposed of at
the site after the effective date of the RCRA regulations; this alternative would not comply with that ARAR,
but it would achieve a standard of performance eguivalent to that required. Therefore, as discussed below, a
waiver of that ARAR is appropriate. This alternative would achieve a standard of performance eguivalent to
those required under Act 451 Part 111, as they pertain to preventing direct contact with contaminated
materials. The intent of a Part 111 landfill cover is to minimize both the potential for direct contact with
contaminated materials, and the potential for leaching of the contaminants into underlying aquifers. With
contaminated materials currently sitting in the shallow aquifer at the H. Brown Site, any additional degree
of impermeability afforded by a Part 111 cap is negated. Additionally, the Pre-Design Field Investigation
found that site related lead contamination is not currently migrating off-site in the groundwater, but
instead is remaining bound to soil particles on-site, showing that direct contact with the contaminated soil
is the exposure pathway of primary concern and the one which should be addressed in the design of the final
cover. The concrete foundations and asphalted areas will serve as an impermeable barrier as long as proper
maintenance is continued. Therefore, under the new future use and redevelopment scenario, with an active
facility to be operating on-site, and with long-term maintenance of the cover system assured, the requirement
to construct and maintain a vegetated clay cap over the contaminated soils is being waived. If the land-use
changes, or the redevelopment fails, the cleanup plan contains a contingency that a vegetated clay cover,
consistent with the requirements contained in Michigan's Act 451, Part 115 will be constructed.

III. Description of Alternatives

The following alternatives were considered for amending the ROD for the H. Brown Superfund Site, taking into
consideration the new information concerning the future use of the property. As required by the NCP, the "No
Action" alternative was considered solely as a baseline to compare the other alternatives.

Alternative 1: No Action

Alternative 2: Warehouse Redevelopment

Alternative 3: Michigan Act 451 Part 111 Cap

Each of the alternatives considered for the ROD Amendment are individually compared against each of the nine
criteria described below. Figure 7 represents the approximate area to be covered with the covers evaluated.
Tables 1 and 2 present the detailed cost estimates for each of the alternatives.

(A) Overall protection of human health and the environment. Alternatives shall be assessed to
determine whether they can adequately protect human health and the environment, in both
the short- and long-term, from unacceptable risks posed by hazardous substances,
pollutants, or contaminants present at the site by eliminating, reducing, or controlling
exposures to levels established during development of remediation goals consistent with
°300.430(e) (2) (1). Overall protection of human health and the environment draws on the
assessments of other evaluation criteria, especially long-term effectiveness and
permanence, short-term effectiveness, and compliance with ARARS.

(B) Compliance with ARARS. The alternatives shall be assessed to determine whether they
attain applicable or relevant and appropriate requirements under federal environmental
laws and state environmental or facility siting laws or provide grounds for invoking one of
the waivers under paragraph (f)(1)(ii)(C) of this section.

(C) Long-term effectiveness and permanence. Alternatives shall be assessed for the long-term
effectiveness and permanence they afford, along with the degree of certainty that the
alternative will prove successful. Factors that shall be considered, as appropriate, include
the following:

(1) Magnitude of residual risk remaining from untreated waste or treatment residuals
remaining at the conclusion of the remedial activities. The characteristics of the
residuals should be considered to the degree that they remain hazardous, taking
into account their volume, toxicity, mobility, and propensity to bioaccumulate.

(2) Adequacy and reliability of controls such as containment systems and restrictive
covenants that are necessary to manage treatment residuals and untreated waste.

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        This  factor  addresses  in particular the  uncertainties  associated with land disposal
        for providing long-term protection from  residuals;  the assessment of the potential
        need  to  replace  technical components of  the  alternative,  such as a cap,  a slurry
        wall,  or a treatment system;  and the potential  exposure pathways and risks posed
        should the remedial action need replacement.

(D)  Reduction of toxicity, mobility,  or volume through  treatment.  The degree to  which
    alternatives employ  recycling or  treatment that  reduces toxicity,  mobility,  or volume shall
    be  assessed,  including how treatment is used to  address the principal threats posed by the
    site.  Factors that shall be considered,  as appropriate,  include the following:

    (1)  The treatment or recycling processes the alternatives  employ and materials they will treat;

    (2)  The amount of hazardous substances,  pollutants,  or  contaminants that will be
        destroyed, treated, or recycled;

    (3)  The degree of expected reduction in toxicity, mobility,  or volume of the waste due
        to treatment or  recycling and the specification of  which reduction(s)  are occurring;

    (4)  The degree to which the treatment is irreversible;

    (5)  The type and guantity  of residuals that  will  remain following treatment,
        considering  the  persistence,  toxicity, mobility,  and propensity to bioaccumulate of
        such  hazardous substances and their constituents; and

    (6)  The degree to which treatment reduces the inherent  hazards posed by principal
        threats  at the site.

(E)  Short-term effectiveness.  The short-term impacts  of alternatives shall be assessed
    considering  the  following:

    (1)  Short-term risks that  might be posed to  the  community  during implementation of
        an alternative;

    (2)  Potential impacts on workers  during remedial  action and the effectiveness and
        reliability  of protective measures;

    (3)  Potential environmental impacts of the remedial action and the effectiveness and
        reliability  of mitigative measures during implementation;  and

    (4)  Time  until protection  is achieved.

(F)  Implementability.  The ease or difficulty of  implementing the alternatives shall be assessed
    by  considering the following types of factors as  appropriate:

    (1)  Technical feasibility,  including technical difficulties and unknowns associated
        with  the construction  and operation of a technology, the reliability of  the
        technology,  ease of undertaking additional remedial actions,  and the ability to
        monitor  the  effectiveness of  the remedy.

    (2)  Administrative feasibility, including activities  needed to coordinate with other
        offices  and  agencies and the  ability and time reguired to obtain any necessary
        approvals and permits  from other agencies (for  off-site actions);

    (3)  Availability of  services and  materials,  including the  availability of adeguate off-
        site  treatment,  storage capacity,  and disposal  capacity and services;  the availability
        of necessary eguipment and specialists,  and  provisions to ensure any necessary
        additional resources;  the availability of services  and materials; and availability of
        prospective  technologies.

(G)  Cost.  The types  of costs that shall be assessed  include the following:

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(1) Capital costs, including both direct and indirect costs;

(2) Annual operation and maintenance costs; and

(3) Net present value of capital and O&M costs.

(H) State acceptance. Assessment of state concerns may not be completed until comments on
the RI/FS are received but may be discussed, to the extent possible, in the proposed plan
issued for public comment. The state concerns that shall be assessed include the
following:

(1) The state's position and key concerns related to the preferred alternative and other
alternatives; and

(2) State comments on ARARs or the proposed use of waivers.

(1) Community acceptance. This assessment includes determining which components of the
alternatives interested persons in the community support, have reservations about, or
oppose.

Based upon the results of the site investigations the following assumptions were used in
developing the alternatives:

15 acres would reguire clearing of trees and shrubs;

3,600 linear feet of fencing would be erected;

15 acres of soil would reguire capping;

180,000 cubic yards of soil, sediments, and battery chips reguire remediation.

Alternative 1: No Action

Description:

Under this alternative, no remedial action would be taken at the H. Brown site.

Evaluation:

Overall Protection of Human Health and the Environment

If no remedial action is implemented at the site, existing risks to human health and the environment from
contaminants at the site would remain. Therefore, this alternative does not provide adeguate protection of
human health or the environment.

Compliance with ARARs

This alternative would not comply with chemical-specific ARARs because the current concentrations of many
contaminants in the soils and the air exceed corresponding ARAR based allowable concentrations and would
continue to do so. For instance, health based standards for preventing direct contact with soils would not be
met. The current concentrations of lead in soil are higher than the cleanup level for lead, and would remain
high indefinitely.

Long-Term Effectiveness and Permanence

This alternative would not be effective for the long-term because the concentrations of metals, especially
lead, would remain indefinitely.

Reduction of Toxicity, Mobility, or Volume through Treatment

This alternative would not reduce the toxicity, mobility, or volume of contaminants at the site through

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treatment.

Short-Term Effectiveness

This alternative would not be effective for the short term because current concentrations of contaminants at
the site would remain at current, high levels indefinitely.

Implementability

This alternative would be easily implemented.

Cost

No capital or O&M costs are associated with this alternative because no remedial action would be implemented.

Alternative 2: Warehouse Redevelopment

Description:

This alternative includes consolidating all of the soil reguiring cleanup onto the H. Brown property.
Excavated areas on the property known as Abbott Auto will be left in a condition that allows for unrestricted
use of the property; this includes providing a final grade across the property consistent with the current
grade, and a grade that will allow for proper drainage of the property. The H. Brown property would then be
redeveloped by private parties, with warehousing facilities being constructed above the contaminated soils. A
continuous impermeable cap will be constructed over all contaminated soils on the site so as to prevent
direct contact with the contaminated materials and to minimize infiltration of precipitation through the
cover into the waste materials. The cap will consist of concrete slab foundations for warehouse structures
and asphalted parking areas. Contaminated soils to be covered by concrete foundations and floors will be
covered by, at a minimum, six (6) inches of concrete and eighteen
(18) inches of compacted, clean fill. Contaminated soils to be covered by the asphalt parking ways will, at a
minimum, receive a cover consisting of the following components, (listed from top to bottom): three (3)
inches of asphalt, eight (8) inches of road gravel, and thirteen (13) inches of clean subbase material. Any
contaminated soils not covered by the foundations or asphalt, will be covered by at least three (3) feet of
clean fill. The remedy also includes deed restrictions, monitoring for landfill gas, if necessary, and
cleaning the Turner Avenue storm sewer. This alternative includes a contingency plan for implementation of
Alternative #3 if the redevelopment plan is not implemented as set forth above, or as approved by U.S. EPA.

Evaluation:

Overall Protection of Human Health and the Environment

This alternative is considered protective of human health and the environment. This alternative would not
comply with all ARARs associated with the site, however, it is considered protective of human health and the
environment. Specifically, Michigan's Act 451 Part 111 is considered applicable for this site because
hazardous waste was disposed of at the site after the effective date of the RCRA regulations; this
alternative would not comply with that ARAR, but it would achieve a standard of performance eguivalent to
that reguired. Therefore, as discussed below, a waiver of that ARAR is appropriate. Because untreated toxic
waste would remain in place, this remedy may not be permanent. Asphalt and concrete covers are susceptible to
damage from weathering and from the use of the property. The risk of this damage will be minimized through
proper maintenance of the cover system. If the cap failed, release of hazardous constituents would possibly
result in unacceptable future risks. This alternative would not be difficult to implement and has a high
degree of short-term effectiveness.

Compliance with ARARs

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centimeters of additional material to prevent damage to the cap from burrowing animals, temperature, erosion,
and rooted vegetation. The cap in this alternative would not meet the reguirement for at least 90 centimeters
of compacted clay, a frost protection layer or a vegetated layer. It does include an impervious cover system
which would meet the reguirements of Part 111 pertaining to preventing exposure to contaminants via direct
contact. It will provide for the same degree of protection of human
health and the environment.

The intent of a Part 111 landfill final cover design is to minimize both the potential for direct contact
with contaminated materials, and the potential for leaching of the contaminants into underlying aguifers.
With contaminated materials currently sitting in the shallow aguifer at the H. Brown Site any additional
degree of impermeability afforded by a Part 111 cap is negated. Additionally, the Pre-Design Field
Investigation found that site related lead contamination is not currently migrating off-site in the
groundwater, but instead is remaining bound to soil particles onsite, showing that direct contact with the
contaminated soil is the exposure pathway of concern. The cover system will serve as a barrier to direct
contact as long as proper maintenance is continued and will also minimize the potential for precipitation
from coming in contact with contaminants in the vadose zone. Under the new future use and redevelopment
scenario, with an active facility to be operating on-site, and with long-term maintenance of the cover system
assured, the reguirement to construct and maintain a vegetated clay cap over the contaminated soils is being
waived. If the land-use changes the cleanup plan contains a contingency that a vegetated clay cover,
consistent with the reguirements contained in Michigan's Act 451, Part 115 will be constructed.

Because of the redevelopment of the property, and the anticipated permanent on-site presence of maintenance
personnel, this alternative is egually reliable, and will take less time to implement than the cap reguired
under the ARAR. Consolidating and capping soils would comply with chemical specific ARARs based upon direct
exposure. This alternative would meet ARARs for the Clean Air Act based upon National Ambient Air Quality
(NAAQ) standards. The installation of the cap over the site will minimize recharge of the shallow aguifer via
precipitation percolating through the contaminated vadose zone, thereby minimizing the potential for
additional contaminants to enter the groundwater.

Long-Term Effectiveness and Permanence

This alternative would remain effective for as long as the integrity of the cap is maintained. Because toxic
constituents would remain untreated in a land disposal unit, the permanence of this alternative is uncertain.
For instance, if the cover failed, risks may be associated with potential direct exposure to exposed waste.

Reduction of Toxicity, Mobility, or Volume through Treatment

Under this alternative, the toxicity and volume and mobility of contaminants in soil would remain unchanged.
As the Pre-Design Field Investigation showed, contaminants are remaining bound to soil particles and remain
immobile in the groundwater. Although the alternative involves no treatment, construction of the cover system
would result in a reduction in erosion and percolation of precipitation through the contaminated waste. The
residuals are persistent, toxic and can become mobile via wind and hydraulic erosion; any failure of the cap
may decrease the effectiveness of the remedial action in limiting this type of contaminant mobility.

Short-Term Effectiveness

This alternative would be guickly and easily implemented. Implementation would reguire between 1 to 2 years.
During implementation, some short-term risks would be posed to the remediation crew through direct contact,
ingestion, or inhalation of contaminated soil. Adults and children off site could also be exposed to
contaminated dust resulting from excavation of soil reguiring remediation.

Risks from exposure to contaminated media during the remediation efforts would be minimized by providing
appropriate levels of protection to the remediation crew. Dust control measures, such as spraying water or
foam, would be implemented. Surface run-off onto and from the site would also be controlled to minimize
generation and off-site migration of contaminated surface water from the site.

Implementability

Construction of the cap would be easy to implement. Collecting surface water and sediments from the sewer
system is expected to be easy due to the number of vendors offering the service.

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Cost

This alternative has a low capital and a low annual O&M cost ($5,011,502 and $13,185, respectively). The
total present worth of the remedy, assuming 30 years of O&M and a 10 percent discount factor, is $5,214,199.

Alternative 3: Michigan Act 451 Part 115 Clay Cap

Description

Under this alternative all soil above cleanup standards would be consolidated onto the H. Brown Co., Inc.
property and capped with a clay cap meeting Michigan's Act 451 Part 115 specifications. The cap would
include, from top to bottom, 6 inches of top soil with vegetation, 1.5 feet of clean fill, 2 feet of clay,
and fill material. A fence would be constructed around the entire site to prevent access and groundwater
would be monitored over the life of the remedy to ensure protectiveness. It also includes monitoring for
landfill gas, if necessary, and cleaning the Turner Avenue sewer.

Evaluation:

Overall Protection of Human Health and the Environment

This alternative would not comply with all ARARs associated with the site, however, it is considered
protective of human health and the environment. Specifically, Michigan's Act 451 Part 111 is considered
applicable for this site because hazardous waste was disposed of at the site after the effective date of the
RCRA regulations; this alternative would not comply with that ARAR, but it would achieve a standard of
protection equivalent to that required at this site because the waste currently sits within the shallow
groundwater, and site contaminants are shown to be adhering to soil particles and, therefore, are not mobile.
As a result, a Part 111 cap would not provide any additional protection against infiltration causing site
contaminant mobility or leaching. Therefore, as discussed below, a waiver of that ARAR is appropriate. This
alternative would comply with Act 451 Part 115 requirements. Because untreated toxic waste would remain in
place, this remedy may not be permanent. If the cap failed, release of hazardous constituents would possibly
result in unacceptable future risks. Clay caps are susceptible to cracking caused by exposure to freeze-thaw
cycles and from other weather related conditions. This alternative
would not be difficult to implement and has a high degree of short-term effectiveness.

Compliance with ARARs

This alternative would not comply with all ARARs for media at the site. Michigan's Act 451 Part 111 is
considered applicable for this site because hazardous waste was disposed of at the site after the effective
date of the RCRA regulations; this alternative would not comply with that ARAR, but it would achieve a
standard of protection equivalent to that required at this site because the waste currently sits within the
shallow groundwater, and site contaminants are shown to be adhering to soil particles and therefore are not
mobile. As a result, a Part 111 cap would not provide any additional protection against infiltration causing
site contaminant mobility or leaching. A waiver of the ARAR is appropriate pursuant to Section 121(d)(4)(D)
of CERCLA. Part 111 requires that a hazarous waste landfill cap include both a layer of compacted clay
exceeding the areas frost depth, but not less than 90 centimeters, and not less than 60 centimeters of
additional material to prevent damage to the cap from burrowing animals, temperature, erosion, and rooted
vegetation. The cap in this alternative would not meet the requirement for at least 90 centimeters of
compacted clay. It does include two feet of compacted clay, plus a layer
of additional material for frost protection.

The cap proposed under this alternative would prevent direct contact with the contaminated waste and would
minimize contact of water with the waste to the same degree as an Act 451 Part 111 cap. Although there is
hazardous waste on-site, a portion of the waste sits in the shallow groundwater minimizing any benefit gained
by placing a more impermeable cap such as an Act 451 Part 111 cap over the waste. The Part 111 cap is
designed to minimize the potential for direct contact with hazardous waste and to minimize the potential for
contaminants to leach from the waste via contact with precipitation. Applying an Act 451 Part 111 cap will
not prevent contact of the groundwater with the waste. An Act 451 Part 115 cap will prevent direct contact
and will minimize the amount of precipitation coming in direct contact with the waste in the vadose zone. It
will provide for the same degree of protection of human health and the environment given the site specific
hydrogeologic and geochemical circumstances at this site. The cover system is equally reliable, and will take
less time to implement than the cap required under the ARAR. The cap under this alternative would comply with

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Michigan's Solid Waste Act 451 Part 115 requirements. Consolidating and capping soils would comply with
chemical specific ARARs based upon direct exposure. This alternative would meet ARARs for the Clean Air Act
based upon National Ambient Air Quality (NAAQ) standards. The installation of the cap over the site will
minimize recharge of the shallow aguifer via precipitation percolating through the contaminated vadose zone,
thereby minimizing the potential for contaminants to enter the groundwater.

Long-Term Effectiveness and Permanence

This alternative would remain effective for as long as the integrity of the cap is maintained. Because toxic
constituents would remain untreated in a land disposal unit, the permanence of this alternative is uncertain.
For instance, if the cap failed, risks may be associated with potential direct exposure to exposed waste.

Reduction of Toxicity, Mobility, or Volume through Treatment

Under this alternative, the toxicity and volume and mobility of contaminants in soil would remain unchanged.
As the Pre-Design Field Investigation showed, contaminants are remaining bound to soil particles and remain
immobile in the groundwater. Although the alternative involves no treatment, construction of the cap would
result in a reduction in erosion and percolation of precipitation through the contaminated waste. The
residuals are persistent, toxic and can become mobile via wind and hydraulic erosion; any failure of the cap
may decrease the effectiveness of the remedial action in limiting this type of contaminant mobility.

Short-Term Effectiveness

Implementability

Construction of the cap would be easy to implement. Collecting surface water and sediments from the sewer
system is expected to be easy due to the number of vendors offering the service.

Cost

This alternative has a low capital and a low annual O&M cost ($1,151,153 and $81,000, respectively). The
total present worth of the remedy, assuming 30 years of O&M and a 10 percent discount factor, is $1,914,741.

Comparative Analysis of Alternatives

A comparative discussion of all alternatives is presented below. The alternatives are compared based upon the
nine evaluation criteria discussed above.

Overall Protection of Human Health and the Environment

Under each action alternative, contaminated soil would be covered by a cap. Both Alternatives 2 and 3 are
considered protective of human health and the environment. Alternative 1 is not considered protective because
it would not reduce the currently unacceptable threats to human health and the environment and would fail to
attain all of the ARARs for the site. Alternatives 2 and 3 would not achieve all of the ARARs for the site,
specifically Act 451 Part 111, however, as discussed above, a waiver is appropriate for the alternatives
because they will achieve the same level of performance compared to the ARAR. Alternatives 2 and 3 would
perform equally well in providing overall protection of human health and the environment.

Compliance with ARARs

None of the alternatives would result in compliance with all ARARs. However an ARAR waiver for Alternatives 2

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and 3 is appropriate. Michigan's Act 451 Part 111, and RCRA landfill closure requirements 40CFR Part 264, are
considered applicable for this site because hazardous waste was disposed of at the site after the effective
date of the RCRA regulations; Alternative 2 and 3 would not comply with that ARAR, but would achieve a
standard of performance equivalent to that required. As discussed above a waiver of the ARAR is appropriate
pursuant to Section 121(d)(4)(D) of CERCLA.

Long-Term Effectiveness and Permanence

Each of the action alternatives would remain effective for as long as the integrity of the cap is maintained.
Because toxic constituents would remain untreated in a land disposal unit, the permanence of the alternatives
is uncertain. For instance, if the caps failed, risks may be associated with potential direct exposure to
waste. While the cap in Alternative 2 would have a slightly greater risk of failure due to its use of cement
and asphalt which are more susceptible to damage from exposure to freeze-thaw cycles than the clay used in
Alternative 3, if it is properly maintained it should perform as well as the cap in Alternative 3. The clay
cap in Alternative 3 is also susceptible to damage from the freeze-thaw cycles. The use of an additional fill
layer as frost protection will minimize any potential for that damage to the clay. The caps would provide for
a greater dewatering effect on the shallow aquifer, minimizing any groundwater flow through the waste.

Considering all of these factors, Alternatives 2 and 3 would provide equivalent overall long-term
effectiveness and permanence.

Reduction of Toxicity, Mobility, or Volume of Contaminants Through Treatment

Alternatives 1, 2 and 3 would provide for no reduction of toxicity, mobility, or volume through treatment.
They leave all of the contaminated waste in place, untreated.

Short-Term Effectiveness

Alternatives 2 and 3 would be equally protective in the short-term since all effects can be mitigated.
Installation of both caps would require extensive labor, increasing risk of exposure to workers. Because both
alternatives require the importation of materials to construct the caps, there is an attendant increased
risk due to truck traffic.

Implementability

Alternatives 2 and 3 would be equally implementable, although many of the construction materials for the
foundations and parking areas are more readily available than clay borrow sources.

Cost

Alternative 2 would be the most expensive with its cost of $5 million. Alternative 3 has a cost of $1.9
million. The higher cost of Alternative 2 is attributable to the costs of building the concrete foundations
and asphalt parking areas as compared to the cost of building a clay cap. If redevelopment by a private party
does not occur, Alternative 2 contains the contingency that Alternative 3 will be constructed. Both
alternatives have similar Operation and Maintenance costs associated with them.

State Acceptance

The State of Michigan has assisted in the development and review of the Administrative Record. The State
concurs with the selected remedy.

Community Acceptance

The specific public comments received, and U.S. EPA's responses are outlined in the attached Responsiveness
Summary.

IV. Selected Remedy

Based upon considerations of the requirements of CERCLA, the NCP and balancing of the nine criteria, the U.S.
EPA has determined that Alternative 2, Warehouse Redevelopment, is the most appropriate for the H. Brown
site.

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The components of the selected remedy are as follows:

1. Access Restrictions

a. Temporary and/or permanent signs will be erected and maintained around the site
as specified by the U.S. EPA. The purpose of the signs is to notify on-site personnel and
visitors of the presence of contaminated soils, and the prohibition of any unauthorized
activities which might damage the cap and otherwise impair the remedy.

b. Pursuant to Michigan Act 451 Part 201, restrictive covenants including, but not
limited to, notice to future property owners of contamination at the site, deed restrictions
to regulate the development of the H. Brown site, and groundwater use restrictions in the
areas that have contaminated groundwater will be sought. Groundwater use restrictions
may be rescinded after remediation standards are met and proven to be maintained.

The purpose of these restrictions is to prevent exposure to site contaminants, prevent
erosion of the cap, and provide security for the remedial action eguipment.

2. Site Monitoring

Groundwater and surface water monitoring. Groundwater aguifers and surface waters
and sediments in the site vicinity will be sampled and analyzed periodically to monitor
chemical contaminant levels over the life of the remedy to ensure that the contaminants
remain contained on-site and the remedy remains protective.

Groundwater monitoring will include shallow and intermediate aguifers beneath the site.
Sampling and analysis will include existing groundwater monitoring wells and, if
necessary, additional groundwater monitoring wells.

3. Soil and Sediment Consolidation

All contaminated soils and sediments which exceed the cleanup standards established in
the ROD will be consolidated to the H. Brown Property (2200 Turner Ave. N.W.)
Contaminated sediments include those found in the wetlands adjacent to the site, the
drainage ditches leading to the Grand River, and the sewer system running along Turner
Avenue, that exceed the cleanup standards. The testing shall be conducted to assure that
all soil and sediment reguiring containment has been consolidated to the area referred to
above. Excavated areas on the property known as Abbott Auto will be left in a condition
that allows for use of the property consistent with its zoned use at the time of the signing
of this ROD Amendment; this includes providing a final grade across the property
consistent with the current grade, and a grade that will allow for proper drainage of the
property and eliminate any safety hazads created by the excavation activities. Other
excavated areas will be backfilled with clean soil from off-site sources, revegetated and
otherwise restored to their existing condition, grade and elevation.

4. Cap Construction

a. The cap construction shall consist of a redevelopment of the property for use as a
warehousing facility. A continuous impermeable cap will be constructed over all
contaminated soils on the site so as to prevent direct contact with the
contaminated materials and to minimize infiltration of precipitation through the
cover into the waste materials. The cap will consist of concrete slab foundations
for warehouse structures and asphalted parking areas. Contaminated soils to be
covered by concrete foundations and floors will be covered by, at a minimum, six
(6) inches of concrete and eighteen (18) inches of compacted, clean fill.
Contaminated soils to be covered by the asphalt parking ways will, at a minimum,
receive a cover consisting of the following components, (listed from top to
bottom): three (3) inches of asphalt, eight (8) inches of road gravel, and thirteen
(13) inches of clean subbase material. Any contaminated soils not covered by the
foundations or asphalt, will be covered by at least three (3) feet of clean fill. If
necessary, the cap design will also include a methane gas monitoring and/or

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venting system for the on-site buildings designed to detect and/or vent
unacceptable levels of landfill generated gases that might accumulate under, or in,
the buildings.

This cover system is considered protective for this site, because it would provide
protection against direct contact with waste at the site and act as a significant
barrier to infiltration of precipitation as long as the cover is properly maintained.
The waste is in direct hydraulic connection with the shallow groundwater.

b. The selected remedy is intended to facilitate re-development of the site and will be
implemented by private parties. No federal or state Superfund money will be used
to implement the redevelopment remedy. If for some reason the plannned
redevelopment of the property by private parties does not occur, a cap will be
constructed on the site in compliance with the substantive reguirements of
Michigan Act 451 Part 115. At a minimum, the cap will consist of, from top to
bottom, a 6 inch vegetative soil layer, a clean fill layer not less than 18 inches in
thickness, 24 inches of compacted clay with a hydraulic conductivity of not more
than 1.0 x 10-7 centimeters per second after compaction, and maximum and
minimum slope. If necessary, the cap design will also include a methane gas
monitoring and/or venting system.

A Michigan Act 451 Part 115 cap is considered protective for this site, because it
would provide protection against direct contact with waste at the site and act as a
significant barrier to infiltration of precipitation. The waste is in direct hydraulic
connection with the shallow groundwater.

5. Other Provisions

Mitigative measures will be taken during remedy construction activities to minimize the impacts of noise,
dust, and erosion run-off to the surrounding community and environs. Fugitive dust emissions will not violate
the National Ambient Air Quality Standard for particulate matter smaller than 10 microns (PM-10). Potential
runoff, silting, and sedimentation problems from construction will be mitigated to comply with Michigan Acts
including Public Acts 203 (1979), 346 (1972) and 347 (1972) for wetland protection, inland lakes and streams,
and soil erosion and sedimentation control, respectively. Because excavation in the wetland area adjacent to
the site will take place, the selected remedy will comply with the Wetland Management Executive Order 11990,
and Michigan's Goemnere-Anderson Wetland Protection Act, Act 203 of 1979.

Because the remedy calls for containing the waste on-site without treatment and the waste is the source of
the contaminants, hazardous constituents will remain at the site. Because this remedy will result in
hazardous substances remainin on-site, above health-based levels, a review will be conducted within five
years of commencement of the remedial action to ensure that the remedy continues to provide adeguate
protection to human health and the environment.

V. Statutory Determinations

The selected remedy must satisfy the reguirements of Section 121 (a) through (f) of CERCLA to:

1. Protect human health and the environment;
2. Comply with ARARs or justify a waiver;
3. Utilize permanent solutions and alternative treatment technologies or resource
recovery, technologies to the maximum extent practicable; and
4. Satisfy a preference for treatment that reduces toxicity, mobility, or volume as a
principle element of the remedy.

The implementation of the selected alternative at the H. Brown Co., Inc. site satisfies these reguirements of
CERCLA Section 121 as follows:

a. Protection of Human Health and the Environment;

Implementation of the selected alternative will reduce and control potential risks to human
health posed by exposure to contaminated soil and groundwater. Containment of all soil

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exceeding cleanup standards will permanently reduce and control existing and potential
risks, through engineering controls.

Restrictive covenants will provide short-term and long-term effectiveness for the
prevention of drinking contaminated groundwater. The selected remedy also protects the
environment by reducing the potential risks posed by site chemicals discharging to surface
water (Grand River) and the adjoining wetlands.

Capping the site, in addition to reducing any potential further risk posed by exposure to site
contaminants, will reduce precipitation infiltration through the cap and maintain that
reduction over time. No unacceptable short-term risks will be caused by implementation
of the remedy. The community and site workers may be exposed to noise and dust
nuisances during construction of the cap. Mitigative measures will be taken during remedy
construction activities to minimize impacts of construction upon the surrounding
community and environs.

b. Compliance with ARARs

The selected remedy will comply with the federal and/or state, where more stringent,
applicable or relevant and appropriate requirements (ARARs) listed below:

1. Chemical-specific ARARs

Chemical-specific ARARs regulate the release to the environment of specific substances
having certain chemical characteristics. Chemical-specific ARARs typically determine the
extent of clean-up at a site.

Federal ARARs

Safe Drinking Water Act MCLs and MCLGs - Maximum Contaminant Levels (MCLs)
and, to a certain extent, non-zero Maximum Contaminant Level Goals (MCLGs), are the
Federal Drinking Water Standards promulgated under the Safe Drinking Water Act
(SDWA) which are applicable to municipal drinking water supplies servicing 25 or more
people. At the H. Brown site, MCLs and MCLGs are not applicable, but are relevant and
appropriate, because the aguifer is a Class II aguifer which could potentially be used in the
area of concern. MCLGs are relevant and appropriate when the standard is set at a level
greater than zero (for non-carcinogens); otherwise, MCLs are relevant and appropriate.
Because this site will have a final cover, the point of compliance will be at the boundary of
the final cover.

Clean Air Act National Ambient Air Quality Standards 40 CFR 50 - These regulations
provide air emission requirements for actions which may release contaminants into the air.
As the selected remedy involves excavation, and construction activities which may release
contaminants or particulates into the air, emission requirements promulgated under this act
are relevant and appropriate.

State ARARs

Part 201 of the Natural Resources and Environmental Protection Act, 1994 PA 451, as
amended (formerly known as Act 307 of the Michigan Environmental Response Act) - The
Substantive provisions of Parts 6 and 7 of the rules promulgated under Part 201 were
identified as an ARAR for the remedial action to be undertaken at this Site. These rules
provided, inter alia, that remedial actions be protective of human health, safety, and the
environment by a degree of cleanup conforming to one or more of three cleanup types;
Type A, B, and C. The ROD and ROD Amendments determined that the selected soil
remedy would satisfy Act 307 soil and groundwater cleanup standards. The Act 307
standards have since been replaced by new Part 201 standards.

The amended Part 201 now defines cleanup standards according to categorical criteria that
define the nature of the site for which Remedial Action is necessary. Specific cleanup
categories are: residential, commercial, recreational, industrial, limited residential, limited

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commercial, limited recreational, limited industrial, and other land use based or limited
categories as established by MDEQ. Part 201 groundwater standards will be considered
ARARs for determination of long-term groundwater cleanup standards.

It is anticipated that implementation of the amended remedy will limit development of the
Site property until long-term remediation measures are implemented. The Site, is an
inactive or abandoned site whose primary activity was industrial in nature, and as such can
continue to be classified as industrial. U.S. EPA foresees that appropriate restrictive
covenants combined with standard site security measures will be adeguate to prevent or
limit the exposure potential for the public and will guarantee that the Site is not used for
anything except industrial activity. Thus, Part 201 industrial or commercial cleanup
criteria would be the relevant ARAR.

Part 201 reguires that remedial action cleanup criteria meet a 10 -5 carcinogenic risk level,
or for non-carcinogenic substances, a hazard guotient of 1.0. Because it will contain and
manage contaminated soils to acceptable Part 201 soil levels, implementation of the
amended remedy would meet or exceed this standard for Site soils and groundwater. Table
3 lists the soil remediation standards for the H. Brown site. Table 4 lists the groundwater
remediation standards for the H. Brown site.

Part 55 of the Natural Resources and Environmental Protection Act, 1994 PA 451 (Act 451
Part 55) (formerly known as the Michigan Air Pollution Control Act or Act 348) provides
air emission reguirements for actions which may release contaminants into the air. The
selected remedy involves excavation, construction, and groundwater treatment activities
which may release contaminants or particulates into the air. This act is relevant and
appropriate.

2. Location-specific ARARS

Location-specific ARARs are those reguirements that relate to the geographical position of
a site. These include:

The Clean Water Act Section 404 - This section of the Act regulates the discharge of
dredge and fill materials at sites to waters of the United States. These regulations are
applicable to capping of the site and other activities which may take place in the wetlands.

RCRA Location Standards 40 CFR Part 264.18 - These standards are relevant and
appropriate for the remedy at the H. Brown site because a portion of the site is located in
the 500 year flood plain. These standards specify that a facility located in a flood plain
must be designed, constructed, operated, and maintained to prevent washout of hazardous
wastes by a flood.

Goemnere-Anderson Wetland Protection Act, Act 203 of 1979 - Regulates any activity
which may take place within wetlands in the State of Michigan. Act 203 is applicable at
this site; it will reguire the replacement of adversely impacted wetlands with comparable
resources.

Soil Erosion and Sedimentation Control Act, Act 347 of 1972 - This act is applicable to
this site due to the selected remedy's use of construction activities that may impact the
Grand River. The act regulates earth changes, including cut and fill activities which may
contribute to soil erosion and sedimentation of surface water of the State. Act 347 would
apply to any such activity where more than one acre of land is affected or regulated action
occurs within 500 feet of a lake or stream.

Michigan Act 451 Part 201, Rule 719(3) - This rule reguires restrictive covenants be placed
on the site including, but not limited to, notice to future property owners of contamination
at the site, deed restrictions to regulate the development of the H. Brown site, and
groundwater use restrictions in the areas that have contaminated groundwater.
Groundwater use restrictions may be rescinded after remediation standards are met and
proven to be maintained.

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3. Action Specific ARARs

Action-specific ARARs are requirements that define acceptable treatment and disposal
procedures for hazardous substances.

Federal ARARS

RCRA Subtitle C Land Disposal Restrictions (LDRs) - Consolidation will occur within the
area of contamination, therefore, the requirements of this act will not be triqqered for
consolidation. The requirements of this act will be applicable to any off-site treatment of
the waste products of the selected remedy that are RCRA hazardous waste. These
requlations qovern the storaqe and disposal of hazardous waste. This remedy will comply
with LDRs throuqh a Treatability Variance for wastes that cannot be treated to meet the
standard.

RCRA Subtitle C Closure Requirements 40 CFR Part 264 - Pursuant to Section 121(d)(4)
of CERCLA, 42 U.S.C. Section 9621(d)(4), U.S. EPA is waivinq this ARAR. The
standards are considered applicable for this site because hazardous waste was disposed of
at the site after the effective date of the RCRA requlations; this remedy would not comply
with that ARAR, but it would achieve a standard of performance equivalent to that
required. A waiver of the ARAR is appropriate pursuant to Section 121(d)(4)(D) of
CERCLA.

RCRA Subtitle C qeneral performance standards require that a final cover be desiqned and
constructed to: a) provide lonq-term minimization or miqration of liquids throuqh a closed
landfill; b) function with minimum maintenance; C) promote drainaqe and minimize
abrasion of the cover; d) accommodate settlinq and subsidence so that the cover's inteqrity
is maintained; and, e) have a permeability less than or equal to any bottom liner system or
natural subsoils present. They also require the implementation of a post-closure plan,
property access restrictions and notifications, and qroundwater monitorinq.

The cap proposed under this alternative would prevent direct contact with the contaminated
waste and would minimize contact of water with the waste to the same deqree as a RCRA
Subtitle C cap. Althouqh there is hazardous waste on-site a portion of the waste sits in the
shallow qroundwater. This minimizes any benefit qained by placinq a more impermeable
cap such as a RCRA Subtitle C cap over the waste. The RCRA Subtitle C cap is desiqned
to minimize the potential for direct contact with hazardous waste and to minimize the
potential for contaminants to leach from the waste via contact with precipitation. Applyinq
a RCRA Subtitle C cap will not prevent contact of the qroundwater with the waste. A
cover system meetinq the direct contact requirements of RCRA Subtitle C cap will prevent
direct contact and will minimize the amount of precipitation cominq in direct contact with
the waste in the vadose zone. It will provide for the same deqree of protection of human
health and the environment. Also, because of the redevelopment of the property and a
permanent on site presence of an active facility this is equally reliable because of the ability
to perform daily inspections and repairs. It will take less time to implement than the cap
required under the ARAR.

State ARARs

Part 111 of the Natural Resources and Environmental Protection Act, 1994 PA 45 1 (Act
451 Part 111) (formerly known as the Michiqan Hazardous Waste Manaqement Act or Act
64) - Pursuant to Section 121(d)(4) of CERCLA, 42 U.S.C. Section 9621(d)(4), U.S. EPA
is waivinq this ARAR for the purpose of the cap desiqn and construction only. Michiqan's
Act 451 Part 111 is considered applicable for this site because hazardous waste was
disposed of at the site after the effective date of the RCRA requlations; this alternative
would not comply with that ARAR, but it would achieve a standard of performance
equivalent to that required at this site because the waste currently sits within the shallow
qroundwater. Site contaminants are shown to be adherinq to soil particles and therefore are
not mobile, so as a resialt, a Part 111 cap would not provide any additional protection
aqainst infiltration causinq site contaminant mobility or leachinq. A waiver of the ARAR
is appropriate pursuant to Section 121 (d)(4)(D) of CERCLA. Part 111 requires that a

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hazardous waste landfill cap include both a layer of compacted clay exceeding the areas
frost depth, but not less than 90 centimeters, and not less than 60 centimeters of additional
material to prevent damage to the cap from burrowing animals, temperature, erosion, and
rooted vegetation. The cap in this alternative would not meet the reguirement for at least
90 centimeters of compacted clay, a frost protection layer or a vegetated layer. It does
include an impervious cover system which would meet the reguirements of Part 111
pertaining to preventing exposure to contaminants via direct contact. It will provide for the
same degree of protection of human health and the environment.

The intent of a Part 111 landfill final cover design is to minimize both the potential for
direct contact with contaminated materials, and the potential for leaching of the
contaminants into the underlying aguifers. With contaminated materials currently sitting in
shallow aguifer at the H. Brown Site any additional degree of impermeability afforded by a
Part 111 cap is negated. Additionally, the Pre-Design Field Investigation found that site
related lead contamination is not currently migrating off-site in the groundwater, but
instead is remaining bound to soil particles on-site, showing that direct contact with the
contaminated soil is the exposure pathway of concern. The concrete foundations and
asphalted areas will serve as a barrier to direct contact as long as proper maintenance is
continued and will also minimize the potential for precipitation from coming in contact
with contaminants in the vadose zone. Under the new future use and redevelopment
scenario, with an active facility to be operating on-site, and with long-term maintenance of
the cover system assured, the reguirement to construct and maintain a vegetated clay cap
over the contaminated soils is being waived. If the land-use changes the cleanup plan
contains a contingency that a vegetated clay cover, consistent with the reguirements
contained in Michigan's Act 451, Part 115 will he constructed.

Part 115 of the Natural Resources and Environmental Protection Act, 1994 PA 451 (Act
451 Part 115) (formerly known as the Michigan Solid Waste Management Act or Act 641)-
If for some reason redevelopment of the property as contemplated in this ROD Amendment
fails, a final cover meeting the reguirements of Part 115 will be constructed. Upon closure
of the site, high levels of contaminants will be left on-site untreated. Because the waste is
sufficiently similar to waste regulated under the Act, the Act's reguirements are relevant
and appropriate for the waste.

Michigan Public Health Code, Public Act 368 of 1978, Part 127 - This act regulates the
water supply intended for use or used to supply groundwater. It is applicable to the
selected remedy, because it addresses the location, construction, and abandonment of
private drinking wells.

Inland Lakes and Streams Act, Public Act 346 of 1972, as amended - The act regulates
construction activities on or over bottomlands of inland lake and streams. This act will be
applicable to the selected remedy, because it addresses the mitigation of potential run-off,
erosion, silting, and sedimentation in the surface waters during construction.

Mineral Well Act, Public Act 315 of 1969, as amended - This act regulates location,
construction, and abandonment of monitoring and test wells. This act is similarly relevant
and appropriate for the selected remedy.

4. To-Be-Considered

OSWER Directive #9355.4-02 Interim Guidance on Establishing Soil Lead Cleanup Levels at Superfund sites -
This directive sets interim soil lead cleanup standards at 500 - 1000 parts per million.

Wetlands Management Executive Order 11990 - The order reguires federal agencies to avoid, to the extent
possible, the long- and short-term adverse impacts associated with the destruction or modification of
wetlands.

Floodplain Management Executive Order 11988 - This order reguires the minimization of potential harm to or
within flood plains and the avoidance of long- and short-term adverse impacts associated with the occupancy
and modification of flood plains.

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c. Cost Effectiveness

Cost effectiveness compares the effectiveness of an alternative in proportion to its cost of providing
environmental benefits. Tables 1 and 2 list the costs associated with the implementation of the remedy.

The selected remedy, Alternative 2, has been determined to afford overall effectiveness proportional to its
cost. Alternative 2 carries moderate costs in comparison to the other alternatives considered. While both
Alternatives 2 and 3 are protective of human health and the environment, Alternative 2 provides for the
additional benefit of providing for the productive, beneficial, continued use of the property and is the
preferred alternative for the current site owner and prospective purchaser. Therefore, although the selected
remedy is not the least costly alternative considered, U.S. EPA believes this benefit compensates for the
additional cost associated with the selected remedy. The selected remedy affords the greatest effectiveness
proportional to its cost.

d. Utilization of Permanent Solutions and Alternative Treatment Technologies or
Resource Recovery Technologies to the Maximum Extent Practicable

The selected remedy represents the maximum extent to which permanent solutions and treatment technologies can
be utilized in a cost effective manner for this site. Of those alternatives that are protective of human
health and the environment and comply with ARARs, the U.S. EPA has determined that the selected remedy
provides the best trade-offs in terms of long-term effectiveness and permanence, reduction in toxicity,
mobility, or volume achieved through treatment, short-term effectiveness, implementability, cost,
andconsidering state and community acceptance.

The selected remedy offers a high degree of long-term effectiveness and permanence. These benefits are
achieved at a reasonable cost.

e. Preference for Treatment as a Principal Element

Because of the large volume of contaminated waste at this site (180,000 cubic yards of
soil) and treatment of the principal threats of the site was not found to be practicable, the
selected remedy does not satisfy the statutory preference for treatment as a principal
element.

VI. Documentation of Significant Changes

The Proposed Plan was released for public comment in August 1997. The Proposed Plan identified Alternative
#2, Warehouse Redevelopment, as the preferred alternative. That alternative stated that three (3) feet of
fill would be brought in to develop the appropriate grades at the site. During the public comment period
discussions between MDEQ, the developer, the PRPs, and U.S. EPA, revealed that the developer had intended on
using consolidated contaminated soil to raise the elevations, i.e. only a portion of the three feet of fill
needed would be clean fill. As a result of the discussions it was determined by U.S. EPA, in consultation
with MDEQ that, at a minimum, the cover would need to consist of at least two (2) feet of clean fill material
to ensure protection from direct contact with the contaminated soils. Therefore, in the areas to be covered
by concrete foundations the contaminated soil would be covered by, at a minimum, six (6) inches of concrete
and eighteen (18) inches of clean fill. In the areas to be covered by asphalt the cover would consist of, at
a minimum, three (3) inches of ashphalt, eight (8) inches of road gravel, and thirteen (13) inches of clean
fill. Contaminated areas to be landscaped would be covered by three (3) feet of clean fill to allow for
protection for things such as planting, rooting zones, and freeze-thaw conditions.

VI. Summary

The presence of soil, sediment, and groundwater contamination at and around the H. Brown site reguires that
remedial actions be implemented to reduce the risk to public health and the environment. The U.S. EPA
believes, based upon the RI/FS, the Pre-Design Field Investigation and the Administrative Record, that the
selected alternative provides the best balance of trade offs among alternatives with respect to the criteria
used to evaluate the remedies. Based upon the information available, at this time, the U.S. EPA believes that
the selected remedy will be protective of human health and the environment, will attain ARARs and will
utilize permanent solutions and alternative treatment technologies or resource recovery technologies to the
maximum extent practicable.

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The total estimated costs for the selected remedy at this site are as follows:

               Total                  Total                   Total
Alternative Capital Cost               O&M                Present Worth
   #2       $5,011,502               $13,185                $5,214,199

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Tables
                                     TABIiE 1
                        RA Cost Estimate for Alternative 2
TASK                    QUANTITY    UNIT

Drain cleaning and      5,480       L.F.
consolidating
sediments

Consolidating soil      4,700       C.Y.
from U.S. 131
R.O.W.

Consolidating Soils     950         C.Y.
South of Abbott
Auto

Consolidating soils     10,200      C.Y.
from Baker Auto

Backfilling, Baker,     14,100      C.Y.
S.  of Abbot Auto
and U.S. 131
R.O.W.

Top soil and seed       4,650       S.Y.
U.S. 131 R.O.W.

Top soil and seed       4,400       S.Y.
Baker Auto

Health and Safety       1           lump

Landfill gas            1           lump
protection for
buildings

Gas monitoring          4           each
probes

Groundwater             3           each
monitoring wells
Institutional controls  1

Scope Contingency

Bonds and Insurance

Engineering and
Design

Construction S & A
UNIT COST    TOTAL     COMMENT

15           82,200
10
10
10
6.5
2.5
2.5
2,100
3,500
             47,000
             9,500
             102,000
             91,650
             11,625
             11,000
20,000       20,000

883,173      883,173
8,400
10,500
1
5
5
5
lump 5,000 5,000
% 63,102
% 63,102
% 63,102
                                                           75,723
                                                                     (Continued)

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General Task
SUBTOTAL

CapConstruction

General Conditions

Demolition of 4
existing buildings

Excavation
Paving
Landscaping and
irrigation

Concrete
Subtotal

Overhead                5

Profit                  5

SubTotal Cap
Construction

Abbott Auto Soil Consolidation

Excavate and            16,160
consolidate soils
 lump

 lump


 lump
140,000

46,500


675,000
 lump
334,600
 lump


 lump
56,000
                                              1,862,280
1,729,775




140,000

46,500


675,000
334,600
56,000
1,862,280
c.y.
           6.00
             3,114,380

               155,719

               163,505

             3,433,604




             96,960
Grubbing site
Fill material
(60,000cy @
$7/cy)
Dig and backfill
foundations
subgrade site
2'  of clay at
landscaped areas
storm sewers

3"  Asphalt (28,700
sy @ 55.6/sy)
8"  - 22A road
gravel
12" subbase
Pavement markings
                         Building foundation
                         6" concrete floors
                         4" concrete
                         sidewalks
                         Concrete curb and
                         gutter
                         8" concrete truck
                         docks

-------
Table 2





COST ESTIMATE FOR ALTERNATIVE 3





         TASK





Cleaning and Grubbing





Fencing





Move Abbott Auto Soil





Random Fill





24" Clay





6" Topsoil





Seeding





Monitoring Wells





Gas Monitoring Probes





Storm Sewer Cleaning











Contingencies











Engineering and Design





Construction S&A





O&M
*(Total Capital Cost and Present Worth of Annual O&M)





<98100F>
QUANTITY UNIT
15
3,600
4,600
33,600
46,800
11,700
15
4
4
1
Acres
L.F.
C.Y.
C.Y.
C.Y.
C.Y.
Acres
Each
Each
Job
UNIT COST
$2,000,
10,
10,
6,
6,
9,
765,
10,000,
2,100,
35,000,
.00
.00
.00
.06
.06
.12
.00
.00
.00
.00
Subtotal
25%
TOTAL
6%
9%
30

Job
CONSTRUCTION
Job
Job
Years
TOTAL PROJECT
200,200,
COST
60,060,
90,090,
763,587,
COST
.75

.23
.34
.00

TOTAL
$30,
36,
46,
203,
283,
106,
11,
40,
8,
35,
800,
200,
1,001,
60,
90,
763,
$1,914,
000.
000.
000.
616.
608.
704.
475.
000.
400.
000.
803.
200.
003.
060.
090.
587.
741.
00
00
00
00
00
00
00
00
00
00
00
75
75
23
34
00
32

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TABIiE 4

CIiEANUP STANDARDS FOR GROUNDWATER

Contaminant            Cleanup Standard  (ug/L)

Antimony                       5.0
Arsenic                        17.9
Cadmium                        4 . 0
Lead                           1.42 E+3
Nickel                         1.03 E+2
Vanadium                       6.81 E+l
Zinc                           4.67 E+3
Benzene                        1.0
Benzo(a)anthracene             5.0
Benzo(a)pyrene                 5.0
Benzo(b)fluoroanthene          5.0
Benzo(k)fluoranthene           5.0
Bis-2-ethylhexylphthalate      5.0
Chrysene                       5 . 0
Dibenzo(a,h)anthracene         5.0
Dieldrin                       1.0 E-2
Heptachlor                     1.0 E-2
Indeno  (1,2,3-cd)pyrene        5.0

-------
Responsiveness Summary

This Responsiveness Summary has been prepared to meet the requirements of Sections 113(k)(2)(B)(iv) and
117(b) of the Comprehensive Environmental Response, Compensation and Liability Act of 1980, as amended by the
Superfund Amendments and Reauthorization Act of 1986 (CERCLA) , which requires the United States Environmental
Protection Aqency (EPA) to respond "...to each of the siqnificant comments, criticisms, and new data
submitted in written or oral presentations" on a proposed plan for a remedial action. The Responsiveness
Summary addresses concerns expressed by the public, potentially responsible parties (PRPs), and qovernmental
bodies in written and oral comments received by EPA and the State reqardinq the proposed remedy for the H.
Brown Co., Inc. Site (H. Brown Site).

A. Overview

1. Backqround/Proposed Plan

The H. Brown site is located in a liqht industrial area in Walker, Michiqan, in south central, Michiqan. It
is located approximately 1/8 mile west of the Grand River, between Turner Avenue and U.S. Hiqhway 131
(US-131).

The site area includes the current, fenced boundaries of H. Brown and an area of known lead contamination
outside the fence. The site includes Zenith Auto Parts on the north, Turner Auto Parts on the south, and is
rouqhly bounded by Turner Avenue on the west, and US-131 on the east. The site area is approximately 16
acres.

Before 1961, Herman Brown operated his property in the site area as an uncontrolled dump. He leased portions
of his property to the City of Grand Rapids, which may have used the leased property for the disposal of
municipal waste. Between 1961 and approximately 1982, H. Brown reclaimed lead from wet-cell batteries. Durinq
that period, up until 1978, the battery acid was reportedly drained directly to the qround before shreddinq
the batteries. The total volume of battery acid disposed of at the site has been estimated between 170,000
and 460,000 qallons. After 1978, battery acid was not drained onto the qround; instead, it was routed to a
stainless steel catch pan and tank. Currently, the company stores scrap, nonferrous metals that are sold to
off-site recyclers.

MDEQ inspected H. Brown several times durinq the 1970s. In 1970, MDEQ noted acidic waters draininq into a
ditch that drained into the Grand River. In 1978, MDEQ sampled wastewater ponded at the site and found
elevated levels of lead, chromium, copper, and nickel.

In the early 1980s, EPA became involved with the site. A site inspection in 1984, found elevated levels of
chromium and lead, and an acidic pH in a ditch leadinq from the site to the Grand River. Subsequently the
site was placed on the National Priorities List (NPL) in 1986, makinq it eliqible for further study and
cleanup under the EPA Superfund proqram. After the potentially responsible parties (PRPs) failed to reach an
aqreement with EPA to conduct an investiqation of the site, EPA undertook the study usinq money from the
Superfund. In 1991, under an administrative order from EPA the PRPs constructed a fence around the area to
the north of the H. Brown property to minimize contact with the contaminated soil by the public.

Testinq durinq the Remedial Investiqation (RI) determined the nature and extent of contamination and found
that the battery crackinq was a source of contamination in the soil and qround water. The Feasibility Study
evaluated 10 cleanup alternatives in order to address the areas of concern.

On September 30, 1992, a Record of Decision (ROD) addressinq the entire site was siqned by the Reqional
Administrator. It included contaminated surface and subsurface soils, surface water and sediments, and
qroundwater.

On September 29, 1995 a ROD Amendment was siqned by the Reqional Administrator. The need for the ROD
Amendment was based upon data obtained from the Pre-Desiqn Field Investiqation (PDFI), which showed that both
the solidification of the soils and the construction of a slurry wall are not feasible and are not necessary
to achieve protection.

The ROD Amendment required the implementation of the followinq components:

• Consolidatinq contaminated surface soil in the area where subsurface soil cleanup will be required;

-------
•      Placing a Michigan Act 451 Part 115 solid waste multilayer cap over all soils exceeding 500 parts per
       million of lead;

•      Long-term monitoring of the shallow and intermediate aguifers to monitor the effectiveness of the
       remedy.

•      Restricting the use of the land and the groundwater.

•      Maintaining a fence around the site to prevent access.

Subseguent to the ROD Amendment U.S. EPA issued a Unilateral Administrative Order to 31 PRPs reguiring them
to implement the remedy selected in the 1995 ROD Amendment. On April 14, 1997, U.S. EPA received notice that
a Buy and Sell agreement had been executed between DBV, Inc. and H. Brown Company Inc. for the properties
comprising the H.Brown Superfund site. The intent of the buyer, DBV, Inc. is to redevelop the property and
bring it back into a beneficial use. The redevelopment plan had been presented to U.S. EPA in an April 18,
1997 proposal which showed the plan to include 2 to 3 large buildings with concrete foundations, parking
facilities and landscaped areas. When constructed, and as long as they are properly maintained, the
facilities would serve as an impermeable barrier preventing direct contact with the contaminated soils and
would minimize the potential for precipitation to leach through the contaminated material. Erosion and runoff
into the adjacent wetlands would also be prevented. The purpose of this ROD Amendment is to change to remedy
to allow the proposed redevelopment of the site to occur.

2.   Public Comment Period

A public comment period on the proposed plan for the ROD Amendment for this Site was held from August 12 to
September 11, 1997. In addition, a public meeting was held on August 19, 1997 at the Walker Community
Building, Walker, Michigan. At this meeting, representatives from U.S. EPA answered guestions about problems
at the Site and the remedial alternatives under consideration. Approximately 5 people attended that meeting.
Comments and guestions from the public were also accepted at the meeting. During the comment period, EPA
received approximately 8 comments concerning the proposed plan.

B.   Community Involvement

The level of public interest regarding this Site has been fairly minimal since the listing of the Site on the
National Priorities List  (NPL). Most interest in the site was spurred by the 1992 de minimis settlement
offer, much of which centered on the fairness of the settlement offer, specifically the dollar amount of the
offer. During the public comment period for this ROD Amendment Proposed Plan most of the comments received
supported the redevelopment plan.

C.   Summary of Significant Comments

Many of the comments below have been paraphrased in order to effectively summarize them in this document. The
reader is referred to the Administrative Record for this Site, located at the Kent County Public Library,
which contains copies of all written comments submitted to EPA. The Administrative Record also contains a
copy of the public meeting notes.

Comment #1:

One commentor urged the Agency to rethink the comparable compositional depths of clay, top soil, fill
material, and vegetative layer. They suggested the consideration of three feet of clay (or two feet with a
vinyl liner) with grading and slope for drainage. The developers could develop on top of this cover system.
They suggest it might be cheaper than Alternative 2.

Response #1:

U.S. EPA disagrees with the comment. Constructing buildings, parking facilities and roads on top of a clay
cover could cause significant damage to the clay cap from the weight of the new structures and the traffic
anticipated on the property after redevelopment. This would add significantly to the operation and
maintenance costs of the clay cover to maintain the integrity of the clay layer. In addition, the three feet
of fill is intended to be used to raise the elevations of the buildings to facilitate the construction of

-------
truck docks. If the elevations weren't raised the developer would have to dig into the contaminated soil to
create the elevation for the docks; this is not a viable option. If the commentors cap was put in place then
on top of the three foot clay cap, the developer would have to import 3 feet of fill to create the
appropriate elevations. In sum the site would then be raised 6 feet over the current elevations creating
drainage and access problems for the site.

Comment #2:

One commentor guestioned the reguirement to place, and maintain a fence around the entire property.

Response #2

U.S. EPA agrees with the commentor. Since the site will be an active facility, and there will be personnel
on-site to monitor security and prevent vandalism, at this time it is not deemed necessary to construct a
fence around the site.

Comment #3

One commentor asked whether the State of Michigan approved the plan.

Response #3

The State of Michigan has assisted in the development and review of the Administrative Record. The State
Concurs with the selected remedy.

Comment #4

One commentor guestioned whether the redevelopment would be reguired to comply with city and county zoning
ordinances, specifically those pertaining to the development in a flood plain.

Response #4

The final remedy will be reguired to comply with any city or county zoning ordinances as enforced by those
bodies of government.

Comment #5

How much lower will the adjoining property (Abbott Auto) be after the soil from that property is consolidated
and the site is covered by concrete and asphalt? Will fill be brought in to bring it back to the original
grade? The commentor reguested a copy of the final ROD Amendment.

Response #5

Final elevations will not be determined until the final design is created, and will ultimately depend on the
amount of soil reguired to be removed. U.S. EPA currently anticipates that two feet of contaminated soil will
be removed. The remedy does not reguire that the Abbott Auto property be restored to its original elevation.
However, a final grade consistent with the current grade will be ensured which will allow for proper drainage
of the property. It might be necessary to bring clean fill in to achieve the final grade. The remedy will
comply with the city's building codes and the property will be left in a useable condition, consistent with
its current use to the extent that it does not present a physical hazard and so that it drains appropriately
and flooding does not become a problem. In addition, drainage controls will be in place on the H. Brown
property so that run-off will be controlled and diverted so as not to create a drainage problem on the Abbott
Auto, or other adjacent properties.

The other properties from which soils will be consolidated will be addressed in accordance with the terms of
their respective negotiated access agreements, i.e. if the access agreement specifies that the excavation be
brought back to the original elevation and condition, then the party performing the work will be reguired to
meet the reguirements of the agreement. At a minimum, the parties performing the remedy will ensure that the
completed work presents no physical hazards and will meet the city's building code reguirements.

A copy of this document will be forwarded to the commentor.

-------
Comment #6

One commentor questioned the statement in the Proposed Plan that cited the current zoning of the property
light industrial. They said it should be heavy industrial instead.

Response #7

As the comment pertains to the Abbot Auto property the U.S. EPA agrees with the comment. However, as
confirmed by the City of Walker,  the H. Brown property is currently zoned light industrial.

Comment #8

Will U.S. EPA pursue additional potentially responsible parties (PRPs)

Response #8

U.S. EPA believes that it has identified all of the PRPs at this site. If information is obtained which U.S.
EPA believes supports liability at the Site, U.S. EPA will evaluate the information and proceed accordingly
using its enforcement discretion. Of the 1500 PRPs identified, approximately 172 settled their liability with
the Agency in a 1992 de minimis settlement. To the extent potentially responsible parties have been
identified and and have not settled U.S. EPA's claims against them with respect to the Site, U.S. EPA
reserves the right to pursue those parties at its discretion. An additional 31 parties were issued a
Unilateral Administrative Order  (UAO) compelling them to implement the remedy specified in the 1995 ROD
Amendment. Those parties have either settled U.S. EPA's claims regarding the Site, are currently negotiating
settlement of those claims, or have otherwise indicated their intent to comply with the UAO.

-------
                           U.S. ENVIRONMENTAL PROTECTION AGENCY
                                     REMEDIAL ACTION

                                  ADMINISTRATIVE RECORD
                                           FOR
                                 H. BROWN SUPERFUND SITE
                                     WALKER, MICHIGAN

                                        UPDATE #5
                                       MAY 19, 1997
NO.     DATE

 1   09/30/92
AUTHOR

Adamkus, V.,
U.S. EPA
RECIPIENT

U.S. EPA
TITLE/DESCRIPTION

Record of Decision
PAGES

   77
 2   09/29/92
Adamkus, V. ,
U.S. EPA
                  U.S. EPA
                                        Record of Decision
                                                                             92
                                        UPDATE #6
                                      JULY 31, 1997
 1   07/01/96
U.S. EPA
                  Respondents
 2   08/19/96
Prendiville,
T., U.S. EPA
Ferroli, J.;
Dykema Gossett
PLLC and
C. Barbieri;
Foster, Swift,
Collins &
Smith
Administrative Order
for Remedial Design
and Remedial Action
w/Attachments, Appendices
and Sample Cover Letter

Letter re:  (1) U.S. EPA's
Notice of Authorization
to Proceed with the
Remedial Design and  (2)
Changes to the Unilateral
Administrative Order and
Statement of Work for the
H. Brown Site
                                                                            273
 3   04/18/97
Kok, A. ;
Varnum,
Riddering,
Schmidt &
Hewlett
Ferroli, J. ,
Dykema Gossett
PLLC
Cover Letter Forwarding
the Revised Redevelopment
Site Plan for the H. Brown
Site
 4   06/30-97
Kok, A. ;
Varnum,
Riddering,
Schmidt &
Hewlett
Lindland, K. ,
U.S. EPA
Letter re: Placement of
Attached Redevelopment Site
Plans and Property Purchase
Agreement into the
Administrative Record w/
Attached January 20, 1997
A. Kok Letter to U.S. EPA
                                                                             10

-------
NO.     DATE

 1   07/00/97




 2   08/18/97




 3   08/19/97




 4   09/00/97
AUTHOR

U.S. EPA
                           U.S. ENVIRONMENTAL PROTECTION AGENCY
                                     REMEDIAL ACTION

                                  ADMINISTRATIVE RECORD
                                           FOR
                                 H. BROWN SUPERFUND SITE
                                     WALKER, MICHIGAN
    UPDATE #7
OCTOBER 14, 1997

   RECIPIENT

   Public
Ulmer, C.,
Smith
Industries
U.S. EPA
Kok, A.,
Attorney for
   Hill, S.,
   U.S. EPA
                  File
                  U.S. EPA
TITLE/DESCRIPTION

Fact Sheet: U.S. EPA
Recommends Changes to
Cleanup Plan at H. Brown
Superfund Site

Letter re: Comments on
the Proposed Cleanup
Alternatives for the
H. Brown Superfund Site

Memorandum: Minutes of
August 19, 1997 Public
Meeting re: the H. Brown
Superfund Site

Public Comment Sheet re:
the
PAGES

    9

-------


By this memorandum we recommend that you authorize a remedial decision for the H. Brown Co., Inc. Site in
Walker Michigan by signing the attached Record of Decision  (ROD) Amendment.

This ROD Amendment was prepared in accordance with the Comprehensive Environmental Response, Compensation,
and Liability Act, 42 U.S.C. Section 1901 et seg.,  as amended by the Superfund Amendments and Reauthorization
Act of 1986, Public Law 99-499, the National Contingency Plan, 40 CFR Part 300, and Agency policy. We have
reviewed the attached documents and have concluded that the ROD is both legally and technically sufficient.
As such, we believe that implementation of this remedial measure is a proper exercise of your delegated
authority.

Please feel free to contact either of us if you should have any guestions.

Attachment

-------