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Mr. Chris Dressel March 4, 2014 Page 2 of 18 limitations on liability and clarify the reasonable steps IDEM considered appropriate for the SBRC to take with respect to hazardous substances and petroleum products found on the property. Prior to the issuance of the Comfort Letter, IBP staff reviewed reports by Hull & Associates, Inc. (Phase I ESA, dated March 2010 and Phase I ESA Update Memorandum, dated April 21, 2010) to determine existing environmental impacts and potential liability at the property. Hull &Associates, Inc. (Hull) identified the following three recognized environmental conditions(RECs) associated with the site. • Historic Site Operations as a RCRA Treatment, Storage, and Disposal (TSD) Facility • Existing Waste Containers in former Container, Storage, Processing&Transfer Building. • Potential Fuel Oil Underground Storage Tank Associated with these RECs, IDEM identified tetrachloroethene, trichloroethene, benzene, toluene, arsenic, and lead impacts in the soil and groundwater beneath the site at concentrations that exceeded applicable residential default closure levels. As a result, the Comfort Letter was issued with the condition that an environmental restrictive covenant (ERC) be recorded on the deed for the site in the name of the SBRC to ensure no exposure to the contamination. Restrictions included the following: • Agricultural or residential usage was prohibited. • Potable groundwater usage from beneath the property is prohibited. No wells can be installed for any purpose other than for monitoring without prior IDEM approval. • Provide full cooperation to persons authorized to conduct environmental response action. • Cap soils exceeding industrial default closure levels or excavate impacted soils and dispose off-site. • Conduct indoor air quality assessment for soil vapor intrusion for any existing or newly constructed buildings on site. • Notify IDEM if land use changes. Weaver Boos understands that the ERC was not recorded, in light of the upcoming 2011 and 2012 demolition and soil removal project that was completed with IDEM oversight.