956019

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, IL 60604-3590

AUG 1 1 ?017 REPLY TO THE ATTENTION OF:

LU-161 Mr. Robert W. Hare Deputy Cleanup Manager - RACER Trust 500 WoodwardA venue, Suite 1510 , 48226

RE: Delco Plant 5 Facility in Kokomo, Indiana- 4.85-acre Northern Parking Lot EPA ID IND000806844

Dear Mr. Hare:

This letter is in response to your e-mail dated May 16, 2017 transmitting your summary report forthe parcel referenced above. This response is based upon the facts currently known to the U.S. Environmental Protection Agency (EPA) and is provided solely fro informational purposes. The parcel is NorthernParking Lot of the Delco Plant 5 facility that is located at 1723 North Washington Street, Howard County, Kokomo, Indiana (Site). The Delco Plant 5 facility (Facility), as well as the Site, are a Resource Conservation and Recovery Act (RCRA) facilitysubject to a 2006 Corrective Action Agreement (Agreement). The Facility has an identification number of IND000806844.

In June 2009, the former Corporation (General Motors Corp.) filed for Chapter 11 reorganizationbankruptcy, and subsequently emerged as two new companies. The first of these two new companies, General Motors LLC, purchased the ''General Motors" name and certain assets of General Motors Corp. and now operates automobile manufacturing plants in Michigan, , Indiana, , and . The second company, Motors Liquidation Company (MLC), retained all of the assets thatGeneral Motors LLC did not purchase, as well as the liabilities. This included many properties, including the Delco Plant 5 Facility.

1n March 2011, the bankruptcy court approved MLC's plan of liquidation (Plan). On the effective date of the Plan, 89 sites were placed into an EnvironmentalResponse Trust (Trust) administrated by the Revitalizing Auto Communities Environmental Response (RACER) Trust. Pursuant to the termsof the Plan and the Trust, specific amounts of funds were set aside for each property in the Trust to address environmental contamination found at the specific property.

The Site is a parking lot and dead end road located on the northern portion of the Facility totaling approximately 4.85-acres. The Site is depicted as Area A in the attachment. The Site is bounded to the east by Washington Street; to the west by a railroad, Davis Road, and Webster Street; to the north by Butler Street; and to the south by the remainder of the Facility. The Site was used forparking for facility employees while the Facility was in operation; however, it is currently vacant. A water pump house and water tank were also present on the southeast portion of the parking lot.

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Recycled Paper (100% Post Consumer) The initial portion of Plant 5 was constructed in 1915 and used until 1926 by Apperson Brothers Automobile Company to assemble Haynes automobiles. In 1926, the property was owned by Wolfe Manufacturing Industries which manufactured radio cabinets. It was then purchased in the late 1930s by Reliance Manufacturing which used the facility for manufacturing women's clothing and packing parachutes during World War II. In 1953, General Motors Corp., Delco Division purchased the property and was using the Facility to assemble and test circuit boards when the plant closed in 1991. Demolition, including the removal of the floor slab, was completed in 1993. The entire property was donated to the Kokomo-Howard County Development Corporation (KHDC) in February of 1999; however, in December of 2003, General Motors Corp. reacquired the Facility. EPA and General Motors Corp. entered into a performance-based RCRA Corrective Action Agreement in March 2006. Pursuant to the Agreement, General Motors Corp. worked in cooperation with EPA to investigate releases of hazardous wastes or hazardous constituents at or from the Facility. As a result of General Motors Corp.'s June 2009 bankruptcy, the RACER Trust (RACER) now has responsibility for completing the Corrective Action activities at this Facility in accordance with the Cost Estimate and Settlement Agreement that are the basis for the Trust.

Under the terms of the GM bankruptcy $7.2 million was allocated for environmental remediation work at the Facility. The EPA is the lead agency for the Site. EPA has overseen the remediation work conducted by RACER at the Facility under the guidelines of the RCRA corrective action program and will continue to oversee remediation work for the Facility.

With regard to the Site, several investigations have been undertaken since 1997. Soil samples were collected within the upper 10 feet of the subsurface as part of Phase I of the RCRA Facility Investigation (RFI); arsenic, cobalt, iron, manganese, and thallium were detected above the Indiana Department of Environmental Management (IDEM) Remediation Closure Guidance (RCG) migration-to-groundwater (MTG) screening levels. However, of these metals, only manganese was detected in groundwater above IDEM RCG groundwater residential tap screening level. Vinyl chloride was detected in groundwater at concentrations higher than the IDEM RCG groundwater residential vapor exposure screening level and IDEM RCG groundwater residential tap screening level at one monitoring well, and trichloroethylene (TCE) was detected in groundwater higher than the IDEM RCG groundwater residential tap screening level at one monitoring well. Vinyl chloride has not been detected at concentrations higher than the IDEM RCG screening criteria at any other monitoring well at the Site. Arsenic and thallium were detected above the IDEM RCG residential direct contact screening levels. An Environmental Restrictive Covenant (ERC) placed on the property will address these levels of contamination.

The levels of contamination present on the Site do not appear to present an unacceptable risk to human health or the environment under a non-residential reuse scenario. EPA can make a risk management decision and a presumptive remedy detem1ination for this parcel alone. EPA believes that Corrective Action requirements are considered complete for this Site, separate from the Facility, with the filing of the ERC on July 8, 201 7 with the Howard County Recorder. The documentation of the Site's status will be included in the overall Delco Plant 5 Final Decision and Response to Comments document, to be issued at a future date. The ERC addresses the current conditions at the Site by requiring: • Prohibition on the use of groundwater at the Site. • Requirement that any future structures at the Site must install a vapor barrier. • Site is restricted to non-residential use.

The specified restrictions in the ERC address current and future risk at the Site and it is available for redevelopment in accordance with those restrictions.

2 This Site is cunently not on the National Priorities List nor does EPA have any current plans to perform any assessment or removal work at the Site under Comprehensive Environmental Response Compensation and Liability Act (CERCLA). Further, if EPA were to take action under CERCLA, a purchaser of the Site who complies with the requirements of 42 U.S.C. §9601(40) would not be a liable party for any pre-existing contamination.

This letter addresses EPA's intentions under the RCRA Subtitle C program, and CERCLA at the Site. This letter does not address any possible actions by the State of Indiana with respect to any potential RCRA corrective action, underground storage tank, or other requirements that the State might deem appropriate at the Site. Finally, this letter would not apply to any entity in the future that engaged in the treatment, storage, or disposal ofRCRA hazardous waste on this Site.

If you have any questions regarding this letter, or if we can be of further assistance, please do not hesitate to contact Peter Felitti at (312) 886-5114 or, Michelle Kaysen, of my staff, at (312) 886-4253.

Jose G. Cisneros, Chief Remediation and Reuse Branch Land and Chemicals Division

Enclosure

cc: Mike Sickels, IDEM

3

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1734012039 BROOKE. CLEAV'ER HOwARD COUNTY IN RECORDER ELECTRONICALLY RECORDED AS PRESENTED ON 07/20/2017 11: 14: 00.AM REC FEE: $25.00 PAGES: 13

Environmental Restrictive Covenant

THJS ENVIRON!\ L RESTRICTIVE COVENANT ("Covenant") is made this ~- day of __l/::::.~¼----c=c:--=--•' 20/J_, by Revitalizing Auto Communities Environmental Response ACER) Trust with an operating address of 500 Woodward Avenue, Suite 2650, Detroit, Michigan, 48226 (together with all successors and 1 assigneesj coUectively ''Owner' ),

"WHEREAS: Owner is the fee owner of certain real estate in the County of Howard, Indiana, which is located at 1723 North Washington Street in the City of Kokomo and more particularly described as the northern parking lot in the attached Exhibit "A" ("Real Estate"), which is hereby incorporated and made a part hereof. This Real Estate was acquired by deed on March 31, 201 !, and recorded on May 25, 2011, as Deed Record l 134()08830, in the Office of the Recorder of Howard County, Indiana. The Real Estate consists of approximately 4.855 acres of land and has also been identified by the County as parcel identification number 34-03-25-203-002.000-002. The Real Estate, to which the restrictions in this Covenant apply, is depicted on maps attached hereto as Exhibit "B" and Exhibit "C".

WHEREAS: RCRA Corrective Action was conducted under the supervision of the Environmental Protec\ion Agency ("USEPA") and in accordance with a Performance-Based Corrective Action Agreement ("Agreement") between USEPA and General Motors Corporation, with an effective date of March 16, 2006. This Agreement enabled General Motors Corporation ("GM") to work independently and voluntarily to investigate, and .as necessary, stabilize and remcdiate releases of hazardous wastes or hazardous constituents at or from the Former GM Delco Plant 5 facility (EPA ID No. IND 000 806 844) that may present an unacceptable risk to human health or the environment.

WHEREAS: As a result of GM's bankruptcy, the operating assets of GM were sold to a newly fmmed company, which is now known as General Mowrs Company. Existing, non-continuing assets remain the property of "old" GM, which changed its name to Motors Liquidation Company ("MLC"). RCRA Corrective Action activities were conducted at the facility by MLC from approximately July 2009 to September 20 l l. A Performance-based Administrative Order on Consent Docket Number RCRA-05-2011- 00]7 (''Order") was signed by and betNeen RACER Trust and USEPA with an effective date of September 29, 2011, at which point, RACER Trust assumed the responsibility for completing the RCRA Corrective Action activities at the facility in accordance with Section VJJ of the Order. The Order may be viewed at the publicly accessible repository located at the Kokomo-Howard County Public Library, 220 North Union Street,

REVIEWED Jul 20 2017 Martha J_ Lake! KW Auditor, Howard County. Indiana Kokomo, Indiana, 46901 The Order may be viewed electronically in the Indiana Depa1tment of Environmental Management ("IDEM") Virtual File Cabinet ("VFC") by accessing the IDEM's Web Site (currently www,in.gov!idem/). The IDEM VFC Document Number (VFC #) is 80476461.

WHEREAS: The RCRA corrective action activities conducted, as approved by the USEPA, provide that contaminants of concern (COCs) will remain in the soil and groundwater of the Real Estate. The USEPA has determined that the COCs will not pose an unacceptable risk to human health or the environment at the remaining concentrations, and that the Real Estate may be withdrawn from the Order provided that the land use restrictions contained herein are implemented. The known COCs remaining are listed in Exhibit "D", which is attached hereto and incorporated herein.

WHEREAS: Pursuant to Section Vil, Paragraph 19 of the Order, RA.CER Trust prepared a report, Parking Lot Summary of Investigation, that summarized the historical uses of the Real Estate and environmental data collected on the Real Estate. The VFC # for the Parking Lot Summary of Investigation report is 80479573. Based on comparison of this environmental data to the IDEM generic screening levels, USEPA determined that land use restrictions to non-residential use and vapor mitigation for future buildings would be required to address potential .risk to residual contamination in soil and groundwater.

WHEREAS: Environmental investigation reports and other related documents are hereby incorporated by reference and may be examined at the EPA Records Center, 77 West Jackson Boulevard - 7th Floor, Chicago, IL 60604 between 8:00 a.m. and 4:00 p.m. (Monday - Friday, excluding Federal holidays) or at the offices of IDEM, which is located in the Indiana Government Center North building at l 00 N. Senate Avenue, , Indiana. The documents may also be viewed at the Public Information Repository, which is located at the Kokomo~Howard County Public Library, 220 North Union Street, Kokomo, Indiana, 4690 I. The documents may also be viewed electronically in lDEM's Virtual File Cabinet by accessing the IDEM's Web Site (currently www.in.gov/idem/),

NOW THEREFORE, RACER Trust subjects the Real Estate to the following restrictions and provisions, which shall be binding on the current Owner and .all future Owners:

l. RESTRICTIONS

2 I. Restrictions. The Owner:

(a) Shall not use or aJlow the use of the Real Estate for residential purposes, including, but not limited to, daily child care facilities or educational facilities for children (e.g., daycare centers or K-12 schools).

(b) Shall not use or allow the use or extraction of groundwater at the Real Estate for any purpose, including, but not limited to: human or animal consumption, gardening, industrial processes, or agriculture, except that groundwater may be extracted in conjunction with environmental investigation and/or remediation activities.

(c) Shall not use the Real Estate for any agricultural use.

(d) Shall not construct or allow occupancy of a dwelling or work space on the Real Estate unless a vapor mitigation system is installed, operated, and maintained within the dwelling or work space.

( e) Shall prohibit any activity at tl1e Real Estate that may interfere with the groundwater monitoring or well network.

IL GENERAL PROVISIONS

2. Restrictions to Run with the Land. The restrictions and other requirements described in this Covenant shaJI run with the land and be binding upon, and inure to the benefit of the Owner of the Real Estate and the Owner's successors, assignees, heirs and lessees and their authorized agents, employees, contractors, representatives, agents, lessees, licensees, invitees, guests, or persons acting under their direction or control (hereinafter "Related Paities") and shall continue as a servitude running in perpetuity with the Real Estate. No transfer, mortgage, lease, license, easement, or other conveyance of any interest in or right to occupancy in all or any part of the Real Estate by any person shall affect the restrictions set forth herein. This Covenant is imposed upon the entire Real Estate unless expressly stated as applicable only to a specific portion thereof.

3. Binding upon Future Owners. By taking title to an interest in or occupancy of the Real Estate, ai1y subsequent Owner or Related Party agrees to comply with all of the restrictions set forth in paragraph 1 above and with all other tenns of this Covenant.

4. Access for USEPA and the IDEM. The Owner shall grant to the USEPA, IDEM, and their designated representatives the right to enter upon the Real Estate at reasonable times for the purpose of monitoring compliance with this Covenant and ensuring its protectiveness; this right includes the right to take samples and inspect records.

5. Written Notice of the Presence of Contamination. Owner agrees to include in any

3 instrument conveying any interest in any portion of the Real Estate, including but not. limited to deeds, leases and subleases (excluding mortgages, liens, similar financing interests, and other non-posse.ssory encumbrances). the following notice provision (with blanks to be filled in):

NOTICE: THE INTEREST CONVEYED HEREBY IS SUBJECT TO AN ENVIRONMENTAL RESTRICTIVE COVENANT, DATED____ _ 20_, RECORDED IN THE OFFICE OF THE RECORDER OF HOWARD COUNTY ON ______, 20_, INSTRUMENT NUMBER (or other identifying reference) ______IN FAVOR OF AND ENFORCEABLE BY THE U.S. ENVIRONMENTAL PROTECTION AGENCY AND THE INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT.

6. Notice to USEPA and IDEM of the Conveyance of Propertv. Owner agrees to provide notice to the USEPA and IDEM of any conveyance (voluntary or involuntary) of any ownership interest in the Real Estate (excluding mortgages, liens, similar financing interests, and other non-possessory encumbrances), Owner must provide the USEPA and JDEM with the notice within thirty (30) days of the conveyance and: (a) include a certified copy of the instrument conveying any interest in any portion of the Real Estate, and (b) if it has been recorded, its recording reference, and ( c) the name and business address of the transferee.

7. Indiana Law, This Covenant shall be governed by, and shall be construed and enforced according to, the laws of the State ofindiana,

UL ENFORCEMENT

8. Enforcement. Pursuant to IC 13-14-2-6 and other applicable law, IDEM may proceed in court by appropriate action to enforce this Covenant. Damages alone are insufficient to compensate IDEM if any owner of the Real Estate or its Related Parties breach this Covenant or othe,wise default hereunder. As a result, if any owner of the Real Estate, or any owner's Related Parties, breach this Covenant or otherwise default hereunder, TDEM shall have the right to request specific performance and/or immediate injunctive relief to enforce this Covenant in addition to any other remedies it may have at law or at equity. Owner agrees that the provisions of this Covenant are enforceable and agrees not to challenge the provisions or the appropriate couii'sjurisdiction,

9. The Owner, EPA, and IDEM may proceed in court, individually or jointly, by appropriate action to enforce the terms of this Covenant, including but not limited to the restrictions. All remedies available hereunder shall be in addition to any and all other remedies at law or equity, Enforcement of the terms of this Covenant shall be at the discretion of the Owner, EPA, and IDEM and any forbearance, delay, or omission by any of them to exercise rights available under this Covenant in the event of a breach of any term of this Covenant shall not be

4 deemed to be a waiver by the Owner, EPA, or IDEM of such rights or of any subsequent breach of the same or any other term. Also, at any time after RACER Trust becomes a former Owner, RACER Trust shall have the right to enforce the terms of this Covenant, including but not limited to the restrictions, in the same manner as granted herein to EPA and IDEM, if actions are taken or threatened by a subsequent owner or a third party in violation of the restrictions that may exacerbate any residual liability of R/1.CER Trust for the remediation conducted at the Real Estate.

IV. TERM. MOD!F!CATION. AND TERMINA T!ON l O. Term. The restrictions shall apply until the USEPA and JDEM determines that the contaminants of concern no longer present an unacceptable risk to the public health, safety, or welfare, or to the environment.

J J. Modification and Termination. Tbis Covenant shall not be amended, modified, or terminated without USEPA and IDEM's prior written approval. Within thirty (30) days of executing an amendment, modification, or termination of the Covenant, Owner shall record such amendment, modification, or termination with the Office of the Recorder of Howard County and within thirty (30) days after recording, provide a true copy of the recorded amendment, modification, or termination to the USEPA and IDEM.

V. MISCELLANEOUS

12. Waiver. No failure on the part of the USEPA or IDEM at any time to require performance by any person of any term of this Covenant shall be taken or held to be a waiver of such term or in any way affect USEPA or the IDEM's right to enforce such term, and no waiver on the part of the USEPA or IDEM of any term hereof shall be taken or held to be a waiver of any other term hereof or the breach thereof

13. Conflict of and Compliance with Laws. lfany provision of this Covenant is also the subject of any law or regulation established by any federal, state, or local government, the strictest standard or requirement shall apply. Compliance with this Covenant does not relieve the Owner of its obligation to comply with any other applicable Jaws.

14. Change in Law, Policv or Regulation. In no event shall this Covenant be rendered unenforceable if Indiana's laws, regulations, Remediation Closure Guide ("RCG") guidelines, or remediation policies (including those concern mg . environmental restrictive covenants, or institutional or engineering controls) change as to form or content. All statutory references include any successor provisions.

5 15. Notices. Any notice, demand, request, consent, approval or communication that either party desires or is required to give to the other pursuant to this Covenant shall be in writing and shall either be served personally or sent by first class mail, postage prepaid, addressed as follows:

To Owner: RACER Trust 500 Woodward Avenue Suite 2650 Detroit, Ml 48226 Attn: Robert Hare, Cleanup Manager

To USEPA: U.S. EPA Region 5 77 W. Jackson Boulevard Mail Code: LU-9J Chicago, IL 60604-3507 Attn: Land and Chemicals Division Remediation and Reuse Branch

To IDEM: IDEM, Office of Land Quality 100 N. Senate A venue IGCN 1101 Indianapolis, JN 46204-2251 Attn: Section Chief, Hazardous Waste Permit Program

An Owner may change its address or the individual to whose attention a notice is to be sent by giving written notice via certified mail.

I 6. Severability. lf any portion of this Covenant, or other term set forth herein, is determined by a court of competent jurisdiction to be invalid for any reason, tbe surviving portions or terms of this Covenant shall remain in full force and effect, as if such portion found invalid had not been included herein.

17, Authoritv to Execute and Record, The undersigned person executing this Covenant represents that he or she is the current fee Owner of the Real Estate, or is the authorized representative of the Owner, and further represents and certifies that he or she is duly authorized and fully empowered to execute and record, or have recorded, this Covenant.

Owner hereby attests to the accuracy of the statements m this document and all attachments.

6 IN WITNESS WHEREOF, RACER Trust, the said Owner of the Real Estate described above has caused this Environmental Restrictive Covenant to be executed on this 2il_ day of n,_,,L '20)7 . .. ~- ~ -/- REVITALIZING AUTO COMMUNIT[ES ENVIRONMENTAL RESPONSE TRUST, a trust fom1ed under the laws of the State of

By: EPLET, LLC, acting solely in its Capacitycas Administr~ye Trustee 7/ J/ / . •-.y·• By;:f,,/'0,{r-'t-i \. q-r,,,...... -... --~-J----- ELLIOTT P. :A:N, , not individually, but acting solely in his capacity as Managing Member

DISTRICT OF CvtuJ~- ) ) SS: CITY OF ~------l

Before me. a Notary Public in and for said City and District, personally appeared ELLJOTT P. LAWS, not individually, but acting solely in his capacity as Managing Member of EPLET, LLC, a limited liability company, acting solely in its capacity as Administrative Trustee of REVITALIZING AUTO COMMUNITIES ENVIRONMENT AL RESPONSE TRUST, a trust organized and existing under tbe laws of the State of New York, and acknowledged the execntion of the foregoing Environmental Restrictive Covenant for and on behalf of said company and trust, and who, have been duly sworn, stated tbat the representations there\fl ontained are true. . - -lj. -· 4/..~"·;·~"•;~····•·, _ Witness my hand and Notarial Seal this 2_ day of_--?1--1,0..,,-,,::--i_ __, 2017. l ..,_~~-····; ·-./'1; . I ~- ·.,."'"' 1.1.1,-. , It f ~-.. .,,._. SLf..a., , /) . . ;: f.\~• -~ :. . f~c-rl (V/,imJ' 0 ·. ,;_' •:<> 9 .11·'1. • .·"".,,_ tJ· 7/! £,'. ' ;!it. \ ~ ·.. _/ ;,." ~J,1tdr{ sit!:Yb , Notary Public ' >, . ··•·· ," I '--.,. l::r ot · (. • • · , ._ I Res1dmg m -~--~~-County, My Commission Expires: Cf. 3a) t y

This instrument prepared by: Sarah Fisher Arcadis U.S., Inc. 132 East Washington Street, Indianapolis, Indiana 46204

7 EXHIBIT A

LEGAL DESCRIPTION O.F REAL ESTATE

Land lying in the Northeast¼ of Section 25 of Township 24 North, Range 3 East, City of Kokomo, Township of Center, County of Howard, State oflndiana:

All that part of Lots 25, 28, 33, 35, 36 in Avery's Addition to the City of Kokomo, lying west ofNorth Washington Street as shown in Recorder's Plat Book 1, Page 9; and also, a strip of ground 18 feet wide adjacent to said Lot 35 in Avery's Addition to the City of Kokomo on the Southwest corner thereof and being the East Half of that part of Robinson Street heretofore vacated which lies .at the Southwest corner of and adjacent to said Lot 35; and also, all of Spraker Street (50 feet wide) vacated lying West of Washington Street and lying between all that part of Lot 25 and all that part of Lot 26 in Avery's A.ddition West of Washington Street and Lots 27, 28, 33, 34 and.35 in Avery's Addition to the City of Kokomo, Center Township, Howard County, Indiana, as shown in Recorder's Plat Book l, page 9. Excepting therefrom that part thereof which has been appropriated for North Washington Street, and more particularly described as follows:

Beginning at the intersection of the South right-of-way line of West Butler Street (50 feet wide) and the East right-of-way line of North Webster Street, said intersection also being the Northwest comer of Lot 36 of Avery's Addition to the City of Kokomo, thence running South 82 degrees 26 minutes 24 seconds East a distance of270.93 feet to a point; !hence South 07 degrees 33 minutes 36 seconds West a distance of208.56 feet to a point; thence South 82 degrees 26 minutes 24 seconds East a distance of393 .56 feet to a point; thence South 00 degrees 00 minutes 00 seconds West a distance of258.56 feet to a point; thence No1th 82 degrees 26 minutes 24 seconds West a distance of 559.89 feet to a point; thence North 26 degrees 47 minutes 30 seconds West a distance of 169.16 feet to a point; thence North 00 degrees 00 minutes 00 seconds East a distance of 328.07 feet to the Point of Beginning.

Containing 4.855 acres of land, more or less, and subject to any and all recorded easements and rights-of-way. EXHIBITB

MAP OF REAL ESTATE

EXHIBITC

SITE MAP WITH SAi"1PLE LOCATIONS '''

' ' i 1 :.1 .:,i,' ;~~l=

'I / EXHlBITD

LISTOFCOCs

Samples have been collected from soil and groundwater within the northern parking lot of the Real Estate prior to and during Corrective Action activities at the Real Estate. The following constituents have been analyzed for and detected at concentrations higher than the identified 2017 Indiana Department of Environmental Management Remediation Closure Guide (RCG) Screening Levels. The analytical results are presented in the Parking Lot Summary ofinvestigation report (VFC # 80479573.)

Soil

2017 IDEM RCG Mitigation to Groundwater Screening Levels • Arsenic • Cobalt • Iron • Manganese • Thallium

2017 IDEM RCG Direct Contact Residential Screening Levels • Arsenic • Thallium

Groundwater

2017 IDEM RCG Groundwater Tap Residential Screening Levels • Trichloroethene • Vinyl Chloride • Manganese ( dissolved)

20 l 7 IDEM RCG Groundwater Residential Vapor Exposure Screening Levels • Vinyl Chloride