This memorandum amends and requests your approval of the Action Memorandum for Region V's request for a ceiling increase and consistency and emergency exemptions to the 12 month and $2 million statutory limits for removal actions at the Illinois Central Spring (ICS) Site located in Bloomington, Indiana. The proposed ceiling increase of $500,000 will bring the project total ceiling to $6,498,973, of which an estimated $6,357,853 is for extramural cleanup contractor costs.

If approved, the additional funding will be used to complete and ensure the proper functioning of the ICS water treatment plant. This will ensure a smooth transition of the operation of the plant from U.S. EPA to the Indiana Department of Environmental Management (IDEM), which has agreed to accept the operation and maintenance (O&M) duties of the plant for a three-year period. It is expected that the water treatment will be incorporated into the final remedy for the associated Lemon Lane Landfill NPL Site, which is currently under development. The State has currently only agreed to an initial three years of Operation and Maintenance. However, the U.S. EPA's Removal Program will not take possession or be responsible for Operation and Maintenance. The Remedial Program is conducting an investigation to address the groundwater and soil contamination that has resulted from this release. It is anticipated that a Remedial Action will encompass, at the very least, plant operation with perhaps some additional remediation measures. If the responsible parties do not implement this remedial action, the action would become "fund lead" and the State would be required to contribute 10% of the costs of the remedial action and assure all future maintenance of the actions provided for the expected life of such actions.