During the 1960’s, the 3348 South Street property was used by the City to place a lime softening sludge–a by-product of the City’s former drinking water treatment plant–in borrow pits on the site before the neighborhood was established. In recent years, the City of Fort Myers, in collaboration with the Florida Department of Environmental Protection (DEP), has been conducting ongoing soil and groundwater testing at 3348 South Street and surrounding areas to ensure that there are no potential risks to human health or the environment. The City is committed to providing a safe place for our residents to live and work and is working closely with the DEP to monitor and assess the groundwater. According to recent testing, the groundwater is not a risk to human health and the environment.
City agrees to purchase South Street property at a public hearing during the City Council meeting. Mayor Edward Simpson states on the record that the property will be used for sludge disposal.
The City advertises for proposals to build a pipeline for sludge disposal to the wellfield. A November 20 News-Press article cites Public Works Director Roger Nooe, who states that “The dumping pits off Henderson are filled.” A November 30 article about the same topic adds, “…the sludge is a non-contaminating mineral mixture, it has no value and is a nuisance to water plant officials.” It is unknown exactly when the City stopped utilizing the South Street pits.
Construction is complete on the City’s new water plant, which uses a membrane process/reverse osmosis to process drinking water. Lime sludge is no longer produced.
City Council approves a contract for the sale of the seventeen South Street lots to Habitat for Humanity to build affordable single-family housing within three years from the date of sale.
City Council rescinds the contract with Habitat for Humanity. “Soil borings revealed that 3-5 feet of lime from the treatment plant was used as fill on the property and the cost of building on pilings renders the affordable housing planned by Habitat for Humanity infeasible.”
The City contracts Environmental Risk Management, Inc. (ERMI) to perform a preliminary environmental site assessment on the property because of “Reported dumping on lime sludge.” The report notes that “lime sludge is not considered to be a hazardous waste.” ERMI does not observe lime sludge on the site, and notes that vegetation could be covering the area of concern, or that the lime sludge may have formed a hard shell. With these exceptions, “ERMI concludes that no environmental concerns would exist if such dumping has occurred on site. Further investigation is not considered necessary.”
The South Street lots are annexed by the City as part of the Dunbar annexation (Ordinance No. 2003-16).
The City contracts ASC Geosciences, Inc. (ASC) to test the South Street property for lime sludge and finds approximately 25,000 cubic yards of sludge on the site. FDEP recommends testing for arsenic and aluminum. ASC tests 44 test pits at varying depths. Aluminum concentration is well below soil cleanup target level of 80,000 mg/kg in all 44 pts. Only one of the 44 test pits is found to have arsenic levels exceeding soil cleanup target levels for commercial/industrial of 12 mg/kg. Test pit #14 is found to have a concentration of 16 mg/kg, eight feet below the ground surface. All other pits are tested at or below target level.
ASC suggests several remediation scenarios, including:
• Excavating all of the sludge and replacing with clean fill.
• Excavating the top two feet of material and replacing with clean fill. (would likely require a deed restriction for the type of structures/foundations allowed)
• Excavating the top two feet of material, and chemically fixating the land with cement or other technique. (would likely require a deed restriction for the type of structures/foundations allowed)
A 2017 Estimate of the costs of each potential remediation strategy are estimated from $3 million to $17 million, depending on the strategy utilized and site-specific factors that cannot be determined at the current time.
City Council passes a resolution (2007-17) to establish funding for the development of the “Home-A-Rama” project to provide infill housing alternatives to residents. The proposed Home-a-Rama affordable housing project is a planned unit development for seventeen vacant lots bounded by South Street, Jeffcott Street, Ford Street, and Henderson Avenue. “The City will work with the Department of Environmental Protection to implement a cost effective solution for mitigating the lime sludge that presently exists on some of the lots”.
The City contracts American Compliance Technologies, Inc. (A-C-T) to perform a limited groundwater assessment report. A-C-T installs six shallow groundwater monitor wells with the approval of FDEP. “The laboratory analytical results indicate that arsenic was detected in two (2) of the six (6) monitor wells in concentrations slightly above the levels established in Chapter 62-550 FAC” [state water standards]. Levels in these wells range from concentrations of .012 mg/l to .018 mg/l.
FDEP asks the City’s Community Development Department to either submit a Remedial Action Plan or request a No Further Actions with Conditions. Additionally, DEP notes, “The Department’s Waste Cleanup Program will require a monitoring plan be instituted at the facility to monitor the site groundwater. Quarterly groundwater sampling according to the interim monitoring plan will continue for a minimum of one year and may be required to continue for an extended period.”
FDEP notifies CDD that it has not yet submitted a remedial action plan for cleanup of the site.
FDEP meets with CDD and Public Works personnel to discuss a timeframe for submittal of the remedial action plan. Because construction plans had been placed on hold due to the recession, the two groups agreed to compromise on a continued monitoring schedule:
“The six monitoring wells on the property would be sampled and analyzed for Arsenic on a semi-annual schedule (August & February) for five (5) years, with a Natural Attenuation Monitoring Report submitted for review within sixty day of the sampling date… A supplement to the RAP, to follow, would include a plan to address impacted soils (sampling of soils, and including a pilot test mixing of impacted and clean soils for example), or other method of remediation to be conducted once development of the associated 1,100 acre property commenced… We accepted the compromise proposal as impacted soils do not appear to be leaching, the groundwater exceedances are insignificant considering the volume of impacted soil, and impacted groundwater was not migrating off-property.”
City submits Remedial Action Plan (described above) to FDEP. The plan is accepted.
City contracts Sanders Laboratories to sample the groundwater wells. Arsenic concentration results range from .0041 mg/L to .0082 mg/L, well below the state water standard of .01 mg/L.
City contracts Sanders Laboratories to sample the groundwater wells. Arsenic concentration results in two of the six wells are below detection limits of .0026 mg/L. Well #2 is measured at .012 mg/L, slightly exceeding the state water standard of .01 mg/L. FDEP responds that: “From the reported concentrations of Arsenic in the groundwater, it is apparent that these sludges are not susceptible to an eleva ted rate of leaching.”
City contracts Sanders Laboratories to sample the groundwater wells. Arsenic concentration results are all below the state water standard. Results in two of the six wells are below detection limits.
City contracts Sanders Laboratories to sample the groundwater wells. Arsenic concentration results are all significantly below the state water standard. Results in three of the six wells are below detection limits.
FDEP reduces the sampling schedule to annual sample collection starting in August 2012.
City contracts Sanders Laboratories to sample the groundwater wells. Arsenic concentration results in all wells are below state water standards. FDEP reminds the City that annual sampling is due in August.
City contracts Sanders Laboratories to sample the groundwater wells. Arsenic concentration results in all wells are below state water standards
City contracts Sanders Laboratories to sample the groundwater wells. Arsenic concentration results in all wells are below state water standards.
City contracts Sanders Laboratories to sample the groundwater wells. Arsenic concentration results in all wells are below state water standards. 2015-2016 (sometime between testing dates). Well #1 on the site is destroyed. It is not known how the damage occurred.
City contracts Sanders Laboratories to sample the remaining five groundwater wells. Groundwater arsenic concentration levels are so low that they are not detectable at the reporting limit.
FDEP reduces the sampling schedule to biennial, with the next sample collection scheduled for September 2018. Additionally, FDEP notes: “We have determined that a replacement for MW-1 will not be necessary.”