Charlie Crist

Florida Department of Governor

Environmental Protection Jeff Kottkamp

Lt. Governor
South District
P.O. Box 2549
Fort Myers, Florida 33902-2549 Michael W. Sole
Secretary

July 25, 2008

Ms. Judy Grippo

City of Fort Myers
Community Development
1700 Medical Lane
Fort Myers, Florida 33907

Re: Lee County WC

Limited Groundwater Assessment Report
Homerama (proposed)
South Street, Fort Myers, Florida
COM_288039

Dear Ms. Grippo:

The Florida Department of Environmental Protection's South District Office has reviewed
the Limited Groundwater Assessment Report for the Homerama (proposed) property.
Arsenic contamination has impacted the groundwater on the property exceeding
Department criteria. Please take the time to read the attached Interoffice Memorandum
dated July 25, 2008 discussing our technical review of the submittal.

The Waste Cleanup Program encourages discussion, and will meet, or teleconference with
the interested parties concerned to determine options proposed in addressing the
contamination, and remediation of the property to the satisfaction of the Department. If
you have additional questions or need further assistance please contact Charles A.
Masella or myself at (239) 332-6975. Your continued cooperation with our office and
attention to this matter are appreciated.

Sincerely,

Frank Nemec, P.G.

Waste Cleanup Program

attachment
FN/CAM/se

cc: George E. Evans, P.G. (ACT) w/attachment

Mel Reinhart (FDEP-SD) w/attachment
Charles Emery (FDEP-SD) w/o attachment

More Protection, Less Process

www.dep.state.fl.us
 Interoffice Memorandum
To: File

Through: Frank Nemec, P.G.

Waste Cleanup Program-South District

From: Charles Masella

Waste Cleanup Program-South District

Date: July 25, 2008

Subject: Lee County - WC

Limited Groundwater Assessment Report
Homerama (proposed)
City of Fort Myers Community Development
South Street
Fort Myers, Florida
Facility ID: COM_288039
--------------------------------------------------------------------------------------------------------------------
The Florida Department of Environmental Protections South District Waste Cleanup Program
has reviewed the Limited Groundwater Assessment Report for the Homerama (proposed)
property administered by the City of Fort Myers. The report was generated and submitted by
American Compliance Technologies, Inc. (ACT), and received by the Department on April 24,
2008. The report documents the installation and sampling of six monitoring wells to
determine the quality of groundwater beneath the property.

The property consists of a city block located south of South Street and north of Jeffcott Street,
bordered to the west and east by Henderson Avenue and Midway Avenue, respectively. The
property was formerly a deposition site for lime sludge material generated at a water
treatment plant operated by the City of Fort Myers. Previous investigations conducted on the
property determined that soils contaminated with arsenic extend below the water table, and a
concern exists that arsenic and aluminum impacted groundwater may be present beneath the
property.

On March 19, 2008, ACT representatives supervised the monitoring well installation. Four
wells were placed on each corner of the property, with two wells installed near the central
area of the site. The wells consisted of 2.0-inch PVC, with 10.0-foot screens, totaling 12.0 feet
below surface grade. The wells were encased by a concrete surface pad, within a steel riser for
protection. The wells were developed until turbidity issues were not a factor, and clear water
was acquired.

continued.
Limited Groundwater Assessment Report
Homerama (proposed)
Facility ID: COM_288039
Page 2

Groundwater samples were collected on March 24, 2008 in accordance with DEP-SOP 001/01
FS 2200 guidelines. The samples were analyzed for arsenic and aluminum by EPA Method
6010. Arsenic was detected in the samples tested from monitoring wells MW-1(northwest
corner and suspected slurry deposition area) at a concentration of 12.0 micrograms per liter
(g/l), and in MW-3 (southeast property corner) at a concentration of 13.0 g/l. Arsenic was
also detected in wells MW-4 (southwest property corner) and MW-5 (west central property) at
a concentration of 10.0 g/l. Arsenic was not detected in the samples collected from wells
MW-2 (northeast property corner), or MW-6 (east central property). The Departments
maximum allowable concentration for arsenic in groundwater is 10.0 g/l, pursuant to Florida
Administrative Code (F.A.C.) Rule 62-777 Groundwater Cleanup Target Levels (GCTLs).

Two samples were re-tested according to EPA Method 200.8 by an alternate laboratory.
Results for wells MW-1 and MW-3 indicated the presence of arsenic at 17.6 g/l, and 18.0 g/l
respectively, slightly higher than the initial testing results.

The metal aluminum was not detected exceeding F.A.C. Rule 62-550 GCTLs for Drinking
Water Standards of 200 g/l in any of the six samples collected.

Summary:
The Waste Cleanup Program has reviewed the Limited Groundwater Assessment Report for
the property, and has determined that the sampling was conducted according to Department
criteria. We concur with the consultant that arsenic levels in the groundwater appear to
slightly exceed F.A.C. Rule 62-777 GCTLs, and further assessment of the quality of the
groundwater is not warranted at this time.

The Department does have continuing concerns with the arsenic-impacted soils buried on the
property, and will require the responsible party to submit a Remedial Action Plan (RAP) to
address contaminated soils existing on the property, or seek approval for No Further Actions
with Conditions, under Risk Management Options (RMO), Rule 62-780.680 F.A.C. for the
facility. If Institutional Controls are chosen for placement on the property as per Rule 62-
780.680, the Application for submittal pursuant to the Departments Institutional Controls
Procedures Guidance document may be submitted for technical review to the South District
Office, for forwarding to the Office of General Counsel (OGC). During the interim period, the
Departments 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 until a decision concerning approval of the No Further Action
with Conditions is published by the Department.