City of Fort Myers, Florida

Engineering Division
Stormwater Management
P.O. Drawer 2217
Ft. Myers, FL 33902
PH# (239) 321-7630
FAX# (239) 344-5943

FDEP ID: COM 288039, Lime Residuals Removal and Disposal Plan

August 30 2018

This plan is in response to the letter dated March 12, 2018 from FDEP signed by Jon Iglehart outlining
the options and procedures required to bring closure to the project. This letter provided two options for
moving forward;
Plan A; Removal of Lime Residual from the site.
Plan B; Complete Site Assessment.
The City of Fort Myers intends to investigate and voluntarily remove all lime residuals from the entire
3.77 acre Block that contains the property associated with the above referenced project. This includes
both the city owned properties as well as the private properties interspersed within the Block.
It is estimated that the City of Fort Myers disposed of 20,000 cubic yards of lime residuals on the
property during the 1960’s. The material has been in place approximately 50 years and testing has
confirmed that there are no immediate health risks to the surrounding neighborhood or the ground water.
The removal of the lime residuals is a complex process that will take a significant amount of time and
coordination to complete successfully. The proposed removal is the final step in the City’s testing and
remedial efforts, which began ten years ago.
Site Preparation
Right of Entry (ROE) permissions will be obtained from four of the five adjacent property owners within
the Block. The fence will then be relocated to the perimeter of the ROW. The City is currently pursuing
the ROE required to complete the project. City staff is currently taking three ROE permissions to City
Council on September 4, 2018 for approval. Additionally, City staff will be taking a contract to City
Council in September to purchase one of the two properties for which we have not received a signed
ROE. City staff is pursuing either buying the fifth property or obtaining a ROE.
The fence will be relocated and all organic debris will be removed from the site prior to excavation. This
is required due to the recycling processes used for the disposal of the lime residuals. The organic debris
will be disposed of according to the rules and regulations of the FDEP. The disposal records for the
organic material will be provided to FDEP within two weeks of the completion of this phase.
Lime Residuals Removal
The lime residuals on the property will be removed completely from the site by a company experienced in
the removal of lime residuals from lagoons and registered with the state of Florida. The private adjacent
properties will be evaluated and any lime residuals found on those sites will be removed.
Five auger borings will be evaluated on each 0.17 acre lot to determine the presence or absence of the
lime residuals. Borings will be 4’ deep or until refusal. If lime residuals are encountered below the
surface, the clean top soil will be moved to the side and lime residuals will be removed from beneath the
soil.

Public Works Department

Website: www.cityftmyers.com
Email: rthompson@cityftmyers.com
The excavation of lime residuals will operate under the rules and regulations of the Florida Department of
Environmental Protection and the Federal Environmental Protection Agency. It is anticipated that the
excavation will be done wet without any dewatering. If dewatering becomes necessary any dewatering
effluent will be contained on the site.
Removal Assurance
Source removal excavation monitoring and confirmatory sampling will be conducted in accordance with
Chapter 62-780.525(5)(a)5, F.A.C. Initial completeness of excavation will be based on the visual
presence or absence of lime residuals. If observations indicate that there is no visible lime residuals
along the sidewalls or bottom of the excavation, and the sidewalls and bottom are above the water table,
confirmatory soil samples will be collected from the bottom and sidewalls of the excavation to determine
completeness of the lime residuals removal.
Two soil samples will be collected from depths of 0.5-ft. and 2-ft. below land surface, approximately
every 25 linear feet of the excavation perimeter/sidewalls. Excavation bottom confirmation soil samples
will be collected from approximately 25-foot centers.
Soil samples will be analyzed for soil texture using the approved NRCS Guide to texture by feel.
(Appendix 1a).
Where the depths of excavation extend below the water table, the material in the excavation bottom and
sidewalls in the excavator bucket will be visually inspected for the presence or absence of lime residuals.
Samples from the excavator bucket will be collected and inspected at approximately 25-foot intervals
along the sidewalls and from approximate 20-foot centers from the bottom of the excavations below the
water table.
Excavations will be determined to be complete when soil textures fall into the target categories in
Appendix 1b.
In addition, the City will perform monthly groundwater monitoring of the ten monitoring wells (MW-1R
through MW-10) until the project is complete with one final round of testing after the completion of the
excavation. The wells will be tested for Al, As, Mn, Fe, Mo & TDS. It is anticipated that wells 5 and 6 will
be damaged or removed during the excavation process due to their proximity to the lime residuals
deposits. These wells will be monitored until they are damaged or removed. At the completion of the
lime residuals removal and the final confirmatory testing, the monitoring wells will be abandoned and
capped.
After it has been determined that all of the lime residuals have been removed from the site, ten soil
samples per ¼ acre will be collected from the upper 12” of the soil (not including the excavated areas
below 12”) and tested for arsenic according to 62-780.680(1)1. F.A.C.
Transportation & Disposal
The lime residuals will be transported by liquid-tight truck from the property to a disposal site in central
Florida. From here it will be transported out of state for reuse in the production of concrete and ceramic
products.
The City of Fort Myers is finalizing agreements with an environmental company that will be responsible
for the transportation and disposal of the lime residuals. The environmental company will take ownership
and responsibility of the lime residuals at the time the trucks are loaded on the site. Copies of the
agreement will be furnished to FDEP after City Council approval of the agreements.
Time Line
The Lime residuals removal project is tentatively scheduled to begin by Oct 1, 2018. The start date will
be dependent on the weather and forecasts at the time.
On Oct 1, 2018, the fence will be relocated and the site cleared within two weeks.

COM 288039, Lime Residuals Removal Plan

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The removal and transportation of lime residuals should begin by Oct 15, 2018. The removal is
scheduled to be completed within 45 days of the actual start date.
Site Assessment
The March 12, 2018 letter from FDEP required the inclusion of a Site Assessment in accordance with 62-
780.600(3) F.A.C. to be done after the completion of the lime residuals removal. The majority of the
information required to complete this assessment has already been completed.
The current and projected use of the affected groundwater in the vicinity of the site is for irrigation wells.
There is no surface water on the property or in the vicinity of the site. The current land use of the area
affected by the contamination is vacant residential. Fort Myers City Council, with input from the
neighborhood, will make a decision on the projected land use.
Arsenic exposure for the human population can be through contact or ingestion. The degree of arsenic
contamination in the lime residuals ranges from 1.84 mg/L to 21.9 mg/L. The extent of arsenic
contamination is contained within the boundaries of the four lime residuals pits on the site. In January
2018, the City of Fort Myers had Dr. Chris Saranko review all the available data to determine the
exposure risk for the surrounding areas. His conclusions were that the detected arsenic concentrations
do not pose a short or long-term health concern to people in the surrounding neighborhood.
The groundwater sampling results do not support a contamination plume extending from the site. There
were no groundwater quality exceedances in any of the monitoring wells after October 2012 and before
October 2017 (after Hurricane Irma). The test results since October 2017 do not show a defined plume
and the majority of the exceedances are up gradient of the lime residuals. The recent results seem to
indicate that a slug of arsenic has passed the site as a result of disturbances created with Hurricane
Irma. This phenomenon has been observed at other sites throughout Florida. With no defined plume of
contamination there is no location, rate or direction for the plume.
Data collected from groundwater sampling performed by the City of Fort Myers since March 2008 show
episodic exceedances of arsenic at various up-gradient, cross-gradient and down-gradient monitoring
well locations. An inspection of the results from MW – 6 shows that this well has never had an
exceedance of arsenic. This well is considered a source well since it is surrounded on three sides by the
lime residuals pits and is immediately down-gradient of the deepest lime residual deposits on-site. This
is the only well that has never had an exceedance. This is also the only well that does not have a
groundwater flow component that is not forced through the lime residuals. This data, as well as the
results of SPLP testing for arsenic concentrations of the lime residuals sample, consistently indicate that
the groundwater has not been impacted by the lime residuals.
Based on the groundwater flow direction of the current monitoring and calculations of the information
from the previous monitoring, Monitoring Wells MW-2, MW-3, MW-4, MW-7 and MW-9 are background
wells. The historic data collected from wells MW-2, MW-3 & MW-4 will be used to establish background
information from 2010 to date. Data collected from all background monitor wells will be utilized for
background information, as well as or the determination of seasonal variability.
The source of arsenic contamination in the lime residuals was through the lime softening treatment
process previously used to treat groundwater for potable use. Once the lime residuals are removed from
the site, any possible source of contamination from the lime residual will no longer be present and there
will not be any potential for further migration of contamination from the site. There is no free product at
the site. In addition, with the complete removal of the lime residuals, the site should meet the No Further
Action Criteria, which eliminates the requirements of 62-780.600(3)(g), (j) and (k) F.A.C.
A well survey was conducted with the original preliminary site assessment and has been submitted to
FDEP. There are no public water supply wells within a ½ mile radius of the site nor private water supply
wells within ¼ mile radius of the site.

COM 288039, Lime Residuals Removal Plan

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Reports
The City will submit monthly status reports of the lime residuals removal commencing with the
anniversary date of initiating the site preparation operations. The monthly reports will be submitted a
week after the end of the reporting month.
Within 60 days of completing the excavation the City will submit a Source Removal and Site Closure
Report containing the following information:
1. The volume of contaminated soil or sediment excavated and treated or properly disposed,
2. The disposal or recycling methods for contaminated soil or sediment,
3. The disposal methods for other contaminated media and any investigation-derived waste,
4. A scaled site map (including a graphical representation of the scale used) that shows the
location(s) where lime residuals was recovered and the area of removal,
5. A scaled site map (including a graphical representation of the scale used) that shows the
locations and results of confirmatory soil samples in relation to the area lime residuals
removal,
6. A scaled site map (including a graphical representation of the scale used) that shows the
locations and results of the risk assessment soil samples in relation to the area lime residuals
removal,
7. Separate tables by media that summarize all available soil, sediment, groundwater, and surface
water analytical results, detection limits achieved for non-detected analytes, and analyses
performed (listing all contaminants analyzed and their corresponding CTLs),
8. Depth to groundwater at the time of each excavation, measurement locations, and method used
to obtain that information,
9. Documentation or certification that confirms the proper treatment or proper disposal of the non-
aqueous phase liquids, contaminated groundwater, contaminated soil, or contaminated
sediment, including disposal manifests for non-aqueous phase liquids or hazardous waste,
and a copy of the documentation or certification of treatment or acceptance of the
contaminated soil or contaminated sediment.
10. Groundwater analysis summary of all groundwater samples collected and analyzed since the
December 2017 samples through one month after the completion of the lime residuals
removal.
11. Documentation of all assertions and testing completed for the Site Assessment.
The Source Removal and Site Closure Report will include all the requirements stated in the March 12,
2018 letter for Plan A: Lime Residuals Removal satisfying all the requirements of 62-780.600(3). It is the
intent of the City of Fort Myers that the site will meet the No Further Action criteria.
Thank you,

Richard H Thompson, P.E.

City of Fort Myers
Stormwater Resource Manager

CC: Saeed Kazemi, P.E. City Manager

Richard Moulton, Public Works Director

COM 288039, Lime Residuals Removal Plan

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 APP
CK
BY
NO.
REVISIONS AND RECORD OF ISSUE

XREF1:
XREF2:
XREF3:
XREF4:
DWG VER:
Residuals Residuals
Lagoon #3 Lagoon #4 Residuals

PLOTTED:
DATE
Lagoon #1b

SAVED:
Maximum Maximum

USER:
≈
Depth = 6'
≈ 4'
Depth = 4' Maximum
≈ 10'
Depth = 10'

Residuals Residuals
Lagoon #2 Lagoon #1a
Maximum Maximum
≈ 14' ≈ 14'
Depth = 14' Depth = 14'

Figure 1: LIME RESIDUALS REMOVAL PLAN

APPROXIMATE LOCATION OF
LIME RESIDUALS LAGOONS
Notes:
1. Source removal excavation monitoring and confirmatory sampling will be
conducted in accordance with Chapter 62-780.525(5)(a)5, F.A.C.
2. Confirmation soil samples will be taken from the excavation sidewalls and
bottom if the soil is above the water table.
3. Excavation sidewall confirmation soil samples will be collected at depths of
0.5 feet & 2.0 feet, approximately every 25 linear feet of the sidewall.
4. Excavation bottom confirmation soil samples will be collected from DESIGNED:
DETAILED:
approximately 25 foot centers. CHECKED:
APPROVED:
DATE:
0 1/2 1

IF THIS BAR DOES NOT

MEASURE 1" THEN DRAWING IS
NOT TO FULL SCALE
PROJECT NO.

SHEET
D7000

OF
6/26/2018 12:24:16 PM
 MW-10 MW-8

SOUTH STREET

MW-2
MW-1R

MW-7

MW-5
MIDWAY AVENUE

MW-6

HENDERSON AVENUE
MW-3
MW-4
MW-9 MW-11

JEFFCOTT STREET

FIGURE 2: Groundwater Monitor Well Sample
Locations
South Street Property
3348 South Street
Fort Myers, Lee County, Florida
LEGEND:
GFA Project No.: 17-5281.00 Approximate City Property
Drawn By: SM; Date: 1/4/2018 Existing Monitoring Well Location Boundary
Source: GoogleEarth, 2/3/17
Approximate Site Boundary
Approximate Scale 1”= 60’
Approximate Sludge
Disposal Area Based on
1958 Aerial Photograph
NRCS Approved Method for Soil Texture by Feel
Appendix 1a
 Appendix 1b

LIME RESIDUAL TEXTURE

TARGET TEXTURES TO INDICATE REMOVAL OF RESIDUAL