TBA Targeted Browntields Assessment

City of Fort Myers -Welltield (TBA) Chronology

1) 12/14/98: Letter to Joseph K. McGarrity from City of Fort Myers, John A

Kremski Jr., Planning Director. Application for TBA assistance.
2) 01/07/99: Letter from Joseph K. McGarrity acknowledging receipt of TBA.
assistance request.
3) 02/02/99: Correspondence from Joseph K. McGarrity stating TBA assistance
approved by USEPA.
4) 10/08/99: Letter to Ms. Christen Hurley, City of Fort Myers Planning from Joe
McGarrity. Submitted Department[s draft Phase I Environmental Assessment
Report completed by Harding Lawson Association for the City of Fort Myers.
5) 1/27/2000: Received completed Phase I Environmental Site Assessment Report,
City of Fort Myers, Florida, Targeted Brownfields Assessment Site (Wellfield).
Consultant: Harding Lawson Associates, Engineering and Environmental
Services, 2590 Executive Center Circle East, Tallahassee, Florida 32031.
[Bureau of Solid Waste (Waste Clean Up) received 1/18/2000]
6) 06/22/01:Memo to Russell Eastenes, final Phase II Targeted Browntields
Assessment (TBA) -Report for City of Fort Myers-Wellfield. Titled: Phase II
Targeted Brownfields Assessment, City of Fort Myers, Lee County-Prepared
for: Florida Department of Environmental Protection, Site Screening Superfund
Subsection, 2600 Blair Stone Road, Tallahassee, Florida. Consultant-Harding
Lawson Associates.
7) 11/17/03:City of Fort Myers Resolution No. 2003-52, Designating the Wellfield
Site as a Brownfield Area. Approved 11/17/2003 and filed 11/17/2003.
8) 07/01/04: Site Inspection-Tour Participants: Charles Maselle, Art Lyall and
Jesus Diaz-Representing the Department, Regina Adams representing the City
of Fort Myers Community Development Planning Division and Kim Broughton
Fikowski, representing Bonita Bay Group. Phase II Environmental Assessment
Report generated by Harding Lawson Associates (HLA) June 2001-documenting
environmental concerns. Tour included representatives from FDEP and Mactec
Engineering and Consulting Inc.-reinspected the following portions of the
property-City of Palms Wellfield, Fort Myers Fire Academy, Small Engine
Shop/West FMPD gun range, Street Light Shop/East LCSO Range and Jerry
Schuetz Nursery.
9) 09/23/04 (receivedl0/14/04): Assessment workplan for the Phase II Targeted
Brownfields Assessment, Fort Myers Wellfield Site, Fort Myers, Lee County,
Florida.
10)11/15/04: Received Continued Target Brownfields Assessment Work Plan.
[Received by Bureau of Waste Cleanup 11/10/04] Prepared by Mactec
Engineering and Consulting Inc., 2533 Greer Road, Suite 6, Tallahassee, Florida
32308.
11)03/14/05: Received Continued Targeted Brownfields Assessment Report, Fort
myers Well field Site, Fort Myers, Lee County, Florida. Prepared by Mactec
Engineering. [Received.by Bureau of Waste Cleanup 3/2/05.]

12) 08/10/05: Letter to Barbara Schuester from Jesus M. Diaz, Bureau of Waste
Clean Up, Fed. Section, received by South District 08/12/05.Final Continued
Targeted Brownfields Assessment, Fort Myers Wellfield Site.
13) 12/28/05: Received letter dated 12/23/05 on 12/28/05.Site Rehabilitation Plan for
Service Letter from ASC geosciences-Geoenvironmental.
14) 03/31/06: Response letter to Site Rehabilitation Plan. Requested additional
information.
15) 04/04/06: Geo-environmental services Report- Revised Site rehabilitation Plan.
16) 04/10/06: Received draft BSRA (letter dated 04/05/06) froom Dan Richardson of
Lewis, Longman and Walker P.A.
17) 04/13/06: Response letter from ASC geosciences-Providing response to
comments in DEP's 03/31/06 letter.
18)04/24/06: Letter acknowledging receipt of response to revised Site Rehabilitation
Plan received 04/04/06.No response required to our correspondence.However, ,
performance methodologies for blending, sampling and documentation are to be
provided at the time remediation work is initiated. A follow up on the
discrepancy of the of the submitted revised ASC site rehabilitation plan versus
the Mactec's final report shall be discussed prior to site rehabilitation [One less
lime sludge pile].
19) 04/24/06: Letter sent to Dan Richardson after review of draft BSRA. Comments
included in attachment A for what was to be corrected.
20) 06/27/06: Second draft BSRA received with their letter dated 06/23/06.
21) 07/13/06: Response sent to Dan Richardson on draft BSRA received on 06/27/06.
22) 09/11/06: Third draft BSRA received.
23) 09/18/06: Response sent to Dan Richardson. Small changes required and
requested final draft provide comments for those attachments not being
completed at this time.
24) 10/23/06: Fourth draft BSRA received.
25) 10/24/06: Comment letter response sent to Dan Richardson.
26) 11/13/06, 11/14/06 and 11/21/06: Final BSRA copy received 11/13/06 from Dan
Richardson and forwarded to Kim Walker 11/14/06 and received by Bureau of
Waste Cleanup 11/21/06.
27) 12/19/06: Emails and phone calls for changes required to finalize BSRA with
changes being forwarded to Kim by Joe Ullo of the law firm of Lewis, Longman
and Walker P.A. (Dan Richardson). Final BSRA signed by OGC and forwarded
to the South District overnight by Kim Walker 12/19/06.
28) 12/20/06: Signed by South District Director 12/20/06. Forwarde to Katherine
Green, Resource Properties, Inc. 12/20/06. Certified return receipt received
12/21/06.
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II 33,zo

II SOURCE:
Maps and data Copyright 2003 Maptech
0,
._.._1,000
.

SCALE: 1 INCH =
2j ,000

2,000 FEET

II NO. DATE REVISIONS

SITE VICINITY
FIGURE:
CITY OF FORT MYERS .
-------.----- - l!MACTEC
ll
CONTINUED TARGETED BROWNFIELDS
ASSESSMENT REPORT
Engineering and Consulting, Inc. FORT MYERS, LEE COUNTY, FLORIDA

11
Tallahassee, Florida
850-656-1293
FLORIDA DEPARTMENT OF
ENVIRONMENTAL PROTECTION 1
I:
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I SOURCE:
Maps and data Copyright 2003 Maptech
0
.._,._ _1 ,000
SCALE: 1 INCH =
'
2,000
2,000 FEET

AERIAL MAP

CITY OF FORT MYERS FIGURE:

---!------------
/IMACTEC CONTINUED TARGETED BROWNFIELDS
ASSESSMENT REPORT
-h,n=
iti-a--, S-u--b,_mlt,,tal-----
v
:-- Engineering and Consulting, Inc.
Tallahassee, Florida
850-656-1293
FORT MYERS, LEE COUNTY, FLORIDA
FLORIDA DEPARTMENT OF
ENVIRONMENTAL PROTECTION
2
 MW-5
A IWSS01
PWGW01

3
(6.6)

SOURCE:
Maps and data Copvriaht 2003 Maptech
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Microwell location a nd sam ple identification

Soil sam ple location a nd identif ication
NOTES:
1 . Only analytes that exceed C:
Jm.
; -c:s-o... .1 oo
1
SCALE: 1 INCH 100 FEET
thei r respective Soil Clea n u p
Arsenic Target Levels {SCTLs) are shown. SOURCE:
Lead
2. All results i n milligrams per Florida Depa rtment of Transportation
Anlimony
kilog ra m. aerial photograph dated 2-14-1999.
No exceeda nces
EAST GUN RANGE WITH SAMPLE LOCATIONS
NO. DATE REVISIONS _ FIGURE:
CITY OF FORT MYERS
a'MACTEC CONTINUED TARGETED BROWNFIELDS
ASSESSMENT REPORT
Engineering and Consulting, Inc.
Tallahassee, Florida
850-656-1293
FORT MYERS, LEE COUNTY, FLORIDA
FLORIDA DEPARTMENT OF
ENVIRONMENTAL PROTECTION
4
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LEGEND NOTES: 0 75 150
Soll sample location and Identification
Arsenic
Bonzo(a)pyreno
1. Only analyles
respective that exceed
Soil Cleanup Target their
Levels
SCALE: 1 INCH
::,
= 150 FEET
(SCTLs) are shown.

II
Chromium
Copper 2. Organic compounds reported in SOURCE :
Lead
micrograms per kilogram.
Ant imony Florida Department of Transportation
Total Recoverable Polroloum Hydrocarbons 3. Metals reported in milligrams per aerial photogra ph dated 2-14-1999.
No exceedances kilogra m.

I NO. OAT E REVISIONS

WEST GUN RANGE, ENGINE SHOP AND
FIRE ACADEMY WITH 'ANALYTICAL RESULTS
CITY OF FORT MYERS
-- ------------------ '1MACTEC CONTINUED TARGETED BROWNFIELDS
ASSESSMENT REPORT

5
Engineering and Consulting, Inc. FORT MYERS, LEE COUNTY, FLORIDA

O Feb-05 Initial Submittal

Tallahassee, Florida FLORIDA DEPARTMENT OF
P: CAO 850-656-1293 ENVIRONMENTAL PROTECTION

,-
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LEGEND
Microwell location and sample identification
NOTES :
1 . Only a nalytes that exceed thei r
respective Grou ndwater Clea n u p Target
0 75
c1.1::11:::-.cJ1--.. 1
150

As Arsenic SCALE: 1 INCH 150 FEET

Levels {GCTLs) a re shown.

I vc B

1 1 -DCE
{NE)
Benzene
Vinyl Chloride
1,1-dichloroethene
2. Orga nic compounds reported in
microgra ms per liter.
3. Metals reported in milligrams per liter.
SOURCE:
Florida Depa rtment of Transportation
aerial photograph dated 2-14-1999.
No exceedances

I WEST GUN RANGE, ENGINE SHOP AND

NO. DATE
REVISIONS a1MACTEC
FIRE ACADEMY WITH GROUNDWATER ANALYTICAL RESULTS
CITY OF FORT MYERS ----
FIGURE:

CONTINUED TARGETED BROWNFIELDS

ASSESSMENT REPORT
Engineering and Consulting, Inc.
Tallahassee, Florida
850-656-1293
FORT MYERS, LEE COUNTY, FLORIDA
FLORIDA DEPARTMENT OF
ENVIRONMENTAL PROTECTION
6
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:
......._
0 50
;1 00

SNGWOl Microwell location a nd sa mple identification
LEGEND
A SNSSOl Soil sample location a nd identif ication SCALE : 1 INCH = 100 FEET
(NE) No exceedances NOTE :
(NO) No detections Only analytes that exceed their respeclive SOURCE :
Florida Depa rlmenl of Tra nsporlalion

Groundwater Cleanup Target Levels (GCTLs)
are shown . aerial photogra ph doled 2-14-1 999 .
JERRY SCHUETZ NURSERY WITH

SOIL AND GROUNDWATER ANALYTICAL RESULTS

NO. DATE REVISIONS
CITY OF FORT MYERS
-FI-GURE : -
6MACTEC CONTINUED TARGETED BROWNFIELDS
ASSESSMENT REPORT
Engineering and Consulting, Inc.
Tallahassee, Florida
850-656- 1293
FORT MYERS, LEE COUNTY, FLORIDA
FLORIDA DEPARTMENT OF
ENVIRONMENTAL PROTECTION
7
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LEGEND 0 75 150
EGRGW01 Microwell location and sam ple identification
-
SCALE:1 INCH i150 FEET

...
(17.48) Grou ndwater elevation (i n feet)
17.4 - - Grou nd water elevation SOURCE:
contou r a nd designation Florido Oeportment of Transporlat ion
Grou ndwater f low direction aerial photograph doted 2-14-1999 .

GROUNDWATER FLOW DIRECTION AT THE WEST GUN RANGE,

111 ENGINE SHOP AND FIRE ACADEMY NOVEMBER 18 2004
CITY OF FORT MYERS

6MACTEC CONTINUED TARGETED BROWNFIELDS

ASSESSMENT REPORT
Engineering and Consulting, Inc.
Tallahassee, Florida
850-656- 1293
FORT MYERS, LEE COUNTY, FLORIDA
FLORIDA DEPARTMENT OF
ENVIRONMENTAL PROTECTION
8
 Table 1
Summary of Recognized Environmental Conditions Onsite
Continued Targeted Brownfield Assessment Report
Fort Myers Wellfield Site
Fort Myers, Lee County, Florida
Recognized
Site/Facility Sample ID Environmental Rationale Sample Parameters
Conditions

Composite sample from each
PWSS09, PWSS10
Lime Sludge Pile #1 sludge pile to evaluate arsenic Arsenic
PWSS11, PWSS12
levels

PWSS01 Composite sample from each

PWSS02 Lime Sludge Pile #2 sludge pile to evaluate arsenic Arsenic
levels
Composite sample from each
PWSS13
Lime Sludge Pile #3 sludge pile to evaluate arsenic Arsenic
PWSS14 levels
City of Palms Composite sample from each
Wellfield PWSS03
Lime Sludge Pile #4 sludge pile to evaluate arsenic Arsenic
PWSS04 levels
Composite sample from each
PWSS05
Lime Sludge Pile #5 sludge
levels pile to evaluate arsenic Arsenic
--
PWSS06 ... . - -- .. --- . -- .. ..- - --- ---- ------- -
.- ,.

Composite sample from each

PWSS07
Lime Sludge Pile #6 sludge pile to evaluate arsenic Arsenic
PWSS08 levels

I PWGW01 Lime Sludge Pile #1

Groundwater sample from sludge
pile to evaluate arsenic levels
Arsenic

FASS01 through Fuel Residues In Fire Determine if contamination is voes, PAHs, TRPH,

I Fort Myers Fire

Academy
FASS16
-------------
FAGW01 through
FAGW09
Training Areas
----- --------------
Fuel Residues In Fire
Training Areas
present from former training RCRA Metals
practices--------------------------------------
Determine if contamination is
present from former training
voes, PAHs, TRPH,
RCRA Metals

I -- - --------------- practices _ _ _ _ _ _ - -- _ _ -- -- --- - -- ----- --- -----

Waste Oil, Solvent,
ESSS01 through Determine if business practices voes, PAHs. TRPH,
Fuel Releases From
ESSS03 have affected environment. RCRA Metals
City of Fort Myers Repair Areas

I Small Engine
Shop
ESGW01
Waste Oil, Solvent,
Fuel Releases From
Determine if business practices
have affected environment. Also
serves as downgradient wells for
Fire Training Area and Engine
VOCs, PAHs, TRPH,
RCRA Metals
Repair Areas

I East Gun Range

(City of Fort Myers
EGRSS01 through
EGRSS07
Lead Slugs From Gun
Range
Repair Shop
Characterize contaminants in soil
and berm to evaluate remediation
Lead, Copper,
Antimony, Arsenic
alternatives
Firing Range)
Determine if contaminants in soil
EGRGW01, Lead Slugs From Gun and berms are leaching to Lead, Copper,
EGRGW02 Range Antimony, Arsenic
groundwater... . _ . _ _ ----------- _ .._ _ _
Characterize contaminants in soil
WGRSS01 through Lead Slugs From Gun Lead, Copper,

II West Gun Range

(Lee County
Sheriff
WGRSS08 Range
and berm to evaluate remediation
alternatives.
Determine if contaminants in soil
Antimony, Arsenic

Department) and berms have leached to VOCs, PAHs, TRPH,

I WGRGW01,
WGRGW02
Lead Slugs From Gun
Range
groundwater. Also served as
downgradient wells for Fire
Training Area and Engine Repair
RCRA Metals,
Antimony, Copper
-
-hP... .. .... --- ---..-- ------ - _ ..........------- ---- ---- ---------------..
I Jerry Schuetz
Nursery
SNSS01 through
SNSS03
Pesticide Residues In
Mix/Rinse Area,
Chemical Storage and
Characterize Past And Currently
Used Pesticides/Herbicides
Pesticides, Herbicides
Container Plant Fields
.. -- . -
111'1 SNGW01,
Pesticide Residues In
Characterize Past And Currently
111/ SNGW02 Mix/Rinse Area and Used Pesticides/Herbicides Pesticides, Herbicides
Fort Myers Wellfield Site
Chemical Storage Tab-1 Prepared by _
Fort Myers, Lee County, Florida
Mar-05 Checked by _
I

I Table 1
Summary of Recognized Environmental Conditions Onsite

I Continued Targeted Brownfield Assessment Report

Fort Myers Wellfield Site
Fort Myers, Lee County, Florida

I Site/Facility . Sample lD
Recognized
Environmental
Conditions
Rationale Sample Parameters

Verify proper VOCs, PAHs, TRPH;

I Site-Wide

-- - ---
---
FMGWEB

- -------- --
decontamination of
groundwater sample
... equipment _
Groundwater sample equipment
rinsate blank
... -... - _ __ _
RCRA Metals,
Antimony, Copper,
_ _ _> -ti_C:<!_!H ic( ----
Verify proper VOCs, PAHs, TRPH,

I Site-Wide

Fort Myers Fire

FMSSEB decontamination of
soil sample
e91Jip_men!
__
Soil sample equipment rinsate
blank
RCRA Metals,
Antimony, Copper,
.. _ _ Pesticides, Herbicides, _
Fuel Residues In Fire voes, PAHs, TRPH, .
FASS17 Duplicate soil sample

I Ade_lllX.
Fort Myers.Fire
Academy _ __ FASS18
Training Areas
Fuel Residues In Fire
..Tra nin Area_ _
Duplicate soil sample
RCRA Metals
voes, PAHs, TRPH,
RCRA Metals
Jerry Schuetz Pesticide Residues In

I Nursery

East Gun Range

SNSS04

EGRSS08
--
Mix/Rinse Area and
elTlic:al Sor:aJf:
Lead Slugs From Gun
...
Duplicate soil sample
_
Duplicate soil sample
_ _ _ - ._
Pesticides, Herbicides

Lead, Copper,
_ _

---------- ----- -- - - _ _ ___ Rn!1 - - - - - - -- -- - 11til1lOt1! e11!c:_ __

I West Gun Range

__
Fort Myers Fire
WGRSS09
_ _ .. .....Range_ ._
FAGW 10
_
Lead Slugs From Gun

Fuel Residues In Fire

----- _
Duplicate soil sample
__ .
Duplicate groundwater sample
_ _ -- _
Lead, Copper,
Antimony, Arsenic
voes, PAHs, TRPH,
_

_Aca J_ _ _ ------ ---- -- _ _ _ _ _ Training Areas _ _ _ _ -- ---- -- ----- .... --- _ --- _Mfl J_s _ _

I Jerry Schuetz
Nursery SNGW03
Pesticide Residues In
Mix/Rinse Area and
Chemical Storage
Duplicate groundwater sample Pesticides, Herbicides

Notes: See Figures.4, 5 and 6 for sample locations

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Fort Myers Wellfield Site Tab-2 Prepared by _

Fort Myers, Lee County, Florida
Mar-05 Checked by _

City of Fort Myers Well field Site: Draft of Continued Targeted Brownfields Assessment Report.

Conclusions and recommendations:

City of Palms Wellfield (PW) Soil Sample (SS):

a.) Six sludge piles identified. Soil samples collected -PWSSOl through PWSS14.
b.) Arsenic concentrations with in each of the soil/sludge piles exceeds the SCTL for residential
and industrial exposure.

SCTL-Soils Cleanup Target Level. Arsenic: Direct Exposure Residential 0.8 mg/kg and
Commercial/Industrial 3.7 mg/kg.

City of Fort Myers Fire Academy (FA) Soil Sample (SS):

a.) Two of three burn areas, petroleum compounds benzo(a)pyrene and TRPH exceed the SCTL
residential exposure and leachability criteria (TRPH only).

SCTLBenzo(a)pyrene: residential 0.1 mg/kg, Commercial/Industrial 0.5 mg/kg

SCTL TRPHresidential 340mg/kg, Commercial/fudustrial 2500 mg/kg
SCTL TRPH leachability: 340mg/kg (TRPHs: Total Recoverable Petroleum Hydrocarbons)

b.) Arsenic concentrations exceed STCL exposure at soil sample locations FASS02, FASS06,
FASS14, FASS15 & FASS16.
c.) Petroleum-related soil contamination appears to be localized in the vicinity of soil samples
FASS04 and FASS03 in the area of the southern end of the former burn area,
d.) While arsenic soil contamination appears to be localized in the vicinity of soil samples FASS02
and FASS 06, in central and northern portions of the former burn area.
e.) In the vicinity of the current burn area, petroleum and arsenic soil contamination appears to be
localized in the vicinity of soil samples FASS.15 and FASS14 (including FASS16 for arsenic
contamination) at the northern end of current burn area.

A source removal for these areas can be addressed in a RAP-Remedial Action Plan

City of Fort Myers Small Engine Shop (ES) Soil Sample (SS):

a.) TRPH compounds were found to exceed the SCTL residential exposure and leachability criteria
at soil sample location ESSS02.
b.) ESSSOl and ESSS03 were collected close proximity to soil sample ESSS02 did not exhibit
TRPH cmpds indicating that soil contamination is localized to a small area.
c.) Additionally, arsenic was detected in all three soil samples at this location at concentrations
that exceed the SCTL residential exposure (ESSSOl, ESSS03) or industrial exposure (ESSS02).
d.) Chromium also exceeded the SCTL leachability criteria at ESSS02.

SCTL (leachability GW) Chromium-hexavalent -38mg/kg

A small localized source removal may be addressed in a RAP-Remedial Action Plan

1
West Gun Range (WGR) Soil Sample (SS):

a.) Metal concentrations were found to exceed the SCTLS (either residential exposure or
leachability criteria).
b.) Soil samples collected from the east-west trending (WGRSS08) and north-south trending
(WGRSS02 earthen berms contained metal concentrations above the SCTLs, as did several of
the soil samples collected on the western side of the shooting range including WGRSS04,
WGRSS05 & WGRSS07.
c.) Metal contamination likely attributable to the shell casings scattered over the ground and the
lead slugs scattered along the base of, and within, the berm.

East Gun Range (EGR) Soil Sample (SS):

a.) Metal concentrations were found to exceed the SCTLs in several soil sample locations
including at the short range shooting pad (ERGSS03), at the base of the earthen berm
(EGRSS04) and within the berm (ERGSS06).
b.) Metal contamination likely attributable to the shell casings scattered over the ground and the
lead slugs scattered along the base of, and within, the berm.

It is recommended that the RAP-Remedial Action Plan, evaluate the most feasible alternative to
address the contaminated soil and earthen berms at both of the gun range sites.

Jerry Schuetz Nursery (SN) Soil Sample (SS):

a.) Target analytes (o,p pesticides and chlorinated herbicides) were not present in the soil samples
at concentrations exceeding detection limits in the soil samples collected in the vicinity of Jerry
Schuetz Nursery.
b.) Operations present and past have not adversely affected the soil. No further action is
recommended for this location.

Groundwater Sampling:

City of Palm Wellfield (PW) Groundwater (GW):

a.) PWGWOl installed through a sludge pile in the City of Palms wellfield, arsenic was not present
at a concentration that exceeded the GCTL Arsenic: Primary Standard 0.05 mg/L
b.) Arsenic noted in the soils does not appear to have migrated/leached into the ground water.

It is recommended that arsenic analysis be added to the parameters that are currently being monitored
during scheduled sampling events conducted at the locations of existing monitoring wells with in the
well field.

City of Fort Myers Fire Academy (FA) Groundwater (GW) :

a.) Based on analytical results of the ground water samples collected from the fire academy area,
arsenic, benzene and chlorinated compounds vinyl chloride and 1,1-dichloroethene were found
to exceed GCTLs locally in three separate areas.

2

Arsenic: Primary Standard 0.05 mg/L (MCL) - Maximum Contaminant Level

Benzene: Primary Standard 0.001 mg/L, Vinyl Chloride: Primary Standard 0.001 mg/L, 1,1-
dichloroethene (1,1 dichloroethylene): Primary Standard 0.007 mg/L

b.) FAGW02 located in center of former bum area contained concentrations of arsenic and vinyl
chloride above GCTL.
c.) North of former bum area, FAGW09 contained benzene at a concentration above the GCTL.
d.) FAGW06 located in an open field west of the main fire academy training area, contained vinyl
chloride and 1,1-dichloroethene at concentrations above their respective GCTLs. -Ground
water clean up target levels.

It is recommended that the RAP-Remedial Action Plan be developed to assess natural attenuation and
other remedial alternatives of contaminants detected in ground water samples collected from micro
wells in this area.

City of Fort Myers Small Engine Shop (ES) Groundwater (GW):

a.) Samples from existing micro-well ESGWOl did not contain analytes (VOCs, PAHs, TRPHs
and RCRA Metals) above applicable GCTLs.
b.) Past & present operations have not affected ground water.

West Gun Range (WGR) Groundwater (GW):

a.) Samples from WGRGWOl and WGRGW02 did not contain concentrations of target analytes
(antimony, arsenic, copper and lead) above applicable GCTLs.
b.) Lead slugs and casings noted in area have not adversely affected the ground water.

East Gun Range (EGR) Groundwater (GW):

a.) Samples taken from EGRGWOl and EGRGW02 did not contain did not contain concentrations
of target analytes (antimony, arsenic, copper and lead) above applicable GCTLs.
'b.) Lead slugs and casings noted in area have not adversely affected the ground water.

Jerry Schuetz Nursery (SN) Groundwater (GW):

a.) Samples from existing micro-well SNGW02 did not contain concentrations of target analytes
(o,p pesticides and chlorinated herbicides) above applicable GCTLs.
b.) Past & present operations have not affected ground water.