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DEP alleges Wellfield Park groundwater is tainted with heavy metals and other toxic contaminants
State agency accuses city of stalling, not monitoring properly, allowing tampering of monitoring wells and making unsupported accusations aimed at the DEP
-- letter from Michael Gonsalves of the DEP, dated 06/06/03
-- discovered by Venice Florida! dot com on 01/16/04, posted to the web on 01/17/04

Got a comment? Make it here.

EDITOR'S NOTE: Wellfield Park in Venice is a sports complex park that is home to Little League baseball, football and soccer. Every youngster involved in sports in Venice spends considerable time at the park.

This letter, which was discovered by Venice Florida! dot com almost by accident, is nothing short of a shocker. It finally gives us publishable confirmation of much of what Venice Florida! dot com has been hearing recently about toxicity problems with groundwater at the sports park.

The letter below refers to other reports and letters that we have not yet seen, but that we will hopefully be able to acquire and publish in the near future. The DEP requested a response back from the city within 30 days (see the final paragraph). The city's response finally came on January 14, 2004, some seven months after the date of this document.

 

DATE: June 26, 2003

FROM: Michael A. Gonsalves, P.G.
Professional Geologist II
Waste Cleanup Section Supervisor
Florida Department of Environmental Protection
Southwest District
3804 Coconut Palm Drive
Tampa, Florida 33619
 

TO: L.A. Heath, Jr., Director
Public Works Department
City of Venice
401 West Venice Avenue
Venice, Florida 34285

RE: Environmental Site Assessment & Groundwater Monitoring Report
Wellfield Park Landfill, Venice, Sarasota County

Dear Mr. Heath:

The Department has received and reviewed the above correspondence, dated January 17, 2003 and prepared by GFA International. The Department is disheartened by the continued lack of cooperation and use of unsupported accusations against its consultants related to this site. With the passage of "Global Risk Based Corrective Action (RBCA)," the issue of contamination could be dealt with easily if the following information is clarified or provided. Without this information, site closure cannot be reached.

Based on the information submitted, the Department has comments and concerns related to this submittal. These comments are as follows:

1.) In Section 1.0 "Introduction & Report Overview" (page 5), please note that the Department indicated to you in the meeting at the District office on October 6, 2000 that the Department would not seek cost recovery for the work performed at state expense from the City "if" a groundwater monitoring plan was submitted and a monitoring only plan implemented after approval. To date, the approved monitoring plan has not been implemented.

2.) Also in this section, the Department notes numerous reports from on site personnel who indicated that the wells have, and continue to be, accessed by individuals not employed or under contract to the Department.

3.) Also in this section, based on the results of the split sampling, the Department does not concur with the definition of the contamination as "random". It is also of interest to note that the most downgradient wells had the highest detections, again placing into doubt the contention that the results are "random." The analytical results were previously faxed to your consultant on January 17, 2003. It does not appear that this report discusses or includes the results of the Departments sampling.

4.) In Section 3.1 "PSI Sampling of Micro Wells" (page 8), the Department takes exception to the reference to PSI's use of "landfill" as "arbitrary." Please note that the determination of this site being a landfill was supported by the soil boring information, on site employee testimonials, and additional information gathered during the assessment, and not simply a review of aerial photographs.

5.) Also in this section, the discussion of the fact that the Departments lab did not conduct "microbial analysis" does not appear to be relevant to our attempt to resolve this case. The information provided in this report does not appear to reveal any correlation between the microbial community and metals results in the on site micro wells and the Department does not believe that the data offers any explanation of the metals contamination. It also does not appear that microbial sampling was conducted by the City during the sampling event at which the Department was present. Please clarify.

6.) In Section 3.2 "PSI Results & Conclusions" (page 8), it should be pointed out that PSI MW-9 was destroyed by the City during site regrading activities, so the results of the PSI sampling event do not appear to have been verified by this report. It may be beneficial to reinstall a well at this location for verification.

7.) In this same section on page 9, please provide some clarification to the accusation that PSI "compromised the sampling effort" with its use of microwell technology.

8.) It must be repeated that the neither the Department nor PSI left any of the wells at this site without watertight well caps, as the accusation suggests. It is apparent that another party or parties accessed the wells on City property on a regular basis without the knowledge or consent of the Department.

9.) In Section 3.4 "GFA Results & Conclusions" (page 10), please note that contrary to the statement in this section, the Department did not "deny" the request for abandonment of all wells, but instead indicated that the City had the option to replace the wells in question as part of the monitoring plan proposal. The City's proposal was to abandon all wells, which was not deemed appropriate due to the contaminant concentrations detected. The request to field filter the groundwater samples was denied due to the fact that the requirements for demonstration that field filtering was appropriate had not been met. A description of the requirements for filtering of groundwater samples is again attached.

10.) In Section 5.2 "City of Venice Police Department- R.V. Waymire Training Center" (page 12) that a potential source of lead contamination may be the City's firing range. The Department did not previously investigate this area as part of this assessment, nor were groundwater samples collected at this location at the request of the City. This area may require further investigation as a potential source area.

11.) In Section 6.1 "New Monitoring Well Drilling, Construction & OVA Soil Screening" (page 14), please note that the "Groundwater Monitoring Plan Approval" letter, dated September 17, 2002, stated that the "depth and construction of these new wells must coincide with the construction design of the assessment wells completed by the Department. Please provide information related to completion depths, screened intervals, etc. for the new wells so as to allow meaningful comparison of resulting data. Please clarify construction methods for these new wells.

12.) In Section 7.1 "Existing Micro-Well and Three New Shallow Monitoring Wells" (page 16), please provide, on a scaled site map, the location and aerial* extent of the "leafy vegetation" landfill area. Please provide all documentation to support the contention that this location has never been used for dumping of other items. Please provide documentation of either approval or closure of this vegetative debris area.

13.) In Section 7.2 "Micro-Well MW-6 Meterbox Skirt Metallurgical Testing & Ballfield Clay" (page 16), it is noted that a second sampling event occurred on December 5, 2002. Please provide a discussion of why the Department was not notified of this second sampling event in order to collect split samples as requested.

14.) In Section 8.2 "Micro-Well MW-6 Meterbox `Skirt' Metallurgy & Bulk Material Testing" (page 20), the theory that the manganese exceedences were the result of impacts from water contacting the metal skirt and draining into the well appear to be unsupported by the documentation provided. While it appears that manganese (1.08% by volume) is a constituent of the skirt material, no leachability tests or documentation that would demonstrate a relationship between the minor content of these metals and the resulting groundwater contamination has been provided. It is also noted that the results of the skirt sampling presented in Appendix L appear to be "semiquantitative," yet no discussion of what that designation implies is made. Please provide clarification of the term "semi-quantitative."

15.) Also in this section, the theory that the wells have been impacted by "red clay" and "marble dust" used during site upgrades does not appear to be supported. The relatively low concentrations do not appear to be a threat to groundwater, and it does not appear that leachability testing by the SPLP method was conducted to determine the actual impact of these materials on surficial groundwater at this site. The Department recommends that the "red clay" and the "marble dust" be sampled and analyzed for the constituents of concern using the SPLP method to determine potential leachability.

16.) In Section 8.5 "Permeability of Clay Aquitard Separating Shallow Aquifer and PZ-1" (page 21), please provide the results of the Shelby-tubes collected for analysis. Please also indicate how it was determined that the clay is laterally continuous across the site. It would appear that the term "aquitard" indicates that contaminant migration will occur across this boundary.

17.) In Section 9.0 "Conclusions" (page 22), Item #8, the Department does not agree that the groundwater data does not show any "significant threat(s)" to human health or the environment. There has been no determination of potential receptors, impacts to surface water bodies or indication that a restriction on water removal from this property has been completed.

18.) Also in that section, Item #9, the Department disagrees that this report is "adequate to refute the previous conclusions provided by PSI." The information provided alleges that there are questions about the validity of the sampling results and the conclusions drawn by PSI, but the new sampling information does not appear to support these allegations.

19.) In Item #11, the Department concurs that additional evaluation of the "shallow groundwater" may not be necessary as indicated in previous correspondence. This, however, does NOT release the City from the responsibility of performing the approved monitoring plan.

Based on the information provided and the above comments, the Department again requests that you implement the approved groundwater monitoring. The overall site contamination issues do not indicate widespread or serious contamination concerns and it appears that the contamination remains on site. The Department does not believe that there is a need for active remediation for this site, which was why the Monitoring Plan was approved. With the passage of "global RBCA," the Department has been given authority to implement "risk based corrective actions" on sites outside the Brownfields, Drycleaner and Petroleum programs. As such, new options become available for this site. The Department believes that the issue of groundwater contamination from the metals noted can be dealt with through various means including deed restrictions to prevent groundwater removal, alternative groundwater concentrations for secondary standard metals, and monitoring for metals listed as Primary Groundwater standards. Without the requested monitoring data, the Department has insufficient information to determine the best course of action for this site. Please provide a response to the above comments with the next sampling event data or within 30 days of receipt of this letter. Please provide a schedule of sampling events with that submittal. Should you have any questions, please contact me at (813) 744-6100, ext. 376.

[signature]
Michael A. Gonsalves, P.G.
Professional Geologist II
Waste Cleanup Section Supervisor

cc: Dave Phillips, SIS
John Ryan, Sarasota County Pollution Control
G. N. Hunt, City Manager
Terry Lawrence, P.G. GFA International
Kirk White, FDEP OGC

*Editor's note: the asterisked word in section 12 appears in the document as "areal," we are assuming here that Gonsalves meant "aerial."