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Venice on the web
A semi-regular column

City to DEP on Wellfield Park letter: Everything's fine, stop worrying
City responds seven months later to DEP's letter that demanded a response within 30 days; city insists DEP has it all wrong, everything is hunky-dory at the Little League youth sports complex park
-- letter from Larry Heath, Director of Public Works
-- posted to the web on 01/18/03
-- lheath@ci.venice.fl.us

Got a comment? Make it here.

Related:
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 June 26, 2003
 

DATE:  01/14/04

TO: Mr. Michael A. Gonsalves, P.G.
Professional Geologist II
Waste Cleanup Section
Division of Waste Management
Florida Department of Environmental Protection
3804 Coconut Palm Drive
Tampa, FL 33619

FROM: L.A. Heath, Jr.
Director of Public Works
City of Venice, Florida
401 W. Venice Avenue
Venice, FL 34285

RE: Wellfield Park Environmental Site Assessment and
Ground Water Monitoring Report

Dear Mr. Gonsalves:

Per your request based on your correspondence of June 26, 2003, the comments and concerns you outlined have not been provided to your office. Most likely some of the nineteen (19) items outlined have been resolved, however, this response will address them numerically as listed in the letter.

1.) An approved monitoring plan has been implemented and other possible onsite sources of concern have been investigated by our environmental consultants at the direction of the City.

2.) The City is not aware of any individuals accessing DEP wells for any reason other than authorized purposes. It is our understanding that all of the City's consultants have advised DEP by phone and/or written notice of their intent to sample any well on the subject site. We believe, the initial wells did not have any security devices to prevent unauthorized access or tampering from the initial installations in 1995.

3.) Alliance Consulting and Environmental Services, Inc (ACES) has indicated that they did not include the FDEP lab test results because they were similar to their own analysis and results.

4.) The comment made in Section 3.1 regarding the terminology of "landfill" and/or "arbitrary" were comments based on the PSI report dated August 1995. Also, issues outlined in Section 3.2, we have had differences of opinion regarding this property, however, the City's position has been that we are not aware of any authorized landfill activity. As a result of investigations from the FDEP landfill theory, we have concluded that unauthorized dumping of domestic waste may have occurred at the site.

5.) ACES indicates microbial activity (both aerobic-with oxygen present, and anaerobicno oxygen present) can cause chemical changes in the water column. For example: iron bacteria are rather common in steel cased water wells if they are not flushed and disinfected periodically.

6.) PSIMW-9 was not destroyed by the City, possibly by County activities since they maintain the site. However, since well #9 could not be located, ACES installed MW11 near its former location based on the site map provided by PSI. MW-11 showed magnesium and vanadium levels initially of metal concern, then just magnesium in subsequent sampling events.

7.) The phrase "compromised the sampling efforts" simply clarified our opinion due to the lack of a watertight cap with confirmed visual and photo evidence of infiltration of rusty rainwater into the Micro-well casing which makes the water quality results suspect.

8.) We understand that DEP has repeatedly indicated that the site had water tight caps and a third party has assessed the wells on a continuous basis without knowledge or consent of the DEP. However, as indicated numerous times in the past, based on three (3) professional environmental companies over the past several years have indicated the same responses that disagree with FDEP position. Employees from Gerhardt M. Witt & Associates, Inc., GFA International and Alliance Consulting & Environmental Services, Inc. have observed leaky PVC Micro-Well caps and/or plugs with golf-tees and duct tape. By your own acknowledgement, these are FDEP wells installed on City of Venice property. The City of Venice, from the very beginning committed to work and assists DEP and PSI and had no objections to the wells being installed on City property to assist in your data research. How these wells were installed and secured, we have no knowledge. Who has accessed or vandalized them, we have no knowledge either. However, it is clearly in both parties' interest to resolve this matter.

9.) I believe this issue has been resolved since additional wells have been installed and sampled three (3) times.

10.) The City of Venice Police Department-R.V. Waymire Training Center had a well installed and is addressed in the third quarterly report dated Dec. 1, 2003.

11.) The well construction details were described in section 6.1 of the report. Copies of the Well Completion Permit records are included in Appendix H and Figure 3. The Micro-wells were installed to depths of 10-12 feet below grade. The new 2-inch monitoring wells were screened from 2-12 feet below grade and gravel packed with clean 6/20 silica quartz sand.

12.) Attached for reference is a copy of the PSI site map as requested to identify the "leaky vegetation" [sic] area. You requested support documentation, but I can only provide you with historical knowledge due to my employment with the City of Venice since 1973. I'm aware the Parks operation used the Wellfield Park to excavate for topsoil and fill material, and then filled the excavated hole with tree trimming vegetation. My recollection of the area is identified on the PSI drawing #3 that indicates former landfill in area labeled soccer field and grass field. I'm not aware of any activity south of the fire training area indicated as another landfill area.

13.) The sampling event was conducted to test raw water from the two (2) onsite deep irrigation wells used for watering the sports fields and several offsite irrigation wells located on the adjacent Capri Isle gold course for comparison of metals concentrations. These wells were not the FDEP well on site. We requested ACES to perform additional well sampling tests to identify other source investigation information. ACES located well CPMW-#3 and sampled to identify groundwater quality conditions in the shallow water table at the northeastern portion of the subject site. Results from this well showed only vanadium concentrations above standards in Nov. 2002. However, no vanadium was reported from this well in the Oct. 21, 2003 sample event.

14.) ACES indicates that microbial bacterial have been documented as in technical literature and reports transporting metals into water supplies. Leachability tests will not accurately reflect the introduction of storm water runoff, rusting, corrosion, and transport process occurring over several years inside the meter box.

15.) ACES have indicated that the presence of trace metals in the two (2) ponds is indication that storm water runoff carries the metals horizontally across the field. Approximately, 10-20% of the rainfall can be considered as direct infiltration in to the shallow water table. Surface ponding of this runoff prior to infiltration and direct introduction via Micro-wells could explain the "random" pattern of metals concentration.

16.) The Shelby-tube clay test results are contained in Appendix M of the Jan. 17, 2003 report.

17.) We still maintain that current ground water data does not show any significant threat(s) to human health or the environment. No shallow water is pumped from the 126+ acre subject site. The two (2) onsite irrigation wells are screened below 150 feet in the PZ-3 Strata. The Jan. 17, 2003 report addresses the historical contributions to the decline of the water quality in the shallow zone from past flowing agricultural wells throughout the area.

18.) The new water quality data supports our contention of surface runoff of dissolved total metals distributed in the shallow water table.

19.) As approved by FDEP, the City has responded and performed an approved monitoring plan. The last report submitted to FDEP was Dec. 1,2003 and was titled Monitoring Well Installation and Third Quarterly Ground Water Monitoring Report.

In summation, I believe we are current in providing FDEP with answers to previous requests and have performed an approved groundwater-monitoring plan. The recommendations in the last report outline re-sampling to provide data for a fourth sampling event in the first part of 2004. Even though we have differing opinions regarding this project, I honestly believe we are mutually gaining supporting data and knowledge to allow the project site to reach closure.

If I can be of any further assistance please advise.

 

[signature]
L.A. Heath, Jr.,
Director of Public Works

cc: George Hunt, City Manager
Lori Stelzer, City Clerk
Martin Black, Deputy City Manager
Jane O'Connor, Assistant to City Manager
Terry Lawrence, PG - Alliance Consulting and Environmental Services, Inc.

 

 


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