21 December 1998 File No. 10063-071 Ms. Patricia Donahue
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UNDERGROUND ENGINEERfNG & ENVIRONMENTAL SOLUTIONS Haley & Aldrich, Inc. 465 Medford Street Suite 2200 Boston, MA 02129-1400 Tel: 617.886.7400 21 December 1998 Fax: 617.886.7600 File No. 10063-071 Email: [email protected] LDIC Ms. Patricia Donahue Department of Environmental Protection 205A Lowell Street Wilmington, Massachusetts 01887 Subject: Notice of Placement of Report in Public Repositories and of Upcoming Subsurface Exploration Program W.R. Grace & Co.-Conn. 62 Whittemore Avenue Cambridge, Massachusetts RTN 3-0277 Dear Ms. Donahue: This letter is to inform you of the placement of a report entitled "Supplemental Petroleum in Soil Evaluation, W.R. Grace & Co.-Conn.," dated 15 December 1998, in five public repositories in accordance with the Public Involvement Plan (PIP) prepared for this site. The report presents the results of a subsurface soil sampling and analysis program. This evaluation supplements previous evaluations of the presence of petroleum products in the soils at the property conducted by Haley & Aldrich, Inc (H&A). The supplemental work performed by H&A was completed in August 1995. OFFICES Cleveland At the time of 1995 subsurface investigation, Department of Environmental Protection (DEP) 0/rio regulations required use of the total petroleum hydrocarbon (TPH) analytical method in Denver evaluating spills and releases of petroleum fuels on sites in Massachusetts. Since this program Colorado was completed, the DEP recently established two new, more accurate, methods of Hartford determining the compounds of petroleum present in groundwater and soil. The new analytical Connecticut methods, for Extractable Petroleum Hydrocarbons (EPH) and Volatile Petroleum Los Angeles Hydrocarbons (VPH), break down the aliphatic and aromatic fractions of TPH. The DEP California developed and promulgated new soil and groundwater cleanup standards for the aliphatic and Manchester aromatic fractions, that became effective on 31 October 1997. Final test protocols to New Hampshire determine EPH and VPH were released in January 1998 with an informal provision to be Newark effective in April 1998. New Jersey Portland In light of the promulgation of the new analytical methods for testing for petroleum in soil, Maine Grace is undertaking a subsurface soil evaluation in the general areas of Massachusetts Rochester Contingency Plan Upper Concentration Limit exceedences determined through the 1995 New York program. Approximately 25 borings will be completed on the property, and soil samples will San Diego California San Francisco California Washington Districtof Columbia P,,,,,do, r'c- pp Department of Environmental Protection 21 December 1998 Page 2 be collected and analyzed using the EPH/VPH methods. The work is scheduled to be completed at the Grace site on 4-5 January 1999. Final copies of the report presenting the results of the EPH/VPH evaluation will be placed in the public repositories for review. It is expected the report will be available in late Spring 1999. Sincerely yours, HALEY & ALDRICH, INC. Amy B. Church Environmental Geologist :/F:\1O063\7I \REPOSLET.WPF MICHAEL F. NAKAGAWA 51 MadIson Avenue Cambridge MA 02140 May 11, 1999 Patricia M. Donahue Re: W. R. Grace & Co. - Conn. Chief, Compliance Branch 62 Whittemore Avenue Bureau of Waste Site Cleanup Cambridge, MA Commonwealth of Massachusetts RTNs 3-00277 & 3-17-104 f Executive Office of Environmental Affairs Department of Environmental Protection Dear Ms. Donahue, This letter is in regard to the documents: Scope of Work, Phase II Comprehensive Site Assess- ment (SOW) and Report on Evaluation for Asbestos in Soil, both produced by Haley and Aldrich, Inc., for W. R. Grace & Co.-Conn. in relation to the asbestos contamination on their Cambridge site. I am writing you directly this time, with a copy to Haley and Aldrich, since you were kind enough to at least reply to the issues I raised in my letter to Mr. Wesley Stimson of Haley and Aldrich last October, regarding the proposed asbestos sampling plan. These comments are pursu- ant to the Public Involvement Plan (PIP) established for this site under the Massachusetts Contin- gency Plan (MCP; 310 CMR 40) established by the Massachusetts Department of Environmental Protection (DEP). It seems that my fears are proving correct, in that as ambitious as their sampling plan appeared, it was only sufficient to minimally characterize the site, and that they would try to claim that the apparently large number of samples were sufficient for a full characterization of the extent of the contamination, when in fact, few statistically significant conclusions can be drawn because of the plan they chtse, as I had cautioned in the letter. In my previous correspondence, I had suggested randomized sampling not because I felt it would be better at identifying contaminated regions, but because it could allow some statistidally defen- sible conclusions in the case that some of the assumptions of the program later proved incorrect, as they have. With the sampling plan undertaken, the only conclusion that can be statistically defended is that asbestos exists at various locations throughout the site. There are significant deficiencies in their testing implementation that further call into question the ability to draw conclusions from the test results, as I will address in this correspondence. Then, since the characterization of the site is deficient, I will explain my concerns regarding the "Air- borne Asbestos Management and Monitoring Plan" which is proposed, and suggest an increase in the Phase II Scope of Work in order to obtain a reasonable comprehensive site assessment, before remediation plans should even be considered. Furthermore, in the Final Asbestos Sampling Plan (FASP, by Haley and Aldrich, dated Nov. 1998), it is stated that "the sampling methodology outlined in this program is not designed to determine if concentrated areas of asbestos are present at the site, but rather to provide the data necessary to evaluate current risk of exposure to surficial soils at the site." Since the plan met its MICHAEL F. NAKAGAW "secondary purpose" by determining that "large or small amounts of asbestos containing soil will be encountered when intrusive activities for the construction of the proposed property develop- ment are undertaken," there now needs to be a directed program to determine all locations and extent of concentrated amounts of soil on the site. Before discussing the reports and plans, I want to set the context of my concern, which is that the nature of asbestos dictates strict caution. It has a different mode of carcinogenesis than most chemical carcinogenic contaminants, such as the polycyclic aromatic hydrocarbons. What differs is that once asbestos lodges in the lungs, there is no mechanism for its removal, and it remains in the body as an irritant throughout life. The latest understanding is that cause of the mutation that starts a tumor is not the asbestos itself. Rather, by causing increased DNA replication for cell repair or replacement (resulting from the irritation), the volume of copying increases the likelihood of either encountering a spontaneous error or being in a vulnerable state of replicition when another mutagen is present. Children are partic'ularly vulnerable to exposure since they are already in a heightened state of cellular devel- opment, their sizes are smaller (so the exposure level to body mass ratio is higher), and they have a longer lifespan with the irritant increasing their vulnerability to transcriptional errors. Therefore, even a short exposure to asbestos has life-long consequences, contrasted with many chemicals which can be cleared from the body after the exposure source is removed, thereby lim- iting the carcinogenic effect. Furthermore, since asbestos is inert, any particles released will remain in the vicinity without degradation. In the case of the Grace site, an escape of asbestos may contaminate the adjacent ball fields and neighborhoods and will not evaporate into the atmo- sphere over time as other chemical contaminants may. Given this context, it is imperative that asbestos must be prevented from inadvertently escaping the site, otherwise it can plague the neighborhood long after the remediation workers have left. By the nature of its effects, there is some question as to whether there is an actual safe threshold level. However, at the very minimum, ey precaution should be taken to ensure that the exist- ing guidelines for safe exposure levels are not inadvertently exceeded. The Evaluatin Report presents the percentage of the December 1998 samples which contained visible levels of asbestos as reported by Haley and Aldrich. However, most locations had both surficial and subsurface samples, so the percentage of samples does not represent the percentage of locations containing asbestos which would be exposed during construction activities. Further- more, Haley and Aldrich did not include, in the percentage, samples with visible asbestos as reported by the laboratory used by both the City of Cambridge and Alewife Neighbors, Inc. The additional 12 sites, when added to the other 33 sites, would bring the total to 45 hits out of 351 sites, or 12.8%. This report also left out the previous (May 1998) results, which would bring the total to 55 hits in 365 sites, that is, 15.1% of tested sites contained asbestos in visible quanti- ties. With regard to the Evaluation Report, I have the following key concerns which I will explain later in detail: " The grid sampling has inconsistencies in the sample locations, such as large regions where no samples were taken. * The "directed systematic sampling in areas where past activity may increase the likelihood Page 2 UNDERGROUND 0. .. Oggys ENGINEERING & ENVIRONMENTAL SOLUTIONS ;1- - Haley & Aldrich, Inc. 465 Medford Street Suite 2200 Boston, MA 02129-1400 Tel: 617.886.7400 Fax: 617.886.7600 HALEY & 9 February 1998 Email: [email protected] ALDRICH., File No. 10063-066 Ms. Karen Stromberg Department of Environmental Protection Northeast Regional Office 10 Commerce Way Woburn, MA 01801 Subject: Notice of Placement of Work Plan in Public Repository W.R.