21 December 1998 File No. 10063-071 Ms. Patricia Donahue

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 pursuant 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 development 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 development, 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 existing 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 quantities. 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. Grace Site RTN 3-0277 Cambridge, Massachusetts

Dear Ms. Stromberg:

This is to inform you that W.R. Grace is proposing to undertake a subsurface exploration and testing program to characterize soil for the possible presence of asbestos at the W.R. Grace site. In accordance with the Public Involvement Plan (PIP) prepared for this site, copies of the Sampling Plan for this work, dated 12 January 1998, will be available at the public repositories listed on the attached Information Sheet on 10 February 1998. As outlined in the PIP, W.R. Grace welcomes public review and comments on the proposed work. Comments OFFICES may be provided to the Haley & Aldrich representative indicated on the attached Information Cleveland Sheet until 3 March 1998. Oio Denver If you no longer wish to be informed of the various activities at this site outlined in the PIP, Colorado please contact us and we will remove your name from the contact list. Hartford Connecticut Sincerely urs, Los Angeles HALEY LDRICH, INC. California Manchester New Hampshire Newark 4 e .timpson,2y LSP New Jersey Senior Vice President Portland Maine F:10063\066\MERGE.WPF Rochester New York San Diego California San Francisco California

Washington District of Columbia

Pnnedon recyclrd paper INFORMATION SHEET n) 10 February 1998 06 Public Information Repositories Department of Environmental Protection Northeast Regional Office 10 Comerce Way Woburn, Massachusetts 01801

Contact: Ms. Holly Migliacci Telephone: (617) 935-2160 File Review Hours: Monday through Friday, 9:00 a.m. to 12:00 p.m.

Cambridge Main Library 494 Broadway Cambridge, Massachusetts 02138

Telephone: (617) 3494044 File Review Hours: Monday through Friday, 9:00 a.m. to 9:00 p.m. Saturday, 9:00 a.m. to 5:00 p.m. Sunday, 1:00 p.m. to 5:00 p.m.

North Cambridge Library 60 Rindge Avenue Cambridge, Massachusetts 02138

Telephone: (617) 349-4023 File Review Hours: Monday, Tuesday and Thursday, 8:30 a.m. to 8:00 p.m. Wednesday and Friday, 8:30 a.m. to 5:30 p.m.

W.R. Grace & Co. -Conn. 62 Whittemore Avenue Cambridge, Massachusetts 02140

Contact: Robert Sorrentino Telephone: (617) 498-4983 File Review Hours: 9:00 a.m. to 4:00 p.m.

City of Cambridge Community Development Dept. 57 Inman Street Cambridge, Massachusetts 02139

Contact: John Buldoc Telephone: Telephone: (617) 349-4628 File Review Hours: 9:00 a.m. to 4:00 p.m.

Contact Changes: New W.R. Grace Contact: New Haley & Aldrich Contact, Address and Phone Numbers: Robert Sorrentino Amy Church W.R. Grace & Co.-Conn. Haley & Aldrich, Inc. 62 Whittemore Avenue 465 Medford Street, Suite 220 Cambridge, Massachusetts 02140 Boston, Massachusetts 02129-1400

Telephone: (617) 4984983 Telephone: (617) 886-7394 Fax: (617) 886-7694

No November 20, 1997

David B. Struhs Commissioner Commonwealth of Massachusetts Executive Office of Environmental Affairs Department of Environmental Protection Metropolitan Boston - Northeast Regional Office

Dear Commissioner Struhs:

It has come to the attention of members of the North Cambridge community that the history of chemical processing and production by W.R. Grace at the 62 Whittemore Avenue facility provided by Haley and Aldrich for their client W.R. Grace (RTN #3-0277) in their Environmental Data Report is substantially incomplete. It is clear from historical records that extensive manufacture of asbestos friction products occurred at this facility, but nowhere in any data assessment submitted by W.R. Grace to the DEP, including their multi-volume EnvironmentalData Report completed in 1988 and the LSP's 1995 Compliance History Summary, is there any mention of such activity and no field testing for asbestos has ever been done. The purpose of this letter is to request that the Phase II of this site be re-opened and that additional and extensive soil sampling and analysis for asbestos be conducted at the Whittemore Avenue site.

Asbestos friction products were manufactured at the 62 Whittemore Avenue facility under ownership and operation by Dewey and Almy

Documentation attached to this communication establishes that asbestos friction products were manufactured at the Whittemore Ave. facility at least from 1929 through 1936. This time corresponds to the period during which Dewey and Almy (acquired by W.R. Grace in 1954) purchased and operated the Multibestos Plant at Walpole, Massachusetts (see document #1: Moody's Index - 1929-1936).

The Walpole site (known formally as the Blackburn and Union Privileges Superfund Site - Cerclis # MAD 9082191363) is on the National Priorities List (NPL) and is completely fenced and secured to prevent any public access due primarily to substantial asbestos contamination. During the period 1929 - 1936 and beyond, both the Walpole facility and the facility at 62 Whittemore Ave. Cambridge, were the subject of special attention by the Department of Labor and Industries Division of Occupation Hygiene (see communication # 2) due to a high incidence of asbestosis complaints resulting in both awards of workman's compensation claims and related legal actions (see communications # 2A and #3).

Ownership and operation of the Multibestos Corp. by Dewey and Almy, (purchased in 1954 by W.R. Grace), is further demonstrated by verifying statements from both Charles Alm)' (then Vice President of Dewey and Almy), and Bradley Dewey (President) in the Harvard Class of 1908 Twenty-fifth Anniversary Report (see documentation #4).

Specific asbestos friction products manufactured

Hervey Elkins (Harvard Class of 1928) then a recent graduate of the Harvard School of Public Health and eventually Director of the Division of Occupational Hygiene, under the supervision of his predecessor, Manfred Bowditch, described his visit to the Whittemore Avenue facility and made the following observation:

"Certain brake linings, especially those for heavy work, are made from asbestos to which carbon black and other substances may be added. and rubber latex. The various materials are mixed in a paper beating machine, spread on a wire screen and the water sucked out, then pressed in a hydraulic press, cured and brought to the proper thickness with a sanding machine." (see page three 'Notes on visit to Dewey & Aliny Chemical Co., on November 27, 1934 and December 11, 1934 and to Multibestos Company, Walpole, on November 28, 1934" ; document # 2). File documentation included with this letter reflects that the Walpole Multibestos facility did in fact supply or at least partially supply the Cambridge facility with raw asbestos. On page 6 of the Workman's Compensation Report to the Industrial Accident Board filed by John Lightbody in 1933, the following description is given:

"When he left the weave room on June 26, 1925, he went to work on the truck immediately. At times witness would be in contact with asbestos dust for a half a day - that would be when he would bag it up and bring it to Cambridge." (see document 2A page 6)

Additionally, it appears that the Cambridge plant may also have manufactured clutch facings as the AR dope (coal tar pitch in toluol) used to impregnate the clutch facings was produced there. The manufacturing stage is described by Dr. Elkins as the process which produces the highest level of Asbestos particulate. It should also be noted that the intensity of the manufacturing protocol at the Whittemore Avenue facility required that the processing equipment be purged on a regular basis. Older neighbors recollect that this phenomenon was so intrusive that it would require residents living nearby to shut their windows when the whistles blew to prevent dust from settling in their homes. In addition to the included information, verbal descriptions from neighbors confirm that manufacture of asbestos-based friction products was a substantial part of the Dewey & Almy operation at the Whittemore Avenue facility during the thirties.

Request for additional and extensive soil sampling and analysis for asbestos

Given the problems encountered at the Multibestos site in Walpole with respect to random and improper disposal of large volumes of asbestos waste product resulting in Superfund designation during the same period, we respectfully request that:

. additional and extensive soil sampling and analysis for asbestos be required immediately of the PRP; . the regulatory status and potential risks posed by the site be reevaluated; and . a fill and forthright accounting of this matter be provided.

The Principal Responsible Party is aware of at least some of these facts

There is evidence that the PRP is aware of at least some of these facts. In a deposition conducted on September 17, 1996 (see document # 5), Bradley Dewey Jr., son of Bradley Dewey, president and co-founder of the Dewey and Almy Company, acknowledged that "everything that had been Dewey and Almy was moved into W.R. Grace ... the entire company, all the facilities, all the records, all the property of whatever nature" (p.58). In that same deposition, Dewey Jr. admits that he "knew that Dewey and Almy had been in the brake lining business" and that "brake linings included asbestos" (p.24 and 27). In the same deposition (p.26), Dewey Jr. identifies photographs of the Dewey and Almy facility at 62 Whittemore Avenue with a fleet of Multibestos Motorized Brake Service Institute vans in the parking lot of the facility.

Additional evidence was provided by Susan M. Cooke, of the law firm Goodwin, Proctor, and Hoar, representing W.R. Grace and Co. Ms. Cooke submitted substantial comments during the public comment period for August 22 to September 21, 1994 regarding the preliminary public health assessment for the Walpole site. Knowledge of the Multibestos and Whittemore Avenue operation (manufacture of asbestos friction products) had to have been common company knowledge for the previous three years if not for the previous sixty years.

Required disclosure by the Licensed Site Professional

There is a comprehensive body of case law regarding when a party knew or should have known of environmental violations. There is also a significant body of law describing how knowledge held by individual members of a corporation can be imputed to the organization itself when applying the "knew or should have known" standard. The actions and statements by W.R. Grace and /or predecessors or agents clearly meet this standard, leaving no doubt that this PRP knew or should have known of the potential for asbestos contamination and had an affirmative duty to act accordingly. It is our understanding that the Licensed Site Professional (LSP) assigned to the Whittemore Avenue site is required to disclose all pertinent facts regarding these circumstances. The Rule of Professional Conduct, 309 CMR Section 4.03 (5) (c) state that:

"a licensed site professional shall make a good faith and reasonable effort to identify and obtain the relevant and material facts, data, reports and other information evidencing conditions at a site that his or her client possesses or that is otherwise readily available, and identify and obtain such additional data and other information as he or she deems necessary to discharge his or her professional obligations under M.G.L. 21A # 19 through 191, and 309 CMR."

Requested action by W.R. Grace

If laypersons concerned about the past practices at this site can access this information with relative ease, it seems only fair that the PRP be required to provide the abutting public a fuller and more candid description of the manufacturing operation in their environmental assessment.

Given the significant data gaps created by the PRP's not having analyzed the site for asbestos contamination, we respectfully request that W.R. Grace through their LSP provide a full accounting for this apparent omission and implement a plan for appropriate field-testing for asbestos. If there is any way that this neighborhood can be of further assistance in this matter, please let us know. Representatives of the Alewife Study Group will call you within ten days to two weeks of your receipt of this letter to discuss these issues.

Submitted on behalf of the Alewife Study Group,

Craig A. Kelley, Esq. David H. Bass, Sc.D., CHMM Joseph J. Joph 6 St. Gerard Terrace 23 Norris St. 20 Columbus Ave. Cambridge, MA 02140 Cambridge, MA 02140 Cambridge, MA 02140 (617) 354 - 8353 (617) 354 - 2797 (617) 354 - 3295

cc: Cambridge City Council John DeVillars, U.S. EPA Karen Stromberg, DEP David Wightman, W.R. Grace Co. Wesley Stimson, LSP State Senator Warren Tolman State Representative Alice Wolf State Senator Robert Havern U. S. Senator Edward M. Kennedy U. S. Senator John Kerry U. S. Representative Joseph P. Kennedy 06

With respect to the 62 Whittemore Avenue W.R. Grace site (RTN #3-0277). we the undersigned support the attached request to Commissioner Struhs. and respectfully request his immediate attention. Specifically, we urge the Commissioner to:

1.) require the PRP to provide a fuller and more forthright accounting of asbestos usage and manufacture at the site: 2.) require additional and extensive soil sampling and analysis for asbestos; 3.) and reevaluate the regulatory status and potential risks posed by the site.

Thank you for your attention to this matter.

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S M-&A46Cscie /pS V Eastern Oi- and acquired oil and Ice i ootnote reatl developed Properties). S5' '23, 1922, as Oklahoma plus from appraisal prating delcit of 3356,233. - gasoline properties of Oklahoma . Wal Gas Co. On Feb. Accounts certined iWaskins & Sells. 14, 1925, merged Devonian Oil Co., incorporated in Delaware Capitol Stock: 1. Devoninn Oil Co. stock'. Autho - June 3, 1920, and assumed that company's name and charter. $3,500.000; outstanding. $3,218,050; in treasury, $69,350; ar Dividends paid per share: 1925, 20 cents; 1926, 40 cents; S Producers of crude oil and gasoline. 1, 1930, when 15 cents was paid, and nae, As of Dec. 31, 1934, the company was interested in Okla- thereafter to Apr. terly thereafter to Oct. 1, 1930. incl. Subsequent divid.n Pur- homa. Kansas, Texas and New Mexico and had undeveloped from Per leases representing .5.399 acres. owns 2 gasoline plants lo- share as follows: Jan. 2, 1231, 10.15 ($0,08746 cated at Kellyville and Chickasha, Okla., with total capacity and $0.06254 from earnings): the following from capital: Juit; Of 40,000,000 cu. ft. of natural gas. (Gas 20, 1932, $0.10, Oct. 2, 1932, $0.15, Jan. 20, 1933, 40.25. pr2 plant at Chickasha. and July 20. 1933, $0.15. Oct. 20, 1933, $0.1578947 ($.i Okla., was not operating in April, 1934). Three producing Jan. 20 and Apr n leases in the East Texas field were sold In 1934. Number of capital and $0.04486 from earnings); employees Jan. 1, 1935, 54. $0.25 each from earnings; June 11, 1934, $5.00 54 capital and $1.60 from earnings); July 20 and Oc MANAGEMENT: OFFICERS: J. H. Evans, Pres.; A. W. $0.25 each from earnings; Jan. 21 and Apr. 20, i: Leonard, Vice-Pres. and Gen. Mgr.; L. C. Ritts, Vice-Pres. Transfer Agent: Colonial Trust Co.. Pittsburgh, P. and Treas.; Geo. D. Foster, Sec., Tulsa, Okla.; H. R. Dean, trar: Peoples-Pittsburgh Trust Co.. Pittsburgh. Pa. L Pittsburgh Stock Exchange. Number of stockholdr Asst. Sec. and Asst. Treas.; W. E. Lofton, Asst. Treas., 1. 1935, 1.911. Tulsa, Okla. DIRECTORS; J. H. Evans, A. W. Leonard, Price Range : 1934 1933 1932 1931 1 Geo. D. Foster, L. C. Ritts, Tulsa, Okla.; H. Heasley, H. J. Stock...... 18-9 10-7 9-I 2-4 14 ;4-3% Crawford, Emlenton, Pa.; J. V. Ritts, T. W. Phillips, Jr., DEWEY & ALMY CHEMICAL CO.: Incorporated under Butler, Pa.; J. P. Flynn, Sistersville, W. Va. ANNUAL Massachusetts laws in 1919. MEETING: Fourth Tuesday in March. OFFICE: 618 Na- Controls the Multibestos Co., Mass. (a sales compan . tional Bank of Tulsa Bldg. (P. 0. Box 1379), Tulsa, Okla. ganized in 1934): Multibestos Co. (a Texas Corp.): L'.w. & Almy Chemical Co. of Canada, Ltd.; Dewey & Anjf. Lu PnoDcrtoN STATIsTics. YEARS EoNDED DEC. 31 (Eng.); Dewey 1 1931 & Almy Chemical Co. (Ill.), and 'Nv polo t1934 1933 1932 Factories. Inc. (formerly Multibestos Co., Walpole, Mass., it. Oil (bbls.) 1,213,564 1,488,064 1,170,702 930,028 (uired in May. 1930). Practically all assets of the hl'tter liasoline (gal.).. 978,652 315,855 77,589 1,046,368 other than land and buildings. were purchased in 1234 by Natural gas (M Dewey & Almy Chemical Co. (Mass.), a division of which cu. ft.) ...... 5,930 72,670 313,780 now carries out many of the manufacturing operations for.' t In 1934 wells were mostly under proration. merly conducted by the old Multibestos Co. Manufactures sealing compositions for tin cans, machines COMPARATIVE INCOME ACCOUNT, YEARS ENDED DIM 31 for applying and drying sealing compositions, soldering fluxes, 1934 1933 1932 labeling adhesives, shoe soles and heels. soda lime, brake Gross income ...... 1,257.078 $948,171 $1,163,024 linings, brake blocks and clutch facings, sold under the tradil Operating expenses 182,764 287,833 421.404 names Dewalco, Gold Seal, Darex and Multibestos, Plants in5i Gen. & admin. expenses . 113,501 95695 8,879 the United States located at Cambridge and Walpole, Mas;,t Operating profit ...... 960.813 2564,643 1655,744 and Oakland. Calif. Subsidiaries' plants located at Naplest' Profit sale producing prop. 1,147.82 Italy; Farnham. P. Q., Canada. During 1933 the company sold Other income credits .36,149 5,971 its entire 45.5% interest in Dartex, A.G., Frankfurt a.-M. Gross Income ...... 2,144.34 1564,643 1661.715 Germany. Federal income tax . 211,225 8...... Management: Officers: Bradley Dewey. Pres.; Charles Other charges ...... 57,37 Almy. Jr., Vice-Pres. and Clerk: H. S. Ferguson. Sec. and. Balance ...... 1,875,736 1546,904 8661,715 Treas., Cambridge, Mass. Directors: Bradley Dewey. Charles Depreciation ...... 143.734 202,32 209,283 Almy. Jr.. S. H. Lawton, Cambridge. Mass.: Merrill Griswold, Depletion ...... 137,072 135,028 103,779 A. L. Putnam. Boston, Mass.; H. S. Ferguson. C. 11. Egan, Und. leasehold chgs.. etc.. 124,320 ...... Belmont. Mass.; P. L,. Reed. Chicago; A. Besse, New York: Net income ...... 1,470,610 219,544 348.653 F. G. Allen. 0. K. Anderson, Richmond Mayo-Smith, J. A, Dividends ...... 1.930.830 150556 164,400 Lunn. Annual Meeting: Third Tuesday In February. nflilce;j North Cambridge, Mass. Surplus for year . . .. (d)$460.220 $88,958 '$184,253 CONSOLIDATED INCoME ACCoUNT, TEAR ENDED DEC. 31, 2934, Earned per share...... $4.57 $0.67 $1.06 (Dewey & Almy Chemical Co. and subsidiaries) Number of shares...... 321,805 f378,800 328,000 (For prior years, see below) Before crediting $152,88 surplus2 adjustment on account of Sales ...... $3,393,202 Net profit ...... 236,189( drilling charges for 1931. which has been capitalized. Costs & expenses 2,08,334 Prior pref. divs.. 151.106 t Includes reacqui red stock. Depreciation . 164,800 * After taxer- .nd undeveloped leasehold expenses, etc. (in 1934, Operating prod, 320.068 before such charges). Margin of profit. 9.43 Surpl. for yr. $85,030 0Deducted above (See t). Other income ... 44.880 Earned per share IAfter undeveloped leasehold expenses. etc. (1934. b~efore such Total income . .. 364,948 prior preference ;27.3 charges). Sundry charges , 66,587 Earned per share Surpluso Accolut, year ended Dec. 31. 1934: Deficit, Dec. 31. Net income ..... 298.361 ptd. & cl.A pfd. 1933, $356,238 (Note: The 1933 annual report gave surplus at Fed. & State tax. 61,400 Earned per share Dec. 31, 1933 as a credit of $219,946). Credit: Development Minority Interest. 772 cm. & cl. A cm. 1.- costs applicable to recoverable oil and gas reserves (previously written off) restored, $205,375: gross operating deficit, CoNSoUDATED INCOME ACCOUNT. YEARs ENDED Dc. 31 3150,868. Debits: Deficit for year (per above). $460,220: ex- (Dewey d Almy Chemical Co. and subsidiaries) ..211,... .225 22 (For later, see above) penses applicable to prior year, $21.514: depreciation appticable, 1933 1932 1931. to prior years (resulting from change to per barrel basis of- Net profit before deprec.. $345,725 $7,869 (d)$2918 computing depreciation of equipment on producing propertes, Depreciation ...... 169,910 162,427 144,29 334,020: total debits. $515,754: deficit, Dec. 31. 1934, $66,6el6. Operating profit ...... 175,816 (d)154,558 (d) 436,1 Note: A change in accounting was made during 1932' in Loss from sale of Dartex, 1 connection with drilling costs, which are now..charged to in- A. G...... 62.327 ..--- vestment and amortized over a period of years. instead of being charged direct to operaIng costs, Net profit for year .. $113,488 (d)$154,558 (d)$436.1 CO.UXRnItaVE BALANCE Snxxr. AS OF DEC. 31 CONSoLIDATED BALANCE SHEET, As or DEC. 31 Assets:1 194 1932 (.pewey & Almy Chemical Co. and subsidiaries) 'Developed propeltles ...... t$4.416,820 $2,376,5M4 Assets: 1934 193 Undevel. leaseholds and fee lands .. . 351,976- t239;234 *Fixed assets ...... $1,312,416 $1,448,51 Materials...... 25,211 26,491 Formulae . and processes ...... 60,000 60,00 Cash ...... 49,700 544999 Cash...... 60,178 97,00 Accounlts receivable...... oz,139 146,948 Notes & acceptances receivable .... 14,819 16 Notes receivasble...... 1,800 130,300 Accounts receivable (net) ... ,..... Z48,435 Investments ...... 7.925 49,115 Life insurance, cash value ...... 50,466 SN'otes receivable...... 204,880 .... ItRaw material and supplies ...... 312,814 -37 Deferred Items ...... 1.224 $$Work in process A ,fnIshed goods 509,163 4 Reacquired stock...... 4,3 Prepayments ...... 11.522 Total ...... $2,579,862 ,5 Total...... $5,484,675 $3.561,26a $ Liabilities: 5175 Liabilities: tPrior preference stock ...... $617,562 $67 Capital stock...... $3,218,050 $3,288,000 2,063,700 Accounts payable..71,,20 4.7,284 Preferred & class A preferred stock tCommon & class A common stock. 189,730 189.79 Federal income tax ...... 1... . 2. Deferred credits...... '26,517 618 Total ...... 2.870,991 Surplus ...... ff,957,762 :1219,946 Less: Treasury stock ...... 100,426 Balance ...... 2,770,565 - Total...... $5,484,675 $,6,8 Less: Defiit ...... 485,8264... 9 69I Current assets...... $501,850 $852,08 Balance ...... $2,214,739 ' Currrent liabilities ...... 282,345 47,234 IMinority Interest ...... 1,337 0 - Working. capital...... 219,505 805,698 Funded debt ...... - Less depletion and depreciation: 1934, 33022,368 : 1933. $3.- Funded debt ...... 2,000 Accounts payable ...... 71,906 393,.071. -,Consists of: t Leaseholds: Cost, $2,411.541 ; apprecia- Notes payable ...... 50,000 tion (see footnote ft relative to surplus). '$2,624,379 : equipment, Dividends pauable ...... 30,230 $2,048,521: total leaseholds4 $7,084,441 ; gasoline plants, $293,194 Federal and State tax reserve .... 61,400 warehouse. automobiles, etc., $61,553 -total, $7.439.188 ;less, de- Accrued accounts ...... 73f33 4 preciation and depletion , 33.022,368 : balance (as above). $4,416.- Reserve for container 820. 1 At cost. I Employees. ff Due from officer: collateralized redemption . 5,018 6 by stocks with market quotations of $257,613 and equities in Deferred credits ...... stocks Pledged with others, *' Discount on treasury stock pur- Total ...... $2,579,862 $2,83,7 plooD1s "937 - riotes on visit to Dewey & Almy Chemical Company, Cambridge, on November 27, 1934 and December 11, 1934 and to the Multibeatoa W J 2ol on No'veter 28 , 1934.

By: H. B. Ilkins

Officials met:

. m (chief chemist) Mr. MMordie (engineer) . Ferguson (plant manager) Mr. Bateson (superintendent, Multibestes) Mr. Leach Mr. Siagle Mr. Edwards Mr. Martin Mr. Boss Mr. Mears Mr. Tensen Mr. Stowe Mr. Taggart

The more important contacts are underlined.

Note: Due to the nature of its business many of the processes of this company are unique. Jtems which it is believed may not be general practice are marked with an asterisk-and should be treated as confidential until passed upon by an official of the company.

The Deny and Almy Chemical Company manufactures primarily latex cements and allied products, such as solvent rubber cements, rubberized fabrics, and rubber b&nded brake linings. It was because of their developments in this last field that they acquired the Multibestos Company, which manufactures brake linirgs and clutch facings of all types.

Dewey and Almy Company

Mr. Egan showed me about the plant in Cambridge.

Latex cements: Rubber latex is obtained in solutions containing 35, 60 or 75 per cent solids. In the dilute solutions there to about three fourths of a per cent of ammonia, which keeps the solution at a pH of 11, and so prevents fermentation and spoilage. In the most concentrated solutions the alkalinity is maintained by a mixture of caustic potash and a potasaium cocoanut oil soap. Ammonia is preferable for most purposes because it evaporates off. Its concentration is so low that it is no problem except when the cement or compound is used in very large quantities.

*Various materials such as pigments and fillers are added to the latex solution in making the compound. One such material is a modifying soap made from beeswax and ammonia under high pressure. Sulfur is added whenever it is desirable and possible to cure the rubber in the cement or other product. In the linings for tin cans sulfur can not be used but fortunately an uncured material i. more satisfactory.

ror many purposes a latex cement is inferior to an artificial rubber emulsion, made by masticating vigorously coagulated rubber and then dispersing it with protective colloids. and other suitable chemicals. A cement of this type seemed much finer and more homogeneous than corresponding latex cements, and its cost was said to be the same. 2.

Latex cements are of interest to us because they compete with solvent rubber cements. One of the chief uses oftbenzol in as a solvent for the latter. For some purposes non-toxic non- ilflmble-. latex cements are better substitut es for toxie,'_hlamuable benzol cements than the slightly toxic but iufiamable naptha eements.

Mr. Ferguson said that there had been a swing away from latex sealing compounds toward solvent compounds, but that he felt that its peak had passed and the immediate future would sea an increased use of the latex products.

Solvent room: This company makes both benzol and naphtha solvent cements and compounds. The latter constitute about two thirds of the total, and it was said that probably next year three quarters of the solvent compounds would be made from naphtha. The so-called solvent room is the second floor of an isolated building. It Is about 35' x 12' x 8', and contains two mixers, for nlaphtha and benzol products, respectively. Each mixer holds about a hundred gallons.

Exposure to the solvent may occur chiefly in three places; the pump room, the solvent room, and muddler room, in which the finished cement is loaded into drums for shipment. In the pump room there is same leakage of vapor, or seamed to be, but the pumps are operated from outside, and the roa is rarely entered. In filling the drums there is undoubtedly same exposure, but the greatest hazard is certainly in the solvent room.

The solvent is ordinarily pumped through a meter into the mixer. The stirrers are heavy spiral shaped knives which twist and tear the mall pieces of rubber which are introduced. Some heat is evolved in this oprtation, so that the temperature of the mixture is raised, the outside of the mixer being above body temperature when the process was observed. The miixers are closed except for an opening in the top about 18" x 10" which Is covered loosely except when meterials ere being added, when, the batch is being inspected, and when it is being emptied, The addition of rubber (cut in small pieces) takes some time, 6s the several layers are torn apart by hand or they are fed into the machine. Some other materials, such as wax, are usually added. In the operation observed inspections of the batch as it was being mixed were trequant. As the top of the .mixer is about five feet from the floor the tendency is for the workman to put his face close to the opening in lookiig in at the batch.

After two to eight hours, depending chiefly on the kind of rubber used, the mixer is tipped on its side and the batch of finished produ: t is dumped through an opening in the floor into the muddler. The dumping operation observed took four minutes, including the time required to rake out the residual compound. The opening in the mixer through which the substance is poured is about three feet from the floor, and the operator stands three to four feet away except when he is cleaning out the residue. The extremely viscous and elastie tf was said to contain only thirty per cent of solids. Its vapor pressure would presumably be appreciably more than 70 per cent of that of pure benzol, but the viscosity of the mixture should out down its rate of evapora- tion considerably. . 3.

A blower was operating in the well opposite the mixer, near the floor, and above it the window was opened. The operator was between the window and the mixer, but a little to one side most of the time. The efficiency of this system of ventilation seems somewhat questionable. Tests on the air in this roca (made by the insurace company) showed satisfactory conditions, however, it was said. The men working on this job are Eiven blood counts every three months and as a rule are transferred after six to nine months. No real cases of benzol poisoning have been encountered.

A dope: This impregnating material is a mixture of about five parts coal tar pitch and one part toluol. The components are heated in mixing, and ventilating equipment has been ordered for the process. The fumes did not seem bad at the time a finished batch was observed in the open mixer.

*Rubber bonded brake lining material: Certain brake linings, especially those for heavy work, are made fron asbestos to which carbon black and other substances may be added, and rubber latex. The various materials are mixed in a paper beating machine, spread on a wire screen and the water sucked out, then pressed in a hydraulic press, cured and brought to the proper thickness with a sanding machine. The last operation is well ventilated, but the method of feeding the paper beeter wea said to be dusty and needs improvement. Probably some such method as was worked out at Walpole will be applied here. None of these proceases were in operation.

*Artifical leather: A soft absorbent paper is passed through a latex solution contalning sulfur, coloring matter, etc., and then over a series of heated rolls where the water and aemonia are given off end the rubber is cured. An exhaust system provides for the removal of the amonia given off (estimated at three pounds, or about sixty cubic foet, per hour).

It is necessary to stop the machine for brief periods in order to attach new rolls of paper. If the stop is for too lonW the paper in contact with the hot rolls tends to disintegrate. Even the short stops unavoidably made may cause variations in quality in the finished material.

The rubberized sheet is passed through a calender to bring it to the proper thickness. Two or more sheets are often cemented together, sometimes two or three rolls being ccmbined on a machine similar to the impregnzting machine, but smaller. No provision for the removal of emonia is made in this case, but there was no appreciable odor of smania around the machine.

If still thicker sheets are to be made, pieces about five feet square are cemented together by hand. In the operation observed a naphtha solvent cement was used.

Other produts: Soda lime, used in gas masks for absorbing phoagene, chlorine and acid gases, is made in some quantity. Zinc chloride solutions and zinc a-muonium, chloride crystals are also made. Soea dermatitis has been caused by these materials. Chloroform and toluene are used as preservatives. Carbon tetrachloride is also used for sc purposes. Apparently these are used in relatively mall amounta. Another mall use of benzol is in eleaning out drum. The tultIbestos Company

Mr. MNMordie, who designed a large part of the ventilating equipment used at the plant, showed me about.

There have been naerous cases of asbestosis developed here, and as a result the methods of manufacture have been greatly modified. The carding process has been dropped, the yen being bought already spun, end a wet weave sub- stituted for a dry weave process. Mr. Bateson said that more oases of asbestosis were developed in the weave room where the dust count was about seven and a half- million particles per cubic foot, than in the carding rotm, where the dust count was much higher. The most recent counts ran from half a million to two million, except at a carboloy saw, where it was 6.7 million, and at the paper beater during its feeding (31 million). A new procese has been developed for feeding the paper beate2 the use of the carboloy saw is discouraged pending its removal, and the general ventilation has been greatly improved since these counts were made.

Woven fabrics are used chiefly for brake linings, but for some clutch facings as well. Moat of the latter and some brake linings, especially for he6vy brakes, are moulded, or made originally as an asbestos paper. For impregnating materials asphalt, chinawood oil, and bakelite resins are used. Rubber bonded linings are not im;rognated; the rubber bending is done in Cambridge, but all cutting, shaping and finishing is done in Walpole.

leave room: The yarn consists of cotton and asbestos fibre wound around a small wire. The warp is dry as it leaves the spools but passes over a wet roll before going through the guide.: so that the dust given off by the vigorous agitation of the dry warp in the weaving process is largely eliminated, since the yam is wet at this stage. The spindles of weaving yarn are soaked in water before use. The loem spools of dry yarn are shaken somewhat but undoubtedly by far the largest port of the potential dust in prevented from coming off.

*On sae of the loms a process of impregnating the yarn as it is woven is being tried. The roll wet with water is replaced with one wet with impregnating solution, in most cases asphalt in kerosene. This is suuposed to give a more thorough impregnation and eliminates a process. It has the disadvantage of dirtying up the loom, however, and the fumes of the solution contaminate the air of the weave room. A solution of resin was also being applied in this way: they hare succeeded in eliminating toluol from the solvent for these mixtures. On one section of a loom a water emulsion of a resin impregnant was being tried, it being both non-toxic and non-inflamable.

The fumnes of kerosene near the looms using the asphaltic impregnant were somewhat obnoxious.

Impregnating room: The method still used for most of the woven linings is that of impregnating the fabric after it is woven. A long strip is run through a bath of solution, before and after which are placed drying ovens. Conditions in this room seemed satisfactory. 6.

Grinding room: Here the clutch facings and brake linings are ground down to the proper siZe, the required holes are drilled, etc., and in this room the most strenuous efforts in ventilation have been made. The removal of visible dust seemed almost perfect in the case of all the grinding operations observed. The chief source of dust seemed to lie in the handling of piles of articles in loading or unloading a machine. In some cases ventilation was even provided for these operations.

One of the men operating an inside grinder (for the inside of clutch facings) wore a respirator, however.

Clutch department: In the process of making moulded brake linings and epecially olutch facings, asbestos is fed into a paper beating machine, where it is mixed with water, piennts, fillers and a little red lead, which helps the impregnant to harden. From here it is pumped to the paper machine where a layer of the mixture is spread continuously on an endless belt, the water drained off, and the resulting sheet of asbestos paper is removed, pressed, and out up.

Formerly the act of feeding asbestos into this machine was very dusty. Now the bags of asbestos are emptied into a chute (in an enclosed room on the second floor) and the water for the mixture is sprayed in simultaneously, wetting down the asbestos so that it is soaked with water when it enters the beater, and little or no dust is given off. The man handling the bags of asbestos wears a respirator, the operation taking but a few minutes. The room where this wee done seemed surprisingly free from visible dust.

This seamed to me a very satisfactory, cmon sense and economical solution of this particular problem.

Twenty pounds of red lead are sprinkled with a hand scoop into each batch mixed up in the paper beater. This is heavier than many lead compounds and none of it seemd to be dissipated in the form of dust. I understood the workman to say that the maximum output of the machine was five batches a day.

Clutch impregnating room: Most of the clutch facings are impregnated with AR dope, a solution of a coal tar pitch in toluol, which is made in the Cambridge plant. A rack about 4' x 5' x 6' is filled with clutch facings and then submerged in one of the tanks of dope, of which t2nre are three or four in a room about 28' x 12' x 8'. The solution is kept at 60 degrees F. or higher, and the tanks are covered except when the solution or solvent is being added, when the rack of clutch facings is being introduced, and when the clutch facings have just been removed and the excess solution in allowed to drain back into the tanks.

There is no ventilation in this room and the fumes are said to be bad at times. The foreman said he wouldn't enter the place on a damp dey, and that the men often got jags from the fumes. One of the men said he was often made dizzy by the toluol vapor, and that he and his colleague suffered con- siderable discomfort generally. A 7.

It seemed to me that unless these men were exagerating greatly the conditions should by all means be improved. A determination of the toluol concentration in the air might be worth while. Two or three window blowers, to be operated when the tanks were open, might improve the situAtion suffi- aisutly for practical purposes.

While the insurance company was seid to have investigated these conditions and to be satisfied, and while it is true that toluol is not as in- sidious a poison as benzol, or asbestos dust, and while there is Sam doubt about its ever causing chronic poisoning, it is still classified with benzol in Bulletin 582 of the U. S. Dept. of Labor. Certainly conditions such as apparently exist here shovid not be tolerated if they can be easily remedied.

Drums containing toluol were in some cases labelled as containing alcohol.

General: Mr. Lc~ordie said that some dermatitis was caused by the formaldehyde used with tar acid in the manufacture of bakelite resins.

Respirators were worn on many odd jobs, such as sweeping the floor, using the carboloy saw, etc.

In general the firm has been admirably thorough, ingenious, and, I believe, effective in the steps taken to eliminate dusty conditions. 20t & (4

Ms. Xe. 94241.

WOWM'B COMPEENATION ACT. Industrial Aeoident Beard Beaton, Nassahusetts.

John L. Lightbody yeployee Multibestos Company Employer Employars' Liability AsSuranee Corpqation, Ltd. Insurer Liberty Mutual Insurane Company Insurer iartford Aesident & Indemnity Company Insurer

WKPORT ON IMtR) C4 ZXDUTA[AL ACCIENT BOARD. (MR. CLARK) The Member of the 'tdustrial Accident Board, appointed under the provisions of 0. L., e. 152, em. 7 and 8, having heard the partios in the absve-nammd ULSE at ecten, Massachusetts, on Tuesday, June 24, 1934, reporta as fellewms

Appearamoeos Sverett Potter, Esq., for the Zaployers' Liability Assurance Corporation, Ltd. Stephen C. Sea, sq., for the Liberty Mtual Imnurasce CempaWy. Francts 0. Claffie, Esq., for the Hartford Aecideat & Indemnity cmpany. Leonard V. weufer, Faq., for the employee,

There is a ruportef Injury dated October 25, 1933 which states the date of the injury as "T? and states further that the employe left wark en October 5, 19331 that he was a truek driver sine 19251 that previously he was aswavert and that his average weekly wages were $23.19. There is no statement in regard to the cause of the injury. A claim for compensation was filed on February 9, 1934 giving the date of injury as, "not able to work sine Get. 3rd 1933"1 the place of the Injury as, "mill, South St., Ralpele, Maes."; the cause of the injury as, "ItAsling asbestos duet's and the mature of the injury as, "Dyapaa from lunge being filled with dust and lining the bronohieles. Vakneas resulting from same together with less of iight." Another claim for compensation ans filed on Varob 27, 1934 which gives the date of injury as, "May 1924"; the cause of the injury as, "inhalation of dust from working in or nearing asbestos products"; and the rature of the injury as, "shortness of breath and loss of weight, weakness, loss of appetite. fains in chest, cough.*

Q4YT108s (1) Whther or not the empleyes sustained an injury arising out of and in the course of his employents. and (a) which insurer is liable.

RKPURT 07 THE RVIIENCK. All the material evidence is reported herewith:- mask or respirator at aaj time during his worAwItnh4e au.b..ere., . that all the men had them,witness did not wear any, weri few won more tanm. aitness could not breaths with a respirator on him. He wore one when he was in the weave room. Asked if it kept out all the dust, witness answered, no "not that kind." Witness alo had to open up bags of cement in the freight ear to get samples for the laboratory. In .toin that work he would get dust on his hands and clothes. (At this point it was stated that the employee left the main weave room June 22,19;n) Asked to describe the condition of his health after he left the main weave roomawitness answeredbe left the weave room in the summer - June July - and went out on the truck, he seemed to pick up in weight and fee a little better but he was always short of wind - if he did any lifting, the last year he started to lose, for six mnths he eculd notice he wasn't so well, he was getting short of wind and losing flesh until he finally had to quit. When he was in the Peter Bent Brigham Hospital he weighed about 106 ponds. When he left the job in the main weave rose t seemed to pick up in weight. He never got all his weight back. Ha weight 136 pounde when be went to work. The must he ever weighed when he left the main weave room was 138 ponds. After he left that room be was always short of wind. From six months to a year before he stopped work he started to lose weight again and got shorter of wind. He gradually lost weigt. *He weighed about 103 pounds when be left work Oetober 3,19 After he developed the cough when working for the Multibestos Company ie was never without it. It would be worse in the morning when he got up He stop;ed work on October 3 because he felt he could not work any longs A day or to before that he had a small hemorrhage - bleeding from the throat. lie lost a half a sup of blood. As a result of that he felt prett nervous and kind of seared. Hs was getting weaker gradually. That laste over a perioa of six months er a year prior to October. on "Otober 3 Ie felt so weak that he couldn't do his work. He thinks it was en that day that he consulted lr. Fuller. He told Miss hooca a bookkeeper aad secretary at the plant, that he would -have to quit because he wis sick. Me has not done any work since October ad has been under the care of Pr. Yuller. He has rot felt able to work; he has not gained in strength; he does not feel a bit better. He doe not think he feels any worse. Asked if he feels about the samewitness answered, he has lost a little more weight. He weighs between 98 sad 99 pounds. From October 3 to now he has lost four or five pounds. During the last year ne worked i.e does not think his cough got any werse. Then he coughed he did not raise very much - once in a while a little. He did not oat very good and sometimes he did not sleep. During the last year he worked his appetite got worse. He did not have as much of a desire to eat during the last year or six montha. as he had five or six years ago. Asked if he slept as well nights during the last six months or year as he did prior to six years agowitaess answered, he does not know as there was a difference. Dr. Fuller had him x-rayed at the Norwood itopital. ~aitnoss has the x-ray pictures with him.

TO ThE COgSSIULHs When he left the weave room ca June 22,1928 he vent to work *n the truck immediately. At times witness would be in contact with asbestos dust for a half & day - that would be Then he wuuli bag it up and bring it to Cambriage.Other times he would n-vt be is. contact with it. There were some days when be was away from t7e plant and rot near asbestos duet. Asked hfl nany days there wore of that art in a period of a monthitness answered, lie cannot eeayvb might be called to Aoston one day aria he mightn't go out of ialpole for a weet. or sohe would be sent off it emergency caces,th~ere would be no set time ti go any place.Aased what the greatest number of hours a d .as since June ;k,19 6 when sitnesa was exposed tu asbestos duatswitnes unswerod, aix hours. That did not happen very often. It usually took three hours to uNload a car of asbestos. it took a half ax& hour at noon to empty tie uust collectors. They were emptied every day. It took ;rotiubly an hour a day a dumhp the refuse. It would taka probably all morning .aturday because the shop would be cleaned. Brake linirge were not swept Every asy. They were eaeptonce in a while. ..itness thi it in feir to say t"at he spent half Sf his time aroun; (ost. C UN AL E. t i. i.?LOsG. 'itness means aobestoa iauSt.

-6- 0

040067 F EI

SOUTH STREET ASBESTOS SITE Z'r71- WALPOLE, MA PRELIMINARY INVESTIGATION ... r NOVEMBER 17, 1986

-JA SITE BACKGROUND

The South Street Asbestos site is located in Walpole, Ma. where the Neponset River crosses South Street. The areas located to the east and west of South Street at the Neponset River junction are contaminated with asbestos waste products. Both areas are owned by the Shaffer Realty Corporation. The site has had industries located there since the early 1800's. The industries included the manufacturing of snuff, wrought iron, tanning products, clothing, cotton batting, and wicking products at various times within the 1800's. Around 1900, the Massachusetts Chemical Company, located there, produced rubber products. The Multiple Triple Woven Hose and Rubber Co. (later known as MULTIBESTOS) located there in 1915 and soon after began manufacturing brake linings containing asbestos. In the mid 1930's, MULTIBESTOS closed the facility due to a class action suit brought by employees suffering respiratory ailments. Since then, the properties have been occupied by Walpole Factories, Industrial Properties, General Fiber, and the Kendall Corporation who used the facility for a fabric manufacturing and bleaching process. In 1985, the Shaffer Realty Corporation bought the property and the facility has been vacant since then. In 11/12/80, the Massachusetts Department of Environmental Quality Engineering (MA DEQE) notified the Kendall Corp. that asbestos contamination was discovered on their property. The Kendall Corp. was ordered to cover up asbestos pile and on 12/9/80 received a letter from the MA DEQE stating compliance to that order. On 9/18/81, the Metropolitan District Commission (MDC), notified the MA DEQE of asbestos waste piles along the Neponset River at South Street observed while working on sewer lines in that area. In October of 1986 a Walpole citizen notified the MA DEQE that vast asbestos waste piles lined the banks of the Neponset River banks at South Street. The MA DEQE responded to the site and obtained samples confirming the presence of asbestos waste products and secured the area to prevent public access. The MA DEQE requested the United States Environmental Protection Agency (US EPA) assistance on October 12, 1986, and on 11/17/86 the US EPA Oil and Hazardous Material Section (OHM) performed a preliminary investigation.

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2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK 3 THE PORT AUTHORITY OF NEW YORK 4 and NEW JERSEY (formerly known as "The Port of New York Authority") 5 and PORT AUTHORITY TRANS-HUDSON CORPORATION, 6 Plaintiffs,

7 vs. No. 91 Civ.0310(CLB) (MDF)

ALLIED CORPORATION (individually and as a subsidiary of "Allied-Signal Inc.,), 9 et al., Defendants. 10

11 DEPOSITION OF: BRADLEY DEWEY, JR.

12 DATE: September 17, 1996

13 TIME: 2:35 p.m.

14 LOCATION: Hanover Inn Hanover, New Hampshire 15 TAKEN BY: Counsel for the Plaintiff 16 REPORTED BY: Cynthia Foster Benson, RMR 17 Testimony of Bradley Dewey Page 24 of 83

11 A Well, I knew that asbestos was commonly

12 used where you wanted resistance to heat.

13 If you wanted to insulate, have something

14 which wouldn't self-destruct with heat. I

15 knew what was in the published

16 literature. Certain risks were

17 well-known. But not, I say well-known,

18 suspected, I think in those days. Like

19 smoking was suspected.

20 Q Did you read any of the literature

21 concerning the health hazards of asbestos

22 when you came to the company?

23 A No.

24 Q Did you know when you came to the company

A. WILLIAM ROBERTS, JR., & ASSOCIATES

1 that Dewey and Almy had previously been

2 involved in the manufacturer of products

3 containing asbestos?

4 MR. MURPHY: Objection to the

5 form.

6 Q You can answer.

7 A I'm not sure. I knew that Dewey and Almy

8 had been in the brake lining business. I

9 think my education must have taught me

10 that brake linings included asbestos.

11 It's my impression that back in those days

12 they all did.

13 Q When you were a boy growing up did you Testimony of Bradley Dewey Page 26 of 83

1? do or not. The water tank looks like the

18 water tank that was over the plant at

19 Whittemore Avenue. The place these cars

20 are parked, I don't know. I can't figure

21 out where that could be in the plant. It

22 looks like it could be.

23 Q Can you make out the name on the water

24 tower as Dewey and Almy Chemical Company?

A. WILLIAM ROBERTS, JR., & ASSOCIATES

1 A Oh, yes, it's clear.

2 Q And parked in the front are the

3 Multibestos vans I guess, for want of a

4 better term?

5 A Sure looks that way. It's a used car lot.

6 Q The vans appear to have on the side panels

7 reading Multibestos Motorized Brake

8 Service Institute, as I can read. Does

9 that look like what it is to you?

10 A Yes.

11 Q The first document I showed you, the

12 interview with your father in March of 19,

13 in June of 1936, references a Multibestos

14 company which it says Dewey and Almy used

15 to own and the picture, Exhibit 2, shows a

16 fleet of Multibestos cars. Were you

17 familiar in 1940 with the term

18 Multibestos? Testimony of Bradley Dewey Page 27 of 83

19 A If you had thrown that word at me it

20 would have rung a bell. Is that what you

21 mean?

22 '2 Yes. Did your father during the time

23 before you came with Dewey and Almy, did

24 he discuss the company and the company's

A. WILLIAM ROBERTS, JR., & ASSOCIATES

work in your presence?

A Two questions.

Q Did he discuss the company in your

presence?

A Yes.

Q Did he discuss any of the work the company

was doing?

A No.

Q2 Did you have any idea of the products the

company was making?

A I knew they were making brake linings.

Q Did you know that-those brake linings

contained asbestos?

A No.

Q Did you know in 1940 anything about the

potential hazards of asbestos?

MR. MURPHY: Objection. Asked

and answered.

A I think you asked me this question

before. And I answered that as an

educated person I did. I suspected Testimony of Bradley Dewey Page 58 of 83

14 Q Do you know at all who may have supplied

15 asbestos to Dewey and Almy?

16 A No.

17 Q To your knowledge, when Dewey and Aimy was

18 merged into W.R. Grace, did everything

19 that had been Dewey and Almy move into

20 W.R. Grace, the entire company, all the

21 facilities, all the records, all the

22 property of whatever nature?

23 A As far as I know that's what happened.

24 Q And would that have included any

A. WILLIAM ROBERTS, JR., & ASSOCIATES

1 outstanding patents?

2 A Yes.

3 Q Would that have included any outstanding

4 license agreements?

5 A Yes. To my knowledge.

6 Q Right. I understand all of this is to

7 your knowledge.

8 When the merger occurred, did

9 most of the people who had been working

10 with Dewey and Almy stay in their

11 positions and simply become Grace

12 employees?

13 A Yes.

14 Q Did you ever work with a gentleman at

15 Grace called Rodney Vining?

16 A Rod Vining. Where was he. The answer is COMMONWEALTH OF MASSACI-JUSETTS EXECUTIVE OFFICE OF ENvIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION ONE WINTER STREET, BOSTON, MA 02108 617-292-5500

WILLIAM F. WELD TRUDY COXE Governor Secretary

ARGEO PAUL CELLUCCI DAVID B. STRUHS Lt. Governor Commissioner

June 30, 1997

Mr. Craig A. Kelley, Esq. Alewife Neighbors, Inc. 6 St. Gerard Terrace Cambridge, MA 02140

RE: TAG for W. R. Grace , 62 Whittimore Ave, Cambridge, MA 02140 RTN: 3-0277

Dear Craig:

I am responding to your letter of May 22, 1997, requesting the DEP to redefine the W. R. Grace site to include additional adjacent properties. Your request to redefine the property is addressed by the attached letter dated January 23, 1997, from DEP's Northeast Regional Office, which handles the site cleanup process. I want to address what activities may be conducted with your Technical Assistance Grant (TAG) funds.

On behalf of the Alewife Neighbors, Inc. you are requesting DEP approval to conduct sampling at two adjacent properties. First, the TAG regulations specifically state that developing new environmental data is an ineligible activity [310 CMR 40.1454(2)(a)]. This includes obtaining soil samples and having them analyzed independently of the sampling and analysis program conducted by the Potentially Responsible Party. Second, as we discussed at your contract scoping, TAG funds are available only for sites that have been tier classified [310 CMR 40.1452(6)(a)]. As the site is currently defined, the adjacent properties are not part of the tier classified site, nor are they classified as individual sites. Based on these two provisions, you cannot use TAG funds to conduct sampling on-site or at the adjacent properties.

Previously we had discussed TAG funded activities that could provide the Alewife Neighbors, Inc., an opportunity to voice their concerns and have these concerns addressed as part of the cleanup process. This site is in Phase III of the cleanup process. The comment period for the Phase III will close this summer, so now is the time for your technical consultant to be reviewing this document and discussing it with the group. Since the W. R. Grace site has been designated a Public Involvement Priority (PIP) site, your comments should be addressed and incorporated, where appropriate, by the party performing response actions, as part of the Phase III report [310 CMR40.1450(6)(f)].

DEP on the World Wide Web: http:/Awwwmagnet.state.ma.us/dep 8 Printed on Recycled Paper The TAG program has been designed to assist groups in obtaining expert technical advice to assist them in becoming more effectively involved in the site cleanup process. Please do not hesitate to contact me directly with any questions. My telephone number is 617/556-1018.

Sincerely,

Patti Mullan TAG Coordinator cc: Senator Warren Tolman Representative Alice Wolfe Councilor Francis Duehay Karen Stromberg, DEPNERO COMMONWRALTH OP MAnACH EXECUTIvE OFICE OF ENVIRONMENTAL APPAIRS DEPARTMENT OF ENVUONMNrAL PROTECTION METrOPOLITAN DOSTON NORTHEAST REIMONAL OPPICE

WILLIAM F. wD TRUDY COXE Governor ARGED PAUL CELLUCCI DAVID B. fMUS L. Omo Comiinr JAN 23 1997 CIRTIIED MAIL RETURN RCEIPT REQUNSTED

W.R. Grace & Co.-Conn. 62 Whittemore Avenue Cambridge, MA 02140-1692

Attn: Mr. David Wightman

RE: CRMBRXDGE - W.R. Grace Company 62 Whittemore Avenue RTN 3-0277 Tranpmittal # 118529 Permit Number: 118529 Permit Category: BWSC 03

DECISION To GRANT PERMIT

Dear Mr. Wightman:

The Department of Environmental Protection (the Department) has concluded its review of the above-reference4 permit application. Using the criteria contained in the Massachusetts Contingency Plan (MCP) 310 CMR 40.0730, the Department is issuing W.R. Grace a Tier IC Permit. Attached please find two (2) copies of the same for your reference and acceptance.

W.R. Grace must notify the Department of it's decision to accept or not accept the permit. To accept the permit, both copies of the permit's Acceptance Statement and the Certification of Submittal, on Page 5, must be signed and one copy of the complete permit with all original signatures must be returned to the Department within 30 days of the date of issuance, unless a request for an adjudicatory hearing is filed in accordance with 310 CMR 40.0770.

10 Commerce Way 0 Woburn, MachuMst 01501 1 FAX (617) 932-7615 * Telpho (617) 932-7600 * TDD I (617) 932-767 997 13:15 17 DEP NORTHEAST RE- P.e3

vage a

Please Noteu After the expiration of the 30 day deadline, the Department may consider this issued permit to become null and void if the completed permit with original signatures is not received by the Department. Consequently, W.R. Grace may be required to submit a new permit application and the appropriate fee in order to obtain another permit.

Any request for an adjudicatory hearing must be made within twenty-one days of the date on which the Department issued the permit. Please refer to 310 CMR 40.0770 and 310 CMR 40.0050 for conditions under which an adjudicatory hearing may be requested. If no request for an adjudicatory hearing is made, this permit shall become effective twenty-one days after the date on which the Department issues the permit and the Department's receipt of W.R. Grace's signed Permit Acceptance Statement, whichever is later.

This approval is an approval of a Tier I Permit to proceed with cleanup actions in accordance with 310 CMR 40.0000, and does not constitute an approval of any plan or action conducted subsequent to the suspension of oversight per Departmental Correspondence dated March 2, 1990.

As you know, the history of the site dates back to 1980, when a groundwater investigation identified contamination' in the vicinity of the W.R. Grace site (the site) where industrial process wastes had been landfilled. Subsequent studies performed for the MBTA concluded that these-process wastes would have to be removed before the Red Line Extension project could continue. According to Mr. Edward Pawlowtki of the Department's Bureau of Waste Prevention, several hundred truckloads of stabilized industrial wastes from the site, were taken to the Kingston, -Massachusetts landfill. The Perini Corporation, which was awarded the waste removal contract, stated that 17,620 cubic yards of material was transported from the site.

On February 9, 1987, The Department issued W.R. Grace a Notice of Responsibility (NOR) . The NOR identified a number of items that the Department required W.R. Grace to complete, including:

* A risk assessment addressing all potentially affected receptors;

* An evaluation of the possibility that contaminated groundwater from the site may enter into basements of residential buildings;

* A Feasibility Study and Remedial Action Plan for soil and groundwater contamination; and

R.,NT/1-17-96 -r- ., - --

* A hazardous materials management plan to monitor and control additional releases of oil/hazardous materials to be implemented during remediation and/or site redevelopment activities.

In order to fulfill the requirements of the NOR a Phase II Comprehensive Site Assessment including a Risk Assessment was submitted and approved by the Department in correspondence to W.R. Grace dated March 2, 1990. A Feasibility Study dated may 1988 was prepared to identify and evaluate possible remedial response actions that could be implemented at the site.

The Department received comments from the public during the review -of this Permit Application, as well as during the Department's recent audit of the Tier II Classification along with other submittals for the W.R. Grace disposal site. The majority of the comments were concerned with the adequacy of the pre 1993 Phase II submittal, the Phase III Feasibility study, the flooding of the Harvey/Clifton Street neighborhood basements, and potential contamination of Russell Field by W.R. Grace. The following discussion intends to respond to those comments.

In correspondence from the Department to W.R. Grace dated March 2, 1990, the Department considered the Phase II Comprehensive Site Assessment and Risk Characterization Plan complete. The Department made the determination that sufficient data had been developed to characterize the nature and extent of the'disposal site. The conclusion was based on the information available to the Department at that time. it was also determined that the risk- characterization provided by W.R. Grace had adequately addressed all of the potential risks. The Department is not aware of any- additional data which has been developed since the Phase II approval that would alter the Department's determination. Please be aware that all investigation and remediation performed at the W.R. Grace disposal site prior to March 2, 1990 received Departmental review and/or approval.

In accordance with 40.1405 and other provisions for Public Involvement Plan (PIP) sites, W.A. Grace shall solicit, consider, address and, where relevant and material to the response action, incorporate into decisions regarding response actions at the disposal site, concerns, information and comments from the public. With respect to the adequacy of the Phase III Feasibility Evaluation previously provided to the Department, this report has not been approved by the Department, and therefore the site is still considered in Phase III. As required by 310 CMR 40.0550 (2) (b), W.R. Grace shall complete the Phase III report, prepared in strict accordance with 310 CMR 40.0850 of the 1993 MCP (as amended), within two (2) years of the effective date of this permit. As part of the Phase III Remedial Action Plan,: W.R. Grace

_P .071.146 5-29-19-1997 13:1IS -87 e3L7 Ma MIS DEP NORWFsMPO "a P.

must consider the community's concern with the ae existing Feasibility Study. W.R. Grace is hereby reminded that the MCP .requires that the feasibility of reducing the concentrations of oil and hazardous material in the environment at the disposal site to levels that achieve or approach background must be determined. In consideration of the provisions outlined at 310 CMR 40.0860, if such a reduction is feasible and beneficial, then the implementation of necessary Comprehensive Response Actions to approach or achieve .background levels of contamination shall be undertaken. Numerous crmments were also submitted concerning the potential for contaminated groundwater to impact the Harvey Street/Clifton Street neighborhood. To address this concern, W.R. Grace notified Kathleen Brown from the city of Cambridge's Community Development, Environmental and Transportation Planning Department, in writing, that W.R. Grace will be completing an elevation survey of groundwater levels in this area in the very near future. A facsimile of this letter was submitted to the Department on January 10, 1997. Should such a survey indicate a potential for contaminated groundwater to migrate toward and potentially affect residences in this neighborhood, then additional investigations and if necessary, response actions shall be conducted to mitigate such conditions by W.R. Grace. It should also be noted that in accordance with 310 CMR 40.0411 (7) W.R. Grace must continually assess -and evaluate site conditions in order to determine if an Immediate Response Action is-required. with respect to concerns regarding the stockpiling of material at Russell Field, this concern was addressed. by the Department in the September 20, 1996 Notice of Audit Findings to W.R. Grace. The Notice of Audit Findings stated that based on the photographs documenting the reconstruction of Russell Field, the conclusion is that the observed sandy fill was brought to Russell field from a location other than the disposal site. However, to definitively resolve the issue, a test pit/boring and environmental testing program is recommended. It may be prudent to do this testing program as part of activities associated with the improvement of the Russell Field recreational facilities. The Department believes that sufficient information-exists to adequately characterize the potential for flooding in the area of the disposal site. The storm of October 1996 demonstrated that the disposal site and the surrounding community are located in the flood plain of Alewife Brook. However, the presence of contamination at the disposal site neither lessens nor increases the potential for flooding in the Alewife area. The issue of preventing future flooding should be addressedto the extant possible, by the city of Cambridge in concert with those potentially affected.

JiRAT/1-17-N 5j5 1DEP NORTHEAST R9NAL

As part of the submitted comments, the Department was asked to extend the public comment period for review of the permit application for six(6) months. To extend the public comment period for six (6) months to- allow for additional review of the permit application would delay the implementation of the final remediation plans. The Permit issued by the Department is to allow W.R. Grace to go forward with the site cleanup. Delaying the issuance of a Permit only serves to delay the implementation of the final cleanup plans. As indicated above, all remedial work performed at this - disposal site to date, has been under the direct oversight of the Department. Questions and concerns developed by the Alewife study -Group and other interested parties under the Technical Assistance Grant should be presented to W.R. Grace during future Public Involvement Plan meetings, as additional meetings must be held as required by the MCP.

If you have any questions, please contact Edward Weagle at the letterhead address or by calling (413) 784-1100 x221. Sincerely,

a( Edward J. Weagle Iris W. Davis Environmental Analyst Section Chief, Permits/Risk Reduction Bureau of Waste Site Cleanup Attachments: Permit and Permit Acceptance Statement (2 copies)

Cc: Cambridge Board of Health, 831 Massachusetts Avenue, Cambridge, MA 02139, Attn: Mr. Michael Nicoloro Cambridge City Hall, City Manager's Office, 795 Massachusetts Avenue, Cambridge, MA 02139, Attn: Mr. Robert Healy Cambridge Community Development Department, 57 Inman Street, Cambridge, MA 02139, Attn: Elizabeth Epstein Cambridge Main Library, 449 Broadway, Cambridge, MA 02139, Attn: Reference Librarian, W.R. Grace Disposal Site North Cambridge Library, 60 Rindge Avenue, Cambridge, MA 02140, Attn: Reference Librarian, W.R. Grace Disposal Site Honorable Charles Flaherty, Speaker of the House, Massachusetts House of Representatives, State House, Boston, MA 02133 Konorable Robert Havern, Massachusetts Senate, State House, Boston, MA 02133 Haley & Aldrich, Inc., 58 Charles Street, Cambridge, MA 02141 Attn: Mr. Wesley E. Stimpson, LSP-of-Record

(continued)

Ui.ANT/1-.96 COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION METROPOLITAN BOSTON - NORTHEAST REGIONAL OFFICE

WILLIAM F. WELD TRUDY COXE Governor Secretary

ARGEO PAUL CELLUCCI DAVID B. STRUHS Lt. Governor Commissioner

W R Grace 62 Whittemore Cambridge, MA 02140 October 18, 1996 re: ACKNOWLEDGEMENT OF PERMIT APPLICATION RECEIPT Application for: BWSC BWSC03 TIER IC RESPONSE ACTION PERMIT at: WR Grace 62 Cambridge Ave Cambridge, MA Transmittal Number: 118529 RTN 3-0277

Dear Applicant:

ur application and the correct payment for the permit listed above has been * ceived. In accordance with 310 CMR 4.04 the Department has 30 days from October 16, 1996 to perform an Administrative Completeness Review. Following the Administrative Completeness determination, the Department has 75 days to complete its Technical Review and issue a decision to grant or deny the application.

Provided your application is administratively complete, technically adequate, and none of the contingencies outlined in 310 CMR 4.04 arise, the Department will issue a final decision within the timeframes listed above. You will be entitled to a refund of your application fee should the Department fail to make a decision to grant or deny the permit within these timeframes.

If you have questions regarding your application, please contact the reviewer, Edward Weagle or his supervisor, Ida Babroudi at 617-932-7600. Please note: it is important to include the permit transmittal number noted above on any further information you may send in for our consideration relative to this permit application.

Sincerely,

Iris W. Davis Section Chief, Permits/Risk Reduction

10 Commerce Way * Woburn, Massachusetts 01801 e FAX (617) 932-7615 e Telephone (617) 932-7600 a TDD # (617) 932-7679

1: Pnmed on RecycledPaper COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION METROPOLITAN BOSTON - NORTHEAST REGIONAL OFFICE

WILLIAM F. WELD TRUDY COXE Governor Secretary

ARGEO PAUL CELLUCCI DAVID B. STRUHS Lt. Governor Commissioner

By CERTIFIED MAIL RETURN RECEIPT REQUESTED October 1, 1996

W.R. Grace & Co. - Conn. RE: CAMBRIDGE - 62 Whittemore Avenue W.R. Grace Cambridge, MA 02140-1692 62 Whittemore Avenue RTN 3-0277 Attn: Mr. David Wightman INTERIM DEADLINE EXTENSION

Dear Mr. Wightman:

The Massachusetts Department of Environmental Protection (the Department) is in receipt of a September 27, 1996 correspondence from your consultant, Haley & Aldrich, Inc. (H&A), addressed to Edward Weagle of this office. This correspondence requests an extension of the September 27, 1996 Interim Deadline established by the Department in it's September 20, .1996 Notice of Audit Findings/Notice of Noncompliance letter, which required revisions to the Numerical Ranking System scoresheet originally"provided for the above-referenced location (the site).

H&A's correspondence states "This extension is requested, and you have granted it, in recognition of the fact that the Audit findings was delayed in being released by the Department and the fact that W.R. Grace & Co. concurs with the Audit Findings that the Tier Classification for the site is to be revised to Tier IC."

Please note that 310 CMR 40.0167 (2) states in part " . . . The Department may modify an Interim Deadline if it deems such action appropriate. Any such modification shall be made in writing." In accordance with the provisions of 310 CMR 40.0167 (1)-(5), please consider this correspondence to be a two week extension to the previously established Interim Deadline. The revised Tier Classification and all other required documentation must be provided to the Department by no later than October 11, 1996.

1 10 Commerce Way * Woburn, Massachusetts 01801 * FAX (617) 932-7615 . Telephone (617) 932-7600 * TOD # (617) 932-1679

Printed on Recycled Paper W.R. Grace & Co. Page 2

If you have any questions regarding this Notice or any requirements contained in it please contact Edward J. Weagle at the letterhead address or by calling (617) 932-7719.

Very truly yours,

Edward J. eagle Iris W. Davis Environmen al Geol gist Section Chief Permits/Risk Reduction Bureau of Waste Site Cleanup

cc: Cambridge Board of Health, 831 Massachusetts Avenue, Cambridge, MA 02139, Attn: Mr. Michael Nicoloro Cambridge City Hall, City Manager's Office, 795 Massachusetts Avenue,.Cambridge, MA 02139, Attn: Mr. Robert Healy Cambridge Community Development Department, 57 Inman Street, Cambridge, MA 02139, Attn: Elizabeth Epstein Cambridge Conservation Commission, 57 Inman Street, Cambridge, MA 02140, Attn: Alex Strysky Cambridge Fire Department Headquarters, 491 Broadway, Cambridge, MA 02183, Attn: Deputy Chief James Harrington Cambridge Main Library, 449 Broadway, Cambridge, MA 02138, Attn: Reference Librarian, W.R. Grace Disposal Site North Cambridge Library, 60 Rindge Avenue, Cambridge, MA 02138,Attn: Reference Librarian, .W.R. Grace Disposal Site Honorable Charles Flaherty, Speaker of the House, Massachusetts House of Representatives," State House, Boston, MA 02133 Honorable Robert Havern, Massachusetts Senate, State House, Boston, MA 02133 Honorable Warren Tolman, Massachusetts Senate, State House, Boston, MA 02133 Alma Balonon-Rosen, Key Petitioner, 51 Madison Avenue, Cambridge, MA 02140 Karen Coker, Key Petitioner, 24 Magoun Street, Cambridge, MA 02140 Joseph Joseph, Key Petitioner, 18 Dudley Street, Cambridge, MA 02140 Haley & Aldrich, Inc., 58 Charles Street, Cambridge, MA 02141 Attn: Mr. Wesley E. Stimpson, LSP-of-Record DEP/BWSC/NERO/Data Entry/Files Karen Stromberg, DEP NERO -e 0 0

COMMONWEALTH OF MASSACHUSETTS EXECUT[VE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION METROPOLITAN BOSTON -NORTHEAST REGIONAL OFFICE

WILLIAM F. WELD TRUDY COXE Governor Secretary ARGEO PAUL CELLUCCI DAVID B. STRUHS Lt. Governor Commissioner

By CERTIFIED MAIL RETURN RECEIPT REQUESTED SEP 2 0 1996

W.R. Grace & Co. - Conn. RE: CAMBRIDGE - 62 Whittemore Avenue W.R. Grace Cambridge, MA 02140-1692 62 Whittemore Avenue RTN 3-0277 Attn: Mr. David Wightman NON-NE-96-3P008

NOTICE OF AUDIT FINDINGS NOTICE OF NONCOMPLIANCE INTERIM DEADLINE LETTER

This is an important notice. Promptly respond to any requests contained herein. Failure to respond to any such requests could result in serious legal consequences..

Dear Mr. Wightman:

The Massachusetts Department of Environmental Protection has completed an audit of the location described above (the site). The audit focused primarily on the Tier II Classification Submittal prepared by your Licensed Site Professional, Mr. Wesley Stimpson of Haley & Aldrich, Inc.. Other activities reviewed during this audit are listed in the attached Audit Memorandum. This Notice informs you of the results of the Department's audit.

VIOLATIONS EXIST THAT REQUIRE FURTHER ACTION

The audited response actions do not comply with the requirements of the Massachusetts Contingency Plan. Department personnel have found that additional actions must be taken to correct violations and deficiencies in the Tier Classification * Submittal provided for the disposal site.

10 Commerce Way * Woburn, Massachusetts 01801 * FAX (617) 932-7615 e Telephone (617) 932-7600 * TOO # (617) 932-7679

0 Printed on Recycled Paper W.R. Grace & Co. - Conn. Notice of Audit Findings Page 2

The activities which are in noncompliance and the actions the Department wants you to take to come into compliance are described in the enclosed Noncompliance Summary. The Noncompliance Summary describes.: (1) each activity identified during the Audit which is in noncompliance, (2) the requirements violated, (3) the action the Department now wants W.R. Grace & Co. - Conn. (hereafter referred to as "you/your") to take, and (4) the deadline for taking such action. An administrative penalty may be assessed for every day from now on that you are in noncompliance.

DEADLINE FOR RETURNING TO COMPLIANCE

You are advised to complete the measures the Department has specified within the timeframes outlined in the Noncompliance Summary, to avoid additional enforcement actions by the Department.

DEFICIENCIES EXIST THAT REQUIRE FURTHER ACTION

A. Deficiencies that Require Further Action. The Department has identified the deficiencies listed below. Steps which should be taken to correct each deficiency are also listed.

Deficiency: In subsection VI. of the NRS, ten points were subtracted from Subsection V.A. Environmental Resources Areas. However, there is no Technical Justification for this 10 point deduction, as detailed in the Department's AudiJ Memorandum.

Steps to be taken to correct deficiency: Revisions to the NRS scoresheet and Transmittal Form BWSC 107A should be provided to correct this deficiency. Such revisions should be provided by September 27, 1996.

Deficiency: The Department's NOR to W.R. Grace included the following requirement: "The possibility of contaminated groundwater from the site entering basements of off- [property] residential buildings must be evaluated. If such a condition can not be ruled out, mitigating measures must be considered. If it can be ruled out, the data and analysis on which that conclusion is based must be thoroughly documented. ... " The Department does not have the "... data and analysis .. which demonstrates that contaminated groundwater has not/will not impact residential basements in the Harvey Street/Clifton Street neighborhood. W.R. Grace & Co. - Conn. otice of Audit Findings age 3

Steps to be taken to correct deficiency: The Department requests that W.R. Grace provide the necessary information which demonstrates that contaminated groundwater has not/will not impact the residences in the Harvey Street/Clifton Street neighborhood.

B. Deficiencies that do not Require Action. No further steps are necessary.to correct this deficiency since it was corrected prior to/during the course of the Audit.

Deficiency: In responding to the comments raised during the public comment period, W.R. Grace misinterpreted section 40.1405 (5) (c) of the MCP and limited their Response Summary to just the comments specifically on the draft Plan. W.R. Grace did in fact answer all other comments received in separate letters to the commentors. Because the Response Summary should have included all comments raised, W.R..Grace addressed this deficiency by amending Appendix G of the Plan to include all comments and responses.

You do not need further Department approval to take the actions described herein. To respond to the Department's request, please complete the additional measures the Department has specified, and then submit the appropriate documentation of your actions for each deficiency. The Department advises you to revise the Tier Classification Submittal in order to correct the identified deficiencies and resubmit by September 27, 1996. This deadline constitutes an Interim Deadline pursuant to 310 CMR 40.0167.

CONCLUSION

DO NOT IGNORE THIS NOTICE. Failure to correct the violations and deficiencies identified and provide documentation of such action to the Department may subject you, your officers,and other involved individuals to enforcement action by the Department. The Department may conduct a follow-up audit to determine whether the required actions have been taken. If the Department finds that the violations and deficiencies have not been corrected, then the Department may issue a Notice of Noncompliance (NON), Notice of Intent to Assess a civil Administrative Penalty (PAN), administrative enforcement order, Notice of Responsibility (NOR), Notice of Intent to take Response Action (NORA), Administrative Consent Order, Unilateral Order, or seek a Judicial Judgement as appropriate. You may also be subject to cost recovery under 310 CMR 40.1200 for failure to perform response actions at the disposal *site. W.R. Grace & Co. - Conn. ->tice of Audit Findings WP age 4

LICENSED SITE PROFESSIONAL

A copy of this Notice has been sent to Mr. Wesley Stimpson, the Licensed Site Professional (LSP) of record for your disposal site. You may consult with the LSP of record when preparing a response to this Notice. Note, however, that you, not your LSP, are obligated to respond to this Notice and remedy the deficiencies. Note that any submittals to the Department made in response to this Notice must include the certification provided in Attachment B signed by an authorized individual as specified in 310 CMR 40.0009.

LIMITATIONS

The Department relies upon the accuracy of the information reviewed during the Audit to make these findings. These findings do not: (1) apply to actions or other aspects of the site that were not reviewed in the Audit, (2) preclude future audits of past, current, or future actions at the site, (3) in any way constitute a release from any liability, obligation, action or penalty under M.G.L. c. 21E, 310 CMR 40.0000, or any other law, regulation, or requirement, or (4) limit the Department's authority to take or arrange, or to require any Responsible Party or Potentially Responsible Party to perform, any response action authorized by M.G.L. c. 21E which the Department deems necessary to protect health, safety, public welfare or the environment.

If you have any questions regarding this Notice or any requirements contained in it please contact Edward J. Weagle at the letterhead address or by calling (617) 932-7719. Please reference the Release Tracking Number in any correspondence regarding the site.

Very truly yours,

. Richard Chalpin, . Regional Engineer for the Bureau of Waste Site Cleanup

Attachments: (A) Site Memorandum (24 pages) (B) Certification of Submittals (1 page) an (C) Noncompliance Summary (2 pages) N.R. Grace & Co. - Conn. Notice of Audit Findings Page 5

cc: (w/ attachment C)

Cambridge Board of Health, 831 Massachusetts Avenue, Cambridge, MA 02139, Attn: Mr. Michael Nicoloro Cambridge. City Hall, City Manager's Office, 795 Massachusetts Avenue, Cambridge, MA 02139, Attn: Mr. Robert Healy

cc: (w/ attachments A & C)

Cambridge Board of Health, 831 Massachusetts Avenue, Cambridge, MA 02139, Attn: Mr. Michael Nicoloro Cambridge City Hall, City Manager's Office, 795 Massachusetts Avenue, Cambridge, MA 02139, Attn: Mr. Robert Healy Cambridge Community Development Department, 57 Inman Street, Cambridge, MA 02139, Attn: Elizabeth Epstein & Stuart D. Dash Cambridge Conservation Commission, 57 Inman Street, Cambridge, MA 02140, Attn: Alex Strysky Cambridge Fire Department Headquarters, 491 Broadway, Cambridge, MA 02183, Attn: Deputy Chief James Harrington Cambridge Main Library, 449 Broadway, Cambridge, MA 02138, Attn: Reference Librarian, W.R. Grace Disposal Site North Cambridge Library, 60 Rindge Avenue, Cambridge, MA 02138,Attn: Reference Librarian, W.R. Grace Disposal Site Honorable Charles Flaherty, Speaker of the House, Massachusetts House of Representatives, State House, Boston, MA 02133 Honorable Robert Havern, Massachusetts Senate, State House, Boston, MA 02133 Alma Balonon-Rosen, Key Petitioner, 51 Madison Avenue, Cambridge, MA 02140 Karen Coker, Key Petitioner, 24 Magoun Street, Cambridge, MA 02140 Joseph Joseph, Key Petitioner, 18 Dudley Street, Cambridge, MA 02140 Haley & Aldrich, Inc., 58 Charles Street, Cambridge, MA 02141 Attn: Mr. Wesley E. Stimpson, LSP-of-Record Steve Winslow, BWSC DEP BOSTON John Fitzgerald, BWSC DEP NERO

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DEP/BWSC/NERO/Data Entry/Files Karen Stromberg, DEP NERO - ) . COMMONWEALTH OF MASSACHUSETTS ExEcuTVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION METROPOLITAN BOSTON - NORTHEAST REGIONAL OFFICE

WILLIAM F. WELD TRUDY COXE Governor Secrtary ARGEO PAUL CELLUCCI DAVID B. STRUHS Lt. Governor commiiner

Attachment A

AUDIT MEMORANDUM

TO: File

THROUGH: John J. Fitzgerald, Deputy Regional Engineer Bureau of Waste Site Cleanup

FROM: Edward J. Weagle, Environmental Geologist

DATE: July 25, 1996

SUBJECT: CAMBRIDGE, RTN 3-0277 W.R. Grace Co, 62 Whittemore Avenue

AUDIT OF TIER II CLASSIFICATION SUBMITTAL

I. ACTIONS AUDITED

The Audit included a review of the following:

E The Tier II Classification Submittal, prepared by Mr. Wesley Stimpson, LSP-of-Record. This review also considered the reported presence of a non-potable water supply well on Whittemore Avenue;

* A review of the potential for contaminated groundwater from the site to impact basements of residential properties located on Whittemore Avenue, Harvey Street, and Clifton Street;

* The potential for contamination to be present at the surface of Russell Field; and

* A review of public participation activities relative to compliance with pertinent DEP regulations and policies.

10 Commerce Way * Woburn, Massachusetts 01801 * FAX (617) 932-7615 * Telephone (617) 932-7600 * TDD # (617) 932-7679

C_ Pinfed on Recvded Paner ier II Classification Audit MBRIDGE, RTN 3-0277 Page 2

II. AUDIT ACTIVITIES

The Audit consisted of the following activities:

N A Notice of Audit dated January 26, 1996.

N An informal request fo; supporting documents. In a February 1996 telephone conversation, the Department requested Haley & Aldrich to supply all of the documents regarding the site which were missing from the Department's files. Additional documents were received on March 15, 1996.

a A site inspection on May 3, 1996 which included visual observation of site conditions, and screening of selected wells, for the presence of volatile organic compounds, with a photoionization detector.

E A review of supplemental information from the LSP received on June 11, 1996, providing additional justification in an effort to support the score assigned to subsection II.D. of the NRS.

During the course of this audit, the Department has received a number of comments/concerns from local residents regarding activities at the site, the most significant of which were transmitted to the Department under a cover letter from Mr.- Craig Kelly, Esq., dated February 12, 1996. Although a thorough response to all the comments received is beyond the scope of this audit, the Department has reviewed and considered all comments received, and has addressed these comments in this memorandum where appropriate.

III. SITE SUMMARY

The W.R. Grace Company-Conn. (W.R. Grace), in conjunction with Mr. Wesley Stimpson (LSP-of-Record) of Haley & Aldrich, Inc. (H&A) have submitted a Tier II Classification for the above-referenced property (the site). Included with the submittal were a Tier Classification Submittal Transmittal Form and a Numerical Ranking System (NRS) Scoresheet. Extensive supporting documentation previously compiled over the years has been provided to DEP.

According to the 1993 Transition List of Confirmed Disposal sites and Locations To Be Investigated, the site is listed as a Confirmed, Non-priority Disposal Site without a Waiver. The Transition requirements for Confirmed, Non-priority disposal sites without Waivers are set forth at 310 CMR 40.0636. The Transition Provisions indicate that a Tier Classification is necessary because a Response Action Outcome was not provided by the Transition Deadline of August 2, 1995. .- 1 4

S ier II Classification Audit AMBRIDGE, RTN 3-0277 Page 3

SITE HISTORY

According to information present, in the Department's file, portions of the site were developed in the 1800's by companies associated with clay mining. Clay was mined from Jerry's pit (now Jerry's Pond) from 1860 to the 1880's. In 1919, the Dewey and Almy Chemical Company established a rubber products (including sealing compounds and gaskets) manufacturing facility at the site. W.R. Grace acquired the site in approximately 1950 and continued the Dewey & Almy manufacturing processes.

Portions of the site are currently utilized as office buildings (One Alewife Center) and for research and development. The remainder of the site is used as paved parking or is currently unpaved and undeveloped. Bricks were reportedly made on-site from the mined clay. Prior to 1860, the site used to be wetlands; a majority of which were filled and/or otherwise altered.

Abutters to the site include: to the north across Whittemore Avenue, residential properties and paved parking areas; to the east, Russell Field Park with residential properties beyond it; to the south across Jerry's Pond and Rindge Avenue, residential high- rise apartments; to the west across Alewife Brook Parkway, an MBTA train station, a parking garage, and commercial properties; and to the northwest, one residence, and additional residences on the far side of Alewife Brook Parkway and Alewife Brook.

The releases reported under RTN 3-0277 are a result of historical releases associated with the operations of the chemical companies and disposal of manufacturing wastes at the site.

In 1980, a groundwater investigation identified groundwater contamination in the vicinity of the site where industrial process wastes had been landfilled. Subsequent studies performed for the MBTA concluded that these process wastes would have to be removed before the Red Line Extension project could continue.

In order for the construction of the MBTA's Red Line extension (which traverses the site) to proceed, all of the industrial process wastes at the site were first treated by mixing the material to create a stable clay-like slurry mixture. Then the slurry was allowed to dry at the site before being removed. After the material was sufficiently dry, it was placed into trucks by the MBTA, reportedly for transport from the site to a landfill in Kingston, Massachusetts.

According to Mr. Edward Pawlowski of the Department's Bureau of Waste Preyention, several hundred truckloads of the stabilized industrial wastes were taken to the Kingston, Massachusetts landfill beginning on November 2, 1981, and ending on April 3, Audit PierA"BRIDGE, II Classification RTN 3-0277 Page 4

1982, with no movement occurring between December 3, 1981 and March 30, 1982. The treated material was used to grade the Kingston landfill in preparation for the final capping process. According .to the Perini Corporation, which was awarded with the stabilized waste removal contract from the MBTA, a total of 17,620 cubic yards of solidified sludge were transported from the site.

An issue which has been raised by the surrounding community is the fact that the hazardous waste manifests documenting the transportation of 'the treated material have not been available for review. According to Mr. Pawlowski, based on Federal and State regulations that were in effect in 1981, the untreated material was likely classified under those regulations as an industrial waste, not as a hazardous waste. Non-hazardous wastes are not required to be transported under hazardous waste manifests, and as such, it is unlikely that the stabilized industrial wastes were transported under hazardous waste manifests. Therefore, hazardous waste manifests documenting the movement of the stabilized industrial wastes probably do not even exist. If other transportation manifests exist, the MBTA, as the generator and the transporter of the treated material, should have copies of these transportation records.

After the stabilized wastes had been removed by the MBTA, excavation into the underlying contaminated soils for tunnel construction had begun. Both cut/cover and tunnel boring were performed. Excavated soil was segregated into three categories: (1) heavily contaminated soil to be removed and disposed of of f- site; (2) marginally contaminated soil to be reused on-site; and (3) uncontaminated soil to be handled properly (including removal from the site). However, it has been reported that some marginally contaminated soil was removed from the site and used at various locations along the Red Line alignment, including at the Davis Square station. The soil was staged at Russell field, along with construction materials and equipment. After the Alewife extension had been completed, Russell Field was restored by the MBTA.

On February 9, 1987, the Department issued W.R. Grace a Notice of Responsibility (NOR) . The NOR identified a number of items that the Department required W.R. Grace to complete, including:

* A Risk Assessment addressing all potentially affected receptors;

* An evaluation of the possibility that contaminated groundwater from the site may enter into basements of residential buildings;

* A Feasibility Study and Remedial Action Plan for soil and groundwater contamination; and Audit . TierCAMBRIDGE, II Classification RTN 3-0277 Page 5

* A hazardous materials management plan to monitor and control additional releases of oil/hazardous materials to be implemented during remediation and/or site redevelopment activities.

The Phase II Comprehensive Site Assessment including a Risk Assessment were approved by the Department in correspondence to W.R. Grace dated March 2, 1990. A "Feasibility Study" dated May 1988 was prepared to identify and evaluate possible remedial response actions that could be implemented at the site. This report was meant to satisfy the requirement of the NOR, and is roughly analogous to a 1993 MCP Phase III - Identification, Evaluation, and Selection of Comprehensive Remedial Action Alternatives, as defined by 310 CMR 40.0850. Because the Department has not approved of this report in writing, the site is considered to be in Phase III of the 1993 MCP. It is the writer's recommendation that W.R. Grace review this report in the context of the requirements set forth in 310 CMR 40.0850. After such review, a Phase III Completion Statement pursuant to 310 CMR 40.0862 should be filed if the May 1988 report meets the requirement set forth at 310 CMR 40.0850. After the Phase III completion statement (and any additional supporting documentation, if necessary) is provided, W.R. Grace may be able to show that they have met the regulatory- requirements to file a Class C Response Action Outcome statement for the disposal site.

SITE INSPECTION

On Friday, May 3, 1996, at 11:00 am, the writer met with: Mr. Wesley Stimpson of Haley & Aldrich, Mr. David Wightman and Mr. Rod McClaren of W.R. Grace Co.; and Ms. Liz Epstein and Ms. Kathleen Brown of the City of Cambridge Community Development Department. The meeting took place at the properties located at and in the vicinity of 62 Whittemore Avenue in Cambridge, hereafter referred to as "the site". It was a humid, cloudy morning with light intermittent rain showers, and temperatures in the upper 60s. The following.notes and comments are based primarily on the Department's observations during this Site Inspection, and may also include information present in the Department's files. This Site Inspection was conducted for the purpose of documenting site conditions as part of the audit. During the site inspection, four (4) groundwater monitoring wells were screened for the presence of volatile organic compounds (VOCs) within the well casing headspace, using an OVM Model 580A photoionization detector. Results are as follows: er II Classification Audit MBRIDGE, RTN 3-0277 Page 6 well ID Comments

703 ND Metal standpipe damaged, PVC riser intact, readings above background not detected 707 0.4 background at 0.1 to 0.2 503 0.2 background at 0.1 to 0.2 207 0.2 background at 0.1 to 0.2

The inspection began at the lobby of the 62 Whittemore Avenue administration building. The group walked west on the sidewalk along Whittemore Avenue down to the corner of Whittemore Avenue and Alewife Brook Parkway. Along the way, the writer took note of the roadbox for well 902. The writer looked carefully for wells 8 and 602A, however, these wells appeared to have been destroyed or buried. Paved parking lots and residences are present along the north side of Whittemore Avenue. A residence is also present at the corner of Whittemore Ave and Alewife Brook Parkway, abutting the site. A grassy landscaped area approximately 30 feet wide separates One Alewife Center (located along the south side of O Whittemore Ave.)- and this residence. The area south of the One Alewife Center building consists of landscaping along the edge of the building, with a large paved parking area just beyond it. A six-foot chain link fence separates the parking lot from the unpaved/undeveloped portions of the site. The fence had been knocked down at two locations. Mr. Wightman indicated that extensive snow removal activities this winter had damaged the fence in these two locations. At this point, Ms. Epstein departed, and the remainder of the group stepped over the downed fence for a closer observation of the unpaved portions of the site, south of the paved parking areas.

The fence that borders between the unpaved portions of the site and the surrounding properties (i.e., the Rt. 16 right-of-way, the MBTA property on the east side of Rt. 16, the walking path easement, and Russell field) is eight feet high and of chain link construction. The writer closely inspected this perimeter fence, which borders the surrounding properties, and noted that the fence was in excellent condition. Breaks or breaches were not observed. Based on the writer's observations, it appears that this portion of the fence is serving it's design purpose: to prevent people from accessing the site from Russell Field, the walkway easement, and the MBTA property.

During the perimeter fence inspection, the interior of the undeveloped portions of the site were closely viewed. Some of these areas contained standing water up to approximately 6 inches deep. The standing water did not exhibit any overt signs of . J

t irBRIDGE,II Classification RTN 3-0277 Audit Page 7

contamination, such as odors, sheens or stressed/absent vegetation, although most of the vegetation present were dried stalks left over from the previous growing season. Extensive areas of very wet, spongy ground were also encountered.

Also, observed in the area were four (4) elongated piles of soil, approximately 150 feet long, which were arranged to form a square. These piles were about 3 to 4 feet higher than the surrounding area, and contained concrete rubble, apparently from former structures that had previously been demolished. According to Mr. Wightman and Mr. Stimpson, these piles are what remains from a bioremediation pilot project that had been conducted in the late 80's. This project is not currently active.

The portions of the site that abut Russell Field were observed next. As indicated above, the fence was in excellent condition. Beyond the fence, Russell field appeared to be well-maintained. The writer observed that the grade of Russell Field at it's northwest corner appeared approximately 4 or 5 feet higher in elevation than the adjacent land surface. According to Mr. Wightman, Russell Field was regraded by the MBTA in the mid 1980's, after the completion of construction activities associated with the extension of the Red Line.

While walking back toward the facility, the writer inquired of Mr. Wightman as to what operations does W.R. Grace currently conduct at the facility. Mr. Wightman stated that research and development of new concrete mixtures is currently performed at the Eacility, and he pointed out blocks of concrete in a fenced enclosure that were subjects of W.R. Grace's work. This work reportedly includes development of new concrete formulations as well as testing of these new formulations for strength and durability.

The writer also inquired as to what were the current redevelopment plans were for the site. Mr. Wightman stated that a Notice of Project Change, which would have reduced the size and altered the scope of the original redevelopment proposal, had recently been withdrawn from the MEPA review process. Mr. Wightman further indicated that the original proposal, which had already been approved by EOEA, would likely go forward in the future. The writer stated that appropriate site redevelopment was consistent with the Department's Brownfields program, which encourages the redevelopment of urban sites where extensive infrastructure is already in place, as opposed to developing previously undeveloped land and open spaces located away from urban infrastructure. In addition, the writer stated that remediating the remaining . :ontamination while redeveloping the property was probably the most :ost-effective way of completing the cleanup for the site. r II Classification Audit BRIDGE, RTN 3-0277 Page 8

After the tour, a discussion among Mr. Stimpson, Mr. Wightman, Mr. McClaren, and the writer ensued. Issues addressed during this discussion included the timing and possible content of the Department's Notice of Audit Findings letter. The inspection of the W.R. Grace property concluded at approximately 12:40 pm.

At 1:00 pm, the writer met Mr. John Hudson of the MBTA at the entrance to the MBTA Alewife station train platform. The writer and Mr. Hudson then proceeded down onto the platform, where the writer screened the ambient air at locations along the platform as well as the four tunnel entrances, two of which lead down under the W.R. Grace property. The writer noted that the approach or departure of a train induced an air current into or out of the tunnels. All readings recorded by the writer were at background (0.0-0.1 ppmv) . Elevated readings were not detected, and the writer did not note the presence of any odors. At approximately 1:10, the writer concluded the screening and departed.

NRS SCORESHEET REVIEW

The following documents the writer's review of the information m contained in the Department's files for the purpose of evaluating the Tier Classification Submittal (the submittal) of the above- referenced disposal site in accordance with the 310 CMR 40.1500. Other comments by the writer are expressed where appropriate. In addition, the writer has reviewed the NRS comments presented by Environmental Health & Engineering, Inc. (EH&E) in an April 23, 1996 final draft report entitled "Public Health Risk Evaluation for W.R. Grace Site in Cambridge, Massachusetts", prepared for the Cambridge Community Development Department. Included is an evaluation of these comments, where appropriate. Although not directly related to the response actions audited, this report concludes that "Based on available data there is no reason to consider the W.R. Grace site, as it currently exists, to be a health concern to the neighboring community, which includes residents and recreational users of the Russell Field Facilities." TOTAL SCORES:

SECTIONS SUBMITTAL SCORE AUDIT SCORE

II. EXPOSURE PATHWAYS 105 120 III. DISP. SITE CHARACTERISTICS 122 126 IV. HUMAN POP. AND LAND USES 25 40 V. ECOLOGICAL POPULATION 100 100 VI. MITIGATING CONDITIONS - 20 - 25

TOTAL 332 - 361 t erBRIDGE, II Classification RTN 3-0277 Audit Page 9

The submittal states that neither of the Tier I inclusionary criteria are applicable for. this release.

SECTION II. EXPOSURE PATHWAYS:

SECTIONS SUBMITTAL SCORE AUDIT SCORE

A. SOIL 15 15 B. GROUNDWATER 20 20 . SURFACE WATER 20 20 D. AIR 0 15 E. SOURCES 50 5o

TOTAL 105 120

The writer agrees with the scores assigned to Subsections II.A, II.B, II.C, and II.E.

Relative to Subsection II.A., Soil Exposure Pathway, the -submittal indicates that oil and/or hazardous material (OHM) is either located beneath paved surfaces or at depths greater than 6 *inches below grade. Based on the results of a 1995 soil boring program conducted in an effort to further delineate the extent of the Total Petroleum Hydrocarbon (TPH) contamination, the writer has taken note that soil samples from the top 6 inches of the site were not collected for analysis. Samples collected from 1 to 3 feet below grade were found to contain TPH concentrations up to 9,120 mg/kg, well in excess of the RCS-1 concentration for TPH (500 mg/kg). Given that such high concentrations of TPH were detected just below the 0 to 6 inch horizon, the presence of contaminants within the 0 to 6 inch horizon, such as TPH concentrations exceeding 500 mg/kg, can not be dismissed without actually collecting and analyzing samples from this horizon. However, although TPH contamination in excess of 500 mg/kg may exist within the top 6 inches of soil at the site, that by itself does not represent a Potential Exposure Pathway, due to the fact that access to this area is restricted by fencing, and the contaminated areas are not used for active recreation.

Relative to Subsection II.B., Groundwater Exposure Pathway, the private well located in the vicinity of the site is NOT a drinking water well, and therefore additional points implying a potential exposure pathway would not be appropriate.

Relative to Subsection II.C., Surface Water Exposure Pathway (surface water includes wetlands), the writer concludes that 20 points is correct for this subsection, for the following reasons: 1) contaminated groundwater from the site eventually discharges to * lewife Brook and detectable concentrations of OHM likely attributable to the disposal site have been identified in Alewife Audit Classification S AMBRIDGE,ier II RTN 3-0277 Page 10

Brook during past sampling rounds; (2) a release (past or on-going) of OHM to surface water (Jerry's Pond) has been identified; and (3) wetlands located on the property adjacent to Russell Field are in the same area where the groundwater contamination is most elevated. Therefore, OHM has been identified in groundwater at concentrations that are likely to result in detectable concentrations in surface water (the on-site wetlands). Finally, the surface water quality in these wetlands (when standing water is present) has not been determined. If future sampling of the surface water in these wetlands identifies concentrations of OHM in excess of Ambient Water Quality Criteria, then it would be necessary to revise the score assigned to this subsection.

The writer disagrees with the assignment of 0 points to Subsection II.D., Air Exposure Pathway. In this subsection, the LSP states: "OHM attributable to the disposal site has not been identified in, and is not anticipated to be identified in air. " This statement is identical to the citation given at 310 CMR 40.1512 (4) and as such, does not provide any Technical Justification as to why this selection is appropriate. The lack of Technical Justification supporting this statement, and the absence of references to the Phase I and/or other applicable reports where the rationale for this statement is presented, is deficient relative to the requirements of 310 CMR 40.1505 (1) and 310 CMR 40.1505 (3).

310 CMR 40.1505 (2) (d) states "310 CMR 40.1512 (4) shall be applied to establish the score for Air Exposures for Subsection II.D. " 310 CMR 40.1512 (4) for None or Not Applicable, states that a score of 0 points shall be assigned if "OHM likely attributable to the disposal site has not been identified in, and is not anticipated to be identified in, air." This designation is clearly not appropriate, as OHM likely attributable to the disposal site has been identified in air, and is anticipated to be identified in air, as detailed below.

Section 1.1 of the Meta Systems Inc. May 16, 1988 Health Risk Assessment states: "Almost any movement of soil containing naphthalene on the site will cause sufficient emission of naphthalene to produce an odor which will be detectable in local neighborhoods when they are downwind. " This statement is in direct contradiction to the rationale presented in this subsection ("OHM ... is not likely to be identified in air.") Given that site remediation and redevelopment may involve the disturbance of naphthalene-contaminated soils, detectable concentrations of odors may be liberated to ambient air. Furthermore, the proposed remedial/redevelopment scenario will expose soil contaminated with . naphthalene, which will subsequently volatilize and be released to ambient air. Due to the low odor threshold of naphthalene, it is reasonable to conclude, as it has been by W.R. Grace's Risk ) a.

SAMBRIDGE,ier II Classification RTN 3-0277 Audit Page 11

Assessment consultant, that detectable concentrations of naphthalene will be released into the air upon site remediation/development.

In an effort to determine the appropriate score that should be assigned to Subsection II.D., the writer has evaluated the Evidence of Contamination and Potential Exposure Pathway definitions set forth at 310 CMR 40.1512 (4) . Evidence of Contamination is considered to be any of the following:

(1) "A release, or potential release, of OHM to air has been identified.," or (2) "OHM that may be released to air as particulate material has been identified in the top 6 inches of the ground surface. Unbroken pavement/concrete slab surfaces may be interpreted as preventing release of particulates to air." or (3) "OHM that may be released to air as a vapor has been identified in an open container or surface impoundment that is part of the disposal site." or (4) "An odor that is reasonably attributable to a release of OHM at the disposal site has been identified."

A Potential Exposure Pathway is considered to be any of the following:

(1) "OHM releases, likely attributable to the disposal site, have been repeatedly identified in ambient air within 100' of a residence, school, hospital, nursing home, or playground when such releases are above ambient background concentrations and are not related to permitted releases." or (2) "Total volatile organic compounds have been identified in groundwater at concentrations greater than or equal to 5 mg/l within 30 feet of a school or occupied residence where the depth to groundwater is less than or equal to 15 feet. ... " or (3) "A reasonable likelihood exists that the indoor air quality of an occupied building will be impacted by OHM likely attributable to the disposal site."

First, under Evidence of Contamination, the writer rules out (3) because open containers or surface impoundments do not currently exist, and retains (1), (2) and (4) because these appear to be applicable. Second, under Potential Exposure Pathway, the writer rules out (2) because this condition has not been identified, and retains (1) and (3) because these appear to be, at a minimum, possible. In order to narrow down these choices even further, it is necessary to consider all documented occurrences of detectable odors likely attributable to the disposal site.

Potentially due to the fact that most of the Department's site file is missing, there is only one documented occurrence of odors emanating from the site in the file. At 2:07 on May 22, 1989, a resident living adjacent to Russell Field called Ms. Nancy Bettinger, the Department's former site manager for this location, from the site. odors were emanating report that strong a to As a result of the absence of written documentation in the file, the writer had several recent discussions with Nancy . ierAMBRIDGE, II Classification RTN 3-0277 Audit Page 12

Bettinger regarding the issue of odors from the site. During those conversations, Ms. Bettinger indicated that she could recall receiving numerous complaints from local residents of odors emanating from the site, and on one occasion when Ms. Bettinger was conducting a site inspection, she personally noted naphthalene odors adjacent to the Russell Field Ballpark. In addition, the writer consulted with the Department's Division of Air Quality (DAQ) in an effort to determine if there had been any recorded complaints of odors from the' site. DAQ indicated that at 2:30 pm on June 25, 1990, the Department received a complaint of naphthalene odors emanating from the site. Based upon the nature and extent of the residual contamination, extensive past agency observations and involvement, and neighborhood/municipal records and observations, odors are clearly a concern at this site.

On June 11, 1996, Haley & Aldrich supplied additional information to support the None or Not Applicable designation. This included a two page narrative and copies of two reports, dated February 1988 and February 1, 1989 and prepared by TRC Environmental Consultants, which documented the performance of air monitoring activities at the site. Samples were collected during each of the four seasons, and samples were analyzed by NIOSH method 1501. The TRC reports conclude that naphthalene was detected above reporting limits in only 2 out of 26 ambient air samples collected during four seasonal sampling events. However, these reports also state that at low concentrations, naphthalene is not easily desorbed from the charcoal collection tube, and ". .that during sampling days, TRC staff observed a mothball odor at the remediation site. This is the indication of the presence of naphthalene." In addition, the fact that a naphthalene odor was observed by TRC during sampling and was detected at concentrations above method detection limits in two of the samples further demonstrates the inappropriateness of the statement "OHM attributable to the disposal site has not been identified in ... air."

Finally, on page two of the narrative, H&A states: "We believe it is not the purpose of the NRS to consider future odors in assigning points for the air pathway." and "The NRS addresses only current issues." These statements are not consistent with 310 CMR 40.1512 (4) for None or Not Applicable: "OHM likely attributable to the disposal site has not been identified in, and is not anticipated to be identified in, air." This regulatory citing clearly intends for the entire site history (save risk reduction measures previously completed) to be used. The Department interprets "... has not been ... " to include documented past site conditions, and " ... is not anticipated to be ... " to include potential future site conditions. Based on these statements, it is clearly not appropriate to narrowly define the temporal relationship of site conditions to the moment that the Tier Classification is developed. Although risk reduction measures were 0 t Ler II Classification Audit AMBRIDGE, RTN 3-0277 Page 13

completed at the site in the early 1980's (the MBTA's removal of the manufacturing waste sludge), all of the potential sources for naphthalene odors, i.e., the naphthalene-contaminated soil, have not been remediated.

It is important to note that while the occurrences of naphthalene odors detectable by local residents are not believed to pose an increased risk of harm to human health via the inhalation exposure pathway, the occurrence of these vapors is a nuisance issue, and as such, this exposure pathway should be scored appropriately.

Therefore, in light of the above, the writer recommends a score of 15 points for this subsection.

SECTION III. DISPOSAL SITE CHARACTERISTICS:

SECTIONS SUBMITTAL SCORE AUDIT SCORE A. OHM TOXICITY 40 40 B. MULTIPLE OHMS 30 30 C. OHM MOBILITY AND PERSISTENCE 40 40 D. DISPOSAL SITE HYDROGEOLOGY 12 16

TOTAL 122 126

The writer agrees with the scores assigned to Subsection III.A., III.B., and III.C. Relative to Subsection III.A., after the writer's review of all OHMs present at the site pursuant to 310 CMR 40.1506 (1) (a), the writer concludes that the correct score has been assigned to this subsection. The writer does not agree with the score assigned to Subsection III.D., Disposal Site Hydrogeology. In this subsection, a score of 12 points was assigned, indicating that site soils have a "medium" permeability and that the highest identified depth to groundwater was between 5.1 and 10.0 feet below grade. However, concentrations of TPH greater than both RCS-1 and RCS-2 have been detected in soil samples collected from locations in the vicinity of well B-212, and concentrations of naphthalene greater that the RCGW-2 standard of 6,000 pg/l have historically been detected in wells B-212, B-707, and B-708, with concentrations as high as 45, 000 pg/l having been previously recorded (at B-212). According to well gauging data collected by Haley and Aldrich in December 1994, the water table in these wells was measured to be between 6.08 and 7.40 feet below the top of the well casing. These three wells all have approximately 3.5 feet of metal well casing which extends above the ground surface. Therefore, after subtracting approximately 3.5 feet from the depth to groundwater measurements S AMRIDGE,!Ler II Classification RTN 3-0277 Audit Page 14

made from the top of the well casing, the writer concludes that the water table in the vicinity of these three wells was approximately 2.5 to 4.0 feet below the ground surface at the time of the depth to groundwater measurements. In accordance with 310 CMR 40.1506 (1) (e) 1., the writer recommends assigning a score of 16 points to this subsection to indicate that the highest identified seasonal groundwater level is less than 5.1 feet below grade. This recommendation is further supported by the writer's observations during the site inspection that surface water is present in wetlands in the vicinity of these three wells for at least a portion of the year.

SECTION IV. HUMAN POPULATION AND LAND USES:

SECTIONS SUBMITTAL SCORE AUDIT SCORE

A. HUMAN POPULATION 25 25 B. AQUIFERS 0 0 C. WATER USE 0 15

TOTAL 25 40

The writer agrees with the scores assigned to Subsections IV.A. and IV.B.

The writer does not agree with the score assigned to Subsection IV.C., Water Use, due to the fact that there is a private well located at 12 Whittemore Avenue. This well was installed for the purpose of providing an alternative source of water (than the MWRA) for the irrigation of plants at Mr. Edward Norberg's greenhouse business. According to a February 15, 1996 telephone conversation between the writer and Mr. Norberg, this well does not have a pump or associated piping for extracting water, and neither a pump (yield) test nor a water quality test have been conducted on this well. According to Mr. Norberg, the well is not currently used and has never been used, reportedly, due to the expense that would be involved in pumping the water from the 960 foot deep bedrock well. However, Mr. Norberg stated to the writer that he desires to retain the ability to use this well in the future, if rising MWRA water costs or water restrictions make it economically beneficial or necessary. The writer has reviewed the available information, and based on Haley & Aldrich figure 3C dated November 1995, the writer concludes that the following exploration locations are within 500 feet of the Norberg well: TP-223, B-201, B-202, and B-901. Evaluation of Soil Quality Information- A soil sample . collected from test pit 223 (TP-223) was composited with three other soil samples (from TP-206, TP-207, & TP-222) then analyzed for a range of parameters. This composite sample was found to STier II Classification Audit CAMBRIDGE, RTN 3-0277 Fage 15

contain concentrations of ABNs, including benzo (a) anthracene, benzo (a) pyrene, benzo (b, k) fluoranthene, and chrysene each of which exceeds the RCS-1 standard of 0.7 mg/kg. In addition, 6 other ABNs were reported as being present but no concentrations were given. Therefore, it' is not possible to determine if any of these 6 reported ABNs exceed the respective RCS-1 concentrations. Because the analyzed sample was collected from four separate locations, three of which were collected farther than 500 feet of the Norberg Well, and because discrete follow-up sampling was not conducted/reported, is not possible to conclusively determine if the exceedance of RCs were due to soil conditions at this location. In the absence of conclusive soil analytical data, and in accordance with the requirements of the Response Action Performance Standard, the writer concludes that the exceedances of RCs are, at least in part, due to soil contaminant conditions at the location of TP-223. Therefore, contaminated soil does exist within 500 feet of the Norberg well. Evaluation of Groundwater Quality Information- The three monitoring wells that are located within 500 feet of the Norberg well are B-201, B-202, and B-901. Based on a thorough review of all available information, groundwater from well B-202 has never been analyzed. Well B-901 was sampled once, on January 21, 1988. Low levels of chloroform (16 jg/l) and bromodichloromethane (6 pg/1l), which are commonly found in municipal water supplies that have been chlorinated, were detected; however, the reported concentrations do not exceed applicable standards. Well B-201 was advanced at total of 113 feet into the ground where refusal (bedrock) was encountered. Boring logs indicate that interbedded sands, silts, and clays were encountered to 34 feet below grade, followed by 80 feet of clay (overlying bedrock). This well is screened from 21 to 31 feet below grade, entirely below the watertable. It was sampled once on October 8, 1987, and was found to contain the following chlorinated compounds: 1,1-dichloroethene (10 pg/l); 1,1-dichloroethane (79 pg/l); both isomers of 1,2- dichloroethene (at a total of 9 pg/1); 1,1,1-trichloroethane (130 pg/l); trichloroethene (5 pg/1l); tetrachloroethene (200 g/1l); and carbon tetrachloride (32 pg/l). Of these, 1,1-dichloroethene and carbon tetrachloride were detected at concentrations which exceed the applicable RCGW-2 concentrations. The source of this detected contamination is not known. Because there are no additional sampling data available from this well, the Department must consider this information to be representative of current conditions at this location. Therefore, the writer concludes that groundwater contamination in excess of applicable RCGW-2 concentrations is present within 500 feet of the Norberg well. Scoring Disposition- Based on the above evaluation of available information, the writer concludes that the disposal site, . as defined in 310 CMR 40.0006, is located within 500 feet of the Norberg well. Furthermore, based upon the Department's communications with Mr. Norberg, this well is intended only for aer II Classification Audit WMEBRIDGE, RTN 3-0277 Page 16

irrigation purposes. Therefore, as required by 310 CMR 40.1507 (1) (c) 3.ii., the Department concludes that Subsection IV.C., Private Water Supplies, shall be assigned a score of 15 points. Possible Mitigating Conditions- As indicated above, the presence of this well should be scored as 15 points, to indicate that a non-potable irrigation well is located within 500 of the disposal site. Because (1) this well is not currently being used; (2) the well is located in an apparent cross-gradient location; (3) considering that the well is designed to collect water from fractures in the bedrock as opposed to groundwater from the saturated unconsolidated overburden deposits; and (4) the fact that 80 feet of clay separates the unconsolidated deposits from the bedrock, it may be appropriate to subtract 15 points from Section VI to indicate the disposition of this well. Conclusions- Should this well be put into service in the future, it may become necessary to re-evaluate site scoring, or to conduct additional investigations, such as a water quality test and a revised Risk Assessment, if necessary, in order to ensure that the risks associated with this potential pathway have been adequately determined, and that this subsection of the NRS is properly scored.

SECTION V. ECOLOGICAL POPULATION:

SECTIONS SUBMITTAL SCORE AUDIT SCORE

A. ENVIRONMENTAL RESOURCE AREAS 80 80 B. ENVIRONMENTAL TOXICITY 20 20

TOTAL 100 100

The writer agrees with the scores assigned in Section V.

SECTION VI. MITIGATING DISPOSAL SITE-SPECIFIC CONDITIONS:

In this section, two (2) separate 10-point deductions were made. The rationale provided for these deductions is as follows:

"The site has been characterized at a level of detail greater than a Phase II Comprehensive Site Characterization. A groundwater and surface water monitoring program has been underway for the last seven years. Therefore significantly more data exists than is commonly available at the end of a Phase I study. As a result of the availability of this data, the following reductions have been made:

Under Section V. - Ecological Population, Part A, the fish habitat on-site (Jerry's Pond) score of 30 points is reduced I k4- a

S erMBRIDGE, II Classification RTN 3-0277 Audit Page 17

by 10 points (to a total- of 20 points) due to data from post- Phase II investigations (Long-Term Monitoring Plan, December 1994) indicating that surface water and sediment contamination do not exist in Jerry's Pond.

Under Section V. Ecological Population, Part A, the protected open space less than 500 ft. from the site (Alewife Brook Reservation) score of 20 points is reduced by 10 points (to a total of 10 points) due to data from the Long-Term Monitoring Report indicating that the surface water contamination does not exist in Alewife Brook at locations both upstream and downstream of the site. The Reservation is also located across Alewife Brook Parkway from the site. Alewife Brook Parkway is a divided, four lane highway with no opportunity for surficial contamination from the site to impact the Reservation."

Regarding the first 10-point deduction taken in this section, the writer disagrees with the wording of the statement "... surface water and sediment contamination do not exist in Jerry's Pond. ", in as much as it is not correct to state that contamination does not exist in sediments, when it has been previously recorded. According to H&A's December 1994 Long Term Monitoring report, on April 4, 1990, a sediment sample collected from Jerry's Pond was found to contain 13 pg/kg of naphthalene, while a sediment sample collected on March 20, 1991 was found to contain 1,800 pg/kg of naphthalene. The next (and last) sediment sample collected from Jerry's Pond did not contain detectable concentrations of naphthalene. The above statement would better express the conclusions that may be accurately drawn from these data if it had been qualified to state "contamination was not detected in the last sediment sample collected from the Pond. " Furthermore, the writer is not aware of any remediation of these contaminated sediments that may have occurred since discharges to the pond from the manufacturing facility ceased in the early 1980's. In light of the above, the writer concludes that the variations in concentrations of naphthalene detected in the pond sediments could be due to temporal and/or spacial variations in these sampling events.

The writer disagrees with the second 10-point deduction, on the basis that the argument is not supported by any Technical Justification. According to the available information, a soil sample collected from B95-62 in July 1995 contained 40,700 mg/kg TPH. The contamination detected at the location of this boring, which was advanced approximately 350 feet from a Protected Open Space that encircles and includes Yates Pond, clearly demonstrates that contamination is located with 500 feet of a Protected Open . Space environmental resource area. The argument is inappropriate for the following two reasons: First, if the contamination was located on or within the boundaries of a designated Protected Open I C, *#0

SIer II Classification Audit NBRIDGE, RTN 3-0277 Page 18 Space, then the correct score to assign would have been 30 points (310 CMR 40.1508 (1) (a) S.c.) . Because this is not the case, 20 points is the correct score to assign to the presence of the contamination at the specified location. Second, the argument focuses on direct human contact issues. Direct contact issues are scored in Section II of the NRS, not in Section V. Section V. deals with the presence or absence of specific resource areas at or within a given distance to a disposal site, not whether there are any exposure issues associated with the specified contamination. Therefore, this 10 point deduction is not supported. Also, in Section VI., the writer recommends that the 15 points scored in Section IV.C., due to the presence of the Norberg irrigation well, be subtracted, for the reasons stated above.

NRS CONCLUSIONS

Based on the writer's scoring of the site according to 310 CMR 40.1500, the disposal site is scored at 361 points. This exceeds the 350 point cut-off between Tier II and Tier I sites.

GROUNDWATER INFILTRATION

The Department's Notice of Responsibility dated February 9, 1987, included the following requirement: "The possibility of contaminated groundwater from the site entering basements of off- [property) residential buildings must be evaluated. If such a condition can not be ruled out, mitigating measures must be considered. If it can be ruled out, the data and analysis on which that conclusion is based must be thoroughly documented. Additionally, long term monitoring must be conducted to assure that conditions do not change. " This requirement was included because occasional groundwater infiltrations into basements are expected, especially in light of the fact that the site and surrounding area were formerly wetlands that have been filled and developed for both residential and industrial purposes.

To fulfill this requirement, monitoring wells were installed at the property in an effort to determine hydrologic conditions at the site. Groundwater elevation data collected from these wells indicate that, generally, groundwater flows from Jerry's Pond to the north in the direction of Whittemore Ave. However, groundwater flow is obviously significantly influenced by the MBTA redline tunnel. A review of groundwater elevation contour diagrams prepared by H&A from data collected during December 1986, February 1987, April 1987, May 1987, August 1987, October 1987, December 1987, February 1988, May 1988, September 1990, March 1991, September 1991, March 1992, September 1992, and December 1994, was conducted. These groundwater contour diagrams show that there is Audit . AMBRIDGE,er II Classification RTN 3-0277 Page 19

a component of groundwater flow from the vicinity of B204, B205, B207, B704, B705, B707, 2806 and B807 toward the MBTA tunnel. The gradient is more pronounced in earlier diagrams, and appears to become less pronounced in the later diagrams.

It is clear that groundwater from the site flows toward the north, in the direction of residences located along the north side of Whittemore Avenue. In an effort to determine if contaminated groundwater could potentially impact residential basements on Whittemore Ave, a review of groundwater quality information from wells B8, B501, B601A, B602A, B801, B802, B803, B901 and B902 was performed. The following table presents information regarding the presence/absence of VOCs in these wells on various sampling dates. Concentrations of detected VOCs are in pg/l:

B8 8/10/84, 11/26/85, 12/ 2/86 & 8/ 4/87- no- VOCs detected (ND). B501 2/ 1/85- 1,1,1-TCA @ 26; 11/26/85- 1, 1-DCE @ 5; 1,1-DCA @ 3; carbon tetrachloride @ 13; 12/ 2/86- methylene chloride @ 82; 1,1,1-TCA S 2.5; 6/10/87- ND. B601A 12/ 2/86- methylene chloride @ 54; 6/ 8/87- ND. B602A 12/,2/86- methylene chloride @ 42; 6/11/87- naphthalene @ 13. B01 6/10/87 & 11/11/87- ND. B802 6/ 8/87- ND; 8/ 4/87- ND; 11/11/87- chloroform @ 2.6. B803 6/ 8/87 & 11/11/87- ND. B901 1/21/88- chloroform @ 16 and bromodichloromethane @ 5.5. B902 1/21/86- ND.

It should be noted that some of these samples contained very low levels of PAHs and metals, at concentrations which are presumed to approximate background conditions for groundwater in this area. As previously stated, chloroform and bromodichloromethane are commonly found in public water supplies that have been treated with chlorine. - Also, methylene chloride is a very common laboratory contaminant, so the detection of methylene chloride may be the result of laboratory contamination.-

Based on the above information, the writer concludes that although groundwater may occasionally infiltrate into residential basements during heavy precipitation events, there does not appear to be any potential for contaminated groundwater to impact residential basements in the Whittemore Avenue area. However, in an effort to respond to concerns from neighboring residents, and due to the fact that these downgradient wells have not been sampled in many years, the writer recommends that W.R. Grace conduct additional sampling of the wells along Whittemore Avenue. At least one additional round of groundwater quality analyses from these wells should be performed to confirm that groundwater quality is consistent with historical data, and to further demonstrate that contaminated groundwater will not impact residential basements in the neighborhood. 4 e! ..

Tier II Classification Audit CAMBRIDGE, RTN 3-0277 Page 20

The writer has also evaluated the potential for contaminated groundwater to impact residential basements along Clifton and Harvey Streets. There have been reports of groundwater infiltrating into residential basements in this neighborhood since the restoration of Russell Field. These groundwater infiltrations are likely due to the fact that when Russell Field was restored by the MBTA after construction had been completed, the final grade elevation of the field was raised by almost 5 feet. This 5-foot increase in the final grade elevation of Russell Field has resulted in a loss of flood storage capacity in the vicinity of the field and Grace property, and has changed the surface water runoff characteristics in the area. In a letter from the MBTA to the City of Cambridge dated May 4, 1987, the MBTA states the following:

It is a well known fact among North Cambridge residents that the northeast corner of Russell Field along with the adjacent W.R. Grace land have historically flooded in the high water periods that typically occur throughout the year. When Russell Field was restored in 1986 by the MBTA after the Red Line Extension construction, a major effort was successfully made toward improving the field's drainage conditions, especially in recreational areas. The northeast corner of the (Grace] site, however, along with the land of adjacent property owners, is low relative to the nearby existing storm drains and surface drainage features, thus making it difficult to treat this drainage problem. The use of grade separation walls, a pump station, or a new storm drain system were beyond the responsibilities and scope of the MBTA's restoration contract.

In light of the above, the writer concludes that the flooding experienced by the Clifton/Harvey St. neighborhood since the reconstruction of Russell. Field is likely the result of the alteration of surface grades and surface water flow patterns. The writer recommends that the City of Cambridge evaluate the feasibility of extending the storm drain system to the areas prone to flooding, in an effort to alleviate this situation.

Finally, with respect to the possibility that contaminated groundwater could potentially impact residences in the Clifton Street neighborhood, due to the fact that there are no monitoring wells in this area, it is not possible to determine if contaminated groundwater exists in this area. However, the overall groundwater flow direction would put this neighborhood in a cross-gradient location to the area of the most severe groundwater contamination. If W.R. Grace has demonstrated that contaminated groundwater has not/will not impact residential basements in this area, the "... data and analysis on which that conclusion is based ... " could not be located -in the file. The writer recommends that the Department require W.R. Grace to provide, or re-provide as the case may be, ... the data and analysis on which that conclusion is based ... .0 S AMBRIDGE,ier II Classification RTN 3-0277 Audit Page 21

RUSSELL FIELD

A concern expressed by many residents in the local community is the potential for the surface soil of Russell Field to be contaminated with contaminants from the site; and thus, the opportunity for children who may be playing at the field to be exposed to contaminants at that location. Russell Field was used by the MBTA as a staging area for equipment while the Redline Extension and the Alewife parking garage were being constructed. In addition, a portion of the field was excavated in order to construct the subway tunnel between Alewife Brook Parkway and Harvey Street. Another expressed concern has been the potential for contaminated material from the Grace site to have been deposited at the field through wind borne transport.

On Monday, May 20, 1996 the writer inspected records in the possession of the MBTA regarding the MBTA's reconstruction of the field. The writer reviewed several sets of photographs of the field reconstruction activities. The first set of photos, dated March 27, 1986, showed large piles of apparently clean sand stockpiled at the location of Russell Field. These piles had a shape which was apparently formed by their deposition on the ground surface directly from dump trucks. This sandy material contained rounded gravel and cobbles indicative of deposition in a lacustrian environment, likely derived from a sand/gravel pit deposited by glacial activity.

The next set of photographs, dated April 30, 1986, showed additional sandy material dumped at the site, while grading of the field had been underway. In this set of photos, it is apparent that the new grade of the field is elevated above the previously existing and surrounding land surfaces. Contract documents in the possession of the MBTA state that Russell Field was restored at an elevation approximately 5 feet above the previously existing grade. These photos also show darker colored loam spread across portions of the fields.

The final set of photos, dated May 29, 1986, showed a full, lush carpet of grass being watered by an underground irrigation system. Due to the fact that the 4/30/86 photos show freshly spread loam and no grass whatsoever, the turf visible in the 5/29 photos must be sod, due to the fact that grass seed could not produce the lush blanket of turf visible in the photos in such-a short amount of time.

The light yellow color of the deposited material indicates that it was deposited in an environment containing very little O organic matter. The morphology of the visible gravel and cobbles indicate that the material was likely deposited in a high-energy environment, such as a river bed having high stream flow t er IX Classification Audit ZBRIDGE, RTN 3-0277 Page 22

velocities, or a similar fluvial environment. The geology at the site does not indicate that the above depositional environment was present at the site in the past.

Based on the photographs documenting the reconstruction of Russell Field, and because the material used to reconstruct the field is not present in the subsurface at the site, the writer concludes that the observed sandy fill was brought to Russell Field from a location other than the disposal site. It is the opinion of the writer that the field was likely reconstructed with apparently clean, sandy fill obtained from a location other than the W.R. Grace site. However, to definitively resolve the issue, a test pit/boring and environmental testing program is recommended. It is the Department's understanding that the City of Cambridge may perform such a program in the near future as part of activities associated with the improvement of the Russell Field recreational facilities.

Regarding the concern that contaminated material from the Grace site may have been transported to the surface of Russell Field through wind action, the writer offers the following comments: If there is contaminated material at the surface of the field, such material must have been transported there after the reconstruction of the field was completed in 1986. Because all process wastes placed at the site during the course of the manufacturing operations were removed in 1981 and 1982, it is not possible for process wastes to be present at the surface of Russell Field.

Public Involvement Plan Compliance

As part of this audit, BWSC/NERO Public Involvement Coordinator Karen Stromberg reviewed the Public Involvement Plan developed for the site, and public comments received on the draft Plan. Based on that review, no violations were identified. However, in responding to the comments raised during the public comment period, W.R. Grace misinterpreted section 40.1405(5) (c) of the MCP and limited their Response Summary to just the comments specifically on the draft Plan. W.R. Grace did in fact answer all other comments received in separate letters to the commentors. Because the Response Summary should have included all comments raised, W.R. Grace addressed this issue by amending Appendix G of the Plan to include all comments and responses.

It should also be noted that the Plan does not include any future public meetings. While no additional public meetings are specifically required by M.G.L. c. 21E or the MCP, the public should determine whether future meetings -are held during the cleanup process. If there is sufficient interest, the Department recommends holding meetings prior to public comment periods on Audit Ser WBRIDGE, II Classification RTN 3-0277 Page 23

specific MCP documents. This allows the public to become educated about the contents of the document, and will provide W.R. Grace with better comments. W.R. -Grace is also reminded that the Information Repositories established for the site should include a complete copy of the entire site file.

AUDIT CONCLUSIONS

The writer recommends that an Audit Findings be prepared as follows:

IV. SUMMARY OF VIOLATIONS

A. Violations That Require Further Action: On the basis of the information reviewed during the audit and in reliance upon the accuracy of that information, the writer has found that W.R. Grace is in non-compliance with one or more laws, regulations, orders, permits, or approvals enforced by the Department. The activity which is in noncompliance and the actions the writer recommends W.R. Grace to take to come into compliance are described in the Noncompliance Summary contained in the Notice of Audit Findings.

V. SUMMARY OF DEFICIENCIES

A. Deficiencies that Require Further Action. The writer has identified the deficiencies listed below. Steps which should be taken to correct each deficiency are also listed.

Deficiency: The Department's NOR to W.R. Grace included the following requirement: "The possibility of contaminated groundwater from the site entering basements of off- [property] residential buildings must be evaluated. If such a condition can not be ruled out, mitigating measures must be considered. If it can be ruled out, the data and analysis on which that conclusion is based must be thoroughly documented. . . The Department does not have the "... data and analysis ... " which demonstrates that contaminated groundwater has not/will not impact residential basements in the Harvey Street/Clifton Street neighborhood. . AMBRIDGE,ier II Classification RTN 3-0277 Audit Page 24

Steps to be taken to correct deficiency: The Department should request that W.R. Grace provide the necessary information which demonstrates that contaminated groundwater has not/will not impact the residences in the Harvey Street/Clifton Street neighborhood.

B. Deficiencies that do not Require Action. No further steps are necessary to correct this deficiency since it was corrected prior to/during the course of the Audit.

Deficiency: In responding to the comments raised during the public comment period, W.R. Grace misinterpreted section 40.1405 (5) (c) of the MCP and limited their Response Summary to just the comments specifically on the draft Plan. W.R. Grace did in fact answer all other comments received in separate letters to the commentors. Because the Response Summary should have included all comments raised, W.R. Grace addressed this deficiency by amending Appendix G of the Plan to include all comments and responses. 4 44 *

Attachment C

NONCOMPLIANCE SUMMARY ENTITY IN NONCOMPLIANCE

W.R. Grace Company-Conn.

LOCATION WHERE NONCOMPLIANCE OCCURRED OR WAS OBSERVED

62 Whittemore Avenue, Cambridge, Massachusetts

DATE(S) WHEN NONCOMPLIANCE OCCURRED OR WAS OBSERVED

August 9, 1995

DESCRIPTION OF NONCOMPLIANCE AND THE REQUIREMENTS NOT COMPLIED WITH:

On August 9, 1995, the Department received a Tier Classification Submittal for the above-referenced location. The following violations were identified in the Numerical Ranking Scoresheet:

Violation of 310 CMR 40.1503 (2) : 310 CMR 40.1503 (2) states in part "... In rendering fan LSP Tier Classification Opinion, the LSP shall consider the data, facts and other information known about a disposal site . . . ." As detailed in the Department's Audit Memorandum dated July 25, 1996, all the data, facts and information were not considered in rendering the LSP Tier Classification Opinion for this disposal site.

Violation of 310 CMR 40.1505 (2) (d) and 310 CMR 40.1512 (4): 310 CMR 40.1505 (2) (d) states "310 CMR 40.1512 (4) shall be applied to establish the score for Air Exposures for Subsection II.D." 310 CMR 40.1512 (4) states that a score of 15 points shall be assigned to Subsection II.D. if: "A release, or potential release, of OHM to air has been identified;" and/or "An odor that is reasonably attributable to a release of OHM at the disposal site has been identified." Although both of these statements are true with respect to the disposal site, the corresponding score of 15 points was NOT assigned to Subsection II.D. Failure to assign the required 15 points to Subsection II.D. is a violation of 310 CMR 40.1505 (2) (d) and 310 CMR 40.1512 (4).

Violation of 310 CMR 40.1506 (1) (e) 1.: 310 CMR 40.1506 (1) (e) 1. states: "The Disposal Site Hydrogeolocgy Score shall be indicated in Table III.D. of 310 CMR 40.1511. This score shall be based on ranges of depths to groundwater and soil permeability specified in this section as follows: (1) The highest identified seasonal groundwater level shall be used for the depth to groundwater. . . ." Because the depth of as groundwater below the ground surface in well B-212 in December ONCOMPLIANCE SUMMARY age 2

1994 was less than 5 feet below grade, the depth to groundwater used to develop the score assigned to Subsection III.D. is not correctly identified. Failure to identify "... the highest identified seasonal groundwater level ... " and assign the appropriate score to Subsection III.D. are in violation of 310 CMR 40.1506 (1) (e) 1.

Violation of 310 CMR 40.1509(5): 310 CMR 40.1509(5) states "Section VI. of 310 CMR 40.1511 shall reference specific pages of the Phase I or other applicable Reports where the basis and Technical Justification for a score amendment are provided." Section VI of the NRS does not reference the specific pages of the applicable reports containing the Technical Justification for the score amendment to Subsection V.A., Protected Open Space. Failure to provide reference to the applicable reports is a violation of 310 CMR 40.1509 (5).

DESCRIPTION OF DEADLINE(S) OF ACTION TO BE TAKEN

Provide a revised NRS Scoresheet- and Form BWSC 107A to the Department by September 27, 1996. 0 S Edward Weagle@BWSC PRR@DEP NERO Cc: Bcc: From: Lisa Alexander@BWSC SMP@DEP NERO Subject: Date: Wednesday, May R, 1996 11:55:03 EDT Attach: Certify: N Forwarded by:

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This E-mail responds to your questions about exposure pathways at the W.R. Grace site. In addition, I have included a comment on the downside of allowing construction at this site without oversight.

Exposure Pathways:

The three exposure pathways you have listed are all pathways of concern.

As I recall, the risk assessment evaluated both the release of contaminated soil particles and the emission of volatile compounds to ambient air. If my memory is correct, it was concluded that neither pathway would pose a significant risk of harm. However, beccause risk assessment practices have changed significantly over the years, the assessment and its conclusions may not be in line with current regulations, guidance and practice.

There were intermittent odors from emission of naphthalene to ambient air. odor problems were identified as welfare issues, and, as I recall, the site management plan specified odor control measures during construction. Naphthalene can cause odors as concentrations lower than the odor threshold.

Air exposures in the MBTA tunnel were not included in the risk assessment. The MBTA had taken the land, knowing that it was contaminated, apparently removed contaminated excavated soil to various neighborhoods in and around Cambridge, and designed the tunnel in full knowledge of environmental conditions, so it seemed unreasonable to hold W.R.Grace responsible for the unhappy results. I advocated and supported the decision to exclude the tunnel from the risk assessment, but in retrospect, I regretted it. In principle, it may be more fair for the MBTA to address the tunnel problems they created, but in practice, they did not seem willing or able to address the problems adequately when problems arose later (1990 - 1991?).

Another pathway I do not recall evaluating is volatilization into the planned buildings. The vapor problems in the T tunnel may be indicative of potential problems at other locations. Ideally, indoor vapors should be evaluated quantitatively before buildings are constructed, so that any necessary vapor controll measures could be installed up front,

Other exposure pathways were also evaluated in the risk assessment, including direct contact with contaminated soil, but as I recall, no significant risk of harm was found.

Tier Classification/Oversight

From my previous experience, I would anticipate a lot of public concern and and questions once active development resumes. It seems to me that it would be eagier and more effic t in the long run to exercise continuing oversight than to have different DEP staff people responding to major issues on an ad hoc basis. However, I'm not sure whether oversight is feasible. November 19, 1995 A 4JQ

Ms. Veronica Wancho O'Donnell Haley and Aldrich, Inc. 58 Charles Street Cambridge, MA 02141

Dear Ms. O'Donnell:

I would like to submit the following questions and informational requests for your response under the Public Involvement Plan:

1. Please provide a legible map designating the location of groundwater monitoring well no. B820-OW and B825-OW (referred to in the September, 1991 Long term Groundwater Monitoring Report.) Several requests have been made for this map, but no map has been received.

2. Please provide a legible map that will show the location of all machine shops that have operated, or are operating, on the W.R. Grace property. Please explain in detail and provide relevant documentation of all processes and materials (including any and all solvents) used in vehicle, equipment, and facility maintenance, repair and cleaning. Please explain all procedures used for storage and disposal of both virgin and used solvents in any machine shop operations at all sites within the Grace property.

3. Please provide a complete history of all uses of Building Number 28.

4. In the 1988 environmental data report, Volume 1 of 7, it is stated that chlorinated volatile organic compounds have been detected at only one site (B20 1-OW). In the light of subsequent sampling results, is this statement true? Which other sample sites have revealed findings of CVOC's? Could W.R. Grace provide a comprehensive mapping over the entire decade and a half of sampling detailing the occurrences of these compounds? 9 .,,-% 2

5. Please provide maps with concentration isopleths for napthalene, acetone, BTEX, and chlorinated organics.

6. Please provide a legible map of W.R. Grace property lines.

7. Please provide a legible map of current groundwater flow paths.

8. Please provide legible maps of all sampling sites.

9. Volatile organic compounds have been detected at several sampling locations on Whittemore Avenue. Please explain their occurrence.

10. Based on your knowledge of the existing conditions in and around the subway tunnel, do you believe that existing clay at the W.R. Grace site will surround and protect any piles driven on the site?

11. Could you characterize and assess the status of contamination at Parkway Pond, with particular attention paid to all cumulative sampling results from groundwater, surface water and sediment samples to date.

12. The MBTA recently added a child care facility to the Alewife Station and a tot lot a short distance from a large vent. Are you satisfied that the children in these areas will not be adversely affected by any proposed construction? How do you propose to notify these children's parents of potential risks from remediation and construction activities?

13. Where were soils from the WR Grace site moved to during One Alewife Center and MBTA subway construction? Please provide any relevant copies of DEP/EPA/DOT manifest receipts. Please provide a point of contact for relevant transfer, storage and disposal facilities.

14. What are WR Grace's long-term plans for the portion of the site it would retain? Will there be any additional development phases beyond what is currently proposed?

15. Could you please request an estimate from the developer of the amount of auto pollution that will result if the current proposal for a shopping center is implemented. Please also 'S. 3

request supporting documentation. Can it be compared with similar estimates from the previous office proposal?

16. Would you compare both of these estimates with pollution produced by a no-build option.

17. If WR grace is responsible in part for polluting Alewife Brook, would WR Grace contribute in like measure to the brook's clean up?

18. If WR Grace was coincidentally responsible for polluting any adjacent land, would WR Grace assume responsibility for clean up?

19. If construction at the site proceeds, and a "sick building" is a result, will WR Grace assume any liability? How will WR Grace deal with a building that is too sick for occupancy?

20. Will you assess the nature, source and extent of contamination on the site.

21. Are you convinced that risk evaluations have taken into consideration the DUAL presence of napthalene and benzene? Are you aware of the most recent data on this subject?

22. What is the source of the "iron oxide" found at Parkway Pond?

23. Why was the Feasibility Study done before completion of the Long-term Groundwater Monitoring Report? Did W.R. Grace consider the original ordering of the separate points of the DEQE's NOR of 1987 as part of the intended protocol?

24. In 1979, several engineering reports advised against any significant construction at this site. Large concentrations of sulfuric acid and other corrosive contaminants such as napthalene posed a recognized and documented risk with regard to the MBTA subway construction. These reports advised against routing the subway through the Grace site, proposing rather a more expensive and circuitous alternative. In WR Grace's opinion do these formerly stated admonitions have any relevance to underground concrete construction currently contemplated (i.e. hotel parking)? Are you aware of any conditions or circumstances regarding the existing subway beneath the WR Grace site which would underscore the validity of these former engineering reports? If you were aware of such conditions, would it qualify your contention that the WR Grace site is in fact "clean"?

25. To what extent will WR Grace guarantee the integrity of any construction at its site?

Respectfully submitted,

Joseph J. Joseph 18 Dudley Street Box 593 Cambridge, MA 02140 cc: Department of Environmental Protection 0

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JOB: 12731 CUSTOMER :BOYNTON CO LOCATION :CONCORD MA SAMPLE DATE :09-08-95 LAB CONTROL NO. : 9507267 MATRIX :SOIL SAMPLE PERSON :ERIC GOMES SAMPLE I.D. :SIDE G REPORT DATE :09-15-95

POLYNUCLEAR AROMATIC HYDROCARBONS EPA METHOD 8100

PARAMETER RESULTS (ppm) MDL

NAPHTHALENE N. D. 1. Oppm 2 -METHYLNAPHTHALENE N.D. 1.Oppm PHENANTHRENE N. D. 1. Oppm

TOTAL PETTROLEUM HYDROCARBONS 40.6ppm 25. Oppm AS #2 FUEL OIL

VOLATILE AROMATIC COMPOUNDS (BTEX) EPA METHOD 8020-MODIFIED PARAMETER RESULTS (ppm) MDL

BENZENE N. D. 0. lppm TOLUENE N. D. 0. lppm ETHYLBENZENE N.D. 0.lppm TOTAL XYLENES N. D. 0.lppm

* EPA METHOD 8020 WAS MODIFIED BY AUTOMATIC STATIC HEADSPACE EXTRACTION (EPA METHOD 3810).

ANALYST:

P-0. BOX 119 + 1771 WASHINGTON STREET - STOUGHTON. MA 02072-0119 TELEPHONE 617-344-0265 - 1-800-242-5838 (Mass.) FAX 617-344-3318 0 0

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CUSTOMER BOYNTON CO LOCATION CONCORD MA JOB # 12731 SAMPLE DATE 9/08/95 LAB CONTROL NO. 9507268 MATRIX SOIL SAMPLE PERSON ERIC GOMES SAMPLE I.D. STOCKPILE 1 REPORT DATE 9/18/95

PARAMETER RESULTS MDL METHOD TOTAL PCB CONTENT AS AROCLOR 1016, 1221, 1232, 1242, 1248, 1254, N.D. ppm 2 EPA 8080 1260, 1262 & 1268 REACTIVE CYANIDES N.D. ppm 5 SW846 7.3 REACTIVE SULFIDES N.D. ppm 5 SW846 7.3 FLASHPOINT >200 F 20 EPA 1010 pH 6.5 EPA 9045

TOTAL PETROLEUM 1811.1 ppm 25 EPA 8100 HYDROCARBONS

TRACE METALS PARAMETER RESULTS MDL METHOD TOTAL LEAD N.D. ppm 3 EDXRF TOTAL CHROMIUM 5.7 ppm EDXRF TOTAL ARSENIC N.D. ppm EDXRF TOTAL CADMIUM N.D. ppm 1 EDXRF TOTAL BARIUM N.D. ppm 30 EDXRF TOTAL MERCURY N.D. ppm 3 EDXRF TOTAL SILVER N.D. ppm 1 EDXRF TOTAL SELENIUM N.D. ppm 3 EDXRF METELS TESTED BY ENERGY DISPERSIVE X-RAY FLUORESCENCE SPECTROMETRY.

ANALY:

P.0 BOX 119 - 1771 WASHINGTON STREET - STOUGHTON. MA02072-0119 TELEPHONE 617-344-0265 - 1-802d?-5R IMo F 71AA- '1 0 S

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CUSTOMER BOYNTON CO LOCATION CONCORD SAMPLE DATE 9/08/95 LAB CONTROL NO. 9507268 MATRIX SOIL SAMPLE PERSON ERIC GOMES SAMPLE I.D. STOCKPILE 1 REPORT DATE 9/18/95

EPA 8240 VOLATILE ORGANIC COMPOUNDS PARAMETER RESULTS MDL

ACETONE N.D. ppm 0.1 ACETONITRILE N.D. ppm 0.1 BENZENE N.D. ppm 0.1 2--BUTANONE (MEK) N.D. ppm 0.1 tert-BUTYL ALCOHOL (TBA) N.D. ppm 0.1 CARBON DISULFIDE N.D. ppm 0.1 CARBON TETRACHLOR IDE N.D. ppm 0.1 CHLOROBENZENE N.D. ppm 0.1 CHLOROFORM N.D. ppm 0.1 1, 2 -DICHLOROBENZENE N.D. ppm 0.1 1,3 -DICHLOROBENZENE N.D. ppm 0.1 1, 4-DICHLOROBENZENE N.D. ppm 0.1 1,L-DICHLOROETHANE N.D. ppm 0.1 1,2-DICHLOROETHANE N.D. ppm 0.1 1,1-DICHLOROETHENE N.D. ppm 0.1 TRANS -1,2 -DICHLOROETHENE N.D. ppm 0.1 1, 2-DICHLOROPROPANE N.D. ppm 0.1 1,3 -DICHLOROPROPANE N.D. ppm 0.1 ETHYLBENZENE 0.53 ppm 0.1 HEXACHLOROBUTADIENE N.D. ppm 0.1 2 -HEXANONE N.D. ppm 0.1 ISOBUTYL ALCOHOL NW. ppm 0.1 ISOPROPYLBENZENE N.D. ppm 0.1 METHYLENE CHLORIDE N.D. ppm 0.1 4-METHYL -2 -PENTANONE N.D. ppm 0.1 MBTE N.D. ppm 0.1

PO. BOX 119 -1771 WASHINGTON STREET- STOUGHTON,MA020720119 TELEPHONE 617-344-0265 . 1-800-242,5818 (Mass.) - FAX 617-344 3318 0 cvYR HI 1 RD0/ Af E AH. ERV IcEs

PG 3 OF 3

CUSTOMER BOYNTON CO LAB CONTROL NO. CONCORD SAMPLE I.D. STOCKPILE 1 REPORT DATE 9/18/95

EPA 8240 VOLATILE ORGANIC COMPOUNDS (CONT)

PARAMETER RESULTS MDL N-PROPYLBENZENE N.D. ppm 0.1 PYRIDINE N.D. ppm 0.1 STYRENE N.D. ppm 0.1 1,1,1,2-TETRACHLOROETHANE N.D. ppm 0.1 1, 1,2, 2 -TETRACHLOROETHANE N.D. ppm 0.1 TETRACHLOROETHANE N.D. ppm 0.1 TETRACHLOROETHYLENE N.D. ppm 0.1 TOLUENE 0.32 ppm 0.1 1, 2,3 -TRICHLOROBENZENE N.D. ppm 0.1 1,1,1-TRICHLOROETHANE N.D. ppm 0.1 1, 1,2-TRICHLOROETHANE N.D. ppm 0.1 TR:ICHLOROETHENE N.D. ppm 0.1 TRICHLOROFLUOROMETHANE N.D. ppm 0.1 1,2,3 -TRICHLOROPROPANE N.D. ppm 0.1 1,2,4-TRIMETHYLBENZENE N.D. ppm 0.1 1,3, 5-TRIMETHYLBENZENE N.D. ppm 0.1 VINYL CHLORIDE N.D. ppm 0.1 XYLENE(S) 1.36 ppm 0.1

METHOD; VOLATILE ORGANIC COMPOUNDS WERE EXTRACTED BY ===t= = EPA 3810 (STATIC HEADSPACE EXTRACTION) AND ANAYZED BY EPA METHODS 8021 (HALOGENATED AND AROMATIC VOLATILES BY GAS CHROMATOGRAPHY USING AN ELECTROLYTIC CONDUCTIVITY DETECTORS IN SERIES: CAPILLARY COLUMN TECHNIQUE) AND EPA METHOD 8015 (NON HALOGENATED VOLATILE ORGANICS BY GAS CHROMATOGRAPHY).

ANALYST: 74r/A117

1 P.O BOX 119 . 1771 WASHINGTON STREET - STOUGHTON MA 02072-0119 TELEPHONE 617-344-0265 - 1-800-242-5818 MassI . FAX 617-344-33 8 0

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CERTIFICATE OF ANALYSIS

LAB I.D. NO.: 9507269 CUSTOMER NAME: BOYNTON CO LOCATION: CONCORD SAMPLING DATE: 09/08/95 SAMPLING PERSON :ERIC GOMES SAMPLE NO.: STOCKPILE 2 MATRIX: SOIL REPORT DATE: 09/15/95

PARAMETER RESULTS (ppm) MDL

TPH 2122.9ppm 25.Oppm

METHODOLOGY: SOILS WERE EXTRACTED BY EPA METHOD 3550 (SONICATION) TPH BY GC/FID METHOD EPA8100 ANALYST:

PO. BOX 119 - 7771 WASHINGTON STREET- S TOUGHTON, MA 02072-0119 TELEPHONE 617-344-0265 - 1-800-24?5818 tMqI. - A 817 44 -3318 0

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1-800-8226365 outside Mass 900 EAST FIRST STREET It00-2425818 in Mass. FiRST FLOOR TEL 617464J70 SOUT BOSTON.MAOZ127 FAX 617-464.5382 A% ~ UNITED STA ES ENVIRONMENTAL PROTECTION AGENCY REGION I

J.F. KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 02203-2211

7, July 1995 SI TE: ql

W.R. Grace & Co., Inc. Attn: Mr. David Wrightman, VP 62 Whittemore Avenue - - Cambridge, MA 02140

Dear Mr. Wrightman:

I am writing to inform you of a United States Environmental Protection Agency (EPA) decision regarding the.W.R. Grace located at 62 Whittemore Avenue in Cambridge, Massachusetts (EPA Identification Number: MAD001409150).

Based upon the information available, EPA has determined that a "No Further Remedial Action Planned" or NFRAP decision is appropriate, and no further work is anticipated at this site by the federal Superfund Site Assessment program. Sites receive a NFRAP decision when the federal Superfund Site Assessment program has completed its assessment of a site, and has determined that no further steps will be taken to list that site on the National Priorities List (NPL), a list of the nation's worst hazardous waste disposal sites.

The NFRAP decision does not necessarily mean that there is no hazard associated with this site; it means only that based upon currently available information, this site is not judged to be a potential NPL site. Sites assigned NFRAP decisions are removed from EPA's Comprehensive Environmental Response, Compensation and Liability Information System (CERCLIS) database, and archived as historical records to ensure EPA does not needlessly repeat the investigations in the future.

Further actions may be taken at sites with NFRAP decisions by the Superfund Removal program, other EPA or federal programs, or by state and local programs. Enclosed in this package is a letter from the Massachusetts Department of Environmental Protection reminding you of this site's status and your obligations under the Massachusetts Waste Site Cleanup program.

Finally, NFRAP decisions may be changed based upon new information or other considerations which make a recommendation for listing appropriate at a later time. In such an instance, you will be notified and the site will be returned to the CERCLIS o database with the NFRAP decision removed.

PRINTED ON RECYCLED PAPER Please contact me at (617) 573-9697 if you have any questions concerning this NFRAP designation, or the removal of this property from the CERCLIS database.

Sincerely,

-Nancy S th Site Assessment Manager Waste Management Division

cc: Mr. Harish Panchal, MA DEP Commonwealth of Massachusetts Executive Office of Environmental Affairs Department of D Environmental Protection William F. Weld Governor Trudy coxe Secretary, EOEA David B. Struha Commissioner May 10, 1995

Dear Sir or Madam:

I am writing to you about the U.S. Environmental Protection Agency's (EPA's) decision to assign -"No Further Remedial Action Planned" ("NFRAP") designations to certain sites in Massachusetts and to remove these sites from the Federal inventory of known and suspected hazardous waste disposal sites (the Comprehensive Environmental Response, Compensation and Liability Information System or "CERCLIS" database), and to inform you about what continuing obligations there may be for these sites under the Massachusetts Waste Site Cleanup Program.

The Federal "Superfund" Program was established in 1980 to provide funding and a process to clean up the nation's worst hazardous waste sites. To be eligible for long-term cleanup actions in the Superfund program, a site must be contaminated with hazardous materials and deemed to pose a high enough risk (as determined by a hazard ranking system) to be listed on EPA's National Priorities List (NPL). Candidate sites for ranking to determine NPL eligibility are placed on the Federal CERCLIS database.

If EPA determines that a site on CERCLIS does not pose a high enough risk to warrant inclusion on the NPL, or is contaminated with oil only, EPA assigns a NFRAP designation to the site and removes it from the CERCLIS database. Sites with NFRAP designations may still pose serious risks to human health and the environment -- a NFRAP designation simply means that a site is not eligible for NPL listing and can be handled by other (in most cases State) cleanup programs.

EPA has assigned a NFRAP designation to the site shown below and removed it from the CERCLIS database., Pursuant to M.G.L. c. 21E and the Massachusetts Contingency Plan (310 CMR 40.0000, the "MCP"), this site is currently listed as a nonpriority disposal site without a Waiver on DEP's Transition List of Confirmed Disposal Sites and Locations To Be Investigated.

WR GRACE & CO, INC DAVID WIGHTMAN, VICE PRESIDENT 62 WHITTEMORE AVENUE, CAMBRIDGE, MA 02140- State Id: 3-0000277 EPA Id: MAD001409150

One Winter Street * Boston, Massachusetts 02108 . FAX (617) 556-1049 e Telephone (617) 292-5500 Our information indicates that you have a connection to the above referenced site or location as a landowner, facility owner or operator, generator or transporter of oil or hazardous material, or another type of connection. The MCP (most recently revised on January 13, 1995) contains specific requirements that must be met by those legally responsible for nonpriority disposal sites (see 310 CMR 40.0636), including deadlines for submission of required documentation.

In summary, the MCP requires nonpriority disposal sites to be assessed to determine whether a release of oil and/or hazardous material has occurred which requires notification to the Department (310 CMR 40.0300) and whether additional response actions are required. A Licensed Site Professional (LSP) Evaluation Opinion must be submitted by a specific deadline providing a determination that either:

1) there has not been a reportable release and no additional response actions are necessary; 2) a reportable release- has occurred but previous response actions were sufficient to satisfy the requirements of a Class A or B Response Action Outcome (310 CMR 40.1000) and no further response actions are necessary; 3) a reportable release has occurred and additional response actions are necessary.

If a reportable release has occurred and additional response actions are required (option 3), the site must be tier classified by the applicable deadline unless a Response Action Outcome can be achieved by the deadline.

If a Phase I Report was submitted to DEP prior to October 1993 which specifically states that no further response actions are necessary at the site, you may submit, in lieu of the above mentioned LSP Evaluation Opinion, a statement affirming that the conclusions reached and recommendations made are supported by the information contained in the Phase I Report. An LSP is not required for this statement, but the no further action recommendation will not become effective until approved by DEP.

The location which is the subject of this letter was originally listed by the Department as a nonpriority disposal -site on 1/15/87. Therefore, the deadline for achieving the requirements summarized above is 8/2/95. The requirements for nonpriority disposal sites can be found in more detail in 310 CMR 40.0636. It is recommended that you review this section of the MCP.

If you have additional questions about the MCP requirements for the above referenced site, please call the MCP Hotline, part of DEP's InfoLine. Dial 617-338-2255 from the Boston area and outside of Massachusetts, or 1-800-462-0444 from area codes 413 and 508 (press 1 at the first menu option).

Sincerely,

- Jamcf C. Colman Assi.A tant Commissioner Bureau of Waste Site Cleanup Since the inception of the Federal "Superfund" program in 1980, and the Massachusetts Waste Site Cleanup program in 1983, hazardous waste disposal sites in Massachusetts have been subject to separate but overlapping Federal and State environmental regulations. In some instances, this has led to duplication of effort by the State and Environmental Protection Agency (EPA) New England, and confusion in the regulated community as to which program requirements apply in any given situation. EPA New England, in partnership with the Commonwealth, has been working for the past year to revamp the Superfund program and to better integrate the Federal and State programs so that they enhance rather than conflict with or duplicate one another.

As part of this new approach, EPA New England and the Massachusetts Department of Environ- mental Protection are reviewing the status of sites listed in the Federal inventory of known and suspected hazardous waste disposal sites (the Comprehensive Environmental Response, Compen- sation, and Liability Information System or "CERCLIS" database). To date, more than 300 Massa- chusetts sites have been assigned "No Further Remedial Action Planned" -(NFRAP) designations by EPA New England, indicating that they have been evaluated and found to be ineligible for inclusion on the National Priorities List (NPL) of "Superfund" sites, the list of the nation's worst hazardous waste disposal sites.

To make more efficient use of public and private resources, clarify for the regulated community which program requirements apply, and redress the perceived "stigma" of being listed in CERCLIS, EPA New England is now removing those sites from CERCLIS which have received the NFRAP designation. The NFRAP designation does not necessarily mean, however, that these sites are "clean". It means only that the sites have been evaluated and found to be ineligible for further investigation under the Federal Superfund program because they do not qualify for inclusion on the NPL. Sites may be ineligible for the NPL for a number of reasons. For example, the threats posed by a particular site may not be severe enough to be among the nation's worst; or a site may have been contaminated by petroleum releases, which are excluded from the Federal Superfuxnd program. Sites receiving Federal NFRAP designations may also be subject to State jurisdiction. While some NFRAP s&is may be ready for immediate reuse or redevelopment, others still have significant environmental issues which must be addressed via the Massachusetts Waste Site Cleanup program.

Enclosed you will find specific information concerning the status of your property with regard to the Federal Superfund Site Assessment program and the Massachusetts Waste Site Cleanup- ogram.

James C. Colman, Assistant Commissioner ida M. Murphy, Direcor Bureau f Waste Site Cleanup Waste Management Division MA Department of Environmental Protection EPA New England April 1995 Fact Sheet 02 (NFRAP-MA) MEMORANDUM

TO: John Fitzgerald, P.E., Principal Sanitary Engineer FROM: Nancy Bettinger, Environmental Analyst I DATE: March 17, 1987

Subject: CAMBRIDGE - W.R.Grace and Co.; Plan for implement- ting requisite site actions.

On March 17,1987, the writer met with Wes Stimpson and Stan Fielding of Haley and Aldrich, Inc., Laura Green of Meta Systems Inc., and Mark Stoler of W.R.Grace and Co.. The purpose of the meeting was to discuss plans for fulfil- ling the requirements outlined in the "Notice of Responsi- bility" letter sent to W.R.Grace on February 9, 1987.

At the beginning of the meeting, the sequence of investigation activities and written submittals was discussed briefly. The writer suggested that interim letter reports on the progress of the investigation would probably expedite the assessment and approval processes, even though a summary site investigation report would be required in the end. The writer also noted that the site investigation should be designed to provide the data necessary for the risk assessment and feasibility study, and therefore these three segments of the project should be conducted concurrently. The consultants agreed and stated they were already taking this approach.

Wes Stimpson noted that additional data requirements fall into two categories: (1) data necessary for the risk assessment and (2) data necessary to determine the presence or absence of continuing sources of contamination. It was estimated that data collection would not be complete for at least three months, and that the site investigation report and risk assessment would be submitted about one month after that. After a specific plan for collecting and analyzing additional samples has been completed, the consultants will meet with the writer to assure that the Department's concerns are addressed before the sampling program begins.

Wes Stimpson then proceeded to outline plans for meeting each task required by the "Notice of Responsibility" letter in the "Requisite Site Action" section, points 1 through 7 and 9:

1) To determine the location and identity of all former storage tanks, Haley and Aldrich will again review all available W.R.Grace and Dewey and Almy plans, as well as City of Cambridge permits. The inventory will include both underground and above ground storage tanks. Additional interviews with long-time W.R. Grace.employees will be conducted to identify past and C'

present uses of all site buildings. State files will be checked for records of NPDES and RCRA permits. Haley and Aldrich will examine any aerial or ground-level photos available from the EPA, DPW, Cambridge Historical Society and W.R.Grace. All available engineering reports concerning the sludge investigation and removal program conducted in conjunction with MBTA construction activities on site will be studied to confirm the location of the disposal areas and to ascertain that all of the sludge has been removed. DEQE records will be reviewed to better characterize how the waste was handled in the process of storing, treating and removing sludge from the site. Haley and Aldrich will obtain City of Cambridge and W.R. Grace records to determine the location and structure of utility lines in the vicinity of the site. The W.R.Grace plans will also be checked for any pits or sumps not pre- vioiusly identified. The MBTA tunnel underdrainage system will be evaluated, and possibly sampled. Locations of potential continuing contamination sources will be identified and compared with nearby sampling locations. Groundwater samples will be used to ascertain whether a location is a continuing source, since soil samples would only reflect very localized conditions, and data from soil analysis would not provide information on contaminant migration. After evaluating the information gathered through these activities, Haley and Aldrich will recommend additional sampling if necessary.

2) Worst case estimates may not provide the best information for evaluating public health and environmental impacts. (The writer noted that the "worst case" estimates were often useful when it is not feasible to obtain accurate and precise data, or in determining the need for further investigation to obtain more accurate data).

3) Plans for investigating areas of the site not slated for development will be based on information collected as outlined in paragraph (1) above. The two areas of concern are the northeast side of the site and the portion south of the MBTA line. Sediments from Jerry's Pond will be sampled for the risk assessment. Additionally, the use of the Grace property north of Whittemore Avenue for parking only will be documented. (Mark Stoler noted that while W.R.Grace had accepted responsibility for evaluating the entire Grace property without respect to development plans, the environmental condition of off-site areas included in the development parcel but not impacted by W.R.Grace would be addressd separately.)

4) Haley and Aldrich is in the process of validating all data that they produced for the April 1985 report as well as for more recent phases of the investigation. Quality assurance/quality control information will not, however, be available for much of the data collected in the past by other consultants. Much of the analysis was done before EPA sampling and analysis protocols were in use. Such data must therefore be evaluated on a more subjective basis. In determining the relevance of previous analytical data to present site conditions, Haley and Aldrich will determine whether the material sampled can be identified, whether that material is still present on the site, how the samples were collected, and how the samples were tested. The possibility that some of the compounds identified were actually laboratory contaminants will be considered. Compounds that were detected in the past but not in more recent samples will be compared with priority pollutant compounds to determine whether the discrepancies may be due to differences in analytical procedures, and whether those compounds would show up in a priority pollutant analysis if they were present. (The writer agreed that this approach was satisfactory, and that retrospective validation of other consultant's data would not be possible. The intent of the requirement simply was to establish a consensus on the utility of various data sets.)

5) A long-term on-site groundwater monitoring plan will be developed, and will ultimately be integrated with the off-site monitoring program.

6) Haley and Aldrich is in the process of compiling the documentation for the groundwater model. The model and the documentation will be ready for review soon.

7) The location of underground utility lines will be determined as outlined in the first paragraph of this section. This information will be used with data on groundwater levels and contaminant concentrations to evaluate the importance of utility lines for contaminant transport at the site. This requirement may be fulfilled as part of the risk assessment rather than the site investigation.

9) To evaluate the possibility of contaminated groundwater from the site entering basements of off-site residential buildings, Haley and Aldrich will conduct a systematic survey of the homes in the area between Seagrave Road and Whittemore Avenue. Haley and Aldrich will request assistance from a community group in conducting a survey to find out which basements take in water. Additionally a piezometer will probably be installed in the neighborhood to measure groundwater levels relative to basement elevations.

Next Laura Green presented the plan for conducting the risk assessment. Preliminary decisions have been based on the 1985 and 1987 Haley and Aldrich data. The approach will be to focus initially on the risks expected to be highest and then proceed to those expected to be smaller. The potential exposure of greatest concern at the Grace site is inhalation of naphthalene vapors or naphthalene contaminated soil particles by particularly sensitive individuals. The sensitive population in this case is comprised of people with glucose 6 PB deficiency. This condition, combined with an acute exposure to high levels of napthalene, can lead to naphthalene-induced hemolytic anaemia. This reaction can result from an acute (short time period) exposure to high levels of naphthalene, but not from a chronic (long time period) exposure to low levels of naphthalene. The deficiency is more prevalent in blacks than caucasians, and the risk would be most significant for construction workers on site. Preliminary evaluations, however, suggest that the levels of naphthlalene detected on and near the Grace site would not result in an exposure high enough to produce the reaction. Since no naphthalene standard that considers the sensitive population is available, Laura Green will have to develop a standard based on data reported in research literature.

Exposures and risks associated with other contaminants detected on site will be estimated using standard calculations and assumptions. The numbers are expected to be very small, but a quantitative assessment is believed to be the most efficient way to characterize the risks and meet the requirements. Exposures will be evaluated for construction workers, neighbors, and, if possible, MBTA workers in the subway.

Efforts to obtain exposure information for the risk assessment will include the following: a) Haley and Aldrich will check with the MBTA for additional information on the sumps and under-drainage system. b) The potential for seepage of water into residential basements will be determined. c) Concentrations of groundwater contaminants in the upper levels of the aquifer will be determined, possibly by converting some of the deep wells on the site to shallow wells. d) To estimate levels of contaminants in surface soil, the highest concentrations found at depth in a particular area will be used, since surface concentrations of organics are likely to be lower if they differ at all from those at depth. e) Sediment samples will be collected from Jerry's Pond for chemical analysis. Based on those results, potential human exposures will be calculated using conservative methods and assumptions.

The on-going air monitoring data will be used in the risk assessment, but Laura Green cautioned that the utility of the data may be limited by the sensitivity of the measurements. Mark Stoler said he would provide the writer with the monitoring protocols as well as a rationale for the sampling plan in the near future. (The writer urged the consultants to reevaluate the monitoring program in light of their data needs, and to propose modifications accordingly.) Wes Stimpson then presented plans for the feasibility study and remedial action plan as outlined under points 10 and 11 in the Notice of Responsibility letter. These two parts of the study will be combined into one report. In the feasibility study, a coarse ranking system will be used to narow the list of all possible options down to two or three, which would then be discussed in greater detail. On site treatment options will be included. Clean-up criteria and indicator parameters will be proposed after the clean-up procedure is chosen.

In the process of excavating for development, a large quantity of oil-contaminated soil will have to be treated, if feasible, otherwise disposed. It is expected that this will also have the effect of removing significant quantities of soil containing residual amounts of other contaminants. The permits necessary to treat groundwater from de-watering operations during construction operations will be sought.

The feasibility study will include the option of "no action" in the event that site development plans would be abandoned. Wes Stimpson predicted that the risk assessment and feasibility study will indicate that no remedial action, including groundwater treatment, would be warranted if there is no development. He emphasized that the consultants would probably recommend groundwater treatment and soil removal only because groundwater would have to be pumped and residu- ally contaminated soil would be excavated during construction activities, thus creating the potential for additional releases and exposures.

After Wes Stimpson concluded the presentation of plans for conducting the investigation and preparing the reports, Mark Stoler raised some of his concerns about the process. He urged the writer to visit the site to observe the procedures when samples were collected on-site, and to split some of the samples for analysis. The writer responded that every effort would be made to be present, but advised him that collecting samples for the purpose of verifying analysis conducted by a private party is not considered to be an effective use of the Department's limited resources, and is prohibited by current operating policy. Mark Stoler also advised the writer that Dr. Spengler had submitted written comments on the Haley and Aldrich report to the Cambridge City council, and that at the present time, there were no specific plans for further involvement in the W.R. Grace project by Dr. Spengler'group. Mark Stoler also requested that, as much as possible, the City of Cambridge comments be reviewed, evaluated, and incorporated into the site assessment process by the DEQE. The writer agreed, and reiterated that the state would consider any recommendations from Dr. Spengler, and if it were shown that the suggested measures would help to evaluate or mitigate adverse public health or environmental effects, the DEQE would require W.R.Grace to carry out the recommendations.

Mark Stoler also noted that W.R.Grace will submit plans for Building 1 within the next two or three weeks.

After the presentation by the consultants, the writer addressed several unresolved issues. First, Wes Stimpson was asked to describe the pilings for the proposed buildings. He stated that, if pilings are driven, they would penetrate to the bedrock. Since the holes will not be pre- augured, however, the concrete sides of the pilings will be in contact with the clay and it will not be possible for contaminants to migrate down along the piling through the 70 foot clay layer to the underlying till or bedrock. If piles are driven, piezometers will be installed in the till layer. This will allow measurement of the vertical component of the hydraulic gradient, and will show whether arte- sian conditions exist below the clay layer.

Next, the need for multi-level wells was discussed. The writer stated that wells screened at two levels, in the silt and in the sand, would be beneficial for long- term monitoring and for designing the groundwater recovery wells, as well as for the risk assessment. Wes Stim- son said that for designing the treatment system, the concentration of contaminants in the silt was not important, because de-watering would be done for construction rather than treatment purposes, and would primarily draw groundwater from the more permeable sand layer. The writer suggested that the acceptability of converting existing wells to shallow wells should be determined before a decision on the number of additional wells necessary is made.

The issue of using visible oil as an indicator for soil removal was discussed briefly. The writer noted that the data in Tables I and III of Haley and Aldrich's draft "Sup- plemental Soil and Groundwater Data, Draft Environmentaal Impact Report", dated January 7, 1987, does not suggest a correlation between "visible oil in soil" and "other PAH's". The consultants agreed but Laura Green noted that the lack of correlation from sample to sample does not preclude the possibility that PAH's and other contaminants are most prevalent in oil contaminated areas and would be significantly reduced when the oil contaminated soil is removed. Further evaluation of the data will be necessary to determine whether such is the case. The writer stated that if the consultants proposed clean-up criteria based on the arguement that the levels of contaminants detected at this site are not high relative to those normally found in urban areas, they must present data to document the basis for the conclusions.

The writer emphasized that the surface water discharge permit for the proposed groundwater treatment system would be based on all contaminants contained in the effluent, including metals.

It was agreed that any available site information not included in the April 1985 report should be included in the site investigation summaryreport. Specifically, much of the information contained in Haley and Aldrich's "Report on Groundwater Investigation, W.R.Grace and Co." dated March 5, 1980 concerning site geology and vertical contaminant distribution should be incorporated into the final site investigation report.

The writer pointed out that the low levels of chlorinated solvents detected at B501-MW and surface water sampling point S-7 indicate a possible continuing source of these compounds in the area of the Grace site. While the levels and distribution of these compounds do not warrant their inclusion in the risk assessment or feasibility study at this time, W.R.Grace should determine whether a potential source of these compounds exists on the site.

At the end of the meeting, it was agreed that Haley and Aldrich would meet with the writer after the investigation plans were complete and before the field work was initiated to discuss the proposal. Press Release

Re: Cambridge - W.R. Grace Public Meeting Announcement Submitted to the Cambridge Chronicle on December 1, 1986

The Department of Environmental Quality Engineering will hold a public meeting to discuss the environmental assessment of the W.R.Grace property in North Cambridge. The meeting will be held on December 8 at 10:00 A.M. in the Sullivan Chambers in Cambridge City Hall. MEMORANDUM FOR THE RECORD

To: John Fitzgerald, P.E.,Principal Sanitary Engineer From: Nancy Bettinger, Environmental Analyst I Date: November 20, 1986

Subject: Meeting at W.R.Grace in Cambridge

On November 19, 1986, the writer met with Wes Stimson of Haley and Aldrich, consultant to Haley and Aldrich, and Joan Lastovica, engineer for the city of Cambridge, at the W.R.Grace facility in Cambridge, Massachusetts. The purpose of the meeting was to conduct a site survey, to discuss the status of the Department's review of assessment activities at the Grace site, and to plan the Pres- entation for the Public meeting scheduled for Decem- ber 8, 1986. MEMORANDUM FOR THE RECORD

TO: John Fitzgerald, P.E., Principal Sanitary Engineer FROM: Nancy Bettinger DATE: March 17, 1987

SUBJECT: CAMBRIDGE - W.R.Grace and CO., File review

This memo is a summary of the documents concerning the Grace site reviewed by the writer since the Notice of Re- sponsibility letter was sent to that company.

1) A report entitled "Groundwater Investigation, W.R.Grace and CO., Cambridge, Ma." dated March 5, 1980, containing the following information: - Boring logs and installation details for shallow single-point wells SW-1 through SW-8 and deep multi- level wells DW-1 through DW-10. These wells were concentrated in the study area south of the manufacturing facilities. - A description of stratigraphic features in the study area. - Evidence of higher (than 600 uMHOs) and lower (than 5.0) pH values indicate contaminated groundwater, and that the distribution of contaminated groundwater in is different in the sand strata than that in the silt strata. - There is a groundwater mound in the disposal pit area caused by infiltration from the cooling channel and settling pond. Immediately under this mound evidence of groundwater contamination in the upper clay layers was found. The writer notes that monitoring wells installed during this phase of the investigation were sealed with benton- ite above the strata being sampled, unlike monitoring wells installed subsequently.

2) A report entitled "Geotechnical Engineering Studies and Foundation Design Recommendations, Proposed Alewife Cen- ter Phase I" dated April 6, 1984, containing the following information: - Borings B5 and B6 were advanced to depths of 127 feet and 146 feet respectively below the ground surface to the decomposed Cambridge Argillite. - The top of the decomposed Cambridge Argillite in borings B5 and B6 were 124.5 and 141.5 feet. (Elevation datum is the MBTA datum, about 105.87 feet below the National Geodetic Vertical Datum). - Organic odor notedat B4 at about the 10 foot depth.

3) A document entitled "Report on Long-Term Chemical Monit- oring Program" dated February 1986, containing the fol- -6 0 0 lowing information: - The monitoring program was proposed on April 6, 1985. - The first groundwater and surface samples under the long-term monitoring program were collected on April 16, 1986. - Groundwater samples were collected from B8-OW, located in the center of the northern side of the site and B501-OW, located about 300 feet northeast of the site, across Whittemore Street. - Three surface water samples (S4, 55 and S6) were collected from Alewife Brook, one, S7, from a sewer trench near Alewife Brook, and one, S2, from Parkway Pond. - A chemical odor was noted at the Parkway Pnd sampling point. - No extractables were detected in any sample. - The groundwater from B501-OW contained 6 ug/l 1,1-dichloroethene, 3 ug/l dichloroethane, and 13 ug/l 1,1,1- trichloroethane. A previous analysis of water from this well showed only 1,1,1-trichloroethane at a concentration of only 26 ug/l. - No VOCs were detected in the groundwater at B8-OW. - No VOCs were detected at Parkway Pond. 460 ug/l acetone and 13 ug/l benzene were detected at this location. - Surface water from location S6 contained 2 ug/l tetrachloroethene. In a previous analysis, no VOCs were detected. - Surface water from location S7 contained 3 ug/l 1,1,1- trichloroethane. This was taken from what appeared to be an open sewer flowing into Alewife Brook. This location had not been sampled previously. i

February 17, 1987

Executive Office of Environmental Affairs 100 Cambridge Street Boston, MA 02202

Attn: Mr. Steven Davis

Dear Mr. Davis:

The Department of Environmental Quality Engineering, Division of Solid and Hazardous Waste, is in receipt of the Draft Environmental Impact Report concerning Alewife Center in Cambridge, Massachusetts, prepared by Monacelli Associ- ates and dated November, 1986. The Department has reviewed Chapters IX and Xf, which were prepared in association with Haley and Aldrich, Inc. and entitled "Subsurface Conditions and Chemical Contamination", and "Mitigating Measures: Sub- surface Conditions and Chemical Contamination" respectively. This letter is to present the Department's comments on these chapters of the EIR.

To provide a perspective on these comments, the Depart- ment's current involvement with the W.R.Grace site should be explained. During December of 1986 and January of 1987, the Department reviewed the 1985 3-volume report prepared by Haley and Aldrich entitled "Report on Subsurface and Hydro- geological Conditions for the Alewife Center Master Plan Study". Based on that document and on additional information in the Department's files, and pursuant to M.G.L. Chap- ter 21E, a "Notice of Responsibility" letter was written to W.R.Grace. That letter documents information showing that a "release" of oil/hazardous material has occured at the site, outlines W.R.Grace's liabilities and responsibilities regarding assessment and remediation pursuant to Chapter 21E, and summarizes "Requisite Site Actions" that the Department deems necessary to evaluate and remediate the site. For your reference, a copy of that letter is enclosed. The following comments on the EIR are essentially a subset of the "Requisite Site Actions", focusing on the requirements that are related to the development process.

(1) In the introduction to Chapter IX, it is stated that a

toxicological assessment of the site was conducted, and "... it was determined that no actual or potential hazard to human health is presented by current or proposed conditions". The risk assessment portion of the 1985 Haley and Aldrich report did not, however, specifically address other potentially important exposures associated with development. The only exposure treated quantitatively in that document was inhalation of contaminated airborne soil particles caused by disturbing dry soil on S

the site during construction. Other potential contaminant transport and exposure pathways related to development include the migration of contaminated groundwater or chemical vapors into on-site buildings and the transport of contaminants into ponds and pond sediments that will be accessible to the public after development is complete. Before the Department approves the development plans, a thorough, quantitative analysis of all potential risks associated with transport and/or exposure to hazardous materials is required to demonstrate that development will not adversely impact public health or the environment in the vicinity of the site.

(2) The "Site Hydrology" section states that "Preliminary calculations indicate that the 10 ft. structure pene- tration below the water table may create a negligible rise in water levels immediately surrounding the structures. Groundwater levels in neighboring residential areas would not be affected by the proposed construction". To confirm that such is the case, and that development will not result in elevated contaminant levels in the neighborhood north of the site, a detailed account of the data and analysis upon which this conclusion is based must be presented before the Department approves the development plans. Since groundwater flow is the major route by which contaminants are transported off-site, it is necessary to rule out or prevent the flow of contaminated groundwater into the neighborhood. If the groundwater flow analysis indicates that contaminated ground water may migrate from the site into the the neighborhood, groundwater diversion structures or interceptors could be required.

(3) The "Chemical Contamination and Analysis" section states that "Using the existing data, estimates were made of likely human exposure under current and anticipated site conditions." Again, in the Haley and Aldrich 1985 report, specific estimates were presented only for the potential exposure pathway believed to be the most significant, that of dust inhalation during construction. The Department is requiring such estimates for all potential exposures.

(4) Also in the "Chemical Contamination and Analysis" section, it is stated that "Construction of building foun-

dations will result in the excavation of contaminated soil, and pumping and on-site treatment of contaminated water". Specific treatment system design plans and soil removal criteria must be submitted to the Department for approval before construction is initiated.

(5) Additionally, the responsible party/developer is required to submit a plan for managing hazardous materials during construction. The plan will address: (a) measures to control and monitor dust levels, (b) decontam- ination procedures for heavy equipment tires to assure that contaminated soil is not transported to neighborhood streets, (c) Procedures to assess the potential for downward vertical transport of contaminants and, if necessary, to prevent such a condition, and (d) procedures for storing contaminated soil excavated during construction that will prevent run-off and/or further spreading of contamination.

(6) The Department is requiring W.R.Grace to submit a report on the feasibility of treating contaminated soil and groundwater at the site using available technologies. Subsequently,a proposal for site remediation must be approved by the Department before construction begins.

It should be noted that some of the tasks listed above may require additional investigation, but others will only involve more detailed description and documentation of the investigation and analysis upon which the Haley and Aldrich conclusions are based. If you have further questions about the Department's concerns, please contact Nancy Bettinger at the letterhead address or 935-2160.

Very truly yours,

Richard J. Chalpin, Deputy Regional Environmental Engineer cc: DEQE/DSHW, One Winter Street, 5th Floor, Boston, MA 02108 Attn: Madeline Snow

Commision of Health and Hospitals, 1493 Cambridge St., Cambridge, MA 02139 Attn: Melvin Halfen, M.D., Comm.

Cambridge Department of Public Works, 147 Hampshire St., Cambridge, MA.02139 Attn: Joan Lastovica

City Manager's Office, Cambridge City Hall, Cambridge, MA 02139 Attn: Robert Healy, City Manager

Cambridge City Council, Cambridge City Hall,

Cambridge, MA 02139 Attn: Alice Wolf, Councilor

W.R.Grace & Co., 62 Whittemore Avenue, Cambridge, MA 02140 Attn: Mark Stoler

Haley and Aldrich, Inc., 238 Main Street, Cambridge, MA 02142 Attn: Wesley Stimson 0 0

Hines Industrial, University Place, 124 Mount Auburn St, Cambridge, MA 02138 Attn: David Vickery MEMORANDUM FOR THE RECORD

TO: John Fitzgerald, P.E., Principal Sanitary Engineer FROM: Nancy Bettinger, Environmental Analyst I DATE: April 13, 1987

SUBJECT: CAMBRIDGE - W.R.Grace, Sampling plan meeting

On April 13, 1987, the writer met with Stan Fielding of Haley and Aldrich and Laura Green and Susan Baer of Meta Systems. The purpose of the meeting was to discuss the Haley and Aldrich plan for further sampling and to review the comments submitted by Dr. Spengler to the city of Cambridge.

Stan Fielding began the meeting by summarizing the plans for the next sampling round. Surface water and sediment sampling plans are as follows:

1) Jerry's Pond - One surface water sample and three sediment samples are planned. The sediment sampling locations near the northern, western and southern edges of the pond were chosen because the sides are the most accessible areas. Figure 1 shows the proposed sampling locations.

2) Parkway Pond - Two surface samples will be collected, on at the inlet from the MBTA underdrain system and one at the outlet. One sediment sample will be collected.

3) Yates Pond - One surface water sample will be collected.

4) Alewife Brook - Three locations are proposed for both surface water and seduiment samples, one upstream of the area of influence of the site, one near B604 OW, and at the intersection of Massachusetts Avenue and Alewife Brook.

5) MBTA Tunnel - Four samples will be collected from the underdrain system, one at the upstream end and one at the downstream end of both of the underdrain sections on the site.

The tentative test pit and surficial soil sampling plan is summarized below, but may be revised after the review of historical information and the analysis of analytical data is complete. In general, surface samples will be collected from the upper layers of test pit excavations. The writer asked for clarification of the item in the previous meeting's notes concerning the use of concentrations measured at depth during previous test pit excavations to estimate surface soil concentrations. In response, Stan stated that soil samples were being selected for analysis 9 S based on organic vapor screening and oily appearance, so that chemical analysis would be done on those samples that appeared to be most contaminated. If surface samples produce relatively low readings on the organic vapor analyzer, it is reasonable to assume that volatile organic compound contamination at the surface is the same or less than in samples showing relatively high organic vapor readings. Such assumptions will not be necessary for locations where surface samples are collected in addition to the selected test pit samples. Current plans for test pit and surficial soil sampling locations are as follows:

1) Eastern side of the site - Two test pits and two surficial soil sampling locations are planned for the the area immediately north of Jerry's Pond.

2) "The corridor" - Three to four test pits and surficial soil samples will be collected along the strip of land that lies between the proposed buildings. Locations will be evenly spaced.

3) The south end - Approximately eighteen test pits are planned for the area north of Jerry's Pond and South of the MBTA Tunnel, sixteen within the footprints of proposed buildings number 6 and 7, and two between those buildings. Additionally, two test pits are planned for the east side of Jerry's Pond.

4) The northwest side - A couple of additional test pits are planned outside of the perimeter of buildings 2 and 4.

For the groundwater sampling program, Haley and Aldrich proposes to obtain samples from existing wells at shallow depths by using a packer system that would be temporarily installed in each well at the time of sample collection. The purpose of the Packer is to hydraulically isolate an interval in the well so that a groundwater sample can be collected from a limited vertical zone. The writer asked Stan to submit a brief proposal in writing so that the technical merits of the procedure can be reviewed.by the DEQE. The proposed sampling locations are shown on the attached figure.

Regarding the comments on the investigation submittedto the City of Cambridge by Dr. Spengler and his colleagues,it was agreed that most of the concerns raised would be addressed by ongoing or planned assessment activities. Certain points were discussed, however, in order to clarify the DEQE's position or to confirm Haley and Aldrich's intentions. A summary of the discussion of selected issues follows: 0

1) Page 8, item 2 - It was agreed that construction staging areas would most likely be set up at various locations on the site, and predicting those locations and conducting detailed analysis for each of them would not be practical. The proposed soil analysis program should provide the information necessary to develop a management plan that will insure that contaminated soil is not spread during construction. Additionally, measures to contain contaminated soil excavated during construction will be required to prevent contaminant dispersion, and must be specified before construction begins.

2) Page 8, item 5 - The writer stated that clean fill should be used for pond alterations. If the consultants propose to use soil from the site for this purpose, it will have to be subjected to detailed chemical analysis.

3) Page 9, item 8 - The writer stated that if contaminated soil from property that belonged to W.R.Grace were stored on Russel Field during the MBTA Tunnel construction, then

W.R.Grace would be held responsible for any contamination caused by such storage/staging procedures, even if the company had not been involved with transporting the soil from the site. The writer noted, however, that available

information indicates that the soil that was stored on Russel Field was clean fill brought to the site from a different location, and there is no reason to suspect any contamination at all. Unless information to the contrary

comes to light, the DEQE will not require W.R.Grace to assess environmental conditions at Russel Field.

4) Page 10, item 11 - The writer noted that while acetate overlays and colored maps would be helpful, such pro- ductions were not normally required by the DEQE Site Assessment Program, and requirements for this project must be consistent with generally applied standards. It was agreed, however, that additional summary tables would facilitate data review. The writer suggested that sample summary tables be added to the appendices of the April 1985 "Three Volume Report" that contain laboratory analytical data.

5) Page 10, item 13 - It was agreed that air sampling for volatiles would be conducted before and during construction. In addition to air samples that have to be sent to a laboratory for analysis, a monitoring program will be developed to include "real time" measurements that will indicate whether off-site ambient air concentrations of of naphthalene exceed safe levels, and, if so, enable immediate corrective action. Since the concentration of contaminants will be measured directly at the perimeter and at nearby receptors, the DEQE will not require the information of empirical ambient emission rates. Such information might provide an indication of wheth-

er it is possible or likely to exceed safe levels, but it is not clear that it is technically feasible to derive a reasonable estimate of emission rates from the concen- tion of vapors in the air above recently disturbed soil. Additionally, since ambient concentrations can be measured directly, the benefit of the information does not justify the level of effort that would be required to estimate emission rates.

6) Page 11, item 3 - The utility of any transport rate estimates that might be obtained from modeling contaminant transport in soil, surface water and ground water does not appear to warrant the great effort that would be required to model pollutant transport for several reasons: (a) Contaminant concentrations in the soil, surface water and groundwater on and near the site are being measured directly, (b) The soil contamination on the site, and to some extent the groundwater contamination, is not concentrated in a discrete source area, but rather is distrib- uted randomly and erratically over various areas of the site. Such conditions are not conducive to transport modeling, and (c) The groundwater model proposed for the purpose of evaluating the effect of construction on the direction of groundwater flow is not sophisticated enough to use as a basis for pollutant transport modeling, and finally, (d) most of the uncertainty about groundwater contaminant transport at the site arises from the hydraulic effects of the MBTA Tunnel. ,A pollutant transport model would not help to predict the impacts of repairing the tunnel might have on groundwater flow.

7) Page 12, item 7 - Stan Fielding stated that developing the property will result in changes in the drainage system in the vicinity of the site such that flooding of the site will be prevented. He agreed to address this point in more detail in a future report.

8) Page 14, item 4 - In addition to the concerns about contaminant transport routes raised in this section, the writer reiterated the importance of evaluating the possibility of underground utility lines acting as conduits for transporting contaminants away from the site. It was also noted that availabe information showed that the nearest water supply, Fresh Pond, will not be impacted by this site.

9) The section entitled "Components of a recommended exposure and risk assessment" was discussed extensively. It was agreed that, in principle, all concerns raised would be addressed, and the risk assessment would meet the intent of the recommendations. It was also agreed, however, that this particular site, with low to moderate levels of contamination, does not warrant the level of analysis that would be appropriate for a federal "Super- fund" site. (This is not because a lower level of safety

is acceptable at a less serious site, but at lower contaminant concentrations the procedures necessary to assess impacts and rule out potential health effects are simpler. Conservative calculations and "worst case" estimates that are used for a "first cut" analysis are more

likely to eliminate the need for further, more accurate analysis when contaminant concentrations are low.) Spec- ific recommendations are addressed below:

a) Page 15, item 3 - Available applicable toxicological data will be used to evaluate the risks associated with the contaminants of greatest concern. Compounds will be selected initially for extensive evaluation based on their prevalence at the site, concentrations detected at the site and relative toxicity. It is not

necessary to "select and apply risk/potency coefi- cients or limits" for all compounds that might be present if a conservative analysis of the compounds of

greatest concern indicates that exposures are well below a harmful level.

b) Page 17, item 3 - The writer stated that the list of compounds to be addressed in the risk assessment should narrowed down from these, but cautioned that toxicities and routes of exposure should be considered in combination with concentration data to select indicator compounds".

During the last part of the meeting, the construction of the monitoring wells installed by Haley and Aldrich in 1984 were discussed briefly. The writer expressed reserva- tions about the effectiveness of using Packer systems in these wells. Stan Fielding said he would review the construction reports for those wells and address the question at a later time. W.R.Grace and Co. 62 Whittemore Avenue Cambridge. MA Re: CAMBRIDGE, Alewife Center Sampling Attn: Mark Stoler Plan, DEQE Case #3-277

Dear Mr. Stoler:

The Department is in receipt of the Sampling Plan for Alewife Center dated July 1987 prepared for W.R.Grace and Co. by Haley and Aldrich, Inc. This letter is to present in writing the Department's comments on the plan as it concerns the identification of areas of the site that are contaminated to the extent that they constitute continuing contaminant sources. The plan for long-term monitoring will be addressed at a later date.

The stated objectives of the sampling plan are: (1) to provide sufficient information to determine whether or not locations identified as chemical storage, use, or disposal areas act as continuing sources of contamination, (2) to obtain more detailed information on areas of the site where there is little data, (3) to establish a database of groundwater and surface water quality information as part of the long-term monitoring program, and (4) to determine the soil quality within the outline of proposed Building Sites #6 and #7 that are on the Grace property.

To address the first objective mentioned above, Haley and Aldrich presented in Table 1 of the Sampling Plan a detailed summary of the potential source areas, data from sampling points nearest those areas, and recommendations as to the necessity of additional sampling to ascertain whether the areas in question are continuing sources of contamination. The Department's comments on Table 1 are detailed in the enclosed internal memorandum, and the specific recommendations for additional sampling at the suspected source areas are summarized below:

(1) Source I.D.#3, the location of an underground tank used for naptha and toluene - According to Stan Fielding, vadose zone analysis using a field gas chromatograph as

well as tenax vapor sampling tubes is the proposed method of analysis for this area. The Department agrees that this is an appropriate screening method, but because of the limitations of vadose zone analysis outlined in the enclosed memorandum, a follow-up plan for sampling based on the screening results should be presented. Should vadose zone analysis indicate the absence of contamination in the area, only limited con- 0 0

firmatory sampling would be required. Additionally, for reasons outlined in the enclosed memorandum, the Department recommends the installation of a shallow, short screened well in the vicinity of B203-OW. Anal- ysis of samples from this well should also address concerns about Source I.D. #s 2 and 3 and Buildings 8 and 40.

(2) Source I.D. #2, the former location of an underground white oil tank - To determine whether this area constitutes a source of free floating product or dissolved petroleum product constituents, groundwater samples shoud be collected from the additional well recommended in the comments regarding source I.D. #1. The recommended well should be screened from above the groundwater table to enable the detection of floating product if any exists.

(3) Source I.D. #3, the former location of an underground tank used for naphtha and toluene storage - To evaluate groundwater contamination originating at this location, samples should be collected from the well recommended in the comments regarding source I.D. #1. Addi- tionally, for reasons outlined in the enclosed memorandum, a sampling plan to follow the vadose zone screening program should be submitted. If vadose zone sampling indicates the absence of contamination in the area, only limited confirmatory sampling will be required.

(4) Source I.D.#9, the location of an underground DAXAD tank - For reasons discussed in the enclosed memorandum, the Department considers wells B805 and B806 more appropriate sampling points than B702 and B704 for evaluating groundwater conditions near this location. Additionally, soil from immediately adjacent to and beneath the tank should be analysed for naphthalene.

(5) Source I.D. #14, the location of an underground diesel fuel tank at the N.E. corner of Building 17 - The comments regarding vadose zone analysis at Source I.D. #3 apply to this location also.

(6) Source I.D. #15, location of settling tank for drum re- conditioning operations - Specific plans for sample sel-

ection and approximate number of samples should be presented. In addition to analysis of soil samples for volatile and extractable priority pollutants, non-priority pollutant, non-petroleum product constituents included in the mass spectrometer data base must be identified. 0 0

(7) Source I.D. #16, location of above ground naphthalene tank on the south side of Building 36 - For reasons given in the enclosed memorandum, monitoring well B807 should be used to obtain ground water quality data at this location.

(8) Source I.D.#21, location of former above ground formaldehyde tank - The evaluation of this area as a potential continuing source should be based onthe areal extent of the soil contamination as well as the fate and transport of formaldehyde in the soil environment. Soil and groundwater data presented in the Sampling Plan for the building 27 show significant levels of contamination at this location. Additional soil sampling as well as more extensive data analysis is necessary to evaluate this area.

(9) Source I.D. #27, former location of above.ground fuel oil tank - To check for contamination that may have originated at this tank, well B804 should be monitored quarterly for floating product.

(10) Source I.D. #29, location of the tank farm east of Parkway Pond - In addition to priority pollutants, analysis of the soil from this area should include the identification of any non-priority, non-petroleum product constituents that are included in the mass spectrometer data base. This location is near the area of highest groundwater contamination on the site, and warrants thorough investigation. A specific plan for sample selection should be submitted.

(11) Source I.D. #30 and #31, locations of wash lagoon, settling pond and process waste areas - The Department considers these areas to be important potential source areas, and the locations of the sampling points cited in Table 1 do not appear to correspond well with the areas of concern. Several borings should be advanced in each of these areas to evaluate the severity and vertical and horizontal extent of any contamination remaining at these locations. The borings should be advanced below the elevation of the bottoms and to the perimeters of the former ponds and lagoons.

(12) Source I.D. #35, former location of a 10,000 gallon oil tank - The test pit program recommended for Source I.D. #s 11,12 and 13 should be expanded to include this area.

BUILDINGS:

(1) Buildings 1,2,3 4 and 5 - For reasons discussed in the enclosed memorandum, the Department does not consider 4

the groundwater analysis data from well B205-OW adequate information to characterize contaminant conditions in this location. Since very little soil analysis data was cited for this area, and the boring log for B205-OW noted a strong chemical odor at a depth of 4 to 8 feet, a plan for sampling and analyzing soil from the vicinity of these buildings and B205-OW should be submitted.

(2) Building 8 - To evaluate groundwater conditions in this area, samples should be collected from an additional well installed in the vicinity of MW203-OW (see comments and recommendations under Source I.D. #s 1 and 8 in the enclosed memorandum.)

(3) Building 18 - Soil samples should be collected from around any sumps, drains or sewer lines leading from the laboratory. These should be analyzed for priority pollutants as well as any other hazardous materials used routinely (in the past or at present) in the lab.

(4) Building 30 - The Department agrees with the Haley and Aldrich recommendation, but would add soil sampling. A specific sample selection plan should be submitted.

(5) Buildings 33, 35, 37 and 38 - The Department agrees with the Haley and Aldrich recommendation that additional soil samples be collected from the footprints of these former buildings, but would also recommend collection of soil samples from just outside of the buildings' perimeters.

(6) Buildings 32 and 34 - The additional sampling performed for buildings 33, 35, 37 and 38 should also encompass nearby buildings 32 and 34.

The comments above are based, for the most part, on the information presented in the sampling plan, and are only as comprehensive as that information. New information received by the Department in the future may may warrant additional sampling requirements.

Additionally, please be advised that these requirements relate to the identification of continuing sources of contamination, but may not be sufficient to provide all of the data necessary for decisions on the removal and treatment of contaminated materials at the site. The feasibility study may indicate the need for additional sampling data, but before that study is initiated, it is not possible to predict such requirements.

You are reminded that samples must be collected and analysed according to applicable EPA protocols. To enable the Department to monitor the implementation of the Sampling Plan, 0

please notify Nancy Bettinger at least one day in ad- vance of specific sampling locations and plans.

If you have further questions regarding this matter, contact Nancy Bettinger at the letterhead address or 935- 2160. All future communications concerning this site must reference the DEQE case number designated in this letter's heading.

Sincerely,

Richard J. Chalpin Deputy Regional Environmental Engineer

RJC/NAB/nab

Enclosure cc: Madeline Snow, DEQE/DHW, 5th Floor, One Winter Street Boston, MA 02108

Karen Stromberg, DEQE/DHW, 5th Floor, One Winter Street, Boston, MA 02108

Wesley Stimpson, Haley and Aldrich, Inc., 238 Main Street, P.O.Box 60, Cambridge, MA 02142 Cambridge, MA MEMORANDUM

TO: John Fitzgerald, P.E., Environmental Engineer IV FROM: Nancy Bettinger, Environmental Analyst I DATE: September 28, 1987

SUBJECT: Review of Sampling Plan for Alewife Center - Source Identification

This memorandum is to document the writer's review of the Sampling Plan for Alewife Center prepared by Haley and Aldrich for W.R.Grace, specifically that portion of the plan which concerns the identification of possible contamination source areas. In Table 1 of the Sampling Plan, Haley and Aldrich itemized potential sources of contamination, data from sampling points nearest those areas, and recommenda- ions regarding the necessity of additional sampling to ascertain whether the areas in question are sources of con- amination. The writer's review of Table 1 is presented below, according to Source I.D. number, Building number and Storage Area number.

SOURCE (TANK) AREAS:

#1 Haley and Aldrich recommend that the area of the former underground acetone tank be evaluated as a continuing source based on the analysis of groundwater samples from monitoring well B203-OW. In the writer's opinion, however, the construction of this well is not optimum for determining the contaminant concentration at any particular vertical location. The well is screened from 20 to 30 feet, and is not sealed above the screen. Since the annular space above the screen is filled with pea stone, groundwater from any depth down to 30 feet can enter the well. The analysis of groundwater from this well can provide information on the presence or absence of contamination, but cannot demonstrate the absence of a continuing source of contamination at this location. A shallow, short-screened well should be installed in the vicinity of B203-OW to obtain samples more representative of the groundwater at shallower depths, where the heaviest contamination from leaking tanks is likely to be found.

#2 Haley and Aldrich have recommended that groundwater samples from B203-OW be collected to determine conditions in the vicinity of the former white oil tank. For the reas-

ons stated in the comments regarding source I.D. #1, this well is not ideal for the purpose. Additionally, since it is not screened across the groundwater surface, B203- S 0

OW cannot be used to monitor for floating product. The well recommended above should be monitored for contamination from this location also.

#3 According to Stan Fielding, vadose zone analysis using a field gas chromatograph as well as tenax vapor sampling tubes is the proposed method of analysis for this area, the location of an underground tank previously used for naptha and toluene storage. The applicability of field gas chromatography (at ambient'temperatures) to the chemicals of concern at this location must be documented, in terms of both detectability and partitioning properties. In the writer's opinion, vadose zone analysis is a useful technique for comparing contaminant levels at different locations and for tentative qualitatative identification of contaminants. It cannot, however, be used to determine the quantity or vertical distribution of contaminants in the soil or groundwater. Therefore, the results of vadose zone analysis alone cannot lead to a conclusion as to whether a "hot spot" or continuing source of contamination exists in a particular area. It should be used to obtain information that will enable a sampling program to be conducted more efficiently and to reduce the number of samples necessary to characterize a particular area. The writer agrees that this technique is appropriate as an initial measure, but plans for follow-up sampling should be submitted. Groundwater samples to evaluate contamination from this location should be collected from the well recommended in comments regarding Source I.D. #1.

#4 The writer agrees with the Haley and Aldrich recommendation.

#5 The writer agrees with the Haley and Aldrich recommendation.

#6 and #7 The writer agrees with the Haley and Aldrich recommendation.

#8 The writer agrees with the Haley and Aldrich recommendation.

#9 The conclusion that the area where the DAXAD tank was located is not a continuing source of contamination is not supported by the information provided in Table 1. Low levels of naphthalene in the groundwater indicate the presence of this chemical, but the construction of wells 702 and 704 is not well suited to determining whether the groundwater is affected by a continuing source of contamination in the area. These wells are screened from 5 to

30 feet, so samples collected from them do not necessarily represent contaminant concentrations at shallow depths, where chemicals from the tank would be found in the highest concentrations. Recently installed monitoring wells B805 and B806 would provide more accurate data on these locations. Additionally, the soil samples that were analyzed from test pits 12 and 16 at site 3 were collected from depths up to 7 feet and may not have been from the correct lateral location or vertical depth to determine whether the Daxad tank caused significant soil contamination. Soil samples from the area immediately adjacent to and under the tank should be sampled for naphthalene.

#10 The writer agrees with the Haley and Aldrich recommendation.

#11,#12,#13 The writer agrees with the Haley and Aldrich recommendation. Based on the results of test excavation and sampling in this area (the former location of three underground fuel tanks), the need for a shallow well to monitor for floating petroleum product should be evaluated.

#14 According to Stan Fielding, vadose zone analysis using a field gas chromatograph as well as tenax tube samples will be used for the analysis at this location. The comments presented for I.D. #3 regarding the applicability of vadose zone monitoring to source identification apply to I.D. #14 as well. A follow-up sampling plan should be specified.

#15 The writer agrees that soil sampling for volatile and extractable organics is appropriate at the settling tank area, but also recommends that any non-priority pollutant constituents be identified. A sample selection plan and documentation of sufficient sampling depth should be presented.

#16 The detection of 20 ppb naphthalene in the groundwater collected from B705-OW, near the former location of an above ground naphthalene tank, indicates the presence of naphthalene in the area, but since this well is screened from 1.8 to 34.8 feet, samples collected from it will not necessarily represent the contaminant concentrations at shallow depths, where the highest levels of contamination would most likely be found. Monitoring well B-807 would be a better sampling point for this purpose. Ad- ditionally, soil samples should be collected from several depths beneath the former above ground storage tank and analyzed for naphthalene.

#17 The Writer agrees with the Haley and Aldrich recommendation.

#18 To check for floating petroleum product that may have originated at this above ground fuel oil tank, the recently installed well B807 should be monitored quarterly, assuming that well is screened across the groundwater surface.

#19 The writer agrees with the Haley and Aldrich recommendation.

#20 The writer agrees with the Haley and Aldrich recommendation.

#21 The evaluation of this area as a potential source of formaldehyde contamination should be based on the areal extent of the soil contamination in this area as well as the fate and transport of formaldehyde in the soil environment. Soil and groundwater data presented for the Building 27 area show significant levels of contaminants in this area. Additional soil sampling as well as more extensive data analysis is necessary to eval- determine whether the soil at this location constitutes a continuing source of contamination.

#22 The writer agrees with the Haley and Aldrich recommendation.

#23 The writer agrees with the Haley and Aldrich recommendation.

#24 The writer disagrees with the statement that zinc "is not of environmental concern", but recognizes that it may not be of concern in this case. The 24 hour aquatic criteria for fresh water is 47 ug/l, two orders of magnitude below the level found in groundwater at this location. A decision on the need for further samples should be justified by considering the fate and transport of zinc in the environment, and the predicted concentration at the nearest receptor.

#25 The writer agrees with the Haley and Aldrich recommendation.

#26 The writer agrees with the Haley and Aldrich recommendations.

#27 To check for floating petroleum product that may have originated at the fuel oil tank at this location, well B804 should be monitored quarterly for floating product, assuming this well is screened across the surface of the groundwater.

#28 The writer agrees with the Haley and Aldrich recommendation.

#29 In addition to priority pollutant volatile organic compounds, the soil from the vicinity of the tank farm east of Parkway Pond should be analyzed for other non-priority pollutants previously detected at the at the site, as well as extractable organic compounds.. This location is near one of the most heavily contaminated areas of the site, and warrants a thorough evaluation. A more specific plan for sample selection should be submitted.

#30 and 31 The writer considers the lagoon, settling ponds and process waste areas to be important potential sourc- areas. The locations of the sampling points cited in Table 1 do not appear to correspond well with the areas of concern. Several borings should be advanced in each of these areas, to evaluate the severity, and vertical and horizontal extent of contamination that may remain at these locations.

#32 A specific sample selection and analysis plan should be presented for the area of the process waste storage areas and the areas used for sludge solidification.

#33 The writer agrees with the Haley and Aldrich recommendation.

#34 The writer agrees with the Haley and Aldrich recommendation.

#35 The test pit program recommended for Source I.D. #11, 12 and 13 should be expanded to include this area, which is nearby.

#36 The writer agrees with the Haley and Aldrich recommendation.

For many of the potential source areas, groundwater analysis data was used to to determine whether a continuing contamination source exists. In most cases, only one sample was collected and analyzed, and contaminant levels in the monitoring wells have not been monitored over time. Long- term groundwater monitoring is necessary, however, to detect trends that can indicate the presence or absence of a continuing source of contamination with any certainty. For this reason, the collection and analysis of soil samples will provide the best information on many of these locations within a short period of time. To determine whether or not soil in an area constitutes a continuing source, the areal extent of the soil contamination and the predicted fate and transport of the contaminants at that location must be considered as well as the contaminant concentrations.

BUILDINGS: 1,2 and 3 Haley and Aldrich's conclusion that no continuing source exists in these areas is based upon analysis of groundwater from monitoring well B205-OW. In the writer's opinion, however, the construction of this well is not optimum for obtaining a quantitative analysis of groundwater in the most heavily contaminated vertical zone. The well is screened from 20.4 feet to 30.4 feet, and was not sealed above the screen. Since the annular space above the screen is filled with pea stone, groundwater from any depth could possibly enter the well. The analysis of groundwater from this well can provide information on the presence or absence of contamination, but cannot demonstrate the absence of a continuing source of contamination at this location. In fact, the boring log for this well indicates a strong chemical odor at the 4 to 8 foot depth. No soil data for this area is available so additional soil samples should be collected and analyzed. A specific plan for sample collection and analysis ahould be submitted.

4 Haley and Aldrich concluded that there is no continuing source in this area based on the analysis of groundwater from well B701-OW, which is screened from 5.1 to 40 feet. For reasons discussed in the previous paragraph, this data does not demonstrate the absence of heavily contaminated soil that might constitute a continuing source of contamination.

5 For reasons presented above, the wells cited as evidence of no continuing source at Building 5 do not provide adequate quantitative information for that purpose.

6 The writer agrees with the Haley and Aldrich recommendation.

7, 11, 12 and 15 Since these buildings appear to have been located in the area that will be excavated for Building Site 2, and since the available information does not indicate a continuing source in the area, the Department agrees that additional sampling in this area is not nec- cessary at this point in time. The excavation process should provide an opportunity to discover any additional sources that may exist in this area. Furthermore, additional sampling has been recommended for the area adjacent to Building 11 (at Building 25).

8 Sampling well B203-OW for solvents will not provide quantitative analytical information on the groundwater quality, for reasons cited in the comments regarding Building 1. Additionally, since the well is not screened at the surface, it cannot be used to monitor for floating petroleum product. An additional. well in the vicinity of well B203 has been recommended in the comments regarding Source I.D. #1. Groundwater 0

samples from that well should provide better information as to the existence of a continuing source of contamination in that area.

9 The writer agrees with the Haley and Aldrich recommendation.

10 The writer agrees with the Haley and Aldrich recommendation.

13 The writer agrees with the Haley and Aldrich recommendation.

14 The writer agrees with the Haley and Aldrich recommendation.

16 Most of the contaminants detected in the soil from Test Pit 16 in Site 3 are usually associated with oil contamination. Although no recommendations were made under this item, Haley and Aldrich has recommended excavating a test pit at the former oil tank location near Building 16.

17 The writer agrees with the Haley and Aldrich recommendation.

18 In the writer's opinion, all laboratories are potential sources of contamination. Soil samples should be collected from around any sumps or sewer or drain lines lead- ding from the lab. These should be analyzed for priority pollutants as well as any other chemicals used routinely in the lab.

19 The writer agrees with the Haley and Aldrich recommendation.

20 The writer agrees with the Haley and Aldrich recommendation.

21 The writer agrees with the Haley and Aldrich recommendation.

25 Sampling recommendations for this area are addressed under Source I.D. #15 in this memo.

26 The writer agrees with the Haley and Aldrich recommendation.

27 Sampling recommendations for this area are addressed under Source I.D. #21 in this memo.

28 The writer agrees with the Haley and Aldrich recommendation. 30 The writer agrees with the Haley and Aldrich recommendation, but would add soil sampling. To the extent possible, the sampling program for this building should be combined with those recommended by the writer for Buil- dings 8 and 18.

31 Sampling recommendations at this location are addressed under Source I.D. #14 in this memo.

33,35,37, and 38 The writer agrees with the Haley and Aldrich recommendation that additional soil samples be collected from the footprints of these former buildings and analyzed for priority pollutant compounds, but would also recommend collection of soil samples from just outside of the buildings' perimeters.

32 and 34 The additional sampling performed for buildings 33,35,37 and 38 should also encompass nearby buildings 32 and 34. It is not clear from the comments in Table 1 why these were determined not to be continuing sources since the available data for the locations of buildings 32 and 34 is not substantially different from that for the other buildings.

36 Sampling recommendations at this location are addressed under Source I.D. #16 in this memo.

39 The writer agrees with the Haley and Aldrich recommendation.

40 In the writer's opinion, for reasons cited in the comments regarding Building 1, samples collected from well B203 cannot be assumed to represent the contaminant levels in the most contaminated stratum, and therefore, cannot be used to determine the presence or absence of a continuning source of contamination in the area.

41,43,44,45 and 46 The writer agrees with the Haley and Aldrich recommendation.

42 The writer agrees with the Haley and Aldrich recommendation.

In some cases, indicator compounds for the building locations appear to have been chosen based on data from the nearest sampling points rather than on building use information, and so the need for additional data was determined essentially by comparing existing data with existing data. This procedure does not really check the adequacy of existing data with respect to chemical handling activities in each building, and therefore has limitations in identifying data gaps. 0 0

MEMORANDUM FOR THE RECORD

TO: John Fitzgerald, P.E., Environmental Engineer IV FROM: Nancy Bettinger, Environmental Analyst I SUBJECT: CAMBRIDGE - W.R.Grace, Sampling Plan Meeting

Date: December 3, 1987

On December 2, 1987, the writer met with Stan Fielding and Wes Stimpson of Haley and Aldrich to discuss the sampling plan for the W.R.Grace property in Cambridge. Prior to the meeting, Haley and Aldrich had submitted a written response to DEQE's comments on the sampling plan. In the writer's opinion, the response adequately addressed most of the DEQE's comments on the sampling plan. The remaining concerns were resolved in the meeting. A summary of the discussion about those concerns is presented below:

(1) Source I.D. #21 - Former location of the formaldehyde storage tank. The writer pointed out that a soil sample from this area was found to contain 320 ug/g (ppm) formaldehyde, and that given since formaldehyde is found in the groundwater on the site, there is not enough in formation to rule out the soil in this area as a continuing source of contamination. It was confirmed, however, that all of the soil in that vicinity would be removed during excavation for building 4, so no further formaldehyde analysis would be necessary at that location.

(2) Source I.D. #29 - The former location of the tank farm east of Parkway Pond. The writer questioned the assumption that contaminants in that area would be priority pollutant volatile organic compounds. It was agreed that doing a GC/mass spec library search would result in tentative qualitative data and no quantitative data-, and that analyzing for compounds known to have been stored in the tanks would be more appropriate. Haley and Aldrich will ascertain that only the compounds listed on Figure 6 of the Sampling Plan were strored at the tank farm, and to the extent possible, the samples from that area will be analyzed for those compounds.

(3) Source I.D. # 30 and #31 - the wash lagoon, settling pond, the western process area and the eastern process area. The Haley and Aldrich response to the Department's comments confirmed that no sludge remains in these areas, but the writer questioned whether the available data is sufficient to show that the underlying soils are not sources of contamination. Haley and Aldrich stated that most of the soil in the area of the wash lagoon and settling pond would be removed during excavation for Building 4, and that the soil in the area of the eastern and western process waste areas will be further evaluated in a test pit program for Building 6. If C4 S% 9 ___K Lz"'t__ntr~rri - -- -9--,-"- *- -j

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MEMORANDUM

TO: John Fitzgerald, P.E., Principal Sanitary Engineer FROM: Nancy Bettinger, Environmental Analyst I DATE: December 26, 1986

SUBJECTT: CAMBRIDGE - W.R.Grace Required additional actions

The W.R.Grace site in North Cambridge has been found to be contaminated with various chemicals, the most prevalent being napthalene, acetone, polyaromatic hydrocarbons and carbon disulfide. The site has been used for the manufacture of dispersants, sealants and various rubber products. In 1919, the Dewey and Almy Chemical Company was founded on the site for the purpose of manufacturing rubber products. Eleven buildings were constructed by 1930. The operations doubled in size by World War II. W.R.Grace purchased the firm in 19 . According to Haley and Aldrich, the nature of manufacturing operations remained unchanged after the transaction.

In the 1970's, during subsurface explorations in connection with the proposed MBTA tunnel that would pass through the W.R.Grace property, it was observed that waste materials had been disposed on the property. In 1979, Haley and Aldrich was retained to investigate the extent and nature of waste materials on the site. The material was removed in 1981 and 1982, with Goldberg, Zoino, Dunnicliff and Associates monitoring the removal on behalf of the MBTA.

In 1985, Haley and Aldrich submitted a report entitled "Report on Subsufrace and Hydrogeological Conditions for the Alewife Center Master Plan Study" to W.R.Grace and Hines In- dustrial, the prospective developer of a portion of the Grace property. A risk assessment based on data collected by Haley and Aldrich was prepared by Research, Testing and Development Corporation (RTD) and Dr. Raymond Harbison of the University of Arkansas. As stated in the report by Haley and Aldrich, the investigation was undertaken to "evaluate, and assess surface, subsurface and hydrogeological conditions at the site in order to determine the potential impact on development plans".

In November of 1986, the writer initiated a review of all past investigations and information concerning the site. Based on the review, which has not yet been completed, certain additional investigation and assessment needs have been identified. These additional needs largely arise from the difference between the stated goal of the Haley and Aldrich investigation and the site assessment approach normally pur- sued by the Department. The Haley and Aldrich Report emphasized the implications of contamination at the site for the 4Z planned development. Pursuant to the Department's usual approach, however, the environmental condition of the entire site should be assessed, and the potential environmental and public health impacts of contamination should be evaluated for three site conditions: (1) as the site now exists, (2) during proposed construction activities, and (3) as the site would exist after development.

There are three major issues that have to be addressed by W.R.Grace and its consultants: (1) Remove all obvious contamination and any continuing sources of contamination. (2) Ascertain that any residual contamination remaining on the site will have no adverse environmental or public health impacts, including effects on aquatic organisms. (3) Determine appropriate disposal methods for materials excavated during construction.

To make the necessary determinations and decisions to adequately address these concerns, two fundamental aspects of the investigation must be extended: (1) the vertical and horizontal distribution of contaminants at the site, and (2) a comprehensive evaluation of all potential contaminant transport and exposure pathways.

The vertical distribution of contaminants in groundwater will determine the exposure pathways...

The distribution of contaminants in the soil will determine the removal and disposal requirements.

Soil contamination on site: The vertical distribution of soil contamination should be evaluated more extensively. Determination of which layers were most heavily contaminate would help to (1) design a better worker protection plan (2) identify hot spots and highly contaminated strata. MEMORANDUM

TO: Carol Rowan West, Director, Office of Research and Standards FROM: Nancy Bettinger, Environmental Analyst I DATE: December 27, 1986

SUBJECT: W.R.Grace, Cambridge - Risk Assessment Review

This memorandum is to request the assistance of the Office of Research and Standards in reviewing the risk assessment section of the site assessment report for the W.R.Grace property in North Cambridge. The report was prepared for W.R.Grace and Hines Industrial, the prospective developer of the W.R.Grace property. Contributors to the report were Haley and Aldrich, Research, Testing and Development Corporation (RTD), and Dr. Raymond Harbison of the University of Arkansas. The report was prepared in April of 1985 and is entitled "Environmental Assessment Report for the Proposed Alewife Center Develop- ment at the W.R.Grace & Co. Property".

The study was conducted in connection with the planned development of a portion of the Grace property in North Cambridge. The investigation focused on the portion of the Grace site slated for construction, although it did include collecting and analyzing some samples from other parts of the property. -Similarly, the risk assessment emphasized the impact of the development process on public health, but did not present a comprehensive evaluation of all potential transport routes and exposure mechanisms that exist now and that may exist after the site has been developed.

From the writer's perspective, the planned development is an important aspect of the site assessment investigation, in that construction activities and new structures may create additional contaminant transport and exposure pathways. Excavation and construction are not, however, the only factors of concern in evaluating potential impacts of contamination at the site. The Department has taken the position that the environmental condition and potential impacts of the entire W.R.Grace property, both in its existing condition and in the developed state, must be determined. To this end, additional site investigation activities must be conducted, and all potential exposure pathways must be evaluated.

Based upon the writer's initial review of the data and assessment reports, the following data gaps and additional assessment requirements have been identified:

1) The vertical distribution of contaminants in groundwater at the site should be better defined. Most existing monitoring wells are constructed so the 9 0

groundwater samples are collected from relatively deep levels or from a wide depth range. Since the potential health impact of dissolved volatiles, via volatilization from ground water into structures on or near the site, depends on the concentrations in the upper levels of the aquifer, additional wells must be constructed so that samples can be collected from shallow depths. 2) Possible groundwater flow pathways must be evaluated more extensively, with consideration given to structures or utility lines that may act as conduits. 3) Based on groundwater contaminant concentrations at shallow depths and information on construction of on site structures (MBTA tunnel as well as proposed office buildings) the potential for elevated vapor levels due to volatilization from groundwater should be evaluated. 4) The possibility of any contaminated groundwater entering residential structures north of Whittemore Avenue, should be evaluated, based on a determination of groundwater flow pathways. If the possibility cannot be ruled out, preventative measures must be considered. If the hydrological data indicates contaminated groundwater will not flow into residential areas, longterm groundwater monitoring north of Whittemore Avenue will be required to assure that conditions do not change. 5) The potential impact of contaminants at the Grace site on the condition of surface water in the vicinity should be evaluated more extensively. Three ponds in the vicinity of the site are of concern: (1) Jerry's Pond, located at the southern end of the site, (2) Parkway Pond, adjacent to the western side of the site, and (3) Yate's Pond, located approximately 300 feet northwest of the site. According to Wes Stimson of Haley and Aldrich, these ponds are currently inter- connected by culverts. Contaminant levels in these ponds are of concern for two reasons: (1) potential affects on aquatic life and (2) potential health impacts arising from recreational activities around the ponds (3) discharge of contaminants into Alewife Brook. Current data appears adequate to address the latter concern, but first two concerns may require contaminant level estimates with a greater level of certainty. Current development plans for the Grace property call for a green space extending along the western side of the site to, and around, Jerry's pond. Parkway and Jerry's Pond, therefore, must be considered recreational areas. Existing surface water sampling points are probably adequate to assess dissolved contaminant levels, but additional sediment samples will be required.

We recognize that it may be difficult for you at ORS to fully evaluate the risk assessment report given the limitations of the available data. Nevertheless, we believe in- put from your office at this point in the investigation would be valuable. We would appreciate any comments and suggestions you can offer, and are especially interested in your comments on the following aspects of the risk assessment:

1) Identification of potential contaminant transport pathways and receptors. 2) Based on risk estimations from the available data, the need for additional data to increase the certainty about exposure measurements. 3) Evaluation of the rationale for acceptable particulate levels during construction presented in the risk assessment.

If you need additional information on this site, please contact me at 935-2160.