Dec 2 8 1995 Dep/Northeast Region

3-02177 7fr/~~-

UNDERGROUND ENGINEER]NG & 0 CAiAA$ k 17 ENVIRONMENTAL SOLUIONS

Haley & Aldrich, Inc. 58 Chad es Street Cambrid ge, MA 02141-2147 Tel: 61 7.494.1606 Fax: 617.577.8142 [email protected] Letter of Transmittal AIC

Date 27 December 1995 DEC 2 8 1995 File Number 10063-066 From Wesley E. Stimpson DEP/NORTHEAST REGION WAR11RN MAR-

To Department of Environinental Protection 10 Commerce Way Woburn, MA 01801 Attention Mr. Richard Chalpin Copy to Cambridge Main Library, North Cambridge Library, W.R. Grace & Co. - Conn. Subject 62 Whittemore Avenue, Cambridge, MA

Copies Date Description 1 12/95 Public Involvement Plan DEP RTN 3-0277 W.R. Grace & Co. - Conn. 62 Whittemore Avenue Cambridge, MA

OFFCES Cleveland Remarks /1 Ohio Denver Colorado Hartford Connecticut

Los Angeles California Manchester New Hampshire Portland Maine Rochester New York San Francisco (ft California

Washington Districtof Columbia /. eg- 4w~ HA E ALDRICH INC

Geotechnical Engineers & Environmental Consultants

7 November 1995 File No. 10063-066

Massachusetts Department of Environmental Protection Northeast Regional Office 10 Commerce Way Woburn, MA 01801 NOV 1 5 1995M

Subject: Extension of PIP Comment Period W.R. Grace & Co. - Conn. DEP/NORTHEAST REGION 62 Whittemore Avenue & WOBURN, MASS. Cambridge, Massachusetts RTN 3-0277

Ladies and Gentlemen:

It has been brought to our attention that the Cambridge Main Library did not place the PIP on the shelves where the W.R. Grace & Co. - Conn. documents can be found, but rather retained the PIP at the Reference Desk: This caused some confusion to an individual looking for the PIP, decreasing the number of days that the PIP could be reviewed. The Cambridge Main Library has informed Haley & Aldrich, Inc. that the PIP will be appropriately placed, and that interested individuals can also ask for the PIP at the Reference Desk. Because of this confusion at the Library, a request was made to W.R. Grace to extend the Public Comment period. It is W.R. Grace's continued desire to provide the public with the information that they require to become informed about the site. Therefore, the Public Comment period has been extended from 22 November 1995 to 27 November 1995 to allow for an additional five days of review time.

If there are any questions or comments regarding this matter, please do not hesitate to call or write.

Sincerely yours, HALEY & ALDRICH, INC.

Veronica Wancho O'Donnell Senior Environmental Geologist

FA10063\066\EXTEND.PIP

c: W.R. Grace & Co. - Conn.; David Wightman

58 Charles Street Cambridge, MA 02141-2147 Offices Scarborough, Maine Rochester, New York Tel: 617/494-1606 Denver, Colorado Silver Spring, Maryland Cleveland, Ohio Fax: 617/577-8142 Glastonbury, Connecticut Bedford, New Hampshire

Pmdon rcyied ppr. November 19, 1995

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 (B201-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? 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 2 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 U4

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 3- a-y-7 7

U- H ALEY & ALDRICH I'NC. J06A

Letter of Transmittal Geotechnical Engineers & Environmental Consultants

To Massachusetts Department of Environmental Protection Date 13 October 1995 10 Commerce Way File Number 10063-066 Woburn, MA 01801 Le al Notice; RTN 3-0277

Attention Richard Chalpin .f I

Copies Date Description OCT T 1995 1 Oct. 1995 Legal Notification for PIP Public Hearing DEP/NORTHEAST REGION WOBURN, MASS.

Remarks Dear Mr. Chalpin:

The copy of the Legal Notice for a Public Involvement Plan Meeting on the W.R. Grace facility (RTN 3-0277) forwarded to

you on 13 October 1995 did not list the time for the hearing. The attached Notice is the Notice to be published in the

Cambridge Chronicle.

58 Charles Street Cambridge, MA 02141 Tel: 617/494-1606 Fax: 617/577-8142 Copy To Offices Brea, California San Francisco, California Denver, Colorado Glastonbury, Connecticut Scarborough, Maine Silver Spring, Maryland Bedford, New Hampshire Rochester, New York Cleveland, Ohio Signed 3-0277

.v,. 4 - &2tL. k4vcw,-tA-voc a CMW6 )ZD6r6f a H A LEY & A LD RI CH I NC.

Geotechnical Engineers & 12 October 1995 Environmental Consultants File No. 10063-065

Massachusetts Department of Environmental Protection Northeast Regional Office 10 Commerce Way Woburn, Massachusetts 01801

Attention: Richard Chalpin

Subject: Publication of Legal Notice for PIP Site W.R. Grace & Co. - Conn. 62 Whittemore Avenue DEP/NORTHEAST REGION Cambridge, Massachusetts WOBURN, RTN 3-0277 MASS.

Gentlemen:

On behalf of our client, W. R. Grace & Co.-Conn., Haley & Aldrich, Inc. is submitting a copy of the Legal Notice which will be published in the Cambridge Chronicle on 19 October 1995, pursuant to CMR 40.1405(5)(a)(1). We have also included copies of the notification of the publication of the Legal Notice to the Cambridge City Manager and the Assistant Commissioner of Health, Housing and Building for the City of Cambridge pursuant to CMR 40.1403(6)(b).

If there are any questions or comments, please do not hesitate to call or write.

Sincerely yours, HALEY & ALDRICH, INC.

Veronica Wancho O'Donnell Senior Environmental Geologist

F:\10063\066\DEPPIP. NOT

Thrmtdonmyciwppr. NOTICE OF A PUBLIC INVOLVEMENT PLAN MEETING

W.R. GRACE & CO.- CONN. 62 WHITTEMORE AVENUE CAMBRIDGE, MASSACHUSETTS RELEASE TRACKING NUMBER 3-0277

W.R. Grace & Co. - Conn. received a petition from residents in Cambridge, Massachusetts requesting this location be designated as a Public Involvement Plan site, in accordance with MGL c.21E §14(a). This law requires that, upon receiving such a petition, a plan for involving the public in decisions regarding remedial response actions must be prepared and a public meeting to present the proposed plan held.

W.R. Grace & Co. - Conn. designated this site as a Public Involvement Plan (PIP) site on September 25, 1995. A public meeting will be held at W.R. Grace & Co. - Conn.; 62 Whittemore Avenue; Cambridge, Massachusetts on November 2, 1995 at 7:00 PM to present the draft Public Involvement Plan, and to provide an update on planning for remedial actions at the site. Copies of the draft Public Involvement Plan will be made available at the meeting.

Any questions regarding this meeting or the Public Involvement Plan should be directed to DAVID WIGHTMAN, VICE PRESIDENT OF ADMINISTRATION, W.R. GRACE & CO. - CONN.; 62 WHITTEMORE AVENUE; CAMBRIDGE, MASSACHUSETTS at (617) 498-4983.

F:\10063\066\notice.pip

DEP/NORTHEAST REG WOBURN, MASS. <'5-. - z-7 ___ S a 1S1

' ALE AL R C INC.

Geotechnical Engineers & 12 October 1995 Environmental Consultants File No. 10063-065

Massachusetts Department of Environmental Protection Northeast Regional Office 10 Commerce Way Woburn, Massachusetts 01801

Attention: Richard Chalpin

Subject: Publication of Legal Notice for PIP Site W.R. Grace & Co. - Conn. 62 Whittemore Avenue Cambridge, Massachusetts RTN 3-0277 DEP/NORTHEAST REGION WOBUKN, MASS. Gentlemen:

If there are any questions or comments, please do not hesitate to call or write.

Sincerely yours, HALEY & ALDRICH, INC.

Veronica Wancho O'Donnell Senior Environmental Geologist

F:\10063\066\DEPPIP.NOT

58 Charles Street Cambridge, MA 02141-2147 Offices Scarbtrough. Mine Rochester. New York Tel: 617/494-1606 Deiwer. Colorado Sliver Spring, Marviland Cl e('ela1d, Ohio Fax: 617/577-8142 Gla stonb ur y, Conlecticut Bedford, New Hampshire NOTICE OF A PUBLIC INVOLVEMENT PLAN MEETING

W.R. GRACE & CO.- CONN. 62 WHITTEMORE AVENUE CAMBRIDGE, MASSACHUSETTS RELEASE TRACKING NUMBER 3-0277

W.R. Grace & Co. - Conn. designated this site as a Public Involvement Plan (PIP) site on September 25, 1995. A public meeting will be held at W.R. Grace & Co. - Conn.; 62 Whittemore Avenue; Cambridge, Massachusetts on November 2, 1995 to present the draft Public Involvement Plan, and to provide an update on planning for remedial actions at the site. Copies of the draft Public Involvement Plan will be made available at the meeting.

Any questions regarding this meeting or the Public Involvement Plan should be directed to DAVID WIGHTMAN, VICE PRESIDENT OF ADMINISTRATION, W.R. GRACE & CO. - CONN.; 62 WHITEMORE AVENUE; CAMBRIDGE, MASSACHUSETTS at (617) 4984983.

F:\0063\066\notice.pip a A A 3 AQA

Geotechnical Engineers & Environmental Consultants 12 October 1995 File No. 10063-066

Bay State Community Newspapers 346 W. Cummings Park Woburn, Massachusetts 01801

Attention: Ms. Marcia Duggan

Subject: Publication of Legal Notice Pursuant to MCP 40.1404(5)(a)(1) W.R. Grace & Co. - Conn. 62 Whittemore Avenue Cambridge, Massachusetts

Dear Ms. Duggan:

Pursuant to the Massachusetts Contingency Plan (MCP) 40.1404(5)(a)(1), Haley & Aldrich, Inc., on behalf of our client, W.R. Grace & Co.-Conn., is submitting the attached legal notice for publication in the 19 October 1995 edition of the Cambridge Chronicle. Also, the portions of the Notice that are capitalized and/or are in bold-face type must be printed as such. We understand that the charge for publication is $15.60 per column inch and that the invoice will be forwarded to Haley & Aldrich, Inc.

If there are any questions or comments, please do not hesitate to call or write.

Sincerely yours, HALEY & ALDRICH, INC.

Veronica Wancho O'Donnell Senior Environmental Geologist

F:\ 10063\066\NEWSNOT.PIP

58 Charles Street Cambridge, MA 02141-2147 Offices Scarborough. Maine Rochester, New York Tel: 617/494-1606 Denv er. Colorado Silver Spring, Miarviand Cleveland, Ohio Fax: r,17/577142 Glaston'Lrv. Connecticut BeOdtord. Ne Hampshire S

A %. a0 A~A

Geotechnical Engineers & Environmental Consultants 13 October 1995 File No. 10063-066

Cambridge Board of Health Assistant Commissioner of Health, Housing and Building 831 Massachusetts Avenue Cambridge, Massachusetts 02139

Attention: Mr. Michael Nicoloro

Subject: Legal Notice Pursuant to MCP 40.1405(5)(a)(1) W.R. Grace & Co. - Conn. 62 Whittemore Avenue Cambridge, Massachusetts

Dear Mr. Nicoloro:

Pursuant to the Massachusetts Contingency Plan (MCP) 40.1405(5)(a)(1), Haley & Aldrich, Inc. is submitting the attached legal notice to the City of Cambridge Board of Health, Housing and Building on behalf of our client, W.R. Grace & Co.-Conn. This notice will be published in the Cambridge Chronicle on 19 October 1995. If there are any questions or comments, please do not hesitate to call or write.

Sincerely yours, HALEY & ALDRICH, INC.

Veronica Wancho O'Donnell Senior Environmental Geologist

F:\ 10063\06\BDHLTH.NOT

58 Charles Street Cambridge, MA 02141-2147 Offices Scarborough, \1aine Rochester. New York Tel: 617/494-1606 Denver, Colorado Silxer Sprig, Marvland Cleveland. Ohio Fax: b17/577-s142 GLstonburv Connectcur Bediurd, New Hampslire A AA

Geatechnical Engineers & Environmental Consultants 12 October 1995 File No. 10063-066

Cambridge City Hall City Manager's Office 795 Massachusetts Avenue Cambridge, Massachusetts 02139

Attention: Mr. Robert Healy

Subject: Legal Notice Pursuant to MCP 40.1405(5)(a)(1) W.R. Grace & Co. - Conn. 62 Whittemore Avenue Cambridge, Massachusetts

Dear Mr. Healy:

Pursuant to the Massachusetts Contingency Plan (MCP) 40.1405(5)(a)(1), Haley & Aldrich, Inc. is submitting the attached legal notice to the City of Cambridge on behalf of our client, W.R. Grace & Co.-Conn. This notice will be published in the Cambridge Chronicle on 19 October 1995. If there are any questions or comments, please do not hesitate to call or write.

Sincerely yours, HALEY & ALDRICH, INC.

Veronica Wancho O'Donnell Senior Environmental Geologist

FA10063\066\CITYCAM.NOT

58 Charles Street Cambridge, MA 02141-2147 Offices Scarborough, Maine Rochester, New York Tel: 617/494-1606 Denver, Colorado 'ilver Spring, Marvland Cleveland, Ohio Fax: n17/577-8142 Glastonburv, Connecticut Bedford, New Hampsbire *0 Oto U HALEY & ALDRICH INC. EA4

Letter of Transmittal Geotechnical Engineers & Environmental Consultants

To Massachusetts Department of Environmental Protection Date 18 October 1995

10 Commerce Way File Number 10063-066

Woburn, MA Subject PIP petitioners letters

Attention Richard Chalpin

Copies Date Description 1I 16 October 1995 Notice of Public Involvement Plan Meeting Letter to Petitioners

Remarks Dear Mr. Chalpin:

Attached, please find copies of the letter sent to the petitioners at the W.R. Grace (RTN 3-0277) property regarding the Notice of Public Involvement Meeting and one copy of the Notice itself. This letter was sent pursuant to 310 CMR 40.1405(5)(a)(2). If

there are any questions, please call,

58 Charles Street Cambridge, MA 02141 Tel: 617/494-1606 Copy To Fax: 617/577-8142 offices Brea, California San Francisco, California Denver, Colorado Glastonbury, Connecticut Scarborough, Maine Silver Spring, Maryland Bedford, New Hampshire Rochester, New York Cleveland, Ohio Signed *6 00 M HALEY & A LDRICH INC. A A

Geotechnical Engineers & Environmentai Consultants

16 October 1995 File No. 10063-066

Alma Balonon-Rosen 51 Madison Avenue Cambridge, MA 02140

Subject: Notice of Public Involvement Plan Meeting

Ladies & Gentlemen:

Pursuant to 310 CMR 40.1405(5)(a)(2), we are enclosing a copy of the Legal Notice which will be published in the 19 October 1995 edition of the Cambridge Chronicle. This Notice deals with the Public Hearing, scheduled for 2 November 1995 at 7:00 PM at the W.R. Grace facility located at 62 Whittemore Avenue.

If there are any questions regarding this meeting, please call Mr. David Wightman at W.R. Grace at (617) 498-4983.

Sincerely yours, HALEY & ALDRICH, INC.

Veronica Wancho O'Donnell Senior Environmental Geologist

F:\ 0063\066\PUBNOT.PIP

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0* 100 HAH LEY & ALDRICH INC. A A

Geotechnical Engineers & Environmental Consultants

16 October 1995 File No. 10063-066

Joel Nogic 94 Clifton Street, Apt. 2 Cambridge, MA 02140

Subject: Notice of Public Involvement Plan Meeting

Ladies & Gentlemen:

If there are any questions regarding this meeting, please call Mr. David Wightman at W.R. Grace at (617) 498-4983.

Sincerely yours, HALEY & ALDRICH, INC.

Veronica Wancho O'Donnell Senior Environmental Geologist

F:\10063\066\PUBNOT.PIP

Prn ucdon mycid rear *0 I** HALEY & A LDRICH INC. AQA

Geotechnical Engineers & Environmental Consultants

16 October 1995 File No. 10063-066

Karen Coker 24 Magoun Street Cambridge, MA 02140

Subject: Notice of Public Involvement Plan Meeting

Ladies & Gentlemen:

If there are any questions regarding this meeting, please call Mr. David Wightman at W.R. Grace at (617) 498-4983.

Sincerely yours, HALEY & ALDRICH, INC.

Veronica Wancho O'Donnell Senior Environmental Geologist

F:\10063\066\PUBNOT.PIP

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HA LEY & A DRICH INC. MGM

Geotechnical Engineers & Environmental Consultants

16 October 1995 File No. 10063-066

Raghu Naia 16 Seagrave Road Cambridge, MA 02140

Subject: Notice of Public Involvement Plan Meeting

Ladies & Gentlemen:

If there are any questions regarding this meeting, please call Mr. David Wightman at W.R. Grace at (617) 498-4983.

Sincerely yours, HALEY & ALDRICH, INC.

Veronica Wancho O'Donnell Senior Environmental Geologist

F:\10063\066PUBNOT. PIP

P t.1 o""d'd MM Oe *10 LH A LEY & AL D RI CH I NC. I A4A

Geotechnical Engineers & Environmental Consultants

16 October 1995 File No. 10063-066

Alison Dowd 115 Harvey Street Cambridge, MA 02140

Subject: Notice of Public Involvement Plan Meeting

Ladies & Gentlemen:

If there are any questions regarding this meeting, please call Mr. David Wightman at W.R. Grace at (617) 498-4983.

Sincerely yours, HALEY & ALDRICH, INC.

Veronica Wancho O'Donnell Senior Environmental Geologist

F:\10063\O66\PUBNOT.PIP

rm-rWr. rW Oe 010 M H A LEY & A L DRI CH I NC.

Geotechnical Engineers & Environmental Consultants

16 October 1995 File No. 10063-066

Helen Flynn 111 Clifton Street Cambridge, MA 02140

Subject: Notice of Public Involvement Plan Meeting

Ladies & Gentlemen:

If there are any questions regarding this meeting, please call Mr. David Wightman at W.R. Grace at (617) 498-4983.

Sincerely yours, HALEY & ALDRICH, INC.

Veronica Wancho O'Donnell Senior Environmental Geologist

FA063\066\PUBNOT.PIP

PWrton rcrled payr 100 *0 H A L EY & A LDRICH INC. A-4A

Geotechnical Engineers & Environmental Consultants

16 October 1995 File No. 10063-066

Janet Malenfant 16 Harrison Avenue Cambridge, MA 02140

Subject: Notice of Public Involvement Plan Meeting

Ladies & Gentlemen:

If there are any questions regarding this meeting, please call Mr. David Wightman at W.R. Grace at (617) 498-4983.

Sincerely yours, HALEY & ALDRICH, INC. (5;&tf4JU,

Veronica Wancho O'Donnell Senior Environmental Geologist

F:\10063\066\PUBN(T.PIP

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H A L EY & ALDRICH INC. I A73

Geotechnical Engineers & Environmental Consultants

16 October 1995 File No. 10063-066

Don Abrams 17 Day Street Cambridge, MA 02140

Subject: Notice of Public Involvement Plan Meeting

Ladies & Gentlemen:

If there are any questions regarding this meeting, please call Mr. David Wightman at W.R. Grace at (617) 498-4983.

Sincerely yours, HALEY & ALDRICH, INC.

Veronica Wancho O'Donnell Senior Environmental Geologist

F:\10063\066PtUBNOT.PIP

Prmid n rayLaiw pr Og 00 HALE Y & ALDRICH INC. A$i9i

Geotechnical Engineers & Environmental Consultants

16 October 1995 File No. 10063-066

Sylvia Barnes 196 Harvey Street Cambridge, MA 02140

Subject: Notice of Public Involvement Plan Meeting

Ladies & Gentlemen:

If there are any questions regarding this meeting, please call Mr. David Wightman at W.R. Grace at (617) 4984983.

Sincerely yours, HALEY & ALDRICH, INC.

Veronica Wancho O'Donnell Senior Environmental Geologist

F:\ 0063\066\PUBNOT.PIP

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Geotechnical Engineers & Environmental Consultants

16 October 1995 File No. 10063-066

Malvina Montero 85 Harvey Street Cambridge, MA 02140

Subject: Notice of Public Involvement Plan Meeting

Ladies & Gentlemen:

If there are any questions regarding this meeting, please call Mr. David Wightman at W.R. Grace at (617) 498-4983.

Sincerely yours, HALEY & ALDRICH, INC.

Veronica Wancho O'Donnell Senior Environmental Geologist

F:\10063\066\PUBNOT. PIP

Pnnteo, cadi 0* 0t SH A LEY & A LD RI CH I NC. I $9%

Geotechnical Engineers & Environmental Consultants

16 October 1995 File No. 10063-066

Lisa Birk 28 Magoun Street Cambridge, MA 02140

Subject: Notice of Public Involvement Plan Meeting

Ladies & Gentlemen:

If there are any questions regarding this meeting, please call Mr. David Wightman at W.R. Grace at (617) 498-4983.

Sincerely yours, HALEY & ALDRICH, INC.

Veronica Wancho O'Donnell Senior Environmental Geologist

F:\ 10063\066\PUBNOT.PIP

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H A L E Y & A L D R I C H I N C. M A 70

Geotechnical Engineers & Environmental Consultants

16 October 1995 File No. 10063-066

Craig A. Kelley 78 Porter Street, #41 Cambridge, MA 02140

Subject: Notice of Public Involvement Plan Meeting

Ladies & Gentlemen:

If there are any questions regarding this meeting, please call Mr. David Wightman at W.R. Grace at (617) 4984983.

Sincerely yours, HALEY & ALDRICH, INC.

Veronica Wancho O'Donnell Senior Environmental Geologist

F:\]0063\066\PUBN0T.PIP

Pnf,,k v~apw O0 ) *I* HALEY & A LDRICH INC. A7A

Geotechnical Engineers & Environmental Consultants

16 October 1995 File No. 10063-066

Ann Barns 50 Churchill Avenue Cambridge, MA 02140

Subject: Notice of Public Involvement Plan Meeting

Ladies & Gentlemen:

If there are any questions regarding this meeting, please call Mr. David Wightman at W.R. Grace at (617) 498-4983.

Sincerely yours, HALEY & ALDRICH, INC.

Veronica Wancho O'Donnell Senior Environmental Geologist

FA0063\066\PUBNOT.PIP

Prnied -n rcWcedp. 00 HALEY & ALDRICH INC.

Geotechnical Engineers & Environmental Consultants

16 October 1995 File No. 10063-066

Jim McSweeney 29 Harrison Avenue Cambridge, MA 02140

Subject: Notice of Public Involvement Plan Meeting

Ladies & Gentlemen:

Pursuant to 310 CMR 40.1405 (5)(a) (2), we are enclosing a copy of the Legal Notice which will be published in the 19 October 1995 edition of the Cambridge Chronicle. This Notice deals with the Public Hearing, scheduled for 2 November 1995 at 7:00 PM at the W.R. Grace facility located at 62 Whittemore Avenue.

If there are any questions regarding this meeting, please call Mr. David Wightman at W.R. Grace at (617) 498-4983.

Sincerely yours, HALEY & ALDRICH, INC. IkT14idl

Veronica Wancho O'Donnell Senior Environmental Geologist

F:\0063\066PUBNOT.PIP

Pimr - rd1.p,' 00 09 HALEY & ALD RICH INC. A 7F]N

Geotechnical Engineers & Environmental Consultants

16 October 1995 File No. 10063-066

Carolyn Mieth 15 Brookford Street Cambridge, Massachusetts 02140

Subject: Notice of Public Involvement Plan Meeting

Ladies & Gentlemen:

If there are any questions regarding this meeting, please call Mr. David Wightman at W.R. Grace at (617) 498-4983.

Sincerely yours, HALEY & ALDRICH, INC.

Veronica Wancho O'Donnell Senior Environmental Geologist

F:U0063\066\PUBNOT.PIP

Prmttai onr WydT. .; H A L E Y & A L DR I C H IN C.

Geotechnical Engineers & Environmental Consultants

16 October 1995 File No. 10063-066

Richard D. Clarey 15 Brookford Street Cambridge, Massachusetts 02140

Subject: Notice of Public Involvement Plan Meeting

Ladies & Gentlemen:

If there are any questions regarding this meeting, please call Mr. David Wightman at W.R. Grace at (617) 498-4983.

Sincerely yours, HALEY & ALDRICH, INC.

Veronica Wancho O'Donnell Senior Environmental Geologist

F:\0063\066\PUBNOTPIP

PrniioW mci prm NOTICE OF A PUBLIC INVOLVEMENT PLAN MEETING

W.R. GRACE & CO.- CONN. 62 WHITTEMORE AVENUE CAMBRIDGE, MASSACHUSETTS RELEASE TRACKING NUMBER 3-0277

W.R. Grace & Co. - Conn. received a petition from residents in Cambridge, Massachusetts requesting this location be designated as a Public Involvement Plan site, in accordance with MGL c.2 1E §14(a). This law requires that, upon receiving such a petition, a plan for involving the public in decisions regarding remedial response actions must be prepared and a public meeting to present the proposed plan held.

F:\I 0063\066\notice.pip V 016 Au* t 30, 1995

Mr. David Wightman Vice President of Administration W.R. &race & Co. 62 Whittemore Avenue Cambridge, MA 02140

Dear Mr. Wightman:

With regard to a 'Notice of an Initial Site Investigation' advertised in the August 10th "Cambridge Chronicle", the enclosed petitioners (see petition) wish to request participation in a plan for involving the public in decisions regarding response actions as provided for in 310 CMR 40.1405.

We look forward to both your reply and to eventual participation.

For the Petitioners,

Alma Balonon-Rosen Joseph J. J se h

24 Magoun St. 51 Madison Ave. 1 8 Dudley t. Cambridge, MA Cambridge, MA Cambridge, MA 02140 02140 02140

cc Cambridge City Council John O'Btien, Health Commissioner Karen Stromberg, DEP *i- r- - - Q Q AQs 1,fl

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i Amended Order

IN CITY COUNCIL

September 18, 1995 COUNCILLOR TRIANTAFILLOU COUNCILLOR BORN COUNCILLOR~DUEHAY COUNCILLOR TOOMEY

WHEREAS: A number of neighbors in North Cambridge have organized themselves into the Alewife Study Group; and

WHEREAS: These concerned citizens of the City have worked countless hours to investigate and process the issues which arise by reason of The proposed development plans on the W.R. Grace site in North Cambridge and prepare a report on their activities, for presentation and consideration by the council; and -

WHEREAS: The City greatly benefits from the participation of such citizens' group; now therefore be it

ORDERED: That the City congratulate the Alewife Study Group for its work; and be it further

ORDERED: That the City Manager and the Community Development Department, be and is hereby requested to take all appropriate steps to determine the best use for the W.R. Grace site in a cooperative manner, including the establishment of a formal committee which would include but need not be limited to representatives from the Alewife Study Group, representatives from Jefferson Park and Rindge Towers, the City Administration, the property owner and the developer, to begin discussions around planning for the site and the recommendations prepared by the Study Group; and be it further

ORDERED: That the process begin with a widely advertised public meeting.

In City Council September 18, 1995 Adopted as amended by the affirmative vote of eight members. Attest:- D. Margaret Drury, City Clerk.

) A true copy;

ATTEST:- D. Margaret Drury City Clerk - Massa e Department of Environme - tection BWSC-107A Bureau NOe Site Cleaqup

TIER CLASSIFICATiON, TIER 11EXTENSION & Release Tracking Number TIER II TRANSFER TRANSMITTAL FORM 0277 Pursuant to 310 CMR 40 0510 and 40.0560 (Subpart E) A. DISPOSAL SITE LOCATION: Disposal Site Name: W R .Grafre & Co - Conn

Street: _9 Whittemore Avenue Location Aid:

City/Town: Cambrirge ZIPCode: 02140-1692 Related Release Tracking Numbers That This Suhrrdtal Wi Address: B. THIS FORM IS BEING USED TO: (check all that apply) Submit a new or revised Tier Classification Submittal for a Tier I Site, including a Numerical Ranking Scoresheet (complete Sections A, B, C, I J, K and L).

Submit a new or revised Tier Classification Subnital for a Tier || Site, including a Numerical Ranking Scoresheet (complete Sections A, B, C, F, G, I,J, K and L). is not Submit a Notice that an additional Release Tracking Number(s) is (are) being linked to this Tier Classified Site and rescoring l required at this time (complete Sections A, B, J,K ar-d L).If this submittal is for a Tier ISite, you must also submit a Minor Permit Modification kTransmittal Form (BWSC-109). List Additional Release Tracking Number(s): l Submit a Phase I Completion Statement support"ig a Tier Classification Submittal (complete Sections A, B, I, J, K and L). El Submit a Tier 11Extension Submittal for Response Actions at a Tier 11Site (complete Sections A, B, D. F, G, 1, J, K and L). El Submit a Tier || Extension Submittal for Response Actions taken after expiration of a Waiver, pursuant to 310 CMR 40.0630(4) (complete Sections A, B, D. F.J, K and L, and aso conplete Sections G and I or Section H).* a Tier 11Site L Submit a Tier || Transfer Submittal for a change in person(s) undertaking Response Actions at (complete Sections A, B, E, F, G, I, J, K L. M, N and 0). LI Submit a Tier || Transfer Submittal for a change in person(s) undertaking Response Actions at a Waiver Site, pursuant to 310 CMR 40.0630(6) (complete Sections A, B, E, F. J, K, L, M, N and 0, and also complete Sections G and I or Section H).* You must attach all supporting documentation required for each use of form indicated, including copies of any Legal Notices and Notices to Public Officials required by 310 CMR 40.1400. *NOTE: The Waiver expires on the effective date of this submittal and allfurther Response Actions must be taken as a Tier || Site. C. TIER CLASSIFICATION SUBMITTAL: Numerical Ranking Score for Disposal Site: (from Numerital Ranking Scoresheet) 332

Proposed Tier Classification of Disposal Site: (check ore) Tier IA [] Tier IB [ Tier IC Tier I Check which, if any, of the Tier I inclusionary criteria are met by the Disposal Site, pursuant to 310 CMR 40.0520:

Groundwater is located within an Interim Wellhead Protection Area or a Zone 11,and there is evidence of groundwater contamination by an Oil or Hazardous Material at the time of Tier CAssification at concentrations equal to or exceeding the applicable RCGW-1 Reportable Concentration set forth in 310 CMR 40.0360.

[] An Imminent Hazard is present at the time of Ter Classification. Scoresheet L] Check here if this Tier Classification revises a prevkxs submittal for this Disposal Site. You must include a revised Numerical Ranking with this submittal. If a Tier IPermit has been issue. you may also need to submit a Major Permit Modification Application (BWSC 10). If incorporating additional Release(s) into the Dispose Site, list Release Tracking Number(s):

D. TIER 11EXTENSION SUBMITTAL REQUIREMENTS: State the expiration date of the Tier 11Classification or Water for the Disposal Site, whichever is applicable: Attach a statement summarizing wtiy a Pennanent or Temporary Solution has not been achieved at the Disposal Site. A Tier || Extension is effective for a period of one year beyond the current expiration date of the Tier || Classification or Waiver. E. TIER || TRANSFER SUBMITTAL REQUIREMENTS: State the proposed effective date of the change in persons) undertaking Response Actions at the Disposal Site:

Attach a statement summarizing the reasons for the proposed change in person(s) undertaking the Response Actions. All Response Actions must be completed by the deadfline applicable to the person who first filed either a Tier Classification Submittal for the Disposal Site or received a Waiver of Approvals. Revised 416195 Supersedes Forms BWSC-010 (in part) and 014 Page 1of4 Do Not Alter This Form Massac' s Department of Environmen' _ itection BWSC-107A Bureau 6-Arte Site Cleanup

TIER CLASSIFICATION, TIER || EXTENSION & Release Tracking Number TIER II TRANSFER TRANSMITTAL FORM 0277 Pursuant to 310 CMR 40.0510 and 40.0560 (Subpart E) F. DISPOSAL SITE COMPLIANCE HISTORY SUMMARY:

> If providing either a T-r Classification Submittal for a Tier || Site or a Tier 11Extension Submittal for a Waiver Site, the person named in Section J must provide a Compliance History. > If providing a Tier NExtension Submittal for a Tier |1 Site, the person named in Section J must update their Compliance History since the effective date of the Tier 11Classification. > If providing a Tier UTransfer Submittal for a Tier || or Waiver Site, the person named in Section M must provide a Compliance History. Compliance History for (povide only one name per History): W. R, Grace & Co.-Conn. Cambridge Facility - Note 1

E3 Check here if there has been no change to the Compliance History of the person named above (Extension Submittal for a Tier 11Site ONLY).

List all permits or license that have been issued by the Department that are relevant to this Disposal Site:

PROGRAM: PERMIT NUMBER: PERMIT CATEGORY: FACILITY ID: Air Quality Note 2 Hazardous Waste (M.G.L c. 21 C) - Note 3

Solid Waste

Industrial Wastewater Maagement

Water Supply Note 4

Water Pollution ContmlIsface Water DEPIN______

Water Pollution ControVrundwater -IaMWOBURN,

Water Pollution ConUroSewer Connection

Wetland & Waterways

List all other Federal. sa or local permits, licenses, certifications, registrations, variances, or approvals that are relevant to this Disposal Site: ISSUING AUTHORITY OR PROGRAM, OR DOCUMENTATION TYPE: IDENTIFICATION NUMBER: DATE ISSUED: Xassachusetts Water Resources Authority Sewer Use 09001993 6/30/95 Note 5

If needed, attach to this Transmittal Form a statement further describing the Compliance History of this Disposal Site. This statement must describe the compliance history of ?e person named above with the following: (1) DEP regulations; ard (2) other laws for the prtection of health, safety, public welfare and the environment administered or enforced by any other government agency. Such a statement should dentify information such as:

(1) actions relevant to t-e Disposal Site taken by the Department to enforce its requirements including, but not limited to, a Notice of Noncompliance (NCN). Notice of Intent to Assess Civil Administrative Penalty (PAN), Notice of Intent to Take Response Action (NORA), and an administrative erafcement order; (2) administrative consErt orders; (3) judicial consent judgements; (4) similar administrate actions taken by other Federal, state or local agencies; (5) civil or criminal actcos relevant to the Disposal Site brought on behalf of the DEP or other Federal, state, or local agencies; and (6) any additional ree'.rit information.

For each action identified. orovide the following information:

(1) name of the issuing authority, type of action, identification number and date issued; (2) description of nonc:rnpiance cited: (3) current status of the matter; and (4) final disposition, if ary.

Revised 415/95 Supersedes Forms BWSC-010 (in part) and 014 Page 2 of 4 Do Not After This Form Massac l Department of Environmen etection BWSC.:107A Bureau te Site Cleanup

TIER CLASSIFICATION, TIER 11EXTENSION & Release Tracking Numbe TIER 11TRANSFER TRANSMITTAL FORM 0277 Pursuant to 310 CMR 40.0510 and 40.0560 (Subpart E) 1. LSP OPINION: (continued) > if Secton B of this form indicates that a Tier ii Extension Submittal or a Tier i Transfer Submittal is being submitted, the response action(s) that is (are) the subject of this submital (i) is (are) being implemented in accordance with the applicable provisions of M.G.L. c. 21 E and 310 CMR 40.0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth inthe applicable provisions of M.G.L. c. 21 E and 310 CMR 40.0000, and (iii) complies(y) with the identified provisions of all orders, permits, and approvals identified in this submittal. I am aware that significant penalfies may result, including, but not limited to, possible fines and imprisonment, if I submit information which I know to be false, inaccurate or materially incomplete. ] Check here if the Response Action(s) on which this opinion is based, if any, are (were) subject to any order(s), permit(s) and/or approval(s) issued by DEP or EPA. If the box is checked, you MUST attach a statement identifying the ap- ' ions thereof.

LSPName: Weley F St-impsnn LSP#: 2 2? Stamp f

Telephone: 617- 494-190; Ext.: T1 1 WESEY FAX: (optional) -'; - I STIPSON. 332 NNo 232 Signature: ST Date: ( r J. PERSON MAKING SUBMITTAL: NameofOrganization: W R- Grace & Co - Cnnn

Name of Contact: navii 1ightman Title:

Street: 62 Whittemore Avenue

City/Town: Cambridge State: - Telephone: 617-49R-49A Ext.: FAX: (o ional) A SS-- K. RELATIONSHIP TO DISPOSAL SITE OF PERSON MAKING SUBMITTAL: hkunECRuSMi E RP or PRP Specify: q Owner Q Operator Q Generator Q Transporter Other RP or PRP: [] Fiduciary, Secured Lender or Municipality with Exempt Status (as defined by M.G.L. c. 21 E, s. 2) [] Agency or Public Utility ona Right of Way (as defined by M.G.L. c. 21E, s. 5(j))

0 Any Other Person Making Submittal Specify Relationship: L. CERTIFICATION OF PERSON MAKING SUBMITTAL: 1, David Wih tman , attest under the pains and penalties of perjury (i)that I have personally examined and am familiar with the information confined in this submittal, including any and all documents accompanying this transmittal form, (ii) that, based on my inquiry of those individuals immediately responsible for obtaining the information, the material information contained in this submittal is, to the best of my knowledge and , u , accurate and complete, and (iii) that I am fully authorized to make this attestation on behalf of the entity legally responsible for this sub ittal. i/t entity on whose behalf this submittal is made am/is aware that there are significant penalties, including, but not limited to, possibi I ent for willfully submitting false, inaccurate, or incomplete informat n. By: Title: (sign ure) For: -R . & - Conn. Date: (print nam prson or entity recorded in Section J) Enter address of the person providing certification(s), including Ability and Willingness Certification where applicable, if different from address recorded in Section J: Street: City/Town: State: - ZIP Code:

Telephone: Ext.: - FAX: (optional) YOU MUST COMPLETE ALL RELEVANT SECTIONS OF THIS FORM OR DEP MAY RETURN THE DOCUMENT AS INCOMPLETE. IF YOU SUBMIT AN INCOMPLETE FORM, YOU MAY BE PENALIZED FOR MISSING A REQUIRED DEADLINE, AND YOU MAY INCUR ADDITIONAL COMPLIANCE FEES. Revised 416/95 Supersedes Forms BWSC-010 (in par) and 014 Page 4 of 4 Do Not Alter This Form r MassaC Department of Environmenl tetion BWSC-1078 Bureau te Site Cleanup

TIER CLASSIFICATION, TIER 11 EXTENSION & Release Tracking Number TIER 11TRANSFER TRANSMITTAL FORM S 0277 Pursuant to 310 CMR 40.0510 and 40.0560 (Subpart E)

Only complete and submit this page if you are providing a Tier |1 Transfer Submittal for a Tier |1 Site or a Waiver Site.

M. PERSON WHO IS TRANSFEREE: Name of Organization:

Name of Contact: Title:

Street:

City/Town: State: ZIP Code:

Telephone: Ext.: FAX: (optional) N. RELATIONSHIP TO DISPOSAL SITE OF PERSON WHO IS TRANSFEREE: (check one) [] RP or PRP specify: Q Owner Q Operator Q Generator Q Transporter Other RP or PRP: [] Fiduciary, Secured Lender or Municipality with Exempt Status (as defined by M.G.L. c. 21 E, s. 2) [] Agency or Public Utility on a Right of Way (as defined by M.G.L. c. 21E, s. 5()) [] Any Other Person Who is Transferee Specify Relationship: 0. CERTIFICATION OF PERSON WHO IS TRANSFEREE: I, , attest under the pains and penalties of perjury (i) that I have persoraly examined and am familiar with the information contained inthis submittal, including any and all documents accompanying this transmittal form, (i) that, based on my inquiry of those individuals immediately responsible for obtaining the information, the material information contained in this subrnital is, to the best of my knowledge and belief, true, accurate and complete, and (iii) that I am fully authorized to make this attestation on behaff of t entity legally responsible for this submittal. I/the person or entity on whose behalf this submijttal is made am/is aware that there are sigriicart penalties, including, but not limited to, possible fines and imprisonment, for willfully submitting false, inaccurate, or incomplete information.

R. Title: (signature)

For. _ Date: (print name of person or entity recorded in Section M)

Enter address of the person providing certification, if different from address recorded in Section M:

Street:

City/Town: State: - ZIP Code:

Telephone: Ext,: _ FAX: (optional) YOU MUST COMPLETE ALL RELEVANT SECTIONS OF THIS FORM OR DEP MAY RETURN THE DOCUMENT AS INCOMPLETE. IF YOU SUBMIT AN INCOMPLETE FORM, YOU MAY BE PENALIZED FOR MISSING A REQUIRED DEADLINE, AND YOU MAY INCUR ADDITIONAL COMPLIANCE FEES.

AUG 9 1995

DEP/NORTHEAST REGION WOBURN, MASS.

Revised 4/6195 Supersedes Forms 3WSC-010 (in part) and 014 Page 1 of 1 Do Not Alter This Form \Br4R: DEPARTMENT OF ENVIRONMIENTAL PfsWcTN

MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL PROTECTION Bureau of Waste Site Cleanup

NUMERICAL RANKING SYSTEM SCORESHEET (310 CMR 40.1511)

CLASSIFICATION SUBMITTAL DISPOSAL SITE SCORE

Initial Submittal Re-Classification II IIt IV V Vi TOTAL

105 122 25 100 -20 332

Disposal Site Tier Classification IF Permit Category (Tier I Only) A B C

I I. DISPOSAL SITE INFORMATION DEP Release 3-0277 N: 4695775 Tracking Number(s) E: 323850 DEP Disposal Site_Coordinates L__ Number(s)

Disposal Site Name W. R . Grace & Co. - Conn -

Disposal Site Address 62 Whittemore Avenue City: Cambridge, Massachusetts zip:02140-1692

Is the Disposal Site classified Tier I because it is located within the boundaries of a Zone II or itnim Wellhead Yes No Protection Area and groundwater concentrations equal or exceed RCGW-I at the time of Twer Classification pursuant to 310 CMR 40.0520(2)(a) .?

Is the Disposal Site classified Tier I because an Imminent Hazard is present at the time of Tier Clssification Yes No pursuant to 310 CMR 40.0520(2)(a)2.? No

I attest under the pains and penalties of perjury that I have personally completed this Numerica Ranking System Scoresheet, and have personally examined and am familiar with the information contained in this submittal, including any aid all documents accompanying this submittal, and in my professional opinion and judgment based upon: (i) the standard of care in 309 CMR 4.02(I), (ii) the applicable provisions of 309 CMR 4.02(2) and (3), and (iii) thovisions of 309 CMR 4.03(5). to the best of my knowledge, informarion and belief, this Scoresheet was developed in accordance wi a plicable provisions of M.G.L. c. 21E and 310 CMR 40,0000. 1 am awrare ti significant penalties may result, including. but not I t sible fines and imprisonment, if I submit information which I know wnte false. inaccurate or materially incomplete. IAJT.AI 2332 JLs Licen lSeg si&al Signature LSP Registration Number Date Wesley E. Stimpson Haley & Aldrich, Inc. (617) 494-1606 LSP Name (Printed) Company Name Telephone Number W.R. Grace & Co. - Conn. . accordance with 310 CMR 40.0009.

1/13/95 (Effective 2/1/95) 3 10 CMR - 1751 0 : DEPARTMENT OF ENVIRONMENTAL PR N

40.1511 (Continued)

1 Table M.A. OHM TOXICITY SCORE

CONCENTRATION soillsediment: pg/g; surface/groundwater/Ag/1) OHM g 99 100-999 1,000 - 9,999 10,000- > 100,000 NAPL NAPL 100,000 NAPL < 0.5" 0.5" - 12" > 12"

Arsee 30. 4...... 50 60 ... ._......

Bezne 15 35 45 55 65 75 Bsistidshex$)pihalate 3(o W 30 40 50 60 70 Cadmnu 20 30 40 50 CabnTtahoie30 40 50 60 70 8O

Cblorobenzene 5 15 25 35 45 55 65 Cra~n f0Hl3 40

Chromb VI 10 (20) 30 40 50

CoalTar 5< l5 25 3$ 4$ 55 6$

Cnnid5 25 35 45 Llulworotbaa 7...... 0......

1,2 Dichloroethane 20 30 40 50 60 70

Edethemene S ' $ 3$ 4$ 55 6$

Ethyee Dibromide 20 30 40 50 60 70 80

121 dnebv00 a Se i 25 35S 45 $ 65

Gasoime (irgin product) 10 20 30 40 50 60 70 Lomd i'5 a0'

Mercurv 30 40 50 60 70 80 Matine Charlh 10 (23 05 0 70

PAdsi10 20 30 40 50 60 70

Terchooehlee1 30 4 50 60 7

1..11 Trichloroethane 5 25 35 45 55 65

1/13/95 (Effective 2/1/95) 310 CMR - 1754 0 : DEPARTMENT OF ENVIRONMENTAL PR 0 N

[Table III.A. OHM TOXICITY SCORE

CONCENTRATION (soil/sediment: ug/g; surface/grounawater ug1) OHM s99 100-999 1,000 - 9,999 10,000- > 100,000 NAPL NAPL 100,000 NAPL < 0.5" 0.5' - 12" > 12"

Trichloroethylene '25___ 35 45 35 65 75

Vinyl Chloride 15 25 35 45 55 65 75 Xienes 10 20 30 40 50 60 Zinc 1 10 20 40

1/13/95 (Effective 2/1/95) 310 CMR - 1755 : DEPARTMENT OF ENVIRONMENTAL PR N

40.1511 (Continued)

Use Worksheet HI.A. . to determine the OHM Toxicity Score for OHM not listed in Table 11.A. See 40.1513 for Human Health-Based Toxicity Values for each OHM.

TOXICITY SCORE IWorksheet II.A.1 OHM CONCENTRATION HUMAN HEALTH-BASED r Jse ug/g for Soil and pg/I for Surface Water and Groundwater TOXCITY VALUE99 100 - 999 1,000 - 9,999 10,000 - > 100,000 NAPL NAPL I j 100,000 NAPL < 0.5' 0.5" - 12' > 12'

< 5 I 10 20 30 40 50 60

5-19 5 15 25 35 45 55 65

20-29 10 20 30 40 50 60 70

30-39 15 25 35 45 55 65 75

40-50 20 30 40 50 60 70 80

[ I.A.O. HM and Concentrations Used in Section lI.A. 1. OHM Human Concentration Concentration OHM Health-Based (Soil - ug/g) ppm (Water - ug/i) ppb Toxicity Toxicity Value Score

Chloromethane 22 -ND- 9.9 10

Carbon Disulfide 8 0.18 300 15

1,1 Dichloroethene 28 0.042 9.6 10

2 Butanone (methyl ethyl ketone) * 8 0.110 1100 25

4 Methyl - 2 Pentanone * 8 1.2 380 15

2 Hexanone 25 0.38 310 20

Styrene 20 25 -ND- 10

2,2 Oxybis propane * -NA- 28

Bromodichloromethane 25 -ND- 5.5 10

* No human health based toxicity value given in MCP

1113/95 (Effective 2/1/95) 310 CMR - 1756 R: DEPARTMENT OF ENVIRONMENTAL PR ,r(ON

40.1511 (Continued)

Use Worksheet IIL A. 1. to determine the OHM Toxicity Score for OHM not listed in T.ble lIL A. See 40.1513for Human Health-Based Toxicity Values for each OHM.

Worksheet IILA.1 OHM TOXICITY SCORE

CONCENT RATON HUMAN HEALTH-BASED Use g/g for Soil and ug/ for Surface Wmr and Groundwater TOXICITY VALUE 99 100-999 1,000 - 9,999 10,000- > 100,000 NAPL NAPL 100,000 jNAPL < 0.5" 0.5" - 12" > 12"

< 5 1 10 20 30 40 50 60

5-19 5 15 25 35 45 55 65

20-29 10 20 30 40 50 60 70

30-39 15 25 35 45 55 65 75

40-50 20 30 40 50 60 70 80

aL A.!. OHM and Concentrations Used in Section lI.A.I.

OHM Human Concentration Concentration OHM Healh-Based (Soil - pg/g) (Water - yg/) Toxicity Toxicity Value Score

Dibenzo (a,h) anthracene* 35.8 175.4

Indeno 1,2,3 - cd pyrene* 44 97.5 138 30

Butyl benzyl phthalate 20 0.111 10.2 10

Di-n-octyl phthalate* 24 85

p-chloro-m-cresol* 0.217 7.4

2,4 - Dimethyl phenol 18 -ND- 150 15

2,4 Dinitrophenol 25 -ND- 170 20

n-nitrosodipenylamine 22 0.123 2.8 10

silver 25 3.6 20 10

No human health based toxicity value given in MCP

1/13/95 (Effective 2/1/95) 310 CMR - 1758 R: DEPARTMENT OF ENVIRONMENTAL P N

Table V.B. ENVIRONMENTAL TOXICITY SCORE -

CONCENTRATION (soil/sediment: ug/g; surface/groundwater ug/) OHM < 1 1 -99 100-999 1,000 - 9,999 2 10,000

Vinyl Chloride * 5 10 15 20 25

Sylenes *:*t $2..t:2> 15 202 Zinc 1 5 10 15 20

*Scores derived by default methods 40.1516(2).

1/13/95 (Effective 2/1/95) 310 CMR - 1763 - PR: DEPARTMENT OF ENVIRONMENTAL fP N

NON-TEXT PAGE

1/13/95 (Effective 2/1/95) 310 CMR - 1765 R: DEPARTMENT OF ENVIRONMENTAL P$ ON

40.1511 (Continued) Use Worksheet V.B.1. to determine Environmental Toxicity Scoresfor OHM not listed in Table V.B. See 40.1516 for Environmental Toxicity Values for each OHM.

Worksheet V.B.1 ENVIRONMENTAL TOXICITY SCORE

CONCENTRA7TON ENVIRONMENTAL TOXICITY VALUE Use ug/g for Sail and ugl for Surface Water or Groundwater

< 1 -99 100-999 1,000 - 9,900 10,000

10 0 1 5 10 15

20 1 5 10 15 20

30 5 10 15 20 25

40 10 15 20 25 30

50 15 20 25 30 35

I~ KB.1. OHM and Concentrations Used in Section V.B. 1. OHM Environmental Concentration Com~entration Environmental Toxicity Value (Soil - Ug/g) (War - yg/1) Toxicity Score

1/13/95 (Effective 2/1/95) 310 CMR - 1766 'I

r OR: DEPARTMENT OF ENVIRONMENTAL PtO N

40.1511 (Continued) VI. MITIGATING DISPOSAL SITE-SPECIFIC CONDITIONS

V. MITIGATING DISPOSAL SIT-SPECIC CONDITIONS

Disposal site-specific conditions that warrant amending the site score. Changes direcdy related to NRS Sections or Subsection scores may not reduce the score more than the relevant subsection value assigned for the disposal site in that subsection. Section VI must reference specific pages of the Phase . Section VI may not exceed ± 50 Points and may be scored only in 5-point increments. Attach addnanal pages as necessary.

The site has been characterized at a level of detail greater than a Phase II Comprehensi' 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 (Je:Tys Pond) score of 30 points is reduced by 10 points (to a total of

20 points) due to data from post Phase II investigations (Long-Term Monitor= Report, December 1994) indicating that surface water and

sediment contamination do not exist in Jerrys Pond.

Under Section V. Ecological Population, Part A, the protected open space s50 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 surface water

contamination does not exist in Alewife Brook at locations both upstream anf downstream of the site. The Reservation is also located

across Alewife Brook Parkway from the site. Alewife Brook Parkway is a di-ided, four lane highway with no opportunity for surficial

contamination from the site to impact the Reservation.

Score Disposal Site Score Amendment (Not to Exceed ± 50 Points) -20

40.1512 Exposure Pathway Designation Criteria

1/13/95 (Effective 2/1/95) 310 CMR - 1767 0 Cct, bia1 C 62- A/ I Tt- orte- HA & A LDRICH INC.

Geotechnical Engineers & 4 August 1995 Environmental Consultants File No. 10063-065

Massachusetts Department of Environmental Protection Northeast Regional Office 10 Commerce Way Woburn, Massachusetts 01801

Attention: Richard Chalpin

Subject: Tier 11 Classification Legal Notice Publication W.R. Grace & Co. - Conn. 62 Whittemore Avenue Cambridge, Massachusetts DEP/NORTHEAST REGION RTN 3-0277 - WOBURN, MASS.

Gentlemen:

On behalf of our client, W. R. Grace & Co.-Conn., Haley & Aldrich, Inc. is submitting a copy of the Legal Notice which will be published in the Cambridge Chronicle on 10 August 1995, pursuant to CMR 40.1403(6)(a). We have also included copies of the notification of the publication of the Legal Notice to the Cambridge City Manager and the Assistant Commissioner of Health, Housing and Building for the City of Cambridge pursuant to CMR 40.1403(6)(b).

If there are any questions or comments, please do not hesitate to call or write.

Sincerely yours, HALEY & ALDRICH, INC.

Veronica Wancho O'Donnell Senior Environmental Geologist

F:\10063\065\DEP.NOT

58 Charles Street Cambridge, MA 02141-2147 Offices Scarborough, Maine Rochester, New York Tel: 617/494-1606 Denver, Colorado Silver Spring, Maryland Cleveland, Ohio Fax 617/577-8142 Glastonbury, Connecticut Bedford, New Hampshire

Printatonn yclepr. W.R. Grace & Co. - Conn. is publishing the following legal notice pursuant to CMR 40.1403(6)(a) regarding a pre-1986 release of oil and/or hazardous materials at the W.R. Grace & Co. - Conn. property located at 62 Whittemore Avenue in Cambridge, Massachusetts. The property has been listed with the Massachusetts Department of Environmental Protection since 15 January 1987.

NOTICE OF AN INITIAL SITE INVESTIGATION AND TIER H1 CLASSIFICATION

W.R. GRACE & CO.- CONN. 62 WHITTEMORE AVENUE CAMBRIDGE, MASSACHUSETTS RELEASE TRACKING NUMBER 3-0277

Pursuant to the Massachusetts Contingency Plan (310 CMR 40.0480), an Initial Site Investigation has been performed at the above referenced location. A release of oil and/or hazardous materials has occurred at this location which is a disposal site (defined by M.G.L. c. 21E, Section 2). This site has been classified as Tier II, pursuant to 310 CMR 40.0500. Response actions at this site will be conducted by W.R. Grace & Co. - Conn. who has employed Wesley E. Stimpson of Haley & Aldrich, Inc. to manage response actions in accordance with the Massachusetts Contingency Plan (310 CMR 4.0000).

M.G.L. c. 21E and the Massachusetts Contingency Plan provide additional opportunities for public notice of and involvement in decisions regarding response actions at disposal sites: 1) The Chief Municipal Official and Board of Health of the community in which the disposal site is located will be notified of major milestones and events, pursuant to 310 CMR 40.1403; and 2) Upon receipt of a petition from ten or more residents of the municipality in which the disposal site is located, or of a municipality potentially affected by a disposal site, a plan for involving the public in decision regarding response actions at the site will be prepared and implemented, pursuant to 310 CMR 40.1405.

To obtain more information on this disposal site and the opportunities for public involvement during its remediation, please contact DAVID WIGHTMAN, VICE PRESIDENT OF ADMINISTRATION, W.R. GRACE & CO. - CONN., 62 WHITTEMORE AVENUE, CAMBRIDGE, MASSACHUSETTS at (617) 498-4983.

F:\10063\065\nodce.wpf is 3-21'7 Art HALEY & ALDRICH INC.

Letter of Transmittal Geotechnical Engineers & Environmental Consultants

To Department of Environmental Protection Date Auaust 8. 1995 Northeast Regional Office File Number 10063-065

10 Commerce Way, Woburn, MA 01801 Subject W.R Grace & Co. - Conn.

Attention Mr. Richard Chalpin RTN No. 3-0277

Copies Date Description 1 4 Aug 1995 Letter to DEP concerning LSP Evaluation Opinion RTN No. 3-0277; Numerical Ranking System Scoresheet for

W.R. Grace & Co. - Conn. (3-0277) and supporting documentation

1 4 Aug 1995 LSP Evaluation Opinion Transmittal Form, BWSC 110 1 4 Aug 1995 Tier Classification Transmmittal Form, BWSC 107A

Remarks

[LEP/NORTHEAST REGION V0BURNWO MAS

LICENSED SITE PROFESSIONAL (LSP) Release Tracking Number EVALUATION OPINION TRANSMITTAL FORM Pursuant to 310 CMR 40.0600 (Subpart F) L 0277 A. SITE OR LOCATION TO BE INVESTIGATED (LTBI) INFORMATION:

Provide the following information as it appears on the Transition List of Confirmed Disposal Sites and Locations To Be Investigated. Site or LTBI Name: W P Grace & Cn - nn,

Street: -62 Wh -i tt mnr Avmm- Location Aid:

City/Town: Cambri d ___ ZIPCode: 07140-1r92

Site Status: (check one) J Location To Be Investigated E] Unclassified Disposal Site Non-Priority Disposal Site without a Waiver Date First Listed in Above Category: 01 / 5/A7

Related Release Tracking Numbers that this LSP Evaluation Opinion Addresses:

B. LSP EVALUATION OF SITE OR LOCATION TO BE INVESTIGATED: (check one of the following)

[ Check here if this location is NOT a Site where a Release of Oil(s) or Hazardous Material(s) occurred that is subject to the notification requirements of 310 CMR 40.0300, and no further response actions are required.

] Check here if a Release of Oil(s) and Hazardous Material(s) subject to the notification requirements of 310 CMR 40.0300 occurred or may have occurred at this location, but Response Actions completed prior to the date of this LSP Evaluation Opinion meet the requirements of a Class A or Class B Response Action Outcome. Ifthis LSP Evaluation Opinion is checked, you must meet all appropriate Response Action Outcome requirements described at 310 CMR 40.1000. You must include with this submittal documentation equivalent to a Response Action Outcome, including all supporting materials.

Indicate the class of the equivalent Response Action Outcome:

Q Class A-1 Q Class A-2 0 Class A-3 0 Class B-1 0 Class B-2 You may choose to submit a completed Response Action Outcome Statement (BWSC-104) and supporting documentation in lieu of an LSP Evaluation Opinion, provided that you make the submittal prior to the LSP Evaluation Opinion deadline.

Check here if a Release subject to the notification requirements of 310 GMR 40.0300 occurred or may have occurred at this location, and further Response Actions are necessary, pursuant to 310 CMR 40.0000.

If this option is checked you must make one of the following submittals by the applicable LSP Evaluation Opinion deadline: (i) provide a Tier Classification Submittal Transmittal Form (BWSC-1 07) and, if necessary, a Tier I Permit Application; (ii) provide a Response Action Outcome Statement (BWSC-1 04); (iii) or provide a Downgradient Property Status Submittal (BWSC-1 04).

El Check here if this location is a Site that is Adequately Regulated, pursuant to 310 CMR 40.0110. Specify which other regulatory authority applies: Q Response Actions at this Site, which are being conducted as a HSWA Corrective Action, are Adequately Regulated, pursuant to 310 CMR 40.0112.

Q Response Actions at this Site, which is a 21C facility under the RCRA Authorized State Hazardous Waste Program, are Adequately Regulated under M.G.L. c. 21C and 310 CMR 30.000, pursuant to 310 CMR 40.0113.

Q Response Actions at this Site, which is a Solid Waste Management facility, are Adequately Regulated under M.G.L. c. 21 H, M.G.L. c. 111, §150A and/or 310 CMR 19.000, pursuant to 310 CMR 40.0114.

You must attach all supporting documentation for the LSP Evaluation Opinion indicated, including copies of any Legal Notices and Notices to Public Officials required by 310 CMR 40.1400. C. LSP OPINION:

I attest under the pains and penalties of perjury that I have personally examined and am familiar with this transmittal form, including any and all documents accompanying this submittal. In my professional opinion and judgment based upon application of (i) the standard of care in 309 CMR 4.02(1), (ii) the applicable provisions of 309 CMR 4.02(2) and (3), and (iii) the provisions of 309 CMR 4.03(5), to the best of my knowledge, information and belief, this LSP Evaluation Opinion was developed in accordance with the applicable provisions of M.G.L. c. 21 E and 310 CMR 40.0000, and the response action(s) upon which this opinion is based, if any, were reasonable and appropriate to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G.L. c. 21 E and 310 CMR 40.0000.

I am aware that significant penalties may result, including, but not limited to, possible fines and imprisonment, if I submit information which I know to be false, inaccurate or materially incomplete.

SECTION C IS CONTINUED ON THE NEXT PAGE.

Revised 3130p9 Suversedes Form BWSC-015 Pane I of 2 Do Not Alter This Form Massachufls Department of Environmental tection BWSC-1 10 Bureau of Vte Site Cleanup

LICENSED SITE PROFESSIONAL (LSP) Release Tracking Number EVALUATION OPINION TRANSMITTAL FORM Pursuant to 310 CMR 40.0600 (Subpart F) C. LSP OPINION: (continued)

E Check here if the Response Action (s) on which this opinion is based, if any, is (are) subject to any order(s , permit(s) and/or approval(s) issued by DEP or EPA. If this box is checked, you MUST attach a statement identifying the applicable f.

LSP Name: Wes1 ey E. At-impson LSP#: 2'1f22 Stamp:

Telephone: 1 7-494-1O( Ext.: 715.E -S E FAX: (optional) -A14 8 STIUPSON 4 No. 2332:

Signature: GST Date: D. PERSON SUBMITTING LSP EVALUATION OPINION:

Name of Organization: W P Grace & rn - Cann-

Name of Contact: David Wicghtman Title:

Street: 6,2 Wh-i temnrpe Avemi. City/Town: ramhr-idge State: MA ZIP Code: 02140-1692

Telephone: 617-49a-9R 3 Ext.: - FAX:(optional) 917-4191-2029 E. RELATIONSHIP TO SITE OR LOCATION TO BE INVESTIGATED OF PER / 0 1- OPINION: (check one)

) RP or PRP Specify: Qt Owner Q Operator (9 Generator (9 Transporter th R 9 Fiduciary, Secured Lender or Municipality with Exempt Status (as defined by M.G.L. c. 2i

F] Agency or Public Utility on a Right of Way (as defined by M.G.L. c. 21 E, s. 5()) AUG 9 1995 ] Any Other Person Submitting LSP Evaluation Opinion Specify Relationship: F. CERTIFICATION OF PERSON SUBMITTING LSP EVALUATION OPINION UL/NORTHEAST REGION 1. David Wightman , attest under the pains and penalti s of perjuW gr rined and 4n familiar with the information contained in this submittal, including any and all documents acco ' , " inquiry of those individuals immediately responsible for obtaining the information, the material information contained in this submittal is, to the best of my knowledge a i f, true, accurate and complete, and (iii) that I am fully authorized to make this attestation on behalf of the entity legally responsible to 's su . I/theperson or entity on whose behalf this submittal is made am/is aware that there are significant penalties, including, but not ~ to, os I ines and imprisonment, for willfully submitting false, inaccurate, or incomplete information.

By: Title: (sig ure For: W R . Co. - in . Date: (print na e of person or entity recorded in Section D)

Enter address of the person providing certification, if different from address recorded in Section D:

Street:

City/Town: State: - ZIP Code:

Telephone: Ext.: FAX: (optional)

YOU MUST COMPLETE ALL RELEVANT SECTIONS OF THIS FORM OR DEP MAY RETURN THE DOCUMENT AS INCOMPLETE. IF YOU SUBM1T AN INCOMPLETE FORM, YOU MAY BE PENALIZED FOR MISSING A REQUIRED DEADLINE, AND YOU MAY INCUR ADDITONAL COMPLIANCE FEES.

Revised 3130/95 Supercedes Form BWSC-015 Page 2 of 2 Do Not Alter This Form 0 /97 cNE4~ 0

A. Daniel Sapir Chairman Kingston Board of Health Ann Frazier 23 GREEN STREET. DRAWER E Vice Chairman KINGSTON. MASSACHUSETTS 02364 Mando Aldrovandi VOICE: (617) 585-0503 - FAX; (617) 585-0534 Philemon Walters William Watson

July 11, 1995

John H. Morgan, Chairman North End Task Force c/o 13 Rock Avenue Winchester, MA 01890

Dear Mr. Morgan:

Please be advised that pursuant to your request for public records regarding W. R. Grace materials which capped the landfill in the early 80's, no file has been located nor do we find any reference in the minutes for 1980, 1981 and 1982.

If we can be of any further assistance, please do not hesitate to contact this office.

Sincerely,

A. Daniel Sapir -dam airman I

ADS/pib 0 A9 7F/7-c ,c~ 6~

UNIVERSTTY OF RHODE ISLAND

a - January 30, 1995

Mr. John H. Morgan, Chairman North End Task Force 13 Rock Avenue Winchester, MA 01890

Dear Mr. Morgan:

In accordance with our telephone conversation of January 27, 1995 I have enclosed the following documents:

* Enclosure C - Volumetric Ranking - Generator PRPs

* Enclosure D - Volumetric Ranking - Transporter PRPs

These lists concern the International Depository Incorporated (IDI) site in North Kingstown, Rhode Island. This was a Superfund site that has been cleaned.

After our conversation I re-reviewed all of my records and do not find any dump sites in Kingston that were open after 1979-80.

Perhaps the reference to Rhode Island was an error and it should read Kingston, Massachusetts.

If I can be of any further assistance in your efforts to trace the material of W. R. Grace Company that you are dealing with, please feel free to contact me.

Sincerely,

Francis L. Mc Govern III, CHCM:CSE Director

FIMh: cal Enclosures

DIARMENI 01 SAl IY ANI) RIS MANAGEMLL1 wh nI. p r 500 Alumni Avenue. Kogston. Rhode hiland 02881 -WOI Phone:401-792-2618 hix 401-89-5126 ______5 ,-77 COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL PROTECTION BUREAU OF WASTE SITE CLEANUP POST OFFICE BOX 4062 BOSTON, MASSACHUSETTS 02106

February 28, 1994

Jay Burrill Environmental Coordinator W. R. Grace Mail Stop 84 62 Whittemore Ave Cambridge, MA 02140

Re: Cambridge - W. R. Grace Site Number 3-0277 Account Number 3-0277/XXXXX-00 Payment Request No. 94-WSC-102047-Al PRP ID: WR GR-03

Dear Mr. Burrill:

Per a telephone conversation with Jeanne Iascone of my staff, enclosed please find Oversight Recovery Request for Information Reports which are detailed listings of Oversight Costs incurred, listed chronologically by phase. For your convenience, I am enclosing reports which itemize the costs appearing on the most recent Request for Payment of Response Action Costs (RAC) as well as the RACs dated November 2, 1990 and June 17, 1991. Please note that the RAC dated February 26, 1992 contained no new costs. Please be advised that the difference in amount between the RACs and the attached listings is due to rounding.

The rate charged for each person is their actual pay rate, plus a fringe rate of .45 times the pay rate. This fringe rate includes an allowance for paid leave as well as actual fringe benefits (refer to 310 CMR 40.020 "hourly rate of compensation"). Indirect costs of $18.40/hour, as provided in 310 CMR 40.621, are also added for all personnel. Please note that the Department will not review the reasonableness or appropriateness of indirect or fringe rates. Both the indirect and fringe rates were developed with extensive input from management consulting and accounting firms and were discussed at public hearings prior to the promulgation of these regulations.

If you have any further questions, please contact Jeanne lascone of my staff at 617/556-1 3.

Si n ly,

Robert P. Kalag an Cost Recovery Section Chief Bureau of Waste Site Cleanup cc: Sites Staff, Northeast Regional Office - A -w to % -D

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-C- -f N V N 3 co 0O Au o . 0 - 6a-o ZIn 0 WNCPPN Ij at D. L Wightman Vice President, Administration (2A(E Construction Products Division WR. Grace & Co. Cambridge, MA 02140 August 20, 1991 (617)876-1400

Dear Mr. Fitzgerald:

Enclosed is a report summarizing the results of the March 1991 round of sampling of selected perimeter wells and surface water bodies. This is the third round of sampling of a long-term monitoring program requested by the Department of Environmental Protection as part of its review of the NOR response for our Cambridge site.

The report continues to show that there is no off-site impact of contamination determined to be present on-site.

In addition to sending you a copy, we have forwarded copies to Alice Wolf, Mayor of the City of Cambridge, and to the North Cambridge Public Library so that the information will be readily available to the general public.

If you have any questions, please don't hesitate to call me at 876-1400, extension 3203. We will be conducting the fourth round of sampling in Septemnber and will report the results as soon as our consultant, Haley & Aldrich, makes the information available.

S nce ly

Mr. John Fitzgerald Department of Environmental Protection 5 Commonwealth Avenue Woburn, Massachusetts 01801

I?' 01

C-_ PI-Y CRMvws1ZsttC

D. L. Wig i Vice President, Administration RA( Construction Products Division W.R. Grace & Co. Cambridge, MA 02140 December 12, 1991 (617)876-1400

Dear Mr. Fitzgerald:

Enclosed is a report summarizing the results of the September 1991 round of sampling of selected perimeter wells at our site. This is the fourth round of sampling of a long-term monitoring program requested by the Department of Environmental Protection as part of its review of the NOR response for our Cambridge site.

The report continues to show that there is no off-site impact of contamination determined to be present on-site.

Sincer' y,

Mr. John Fitzgerald Department of Environmental Protection 5 Commonwealth Avenue Woburn, Massachusetts 01801 3-o2 -77 * avid L.Wightman CtAn-, b o q Vice President, Admnistration Grace Construction Products &7. (Ai /it7 /oLec GRACE W.R. Grace & Co.- Conn. A 62 Whittemore Avenue Cambridge, MA 02140-1692 March 15, 1995 (617) 498-4983

Via AirBorne Express

Mr. John Fitzgerald Department of Environmental Protection 10 Commerce Way Woburn, MA 01801-1006

Dear Mr. Fitzgerald:

Enclosed is a report summarizing the results of the December 1994 sampling of selected perimeter wells and off-site water bodies in the proximity of our site. This is the eighth round of sampling in a program requested by the Department of Environmental Protection as part of the NOR response for our Cambridge site.

Once again the report continues to show that there is no off-site impact of contamination determined to be present on-site. We now have data spanning eight years which confirms this fact. Further, the data shows a gradual but steady decline in concentration levels of napthalene in groundwater wells located on-site. Napthalene is the only chemical compound present in levels considered to be-higher than trace amounts.

Because eight years of sampling show no off-site impact on groundwater on nearby bodies of water and on-site groundwater shows declining concentrations of napthalene, there appears to be no rationale for fcontinuing the sampling program based on risk. Unless advised to the contrary, it is our intention to conclude the long-term monitoring plan Iwith this report.

A copy of the report has been forwarded to the North Cambridge Public Library so that the information will be readily available to the general public.

If you have any questions, please don't hesitate to call me at 498-4983.

Sinc ly,

DLW/BLD Enclosure

Ir D.L Wightman Vice President, Administration Division Construction Products W.R. Grace & Co Conn. 62 Whittemore Avenue Cambridge, MA 02140-1692

January 26, 1993 (617) 876-1400

Dear Mr. Fitzgerald:

Enclosed is a report summarizing the results of the September 1992 round of sampling of selected perimeter wells at our site. This is the sixth round of sampling of a long-term monitoring program requested by the Department of Environmental Protection as part of its review of the NOR response for our Cambridge site.

The report continues to show that there is no off-site impact of contamination determined to be present on-site.

In addition to sending you a copy, we have forwarded copies to Alice Wolf, Vice Mayor of the City of Cambridge, and to the North Cambridge Public Library so that the information will be readily available to the general public.

You will note the recommendation by Haley & Aldrich to reduce the sampling periods to once a year (March) and to limit the sampling to those wells and off-site bodies of water which have the capability to measure off-site impact. It is our intention to follow their recommendation, unless otherwise directed by you.

If you have any questions, please don't hesitate to call me at 876-1400, extension 3203.

Since ely,

Mr. John Fitzgerald Department of Environmental Protection 5 Commonwealth Avenue 3S Woburn, Massachusetts 01801 dE,{j 7 3 - a-9 Davd L Wig n Vice President, Admnistration Grace Construction Products

GRACE W.R. Grace & Co: Conn. 62 Whittemore Avenue J Conibrige, MA 02140-1692

(617) 498-4983 September 1, 1993

Dear Mr. Fitzgerald:

Enclosed is a report summarizing the results of the April 1993 round of sampling of selected perimeter wells at our site. This is the seventh round of sampling of a long-term monitoring program requested by the Department of Environmental Protection as part of its review of the NOR response for our Cambridge site.

The report continues to show that there is no off-site impact of contamination determined to be present on-site.

In addition to sending you a copy, we have forwarded a copy to the North Cambridge Public Library so that the information will be readily available to the general public.

You will note that we have followed the recommendation of Haley & Aldrich to reduce the sampling periods to once a year (spring) and to limit the sampling to those wells and off-site bodies of water which have the capability to measure off-site impact. This recommendation had been communicated to you in my letter lated January 26, 1993, covering the September 1992 report.

If you have any questions, please don't hesitate to call me at 498-4983.

Mr. John Fitzgerald Department of Environmental Protection 10 Commerce Way Woburn, Massachusetts 01801-1006

A& 0 D. LWightm Vice President, Administration RPZE Construction Products Division WR. Grace & Co. Cambridge, MA 02140 May 28, 1992 (617) 876-1400

Dear Mr. Fitzgerald:

Enclosed is a report summarizing the results of the March 1992 round of sampling of selected perimeter wells at our site. This is the fifth round of sampling of a long-term monitoring program requested by the Department of Environmental Protection as part of its review of the NOR response for our Cambridge site.

The report continues to show that there is no off-site impact of contamination determined to be present on-site.

If you have any questions, please don't hesitate to call me at 876-1400, extension 3203. We will be conducting the sixth round of sampling in September and will report the results as soon as our consultant, Haley & Aldrich, makes the information available.

Since el

Mr. John Fitzgerald Department of Environmental Protection 5 Commonwealth Avenue Woburn, Massachusetts 01801 Page 1 COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL PROTECTION BUREAU OF WASTE SITE CLEANUP

Request for Payment of Response Action Costs

ip Payment Is Due 45 Days From Payment Request Date 44

Payment Request No...: 92-WSC-101014-Al Payment Request Date.: February 26, 1992 Payment Due Date.: April 11, 1992 Account No...: 3-0277/XXXXX-00

REQUESTED FROM: W.R. -01

W.R. GRACE DAVID WIGHTMAN, VICE PRESIDENT 62 WHITTEMORE AVENUE CAMBRIDGE, MA 02140

Amount Paid SITE NO.: 3-0277

W.R. GRACE 62 WHITTEMORE AVE. Total Amount Due CAMBRIDGE, MA 02140 $ 0.00

A copy of this Request for Payment is beinc sent to each of the parties listed in Appendix B. It is the responsibility of the parties to apportion costs among themselves. Each party remains jointly and severally liable to the Commonwealth for the Department's total costs, unless you have filed a request for an administrative review of costs pursuant to 310 cmr 40.620 (4) or you are a debtor in bankruptcy. Please return a copy of this page with your payment. Make sure that the Payment Request No. '92-WSC-101014-A1', the Site ID No. '3-0277', and the PRP ID No. 'W.R. -01' are on the check as well in order to give a clear indication as to who is making the payment. Additional information regarding your responsibility can be found in Appendix A. Make checks payable to the Commonwealth of Massachusetts and MAIL ONLY to Department of Environmental Protection Post Office Box 4062 Boston, MA 02211 9 Page 2 COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL PROTECTION BUREAU OF WASTE SITE CLEANUP

Request for Payment of Response Action Costs

on Payment Is Due 45 Days From Payment Request Date 44

S U M M A R Y O F A M O U N T D U E Request for Payment No. 92-WSC-101014-Al For Costs Recorded Between July 2, 1989 and February 26, 1992

" PRIOR COSTS AND CREDITS Prior Balance Due ...... 1,402.82 Payment Received - Thank You..(W.R. -01)...... 1,402.82 CR

Outstanding Balance Before New Costs...... 0.00 " Net Balance Before New Costs...... 0.00

" NEW COSTS Posted between June 17, 1991 and February 26, 1992

Total New Costs...... 0.00

" NEW BALANCE DUE...... 0.00

" SUMMARY COST TO DATE INFORMATION Total Costs Processed to Date...... 6,894.86 .A 4n~ 0 Appendix B-1 COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL PROTECTION BUREAU OF WASTE SITE CLEANUP

Request for Payment of Response Action Costs

Pi Payment Is Due 45 Days From Payment Request Date 44

Re: Site Number 3-0277 / W.R. GRACE

R E S P O N S I B L E P A R T Y L I S T A copy of this Request for Payment is being sent to the parties listed below. It is the responsibility of these parties to apportion costs among themselves. Each party remains jointly and severally liable to the Common- wealth for the Department's costs.

W.R. -01 W.R. GRACE 62 WHITTEMORE AVENUE CAMBRIDGE, MA 02140 COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL PROTECTION BUREAU OF WASTE BITE CLEANUP POST OFFICE BOX 4062 BOSTON, MASSACHUSETTS 02106

August 16, 1991

Jay H. Burrill W. R. Grace & Co. 62 Whittemore Avenue Cambridge, MA 02140

Re: Cambridge - W. R. Grace Site Number 3-0277 Account Number 3-0277/XXXXX-00 Payment Request No. 91-WSC-100663-A1

Dear Mr. Burrill:

Per your request, enclosed please find documentation of the costs appearing on the above referenced Request for Payment of Response Action Costs (RAC).

Attachment 1 is a detailed listing of Oversight Costs incurred, listed chronologically by Phase. Please be advised that the difference between this listing and the above referenced RAC is due to rounding. The rate charged for each person is their actual pay rate, plus a fringe rate of .45 times the pay rate. This fringe rate includes an allowance for paid leave as well as actual fringe benefits (refer to 310 CMR 40.020 "hourly rate of compensation"). Indirect costs of $18.40/hour, as provided in 310 CMR 40.621, are also added for all personnel. Please note that the Department will not review the reasonableness or appropriateness of indirect or fringe rates. Both the indirect and fringe rates were developed with extensive input from management consulting and accounting firms and were discussed at public hearings prior to the promulgation of these regulations.

Supporting documentation for this report is available for viewing at our offices. If you wish to review this documentation, please contact Jeanne Iascone of my staff at (617) 556-1013 to set up an appointment.

Oversight costs were included in line items labeled "all other response actions" and "short term measures" on the RAC. Re: Cambridge - W. R. Grace Site Number 3-0277 Continued

If you have any questions, please feel free to contact Jeanne Iascone on my staff at 617/556-1013, Monday through Friday, between the hours of 8:00 AM and 4:00 PM.

ly,

Einc Robert P. Ka ag an Cost Recover ection Chief Bureau of Waste Site Cleanup cc: Staff, NERO -n -- DCI t CD C

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r . & 0 n4&1& e -- CLJcc G G G m e r M. lD I i----i- I- Page 1 COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL PROTECTION BUREAU OF WASTE SITE CLEANUP

Request for Payment of Response Action Costs

oP Payment Is Due 45 Days From Payment Request Date 44

Payment Request No...: 91-WSC-100663-A1 Payment Request Date.: June 17, 1991 Payment Due Date.: August 1, 1991 Account No...: 3-0277/XXXXX-00

REQUESTED FROM: W.R. -01

W.R. GRACE DAVID WIGHTMAN, VICE PRESIDENT 62 WHITTEMORE AVENUE CAMBRIDGE, MA 02140

Amount Paid SITE NO.: 3-0277

W.R. GRACE 62 WHITTEMORE AVE. Total Amount Due CAMBRIDGE, MA 02140 $ 1,402.82

Pursuant to Chapter 21E, Section 5, of the Massachusetts General Laws and 310 CMR 40.000, the above-named Department hearby requests payment of the response action costs which the Commonwealth has incurred in performing the response actions at the above noted site. A copy of this Request for Payment is being sent to each of the parties listed in Appendix B. It is the responsibility of the parties to apportion costs among themselves. Each party remains jointly and severally liable to the Commonwealth for the Department's total costs. Please return a copy of this page with your payment. Make sure that the Payment Request No. '91-WSC-100663-A1' is on the check as well as a clear indication as to who is making the payment. Additional information regarding your responsibility can be found in Appendix A. Make checks payable to the Commonwealth of Massachusetts and MAIL ONLY to Department of Environmental Protection Post Office Box 4062 Boston, MA 02211 0 Page 2 COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL PROTECTION BUREAU OF WASTE SITE CLEANUP

Request for Payment of Response Action Costs

ii Payment Is Due 45 Days From Payment Request Date 44

S U M M A R Y O F A M O U N T D U E

Request for Payment No. 91-WSC-100663-Al For Costs Recorded Between July 2, 1989 and June 17, 1991

i PRIOR COSTS AND CREDITS Prior Balance Due ...... 5,492.04 Payment Received - Thank You..(W.R. -01)...... 5,492.04 CR Outstanding Balance Before New Costs...... 0.00

o Net Balance Before New Costs...... 0.00

i NEW COSTS Posted between November 2, 1990 and June 17, 1991 Planning, managing, directing, or performing all other response actions.*...... (30.00 hrs)...... 1,402.82 Total New Costs...... 1,402.82

y NEW BALANCE DUE...... 1,402.82

y SUMMARY COST TO DATE INFORMATION Total Costs Processed to Date...... 6,894.86

* This may include, but is not limited to, activities such as: meetings and other communication with PRPs and/or their agents; review of reports submitted by PRPs or state contractors; site inspections; oversight of field activities such as well drilling and sampling; analysis or review of environmental data; enforcement activities; management of state contractors performing remedial response actions at the site. S.

Appendix B-1 COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL PROTECTION BUREAU OF WASTE SITE CLEANUP

Request for Payment of Response Action Costs

> Payment Is Due 45 Days From Payment Request Date 44 Re: Site Number 3-0277 / W.R. GRACE

R E S P O N S I B L E P A R T Y L I S T

A copy of this Request for Payment is being sent to the parties listed below. It is the responsibility of these parties to apportion costs among themselves. Each party remains jointly and severally liable to the Common- wealth for the Department's costs.

W.R. -01 W.R. GRACE 62 WHITTEMORE AVENUE CAMBRIDGE, MA 02140 F&;. 3-oz.

tqe 620wez yt w0rz~A/Ac~

Zw~ J #&swe Jtl Cbvut& Daniel S. Greenbaum (One tret 0oton, AfassazcAewst02910& Commissioner

James C. Colman Assistant Commissioner MEMORANDUM

TO: BWSC Oversight Coordinators, Site Managers

CC: BWSC Site Assessment Section Chiefs

FROM: Dana Muldoon, Section Chief, Cost Recovery

RE: Cost Recovery Correspondence

DATE: December 17, 1990

It has been brought to my attention that I have been remiss in keeping site managers informed of the cost recovery activities at their sites. Although I have been sending copies of the draft RACs, I have neglected to send copies of follow-up correspondence related to the RACs, including requests for administrative review, further detail, and miscellaneous other requests. For this I will undoubtedly receive coal tar in my stocking.

I have attached copies of correspondence which has been generated as a result of RACs sent to date, separated by site manager. I apologize for the volume, in the future I will send it as it is generated. If you do not wish to receive this correspondence let me know.

oriinal Printed on Recvcied Paper 010 D L WghtmQ Vice President, Administration GRACE Construction Products Division WR. Grace& Co. Cambridge, MA 02140

December 11, 1990 (617) 876-1400

Dear Mr. Fitzgerald:

Enclosed is a report summarizing the results of the Spetember 1990 round of sampling of selected perimeter wells at our site. This is the second round of sampling of a long-term monitoring program requested by the Department of Environmental Protection as part of its review of the NOR response for our Cambridge site.

The report is self-explanatory and continues to show that there is no off-site impact of contamination determined to be present on-site.

In addition to sending you a copy, we have forwarded copies to Alice Wolf, Mayor of the City of Cambridge, and to the North Cambridge Public Library so that the information contained within the report will be readily available to the general public.

If you have any questions, please don't hesitate to call me at 876-1400, extension 3203. We will be conducting our third round of sampling in the spring of 1991 and will report the results as soon as our consultant, Haley & Aldrich, makes the information available.

Sinicere y s,

Mr. John Fitzgerald Department of Environmental Protection 5 Commonwealth Avenue Woburn, Massachusetts 01801 COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL PROTECTION BUREAU OF WASTE SITE CLEANUP POST OFFICE BOX 4062 BOSTON, MASSACHUSETTS 02106

November 28, 1990

David L. Wightman W. R. Grace & Co. - Conn. 62 Whittemore Avenue Cambridge, MA 02140

Re: Cambridge - W. R. Grace Site Number 3-0277 Account Number 3-0277/XXXXX-99 Payment Request No. 90-WSC-100073-Al

Dear Mr. Wightman:

Per Ms. Seeler's request, enclosed please find documentation of the costs appearing on the above referenced Request for Paymant of Response -Action Costs (RAC).

Attachment I is a detailed listing of Oversight .Costs incurrec, listed chronologically by Phase.-

Supporting documentation for this report is available for viewing at our offices.. If. you wish to review this documentation, please contact me to set up an appointment..

Oversigit costs were included in line items labeled "all other response actions". and "short term measures" on the RAC.

If you have any questions, please feel free to contact me at 617/292-5649, Monday through':Friday, between the houtrsof 9:00-AM. and 5:00 PM.

Sincerely, -

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'I Grace Specialty Chemicals Co.

GRACE W R. Groce & Co.- Conn 62 Whitlemore Avenue Combridge, Mass. 02 40-1692

(617} 876-1400

November 9, 1990

Department of Environmental Protection Post Office Box 4062 Boston, Massachusetts 02211

Attention : Cost Recovery Documentation Request Coordinator

RE: Site Number 3-0277 Payment Request No. 90-WSC-100073-Al

Dear Sir or Madam:

W.R. Grace has received a request for payment of response action costs for the above referenced site in the amount of $5,492.04. W.R. Grace requests an itemization of this bill in order to determine the reasonableness and/or appropriateness of this assessment.

Please mail the itemization requested to the attention of:

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

Thank you for your prompt attention to this matter.

Very truly yours,

Marcia Seeler Assistant Environmental Counsel U.- I..

U -' D. L.Wightman Vice President, Administration Construction Products Division

W.R. Grace & Co. Cambridge, MA 02140

(617)876-1400 October 26, 1990

Dear Bob:

Enclosed is a copy of the final report of our bioremediation test project in Cambridge. Entitled "W. R. Grace Field Demonstration Report - Phase II," it covers the results of the study for the period May 1989 through July 1989; however, data is included for the Phase I operating period as well.

We have concluded that bioremediation is a viable remediation technique for our site based on geotechnical conditions that exist and the nature of the contaminants present.

The enclosed copy is my file copy, so I would appreciate your returning it when you have completed your review. If I can be of any further help, please feel free to give me a call at 876-1400, extension 3203.

Si cerely,

Mr. R. H. Eisengreen 5 Valley Road Acton, Massachusetts 01720 0 * FILE COPY Jvuc&z1ilsyo

Status Report

W. R. Grace fleld

Demonstration Report

Phase I

PREPARED BY

ENVIRONMENTAL SOLUTIONS, INC. P. 0. BOX 45212-231 BATON ROUGE, LA 70895 (504) 291-4440

SEPTEMBER 18, 1990

;John A. Christiansen, P.E. 3 Ralph J ler, Ph.D. Status Report

W. R. Grace Field Demonstration

Technical Report

TABLE OF CONTENTS

EXECUTIVE SUMMARY

1.0 Discussion of the Phase I Activity (August 1988 - October 1989)

2.0 Description of the Phase I Operations (May 1989-August 1989)

3.0 Results of Phase il Demonstration

4.0 Conclusions

.0 Recommendations

REFERENCES

TIME LINE OF MAJOR EVENTS DURING PHASE I AND 11

FIGURES AND TABLES

APPENDICES - ANALYTICAL DATA FIGURES AND TABLES

Figures

Figure 1 Vicinity Map Figure 2 Site Map Figure 3 Field Demonstration BCU Construction Details Figure 4 Soil Microorganism Concentration Variation with Time-Cell 1 Figure 5 Soil Microorganism Concentration Variation with Time-Cell 2 Figure 6 Soil Temperature During the Field Demonstration Figure 7 Total Petroleum Hydrocarbon Concentration Variation with Time-Cell 1 Figure 8 Total Petroleum Hydrocarbon Concentration Variation with Time-Cell 2 Figure 9 Naphthalene Concentration Variation with Time-Cell 1 Figure 10 Naphthalene Concentration Variation with Time-Cell 2

Tables

Table 1 Soil Sampling and Analytical Schedule Table 2 Field Demonstration Laboratory Report Table 3 Summary of Chemical Analytical Results Table 4 Summary of Kinetic Data and Treatment Times Executive Summary

W.R. Grace Construction Products Division, Cambridge, MA, authorized Environmental Solutions, Inc. (ESI) and Haley & Aldrich (H&A) to investigate the feasibility of bioremediation of soils contaminated with petroleum hydrocarbons and naphthalene at the Alewife Center site. The field demonstration was initiated in August 1988. Phase I activity consisted of constructing the field demonstration unit and excavating 400 cubic yards of soil from two areas on the site for initial treatment. The initial treatment took place from August 30, 1988, to October 31, 1988, when it was shut down due to cold weather conditions. ESI prepared a status report dated February 27, 1989, which described that period of activity (identified as Phase 1) in detail. The report, summary, and conclusions indicated successful bloremediation of petroleum hydrocarbons (TPH), principally from Site 3 soils and some success in degrading naphthalene primarily from soils taken from Site 4. The report identified operating problems, principally associated with poor cultivation and low temperatures, which may have Interfered with successful operations on the Site 4 or naphthalene contaminated soils.

In order to complete the bioremediation demonstration and determine whether operating problems could be overcome, a second phase was initiated. This phase was initiated on May 23,1989 and carried out until July 27,1989. ESI supplied a site foreman, equipment, chemicals, and technical assistance to carry out this phase. Haley & Aldrich provided engineering oversight, sampling assistance, and analytical interpretation. Control analyses, consisting principally of microbiological and nutrient parameters, were performed by ESI at their Baton Rouge laboratory. Target hydrocarbons, consisting of naphthalene, volatile organic hydrocarbons (VOCs), and TPH were analyzed by Alpha Analytical, Inc. in Cambridge, MA.

The Phase I demonstration consisted of performing some repairs on the demonstration cell constructed during Phase 1,removing the water from the cell, and completing the treatment of any soils remaining in the treatment unit. The treatment unit, which was divided into two areas, contained primarily petroleum hydrocarbon contaminated soils in Cell 2 and primarily naphthalene contaminated soils in Cell 1. After removing the water from Cell 2 and drying out the soils, sampling activity determined that the target parameters on Cell 2 had been met for petroleum hydrocarbons, naphthalene, and VOCs. Soils In Cell 1, however, required further treatment for naphthalene. This was primarily due to inadequate cultivation during the Phase I demonstration. Subsequent corrected cultivation and nutrient amendment techniques allowed treatment of the naphthalene contaminated soils during the remainder of the Phase Il demonstration. In order to more adequately determine contaminant levels at the site and provide fUrther demonstration, ESI returned to Site 4 and excavated an additional 200 cubic yards of naphthalene contaminated soil. This material had a range of naphthalene of 8-79 mg/kg with a mean value of 46 mg/kg naphthalene. During subsequent treatment In Phase 11,over 90 percent of the naphthalene was removed.In addition, petroleum hydrocarbons and VOCs were treated to target levels. This report details the Phase I demonstration, as well as provides a summary of Phase I activities which were the basis for this year's work. The report Is organized as follows:

Section 1.0 - This section provides a description of the Phase I activity including the construction of the treatment unit or biological closure unit (BCU), the initial excavation, contaminant levels, and treatment activities. it also describes some of the operating problems which were identified in Phase I and which were corrected in Phase lI. Section 2.0 - This section provides a description of the Phase li activities. It describes how cultivation, maintenance, and sampling operations were carried out and also describes where material was excavated from and what observations were made. This section also describes the sampling and analysis activity during Phase I and some of the analytical procedures used to insure adequate data quality control.

Section 3.0 - This section states the results of the combined Phase I and Phase i field demonstration, including a discussion of the potential treatment rates for naphthalene.

Section 4.0 - This section provides conclusions as to the feasibility of bioremediation. it also provides treatment times for each constituent.

Section 5.0 - This section provides recommendations for full-scale implementation of a bioremediation project with conceptual design information regarding the size of treatment units required and their annual rates of treatment.

This report is intended as a supplement to the ESI Phase I report dated February 27,1989. The appendix to this report contains only those data and analyses generated during Phase li (June 1-September 1, 1989). The figures and tables, however, include the entire Phase I/Phase Il operating period with some corrections made for the dormant period during winter (November 1, 1988-May 31, 1989). 1.0 Discussion of Phase I Activity

W.R. Grace, Incorporated, Construction Products Division, has a building site at Alewife Center in Cambridge, MA. Plans include construction of an office complex on up to seven sites over a period of several years. Figure 1 shows the location of the project. During excavation, various affected soils containing petroleum hydrocarbons, naphthalene, and volatile organic compounds (VOCs) are anticipated. Among the options for treatment of this material is bioremediation. To determine the feasibility of this option, W.R. Grace (WRG) contacted Environmental Solutions, Inc. (ESI) to evaluate bioremediation through laboratory and field-scale simulations and demonstrations. A laboratory feasibility study was conducted from April to June 1988, with results documented in a report dated December 7,1988. The conclusion of this study was that bioremediation was feasible for the constituents listed above. In order to evaluate the field feasibility of this option and determine what materials-handling problems would be encountered, a field demonstration was recommended. A field demonstration was authorized by W.R. Grace and began on August 20, 1989. Haley & Aldrich (H&A) provided engineering oversight and analytical Interpretation. Subsurface Technologies Inc. (STI), a local contractor, provided excavation and materials-handling, including cultivation. Alpha Analytical, Inc. provided analyses of target hydrocarbon parameters. ESI provided technical support for the bioremediation option, as well as microbiological control analyses for operations.

The results of this study are completely described in an ESI report dated February 27, 1989. Construction of the demonstration unit or biological closure unit (BCU) was complete by August 29, 1988. The location of the BCU is given in Figure 2. The construction details of the demonstration unit are shown in Figure 3. In the week which followed, approximately 200 cubic yards of contaminated soil was excavated from Site 3 and placed In Cell 2. An additional 200 cubic yards was excavated from Site 6 and Site 4, and placed in Cell 1. The Site 3 soils were primarily contaminated with petroleum hydrocarbons. The Site 4 and 6 soils placed in Cell 1 were contaminated with trace amounts of phthalates and higher concentrations of naphthalene. Most of the naphthalene contaminated soil came from Site 4.

Operations progressed through October 31, 1988. During this period, Cell 2 materials were easily cultivated and responded to biological treatment. Evidence of this, as described in the report, consisted of increasing microbial concentrations, removal of total petroleum hydrocarbons as described by the Coast Guard method, and total petroleum hydrocarbons as described by 418.1. During the 60-day treatment period, TPH (Coast Guard) declined over 99.5% from an initial level of 1200 mg/kg to a final mean concentration of <6 mg/kg. It was concluded that Cell 2 demonstrated successful bioremediation of petroleum hydrocarbons.

Interpretation Cell 1 data was less clear. Initial naphthalene concentrations were higher that anticipated. This caused problems in the Phase I demonstration from two perspectives: (1) Since biodegradation rates are concentration dependent, the initial higher than anticipated concentration slowed down the rate of treatment, and (2) the initial nutrient applications made to Cell 1 were based on anticipated naphthalene levels and inadequate for the actual starting concentrations. The higher than anticipated naphthalene concentrations resulted in nutrient depletion and a lower than required microbial population. erations and material handling was also a problem in Cell 1. The Cell 1 material included ds which tended to pack tightly and inhibit transfer of oxygen and provide cultivation blems. The equipment and operating problems were also caused from deeper material within Cell 1 to be turned over slowly rather than In the first few days of operation. This resulted In the higher concentration naphthalene material being brought up into the zone of incorporation (ZOI) during the entire 60-day treatment period. When all of the material had been brought up, cold temperatures impacted upon the degradation of further material, and on October 31, 1988, the demonstration was halted because winter temperatures had caused biodegradation to decline below effective treatment rates. The conclusions of the report Indicated that bioremediation was feasible but that operating problems would have to be overcome for bioremediation to be successful. A second phase was recommended In which the following corrective actions would be Implemented: 1. Improved cultivation techniques for mixing. 2. Analyses for naphthalene specific organisms (NSO) to aid in controlling the demonstration. 3. Improved control over materials excavated to limit starting concentrations of naphthalene. 4. Improved nutrient control by the use of priority analytical turnaround for nutrients on Day 0.

These recommendations were implemented during Phase I. 2.0 Description of the Phase II Operations (May 1989 - July 1989)

ESI provided a site foreman and laborer to mobilize on site for Phase 11.As in the previous phase, H&A provided engineering oversight and analytical interpretation. Alpha Analytical provided analyses of target hydrocarbons; primarily for total petroleum hydrocarbons, volatile organic compounds (VOCs), and naphthalene. ESI also provided technical support personnel for Phase Il as required as well as control as parameter analyses at the Baton Rouge, Louisiana facility.

Operations began on May 15, 1989. Initial operations consisted of removal of water from the cells which had accumulated from winter storm events. Since it was known that naphthalene concentrations persisted in Cell 1, this material was treated first. The material was cultivated for a period of 6 days and then sampled. This sampling date May 23,1989, was designated as Day 63 for Phase 11and is so identified in all graphs. This terminology was used because of the dormant period of time between 10/31/88 and May 1989, when no biodegradation would have occurred. The time line is depicted in an attachment. During cultivation an improved harrow was used by ESI which resulted in cultivation of 14 inches of material. It was evident that some unmixed material from Phase I (with high naphthalene concentrations) was present in hot spots throughout the cell. For this reason, Day 63 naphthalene concentrations ranged from 1055-2643 mg/kg naphthalene and Day 78 samples ranged 1060-1840 (ESI) mg/kg or slightly higher. As operators gained improved cultivation and moisture control, naphthalene odors decreased markedly and the soil resembled a properly controlled microbiological landfarm. During this period 150 pounds of biochemical amendment and 400 pounds of 10-10-10 fertilizer were added to Cell 1. Table 1 shows the control analytical and target hydrocarbon parameters for Cell 1 and Cell 2.

Treatment in Cell 2 was initiated more slowly because of collected water from storms. The water was tested and disposed of approximately one week later. After removal, soil was cultivated and dried to permit sampling. The cell was sampled on June 11, 1989. While an analytical turnaround of approximately fourteen days was occurring, the material continued to be cultivated and dried out to treat any potential hot spots remaining in the material. These results showed complete removal of total petroleum hydrocarbons. The cell was now ready for reloading. On June 22, 1989, Cell 2 was reloaded with 200 cubic yards of contaminated soils taken from Site 4. The objective of taking more material from Site 4 and mixing it in with Cell 2, which prior to this point had held petroleum hydrocarbon contaminated soils only, was three-fold. These objectives were:

1. To verify that the naphthalene concentrations in the material previously excavated from that area were unusually high and not typical of the average naphthalene concentration on the site. 2. To demonstrate that when properly cultivated and amended, the naphthalene concentration could be treated to target hydrocarbon limits. 3. To evaluate excavation techniques to minimize odors associated with the site before excavation. Site 4 was excavated over a period of 24 hours on June 15, 1989. During this period, observers cra W.R. Grace, H&A, and ESI were on site assisting the excavation crew to Insure that no W*odors left the site area. Site 4 was adjacent to the MVTBA station which was heavily traveled during. morning rush hours. The excavation crew carried out the operation in Level D personal protective equipment with an option to use higher levels of protection if required. During the excavation only once did the crew use Level C personal protective equipment. This was when free flowing water was encountered In the excavation. The crew donned protective equipment as a precaution, but it was later determined that the water was stormwater accumulated in a long unused storm drain which was opened during the excavation. Draeger tubes and an organic vapor analyzer were used for volatile hydrocarbon detection and observers detected no noticeable naphthalene odors. The crew resumed their work in Level D. By 5:00 p.m., June 15, 1989, approximately 200 cubic yards of soil were excavated and placed in Cell 2. Logs and sample pit locations are shown in the Appendices. This material was spread to form a lift approximately 12 inches deep. All foreign materials and construction debris were removed and piled at the site of the BCUs. On June 22, 1989 (Day 0 for Cell Two, Lift Two), composite samples were collected by H&A and ESI for analyses. These samples showed naphthalene ranging from 8 to 79 mg/kg with a mean value of 46 mg/kg or well below those associated with 1988's loading of Cell 1. The 1989 excavation was also made at 4 to 5 test pits within the site area so that the new material represented an attempt to locate any more highly contaminated naphthalene material.

During the ensuing 45-day treatment period, approximately 150 pounds of biochemicals and 300 pounds of 10-10-10 fertilizer were added to set up a proper microbial environment. Tables 2 and 3 display Cell 2 analytical data both before and after the addition of the new material. Target hydrocarbon analyses were also performed on samples on Days 0, 20 and 35. All sampling was arried out in the same manner as Phase 1. Each cell was divided into 8 - 50' x 50' squares. A omposite of forty (40) random samples (5 per square) was taken. Replicate samples were also taken to generate three (3) samples for analyses. Methods of analyses were those listed in Table One. Full chain-of-custody procedures were used. At the end of July 1989, operations were discontinued due to pending excavation in the Site 5 area and the onset of heavy rain. Sufficient data has been collected by the project team to determine the full capability of the bioremediation alternative. 3.0 Results of Phase If Demonstration

The analytical results of the Phase i demonstration are divided in to control parameters which were analyzed by Environmental Solutions at the Baton Rouge Laboratory. The sample schedule and methods are shown in Table 1. The results of these analyses are shown in Table 2. Target hydrocarbons are analyzed by Alpha Analytical with interpretation assistance by H&A. These are listed in Table 3. These results will be discussed separately for each cell.

Cell I was one in which soil from Phase I demonstration remained and was treated during the entire Phase 1iperiod without reloading. Since there were no longer detectable volatile organic compounds (VOCs) or phthalates, the principal constituent of concern was naphthalene. As previously described operational problems resulted in highly variable naphthalene results during Phase 1. At some point naphthalene concentrations increased due to poor mixing. During the Phase i concentration, there was some evidence of this phenomenon. For instance, Day 63 naphthalene ranged from 1055 mg/kg to 2643 mg/kg with a mean value of 1670 mg/kg. This was higher than Phase One ending data. After the operator gained control of the cell, Day 93 samples actually yielded lower naphthalene results. This phenomenon was brought under control and thereafter naphthalene results steadily decreased for the remainder of the treatment period. Operators observed one hot spot on the east side of Cell 1 which, as it was more thoroughly mixed on Day 118, continued to cause high naphthalene samples as evidenced by Day 128 data. The total removal of naphthalene was 95% from Day 63 to 128. This corresponds to a total half-life during the demonstration of 15- 20 days for naphthalene, however, if one assumes that up to 33% of the time treatment may have been less than optimum due to improper mixing, a reasonable half-life estimate of 15-30 days for naphthalene may be used for bioremediation design purposes. As shown in Table 4, we indicate treatment times which would be used to design a system based on 95% naphthalene removal criteria.

Cell One was also sampled for total petroleum hydrocarbons, VOCs and phthalate. VOCs and phthalates are not graphed because those criteria for Cell 1 were met during Phase I or in the first sampling and treatment period of the Phase I demonstration. Figure 7 depicts TPH results in Phase One. Of the control parameters analyzed for Cell 1, the most significant ones are total estimated microorganism count as generated by use of the adenosine triphosphate (ATP) analyses method. Naphthalene specific organisms (NSO) is a test in which a sole source of carbon agar containing 50 ppm naphthalene was used to identify microbial concentrations. The results show that Cell 1 was fairly low in microbial population and NSO, but after application of nutrients and proper cultivation in Phase 11,population increased dramatically and was high throughout the duration of Phase If in marked contrast to Phase I data. This in indicative of the ability of bioremediation to cultivate or if necessary augment the population of a specific . hydrocarbon degrader. The data from this cell indicates that non-indigenous microorganisms may provide the best source of seed for naphthalene degradation.

Interpretation of Cell Two data is more complicated. This is because Cell 2 was loaded in Phase I with primarily petroleum contaminated soil from Site 3, but was reloaded during July with primarily naphthalene contaminated soil from Site 4. Figure 8 displays total petroleum hydrocarbons for Cell 2. The average total petroleum hydrocarbons at the initial loading of the cell was 1260 mg/kg which declined in the 60-day Phase I period to <6 mg/kg. As Figures 8 and 9 illustrates, total petroleum hydrocarbons concentration did appear to increase during the Phase If reloading event and then declined to target levels of <100 mg/kg. Volatile organic compounds (VOCs) were detected In the initial Phase I loading of this cell but were not detected ain even during the reloading of this cell. Naphthalene was present in trace concentrations Phase I but was a significant contaminant in the Phase 11reloading. As Figure 10 shows, initial hase I loading were 2.0 mg/kg naphthalene while the reloading event averaged 46 mg/kg naphthalene. As Figure 10 shows, this was treated uniformly during the Phase 11treatment to an average level of 8 mg/kg. The Phase i reloading data taken by iself shows a half-life calculation of 15-20 days which is consistent with that postulated for Cell 1. As Table 4 shows, a design for a 95% removal level with a target treatment of 1 mg/kg would result in a design with treatment time of 45 days.

The control parameters for Cell 1 display an interesting phenomenon. The most significant parameters are total microorganisms concentration and in this case particular attention should be paid to the reloading event. NSO samples taken immediately after reloading show a minimal population (103 NSO/gm soil) of specific degraders but a high general microbial population. As nutrient and cultivation become a factor in treatment, total population increases slightly but NSO population increases by three orders of magnitude. This data is reproduced throughout the rest of Cell 2 treatment. The significance of this data is that soil loaded into the cell while maintaining a high general microbial population and a relatively high naphthalene concentration supported a very low naphthalene degrading microorganism population. After the addition of nutrients and a specific microbial amendment containing naphthalene degraders, this specific degrader population leaped. This indicates that a value can be obtained by using biochemical amendments in the treatment of relatively high concentration naphthalene material.

Data from both cells, contained in Table 2, shows that generally high microbial populations were maintained in both cells during treatment, that nutrients were maintained in excess concentration, W-was relatively stable, and moisture was relatively stable. This demonstrates that the Phase activity resulted in a generally better managed land farm which in turn lead to successful degradation results in both cells. 0

4.0 Conclusions i We conclude that a land treatment bioremediation can be used to successfully degrade target organics at the W.R. Grace site. Of the primary target organics, volatile organic compounds are expected to be a minimal problem. Total petroleum hydrocarbon containing soils may-be land treated using a design lift retention time of 60 days or less. Soils containing primarily naphthalene can be treated using a design retention time of 60 days or less as long as initial concentration is <60 mg/kg. The successful protocol for treatment is the aeration of the material via cultivation, application soluble fertilizer to enhance microbial growth and addition of a biological Inoculum for the high level (>30 mg/kg) naphthalene contaminated soils.

For purposes of treatment a design retention time of 60 days may be used for lifts throughout the project. Lift depth may vary up to 14 inches or as long as harrow-type cultivating equipment with variable type depth is used. The width of the cultivator must exceed the width of the tractor or bulldozer up to 4 feet (2 feet on either side). The unit should be sloped at 1-2% to a storm water collection area. Provision must also be made for storm water disposal during winter periods. The operating temperatures for this land farm will be average daily temperatures above 500 or the period May 1 to October 31 of each year. Some variation in these dates may occur due to seasonal weather fluctuations. .

The BCU or contained biological closure unit provide a method of treating soils in a controlled and safe manner. Subdivision of the BCU allows the treatment of soils containing primarily one contaminant or another separate from other materials. The size of the unit should be approximately two (2) acres as outlined in our conceptual design report of December, 1988. The current demonstration BCU can be maintained for additional capacity until Site 6 is developed.

In full-scale treatment material handling will be a major consideration. Up to 15% of all material removed from excavations was debris and nonbiodegradable materials. These have been stockpiled on site and should be examined on an individual basis to determine whether they are suitable for a fill or if they should be disposed by other methods. Excavation during the demonstration revealed as a whole that soils would be found with primarily one contaminant or another but not with all contaminants. During Phase 11,excavation on Site 4 showed that the high naphthalene contaminated soils excavated during Phase I seemed confined to an isolated area adjacent to the MBTA station. Naphthalene concentrations in the rest of Site 4 are represented by the <50 mg/kg maximum with most concentrations <10 mg/kg value rather than the Phase I naphthalene concentrations higher than 1000 ppm. !* .0 Recommendations

We recommend that should bioremediation be chosen for this site, it be designed to be Implemented at the site as described in our conceptual design report, dated December 1989. Construction of the treatment cells should be similar to that used for the demonstration unit. A cross section of the demonstration unit is shown for reference in Figure 2. It is recommended that design treatment time for the unit be 60 days per lift with each lift a maximum of 12-14 inches deep when placed in the BCU. Subdivisions should be used for soil containing primarily one contaminant or another. The protocol for treatment of this material should be the addition of 250 pounds of nitrogen per treatment acre, 80 pounds of phosphorous per treatment acre, and 30 pounds of potash per treatment acre. When high naphthalene materials are encountered, a microbial amendment equivalent to that used on the demonstration should be applied at a rate of 100 pounds per treatment acre lift. Moisture should be maintained at range of 20% to 50% for soils in the BCU. During treatment, target hydrocarbons should be analyzed in triplicate at Day 0 and thereafter on 20-day intervals. Control parameters equivalent to those measured in Phase Il should be analyzed biweekly although the first analyses after Day 0 should be on 7 to insure that adequate nutrients have been added to the lift. A harrowing device similar to that used in the demonstration should be used to cultivate and turn the material.

Odors can be controlled by isolating any high naphthalene material during construction and placing it in a separate cell. This cell can be covered with fresh low naphthalene concentration soil, if needed, to control odors. The high concentration naphthalene materials should be augmented with nutrients and microbial seed and initially cultivated and mixed during a period of light rain or high moisture. The moisture can be added through heavy sprinkling. This will .promotean environment which naphthalene prefers solubility in water attached to soil particles versus volatilization. Data and research developed during the Phase I investigation showed us that high concentrations of biomass will result in minimal volatilization of naphthalene. As shown in the Phase 11demonstration high naphthalene odors will be confined to the BCU itself and have a window of 48 hours after mixing. Personal protective equipment for such a treatment is recommended at Level D with capabilities to go to higher levels if necessary.

JAC/mlh/091 8jc0l.rpt Dwaniel S. Greenbaum w o/,J C4 d 0J/ww Commissioner 935-2160 March 2, 1990

W.R. Grace & Company Re: CAMBEDGE - W.R. Grace & Co. 62 Whittemore Avenue 62 Whittemore Avenue, Cambridge, mA 02140 DEP Case No. 3-0277 Site Status/Suspension of DEP Oversight

Attention: David Wightman

Dear Mr. Wightman:

This letter concerns the status of the investigation and remediation activities conducted pursuant to MIL Chapter 21E at the W.R. Grace site in Cambridge, Massachusetts. The Department has reviewed the assessment report submitted on behalf of W.R. Grace and concluded that environmental conditions at the site have been sufficiently characterized and the procedures employed to estimate exposures and evaluate risks have been adequately documented. As of the date of this letter, Phase II of the site assessment and cleanup process is considered complete.

The risk assessment indicates that present site conditions do not require remediation for the purpose of protecting public health. Nevertheless, given that the site will be excavated extensively and larte quantities of soil will be relocated, measures must be taken to minimize exposure during construction. It should be noted that the risk assessment was based on the assumption that the site would be developed for commercial purposes. If land use plans change, the applicability of the assessment must be re-evaluated. The Department's review of the risk assessment submittals is discussed in a memorandum dated February 28, 1990.

Specific measures to control emissions during construction are discussed in the "Hazardous Materials Management Plan", dated January 1990, which was prepared by Haley & Aldrich on behalf of W.R. Grace. The "Long Term Monitoring Plan", dated December 1989 was also prepared by Haley & Aldrich. The Department's position on these submittals is presented in the following two sections. The last section of this letter will address the status of Departmental oversight activities.

Original Printed on Recycled Paper WR Grace Page -2-

Hazardous Materials Management Plan.

The Department approves the Hazardous Materials Management Plan dated January 1990, under the condition that W.R. Grace addresses the following concerns when implementing the plan:

1. Particulate monitoring should be conducted periodically during dust generating activities throughout the construction period. It should not be discontinued based on initial findings of particulate concentrations below the action level. However, the initial results should be taken into consideration when deciding the appropriate sampling frequency for each building site.

2. If the OVA field gas chromatograph is not sensitive enough to monitor naphthalene levels associated with nuisance odors, a field gas chromatograph with a photoionization detector (PID), a more sensitive instrument, should be employed. A total organic vapor field screening instrument with a PID is not adequate.

3. The generic sampling procedures presented in Appendix A are not sufficiently detailed. To assure that the sampling program will generate data of acceptable quality, these procedures should be further developed prior to initiating the sampling programs.

4. The additional soil sampling programs for building sites other than Building Site 5 should employ a sampling frequency of one sample per 100 cubic yards, unless otherwise directed by the Department.

5. Soil samples collected south of the MBTA tunnel prior to the development of that area should be analyzed for cyanide, as well as the other soil classification parameters. If you detect cyanide in these samples, the Hazardous Materials Management Plan should be revised accordingly.

6 Soil of "urban fill" quality should be used for backfill around the Alewife Center underground utility lines that are likely to require service.

7.. The Department has approved the use of four indicator polynuclear aromatic hydrocarbons (PAHs). These are pyrene, fluoranthene, benzo (bk) fluoranthene and phenanthrene. In soil samples from the Grace site, the total concentration of this group is typically around fifty percent of the concentration of total PAHs. The approved soil categorization criteria are based upon total PAH concentrations. Therefore, the PAH concentrations for comparison to the categorization criteria should be obtained by multiplying the indicator concentration by two.

8. It should be noted for the record that groundwater pumped for dewatering purposes will be discharged in accordance with an NPDES permit. WR Grace Page -3-

9. Pegarding the procedures for relocating soil that is characterized as urban fill, Item 5 on Page 3 should be modified to meet the intent of the Department's stated requirement. In discussions with Wesley Stimpson of Haley & Aldrich, John Fitzgerald of DEP stipulated that deed notices must be entered for locations receiving soil from W.R. Grace. As an alternative, the Department would accept a risk evaluation showing that no significant health risk would result fram exposures to the residual contaminants fram the W.R. Grace site with any forseeable use of the receiving property. If such an evaluation indicates significant health risks under the existing use of the receiving location, the soil should not be brought there. If significant health risks are predicted for any forseeable future use of the property (such as excavation and relocation of soil to a more sensitive area), a deed notice must be entered.

LNG TERM MONITORING PIAN

The Department approves of the long Term Monitoring Plan dated December 1989 and submitted by Haley & Aldrich on behalf of W.R. Grace.

If the long term monitoring data for Jerry's Pond indicate significantly higher contaminant levels then have previously been reported, it would be prudent for W.R. Grace to quantify the resulting health risks for children who might play at the pond. This location has been singled out for additional attention because so few samples have been collected from Jerry's Pond and because that area may be more attractive for recreational use after development. The currently available data indicate that exposures to children playing at the pond would be insignificant, but, if the monitoring results show higher levels, the risks should be re-evaluated.

DEPARIMENfAL OVERSIGIf

Due to personnel constraints within the agency, a staff person from the Department of Environmental Protection will no longer be able to oversee or review work conducted by you as a potentially responsible party on the subject site.

As a result of this suspension of Departmental oversight, further approvals for remedial actions at this site will not be forthcoming for an indeterminate period of time.

Under the provisions of Massachusetts General Law Chapter 21E and the Massachusetts Contingency Plan (MCP), in the absence of direct Departmental oversight, potentially responsible parties have two alternatives: discontinue response actions or agree to perform an "at - risk" site investigation and cleanup under the "Waiver of Approval" provisions of the MCP (40.537). The latter option is only available for sites classified as "non-priority" disposal sites pursuant to 40.544. WR Grace Page -4-

A fact sheet is enclosed in order to inform you of the Department's Waiver Application process. Please be advised that even with an approved Waiver Application, all work at the site must be conducted in accordance with all applicable MCP requirements and any other applicable federal, state, or local permits, licenses, or approvals.

Should a situation arise at the site in which an imminent hazard is posed to public health or the environment, then you as a potentially responsible party may contact the Department to receive an approval for a Short Term Measure, as outlined in the MCP, (40.542), to abate this imminent hazard. Please be aware that approval of a Short Term Measure is generally reserved for sites or locations to be investigated where:

o There is the potential for fire or explosion.

o The potential for direct contact with oil or hazardous material exists.

o Continued or future migration of oil or hazardous materials constitute an imminent threat to the environment. [see 40.542(2) of the MCP].

The decision by the Department to suspend its active involvement in assessment and cleanup activities at this site is unfortunate. However, be advised that there are currently more than 2500 pending cases within this office. Relative to the subject site, many of these cases appear to present a greater or more immediate threat to public health and the environment. Accordingly, given the agency's staffing limitations, the Department is ccmpelled to allocate its limited resources in a manner which best protects these interests.

Your cooperation and responsiveness in conducting the W.R. Grace site investigation has been appreciated. If you have further questions about the Department's conclusions or caments, contact Steve Johnson at 935-2160 or the letterhead above.

Very truly yours,

ota Analyst

Ri J RTC/nb/dv cc: Alice Wolf, Counselor, City Hall, Cambridge, MA 02139 WR Grace & Ccmpany, 62 Whittemore Avenue, Cambridge, AM 02140 ATIN: David Wightman Cambridge Environmental, 58 Charles Street, Cabridge, MA 02141 ATIN: Edmund Crouch Haley & Aldrich, Inc., 58 Charles Street, Cambridge, MA 02141 ATIN: Mehdi Miremadi Daniel S. Greenbaum Ivcvsed Jtzr Commissioner Jg & 14oo >

MEMORANDUM

TO: Steve Johnson, Supervisor, NERO

THRU: Mike Murphy, Supervisor, ORS c4V9111

FROM: Nancy Bettinger, Project Manager, NERO/ORS r

DATE: February 21, 1990

This memorandum concerns the Risk Assessment for the W.R. Grace site in Cambridge. The assessment was conducted on behalf of W.R. Grace by Cambridge Environmental, Inc., and is documented in the following submittals:

1. A report entitled "Health Risk Assessment for the W.R. Grace & Co. Property" dated May 16, 1988. This report was prepared by Laura Green and Edmund Crouch, who at that time were employed by Meta Systems, Inc. and now are associated with Cambridge Environmental, Inc.

2. A document entitled "Addenda to Health Risk Assessment for the I. R. Grace & Co. Property", dated August 8, 1989 and prepared by Cambridge Environmental Inc.

3. A letter to the Department from Cambridge Environmental dated September 25, 1989.

4. A letter to the Department from Cambridge Environmental dated October 2, 1989.

5. A letter to the Department from Cambridge Environmental dated January 9, 1990.

The addenda and letters listed above were prepared in response to the Department's questions and comments about previously submitted correspondence. Cambridge Environmental wrote the January 9, 1990 letter in response to a letter from the Department to W. R. Grace dated January 8, 1990. In that letter, the Department requested the modification of some exposure point concentrations and the reorganization of several data tables. W. R.Grace Page 2

After reviewing the modifications contained in Cambridge Environmental's January 9, 1990 letter, the Department's Office of Research and Standards (ORS) has concluded that the methods employed to estimate exposures and evaluate risks have been adequately documented. Nevertheless, some portions of the assessment differ from the evaluation methods currently recommended by the Department. For the record, the most significant deviations are noted in the following items:

1. In the risk assessment, cancer potency factors for carcinogenic PAHs were estimated by a method that differs from the practice currently recommended by ORS. Only PAHs for which a potency factor could be derived from available toxicological information were considered carcinogenic. These were benzo(a)pyrene and dibenzo(ah)anthracene. A description of the procedure followed to estimate potency factors was presented in reports submitted prior to the Jasnuary 9, 1990 letter, but to date the Department has not commented on this issue. At this time, until more information is available and more accurate assessment procedures are developed, ORS recommends using the benzo(a)pyrene potency factor for all carcinogenic PAHs. Those considered carcinogenic are benzo(a)anthracene, benzo(a)pyrene, benzo(bk)fluoranthene, benzo(ghi)perylene, chrysene, dibenzo(ah)anthracene and indeno(123-cd)pyrene. Furthermore, since no inhalation potency factors have been developed for carcinogenic PAHs, ORS recommends applying the benzo(a)pyrene ingestion potency factor to inhalation exposures for all carcinogenic PAHs. These practices are controversial because they involve assumptions about which substantial uncertainty exists, and because using the benzo(a)pyrene potency factor for other PAHs results in overestimates of risk.' Nevertheless, in the absence of accurate toxicity information, ORS considers this the best approach.

To determine whether these more conservative assumptions would affect the conclusions of the risk assessment, ORS calculated the cancer risks from PAHs at the site by applying the benzo(a)pyrene potency factor to all carcinogenic PAHs. When risks were characterized by this method, the total site cancer risk estimates for all receptors were below the regulatory limit of 10 , and the conclusions of the assessment were the same.

2. The Cambridge Environmental reports do not provide non-cancer health effect risk estimates for direct contact with PAHs in soil, -possibly because individual reference doses are not available. In the absence of specific reference doses, ORS recommends applying the oral reference dose for naphthalene to doses of all PAHs received by all exposure routes. This practice may overestimate the risk, but it can indicate exposure levels below which one can be confident of no adverse health effects. To determine whether this more conservative assumption would affect the conclusions of the risk assessment, ORS estimated the total site risks of non-cancer health effects from PAHs by applying the current reference dose for naphthalene directly to W. R. Grace Page 3

the total PAH doses predicted for the "no-build" and "construction with bioremediation" conditions. All estimates fell below the regulatory limits, and the conclusions of the assessment remained the same.

3. Cambridge Environmental's January 9, 1990 letter report presents an original analysis of the effects of earthworn activity on the burial rate for contaminants deposited with dust on surficial soil. The resulting concentration 4ecrease does not significantly affect the results of the risk assessment. Nevertheless, it should be noted for the record that this office has neither reviewed nor approved the use of this analysis.

4. In the assessment, non-cancer health risks were calculated using average lifetime exposure assumptions. ORS generally recommends that threshold risks be calculated for shorter averaging periods, particularly for periods of higher exposure, such as ingestion of soil during childhood. In the W.R.Grace case, however, if shorter averaging periods were used, the risk assessment results would not be significantly different and the conclusions would not change.

5. In the assessment, absorption efficiencies for the exposure routes being evaluated are referred to as bioavailability adjustment factors (BAFs). As described in the Department's "Guidance for Disposal Site Risk Characterization", a BAF adjusts the average daily dose estimate for the difference between the absorption efficiency for the exposure route of concern and that of the exposure route upon which the RfD or potency value is based. Absorption efficiencies are not equivalent to BAFs.

For the record, the following items present comments on several issues that have not been addressed extensively, either in the W.R. Grace Report or in the Department's review process. These include: (1) the model used to estimate potential future groundwater impacts on the neighborhood north of Whittemore Avenue; (2) the omission of a thorough environmental assessment; and (3) potential health effects on children who participate in athletic activities at Russell Field.

(1) The Department required a quantitative evaluation of impacts that could occur if contaminated groundwater migrates from the site into the neighborhood north of Whittemore Avenue in the future.. The reason for the requirement was to establish a basis for evaluating the need for remedial action if, at some time in the future, monitoring data indicates that contamination is migrating into the neighborhood. After reviewing the models and estimates initially presented in the "Health Risk Assessment for the W.R. Grace and Co. Property" dated May 16, 1988, the Department requested two basic changes: (1) a modificiation of the assumptions used to estimate volatilization of contaminants into residential basements, and (2) a more straightforward approach to estimating the impact of basement flooding. In response W.R.Grace Page 4

the "Addenda to the Health Risk Assessment" dated August 8, 1989 presented a detailed analysis of diffusion of contaminants from groundwater into residential basements. Unfortunately, the Department cannot allocate the time necessary to thoroughly review this analysis, and so a more rigorous evaluation may be appropriate at some time in the future. It is important to note, however, that the Department's position has always been that the neighborhood north of Whittemore Avenue should be protected from adverse impacts by preventing groundwater contamination from migrating beyond Whittemore Avenue.

(2) Potential Environmental Impacts were not addressed extensively in the W.R. Grace Assessment. The Department did not require extensive work of this nature because the available data show no evidence that downgradient receptors (Parkway Pond, Yates Pond and Alewife Brook) have been impacted by the site.

(3) The Department required W.R. Grace to specifically evaluate potential health impacts of air emissions on children who participate in athletic activities at RusselField. The response, which was presented in a letter dated September 25, 1989 from Cambridge Environmental to the Department, was not satisfactory. To determine whether such activities would result in significantly increased exposures to contaminants from the site, the DEP project manager calculated the factor necessary to convert the reported residential daily dose to a daily dose for a child who plays at Russell Field. The results indicated the difference in the exposure rate would not significantly increase the risk estimates. cc: W.R. Grace & Company, 62 Whittemore Ave., Cambridge, MA 02140 Attn: David Wightman

Cambridge Environmental Inc., 58 Charles St., Cambridge, MA 02141 Attn: Edmund Crouch Cambridge Environmental Inc 58 Charles Street Cambridge, Massachusetts 02141 617-225-0810 617-225.0813 FAX

September 25, 1989

Nancy Bettinger Dept. of Environmental Protection, 5 Commonwealth Avenue Woburn, MA 01801

Re: DEP case No. 3-0277 W.R. Grace & Company Alewife Property Cambridge, Massachusetts

Dear MsBettinger:

You have requested some written comment on the potential effects of the Alewife site on persons crossing the Alewife site (e.g. to the MBTA station), and on children playing in the adjacent Russell Field Park. Both these situations are taken into account in the risk assessment.

The first is an explicit group included in Addendum A to the risk assessment (August 10, 1989) as "Transient persons: MBTA commuters, pedestrians, trespassers" (Tables A.1 through A-3) of the addendum, with total site hazard index of 0.0034 and total estimated site cancer risk of 7.1 x 10 (Table A.24, page A-41 of the addendum). These values result from ",conservatively assumed exposure for 1 hour per day for life at positions immediately adjacent to contaminated areas (as for workers on site).

The second group, children playing in Russell Field Park adjacent to the property, is -rincluded in the more general heading of "Residents adjacent to the site" (Tables A.1 through A.3 of the Addendum A). You seemed to be particularly concerned about the fact that -Lussell Park is adjacent to the site, so that children are potentially right next to the site. "-'-iowever, children playing in this park will not be located at a single point adjacent to the site all the time they are there (which would be only a small fraction of the continuous exposure assumed for residents adjacent to the site). Russell Field Park is approximately rectangular, 130 x 360 m, with two adjacent sides abutting the site. Children using the site are thus, on average, going to be located a distance of approximately 130/2 = 65 m from the nearest part of the site (actually, if we assume equal probability to be in any part of a rectangular area of size I x w, with w < I, the average distance hom either of two adjacent sides is (w/2)(1-w/(31)), -. which in this case comes to 57 m -- the second term of the expression accounts for ie fraction of time closer to the short edge). Assuming equal probability to be on any part of the Nancy Bettinger Page 2 September 25, 1989 field probably overweights the edges and corners of the fies (i.e. those closest to the site), especially for the most active children. This distance is an underestimate of average distance from the contaminated areas, since most of the long edge of Russell Field abuts a part of the site (round the pond) that is not qontaminated. Even at the corner of the Field that is closest to the site, the main areas of contamination, as used in the Assessment, are a substantial distance (-50 m) away. It is important to recognize that what is required is not the distance from the nearest point at which contamination has been found, butsome measure of average ,distance from the bulk of the contamination. The major contribulion to exposure comes not from the nearest point, but from the rest of the contaminated area.

With the methods used for estimating air concentrations in the Assessment, all that was required for the exposure models was an estimate of an approximate "diameter" of the contaminated regions, and a distance to the nearest "currently inhabited" area. Both these dimensions were measured on a display similar to those shown in Figures 4.1 and 4.2 of the Assessment, and are listed in Table 4.6 of the Assessment. The measurements were made conservatively, in the sense that the "diameter" of the contaminated region was taken to be the largest distance across the major areas of continuous contamination (as judged visually), and the distance to the nearest "currently inhabited area" was taken to be the distance to the nearest off-site point from the edge of this region.

These distances are thus not physically well defined. However, as described in Section 4.2 of the Assessment, the precise dimensions are not particularly important since ambient concentrations do not.depend very strongly on them for receptors as close as the nearest off-site points. For example, for naphthalene, the assumed dimensions were: diameter 320 m, distance to nearest inhabited point 50 m. Even at half that distance, 25 m, from a 320 m diameter unliirmly emitting area, the worst case (F stability) peak concentrations to be expected are less than 10% higher than at 50 m, while the long term average is less than 45% higher. You might care to note that the distance from Whittemore Avenue to the MBTA station is about 300 m.

In the Assessment, ambient concentrations were compared with concentrations that would be safe for short term and long term exposures, based on possible acute and chronic effects. The breathing rates assumed in these assessments corresponded (of residents adjacent to the site) to relatively active persons, with exposure assumed to continue for 24 hours per day. In Addendum A, the breathing rates assumed also correspond to fairly active persons, again with exposure assprned to continue for 24 hours per day. The ATCs used in Addendum A were designed spedifically to account for any high risk groups, presumably including active children. Although children playing in an adjacent field will be breathing at high rates, such activity will only continue for a small fraction of the day. Such periods of high activity are incorporated into. the average breathing rates used. We showed in the Assessment that maximum exposures were so low that only relatively long term averages

Cambrdge Environmental Inc 58 Charles Street Cambridge, Massachusetts 02141 C

.1.

Nancy Bettinger Page 3 -September 25, 1989 could be any concern. In particular, for naphthalene, the cumulative intake over several days is the determinant of acute effects. The other major route included in Addendum A, sod ingestion, explicitly included increased exposure to children through the age dependence of assumed soil ingestion rates. Exposure in this case was assumed to be right at the edge of a contaminated region of diameter 315 m (page A-39 of Addendum A, and the appendix to Addendum A). It you have any further concerns, or would like further explanations of any parts of the risk assessment, please contact us.

Sincerely,

Edmund A. C. Crouch, Ph.D. Senior Scientist cc. M. Murphy, DEP M. Stoler, W.R. Grace D. Wightman, W.R. Grace

Cambridge Environmental Inc 58 Charles Street cambridge, Massachusetts 02141 Jk~oA6&olea-AMkeawt

Daniel S. Greenbaum 1 $ h Q &eA O/6O/ Commissioner 935-2160 September 14, 1989

W.R. Grace & Company RE: CAMBRIDGE-W.R. Grace 62 Whittemore Avenue 62 Whittemore Avenue Cambridge, MA 02140 Groundwater Sampling DEQE Case No. 3-0277

Attention: Mr. David Wightman

Dear Mr. Wightman:

The Department of Environmental Protection (DEP, formerly the Department of Environmental Quality Engineering) has received a letter from Haley & Aldrich, Inc. proposing an additional groundwater sampling program at the W.R. Grace site in Cambridge. The proposal, dated June 22, 1989, was gubmitted in response to the Department's request that W.R. Grace attempt to determine the cause of the groundwater discoloration and foaming observed during test pit excavations. The locations of particular concern to the Department are Site 6, the eastern side of Site 7, the area between Sites 2 and 3, and the area between the west side of Site 4 and Parkway Pond.

Haley & Aldrich has proposed collecting groundwater samples from monitoring wells 8503-OW, B708-OW and B212-OW and testing the samples for the following contaminant indicators: conductivity, total organic carbon and methylene blue indicator. An additional sample from B501-OW was proposed to obtain background levels for these parameters.

The analytical parameters were reportedly selected on the basis of interviews with W.R.Grace employees familiar with materials used at the facility and discussions with commercial laboratory staff. The Department considers this approach to be appropriate and does not have additional recommendations at this time. The ability of these tests to show the cause of groundwater foaming and discoloration can only be judged by evaluating the analytical results. While this office recognizes that a definitive analysis is probably not feasible, it should be noted that site management options may be limited if the groundwater cannot be adequately characterized.

Regarding the sampling locations, the Department's recommendations follow:

0 Samples should be collected from at least three to obtain ranges of background levels for e paramq-%pjVX

Original Printed on Recycled Page 2 W.R.Grace

* Well B502-OW should be sampled because foamy groundwater was observed near this well on the eastern side of Site 7.

* Well B702-OW should be included because foamy groundwater was observed in this area between Sites 2 and 3.

If you have further questions about these comments, contact Nancy Bettinger at 935-2160 or the letterhead addtess. All correspondence concerning this site must reference the DEP case number designated in the subject heading.

Sincerely,

Nancy Bettinger Environmental Analyst

Richard J. Ctpin Regional Engineer

RJC/NB/ram cc: DEP/BWSC, 5th Fl., 1 Winter St., Boston, MA 02108 Cambridge City Council, City Hall, Cambridge, MA 02139, Attn: Alice Wolf Haley & Aldrich, Inc., 58 Charles St., Cambridge, MA 02141 Attn: Wesley Stimpson TELEPHONE CONVERSATION NOTES MASS DEQE/NERO/DSHW

SITE REFERENC E /2/K' tat DATE

SUBJECT - TIME

FROM REPRESENTING

TO REPRESENTING

ACTION REQUIRED/REFERRED TO Michael - in - TO: Supervisor of Occupational Safety MASSACHUSETT' and Heai.'La BAY TRANSPORTATIO AUTHORITY

FROM: Stephen M. Kelley DATE: Industrial Environmental Engineer Juiv 17, 1989

RE: Results of Analysis of Alewife Tunnel Sludge Samnle

On Wednesday, July 12, 1989. I reported to Alewife Station along with a representative from Engineering and Maintenance in response to a complaint from an employee who claimed that she was burned by an orange sludge-Like substance which had leaked from the slurry wall and was on the tunnel floor near layup track 11 at the station. I consequently obtained a sample of this substance and submitted it to Clean Harbors Inc. Environmental Engineering for analysis.

The pH of the sample was determined to be 8.4, which is slightly basic or caustic. In addition, approximately 240 ppm of sulfate ion was present in the sample. Sulfate ion is sometimes related to the presence of sulfuric acid in a sample, which potentially could cause the symptoms reported by the affected employee. However, the presence of sulfuric acid is contradicted by the fact that the pH is basic and not acidic. The sulfate then is likely grouped to a heavy metal such as iron or sodium.

While the results of the analysis are inconclusive in terms of definitively identifying the sample component(s) which may have caused the symptoms reported by the employee, a substance which is slightly basic could possibly cause mild skin irritation such as that reported. In light of the fact that in near future, a contract is anticipated which will involve more in depth. comprehensive sample analysis to investigate odor problems at the station, I do not see the usefulness of additional analyses for the sample submitted at this time.

Stephed M. Kelley /Industrial Environmental Eng'neer

SMK' /lp cc: J.W. Sisk, Jr. A.T. Slowe File

rcc,I I - - - - -. ------c--'-- C 0 6 ( p 13 Bill M. Eric F.. Ft' Mike M._ Cathy E. ___ Bob B..

Reports C : V 1P R E

status' Printed' JULY 13 1989 1'32 PM

, UP REPORT OF ANALYSIS

MBTM

SOS~t6 si 0o2gI( Project' f f..atf. S4a4i+ Date Receiuede 07/12/99 P.O. * CHAS Lab #s 8907076

EnclsAed are the results for the senple(s) delivered to our laboratory on the date indicated above.

The methods listed reprement those mthodologies which were used to daielop the bust analytical techniques. Analytical results and quality assurance protocols are based on thee guidelines. These met the requiraments for the reporting of results under the RCRA, NPDES and Safe Drinking Water Act regulations.

Clean Harbors Analytical Services has an active program of quality assurance and quality control. The progra closely follows the guidance provided in the EPA Contract Laboratory Progran Statemnt of Work (organic - 7/97 and inorganic - 7/85),. the guidance provided in SW-044. and nwiy other pertinent documents.

Should you ham any questions concerning this work, please do not hesitate to contact Me.

The information contained in this report is, to the best of W knowledge, accurate and cqdlne.

------NOTES ~~~ENF~~~~7-f&;1a e~cs zY'.r -- s ;IF 617848195, 617 7Z :~. 45 P~ 40

Report I A N j-1" R E Initials' P- V Status' D :AF) -r r Printed' JULY 13 1989 1034 P

Client' rBTA CNAS Lab *1 6907079-01M Sample I.D.' Date Receiads 07/12/8 Sample Type' Sludge AnalysIs Method Numbe Parameter MDL Resul t Un i ts Date end Referenc

Chlor ide 3, 9 16 mg/kg 07/12/89 104b. 500.0(a Fluoride 3.9 ND mg/kg 07/12/89 300.0(a Nitrate 3.9 ND mg/kg 07/12/89 300.0(6 Nitr ite 3.9 NO mg/kg 07/12/89 500. 0(0 Phosphate 3.9 ND mg/kg 07/12/89 300.0(a sulfate 3.9 240 mg/kg 07/12/89 300.0(a

Notes ND - Below minimun detectable 1e"sl (MDL) Soil/solid seples based on sample dry weight ------NOTES The sludge was aqueous extracted for I ho ur prior to analysis. Based on sample weight as receiued. DANIEL S. GREENBAUNI 5,nwwat eu Commissioner

MEMORANDUM

TO: John Fitzgerald, P.E., Environmental Engineer V FROM: Nancy Bettinger, Environmental Analyst IIl4I 3J DATE: May 15, 1989

SUBJECT: Relocation of urban soil

As DEQE project manager for the Cambridge W.R.Grace site, where the "forseeable future use" consists of a major development project, the question of allowing and controlling the transportation of soil that will be excavated during construction has arisen as a major problem in managing residual contamination at the site. My understanding is that management of excavated soil is also an unresolved question at numerous other urban construction sites in the metropolitan area. This memo is to propose an approach to decisions about the relocation of residually contaminated soil from one urban industrial/ commercial location to another.

The baseline risk assessment for the "no development" scenario at the W.R.Grace site does not indicate a significant risk associated with existing exposure pathways. Nevertheless, since thousands of cubic yards of soil must be excavated and removed during construction, and some of that material is significantly contaminated, soil treatment has been proposed. Haley and Aldrich, the environmental consultant for W.R.Grace, has proposed to categorize soil as follows: (1) heavily contaminated soil, for which treatment is required before either transporting to another location or using for backfill on-site; (2) moderately contaminated soil, which is suitable for backfilling but may not be removed from the site; and (3) urban fill, which is relatively clean by urban standards and may be used for backfill or brought to a suitable off-site location.

The specific levels proposed for the W.R.Grace site are omitted here to avoid clouding the larger issue of an acceptable approach to soil management decisions. If W.R.Grace decides that it is not feasible to treat to levels the Department deems acceptable for urban fill, the development project will probably be re-evaluated. If it is cancelled, the necessity and feasiblility of treating some of the soil on the site will be re-assessed by the Department.

The situation described above leads to the questions I wish to address in this memo: (1) How should the Department regulate the relocation of residually contaminated urban fill that is excavated for purposes other than site clean-up? (2) What levels of residual contamination are acceptable in soil that is to be re-located? (3) How can exposure to these residual contaminants be controlled after the soil is removed from a site?

One of the central issues in this problem is whether the MCP/21E risk assessment process should extend to decisions about transporting soil from a 21E site to another location. In other words, should the risk assessment procedure outlined in the MCP be used to determine whether a proposed location is suitable to receive residually contaminated fill? In my opinion, there are several serious problems with this approach: (1) Soil excavated for construction purposes at 21E sites comprises only a fraction of all of the residually contaminated soil excavated from urban industrial/commercial locations in the Commonwealth. If the 21E process is employed as the mechanism for controlling soil relocation, then I believe we would have to accept the idea that only a fraction of excavation projects would be regulated. (2) Typically, the location to which excavated soil will be brought is unknown at the time the baseline risk assessment is conducted. In fact, the excavation may take place years after the risk assessment has been completed, and the receiving location would not be arranged until that time. (3) Even if a proposed fill location was known when the risk assessment was prepared, in my opinion it would not be practical to include in the 21E process the evaluation of locations that are separate and different from the 21E site. Such assessments would involve separate land use studies, and the identification and evaluation of different exposure pathways and receptors. (4) The MCP risk assessment procedure results in data that is subsequently employed in making risk management decisions at an MCP site. Sites designated to receive urban fill may not always lend themselves to the same risk management options aplied at 21E sites, such as long-term monitoring, re-evaluation of remedial technologies, and certain institutional controls.

As an alternative, I would advocate adopting an interim policy that would provide equivalent public health and environmental protection, but could be applied to any urban soil relocation proposal. I would recommend that the policy place the following conditions on the relocation of urban soil: (1) In general, only soil contaminated with metals and organic compounds of low volatility and mobility should be considered for re-location. (2) Urban soil may only be moved to locations that are used for industrial or commercial purposes, or to other specifically designated locations, where placement of the soil precludes direct contact or any other route of exposure to the contaminants. The soil must not be placed in contact with, or near, underground utilities that are likely to be excavated from time to time for maintenance. Soil must not be placed in wetlands or other sensitive environments without Departmental approval and stringent controls to prevent adverse impacts. (3) Soil can only be removed from locations where there is no known source of contamination. If a source or source area is identified, the property must be reported to the Department as a location to be investigated. (4) For projects being conducted without DEQE review, the parties involved in soil re-location must adhere to the following guidelines: (Specifications for maximum contaminant levels, to be set at a later date, should be high Es

enough to allow relocation of soil with normal urban contamination levels, but low enough so that relocation is used niether in lieu of treatment nor to transfer the need for institutional controls from one property to another.) Category 1 - Slightly Contaminated Soil: Soil in this category can be used as urban fill. Category 2 - Moderately Contaminated Soil: Soil in this category can be re-located to an urban industrial/ commercial location where placement will preclude direct contact or any other route of exposure to the contaminants. The soil must not be placed in contact with or near underground utilities. Category 3 - Significantly Contaminated Soil: Soil in this category can be re-located to landfill in conjunction with closure activities. Category 4 - Heavily Contaminated Soil Soil in this category connot be re-located. (5) For projects being conducted with DEQE review, the project manager may allow soil contaminated at higher levels to be relocated, if treatment is not feasible, and if the soil must be excavated for purposes other that waste site cleanup. (6) A deed notification must be entered for the receiving location. The notification must note that further testing and approval will be required before the soil in question can be transferred to another location, that the soil is not suitable for use in a residential area or a sensitive environment, and that future disturbance or movement of the soil without DEQE approval may constitute "release" of oil/hazardous materials.

Ideally, such a policy would prevent inappropriate and unsafe urban soil management and lead to urban soil management practices that are more consistent from project to project. Precluding transport and exposure pathways would protect public health and the environment as well, if not better than, separate risk assessment and management programs for individual urban fill locations. By setting guidelines for soil relocation, the Department could reduce the demands to deal with what are really construction problems that are increasingly being placed upon its limited site assessment staff. MEMORANDUM FOR THE RECORD

To: Steve Johnson From: Nancy Bettinger, Date: January 4, 1989

Subject: CAMBRIDGE - W.R. Grace, Risk Assessment Meeting

On January 4, 1989, 1 met with Wes Stimpson of Haley and Aldrich and Edmund Crouch of Meta Systems to discuss the Risk assessment prepared by META Systems on behalf of W.R.Grace in Cambridge. Specifically, the approaches and assumptions used to predict contaminant transport for three potential esposure pathways were questioned. These are summarized in the following sections:

(1) Some of the assumptions used In assessing potential exposures from basement seepage were questioned. Meta Systems developed this scenario for the purpose of estimating long term exposures that might result if contaminated groundwater moved into residential areas and then seeped into basements. For this analysis, It was assumed that, over the long term, water wouldn't enter a basement faster than it could dry from the walls (otherwise the leaks would be repaired to keep the basement dry). Furthermore, the rate at which contaminants were released to the basement airspace was related to the maximum rate of evaporation of the contaminated water.

Based on our experience, I expressed the opinion that long-term exposures from contaminated groundwater were more likely to result from volatilation of contaminants directly into basements. Additionally, I indicated that transport of contaminants from groundwater into airspaces is usually estimated using Henry's Law. Dr. Crouch agreed to add another section to the report to evaluate direct volatilization into basements.

(2) The approach used to estimate the amount of contaminated water that might enter a basement during a flood was also discussed. Meta systems related the rate at which contaminated groundwater enters a basement to the groundwater flowrate. They further assumed that as clean rainwater raised the water table, the groundwater flow rate would increase by a factor equal to the decrease in contaminant concentration. ( i ing

I i giti

fflZL t5111 Chles Sotreet Camiridgc M A (.214 617/494-1606

Letter oflTransmitial

T . X Date - tI9te14co 6y File Number / Cwiri~e A/ ulyo subt A/ $

Copies Date Descripton >4

- /Vr ,%7)o7"e

Remiulks

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Cor 6 /fa AM S/ie, W. 4. rc e Branch Offices 4 L Qu4 re Gre , /fe4 s b-s Glastonbun-y, Connecticut 'r Q Portlaid N eili Bedford. Nw 'I iiiishin Affiliate I I & A of New York Rocherer. New )rk Erco Laboraiory

Enseco

June 6, 1988

Mr. Anthony J. Tawa, Jr. Sverdrup Corporation 38 Chauncey Street Boston, MA 02111

Dear Tony:

Enclosed are the results of the analyses performed on the one aqueous sample for MOTA: Alewife Sump (Project No. 5152R). This project was received under chain of custody at Enseco - Erco.Laboratory on May 16, 1988, and was processed for a three-week turnaround time. A brief description of the Quality Assurance/Quality Control and methods employed by Enseco are contained within the report. This letter authorizes the release of the analytical results -and should be considered an -integral - - part of this report.

o Please refer to this project by the Erco Laboratory Identification No. 7863 to help expedite any future discussions. We will be happy to answer any questions or concerns that you may have.

Sincerely,

Clyde E. Tressler Client Service Representative

Thomas R. Copeland, Ph.D. Technical Director

Enc1. ANALYTICAL RESULTS

The method number provided on each data report sheet refers to a publication originating from a regulatory or standard-setting organization. In general, the methods employed are those specified by the U.S. Environmental Protection Agency and other state and federal agencies. In cases where an approved regulatory method does not exist, a method developed by Enseco will be employed to meet the specific needs of the client. The methods commonly employed by Enseco are based on methods from the following references.

U.S. Environmental Protection Agency. 1983. Methods for chemical analysis of water and wastes. EPA-600/4-79-020. Cincinnati, OH, March.

U.S. Environmental Protection Agency. 1984. Test methods for evaluating solid'waste, phvsical/chemical methods. (SW-846); Washington, D.C. April.

Ui.S.EnvIronmental Protection Agency. 1986. Methods for the determination of orcanic compounds in finished drinking water and raw source water. Cincinnati, OH, September.

"Guidelines Establishing Test Procedures for the Analysis of Pollutants Under the Clean Water Act," 40 CFR, Part 136; Federal Register, Vol. 49, No. 209 (1984).

American Public Health~Association, American Water Works Association, Water Pollution Control Federation. 1985. Standard methods for the examination of water and wastewater/ 16th Edition. Washington, D.C.,. April.

Current EPA Contract Laboratory Program (CLP) protocols for the analysis of organic and inorganic hazardous substances including chlorinated dioxins and furans.

-C .,?gjtfliC, .*~.I A *A * ~ W/ - 8 saEseco ICP QUANTITATIVE SCAN

EPA Method 200.7

Client Name: Sverdrup Corporation Client ID: Alewife MBTA-SP-1 Sump Laboratory ID: 7863-01 Matrix: Aoueous Sampled: 05/16/88 Received: 05/16/88 ~ Authorized: 05/16/88 Prepared: 06/03/68 Analyzed: 06/06/88

Reporting Parameter Result Units Limit

Al uminum ND mg/L 0.05 Antimony ND mg/L 0.05 Arsenic ND mg/L 0.1 Barium ------0.030 ng/L 0.005 Beryllium NO mg/L 0.001 Boron ND mg/L 0.1 Cadmium ND mg/L 0.005 Calcium ------93 rng/L 0.1 Chromium ND mg/L 0.01 Cobalt ND mg/L 0.01 Copper ND mg/L 0.006 Iron ------20 mg/L 0.05 Lead ND mg/L 0.05 Lithium ------ND -m/ L 0.02 Magnesium ------31 mg/L 0.1 Manganese ------2.2 mg/L 0.005 Molybdenum ND mg/L 0.02 Nickel ND mg/L 0.04 - I Potassium ------7 mg/L 5 Selenium ND mg/L 0.2 Silver ND mg/L 0.005 Sodium ------75 mg/L 0.5 Thali um ND mg/L 0.4 Tin ND mg/L 0.03 Titanium ND mg/L 0.005 Vanadium ND 0.01- Zinc ND mg/L 0.03

ND = Not detected.

Repcrted by / Approved by 0

f ecua0:c unofvOwcnwrrfar/I

/00 %mAra&e f/red

MICHAEL S DUKAK.S GOVERNOR

JAMES S. HOYTE SECReTARY January 20, 1988 -c

CERTIFICATE OF THE SECRETARY OF ENVIRONMENTAL AFFAIRS ON THE FINAL ENVIRONMENTAL TMPACT REPORT

PROJECT NAME : Alewife Center PROJECT LOCATION : Zambridge EOEA NUMBER 5869 PROJECT PROPONENT I Gerald.D. -ines Devel. Boston, Ltd. - DATE NOTICED IN MONITOR November 27, 1987

The Secretary of Environmental Affairs herein issues a - statement that the Final Environmental Impact Report submitted on the above project does -not adequately and properly comply with the Massachusetts Environmental Policy Act (G.L.,-c.30, s.61-62H) and with its implementing- regulations (301 CMR 11.00).

-Based on discussion with agencies and. the proponent and -on correspondence on the Final EIR, it-is-apparent that supplemental analysis is necessary- for this project.- In the main, the.need for supplemental analysis is due to the complexity of the project site rather than poor environmental compliance. I anreciate the proponents willingness to allow the Final EIR additional review time during the holiday season. The preparation of a Supplemental Final EIR (SFEIR) will allow the proponent the opportunity- to respond to the substantive comments received on the Final EIR and to issues of flood elevations, traffic., and hazardous material as briefly outlined below.

FLOOD MANAGEMENT

-, I am aware of particular questions related to the flood nrofile data used in site design for the project. This must be resolved in the Supplemental Final EIR and appropriate design modifications incorporated into the plan.

Additionally, the Wetlands Protection Act regulations EOEA #5869 FOTR Certificate .January 20. 19se

require that compensatory flood storage have an unrestricted hydraulic connection to the same waterway or water body (310 CMR 1.057(4)(a)11. The use of a mechanical pump from parkway pond to Jerry's Pond during major storm events and the use of a valve to close the pipe when certain flood conditions are reached appear to be impediments to "unrestricted hydraulic flow." This issue should be discussed and resolved in the Sunolemental Final EIR.

WETLANDS

The proponent and their consultants are to be commended for the modifications to the project plans which minimize the impacts to the resource areas. No further analysis is required. Additional issues, barring major project changes, can be addressed appropriately at the local level through the Conservation Commission.

TRAFFIC

Concerns regarding. traffic impacts were expressed during the Final EIR review period. The MEPA staff has consulted with the proponent with regard to errors in the traffic analysis. The proponent has expressed a willingness to correct these errors in the Supplemental Final- EIR. I would refer the proponent to the comments of S. Kaiser with regard to technical analysis and request that those comments related to analysis and results of the analysis be addressed in the Supplemental Final EIR.

The EOTC has submitted thoughtful comments on the Final EIR. It appears that it would be most advantageous for the proponent to meet with the EOTC and MDPW with regard to Route 2 improvements. The results of these discussions should be reported on in the Supplemental Final EIR. Additionally, I would point to the comments of S. Kaiser with regard to site access. These comments have merit and should be investigated further.

Finally, in terms of traffic, I concur with EOTC with respect to the need for a Transportation Management Association in the area.

HAZARDOUS MATERIALS

The proponent has presented adequate information to date with regard to site contamination. I understand that the proponent will be continuing to work with the DEQE. I had specifically requested in my Certificate on the Draft EIR that the Final EIR contain a toxicological risk assessment (summary). No sach summary was included in the Final EIR and must be included in the Supplemental Final EIR. The North Cambridge Stabiliratfion Committee has expressed many legitimate and

2 0

EOEA #5869 FEIR Certificate Januarv 20. 1988

important concerns. These can be resolved in a 0uestion and response format in the Supplemental Final EIR. The Cambridge Conservation Commission also raised some important issues related to their interests in wetland areas. The Supplemental Final EIR can address these issues as well. Finally, the MWRA has concerns regarding treatment methods for the contaminated groundwater and soils which can be addressed in the Supplemental Final-EIR.

CIRCULATION

The Supplemental EIR should be circulated to those who received copies of the Final EIR.

January 20, 1988 DATE JE

Comments received: 12/17/87 MWRA 1/6/88 DEQE 1/13/88 DEM 1/13/88 T. Maguire 1/13/88 MAPC 1/14/88 S. Kaiser 1/14/88 R. Kraus 1/14/88 EOTC .1/14/88 Communications Council 1/14/88 NCSC 1/14/88 Boston Bicycle Coalition 1/14/88 City of Cambridge 1/15/88 DEQE/AQC

JSH/JD/bk

3 t - FROc: North Cambrilge Stabilization Committee RE E IVED c/o Community Development Department 57 Inman Street Cambridge, MA 02139 EL~1£7 TE ;,F.NTfAfl$%, r OF

TO: Mr. James Hoyte, Secretary Massachusetts Executive Office of Environmental Affairs Leverett Saltonstall Building 100 Cambridge Street, 20th Floor Boston, MA 02202 -

ATT: MEPA Unit

REi EDEA #5869, Alewife Center Final Environmental Impset Report

ENCLa 1) North Cambridge Stabilization Committee's (N.C.S.C.) comments on Draft EIR, dated February 22, 1987 2) N.C.S.C. letter to the City of Cambridge's Planning Board regarding the Alewife Center Project, Circa August 1987

DATE: January 12, 1988

Dear Secretary Hoytes

The North Cambridge Stabilization Committee (NCSC) is-a city- sponsored group of North Cambridge residents which functions in an advisory capacity to the City of Cambridge and its various boards and departments on a variety of issues. The Committee has met with the developer a number of times, has sponsored several commnianity 'meetings, and has appointed a subcommittee to convey to your office in this letter the concerns and comments which have arisen from these meetings and our own review of both the DEIR and the FEIR. Enclosed for your convenience please find a copy of our comments previously submitted to your office relative to the DEIR. -Also, please find a copy of the NCSC letter to the City of Cambridge's Planning Board regarding the Alewife Center Project. We are pleased to have the opportunity to now comment on the Final EIR for Alewife Center. The stated goals of the NCSC continue to be supportive of

(1 of 12) / #5869 - NCSC Response to - Alewiff enter FEIR J uary 12, 1988

site cleanup and development inz a-manner that meets the needs of the community. Again, we would like to thank the developer for the amount of time and effort already spent in meeting and working with the community. There remain, however, major areas of concern which have not been satisfactorily addressed. In particular, our primary and repeated areas of concern relate to the proper handling and cleanup of contaminated soil, groundwater, and any remaining hazardous wastes on the site. Also of particular and primary concern are the impacts of Alewife Center on traffic, parking, and transportation. Other areas of major concern relate to impact on utility infrastructure, project design, housing, and wetland issues. Our specific comments on these topics are as follows. Please take note that foot note references are provided at the end of each section.

CONTAMINATION ISSUES

Our primary focus is that questions and concerns relative to contaminated soil, contaminated ground water, and contaminant etissions into the air during proposed construction have not yet been satisfactorily resolved. We are particularly alarmed by the staggering discrepancies between the DEIR and the FEIR relative to the levels of groundwater contamination.* See Chart 1 below. The levels of groundwater contamination are up to 1000% greater in the FEIR

Chart 1

Specific Level of groundwater Level of groundwater Chemical ontamination in ppb's contamination in ppb's differencia] s reported in DEIR as reported in FEIR

Acetone up to 4500 ppb's up to 12,000 ppb's + 270%

Naphthalene above 3000 ppb's up to 24,000 ppb's + 800%

PA'Is 22 ppb's 221 ppb's + 1000% (Polycyc1ic2 Aromatic Hydrocarbons (2 of 12) .EA #5869 - NCSC Rtonse to Alewife Center FEIR January 12, 1988

The references for the chart on the preceeding page can be found in the DEIR Volume 1 - IX-11 and the FEIR Volume 1 - IX-18,19,& 20. Chart 1 is not meant to be all inclusive of the many other chemical contaminants on the site. The NCSC has repeatedly requested that the developer financed Haley & Aldrich (H&A) report and site sampling be verified by the random sampling and subsequent report of an independent agency. We have asked that the reported levels of contamination be accompanied by a corresponding report of what safe levels are. This would provide us with a more convenient and understandable reference with which health hazards and risk assessment could be judged. To date, we have not received any such reference sheet. The toxilogical risk assessment performed by H&A . and based on their 1985 Repcrt of on site contaminants has been repeatedly questioned by members of the community, the NCSC, a Harvard University study dated February 19, 1987, some City officials, and the EPA. In their summary of findings on page 3, the Harvard University study (Spengler,Smith,Ozkaynak,&Fingleton - dtd 2/19/87) states "claims that development- of the site will present no risks to the health and safety of the public are not adequately supported." H&A claims in the FEIR that "no actual or potential hazard to human health is presented by current or proposed development conditions."(3)The FEIR correctly states that "The site was evaluated in accordance with the ranking system and standards used by the EPA for Superfund sites. The site scored less than the minimum required for further evaluation; therefore, no further action by NUS or EFA (4) was necessary." However, as documented in Volume 2 of the FEIR, the EPA reports that "Planned construction on the site could release contaminants to the air. Potential for worker exposure/injury will exist during planned construction on the site. There is a potential for population exposure and injury through contact with contaminated soil and surface water. There is a potential for vapors in subway tunnels and buildings."(5)The EPA Site Inspection-report states "The potential exists- for inhalation of volatile organic compounds and particulates during constructtn activities at the site."( 6 ) In another section of Volume 2 of the FEIR, NUS recommends that additional "samples shoud be collected and analyzed for comparison with the Haley and Aldrich data."()

(3 of 12) E0EA # 5869 - NCSC * ponse to Alewife Center FEIR JPuary 12, 1988

In light of the large discrepancies of contamination levels - V-7 as reported in the FEIR vs. the DEIR, and the conclusions of other agencies and reports as listed bn the preceeding pages, it would be difficult not to conclude that the developer financed H&A report and risk assessment is highly questionable. Other questions and concerns regarding on site contaminants include, but are not limited to the following: 1. Is the ongoing soil and water testing by i&A 8)being verified with an actual random sampling by DEQE or any other independent agency? 2. The map in Volume 1 of the FEIR - IX-17 which contains the location and contents of former underground tanks, above ground tanks, and drum storage is virtually unreadable in critical areas. 3. There is concern over the apparent FEIR decision to use "low level" contaminated soil as backfill and road base subsurface fill.(9IShould it not also be either treated and neutralized, or removed from the site? 4. There is concern over the apparent FEIR decision to stockpile "low level" contaminated soil.(1O)Where will it be stockpiled? On site?? If so, should it not also be either neutralized or removed? 5. Is the depth of soil sampling adequate? 6. The horizontal and vertical groundwater movement should be closely monitored both during the proposed construction period (approximately 10 years) and for some time after occupancy for the proposed project has been accomplished. 7. There is a major concern in the neighboring community to the site regarding the discharge of contaminants into the atmosphere during construction. There are a number of references in the FEIR and reports from other agencies including the Harvard University report dated February 19, 1987 in this regard. 8. Will there be continuous and regular monitoring by DEQE? 9. Who will control the site?(11)

(4 of 12) /EuEA 59bb9 - NFwu Response to Alewi Center FEIR January 12, 1988

-5,- CONTAMINATION ISSUES - Foot Notes

(1) Volume 1, FEIR - IX-20; & Volume 1, DEIR - IX-11

(2) Volu me 1, FEIR - IX-20

(3) Volu ne 1, FEIR - IX-20

(4) Volu ne 1. FEIR - IX-22

(5) Volu ne 2, FEIR - Appendix VI-Potential Hazardous Waste Site Preliminary Assessment - Part 3

(6) Volu ne 2, FEIR - Appendix VI-Potential Hazardous Waste Site Site Inspection Report - Part 3

(7) Volu me 2. FEIR - Appendix VI-NUS.Corporation Superfund Division, Internal Correspondence to Don Smith from Herb Colby, Page 4, dated July 8, 1985

(8) Volu me 1, FEIR - IX

(9) Volu ne 1, FEIR - IX-21

(10) Volu me 1, FEIR - Xf-2

(11) Volu me 1. FEIR - Xf-2&3

(5 of 12) EA #5869 - NCSC sponse to Alewe Center FEIR *anuary 12, 1988

TRAFFIC, PARKING, and TRANSPORTATION ISSUES

The traffice congestion in the area of the proposed development remains quite extreme. The FEIR estimates "that the increase in travel time in the Alewife Brook Parkway corridor due to the 'Pt Alewife Center development would be approximately 10 to 15 total minutes during peak hour periods combined."( 1)The NCSC feels that this is a conservative estimate. Moreover, the Route 2/Alewife Brook Parkway Road Redesign Project, scheduled to begin during the Alewife Center construction period, will further- exascerbate this congestion. The NCSC notes and appreciates the developers committment to "capital improvements to the roadway system abutting the development site."(2)Although we are encouraged that the developer has committed to work with the CARAVAN program, we are disappointed that "The Alewife Center developer is unable to commit to 'no-charge to employee' SBTA passes" or to providing "bus service to the western suburbs".(3 We are also disappointed that the developer was unable to commit to free on site parking. (4) Whereas on site parking will be somewhat limited to begin with, anything short of total committment by both the developer and tenants on the site toward promoting Rapid Transit use, car pooling, and free parking, will surely add congestion to the neighboring community with regard to both local traffic and on street parking availability. We are encouraged by the developers committment to exclude access from Harvey Street; and their committment not to use the Rindge Avenue right-of-way which has been dormant for many years.(5) It is important to note that these committments are consistent with community desires, NCSC goals, and the City of Cambridge Planning Board's Alewife Center Design.Guidelines.(pages 3,4,&7 - dated July 3,1 We are also encouraged that the developer further agrees to "promote the minimization of traffic in the Whittemore Avenue residential area. The NCSC recommends that traffic studies be ongoing throughout both construction and occupancy. It further recommends that mitigating measures relative to the traffic impact, be taken promptly by the developer, whenever and wherever needed.

(6 of 12) E0EA #5869 - NCSC Response to AlewiCenter FEIR uary 12, 1988

TRAFFIC, PARKING. and TRANS PORTATION ISSUES - Foot Notes

(1) Volume 2, FEIR - Appendix IV - NCSC Correspondence & Developer Response - (22.17)

(2) Volume 1, FEIR - Xa-4

(3) Volume 2, FEIR - Appendix IV - Cotrespondehce from-Alice K. Wolf, Cambridge -City Councillor and~Chair of Council Committee on the Environment, & Developer Response - (21.9) & (21.10) Appendix IV - NCSC Correspondence & Developer Response - (22.19)

(4) Volume 2, FEIR - Appendix IV - NCSC Correspondence & Developer Response - (22.20)

(5) Volume 2, FEIR - Appendix IV - NCSC Correspondence & Developer Response - (22.21) & (22.22)

(6) Volume 2, FEIR - Appendix IV - NCSC Correspondence & Developer Response - (22.18)

(7 of 12) )EA # 5869 - NCSC sponse to Alewife Center FEIR *uary 12, 1988

PROJECT DESIGN

As noted in the NCSC DEIR comments, the Alewife Center development is not proceeding as a matter-of-right, but rather as a matter of "privilege under the special permit process at the discretion of the Planning Board."(1)The NCSC and many voices within the community have questioned the size of the development throughout the process. The NCSC is generally in approval of the Planning Board's decision to scale down and limit building height as the project approaches Russell Field. (2 )Although, in truth, there are members of bbth the community and the Committee who feel that this height limitation has not gone far enough. There is a major concern that there may be an open ended future option to exceed the 85' height limitation as the project approaches its Alewife Brook Parkway border. The Committee is generally opposed-to this option.i The North Cambridge Stabilization Committee approves of the Planning-Boardis.decision "for-a.continuous process of review of the various phases of this developement.'

PROJECT DESIGN - Foot Notes

(1) Volume 2, FEIR - Appendix IV - NCSC Correspondence & Developer Response - (22.23)

(2) Volume 1, FEIR - Xb-1 Volume 2, FEIR - Appendix IV - NCSC Correspondence & Developer Response - (22.24)

(3) Volume 1, FEIR - Xb-1

(4) City of Cambridge, Planning Board - Grace Decision Draft, page 12, dated August 10,198 Volume 2, FEIR - Appendix IV - NCSC Correspondence & Developer Response - (22.27)

(8 of 12) OEA # 5869 - NCSC Response to Alew4 e Center FEIR January 12, 1988

UTILITIES AND 0THER CITY SERVICES

In addition to concerns raised in the NCSC response to the DEIR, we are disturbed that the developers have changed their plans with regard to the sewer system hookup. Initially, the developers had proposed to the community that their intentions were to hookup to the Massachusetts Water Resource Authority (MWRA) Sewer System which virtually borders the Alewife Center site. This made a lot of sense to the community since the MWRA sewer system is well equipped to handle the sewerage of the proposed 1,000,000 + sq.ft. development According to the FEIR, the developer now plans to hookup to the City of Cambridge's sewer system. Notwithstanding the City's Phase VII Sewerage System Improvement Program (scheduled for completion in March 1991), the MWRA sewer system is far better equIpped than the City's system; and connection to the MWRA sewer system would certainly lessen both the physical and fiscal impact on the City of Cambridge's utility infrastructure. The North Cambridge Stabilization Committee strongly recommends that the developers for the Alewife Center actively pursue the MWRA sewer system hookup.

UTILITIES AND OTHER CITY SERVICES - References

See Volume 1, FEIR - VIII; & Volume 2, FEIR - Appendix VII - Mtonacelli Associates, Inc., Meeting Minutes dated July 8 & 21, 1987.

(9 of 12) FbEA #5869 - Nsc sponse to Alewi e Center FEIR *anuary 12, 1988

CONCLUSIONS

The goals of the North Cambridge Stabilization Committee continue to be supportive of site development consistent with the needs of the community. We believe that there are a significant number of issues which we have raised that have not been satisfactorily addressed. In particular, our primary concern is that the problems regarding contaminated soil, contaminated ground water, and contaminant emissions into the air during construction must be resolved before development proceeds. Given our concerns about traffic impact, design -sensitivity and housing demands, we continue to question the size of the proposed development. We do not feel that the developer, in most cases, has demonstrated a sufficient effort to find mitigating measures that would satisfactorily address our concerns. In addition, there are several new areas of concern that have arisen since our response to the DEIR. Notably: 1. The elevated levels of contamination as reported in the FEIR vs. those reported in the DEIR. 2. The apparent decision of the developer not to use the MWRA sewer system hookup. 3. An apparent open ended option to exceed the B5' height limitatic

There remain other issues which we have not commented on in any great detail. Most notably they include: 1. No build options. 2. Flood compensatory storage and drainage issues. 3. Wetland resources. We defer:comments in these areas to other individuals and organization However, the questions and concerns which we have raised, require careful scrutiny. We greatly appreciate the efforts of your office in this regard.

(11 of 12) t FA #5869 - NCSC *ponse to Alewife Center FEIR January 12, 1988

Respectfully,

Olivia Golden, Chair North Cambridge Stabilization Committee

Peter V. Cignetti III

Peter C. Kasch

cc: David Vickery RVMi&G 124 Mt. Auburn Street Cambridge, MA 02138

Michael Rosenberg Cambridge Community Development Department City Hall Annex 5? Inman Street Cambridge, MA 02139

Cambridge City Council

Cambridge Planning Board

(12 of 12) 9

North Cambridge Stabilization Committee c/o Community Development Department City of Cambridge Cambridge, MA 02139

February 22, 1987

Mr. James Hoyte, Secretary Massachusetts Executive Office of Environmental Affairs Saltonstall Building 100 Cambridge Street, 20th floor Boston, MA 02202

Attention: MEPA Unit

Re: EOEA #5869, Alewife Center Draft Environmental Impact Report

Dear Secretary Hoyte:

The North Cambridge Stabilization Committee is a city- sponsored group of North Cambridge residents which functions in an advisory capacity to the City of Cambridge and its various boards and departments on a variety of issues. The Committee has met with the developer a number of times, has sponsored several community meetings, and has appointed a subcommittee to convey to your office in this letter the concerns and commments which have arisen from these meetings and our own review of the DEIR.

We are very pleased to have the opportunity to comment on the DEIR for Alewife Center. We are eager to see the site cleaned up and developed in a manner that meets the needs of the community, and we would like to thank the developer for the amount of time and effort already spent in meeting and working with the community. Nevertheless, we believe that major questions still need to be addressed before the development should go forward. In particular, our primary and repeated areas of concern relate to the proper handling of the'hazardous wastes on the site and the impacts of traffic. Other major concerns relate to housing and to project design.

Our specific comments on these and other areas are as follows:

Hazardous Waste

Our primary concern is that the questions about contaminated soil, ground water, and emissions into the air during construction must be resolved to everyone's satisfaction before development proceeds. This includes the information requested by DEQE (see the Notice of Responsibility dated February 9, 1987 and the letter of comments on the DEIR dated February 17, 1987) as well as any requests which may be made by the City. As the F 0 60 immediate neighbors of the site, we are particularly concerned that development is carried out in a way that does not endanger our health.

Specific environmental concerns raised at community meetings include:

1. The draft EIR generally reports contaminant levels only for the portions of the site planned for building construction. We believe that the developer should test and propose methods for cleaning the entire site. Given the concerns noted below about possible shifts in groundwater flow, we are concerned that contaminants outside the building areas might flow into the neighborhood. Specific concerns expressed in the meetings include: a. Is the 12' depth of the test pits too shallow? Might groundwater carry contamination from deeper levels? If the level of the basement parking areas is lowered as is being suggested by the Cambridge Community Development Department P.U.D. design review, then all of the test pits will need to be redug to a lower level. What is the effect of the piles proposed to be sunk to levels below 12'? b. If the entire site is not cleaned up, will there be plans for identifying and cleaning up "hot spots" of contamination that are not on the building sites? What is the justification for not cleaning up the entire site?

2. Neighbors of the site experienced dust during the MBTA construction, are aware of the ill effects this dust caused to construction workers, and are concerned about similar air-borne releases during construction of this development. Specific questions include: a. What will be the effect on asthmatics living in the area? b. What measures are planned for dust control? cMEr7Dt~twlf&yts"iiI ny be einfired t'e 1 -rewWeif rrw tOn. Mwattr ~r-s pkyr for- neaA

3. We are concerned about both groundwater quality and the flow of groundwater during and after constructiqn. In particular, the developer must provide evidence that construction of the sunken portions of the parking garages will not direct groundwater (possibly, contaminated groundwater) into the neighborhood and particularly into neighbors' basements.

4. In general, as noted also in the DEQE letter cited above, we are concerned by the inadequate documentation of conclusions and rationale in the environmental portion of the report (see Chapter IX-12). There is often a substantial leap from the actual evidence that is presented to the conclusions that are drawn.

5. Other specific questions were raised by neighbors at community meetings and in meetings of the subcommittee: a. Neighbors were skeptical of the reported finding that Jerry's Pond is free of contamination. b. One neighbor suggested that the developer be required to post a bond to pay for any damage due to release of contaminated material. c. A random sample should be done by an independent third party to verify the validity of Haley & Aldrich's core samples, since W.R. Grace's credibility is weak as a result of its track record on contaminant information in other communities. d. The use of composite core samples appears to have occurred in some instances which would be-misleading.

6. Any area of the site used in construction (including staging areas) should be cleaned up as it is used.

7. Will the developer make available the Material Safety Data Sheets for each of the known contaminants so that we may have a frame of reference against which exposure to the various levels of contaminants can be measured?

8. The remaining underground storage tanks at the site should be removed.

9. Continuous oversight and monitoring of the site by DEQE during construction and after completion is essential.

Traffic and Transportation

The traffic congestion in the area is now quite extreme. We are uncertain whether a development of this size is warranted given the impacts both on the arterial and local streets. We believe that a minimum condition for supporting a development at the proposed size is that the final EIR show that the increased congestion will not force additional traffic onto local streets. However, at present, it is impossible to reach a conclusion as to the proper size of this development because the traffic section of the report is not fully credible.

In particular, the report inadequately addresses the following issues:

1. It does not analyze the impact of the development on local streets. For instance: a. There are limited traffic counts on the individual streets north of Whittemore Avenue, which is a likely route for bypassing the increasing Alewife Parkway congestion. Residents believe current levels to be far higher than the report's derived figures (see below). b. There is no analysis of the Mass Ave. to Cedar to Rindge bypass alternative. c. There is no analysis of the Concord Ave. to Walden St. to Mass Ave. connection.

2. The report is based upon traffic counts which have not been actually measured, but rather are derived from previous There are additional mitigation measures hat we suggest at this time:

1. There should be no access to the site from Whittemore Avenue. This will virtually eliminate the incentive to use the local streets to the north as a short-cut to avoid Parkway congestion.

2. Employees should be offered T passes free of charge, rather than only at a reduced rate (unspecified in the DEIR) to encourage the use of public transportation to the fullest possible extent.

3. There should be no charge for parking on the site to insure that none of the neighborhood streets will be used for that purpose. (If this conflicts with public transportation incentives, the alternative is increased police enforcement of resident parking in the area--which imposes a cost to the city that the developer should be prepared to bear.)

4. The access from Harvey Street across other lands owned by W.R. Grace should not be used. W.R. Grace must make this commitment.

5. The existing right of way from the site to Rindge Avenue must be extinguished.

Design

There are two statements in the DEIR which in our view deserve correction:

1. The report implies that the developer is entitled to an FAR of 2.0 as a matter of right when in fact he is only entitled to it as a privilege under the special permit process at the discretion of the Planning Board. The FAR is therefore in excess of that allowed by right, which is 1.0.

2. The report argues that the area lacks "a strong homogeneous context," which is then used to justify the introverted orientation of the design solution. We see the commercial area to the west and the residential-area to the east as being highly homogeneous in themselves with the Alewife Center site being the key transition between them. This means that rather than turning away from both of these areas, the site should relate to both of them equally well. We fail to see the design appreciably "varying at its four edges" to do this; instead, it seems too monolithic and out of scale with the residential neighbors on its eastern side. It should scale down towards Russell Field and not impinge on it. Furthermore, we share concerns voiced by the City Community Development Department that the design is too cold and inhuman and would look for some way of relieving that. This might mean a reduction in the size of the project. Other comments made during community meetings about housing demand risks bidding up prices even further, we would expect to see low and moderate income units included in the developer's plan.

Conclusion

We wish to see the site cleaned up, and we appreciate the efforts of the developer to design a plan that will respond to the needs of the city and the neighborhood. However, we believe that considerable additional work is required to reach a final design that meets our concerns. In particular, we do question the size of the development given the concerns about traffic impact, design sensitivity, and housing demand; we believe it is up to the developer either to find and demonstrate effective mitigating measures or to scale down the plans. These questions, as well as the environmental concerns listed in detail above, require careful scrutiny, and we greatly appreciate the efforts of your office.

Resp fully,

Peter C. Kasch, Chairman North Cambridge Stabilization Committee 48A Rice Street

Peter Cignetti Il

cc: David Vickery RVM&G 124 Mt. Auburn Street Cambridge, MA 02138

Michael Rosenberg Cambridge Community Development Department City Hall Annex 57 Inman Street Cambridge, MA 02139

Cambridge City Council

Cambridge Planning Board e. r Northe Cambridge Stabilization Committee

Planning Board City of Cambridge Community Development Department 57 Inman Street Cambridge, MA 02139

Dear Planning Board Member;

Enclosed for your convenience please find a copy of the letter previously submitted to the Massachusetts Executive Office of Environmental Affairs (EOEA) and yourselves outlining our response to the Alewife Center proposal. These comments are still applicable. In addition, we would like to address some changes to the plan which the developer has been obliged to make.

The principal change in the plan is the developer's forced decision not to alter Jerry's Pond. We understand that changes to the plan have been made since it was last presented to the Committee. Therefore, we cannot comment on these until we have reviewed their content. We urge you to ensure that any planned development in the area enhances the pond, making it a more prominent visual and recreational amenity linked to the adjoining public parks.

The key issues raised in the attached letter to EOEA relate to hazardous waste, traffic, design and housing. To briefly reiterate these concerns: Regarding hazardous waste, our concerns raised in the attached letter largely remain. In addition since that letter was written researc-hers at Harvard University have issued a report (dated Feb. 19, 1987) also asking a variety of questions pertaining to public health and safety. In their Summary of Findings (page 3) they stated "claims that development of the site will present no risks to the health and safety of the public are not adequately supported". Throughout the report this condern is repeatedly raised. The Board should take particular note of the "mitigating measures and other Recommendations" including the monitoring of air quality during construction (page 22).

The traffic impacts on the local streets have not been fully analyzed and the figures in the report have some obvious inaccuracies. Projected future traffic at some intersections is less than actual present counts, which makes no sense. The impact of increased use of the Whittemore Avenue area as a -2- shortcut access to the site is a real problem which still needs to be addressed. We have reviewed the additional traffic counts made by the developer (July 1987), however, there is still no analysis of the future impact of the develpment on these areas. The left turn exit from the site onto the Parkway at LeHigh Metals does not have enough storage length to function in a freeflowing manner.

The design did not seem to vary sufficiently at its edges to relate well to the neighborhood on its Russell Field side. The pedestrian access to the MBTA needs to be as direct as possible.

The provision for affordable housing is important. The developer's proposal to do something with the lots on Whittemore Avenue is vague and the suggested figure of 20 units appears to be determined by convenience rather than by the size or impact of the development.

Please do not hesitate to contact us for any reason.

Respectfully,

Lucy Doherty,

Peter Kasch,

Peter V. Cignetti, III on behalf of the North Cambridge Stabilization Committee MEMORANDUM

10 December 1987 File No. 611802

TO: Nancy Bettinger - DEQE, NE Region

FROM: W. E. Stimpson - Haley & Aldrich

SUBJECT: Draft Soil Disposal Criteria for Excavated Soil Alewife Center Project Cambridge, Massachusetts

Development of Buildings 2, 3, 4 and 5 will result in the need to excavate approximately 80,000 cy of soil. It will be necessary to dispose of the majority of this soil off-site. This memorandum provides our suggested action levels for soil disposal and reuse for the project. It is not intended to provide remediation levels for situations where construction does not require excavation of the materials.

Based on our review of the available laboratory testing information, we have concluded that, for the purpose of disposal, the level of metals present in the soil are not of concern. This is based upon the facts that the levels are typical, in our experience, with other urban sites, there have been no operations at the site that might be considered to be heavy metal sources and all EP Toxicity testing to date has been negative. Likewise, PAH compounds, other than naphthalene, are considered to be of no concern for soil disposal.

The PAH's present on the site can be attributed to petroleum products or ashes. Those attributed to petroleum products will be handled as petroleum products. Those attributed to ash will not be addressed individually. ?7r'C

MEMORANDUM 10 December 1987 Page 2

We have divided the material to be excavated into three categories; "clean", "reusable on-site", and "requiring special treatment or disposal". Of the 80,000 cy, some 58,000 cy are considered to be clean. The excavated materials will also have debris from past site usage including concrete and brick-bats, old foundations, wooden timbers, pipes, wires, etc. This material will be segregated as it is excavated, cleaned if necessary and disposed off-site. Our proposed criteria are as follows:

Concentration, mg/kg (dry weight) C-~ t A Otyt U On-Site C eTes . Suitable Treatment or Test Ac On-Site Off-Site Constituent Method Clean- Disposal Disposal

Individual Volatile EPA 8240 40.10* K4 1 . 0 >1/0 ) Organics Total Petroleum CG D-52-77 10500 . 00-Z >500 Hydrocarbons 5 Individual Phthalates EPA 8270 4<0.33* (15_) >15 Naphthalene EPA 8270 (0.33* ~60 ) >15 Formaldehyde NIOSH PUB. 0.5* 10 >10 1- No. 77- t.sjt' -C 237A** Cc.' Kc~~i.t. * Detection limit of test method - 2oO o c ** Wet Weight Co

We propose to dispose of "clean" soils off-site in a DEQE ------,accepted site, but not necessarily a permitted solid waste disposal site. Soil which has been remediated to "clean" standards would also be disposed as clean. Soils suitable for on-site disposal would be used as on-site fill in areas where it would receive soil and vegetation or pavement cover. Soil- determined to require on-site treatment or off-site disposal would be handled as approved by DEQE as a hazardous material.

We look forward to the opportunity to discuss and review this memorandum with you.

WES:hjs/2504s S. Russell Sylva Commissioner (617) 292-5851 ne~$mke Ycee4 Aca/ano ALa 02108

MEMORANDUM

TO: Jim Colman, Madeline Snow

THRU: Sarah Weinstein

FROM: Karen Stromberg S

DATE: August 12, 1987

SUBJECT: 7/29/87 W.R. Grace, Cambridge, Public Meeting

The purpose of this meeting was to review the results of W.R. Grace's Source Identification Study and discuss the proposed Sampling Plan for the site. The meeting was held in the Grace cafeteria and attended by approximately 35 people including W.R. Grace's attorneys and their consultant (Haley and Aldrich); members of the Cambridge City Council's Environment Committee; Cambridge Health Department Commissioner; the City Engineer; reporters from the Cambridge Chronicle and TAB; and neighborhood residents. Nancy Bettinger and I were there for DEQE. Mark Stoler, the W.R. Grace attorney, took a few minutes before the meeting began to discuss the outcome of an odor incident that occurred last month. Complaints came in to the Health Department and it was determined that the odor was caused by an additive that was being used in the air conditioning coolant water. Grace has since changed products and the way that the material is added to the coolant water. Mr. Stoler has given the Health Department names of the people at Grace to contact if any incidents occur in the future. He also indicated to people that if they call closer to the time of the actual incident, it is much easier to trace the source.

Nancy then summarized the site work to date. She explained how the Sampling Plan fits into what has been requested in the NOR and said that she will be looking for public comments in the weeks to come. She also informed people that she plans to approve the beginning of construction of Building 1, on the northwest corner of the development site. There will be minimal excavation (no substructures), but Grace will be required to do vapor screening during construction and must have DEQE approval for their soil disposal plan. Some residents were concerned about rats being driven into their neighborhood due to construction. Nancy deferred this issue to the Health Department. -2-

Haley and Aldrich presented the Sampling Plan, explaining how the Source Identification Study indicated which areas of the site need more information. -A good deal of sampling has already been done. A 1985 report looked for areas of major contamination that might interfere with the proposed buildings, and Haley & Aldrich does not feel there were any areas of interference. In 1986, 80 test pits were dug (20 per building) and wells were installed. Grace received the NOR in 1987, so they stopped evaluating information and data to gather information for the NOR requirements.

The major concerns that were raised related to sampling beyond Grace's property. It was explained that the NOR specifically addresses the Grace property and any contaminated material that was possibly transferred from their property off-site. Haley and Aldrich will be sampling groundwater at points where it flows off the property and the ponds in the area. An area of specific concern is the city-owned Russell Field, adjacent to the site. Grace has never owned the site, although fill from the excavation of the MBTA tunnel was temporarily stored there during construction at that time. GZA (MBTA's contractor) has indicated that the fill was clean and therefore Grace had not been planning to test there. There is considerable question in the community as to whether this is true. Residents would feel more comfortable if either Grace or the Department tested the field, or presented documentation of the fill being "clean". Nancy thought the information from GZA may have been verbal, but will check on it. The meeting ended with the City Council's Environmental Committee making a formal request of the Department to have Russell Field tested. Just before the meeting concluded, Nancy reviewed the next steps for the site. She will be reviewing and approving (possibly with amendments) the Sampling Plan, hopefully by the end of August. Grace will carry out the sampling and submit a full assessment report to DEQE, then Grace will do a feasibility study for any required remedial actions. Nancy envisions this being the next point for public input and would plan to hold the next public meeting at that time.

jp MASSACHU TS BAY V TRANSPORTATION AUTHORITY

Regional Construction Offlee May 4, 1 987 21-Arlington Avenue Charlestown, MA 02129

Ms. Joan Lestovica City Engineer City of Cambridge 147 Hampshire Street Cambridge, MA 02138

Subject: MBTA Red Line Extension NW - Contract No. ElCN36 Restoration - Russell and Magnolia Fields, Drainage Conditions at NE Corner of Russell Field, Cambridge

Dear Ms. Lestovica:

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 (see attached photo) 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 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.

As an intermediate type solution, an eight foot' diameter drywell surrounded by two feet of crushed stone with filter fabric was installed at the low point of a depression, which was graded to collect this areas stormwater runoff. Water that now ponds in this area during high water periods will have to be treated in one of the three methods mentioned above before the ponding situation is corrected.

Please feel free to call me with any further questions that you may have regarding this situation.

Very truly yours,

Howard M. Haywood Project Manager

HMH/rh Attachment - *1

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 uMROs) 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- I .

Documentation of SAC Soil & Test Pit Data Review for the W.R. Grace Site in North Cambridge

This section presents a summary of the review of test pit logs and soils data.

Site 2, Northwest part of the site. O Evidence of oil was observed in test pits 7,5,8,14,15 and 16. o White clayey silt was observed in test pit 8 at depth of 4 ft. o Black rubbery silt was observed in test pit 13 at a depth of 3 ft. o Elevated HNU readings were noted for test pits 15,16,17,18,19 and 20. The level in test pit 17 was 200 ppm. o The highest levels of contamination were observed at the southern end. o Specific contaminants detected: acetone, methylene chloride, moderate PAH levels (40 ppm each), high levels of zinc (up to 11,000 ppm in test pit 13) formaldehyde and phenolics. o The black rubbery silt sample (S1 from test pit 13 contained elevated levels of zinc, chroptium and nickel, but no organics, although the consistency is most likely due to the presence of an unidentified organic material.

Site 3, in the central northern portion of the site. O Slight oil contamination was observed in test pits 9,10 and 19. o Heavy oil contamination was observed in test pits 12,13,14,15,17 and 18. A broken ceramic pipe was observed in test pit 12 at a depth of 2 ft., and a foundation containing oily fill and water was observed in test pit 15. o Generally, the heaviest contamination was observed at the southern end of Site 3. o Specific contaminants detected: acetone (hundreds ppb) methylene chloride (hundreds ppb), BTEX (hundreds ppb), high PAH levels (up to 70 ppm individual values), high zinc (up to 4,000 ppm in TP 101), formaldehyde, phenolics.

Site 4, on the west side of the site north of the MBTA tunnel. o An oily sheen was observed in test pits 1,2,3,5,6,7,8,11,12,13,14,15,16. o A slight oil odor was observed in test pits 5,6,9 and 10. o A strong oil odor was observed in test pits 7,11,12,13,14,15,16,17,18,19. o Elevated HNU readings were noted in test pits 1,2,8,11,12,13,14,15,16,17,18,19, and 20. o Mothball-like odors were detected in test pits 14 and 20, at the southern end of Site 4. o Generally significant oil contamination was observed everywhere except the northern end. o Specific contaminants detected: acetone (hundreds pph), methylene chloride (hundreds ppb), BTEX (up to 25 ppm), low PAH, phenolics, formaldehyde * Naphthalene at 150 ppm in test pit 18. Site 5 near the eastern side of the site north of the MBTA tunnel. O Oily sheen was observed in test pits throughout Site 5. o Mothball odors were detected in pits 13,14,17 and 19, at the southwest corner of the site. o Specific contaminants detected; acetone (hundreds ppb), methylene chloride (hundreds ppb), low PAHs, (up to 30 ppm only in the test pit 15), formaldehyde, phenolics. o Napthalene detected in test pits 15 only at 1.5 ppm.

Site 6, on the eastern side of the site south of the MBTA tunnel. o A sheen was observed in test pits 4 and 5. o An oily odor was detected in test pit 1. o A chemical odor was detected in test pits 4,6,8, and 9. o Frothy water in test pits 1,4,5,6,8 and 9. o Discolored water in test pits 1,6,8 and 9. o White material in test pit 3. o Dump material in test pit 5. o Piles in test pit 6. Site 7, on the western side of the site just south of the MBTA tunnel. o A sheen was observed in test pit 2. o An odor was detected in test pits 1,2,3,4 and 5. o Elevated HNU readings were noted in test pits 2,3 and 5. o Frothy water was observed in test pits 3 and 5. o The east side of the site shows similar characteristics to Site 6.

Northeast corner of the W.R. Grace Site TP301 and TP302 both show relatively low levels of contamination.

Between Sites 2 and 3. o High readings were observed in test pit 303. o Frothy water was observed in test pits 303 and 304.

East of Sites 3 and 5. o Test pits 305, 306 and 326 do not appear to be significantly contaminated.

Area Between Site 4 and Site 5. -East of Site 4 o Occasional clumps of white pasty material. o Water has an oily sheen. -West of Site 5 o A mild naphthalene odor was detected in test pit 327. o A slight oil sheen was observed in test pit 307. o A strong chemical odor was detected in -South end of space between sites 4 and 5. o Strong naphthalene odor was detected in test pits 318. o Strong naphthalene and oil odors were detected in test pits 310,320 and 321. 0 A sulfur odor was also detected in test pit 319. p

Area East of Parkway Pond and West of Site 4. * Strong sweet pungent chemical odor was detected in test pits 309,310,322 and 323, all of which are on the north side of the area in questions. O Of the test pits on the south side of the area in questions, a strong sweet odor was detected in test pits 311,312 and 325. Elevated HNU readings were detected in test pits 311,312,324 and 325. Dark frothy water was observed in test pits 311 and 312.

Reviewer's Comments

(1) The test pit logs contain several references to observations of white materials that are apparently waste materials. In some cases the logs refer to these materials as soil types, for example, "white clayey silt". Apparent waste should be called apparent waste. Furthermore, the soil management plan for handling materials during excavation must include contingencies for handling this waste.

(2) A comparison of the results of naphthalene analyses with test pit logs shows no apparent association between the detection of naphthalene odors at a particular location and the naphthalene concentration in samples collected from the same area. The low correlation observed (by inspection, not statistics) may be the result of a very in homogenous distribution of naphthalene in the soil, even within a very small area.

NB/ae DATA/VALIDATION REVIEW

-~ On page III-1 of the report, in the section &. ?Chemical Analysis Validation", the text states that "...large variations in concentration were observed between soil samples and their duplicates.. .These variations are not due to the analysis method; they are due to the fact that chemicals adhere differently to individual particles in the soil". This statement is an oversimplification. While the uneven distribution of the contamination in the soil is probably the dominant factor, significant variation may result from the chemical analysis procedure, even if that procedure is done correctly.

In the section on data validation on page 111-3, the second sentence of the last paragraph states that the QC data for certain groups of samples was insufficient to "invalidate the data". For the record, it should be noted that analytical data is guilty until proven innocent, invalid until proven valid.

On the Haley and Aldrich validation forms, the surrogate recoveries are simply marked "N.A.." According to Stan Fielding, this notation does not mean that the procedure wasn't done or that the data is not available from the lab, but simply that the data was not provided with the analytical report to the consultants.

On the validation form for some of the samples collected for Phase II of the Alewife Center Master Plan, under the "Surrogate Recoveries" heading, the text states that "The formaldehyde spike results indicated none detected; it is suspected that the sample was not spiked with any formaldehyde". This assumption is not justified by any information on the form. The text of the "Summary of suspect or invalid data" should, therefore address the formaldehyde data.

The Haley and Aldrich report indicates that data from Alpha Labs is corrected for blanks. This procedure is not recommended. Blank values should simply be reported. (The reviewer noted that most Alpha Lab reports indicated that the data were not corrected for blank values).

Most Alpha Laboratory data reports appear to contain an error, or ---contradictiona Volatile organic compound concentrations are reported as being obtained by EPA Method 8240. Just above that section, the reports state that the analysis was done by Method 624.

NB/ae

'A REVIEW OF STREAM AND POND DATA

* The Jerry's Pond sediment sample was found to contain 1,100 ppb naphthalene and 5.1 ppm formaldehyde.

* The stream sediment samples, SD4, SD6 and SD8, from Alewife Brook were found to contain number 6 fuel oil and PAH's, but no naphthalene or formaldehyde.

* The data for surface water samples from the ponds and from Alewife brook don't Indicate persistently elevated levels of any contaminants.

* The Department recommends sampling sediments in Parkway Pond and Yates Pond once per year for at least five years, in conjunction with the long-term sampling program. One composite sample from each pond would suffice. Jerry's Pond is not included in this recommendation, even though site contaminants have been detected there, because there is no continuing transport mechanism that could increase contaminant levels. -2-

Some residents indicated they have more water in their basements since the construction of the MBTA Red Line, and wondered if monitoring would be done in area homes. Nancy indicated DEQE is interested in any potentially contaminated basement water, and people should notify her if they believe they may have a problem. Because portions of some of the proposed development may be below the water table, people have concerns over the potential permeability of the buildings. They also expressed a concern about the impact of permanent dewatering on groundwater levels, flow and directions. The City Council raised the issue of timing. The City has a schedule for reviewing the development plans and wondered how our timing fits into that, i.e., how long does W.R. Grace have to respond to the NOR and do the requested work; how long does the city have to get their comments to MEPA; and how soon will DEQE be making any decisions. Nancy explained that DEQE's comments on the Draft EIR are on a separate track from the NOR, since the area proposed for development is only a portion of the site. Because DEQE does not specify timetables in NORs, the information the city would like before making their decisions will probably not be available.

The biggest concern raised was the issue of oversight - who will be making sure W.R. Grace is doing what their plans say they are? Nancy explained DEQE's oversight role, but many people indicated the desire for a third party to monitor the remedial process. They suggested, at least, that split samples be taken. Nancy went over QA/QC procedures, explaining that they should eliminate the need to do split samples. She also discussed the Department's limited resources, and the fact that DEQE would probably use the same labs for analysis that Grace will use. W.R. Grace's credibility is an issue, as well as an uncertainty of how commited DEQE is to this site. Some residents suggested that the Department should be on-site daily whenever Haley and Aldrich are there. When the topic of how often we would be back for meetings came up, Sarah discussed what a Public Involvement Plan could consist of. Nancy identified some points in the remediation process where input would be useful: after Haley and Aldrich summarize the data available on the site, when sample locations are proposed; after test results come back. Sarah suggested that we provide a brief summary of reports from Haley and Aldrich. The residents are interested in having some input when options are defined, and before options are ruled out. Alice Wolf, City Councilor, brought up the point that people have been to meetings weekly on this site lately, and when it comes time to make decisions people may be "burnt out" if meetings are too frequent.

The meeting was concluded with an agreement that we meet again after Nancy receives the data summary report from Haley and Aldrich.

KS/pm cc: Nancy Bettinger, NERO MEMORANDUM

/adeline Snow TO: - Jim Colman, .n So THRU: Sarah Weinst FROM: Karen Strombe DATE: March 2, 1987

SUBJECT: W.R. Grace, Camridge - 2/11/87 Public Meeting

The purpose of this meetintwas to discuss the NOR sent to W.R. Grace, DEQE's comments on the Alewife Cener Draft EIR, and the process for involving the public in remedial action pinning. It was held in the W.R. Grace cafeteria and attended by approximately 40ieople including, W.R. Grace's attorneys and their consultant, Haley and Aldrict the Cambridge City Council's Environment Committee and their consultan, Dr. Jack Spangler from Harvard; representatives from the City Manager's offic Public Works and Fire departments; reporters from the Cambridge Chron)iile TTA8; and neighborhood residents. Nancy Bettinger, Sarah Weinstei and I were there for DEQE. Nancy began the meeting with a sum .Of the information that DEQE is requesting in the NOR, emphasizing that"t-Wrequest is based on what DEQE knows about the site now. If additional community -cerns are raised, Nancy can make further requests of W.R. Grace. Some people were acerned that testing may not be required in all relevant locations, and the samples'y not be taken at appropriate depths (the developer is planning on 100' piuns in some locations). The community is concerned about air emissions during construct - what will be emitted; how will it be monitored and what guidelines will be 2d; how will community residents be notified of excavation dates, and when. Dilpangler will be reviewing risk assessment work done by Grace's consultants, I may propose that W.R. Grace test and develop an innovative air model to c with the problem. Nancy explained the procedures that are followed when anitor detects any emissions, and Sarah discussed possible community notificalq procedures. EXHIBIT A

S, RUSSELL SYLVA S 4 nnneA4 &lne commisum

935-2160 February 9, 1987 I .;QI

LEGAL DEPARTP " CAlAZDC)G?. W.R. Grace & Company RE: CAMBRIDGE-W.R. Grace 62 Whittemore Avenue Cambridge, Massachusetts 02140 NOTICE OF RESPONSIBILITY PURSUANT TO M.G.L. CHAPTER 21E Attention: Mark Stoler DEQE Case No. 3-277

Dear Mr. Stoler:

The Department of Environmental Quality Engineering is in receipt of an environmental assessment report prepared by Haley and Aldrich, Inc. concerning environmental conditions at the subject site. This report is dated April 1985 and is entitled: "Report on Subsurface and Hydrogeological Conditions for the Alewife Center Master Plan Study." Such an assessment has been voluntarily conducted to evaluate and assess hydrogeological and environtental conditions in order to determine the potential impact upon development plans.

Site History

According to Haley and Aldrich, the site was developed in the 1800's by companies associated with clay mining. Clay was mined from Jerry's pit, located at the southern end of the site, from 1860 to the 1880's, after which the pit was filled with water. In 1919 the Dewey and Almy Chemical Company was established at the subject site for the manufacture of rubber products. The facility also produced sealing compounds and gaskets from processed rubber. Naphthalene sulfonate (trade named DAXAD) was also manufactured on the site for use as a dispersant. Other products manufactured were TDA (a dispersant made from calcium lignosulfonate), SodaSorb (made from processed lime), water-based sealing compounds, soda-lime, synthetic leather-type materials, and various latex materials. When the firm was purchased in 1954 by W.R. Grace, the processes were not changed.

The Haley and Aldrich report states that during the time DAXAD was manufactured several lagoons on the site were used as settling ponds. In 1981, W.R. Grace reported to the EPA that the Company had disposed of wastes on the property. In conjunction with the proposed construction of the MBTA tunnel across the W.R. Grace property, waste from the DAXAD process was excavated, stabilized and disposed of off-site in 1981 and 1982. S 0 W.R. Grace Page 2.

Currently, the W.R. Grace property is mostly vacant, with several W.R. Grace buildings situated along the northern edge, a defunct railroad grade running roughly from east to west through the property near the northern end, the HBTA tunnel located approximately 200 feet south of the railroad grade, Jerrys Pond situated at the southern end of the site, and Parkway Pond adjacent to the eastern end of the site.

Site Investigations

The Haley and Aldrich investigation included excavating 52 test pits, advancing 36 borings and 12 auger holes and installing 21 monitoring wells. Soil and groundwater samples were analyzed for EPA priority pollutants as well as other compounds used at the W.R. Grace site, including acetone, methyl ethyl ketone, methyl isobutyl ketone, xylenes, vinyl acetate, styrene, methyl acrylate, di-butyl maleate, butadiene and formaldehyde. Analysis of groundwater samples collected from these locations indicated maximum contaminant concentrations of 3,000 ug/l (ppb) naphthalene, 4,500 ug/l acetone, 1,100 ug/l methyl ethyl ketone, 640 ug/l methylene chloride, 470 ug/l ethyl benzene, 380 ug/l methyl isobutyl ketone, 300 ug/l carbon disulfide, 310 ug/l hexanone, 140 ug/l dimethylphenol, 125 ug/1 formaldehyde, 74 ug/1 bis-2-ethyl-hexyl phthalate, 85 ug/l di-n-octyl phthalate, 26 ug/l trichloroethane, 21 ug/1 vinyl acetate, 15 ug/l benzene and 2,900 ug/1 zinc. Analysis of soil samples showed maximum contaminant levels of 20,000 ug/kg (ppb) naphthalene, 16,600 ug/kg formaldehyde, 356,900 ug/kg total polycyclic aromatic hydrocarbons (other than naphthalene), 24,000 ug/kg di-n-butyl phthalate, 680 ug/kg acetone, 110 ug/kg ethyl benzene, 22 ug/kg toluene, 19 ug/kg methylene chloride, 35 ug/kg carbon disulfide, 11 ug/kg benzene and 3,430 ug/kg zinc. (It should be noted that these are maximum levels for the samples analyzed, not necessarily for the site.) The highest levels of groundwater contaminants were found on the western side of the site, in the vicinity of former manufacturing operations.

The 1985 Haley and Aldrich Report also contained an assesssment of the potential health risks associated with site development.

Other information in the Department's files concerning environmental conditions at this site is itemized below. This list is not a comprehensive file inventory, but includes documents deemed to be relevant to the site assessment. W.R. Grace Page 3.

Previous Site Investigations

(1) A "Memorandum for the Record" dated June 1, 1970 written by Peter Moleux of the Massachusetts Division of Water Pollution Control (WPC). The memorandum concerns a meeting with Mr. John Kelly, superintendant for W.R. Grace, during which it was determined that industrial waste from Grace's process was discharged through settling tanks, some of which were in series. These included: a wash drum tank and a tank in each of buildings 29,8,1,3 and 5. It was also noted that all land drains discharged to a common sump tank. A sample from this tank indicated the presence of a large quanity of floating grease-like material.

(2) A letter from P.D. Delphia, W.R. Grace's Project Engineer addressing the spill clean-up procedures and stating that the procedure would prevent all of the trietbynol diamine (sic), vinsol resin, calcium chloride and tale from getting into the (sewerage) system.

(3) A Goldberg-Zoino-Dunnicliff & Associates report dated December 26, 1978. Their investigation was conducted in conjunction with the construction of an MBTA tunnel on the W.R. Grace property. The report presented hydrogeologic conditions on the site, and focused on sulfate contamination.

(4) A "Memorandum for the Record" dated February 14, 1979 written by Peter Logan of WPC. The memorandum concerns a meeting attended by the writer, Dan Bourque of WPC and four representatives of W.R. Grace. According to the memorandum, at that time, the only chemical produced at the W.R. Grace facility was a dispersant manfactured by mixing concentrated sulfuric acid, 45% sodium hydroxide, 45% KOH and 38% formaldehyde. All chemicals were stored in buildings having floor drains. There were seven raw chemical storage tanks with capacities from 750 to 1000 gallons at the Grace site. Rinse materials from the tanks were neutralized, then discharged to a pit. Process waste, consisting mainly of filtration media backwashing, was discharged to the wash lagoon, which overflowed into the adjoining sludge lagoon. The sludge was piled near the lagoons. "Blow-off" from the sludge lagoon was evident on the nearby athletic field. W.R. Grace Page 4

(5) A memorandum written by Peter Logan of WPC concerning a meeting with George Kevourkin of W.R. Grace relative to a discharge of #6 oil into Alewife Brook. The oil was being discharged from a pipe at ground level outside of the boiler room, overflowing from the containment area because of a broken berm, entering a surface drain about 20 feet away, and flowing to a sump near Fresh Pond Brook, where the banks had been saturated with oil that had overflowed.

(6) A letter from WPC to W.R. Grace dated May 1, 1979 concerning a site visit by C.W. Lombardi and J.M. Wikinson of WPC. It was noted that a large volume of effluent, including cooling water, boiler blow-down, DAXAD wash-down water and storm water were discharged to the municipal sanitary sewer system. Additionally, large amounts of various chemicals were stored near floor drains that lead to the sanitary sewer.

(7) An NUS laboratory report dated May 25, 1979 with data from the analysis of six soil samples for volatile matter and one water sample for volatile and extractable organic compounds. Sampling locations were not specified. The results for the water sample indicated the presence of 1300 ug/1 (ppb) methylene chloride, 500 ug/1 2,2' thio-bis-propane 200-400 ug/1 phenol, 1,000-3,000 ug/1 methyl phenol, 400-1,500 ug/l benzamides, 400 ug/l anilines and 75,000 ug/l benzoic acid.

(8) A Recra Research, Inc. report dated December 14, 1979 concerning the analysis of an aqueous (toxic extraction procedure) extract of a solidified sludge sample submitted to the lab by W.R. Grace. The leachate was found to contain 220 ug/l phenol and and 50 ug/l total cyanides.

(9) A Camp Dresser McKee laboratory report dated January 22, 1980 presenting analytical results for a composite soil sample collected from TP-10. Analysis of an aqueous extract of the sample showed concentrations of greater than 2,000 ug/l 2- chlorophenol and greater than 150,000 ug/1 naphthalene. A groundwater sample SW5, collected from a shallow well at the filter cake disposal site, was reported to contain greater than 8,200 ug/l naphthalene and less than 10 ug/l 2-chlorophenol.

(10) An Energy Resources Co., Inc. laboratory report dated August 28, 1981 containing the volatile organic analysis results for soil samples collected from various depths at an unspecified location. The results showed levels of naphthalene ranging from 1.72 to 778 ug/g (ppm) on a wet weight basis. W.R. Grace Page 5

(11) Three GCA laboratory data sheets dated September 5, 1981 concerning analysis of soil and water samples from unspecified locations. The first sheet, on which "Soil Sample 21'-0"" was written in pencil, indicated the presence of 350 ug/kg 2,4-dimethyl phenol. The second, labelled "Solidified Sludge" in pencil, showed naphthalene at 2,300 ug/kg, quinoline at 4,900 ug/kg, isoquinoline at 2,400 ug/kg, carboxylic acid at 4,600 ug/kg and methyl naphthalene at 5,600 ug/kg. The third was labelled "Water Sample" and reported 2,2' thio-bis-propane at 5,000 ug/kg. The fourth sheet, also for a water sample, showed 2,4-dimethyl phenol at 300 ug/1, naphthalene at 380 ug/l, phenanthrene at 20 ug/l, pyridines at 718 ug/l and quinolines at 10,760 ug/l.

(12) A GCA laboratory report dated October 29, 1981 concerning volatile organic compound analysis of ten soil samples from various locations in the MBTA tunnel area for non-priority pollutants. The results show levels of thio-bis-propane up to 1200 ug/kg, methyl ethyl ketone up to 440 ug/kg, 1-butanol up to 350 ug/kg and methyl isobutyl ketone up to 220 ug/kg.

(13) A GCA laboratory report dated November 4, 1981 for extractable organic compound analysis of the same ten soil samples discussed in the preceding paragraph. The results indicate the presence of up to 79,000 ug/kg naphthalene, 54,000 ug/kg quinoline, 16,000 ug/kg methyl naphthalene, and 18,000 ug/kg molecular sulfur.

(14) A GCA laboratory report dated March 12, 1982 containing analysis results for two soil samples from the site. The data showed the presence of 300 ug/kg 2-propanol, 220 ug/kg methyl ethyl ketone, 130 ug/kg 2,2' thio-bis-propane 820,000 ug/kg quinoline and 200,000 ug/kg isoquinoline in one sample. The other was found to contain 950 ug/kg propanol, 260 ug/kg methyl ethyl ketone and 44,000 ug/kg quinoline.

(15) A March 8, 1982 letter from W.R. Grace to Sabin Lord (WPC) providing notification of a #6 fuel oil spill from the power plant storage tank. From boiler room records, it was estimated that approximately 569 gallons were released. W.R. Grace Page 6

Statement of Conclusions/Statutory Liabilities

Based upon the aforementioned information, a condition of soil and groundwater contamination has been documented at the subject site.

Be advised that such a condition constitutes a "release" of oil and hazardous material at the site. The prevention and/or mitigation of such a release or threat of release is governed by Massachusetts General Law, Chapter 21E, the "Massachusetts Oil and Hazardous Material Release Prevention and Response Act."

Chapter 21E identifies as responsible parties the current owner or operator of a site at which there has been a release or threat of release of oil or a hazardous material; the past owner or operator of a site where a release of a hazardous material has occurred; any person who directly or indirectly arranged for the transport, disposal, storage or treatment of hazardous materials to or at such a site; and any person who caused or is legally responsible for a release or a threat of release of oil or a hazardous material at such a site. Such parties are liable without regard to fault; the nature of this liability is joint and several. (M.G.L. Chapter 21E, Section 5 a).

This letter is to inform you in writing that:

(1) The Department has determined that a release of oil and hazardous materials has occurred at the subject site.

(2) Additional investigation and assessment is needed to adequately define the impact of this release on public health and the environment, and to determine what, if any, remedial/cleanup measures are necessary.

(3) Information available to the Department indicates that you as owner/operator of the subject site, are a liable and "responsible" party pursuant to Section 5(a) of Chapter 21E.

(4) Should you fail to implement those actions deemed necessary by this Office, the Department may, pursuant to M.G.L. Chapter 21E, take or arrange for any and all necessary actions at the site. If public funds are expended under such conditions, Chapter 21E, Section 11 stipulates that the Attorney General of the Commonwealth of Massachusetts may initiate legal action against the responsible party(s) to recover all costs incurred by the Department in the assessment, containment, and removal of any release or threat of release of oil or hazardous materials. 1.R. Grace Page 7

(5) The liability of responsible parties in (4) above includes up to three times the cost of:

a. all response costs incurred by the Department due to the release/threat of release, including all contract, administrative, and personnel costs; and

b. all damages for any injury to, destruction, or loss of, natural resources due to the release/threat of release.

This liability constitutes a debt to the Commonwealth. The debt, together with interest, would constitute a lien on all your property in the Commonwealth. In addition to the foreclosure remedy provided by the lien, the Attorney General of the Commonwealth may recover that debt or any part of it in an action against you. You may also be liable for additional penalties or damages pursuant to other statutes or common law.

As previously stated, the 1985 Haley and Aldrich investigation was undertaken to evaluate environmental conditions at the site in order to determine the potential impact upon development plans. At this time, however, the environmental investigation must be extended to assess the environmental conditions and potential impacts of the entire W.R. Grace property as it presently exists, as well as during and after development. Additional assessment requirements are outlined below. Further site investigation will be necessary to meet some of these requirements, while others may be adequately addressed by compiling and analyzing available information, or by more fully describing the evaluation processes leading to some of the conclusions stated in the 1985 Haley and Aldrich report.

Requisite Site Actions

(1) Information regarding the location and identity of all former storage tanks, waste tanks and disposal areas must be reviewed and compiled. Documentation confirming the removal of any storage tanks or other structures that may, if present, constitute continuing sources of contamination must be provided. Locations of all such structures should be compared with soil and groundwater sampling locations to determine whether the analytical results indicate the presence of "hot spots" or continuing sources of contamination. The need for additional sampling and analysis at these locations to identify "hot spots" should be evaluated, and the rationale for decisions on additional sampling must be documented. W.R. Grace Page 8

(2) Where definitive concentration data does not exist, "worst case" concentration estimates should be used as a basis for evaluating health and environmental impacts, as well as for designing a groundwater treatment system and determining soil removal criteria. The need for additional sampling to obtain such estimates should be evaluated. Any data and assumptions used in lieu of sampling to arrive at a "worst case" estimate, or to eliminate the need for one, must be clearly documented.

(3) The need for additional sampling and analysis to adequately characterize areas of the site outside of those slated for development must be evaluated. In particular, more information on the eastern and southern portions of the site must be provided.

(4) All currently available analytical data for soil and groundwater samples previously collected at the site must be evaluated. Judgements and assumptions by the consultants regarding the applicability and validity of previous analytical data should be clearly documented.

(5) Groundwater contaminant levels in all areas of the site must be confirmed by one year of quarterly sampling and analysis in order to detect seasonal variations.

(6) Data, methods and assumptions used to predict groundwater flow rate and direction must be documented. If a computer model for groundwater flow is used, supporting documentation should include: (a) a description of both the conceptual model and the mathematical model, (b) a map showing the geographic boundaries of the model, and a discussion of the rationale for selecting those boundaries, (c) an indication of the vertical extent of the modeled layer(s) and the soil strata included in the layer(s), (d) a map illustrating the grid spaces overlying the site, (e) an explanation of the boundary conditions and the data on which these conditions are based, (f) a list of the input parameters, with a summary of the data and assumptions on which they are based, (g) an explanation of the sensitivity analysis and the calibration procedures, (h) field and laboratory permeability measurements against which model input and output parameters can be checked. g It . I i .

W.R. Grace Page 9

(7) The location, depth and structure of underground utilities in the vicinity of the site must be determined and the potential effects of such structures on contaminant transport must be evaluated.

(8) The risk assessment must be extended to address all possible transport pathways, and receptors that might be affected by hazardous materials at the site, both under existing and developed conditions, must be identified. Transport pathways should include, but not be limited to, (1) migration of vapors or contaminated groundwater into existing or proposed on-site buildings and the NBTA tunnel, (2) migration of contaminants along off-site structures or utilities that may act as conduits for transporting contaminated groundwater off-site, and (3) migration of contaminants into ponds and pond sediments via groundwater and surface water. Receptors should include proposed and existing on-site buildings, the KBTA tunnel, off-site buildings and surface water on and near the site. Based on the results of the risk assessment, the design plans for on-site buildings must be reviewed, and if necessary revised, to assure that the occupants will be adequately protected from exposure to contaminants.

(9) The possibility of contaminated groundwater from the site entering basements of off-site residential buildings must be evaluated. If such a condition cannot 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. Such monitoring will require additional shallow wells on either side of Whittemore Avenue. To accurately assess the quality of the groundwater in the upper portion of the aquifer that could potentially impact residential structures, the Department recommends that the monitoring wells be screened to approximately 10 feet below the water table.

(10) A Feasibility Study Report for groundwater and soil treatment must be submitted to the Department. The report must document the evaluation of available treatment technologies and remedial action alternatives, and provide recommendations for site remediations.

(11) A Remedial Action Plan for soil and/or groundwater treatment, including specific design criteria, must be submitted to the Department for approval. A-diTTKcrTon-fIrfer groundwater-treatmaent. **

W.R. Grace Page 10

(12) A plan for the evaluation, classification, and subsequent disposal of soils excavated during construction must be submitted. The plan should include a characterization of contaminant types, estimates of "worst case" concentrations and delineation of vertical and horizontal contaminant distribution in the excavation areas. A proposal for removal and disposal criteria, detailing screening methods to be used, should be presented.

(13) A Hazardous Material Management Plan detailing proposed measures to monitor and control additional releases of oil/hazardous materials during excavation and construction activities must be submitted. The plan should include: (a) dust control measures and an air monitoring program to assure that those measures are effective, (b) decontamination procedures for trucks and heavy equipment to prevent the transport of contaminated soil to neighborhood streets, (c) a system for treating and discharging water during construction de-watering operations, and (d) procedures to assess the potential for downward vertical/transport of contaminants and, if necessary, to prevent such a condition.

(14) If building design requires de-watering to be continued indefinitely or permanently, a monitoring and treatment plan must be submitted for approval.

The information required in paragraphs (1) through (9) above, as well as that collected by Haley and Aldrich after the April, 1985 report, should be presented as an addendum to that report. Documentation to support all conclusions and recommendations made by Haley and Aldrich should be included in the addendum or in the April, 1985 report. After the Department evaluates the addendum, and when the site investigation is deemed to be complete and adequately documented, the Feasibility Study Report will be reviewed. Subsequently, the Remedial Action Plan, the Soil Disposal Plan, and the Hazardous Material Management Plan should be submitted for approval. oa .

W.R. Grace Page 11

A written response indicating your intention to comply with the conditions of this letter is required within 14 days. Your cooperation in this matter has been greatly appreciated. If you have further questions, contact Nancy Bettinger or 935-2160 or the letterhead address. Please reference the DEQE case number in future communications.

ry truly yours,

Richard J. lpin Deputy Regional Environmental Engineer RJC/NB/ae

cc: DEQE/DSHW, One Winter Street - 5th Floor, Boston, MA 02108 ATTN: Madeline Snow Commission of Health and Hospitals, 1493 Cambridge Street Room 715, Cambridge, MA 02139 ATTN: Melvin Halfen, M.D., Commissioner Hines Industrial, University Place, 124 Mount Auburn Street, Cambridge, MA 02138 - ATTN: David Vickery '3-02 71 6 ) wy v- QAW6RI Mt

SUPPLEMENTAL SOIL AND GROUNDWATER DATA DRAFT ENVIRONMENTAL IMPACT REPORT ALEWIFE CENTER CAMBRIDGE, MASSACHUSETTS

PREPARED BY

HALEY & ALDRICH, INC. CAMBRIDGE, MASSACHUSETTS

DRAFT

File No. 611800 7 January 1987 GENERAL

As part of the recent exploration and chemical analysis program completed at the site additional data have been collected on groundwater flow direction and groundwater and surface water quality on the site, at the the site boundaries and off-site. In addition, extensive data have been collected to characterize the quality of soils to be exposed and handled during the proposed site development program.

This document contains summarized data from the recently completed exploration and testing programs which together with previously prepared data provide a general assessment of the impacts the detected levels of contamination will have on site development. The newly acquired data substantiates the conclusions presented in Haley & Aldrich's 1985 Environmental Assessment of the site. The compounds of concern continue to be primarily petroleum products, naphthalene, and acetone. The distribution of the materials in the environment at the site is consistent with past site usage and indicative of general miscellaneous spillage and leakage beyond the known DAXAD waste disposal area. Development of the site can safely proceed, with appropriate precautions, to expose the soils and construct the building. Construction activities will remove selected soils contaminated primarily with petroleum products, such as fuel oil and lubricating oil, from the site to DEQE approved disposal sites. Groundwater will be pumped, treated as required, and discharged to nearby surface waters. Odors will probably be present during the construction activities, but workers and adjacent public will not be exposed to hazardous conditions.

RECENT GROUNDWATER AND SURFACE WATER DATA

Fifteen additional groundwater quality monitoring wells have been installed since the 1985 study to allow long-term monitoring of groundwater elevations and quality and to replace wells destroyed during recent site grading activities. Groundwater samples have been collected from twenty wells and at five surface water locations as indicated on Figure 2 and analyzed for the compounds indicated on Table III. Groundwater level data has been obtained at 26 available wells and

(1) groundwater surface elevations calculated. Groundwater flow directions have been inferred from groundwater contours indicated on Figure 4.

In general, the groundwater flow pattern has the same overall pattern as existed at the site in 1985. Groundwater flows from the central portion of the site radially in all directions. The data indicated that the leak which was present at the construction interface for the MBTA tunnel and identified in the original report has apparently been sealed. However, additional infiltration appears to be occurring into the tunnel in the vicinity of the groundwater passageway which is preventing the groundwater from returning to its pre- construction condition.

Groundwater quality data indicate that the primary compounds in the groundwater are acetone and naphthalene. This is consistent with the 1985 study. No significant contamination exists along the Whittemore Avenue site boundary and in the northeastern portion of the site. The highest level of groundwater contamination continues to be in the vicinity of the present man-made Parkway Pond in the area of the site formerly used for above ground materials storage and DAXAD manufacturing. The present groundwater flow pattern indicates that no appreciable levels of contamination are moving from the site towards the residential neighborhoods bordering or near the site. Low levels of acetone and naphthalene exist in the groundwater adjacent to the Alewife Brook. The brook as well as other surface waters surrounding the site continue to be free of these materials.

RECENT SOILS DATA A total of 216 soil samples have been collected at various depths across four proposed building site areas. These samples have been screened to provide indications of the presence of volatile organic compounds using an HNU photoionization analyzer and a gas chromatograph. The samples have been visually classified and general conditions in the sample vicinity observed for the presence of odors and petroleum products in the soil and on the groundwater. All of the samples have also been analyzed for the level of oil and grease contained in the soil. Forty of these soil samples were selected for analysis of the compounds indicated on Table III and an additional 8 duplicate samples were obtained and tested for quality control purposes.

(2) These samples were also tested for EP Toxicity metals as an indication of the possible presence of RCRA classified hazardous wastes and to determine the concentration and nature of petroleum products present.

In general, the results of the soil testing indicate the general presence of low levels of solvents, occasional presence of naphthalene, and generally elevated levels of petroleum products (fuel oil and lubricating oil) with related PAH compounds. Heavy metals were also detected at levels consistent with past site usage. The results of the soil testing program is summarized on Table III. These findings are consistent with the results of the 1985 studies and the past site usage.

No evidence has been found to indicate that, except at the known DAXAD operation, the source of the contamination is other than incidental spillage and leakage associated with the long-term operation of a manufacturing facility.

SITE DEVELOPMENT CONSIDERATIONS

The general considerations and approaches to excavation, handling, and disposal of soils at the site outlined in the Draft Environmental Impact Statement are valid based on the recent soil data.

The development of the site will require pumping groundwater. Two or more construction dewatering well systems will be used. One well system will be developed in the vicinity of Building 4 where the highest level of contamination is present in the groundwater. Water collected in this system will be treated and discharged to surface waters in the area. The method and level of treatment as well as the discharge water quality will be reviewed and approved by DEQE. Supplemental construction dewatering will occur at other building areas using standard procedures where groundwater contamination does not exist. Excavated soil will be grouped into three general classifications based on the levels of petroleum products, volatile organics, and naphthalene. To the extent possible excavated soils will remain on site, placed under landscaped and paved areas to maximize environmental protection. Acceptable levels of the various indicator components will be established with DEQE for materials that are removed from the site for disposal in non-secure areas. Likewise, levels above

(3) which off-site disposal at DEQE approved secure disposal facilities are required will be established with DEQE. The soil test data indicate the level of petroleum products (fuel oil, etc.) will control off-site disposal requirements. It is probable that the more contaminated materials will be classified as oil spill debris and removed from the site for disposal as non-hazardous material. None of the data collected indicate that an unsafe condition will result during construction. Worker protection will be required as a safeguard for those workers who have the potential to come into direct contact with the more heavily petroleum contaminated soils.

Excavation into the soils will result in odors being produced in certain portions of the site. Respiratory protection will probably be required for construction workers at certain times depending on the building site under construction, depth of excavation and weather conditions. While the odors will be noticeable, they will not result in a health threat to the public at the boundaries of the work area. Construction measures will also be implemented to control the level of dust generated by the construction activities to prevent a general nuisance as well as minimize potential exposures to wind-blown contaminants. All phases of the earth work activities will be monitored by real-time and collection equipment so that no unacceptable worker and public exposure occurs during site development.

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a-00 e S E1oE EeE E E E~e E E EE E 0- 0 0 APPROVAL NO: ~0 REQ'UEST I 1.) CHANGE ORDfERs- MASSACHUSETT BAY TRANSPORTATION AUTHOR'I TY PFCOFOSAL FOR A CHANGE IN THF C:ONSTRUCTJON CONTRACT DOCUMENT S M;TA COUN tRACT NO. F1 CN:hS- - CCNTfACT REST ORAT ION - RUMCELL AND PROJ: RED LINE EXT - NORTH MAGNi:OL I A F I EL DS, iIAMBR I 0OE CONTRACTOR: THE MODERN CpONTINENTAL CONSPT. ALDRES:; 227 . AY. CO.MPANY, I NC:. CI TY: CAMBRIDGE, MASS. o 1. PROPOSAt FOR A CHANGE IN THE CONTRACT DfOtCUME NT S (A) TED [UITBY: F. HA1RHON FO:'R: MBTA (B) B IEf DEliSCR IPT I ON OF PRO'POSE I CHANGE: AF RUJSSELL FILD, BLETWEEN THE Foo rBALL/SC CER FIELD' AND YOURH Sni FIELD AND BEHINI' THE BACKST'P OF THE LITTLE EiFAGUE FIELD. REMOVE AND LOAM ALON'3 C:FNTER OF UNDLRDRAIN AND REPLACE WITH 2" OF ORAVEL BE TOPPEDBY 4" OF GRAVEt AND LOAN AND THEN SEEE WITH MIX TYPF (C:) DES I 'NA IO N1: EX R A WORK 2, CONTRACTORS FROPOSAL (A) IN ACCORDANCE WITH THE TERM. AND COND] IONS OF THE APOVE DESCRIBEDi COLNTRAC:T AND SUCH FURTHER IERMS AND CONDIT IONS AS ARE HEREWITH C:ON OR ATTACH E[D AND MADE A PART HEREOF , THE UNDER-SIGNE i' CONTRACIOR PROF TO PERFORM I HE WORK DiESC:R]BED IN 1([:) ABOVE FOR AN ADDITION TO THE CONTRACT PRICE THE LUIMP SUM OF 7, 545. E,1 rIME EXTENSION: 0' CAl ENDtAR DAYS: CONT RACl OR: TFHEMDERN C:ON1 INE. NT AL C:ONSJT 'Al E :II

AUTIH SIGN: TI Ii E: YUF. 3. APPROYAL OFLERIIarTU4h ROPOAL RECOMMENDED ( SEE A FTACHJED RPORV U (A) DESIGNEF F 1RM:SVERDRUP & FARCE A C

(B) PROJI MOR DAl E: (C: TO THE EXTEN REQUIREDtYLCHAP. :30, 39I, THE AUTHOdi T Y CERT IF IE:i THAT THIS CHANGE ORDER DOCES NOT MATERIALLY INJURE THE PROJECT AS A WHOLE , THAT EI THER THE WORK 'SUBST I TUTEDP F OR 1 HE WOFi SPE CIFT ED IS OF SAME COST AND QUALI TY, OR THAT AN E'Q UITABLE ADJUSTMENT HAS 1-HEN AOR UPON BETWEEN THE AUTHORITY AND THE CONTRACTOR AND THE AMOUNT OF DOLL OF SAID ADJUSTMENT AND THAF THIS CHANGE ORDER IS IN THE BEST INTEREE THE AUTHORITY. THIS CERTIFICATION SHALL NOT CONSTITUTE A WAIVER OF 0 DEFENSE TO -lYt AA:LAIMS AGAINST ANY PARTY ARISING OUT OF THIS CH

ASST.LDOC}' ~ C - __ .. DATE: g (D) ti-- : DATE: 4. APPROVED AS TO FORM: OENERAL COUNSEL '"Dt-J .be< //2 DATE: 3-V-7 5. APPROVAL AND ACCEPTANCE OF AEOVE PRPO_ AL BY TU Bh FILLED IN BY MBTA: THE. MASSACH. ISE TTS PAY TRANPrORTAT ION AUTHOR I T Y - OR I'NAL AWARD 1, 524, 245 EXEC ADDITON 3, ,347 J ECEXEC DEDUC'ZTON COMI T FED VALtU 1, 282, 22( VALUE THS CCO. 7, 54' TIA6,ELAK TuT INC THS CO 1,289, 766 AUHT DA TE: /t MTA CONS lRUC T ION FO:'f AU H PAGE OFI / MAS,SACHU*TS 4 SAY TRANSPORTATION AUTHORITY

Ten Park Plaza. Boston, MA 02116

November 18, 1986

The Modern Continental Construction Co., Inc. 2277 Massachusetts Avenue Cambridge, MA 02140

Attention: Raymond A. Comparetta

Re: MBTA Contract No. EICN36 - Russell and Magnolia Fields

Gentlemen:

Reference is made to your proposal dated October 22, 1986 for a lump sum of $7,545.81. You are hereby authorized to proceed with the following scope of work.

Scope of Work: At Russell Field,,between the football/soccer field and youth soccer field and behind the backstop of the Little League field, remove sod and loam along center of underdrain and replace with 2" of- gr-avel to be topped by 4"-of grav-el and loam. The area will then be seeded wi-th mix Type-"B".

aasis of Payme-nt? Payment will be made in accordance with Division I, General Requirements and Covenants, Section 01150, Subsection 1.05(B)(1) for a lump sum of $7,545.81.

Time Extension: None.

A change order will be issued to cover this work.

Very truly yours,

Peter F. McNulty Assistant Director of Construction-Administration

FMH/w cc: R. C. Tangard F. M. Keville

IL AGES 4. 1 4 1 0* 0 soe

I C~ MBTA Contract No. EICN36 / Change Order Request No. 5

EXPLANATION OF NECESSITY

The underdrain system for Russell Field, in Cambridge, works efficiently during light rain fall. However, due to the high water table, during heavy rain storms the underdrain system works, but is inadequate for the additional volume of water. Therefore, such a storm would delay the recreation activity scheduled for that particular day.

The Project Staff requested that the underdrain between the football/soccer field and the youth soccer field, and the underdrain behind the little league field backstop be- improved to increase capacity for the underdrain system. This improvement will alleviate flooding and also prevent any lost time scheduled by the Cambridge Recreation Department.

The Authority directed Modern Continental Construction Company, Inc., the General Contractor, to submit a cost proposal to reflect Field Memo No. 7 and Field Memo No. 9.

- The Contractor's- cost proposal of $7,543.81 for this change order was reviewed.by ~the Project Staff and Consultant and found to be fair and- reasonable.

This change order will not require any additional time.

Mary . Ainsley _..Resident Engineer

!USX!LAGES I t A- I.A, A, I

RF; I..1E __T.'_..EE' / MiAE:EACHU:EE TTS BA T. -o. E0 ~A T c*'N AZUTH3R IT- PPCF cISAL FCR --.HANt-rEN TEE JNITRD CT ON CONTE CT DOCUMENTS MITA CT N . C ---- - t C QTFRAC 7T ??RAT ION - F:U-LEL AND HR3.: D LfNE E T - NG TH vA31N~L:A FIEzL:, CAMERJDi

TK-FCAL FOP A. IHNO-s i+. -iME IiVFT~iUET .S~UEtIT TED' 1<: MiAR\ F. RAYMOND FOR: MB~I

Pt:R IEr :,ESC5rPTIoN4 ?FROPOSEf' CHANE:- EXKA':-TE- PEPA'p AN CA A:DAXDNE~D :EEWER LiNES AT THE NIOFTH-EA.T ICORJNEn I!F RUJSEELL FIL C) DECN'TION: EXTRA WC'RK -, .NT4;7CTUR$ FPOF EAL:

7Fe.IM-E 10 NALENDA-----:TN'r DA

CNITRACTCIF: THE MiOD~ERN c jNT INENTAL CQNE T. 'ATE: cPtd

AUT SIGN: __ TITLE:______. APF'RAL OF AD\E P fU. T AND FRCPE"AL RECOMMENDED .EE TACHEE RErOF - ,PRJMG _ D TIEzzrELr-A'ii;

THE EXTENT r:EUIRED Y L3C.$ . THE AUTHORITY CEPTIFIES THAT THIS CHANGE OPDER DOES NOT MATERIALLY INJURE THE PROJECT AS A WHOLE THAT EITHER THE WORK SUBSTITUTED FOR THE WORK SPECIFIED IS OF THE :AME COST AND '?UALITY, OR THAT AN EQiUITABLE ADJUSTMENT HAS BEEN AGREED UPON BETWEEN THE AUTHORITY ANDI THE CONTRACTOR AND THE AMOLUNT OF DOLLARS OSAID ADJUSTMENT AND THAT THIS CHANGE ORDER IS IN THE BEST INTEREST OF THE AUTHORITY. THIS CERTIFICATION SHALL NOT CONSTITUITE A WAIVER OF OR 4. DRES RA, .ET MAGAINST ANY FPARTY ARISING OUT OF THIS CHANGE. ASTT. IM_//'IAZ!-VDOC DATE:

AENERAL COUNSEL 1NEz4 6O 56/td DA TE: / -. APPROVAL AND ACCEPTANCE OF ABOVE PROPOSAL BY a TO BE FILLED IN BY META: THE MASSACHUSETTS AY TRANSFORTAT ION AUTHORITY ------* ORIGNAL AWARD 1 524 -245. 0 +- E.XEC ADD'ITC'NS * EXEC DEDUICT0N COMITTED VALU 1,524,245.± ' VALUE THS CO. 1, 736. 4 *TOT INC THS CO 1 ,525, 981. 49 DA TE: / MBTA CONSTRUCTION FORM 3 AWlTHOR1/-tSI f iR I AH I E PAEz.FAJRPAGE OFF T : MASSAC TTS 'Y0' - BAY W 0I TRANSPORTATION AUTHORITY

Ten Park Plaza. Boston. MA 02116

July 24, 1986 Modern Continental Construction Co., Inc. 2277 Massachusetts Avenue Cambridge, MA 02140

At tention: Ray Camparetta Project Manager

Re: MBTA Contract No. EICN36.. Russell and Magnolia Field Extra Work Order

Gentlemen:

Reference is made to your proposal dated July 10, 1986, for a lump sum of $1,736.49. You are hereby authorized to proceed with the following scope of work.

Scope of Work:

Excavate, repair and cap abandoned sewer lines at the Northeast corner of Russell Field.

Basis of Payment:

Payment will be made in accordance with Division I, General Requirements and Covenants, Section 011050 Subsection 1.05(B)(1) for a lump sum of $1,736.49.

Time Extension:

None.

A change order will be issued to cover this work.

Very truly yours,

Peter V. McNulry Assiskant Director of Construction -Adminis tration

FMH/kas cc: R. C. Tangard

PAGE 2C lS MASSACHUITTS BAY TRANSPORTATION AUTHORITY

Regional Construction Office 21 Arlington Avenue Charlestown, MA 02129

March 25, 1986

Joan Lastovica, P.E. City Engineer City of Cambridge 147 Hampshire Street Cambridge, MA 02138

Dear Ms. Lastovica:

Re: Russell Field Flood Retention Area

I have been informally notified by Ms. Brooke Monroe of D.E.Q.E.- that your request to upgrade the proposed compenta- tory flood storage area at Russell Field will be approved.

Our consultant engineers have been directed to prepare a field memo which we will issue to Modern Continental. The issuance of this field memo will result in additional work for the contractor. Because this work was initiated by the City of Cambridge, we feel that the cost of this work should be deducted from the City's Athletic Replacement Fund.

A copy of the field memo and a breakdown of the contractors estimated extra cost will be submitted to you for review and information, and a change order will be initiated following your review and our approval.

Please contact me if you have any questions regarding this matter.

Very truly yours,

Howard M. Ha ood Project Manager HMH/rh cc: J. Powers K. Arpino

R. Patterson - Cambridge

E-.1 -..... CITY OF CAMBRIDGE CAMBRIDGE, MASSACHUSETTS 02139 REC:VED

OFFICE OF THE CITY ENGINEER Joan Lastovica P.E. City Engineer CONSTRUCTION OFFICE NQRTH

Mr. William St. Hillaire, P. E. Regional Environmental Engineer Department of Environmental Quality Engineering 5 Commonwealth Avenue Woburn, MA 01801

3 March 1986

Subject: DEQE File #123-19 Russell Field Wetlands/Cambridge

Dear Mr. St. Hillaire:

In accordance with the enclosed correspondence of July 7, 1982 from Leslie Moore of Ellenzweig, Moore and Assoc., Inc., and of May 10, 1985 from Donald J. Kidston of the MBTA, and of May 24, 1985 from William A. Krol, P.E. of the DEQE; the City of Cambridge is requesting the concurrence of the DEQE regarding the following proposed method of providing compensatory flood storage for the Russell Field site.

The City is requesting the storage volume of 13,000 cubic feet be considered as provided on the contiguous lands of the MBTA Alwife Station site. Specifically, the MBTA design storage volumes were calculated based on a 100 year floodplain elevation of approximately 114.4 - which is 1.3 feet greater than the FEMA required elevation of approximately 113.1. Transferring the Russell Field volume to the storage volumes on the MBTA Station site will enable the removal of a potentially hazardous basin immediately adjacent to athletic playing fields. The additional 13,000 cubic feet represents less than 0.02% of the MBTA flood storage volume of 771,800 cubic feet.

The conservative flood elevations that are contained at the MBTA Alewife Station and the potential danger to the playing public at Russell Field lead the City to request your consideration and acceptance of this proposal. Please contact me if additional information is required. As this project is now beginning construction, your attention to the matter is most appreciated.

Very truly yours,

Joan Lastovica, P.E. City Engineer

Enc. Sketch and cales, Russell Field cc: Everett Kennedy, Cambridge Public Works Department Cambridge Conservation Commission John Powers, MBTA Howard Haywood, MBTA Brooke Monroe, DEQE MASSACHUSETTS BAY TRANSPORTATION AUTHORITY

Construction Directorate Ten Park Plaza, Boston, MA 02116

December 4, 1985

Frederick P. Salvucci, Secretary Executive Office of Transportation and Construction Ten Park Plaza Boston, Massachusetts 02116

SUBJECT: Massachusetts General Laws - Chapter 480 Acts of 1979 - Request for Contract Approval

Dear Mr. Salvucci,

Pursuant to the above-captioned matter, which requires the MBTA to obtain Executive Office of Transportation and Construc- tion approval of any agreements entered into for the construction or acquisition of mass transportation facilities or equipment of more than $1 million, the MBTA hereby submits, for the approval of the Secretary of EOTC, the following contract awards and supporting documentation.

Authorization for the execution of MBTA Contract No., ElCN36, Restoration, Russell and Magnolia Fields, Arlington and Cambridge, with The Modern Continental Construction Co., Inc., for the estimated sum of $1,524,245.

Authorization for the execution of MBTA contract No. P4CN01, Modernization of Dewey Substation No. 11N, with Buffalo Electric Construction Co., Inc., for an estimated contract price of $3,781,800.

CONSTRUCTON OFFICE 1ORTWH

12/10/85 To H. Haywood, K. Aroino FYI & Records JEP j h A hS,q01 0 t.) bcc: J. - 9 e+ BAY P. F. McNulty TRANSPOR ION R. E. Russell R. C. Tangard H. R. Sinclair J. H. Scanlan Thn Park Plaza. Boston, MA 02116 6 1985

H September 5, 1985

Urban Mass Transportation Adminis trat ion TSC/Kendall Square Cambridge, MA 02142

Attention: Richard H. Doyle Administrator, Region I

Gentlemen:

Re: MBTA Contract No. E1CN36, Restoration - Russell and Magnolia Fields Cambridge and Arlington, MA Sole Source Products

The Authority is currently involved in the preparation of plans and specifications for the above mentioned contract. At the 90% completion level there are four products specified that do not meet UMTA's proprietory specification requirements. The Authority is requesting that UMTA approve the use of these products for the reasons stated below:

1. Erosion Control Mat

The above referenced contract involves the restoration of Cambridge's Russell Field to an elevation almost five feet higher than it was prior to MBTA Red Line Extension construction. In order to provide for the required ball field areas, bleachers and pathways on this elevated field, an embankment slope of 1.5 feet horizontal to 1.0 foot vertical is to be constructed in the southwest corner of the site. The most practical erosion protection treatment for this slope is the use of a permanent erosion control and revegetation mat. Due to the paved pathway to the MBTA's East Entry of Alewife Station being immediately at the top of this steep slope, special protection of this slope is warranted. This treatment should be permanept to insure this protection in the future so a photodegradable or biogradable material is not acceptable for this application. There are only two products available that meet the requirements of this slope treatment. They are as follows: 9/1/s

I Am- 1 10, ij&&: :LM IP UMTA Page Two

a. Erosion Control/Revegetation Mat - Miramet (ECRM) by Mirafi

b. Soil Reinforcement Matting - Enkamat by American Enka Company

2. Grandstand Pressbox

Due to concerns for construction quality control, compatibility with bleacher structure and portability of the unit, a pre-coastructed pressbox is justified for this grandstand installation. It is recommended that the MBTA obtain approval from UMTA for the use of the sole-source pre-assembled pressbox as provided by Stadiums Unlimited.

3. Porous Concrete Underdrainage Pipe

Previous experience in the City of Cambridge with combination perforated pipe and filter fabric underdrain systems has often been unsuccessful; these systems often clog. The underdrain system proposed in this contract is an attempt to minimize this effect by calling for the use of continuous porous wall underdrain pipe. This type of pipe allows for a more evenly distributed and slower groundwater infiltration at any one spot on the pipe and surrounding fabric; this results in.less movement and accumulation of fine soil particles that otherwise tend to block or hinder infiltration. Since the site of this contract has soils that have fine sands with traces of silt we are specifying the use of a porous wall concrete pipe that is manufactured only by these two different sources:

a. Gelinite Porous Concrete Underdrainage Pipe by Perma-Por Corp.

b. Poroswall Underdrain Pipe by Walker Poroswall Pipe Co.

4. Police Alarm Components

For the reasons of City-wide system compatibility, Cambridge is requesting the following components to be specified for procurement in this contract: Ii II~ Up Item No. Description antity A Unit Unit Price Amount 0261.200 CLASS I BIT. CONC. PAVEMENT 7 TON $ 40.00 $ 280.00 TYPE I-1 TOP COURSE 0261.201 CLASS I BIT. CONC. PAVEMENT 12 TON 40.00 480.00 TYPE I-1 BASE COURSE 0:262.160 GRANITE TRANSITION CURB 4 EA 100.00 400.00 0262.208 GRANITE CURB CORNERS TYPE A 2 EA 130.00 260.00 0262.214 GRANITE CURB TYPE VA4 STRAIGHT 135 LF 20.00 2,700.00 0262.701 CURBING REMOVED AND RESET 50 LF 10.00 500.00

0263.107 BITUMINOUS CONCRETE WALKWAY 3,710 SY 7.00 25,97 0.00*** 0263.200 CONCRETE SIDEWALKS 1 COURSE 120 SY 17.00 2,040.00

0270.990 FENCES REMOVED AND DISCARDED 670 LF 2.50 1,675.00

0271.001 FENCES REMOVED AND RESET 515 LF 6.00 3,090.00

0271.056 FENCES WITH SLATS 255 LF 20.00 5,100.00

0271.101 48 IN. CHAIN LINK FENCE 1,550 LF 12.00 18,600.00 VINYL COATED

0271.103 72 IN. CHAIN LINK FENCE 365 LF 21.00 7,665.00 VINYL. COATED

0271.104 96 IN. CHAIN LINK FENCE 2,025 LF 27.00 54,675.00 VINYL COATED

96 IN. CHAIN LINK FENCE GATE 20 LF 70.00 1,400.00 WITH POSTS

0271.248 48 IN. CHAIN LINK FENCE GATE 31 LF 42.00 1,302.00* WITH POSTS

0271.000 IRRIGATION SYSTEM 1 LS 50,000.00 50,000.00* 0282.150 SEEDING 22,310 SY .80 17,848.00 0282.160 SEEDING TYPE B 860 SY .80 688.00 0282.300 LAWN SODDING 28,130 SY 5.00 140,650.00**

0282.402 WOOD BARK MULCH 58 CY 40.00 2,320.00

0284.145 PLANTING 1 LS 60,000.00 60,000.00 Item No. Desc ion uantity & Unit Init Price Amount 0348.412 12 IN.REINFORCED CONCRETE 224 LF $ 40.00 $ 8,960.00 PIPE CLASS IV 0348.418 18 IN. REINFORCED CONCRETE 414 LF 45.00 18,630.00 PIPE CLASS IV 0426.151 BRICK PAVING ON BITUMINOUS 100 SY 75.00 7,500.00 CONCRETE

GRAND STANDS LS 85,000.00 85,000.00* RECREATIONAL EQUIPMENT 1 LS 16,000.00 16,000.00* 1520.009 PUMPING STATION LS 210,000.00 210,000.00 1611.051 STEEL JUNCTION & DEVICE BOXES 2 EA 5.00 10.00 1611.120 12 X 24 INCH PRECAST CONCRETE 49 EA 400.00 19,600.00 PULL BOX - MUNICIPAL STANDARD

1611.511 CASTING AND COVER FOR PULL BOX 49 EA 165.00 8,085.00 1613.006 NO. 6 AWG CONDUCTORS 400 LF .50 200.00

1613.601 #12 THWN WIRE 3,000 LF .35 1,050.00

1613.604 #6 THWN CABLE 19,800 LF .65 12,870.00

1613.605 #4 THWN CABLE 4,500 LF .90 4,050.00*

1613.606 #2 THWN CABLE 3,300 LF - 1.20 3,960.00* 1615.291 1-3 INCH PVC CONDUIT 8,000 LF 6.00 48,000.00**** CONCRETE ENCASED

1619.200 3/4 IN. RIGID STEEL CONDUIT 100 LF 4.00 400.00

1619.204 2 IN. RIGID STEEL CONDUIT 900 LF 8.50 7,650.00

1624.982 GROUND ROD, 5/8H X 8 FEET 32 EA 90.00 2,880.00

1633.006 LIGHTING CONTACTOR, 60A, 1 EA 700.00 700.00 6P, 120V

1633.095 ENCLOSED CIRCUIT BREAKER EA 350.00 350.00*

1633.100 PANELBARD.S 1 EA 1,000.00 1,000.00 1634.020 WIRING TROUGHS 1 EA 30.00 30.00 1634.021 METER TROUGH 1 EA 140.00 140.00

nnu mi, n Item No. Description Quantity & Unit Unit Price Amount ) 1634.180 TIME SWITCH, ASTRONOMIC DIAL 1 EA $ 500.00 $ 500.00 1634.207 DISCONNECT SWITCHES 1 EA 200.00 200.00*

1635.413 RECEPTACLE W/S.S. COVER 2 EA 25.00 50.00

1640.038 STREET LIGHTING CONTROL 1 EA 3,500.00 3,500.00 CABINET, PULL BOX BASE

1640.063 IRRIGATION CONTROLLER CABINET 14 EA 1,000.00 1,000.00*

1640.700 LIGHTING FIXTURE TYPE A 24 EA 2,800.00 67,200.00 1640.704 LIGHTING FIXTURE TYPE B 4 EA 1,700.00 6,800.00 POLICE ALARM SYSTEM _1 LS 6,000.00 6,000.00*

1680.081 MAG. MOTOR STARTER COMB. TYPE 1 EA 500.00 500.00* NEMA SIZE 1, W/HOA, R&G PILOTS, NEMA 12 ENCL.

TOTAL ESTIMATED CONTRACT BID PRICE $1,350,514.00

* Use of Athletic Replacement Fund (A.R.F.).

** Includes $118,146.00 from A.R.F. over and above the seeding cost as recommended by the Engineer.

* Includes $7,469.00 from the A.R.F. for bleacher apron.

* Includes $20,000.00 from the A.R.F. for Police Alarm System and Irrigation system encased conduits.

TOTAL ESTIMATED CONTRACT BID PRICE WITHOUT ATHLETIC REPLACEMENT FUND WORK EQUALS $1,035,287.00 NUS CORPORA lON INTERNAL CORRESPONDENCE SUPERFUNDDIVISION

TO: DON SMITH DArE 3ULy 9,198

FROM! HERB C YFIt

SUBJE PRELIMINARY ASSESSMENT OF W.R. GRACE AND COMPANY, CAMBRIDGE. MASSAC T TDD NO. FI-g504-12 JOB NO. MA38-PA

The W.R. Grace and Company, Cons ction rod ts Division is located 800 feet west of the Route 2, Alewife P wa r at 62 Whittemore Street in Cambridge, Massachusett , A peri eter survey of the site (Figure 2) was performe n May 17, 85, b er Colby and Barbara Felitti (NUS/FIT). A chain lin fence encom e e are 27 acre site. Gates are guarded and access throug restrict altho access appears not to be' difficult due to numerous holes in the fence. Grac buildings are located in the northeast portion of the site j to Whi m e Avenue. Jerry's Pond is located in the southern end the site, an rs pproximately 5 acres. The remainder of the site is quite I vei is covered ith asphalt or gravel, with little or no vegetation growing. Th en ur ace is a result of the recent demolition and removal of many b ding on e site, and the construction of the Massachusetts Bay Trans' orit (MBT Red Line Extension tunnels which bisect the site east to t (3). ere e a ew large piles of dirt and gravel on the site. The entire ea a ear nably neat and well maintained (4). The site is boun d on so by ndge Avenue and the Rindge Towers Apartments, to t west y ew ook Parkway and Lehigh Metais, to the north by Whittemore venue d residential properties, and to the east by Russell Athl ' d re ' ential properties (Figure 2). The North Cambridge/ resh Pond a' h vily populated with multiple family dwellings and highr' an en a t t complexes. In addition, there are a number of shoppin ent , rese rch fices and indus tries in the area.

Fresh P a ho re rvoir for Cambridge's water supply, is located 0.5 miles to the th. It sup ies water to approximately 102,000 people (5). Site History

Much of the North Cambridge area is underlain by extensive clay deposits. In the 1800's, these deposits were mined extensively for the manufacture of bricks. Jerry's Pond and Yates Pond (Figure 2) are former clay pits which, due to the high water table In the area, have filled with water. Most clay mining ceased in the late 19th and early 20th centuries. The Dewey and Almy Chemical Company and W.R. Grace and Company have utilized the site since Dewey and Almy's founding in 1919. The site has been used for various chemical manufacturing processes. Some of the products manufactured in the past Include rubber products, can sealing compounds, drum and pail cover gaskets, bottle cap hus ON SiU t 1--

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gaskets, latex sealants and adhesives, air-entraining a nts f r concrete, silicone sealants, synthetic leather-type materials, sodium n phth ene sulfonate (trade name DAXAD) and SodaSorb, a material used to al w the use of anaesthetics (3).

Raw materials and manufactured chemical pr t ere s ed on he site in a variety of vessels, including above and- under roun storage ta d drums. A wide variety of raw materials have been ore o 'te at various times in the past. The materials include, but may at f ite to acetone, butadiene, styrene, vinyl acetate, methyl aceta , me nol, ibutyl maleate, isobutyl ether, hexylene glycol, naphthalene, rmaldeh e, sulfuric acid, sodium hydroxide, potassium hydroxide, methyla ate, a monia, fuel oil, toluene, hexane, alcohol, zinc chloride, calcium lignos te, ga line and diesel fuel (3). Wastes were treated and/or disp se numbe f I goons and settling ponds (Figure 2). Figure 3 shows the I ation of ta - tor e capacity (where known) and contents.

Prior to the construction of the b TA ed in Extension through the site, a number of soil, groundw dro gy an waste contamination studies took place. The first, perf med by Gold rg, oino, Dunnicliffe and Associates in 1978 indicated the pr enc of D D as materials and also areas-of low pH along the proposed ne nment. ther investigation into the nature and extent of the #ast mat was rior ed by Haley and Aldrich in 1979, prior to the start of t tunne co tru '. As a result of the investigations and discussions between . Gra , the MBTA and the Massachusetts Department of Environme a Engin ring (DEQE), waste materials (sludge) were excavated d were disp e of i ingston, Rhode Island during 1981 and 1982. Groundwa r m ing Ils ere also installed and monitored by the MBTA (3). Soil em ed for he t nel construction was stockpiled on the site. Some of the clean xcava ed i1 was transported ' hore c' and e appin mater'i which was co tammnate ained on 'te or - art an -as used f b ~ . certain amo cont 'nated soil was truck to Davis ar Somerville for use as backf illI ar the tunnel. I en Tznbecames aware R te situaon, stoppe , and the affected area was covered with asphalt. There is a question as to whether all the sludge was removed from the Grace Site. An MBTA official had remarked that "though the MBTA had excavated more sludge than was required by law, if we were to look for more sludge in the area we would find large quantities of it still in the ground" (8). Since 1979, many buildings on the site have been removed or demolished. The remaining buildings are used for offices and research laboratories. There are currently no manufacturing operations on the site (3).

W.R. Grace and Co., in cooperation with Hines Industrial of Cambridge, Massachusetts, is proposing to construct several multi-story buildings on the site. C-583-7-5-59

-MEMO TO: DON SMITH JUNE 25, 1985 - PAGE THREE

A two phase soil and groundwater investigation w con cted by Haley and Aldrich during 1984, in an effort to better define oth e depth to suitable bearing soils and environmental conditions pres nt on t site. A report detailing the results of the latter investigation as e ava ble in April of 1983, under the title "Environmental Assess t ep t for e Proposed Alewife Center Development at the W.R. Gra- a o. Prop ty". opies were made available to the U.S. Environmental P tect' n Agency, t assachusetts DEQE, various boards and libraries in Cam idge

The report indicates the presence a n ber of contaminants in the groundwater and soil on-site. Conta 'nants esent in samples include naphthalene, acetone, polycyclic arornati hydroc bons, carbon disulfide, benzene, formaldehyde, phthalate zinc, lead d co r. In addition, zinc, copper, naphthalene, acetone, b zene a ormal e were found in off-site soil and surface water samples.

Chemical analysis data and sampi loca.j' I e Alewife Center Master Plan Study have been included in Appendi A.

Site Hydrology,- Geolo , Topogr hy

The W.R. Grace Sit is r at' ely level, h a relief of approximately four feet. It appears that s face -off m e southern section of the site enters Jerry's Pond or Par ay Pond igur ). Run-of f from the northern section of the site, near ' dings obably is collected in storm drains along Whittemore nue, o rs Ale ' fe Brook 600 feet north of the site.

Near-surf e ater ver uch of the site flows to the Red Line Tunnel where s p mps re ove he water to Parkway Pond and eventually Alewife Brook . Ar wid gro dwater flow is rather complex and is not well underst . Low ef, iscontinuous clay layers and sand layers of poorly defined exten ontribut to the lack of understanding. In addition, man-made features (tunnel, avi , etc.) and water management practices (lowering of Fresh Pond water le , etc.) Likely affect groundwater flow patterns in the area.

Surficial deposits beneath the site generally consist of 0-23 feet of fine sand overlying a thick (55 to 85 feet) silty clay. It is assumed that most groundwater movement occurs in the overlying sand layer, which is considerably more --permeable than the clay (3).

Receptors

.Likely groundwater and surface runoff receptors include Jerry's Pond, Parkway Pond, Yates Pond and Alewife Brook. These bodies of water are potential or ,42-r6 e/ -/t~ V7 I 9 C-5g3-7-5-59

MEMO TO: DON SMITH JULY 8, 1985 - PAGE FOUR

existing recreational areas for local citizens. Due to the hydrogeologic characteristics of the area, Fresh Pond cannot be ruled out as a potential receptor.

A number of residents in the area have reported unna ral odors in local basements and "seemingly high incidences of eye an skin ' ritations, respiratory problems, cancers and other health problems" ( . Acco ing to the North Cambridge Toxic Alert Coalition, government s onso d soil d groundwater tests revealed the presence of naphthalene at t f rso Park sing Project which is located 1000 feet to the southeast of e te (8). wat in the area isp plied by the Metropolitan Distri u I systems 4%fnrirtUren y no groundwater usag in

Based on the information collected or th pre' inary assessrmn t it [I ecothat a site inspeco f h thisrecmme-nidruan in-du e:

* The existence of unk taminated soils and II groundwater on the site. hazardous sludge may be present. / ii

* The possibility of off-site i o contaminants to critical receptors including Jerry's a c ewife Brook, and local basements. The presence o volatile' :pounds in Parkway Pond has been 1' ) documented. * A hydrolog' conn n the site and the Fresh Pond-Reservoir - may exist, hough th ic and hydrogeologic evidence suggest that the possib ' y is sli

Additionally a &s cr'4cal review of the Haley and Aldrich report "Environm ntal t Keport for the Proposed Alewife Center Develop ent"( Uded in the Site Inspection. If it is determined that the SI annot bd using the analytical data in approprkiafs ialysis program should be undertaken In addition, N ison e Haly a nd /

HC/alh cc: R. DiNitto B. Buckley T. Plant M. Mengel T. Centi

Reviewed and Approved by: Reference

1) USGS, Lexington, MA, 7.5 Minute Topographic Map (1971).

2) USGS, Boston North, MA, 7.5 Minute Topographic Map (1971, photorevised 1979).

3) Haley and Aldrich, Inc. for Hines Industrial, C bri e, MA, "Subsurface and Hydrogeological Conditions for the Alewi Cente Master Plan Study, Cambridge, Massachusetts" April 1985.

4) NUS/FIT Project Logbook, Herb Colby, 85.

5) Massachusetts Department of Enviro en Quality Engineering, "Identification and Preliminary Asses ent . Grace and Company", 1980.

6) Cambridge Historical Corn ssion 77), Surv of Architectural History in Cambridge, Report Five, Nort est m' i e The MIT Press.

7) Pawlowski, Ed, : A E, ing me .ing with Herb Colby, NUS/FIT on May 2,_ 1985. S e N Project book.

8) Letter to Ms e Pryby Office of Public Relations, US EPA, Region 1, from W dy Baruch th ridge Toxic Alert Coalition, Cambridge, MA, ece 84. US IT Project files.

I GOLO8EPG ZOINO& ASSOCIATES. INC

A. 4N'e

SL~t

August 6, 19S5 Rile No. G-1745C rile No. G-1745-601-W-6.l

Sverdrup, Parc:el I Associates. Inc:. 28 Chauncy Street Poston, Massachusetts 0111

At tent i on: Mr . Gene Pekro

Re: Status of Contamination Invest i oat ion

'entIenren:

As of this date, the conplete set of air and water quality results fron the contract laboratory (Canibridge Analytical Associates, CAA) have just become available. This Cata is enclosed herewith for your records and for transnittal to the "T".

Both the air and water sampl es were anal y:ed by gas chr ornat oar aph / rmass spectrometer, GC/MS, miethods for volatile Priority Pollutants, naterials on the Ha:ardous Substances List and other materials known to be present on the Grace Chermical property. In addition, all water sanples were analy:ed fcr pH and conductivity values. In surruar y, On1 y low levels were detected ana thus should not pose a health hazard tc "T" employees as based on applicable current occupational h+alth standaros.

WATER SAMPLES

Si x of the 27 wat +r sarmpl es taken f ron the tunnel or ai nape system

on 6/7/E5 were subnt ittec to CAA for GUME analysis. These

sanples correspond to stations Z:4 - 05N, 217 SON, 317 + 90S, 3? + (OS, ='o + 2O and ::5 - BON and were selected basec on GC screening performed by GZA isee letter dated 7/9/85). A surrary of the data is provideo in the enciosdC taole.

The nmaxiiur" concentrations of the chemicals detected are well

'WC7r ?-r-~ , n,'V S*n I T C7 NM "i~T-11" DOCM En I. Z twpCC, ,CC~cr'c -- "-. ~ -'~l nn Sve-drup, Parcel Associates. Inc. - Auogst- 6, !9e - Faqea

0e Ow the one day health advisory val ues 2 4or dr itW i nC water. As such, occasional so n contact with this water should not result in aoverse health efiects. Of the chemicals detected ttrans-1,:-dichloroethylene, thiobispropane, trichloroethylene, and bentene only thiobispropane was previously found in sianificant concentrations on the Grace property. This material is a mercaptan and as such, could partially account for the "rotten egg" smell in the tunnel.

The pH values for the tunnel drainage samples collected are typically slightly basic. This is as would be expected for water in contact with concrete. The -pH values detected indicate that irritation should not result from occasional skin contact.

While somewhat elevated above typical background values, the conductivity of the samples collection are in accordance with expected values in light of the previous site uses.

AIR SAMPLES

Air samples were collected at 5 points within the tunnel. These correspond to stations 310 + 80, 215 + 00, Mezzanine, 220 * 50, ana 230 + 60. (See GZA letters of 6/20/85 and 7/9/65 for the rationale leading to the selection of these stations.) The "breathing zone" air was sampled continuously at these locations for a period of 3 to 4 hours between 1:00 A.M. and 5:00 A.M. on 6/27/85. This period should result in the highest contaminant concentrations due to the absence of ventilation as forced by train movement. The samples were sub'mitted to CAA for GC/MS analysis. A summary of the data obtained is provided in the enclosed table.

The most prevalent compound detected was toluene. As shown

Those values which have been established by the EPA for specific compounds in drinking water as consistent with safe consumption over a one day period.

2 Health advisory values have not been established for 2,2- thiobispropane. However, this compound is not carcinogenic and, as based on the available toxicological information, it is unlikely that it would result in detrimental health effects due to occasional skin contact. on - tne en::losec table, the thrshol c mi t va; ue, TLV2, for to.aene is 100 pprn. As such, tne con:cntrations in the tunnel are bec the value established as Cnstituting safe working con= I t I ens.

The cOnclusicns drawn herein, as well as the data upon which they are based, reflect the conditions existing in the tunnel at the tine the samples were taken. It should also be reali:e that the tunnel environment reflects a complex interaction between c*:sce grounowater levels, chemical witer/air volatili:ation rates, internal air exchange rates, etc. As such, it is expected thai conditions within the tunnel will vary over tin.e. Therefore, al:nough the sampiing round was designed to take advantage of conc ItIons which promote maximum contaminant concentrations tsamol i ng during a rainy period, no train movement , no mechanical ventilation, etc.), it cannot be concluded that conditions have/will not be worse in the past/future.

ne oata sumnari:eo herein has been providec as an interim submission n I eu of the f:nal report. The previous due date for this re:.rt of 8/5/E5 has been postponed as per our conversation of 7/'i2/e5. Fostponemient has resulted cue to a delay in availability f the GC/MS data fronm CAA. The final report will be forwarded as soon as possible.

Very truly yours,

GOLDBEPG-ZOINO & ASSOCIATES, INC.

Matthew J. Barvenilk Associate

That value for a speci fic compound which has been establ i shec by NIOSH and OSHA as consistent with safe workinc conditions for continuous exposure for S hours/day, I days/weeP. on 4 4 te .~ .jci m. .. e,

C-, L-ZDSZ:C1,a DZ ES.INC,

C June 20, 1985 - -- . File No. G-1745.1-C-1745-601--W-6.1

Sve:drup & Parcel & Associates, Inc. 38 Ctauncey Street Boston, Massachusetts 02111

Attention: Gene Perko

Re: Tunnel Contamination Investigatory Plan

Gentlemen:

As a result of worker health complaints forwarded through the T's operations group, GZA has been contracted by Sverdrup & Parcel (S&P) to investigate the potential sources of contamination, as well as the existence of contamination itself, in- the Alweife Station/Tunnel- Complex.

To date, the following tasks have been completed:

1. The data supplied by the T's cperations personnel, as obtained by Water Chemist Inc., has been reviewed.

2. Previously existing data with respect to contamination on the Grace site, through which the tunnel passes, has been reviewed.

3. The Haley & Aldrich (B&A) report, done on behalf of Grace, has been reviewed.

4. Two site visits have been made to inspected the tunnel during off peak hours. The objective of the first visit was to obtain air samples with direct reading portable equipment. The objective of the second visit was to determine potential leakage paths into the tunnel, potential contamination

THE GEO BUILDING a 320 NEEDHAM STREET @NEWTON UPPER FALLS, MASSACHUSETTS 02164 a (617)969-0050 SJ:OGEPORT C, . BUFFALO NY e VERNON CT . MANC-SSTER NH - PROVIDENCE Ri . TAMPA, FL

Sverdrup & el & Associates, Inc. i le No. G-1745 June 20, 1985 - Pae

sources, and potential sampling sites for both water and air sampilins.

5. GZA had recuested of and received from S&P. a schematic surrary of the drainage paths into the tunnel. This data has been reviewed.

6. GZA has formulated a sampling plan and methodology for investigating potential sources of contamination via both air sampling and water sampling.

Based on the work completed to date, the followina conclusions can be drawn with respect to potential contamination sources in the tunnel.

1. During site visit No. 1, which was executed between 1:00 a.m. and 4:00 a.m. on May 30, 1985, a number of odors were noted. However, based on data obtained from direct reading portable air sampling equipment, no measurable levels of contaminants were found in the air. This indicates that contaminant level are less than 1 ppm for those materials detected by the equipment used (A.I.D. Model 580 Photoionization Detector).

2. Of the four chemicals detected by Water Chemist Inc. (ethyl acetate, MEK, acetone and benzene) it appears that three had been previously stored on the Grace property and recently detected in the groundwater by B&A. The first compound, ethyl acetate, has actually not been stored on the Grace property. However, it is probable that either the methly acetate or vinyl acetate stored on-site was actually detected by Water Chemist Inc. and miss-identified as the more common ethyl acetate (mass. spec. analysis was not used). MER and acetone were both stored at Grace in the proximity of the tunnel. The final compound, benzene, does not appear to have been stored at Grace nor has it appeared in the groundwater samples in any significant concentrations. Therefore, with the exception of benzene, it is likely that the chemicals detected in groundwater samples by Water Chemist Inc. could be attributed to contamination from the Grace site. However, it should also be pointed out that these chemicals are also commonly found in many glues, mastics, concrete treatment formulations, etc. and therefore, could also be attributed to the use of construction materials in the tunnel. It should, onX Svercrup 6 P Associates, Inc. - e No. G-1745 June 20, 1985 - Pace 3

- also be noted that benzene has not been associated with the processes previously used by Grace and is more likely a contaminant due to oil and gasoline spills around the tunnel site. Such spills may have occurred prior to tunnel instalation and also during the actual tunnel construction sucn as ircor sump pumps, chain saws, excavation equipment, etc.

3. Durinc the site visit of June 2, 1985, between 10:00 p.m. and 12:00 p.m., a number of additional potential contamination sour ce s were noted. These are due to standard operaticns within the tunnel as follows: (A) oily slicks were ncted in standing water in the track drainage systems (b) it was noted that creosoted ties were used in the western portion cf the tunnel (c) it was noted that the wheels of the trains undergo greasing operations to reduce noise levels and (d) A number of oily spots were noted on the concerte which potentially could be drippings from standard maintenance on the trains.

4. Review of the drainage data submitted to GZA by S&P indicates that larce areas of the tunnel are drained into a common track drainage system which discharages into two widely separated sumps. As such, introduction of contaminates at widely spaced points along the tunnel alignment, could all be detected at the same location in the tunnel track drainage system.

5. Based on a review of all available data, it appears that the contamination detected by Water Chemist Inc. can potentially be attributed to one, or a combination of four general sources. The first is standard train operations procedures. The second relates to construction of tne tunnel. The third is the Grace Chemical Property. The fourth, which potentially relates to benzene, involves the prior storage of fuel oils, gasoline, etc. on the site during operations before the tunnel was constructed.

Investigatory Plan

The investigatory plan formulated involves both air and water ' sampling. The objective of the air sampling is to determine the potential cause of operations personnel complaints. The objective of the water sampling is to determine potential sources of the air emissions.

GZ\ Sverrup & %cel & Associates, Inc. %le No. G-1745 June 20, 1995 - Pace 4

Air SamrlinO

:t is ar.:tcipate that seven ceneral locations will be utilized for air samping Lsee Tatle III fcr detailed station desicnations). They are as follows:

1. Sanrm'.es will be taken from the tail track area. This is an area identified by "T" operations personnel as having the worst contaminate levels.

2. Samles will be obtained near the previously existing oil tank (approximately station 322) inasmuch as this could be a source of benzene contamination.

3. Samples will be taken near station 316 due to the proximity of the solvent storage area previously operated by Grace.

4. Samples will be taken near station 311 which corresponds to the groundwater passageway. Hydrologic data indicates that contaminates may flow in that direction.

5. Samples will be taken in the station proper for background comparisons.

6. Samples will also be taken in the garage area for background comparisons.

7. Samples will be taken at the Alewife Brook Parkway Rindge .f Avenue traffic light to supply comparatory data.

Samples 1 through 5 will be taken between 3:00 a.m. and 5:00 a.m., in that this is the period when there is no train operations in the tunnel. Hence this corresponds to the worst air contamination levels due to the absences of train driven air dilution. Samples No. 6 and 7 will be taken during rush hour traffic to provide comparatory data with respect to situations ,easily identified with by lay people. At each sample location a minimum of two sorbent tubes will taken. The first is for in-house screening to determine which samples should be sent out for independent laboratory verification and quantification. The second tube will be supplied to the outside lab for testing.

GZ\ Sverdrup . Parc & Associates, Inc. - F No. G-1745 une 20, 1985 - Paae 5

Water Sampling

As previously indicated, water contamination can result from a n'.mber of sources. Three major source areas are 1) leakage into the tunnel through the cutoff walls, 2) leakage into the tunnel throuch the underdrain system, and 3) leakage into the tunnel -ia trains and standard operating practices. All three sources empty into the common interceptor drain system. Therefore, to determine the source areas, numerous, samples are required. The sampling program recommended is broken into three series of samples as follows (see Tables I and II for details). The first series of samples will be taken from the tunnel drainage interceptor system catch basins. These sample's will provide a composit data basis from all sources. The second series of samples will be taken from discreet leakage points along the cutoff wall. This series of samples will supply specific data on the influence of contaminants outside the tunnel. The third series of sampling locations will correspond to those sampled by Water Chemist 'Inc. This data will be us-ed for comparison purposes.

Two samples will taken at each location. The first vial will be analyzed in-house for volatile components via general screening techniques to provide a rapid indication of contamination sources. This data will also be used to determine which samples to send to an outside lab for verification/quantification (this testing requires the second vial).

If it is considered necessary, as based on the data from volatile samples, additional samples will be taken and analyzed for aicd extractable and base neutral compounds. The locations for these samples will also be determined based on the results of the initial sampling round.

Scheduling

It is anticipated the sampling will take place during the beginning of the week of June 24, 1985. Samples will, be immediately processed in GZA's in-house lab to screen for chemical constituents and allow initial assessment of potential contamination sources. on, Sverdrup & Pa el & Associates, Inc. - e No. G-1745 . *June 20, 1965 - Pace 65

It is anticipated that the screening work will be completed by :.y 2, 198 and preliminary results will be availabLe in written form byr uly 5, 1985. Samples will then be sent to independent ou:side at for verificaticn and cuantifaication of the screenina resul:s. :t is emphasize that zased cn conservation with the a-oratcries :r. tse area, -nat turn around time for the results of these sa:qples is likely be cn the order three weeks (July 2, '985 to July 22, 1985.

We hope that the data provided herein meets your current needs. We will keep in contact to informed you of the status of the work and any conclusions tnat car. be drawn during progress of the worrs.

Very truly yours,

GOLDBERG-ZOINO & ASSOCIATES, INC.

Matthew J. Barvenik Associate-in-Charge

MJB: jg Enclosures: Tables

cc: John Powers

onZ S. BUSSELL SYLVA 5 ornenouweaA/' Sena- Commissioner

935-2160 May 24, 1985

MBTA RE: WETLANDS/CAMBRIDGE Ten Park Plaza File #123-19 Boston, MA 02116 Russell Field

Attention: Don Kidston:

The Metropolitan Boston/Northeast Regional Office is writing in response. to your request for an amendment to the Superseding Order of Conditions issued for the above-referenced project file. Specifically, condition #15 of the Department's Order dated March 28, 1980, which states that, "Russell Field shall be restored to the ground elevation existing at the time of filing of the Notice of Intent"... It is the Department's understanding that the 100 year floodplain elevation used at the time of the original filing (approximately 114.4) was based upon a preliminary hydrologic study which was prepared prior to any FEMA studies. In 1982, however, FEMA completed its own final flood analyses and they were thus adopted by the City of Cambridge. Recent concern(s) and recommendations expressed by the City (see letters dated April 17, 1985 and May 2, 1985) have indicated a need for the adjustment in the flood elevation,and subsequent grading at this site,in order to. eliminate the puddling and poor drainage conditions which presently exist and create a field which will drain much more effectively than in the past. After a review of the revised plan submitted (entitled: "Russell Field Restora- tion"/Red Line Extension NW Davis to Alewife; Contract No. 091-512; Dated April 1985; Prepared by: Sverdrup & Parcel and Associates, Inc.), and taking into account the above-mentioned circumstances, it is the Department's opinion that the proposal as submitted is not one which is so significant that it would require a new filing. As specified in the Regulations 10.57(2)(3)..." the floodplain boundary shall be determined by reference to the most recently available flood profile data... administered by the Federal Emergency Management Agency..." Therefore, the Department accepts the MBTA's request for the adjustment of the floodplain elevation and subsequent grading of the site to that determined by FEMA (approximately 113.1), and approves the referenced plan as submitted herewith. Please be reminded that all work shall be in conformance with said plan and completed as such prior to the issuance of a final Certificate of Compliance. TRANSPO ATION AUTHORI3

Ten Park Plaza. Boston. MA 02116

May 10, 1985

Mr. William St. Hillaire, P. E. Regional Environmental Engineer Department of Environmental Quality Engineering Five Connonwealth Avenue Woburn, Massachusetts 01801

Dear Mr. St. Hillaire: SUBJECT: DEQE File No, 123-19 MBTA Contract No. 091-508A Russell Field

We hereby request that Order No. 15 of the above-cited Superseding Order of Conditions be amended.

Order No. 15 reads, in part, "Russell Field shall be restored to the ground elevation existing at the time of filing of the Notice of Intent . . . ." The City of Cambridge has requested that the elevation of the field be altered in order to provide improved surface drainage without pumping.

The attached plan, 091-512 - Russell Field Restoration, April 11, 1985 - Sverdrup & Parcel & Associates, Inc., has been developed in response to the City's request and meets with their concurrence.

Additionally, both the Cambridge Conservation Comnission and City Engineer have reviewed the proposal to alter the elevation of Russell Field, as it relates to Wetlands Protection, and have expressed their support of the proposed change as indicated in the enclosed April 17th and May 2nd letters.

Therefore, the MBTA requests that Condition No. 15 of the above-cited Superseding Order of Conditions be amended to provide for restoration of Russell Field to the ground elevation described in a plan identified as 091-512 - Russell Field Restoration, April 11, 1985, prepared by Sverdrup and Parcel & Associates, Inc. Sincerely,

Donald J. idston Project Manager-Development cc: J. Burns J. E. Powers R. Easler J. Lastovica J. Anthony

1IN I~'I I CITY OF CAMBRIDGE 57 INMAN STREET. CAMBRIDGE. MASSACHUSETTS 02139 . TEL 498-9048

CONSERVATION COMMISSION May 2, 1985

William St. Hiliare DEQE Regional Office Division of Wetlands and Waterways 5 Commonwealth Avenue Woburn, MA 01801 RE: DEQE file no. 123-19 Russell Field Restoration

Dear Mr. St. Hiliare:

This letter is in support of the MBTA request to change the elevation requirement regarding restoration of Russell Field. The project is referenced in the Superseding Orders of Condition issued by DEQE March 26, 1980. 15. "Russell Field shall be restored to the ground elevation existing at the time of filing of t'he Notice of Intent not later than the completion date as established in Contract 091-602 between the City of Cambridge and the MBTA." At this time the MBTA and the City of Cambridge are working toward a final plan for Russell Field to be implemented by the T under Contract 091-602. Through this restoration project the City hopes to achieve a playing field designed to drain more effectively than in the past. This project is new and was not envisioned at the time of the Superseding Orders. - The MIBTA has requested permission to adjust the 100 year flood elevation to the FEMA elevation. The 100 year flood storage calculated for all Alewife T Dlans -to date is consistent with the pre-FEMA elevation so that flood storage provisions, in structures and landscape features can be considered conservative compared to FEMA requirements. We will not readjust the elevation for the remainder of the.MBTA site. The 100 year flood elevation in the original submitted plans was based on a hydrologic study of the Mystic River prepared for the MDC and available before the FEMA study. The FEMA study was adopted by the City in 1982. There is a foot or so difference between the 100 year flood elevation used to calculate flood storage in plans submitted with the Notice of Intent by the MBTA, and the 100 year flood elevation of the FEMA study. If the pre-existing topography of Russell Field were re-created as required, only a few puddling areas would be at the F1MA 100 year elevation or lower whereas much ofrtW itea wold-br--at or below the 100 year flood elevation if the original 100 year elevation were in effect. The adjustment in the 100 year flood elevation, requiring no compensatory storage or pumping, is crucial to the success of the new facility. The design problems of the site and workable solutions have been described to the Commission and as they are understood, we believe the change requested can be granted without detriment to flood storage in the area.

Sincerely,

Dorothy Altman, Chair cc: Don Kidston, MBTA

En-rn IMI CITY OF CAMBRIDGE CAMBRIDGE, MASSACHUSETTS02139

OFFICE OF THE CITY ENGINEER Joan Lastovica P.E. City Engineer

Commorwe lth), of Massachuse* ts Department of Environmental Quality Engineering Division of Wetlands Protection

April 17, 1935

Re: City of Cambridge Russell Field Determination of vI'ood Plain Elevation

TO WMOQ IT MAY CONCFDN:

I am writing to support a request to the Departm3nt of Fnviron- mental Quality Pngineering (C0Eo) from the Massachusetts Sav Transportation Authority (nTA) to issue a Superceding Crder of Conditions allowing use of the flood plain elevation of 7.2 (USGS) in matters relating to the restoration of Russell FielV.

In consideration of the request, please be advised of the following: In accordance with the City of Cambridge Zoning Ordinance 11.70, as of May 13, 1992, a FlooA Plain Overlay Fist:ict Special Permit process has I-een estahlished Ani imnle- mented. The stated purpose of the Special Permit Section 1.71, is 'to preserve the natural flood control characteris-ticz, -nd the flood storage capacity of the flood plain.. .an to provide a nechanism for a comprehensive review of develooment in the FlooA Plain Overlay Pistrict and the design and location of flood water retention systems and their relationship to other surrounding developments."

The evaluation of flood storage capacity is based upon the 200 year flood elevation of 7.2 (USgS) established in 3092 by the Federal Emergency Management Agency (FEMA). The flood elevation reflects the hydrologic and hydraulic analyses of the FLMA consu'tants C.v. "aguire, Inc. and ?.esearch Analysis, Inc. * e

In review of the plan to restore Russell Field for recreational purpose, and consistent with all Flood Plain development projects in this area permitted since enactment of the City Ordinance, it is my interpretation, that based on a 198 topographic map included in the MBTA Contract 091-509, Russe3l Fie~'d was not below the elevation 7.2, except for very localized spot elevations. Therefore, I would accept and approve a grading pla that provides compensatory-storage volumes for those spot elevations, if quantifiable; \and I would advise that the field is not within the 100 year flood plain.

Please contact me if aiditiona3 information is requested.

Very truly yours,

Joan Lastovica City Wngineer

Fnc: Cambridge Zoning Ordinance 11.70 cc: Cambridge r'onservatior Commission Cambridge Planning Roard