For the Alewife Site in Cambridge Appendix

RESPONSE TO THE W.R. GRACE MCP PERMIT APPLICATION FOR THE ALEWIFE SITE IN CAMBRIDGE Prepared on December 20, 1996 for the Alewife Study Group

APPENDIX

A-1 Letter to Mass. DEP Regarding contamination issues on the Cambridge 2/11/96 W. R. Grace Site A-2 Site Sampling Maps 11/95 A-3 EH&E Report on Cambridge W.R.Grace Site 4/23/96 A-4 Notice of Project Change Cambridge Grace Site 1/16/96 A-5 EPA/NUS Corp. Review of Haley & Aldrich Report 9/5/86 A-6 Spengler/Smith Report 2/19/87 A-7 Chemical Contamination of Water: The Case of Acton, MA 6/81 A-8 DEQE Notice of Responsibility for Cambridge Grace Site 2/9/87 A-9 EPA/NUS Corp. Preliminary Assessment of Cambridge Grace Site 7/8/85 A-10 NCSC Letter to the Secretary of Environmental Affairs 1/12/88 A-11 Certificate of the Secretary of Environmental Affairs 1/20/88

B-1 H&A Neighborhood Basement Flooding Study in the 4/88 Cambridge Grace Site Area B-2 DEP's Notice of Audit Findings for the Cambridge Grace Site 9/20/96 B-3 Federal Highway Administration/Massachusetts DPW Report 2/20/87

F-1 Grievance Report 7/30/88 F-2 Grievance Reports 8/25/85, 4/26/89 et al, 7/7/89, 5/23/90, 3/10/94, & 3/10/94

N-I North Cambridge News November/December 1996 N-2 North Cambridge News June 1995

S History of Sulfate & pH Testing and Dialogue 1979-1988 Involving MBTA and Other Agencies

I I

I, "'~* S Ms. Trudy Coxe Massachusetts Department of Environmental Protection 100 Cambridge Street, Room 2000 (Attn: MEPA Unit) Boston, MA 02202

RE: W. R. Grace Co. Remediation Alewife Center Development EOEA #5869 Cambridge, MA 11 February, 1996 Dear Ms. Coxe:

We are writing to bring your attention to community concerns regarding contamination issues relevant to the W.R Grace site in North Cambridge. As North Cambridge residents, homeowners and active members of the community, we have a strong interest in ensuring that any proposed development on this site proceeds only alter all of the contaminated soils, groundwater and sludge issues have been addressed to the community's satisfaction.

In particular, we are concerned that contaminated soils, groundwater and sludge on this site, dating back decades to its extensive use as a chemical manufacturing area for W.R. Grace and its predecessor, have not been properly cleaned up or removed. Further, we are concerned that research regarding this site has not uncovered the answers to several questions involving the contaminated soils and related issues. Without these answers, we feel that proper remediation actions for this site may be problematic. Since this site scored just a few points below Tier I category, in a scoring process that allows considerable discretion, we would like these questions to be answered before placing reliance on the site's scoring. While we are heartened at the news that this remediation project will be the subject of a DEP audit, we want to ensure, either through the audit or via some other mechanism, that the concerns noted below are addressed to the satisfaction of the North Cambridge community.

We have enclosed a variety of supporting documents or sections of supporting documents in the order in which we have referred to them in this letter. The draft PIP, which we have referred to as the PIP, and other documents which exist in book-type formats have not been enclosed. Many of these documents were created as a result of the Cambridge Conservation Commission's attempts to determine the status of waste materials from this site. We understand that these documents should not be reviewed in a vacuum and that it is possible that other documentation exists which we have not been able to locate and that some of the concerns raised in our documents may be fairly innocuous. If so, we ask that you send us copies of relevant documents, or provide us with a description of the documents and where they can be found, and provide an explanation of why you believe any of our concerns may be misplaced.

We are enclosing copies of this letter and the supporting documents, under separate cover, to the LSP and the Cambridge Conservation Commission in the hope that these parties may be able to help our good faith efforts to put these concerns to rest prior to development of the site:

6Icr'cQ Our specific concerns are as follows:

1. Page 4 of the PIP document, prepared in late 1995, states that "All waste materials were removed from the site." However, according to a memo dated 27 September 1983 from MBTA to the Cambridge Conservation Commission, contaminated soil was mixed with clean soil and backfilled on the site. This memo seems to contradict the statement on page 4 of the PIP and again on page 5 that "All wastes disposed of at the site have been removed from the site."

2. The Cambridge Conservation Commission apparently has never received any certificates of proof that the estimated 60,000 cubic yards of material from the site actually went anywhere offsite. The PIP claims that this material, including contaminated or treated soil and sludge, considered a special waste, was removed from the site. When we refer to "sludge", we do so without accurate information on the exact chemical makeup of this material. Such information would be extremely valuable in our efforts to address contamination issues concerning this site. Page 4 of the P tes that "Grace was informed by the MBTA that the stabilized sludge was disposed of in Kingsto RI i the Fall of 1981 and Spring of t S 1982..." This disposal apparently ppened. According t unication from F.L. 1 McGovern, III of the University fRI partent of Safety and Risk Management, no dump sites were open in Kingston after 1979-19 rther, in a July 26, 1983 memo from the MBTA to the Cambridge /a Conservation Commission, the MBTA stated that they were still searching their records for acceptance of treated ae waste by Kingston facility. Accordingly, it seems clear that this waste did not go to Kingsto RI, en though the PIP implies, if not directly stating, that it did. No one knows where the waste w&1Lafid a memo dated II July, 1995 indicates it did not go to Kingston, MA either. The MBTA memo dated 26 July 1983 clearly indicates that the MIBTA still had not received a certification of sludge removal at that time. The 60,000 cubic yard figure used above is a combination of the 50,000 cubic yards discussed in an MBTA memo dated 9 December, 1981 plus an estimated 10,000 cubic yards of solidified sludge at the site (Notice of Intent, August 29, 1980).

3. Page 6 of the PIP contains the Risk Assessment Conclusion but does not take into account new concerns about the dangers of naphthalene. These new concerns, which have led California to classify the chemical as being more dangerous than previously thought and prompted Massachusetts to review its classification, make this RA conclusion inaccurate.

4. Pages 6 through 9 of the PIP indicate that the February 9, 1987's NOR requirements for the prediction of groundflow after construction of the Alewife center were fulfilled. It is not at all clear from the PIP that these groundwater flow predictions were ever recalculated for the current construction proposal. We must emphasize that this current proposal has changed even within the last few months and that roughly half of the new proposal's footprint is completely outside of the footprint for the proposal referred to in the NOR. We believe, therefore, that these predictions must be redone. Additionally, there is very little environmental data, such as test borings or wells, compiled for that section of the current proposal which is outside of the original proposal's footprint.

5. A similar argument as discussed in paragraph 4 exists for the evaluation of the effect of underground utilities on contaminant transport required by the NOR. 6. A similar argument to paragraph 4 exists for the evaluation of the potential for contaminated groundwater to enter residential basements, specifically those on Harvey Street, Clifton Street and Whittimore avenue.

7. We understood the LSP to state, at an advisory Committee meeting conducted by the City of Cambridge on January 11, 1996, that there was no contaminated soil ever stored on Russell Field, but the 27 September 1983 MBTA memo states otherwise. If one considers the contamination of Russell Field, which abuts the site, to be an extension of the site, then possible sources of contamination do not seem to have been located and evaluated as directed in the NOR and as noted on page 6 of the PIP. Because we have received no explanatory record of what occurred at Russell Field concerning the amount and nature of contaminated soil, duration of storage and proof that this soil was ever removed from the Field, we believe that the Field must be considered an identified source of contamination. Additionally, according to a February 9, 1987 memo from DEQE (now DEP) to W.R. Grace, "'Blow- off from the sludge lagoon was evident on the nearby athletic field." We believe that any Tier classification or risk assessment for this area should reflect possible contamination issues at Russell Field unless there is solid proof that no such issues exist.

8. We disagree with the PIP's conclusions, on page 9, that there is no risk to human health or the environment presented by current or proposed development conditions for the following reasons: 1. the LSP did not consider Russell field a possible source of contamination; and, 2. because naphthalene is considered more carcinogous than previously thought. We believe that these two issues' not being mentioned is enough to warrant a rebuttal of these conclusions. A risk assessment dated 25 September, 1989 which discusses the exposure risk to children playing on Russell Field, illustrates the problem with statements concerning risk. No risk assessments have considered Russell Field itself as a possible source of contamination, but, since it has never been found to be clean since being used as a holding' area for contaminated material, the Field must be considered a source of contamination and any risk assessment that does not reflect this fact should not be considered accurate.

9. Question #1 on page three of the draft PIP responses (enclosed) remains unanswered. The response confuses well designation B820-OW with B620-OW, which was not itself a subject of any inquiry. Table VI of September 1991 Longterm Ground Water monitoring report lists all trip blank samples, including B620-OW but not B820-OW, which was a partial subject of this question. B820-OW is not listed as a trip blank nor would one expect it to be so listed given the reported sampling data which were not those one would expect for distilled water. Information regarding the location of this site has yet to be provided.

10. PIP comments and questions from the public were answered in a manner that left many questions and comments unaddressed. We are not sure where the LSP gets the authority to chose which questions to answer and would appreciate clarification on this matter. We understand that individual responses were to be sent out in the beginning of February which may or may not address this concern, but, as of the writing of this letter, we have not received those responses.

I 1. Requests for documentation of the original estimates of hazardous materials from the W.R. Grace site have not yet been fulfilled. In addition, Order 15 (DEQE 123-24) required that "the applicant shall conduct [an approved] testing program prior to refilling the areas from which the sludge is removed." To date, the City Advisory Committee has apparently received no documentation that this order was complied with. A certificate of compliance with this order was recorded in 1988, but we have not been able to find supporting documentation, Further, this certificate should have been issued before the backfilling was allowed to proceed as required by Order 15. Since citizens have not been able to determine how much material was supposed to have been removed nor that the site was properly remediated prior to backfilling, it is virtually impossible to determine that the site was actually cleared of hazardous material, which is an assertion that we are not willing to take on faith.

12. MEPA review should include revisiting the general inconsistencies with reported data, as noted on 12 August 1991 in the March 1991 Groundwater Monitoring Report (page 5). These inconsistencies, which may be due to contaminant migration, hydrological changes, sampling procedures or some other reason, are not completely explained. An order of magnitude increase in Naphthalene concentration observed in B604-OW, directly adjacent to Alewife Brook, seems to contradict the assertion in the subsequent paragraph that "there was no significant offsite migration." Test results in 5% of the boring wells actually indicated at least some offsite presence of naphthalene, further bringing into question the assurances concerning offsite migration.

13. An abutter to the W.R. Grace property, Mr. Edward F. Norberg, operates a well which provides non-ingested water within 500 feet of the W.R. Grace site. Our understanding of the scoring procedure is that such a well would add 15 points to the site's score, bringing it within just 3 points of being Tier I! Mr. Norberg's letter concerning his well is enclosed.

In conclusion, many residents of the area still remember the waste lagoons and chemical operations of W.R Grace on the site. Others recall the noxious fumes that they experienced when the area was disturbed for the Red Line MBTA extension and the piles of material scattered about. Anecdotes are plentiful of cancer victims living near the site, including one street where four out of nine houses had women die of cancer years before their expected life spans. These concerns, combined with the remediation and risk analysis issues we've noted above, should convince the Secretary to conduct an especially close investigation of the remediation procedures for this site and to require MEPA documentation to commence with an Environmental Notification Form rather than proceed via a Notice of Project Change.

If you have any questions or comments concerning this letter, please feel free to contact any of us at the addresses and phone numbers listed below.

Sincerely,

Ciraig A. elley, Esq. /-Joe Jos r Peter Cignetti 6 Saint Gerard Terrace 18 Dudlftreet 5 Theriault Avenue- C- Cambridge, MA 02140 Box 593 Cambridge, MA 02140 617-354-8353 Cambridge, MA 02140 617-491-6314 617-868-5136 cc: Senator Warren Tolman David B. Strubs, Commissioner, Massachusetts DEP Edward J. Weagle, Massachusetts DEP John D. Spengler iACHUSETTS

'ATION

50 mwt Street e5s:0e. Massachusetts 02110

-t Jn- September 27, 1983 NORTHEAST REGIOr; c.abridge Conservation Commission City Hall Annex SEF 2 U3 57 Innan Street Caseridge, Massachusetts 02139 DEPT. Of LNVIRONMEN T L.rrE~'r -- Attention: Ms.urns

Subject: OEQE No. 123-24 MBTA Contract No. 091-508 Red Line Northwest: Harvey to Alewife

Dear Conmissioners:

&Aresponse to Conditions 23 and 25 of the above-cited Order, the 'tering is submitted: 23. As documented in the HSTA's transmittal s of July 26, 1983 and August 25, 1983, all of the sludge, questionable soil and mixtures of soil and sludge in the areas identified in the Cambridge Con- ser-vation Commission's Order of October 11, 1980 were excavated, treated and transported to a sanitary landfill in Kingston, Mass.

Of the disturbed .soi ls containing.napthalene, a portion has been WSWd as backfill for the Red Line Tunnel and a portion Is stockpiled at Russell Field. I .0f the portion used as backfill, a small amount has been placed Alewife area and approximately 6,000 cubic yards have been Vaced on the tunnel west of Davis Square.

ultimate location of the remaining soil , which is approximately .000 cubic yards, is under review. t illil lii I

*,-IVERSTr OF RHODE [SAND

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, V41

Francis L. Mc Govern III, CHCM:CSE Director

FLM:cal Enclosures

rl V."", 'd DFl)EIPARMEN1OF SAIE l'Y AND RISK MANAGlMEN7 WV 1e 500 Alumni Avtnue, Kingston, Rhode Island OZ81-0801 .- A T".raY r e.n7r, Phone: 401-792-2618 Fax. 40 1-7K9-5126 MASSACHUSETTS BAY TRANSPORTATION AUTHORITY

50 Higq Street, Soston, MA 023 10

July 26, 1983

Cambridge Conservation Commission City Hall Annex 57 Inman Street Cambri'dge, Massachusetts 02139 Attention: Ms. Janet Burns

SUBJECT: DEQE No. 123-24 MBTA Contract No. 091-508 Red Line Northwest: Harvey to Alewife

Gentiemen:

In accordance with-Condition Nos. 22 and 24 of the above-cited Order of Conditions, as amended on July 8, 1983, transmitted herewith is certification from the MBTA's Consulting Engineer that the sludge wastes were excavated and treated. We are still searching our records regarding removal of the treated sludge to the Department of Environmental Quality Engineering approved site in Kingston so as to provide the requested certification on sludge removal. As soon as this additional certification becomes available, it will be forwarded to you. Sincerely,

Donald J idston Development Coordinator

DJK:aaf Enclosure cc: W. J. St. Hilaire, DEQE J. E. Powers J. A. Carey E. J. Perko, S&P M. J. Barvenik, GZA A. Daniel Sapir Chairman Kingston Board of Health Ann Frazier 23 GREEN STREET, DRAWER E Vice Chairman KINGSTON. MASSACHUSETTS 02364 Mando Aldrovandi Voics: (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 lodated 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 ~irman p ADS/pib MASSACHUSETTS BAY AJ TRANSPORTATION - AUTHORITY

Red Lne Extension - Northwesz 58 Day Street, W. Somerville, MA 02144 December 9, 1981 RECEIVED RECi>;B

Department of En.ironrnz' Quality Engineering 323 New Boston Street Woburn, Massachusetts 01801

Attention: Mr. Edward J. Pawlowski Senior Sanitary Engineer -n1 Gentlemen: Re: MBTA Contract No. 091-601 Alewife Station/Garage/Tunnel Removlal of Soils East of Alewife Broo'< Parkway In the c nstruction area east of Ale..ife Brook Parkoay in :re Alewife area of Cambridge a large quantity C che:ical sijage was:e from the W.R. Grace plant was solidified and removed from the s!te. with the area backfilled with clean fill. :nderlying this su:;e is a layer of soils into which has leached va-ous chemicals from -he sludge over the years. The MB~A had this -aterial chemically a-'!yze:- by an independent testing laboratory, GCA Corporation of Bedfcrt, ass., and their report is attached for your information and review. The MBTA is presently constructing a station and tunnel through this area and will require the disposal of approximately 25,000 cubic yards of this material with approximately another 25,000 cubic yards of over- burden also to be removed. We are aware that the MassPort Authority is in the process of filling approximately 32 acres of land for their new Marine Terminal Facility and that they are searching for fill material.

This letter is to request your consideration and/or approval to disx'se of the material from the MBTA site in the MassPort Marine Terminal landfifl. V y ly yours,

John A. Carey Project Manager - Construct n JAC/rh Attachment cc: Mr. Thomas Galvin - MassPort Authority Mr. David Malone - Perini Corporation Mr. Chris McDermott Perini Corporation Sludge Solidification As CcCc- MASSACHUSETTS G.L. C. 131 a. 40

NOTICE OF INTENT

All parts of this form and the attached Environmental Data Form shall be completed under the pains and penalties of perjury. Incomplete filings may be rejected.

DATE: August 29,-1980

Conservation Comission of (City/Town): Cambridge

1. Notice is hereby given in accordance with the provisions of Massachusetts C.L. c. 131, s. 40 that the proposed activity described herein is within the jurisdiction of

(City/Town) Cambridge at Alewife Brook Parkway Street

Host recent recording at the Registry of Middlesex County , Book 6634

Page 529

Certificate (if registered)

2. The land on which the work is proposed to be done is owned by:

NAME(s) W. R. Grace & Company ADDRESS 62 Whittemore Ave., Cambridge, MA 02140 3. The Applicant submitting this Notice is: Massachusetts Bay NAME Transportation Authority ADDRESS50 High St., Boston, MA 02110

TVEEONE -

(Optional)The following person is hereby designateu to represent the applicant in matters arising hereunder:

Name Charles B. Steward, Address 50 Hi gh St., Boston, MA 02110 Environmental Coordinator Telephone 722-5005

4. Plans describing and defining the work, included herewith and made a part hereof, are titled and dated:

Sludge Solidification, Notice of Intent Composite Plan, August 29, 1980. hand delivery 5. Identical material has been submitted by er-t-ted-mail-as follows:

Original to Conservation Coission (Date) August 29, 1980

Three copies to appropriate regional office of the Department of Enviromental Quality Engineering (see map for regions and addresses). Date August 29, 1980

Northeast x Southeast Central Western Sludge Solidification

DESCRIPTION OF MODIFICATIONS PROPOSED ON THE SITE

The site now contains approximately 10,000 cubic yards of sludge which is a waste product of W. R. Grace & Company's chemical manufacturing process. In a soil and groundwater sampling program, planned in cooperation with state and federal regulatory agencies, the sludge was found to contain large quantities of organic compounds and the groundwater beneath the sludge was found to contain high concentrations of sulfate and to be acidic in nature.

In order to relieve the site of this unsuitable condition, the Massachu- setts Bay Transportation Authority and W. R. Grace & Company, in a cooperative effort, will undertake a program to solidify and stabilize this material. The solidification process will involve mixing groundwater and chemicals with the sludge to produce an insoluble solid that is chemically and mechanically stable and will not revert to its original form. The end result of the process will be a clay-like inert material.

The solidification process will involve four steps. First, the sludge will be loaded into a Charging Area, a sixty foot by sixty foot area surrounded by a four foot high earth berm. This will serve as a containment area for the sludge prior to processing. Second, the sludge will be loaded into a hopper and conveyed to the Mixing Area where the chemicals and contaminated groundwater will be blended in with the sludge to achieve solidification. Third, the treated sludge, still in containment liquid form, will be transported to the Deposit Area, a series of five cells formed by earth berms. The sludge will remain in the Deposit Area for -approximately 10 days to achieve a clay-like consistency in which it can be easily handled. Fourth, the now dry, solidified sludge will be transported to a tempo- rary storage stockpile prepatory to being either (1) removed from the site or (2) graded on the existing site.

Department of Environmental Quality Engineering letters to the MBTA August 1, 1980 and April 23, 1980 detail their acceptance of the solidification process. These letters are attached. The DEQE has classified "the solidified acid sludge as a special waste subject to 310 CMR 10.16: (1) due to the handling that will be required for the disposal of the waste. This solidified waste can be safely disposed of at a landfill facility, provided that it is not mixed with biodegradeable refuse. As such, it must be isolated in a separate area of the landfill, or on top of closed sections, and covered.

The MBTA is presently negotiating with DEQE recommended landfill sites for acceptance of the solidified waste. However, if the MBTA is..unable to find a landfill that will accept the solidified waste, it will remain on the Grace site. A plan showing final grading including effects on wetlands and/or flood storage will be submitted to the Conservation Commmission.

Attached is material prepared by Solid Tek on the solidification process. A letter from DEQE dated April 23, 1980 is also attached. The approximate time involved for the work will be 90 days. At the completion of the work, the site will become available for use as part of the work area for Massachusetts Bay Transportation Authority Construction Contracts 091- 508A and 091-601. S. RUSSELL SYLVA S nvmmaweat ed-enee Cornmtnoner

935-2160 February 9, 1987

W.R. Grace & Company RE: CAiBRIDGE-W.R. Grace 62 Whittemore Avenue Cambridge, Massachusetts 02140 NOTICE OF RESPONSIBILITY PURSUANT TO M.G.L. CHAPTE& 21E Attention: Mark Stoler DEQE Case No. 3-277

Dear Mr. Stoler:

Site Eistory

According to Raley 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 1S60 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.1. 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 tBTA tunnel across the W.R. Grace property, waste from the .DAXAD process was excavated, stabilized and disposed of off-site in 1981 and 1982. W.R. Grace Page 3.

Previous Site Investigations

(1) A "Memcrandum for the Record" dated June 1, 1970 written by Peter Moleux of the Massachusetts Division of Water Pollution Control (VPC). 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, V.R. Grace's Project Engineer addressing the spill clean-up procedures and stating that the procedure would prevent all of the triethynol diamine (sic), vinsol resin, calcium chloride and talc from getting into the (sewerage) system.

(3) A Goldberg-Zoino-Dunnicliff g Associates report dated December 26, 1978. Their investigation was conducted in conjunction with the constructica 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.F. 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, thea-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. t.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.

-r truly yours,

Richard J. 1pin Deputy Regional Environmental Engineer EPJCINB/ae cc: DEQE/DSEW, One Winter Street - 5th Floor, Boston, MA 02108 ATTN: Madeline Snow Commission of Eealth and Eospitals, 1493 Cambridge Street Room 715, Cambridge, MA 02139 ATTN: Melvin Ealfen, M.D., Commissioner Eines Industrial, University Place, 124 Mount Auburn Street, Cambridge, MA 02138 - ATTN: David Vickery - Cambridge Environmental Inc .. 58 Charles Street Cambridge, Massachuseis 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 M eltinger:

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 107 (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 included 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 -Russell Park is adjacent to the site, so that children are potentially right next to the site. -4-However, 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 vi, with w < I, the average distance horn 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 ihe fraction of time closer to the short edge). Assuming equal probability to be on any part of the 4.

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, soil ingestion, explicitly included increased exposure to children through the age dependerce of assumed soil ingestion rates. Exposure in this case was assumed to be right at the edge ol a contaminated region of diameter 315 m (page A-39 of Addendum A, and the appendix to Addendum A).

If 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. 0 Senior Scientist cc. M. Murphy, DEP M. Skler, W.R. Grace D. Wightman, W.R. Grace

I,.

.0_

Cambridge Environmental !nc_ 58 Charles Street Cambridge. Massachusetts 02141 Ou n/REsnrtes P-orr th Drirr PIP PrroviclW hv JwIn'h J Jcenh nn 19 \N'ov-mber 1995:

Question 1: para. i: "Please prbvide a legible map designating the location of groundwater monitoring well nos. 8820-OW and 8825-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."

K Response: para. i: I The September 1991 Long Term Groundwater Monitoring Report does not refer to well nos. B820-OW and B825-OW. Monitoring wells with these designations do K. not currendy exist, nor have they existed in the past at the site. The sample Sdesivnadons B620-OW and B825-OW referred to in Table VI identify trip blank samples. Trip blank samples are a quality assurance/quality control measure used to confirm the validity of laboratory analyses. Trip blank samples are sample bottles filled in the laboratory with distilled water which are transported to the site. The trip blank bottles remain at the site during the sampling event, and are transported back to the laboratory with the samples collected from the site. The trip blanks are submitted for the same chemical analyses as the actual media samples collected at the site. The trip blanks are given fictitious numbers on the documentation sent to the analytical laboratory so the laboratory won't know they ' a are not actual samples, thereby adding to the quality control. .3 V Question 2: "Please provide a legible map that will show the locadon 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 r shop operations at all sites within the Grace property." La? Response: Figures 3A through 3D of the final PIP have been modified to include the location of known machine shops. The Machine Shop is located in a portion of Building 2 a - and 8. This area is the only area that has been or is currently used as a machine I shop to the best knowledge of W. R. Grace. The history of the machine shop area is beins researched and will be responded to in a separate letter to the respondant.

Question 3: "Pleasc provide a complete history of all uses of Building No. 28." I-. Response: Page4 of the final PIP provide a history of Building 28. Building 28 served as an ~/ ice cream manufacturing plant previous to ownership by Grace. Grace purchased the building between 1942 and 1946. From the date of ownership undl 1973, the L building was used as a research facility for printing blanket and battery separators, which ar: specialty paper products. The building was vacant from 1973 to mid- A 1980, and was at that time converted into a Thermal Measurement Laboratory for the recording of thermal gradients of building components. The building served as Lw a Thermal Measurement Laboratory for approximately five years, and was subsequently used for the long term storage of concrete samples. T'ne date of 1 construction for the building is not known. This information has been incorporated A into the PIP. if 3 I romi 4 Li U ODER O? CONDITIOUS

W E T L A 1 D S PRO TEZCt'I O A C T

G.L.. C. 131, s. 40

*TfCl?_Cambridge, Massachusetts FIIL .ER 123-24 Massachusetts Bay 50 High Street r: bim Tranportator Athority ADDEEss tnra r911n

:RT:YEIID HAIL NU1'dER_____

'ROJECT LOCATION: A2dress W.R. Grace & Company, 62 Whittemore Ave., Cambridge, MA 02140

Recorded at Registry cf Middlesex Count y Boot 6634 , Page 529

Certificate (If registered)

GARDTNG: OticE of Intent dated August 29, 1980

ad plans titled and dadSludge Solidification, Notice of Intent Composite Plan, August 29, 1980 , S ORDER IS ISSUED ON(date) October 1, 1980 ------1 ------Pursuant to the authority of G.L. c. 131, s. 40, the Cambridge C.neyzvion Commission has reviewed your Notice of Intent and plans Ldantlfiezd above, and has deeL-mined that the area on which the proponed work Is to be !one is szit.ificant to one or more of the interests listed in C.L. c. 131, s. 40. The Cambridge Conservation Com-he:eby orders that the following condi ions are tzessary to protect said interests and all work shalt be performed in'strict accordance atth the:: and with the Notice of Intent and plans identified above except where such 1iens arc nodified by said conditions. ------

1. Failure to comply with all conditions stated herein, and with all related statutes and other regulatory measures, shall be deemed cause to revoke or modiiy this order.

2.. .Thitr order does not grant any property rights or any exclusive privileges; it does not authorize any injury to private pro~perty or invasion of private rights.

3. This order does not relieve the permittee or any other person of the necessity of coplying with all other applicable federal, state or local statutes, ordinances, 7-laws and/or regulations.

. The wvrk authorized hereunder shall be completed within one (1) year from the date of this order unless it is for a maintenance dredging project subjecc to Sectiotn 5(9). The order may be exNtended by the issuing authority for one or more additional one-year perioon upcr npplication to'the said iszuing authority at least thirty (30) day prior to the expiration date of the order or its =zeunsion. RDER OF CONM.TIONS CoNTINUtED - 2 . FILE NO. 122-2, 2 ~31

.3, -Ay fIll uSed in connection vich this project shall be clean fill, containing no trash, refuse, rubbish or debris, including, without liziting the generality of the -W fortgoing, luber, bricks, plaster, wire, .l:th, paper, cardboard, pipe, tires, ashes, refricratorgvrocor vahicleo or parts of Pay of the foregoing.

6. Nc work may be cczienccd until all appeal periods have elapsed from the order of The Concervation Co=iizsioan or from a fial order by the Departent of Environmental Quality Engineering.

7. No work shall be undertaken until the final order, with respect to the proposed project, has been recorded in the Registry of Deeds for the district in which the land 1o located within the chain of title of the affced property. The Docu'car tunber indicting such recording shall be submitted on the for at the end of this order to the issuer of this order prior to coutmencement of work.

8. A sign shall be displayed at the site not less that two square feet or more than - three scuare feet bearing the words, "Massachusetts Department of Enviromrental Quality Enginizering. Number -"

9. Where the Department of Envirormental Quality Engineering is requested to make a detc=rnaticn and to izste a superseding order, the Conservation Cctission shall be a party to all agency proceedings and hearings before the Department.

10. Upon.ccmpletion of the work described herein, the applicant shall forthwIth request, in triting, that a Certificate of Compliance be issued stating that the work has been satisfactorily completed. 9The work shall conform to the following described plans an, additional condition:: a. Notice on Intent dated August 29, 1980 as amended at the public hearing on September 23, 1980, by striking the last sentence of paragraph 12 of said Notice and substituting therefore the following sentence: "This material will then be transported to a Department of Environmental Quality Engineering approved site outside the City of Cambridge."

b. Notice of Intent Composite Plan, Sludge Solidification, dated August 29, 1980, prepared for the Massachusetts Bay Transportation Authority. 12. All sludge, including contaminated water and contaminated soil, shown on the Plan referred to in paragraph 11b above designated as "Present Sludge Locations" and shaded on the Plan, as well as ~all sludge in the existing lagoon located south of the. eastern sludge location -shown on said Plan, shall be excavated and-treated 'in accordance with the process described in the report prepared by Solidtek, Inc., dated July 10, 1980 and attached to the Notice of Intent and said material shall be converted to an insoluble, clay-like, stable material that will not revert to its original form, all as described in said Solidtek report;- All said sludge, treated as herein specified, shall be transported to a Department of Environmental Quality Engineering approved site outside the City of Cambridge within one year after the issuance of this Order of Conditions. ORDER OF CONDITIONS CONTINUED -3- FILE NO. 123-24

13. In performing the work described in paragraph 12 hereof, the applicant shall comply with the procedures specified by the Department of Environmental Quality Engineering in a letter dated April 23, 1980, addressed to the applicant and.attached to the Notice of Intent.

14. The areas from which the sludge is removed, pursuant to the Notice of Intent, shall be refilled with suitable ground material immediately after the removal of said sludge, and in any event, within one year after the date of this Order of Conditions.

15. Prior to the commencement of any work hereunder, the applicant shall.prepare and submit to the Conservati-on -Commission, and the. Commission shall have approved, a program for testing the site after the sludge has been removed and before the areas are refilled, to demonstrate that all contaminated material has been removed from the site. The applicant shall conduct said approved testing program prior to refilling the areas from which the sludge is removed.

16. Prior to the commencement of any work hereunder, the applicant shall develop a monitoring program, in consultation with the Water Department of the City of Cambridge, and submit to the Commission, and the Commission shall have approved said program, which program shall assure that the groundwater on the site, which potentially may flow from the site, will not contain any water contaminants. 17: If said monitoring as provided in paragraph 16 indicates that water, which potentially may flow from the site, will contain water contaminants, the applicant shall take such reasonable measures as the Commission may require to ensure that said water will not contain contaminants. 18. The Conservation Commission and its representatives or designees, including representatives of the Water Department of the City of.Cambridge, shall have the right at reasonable times, to enter upon the site for the purpose of ensuring that the conditions specified herein are being complied with and further shall have the right to take such soil and water samples as they may deem necessary to ensure that water,,which potentially may flow from the site, will not contain any contaminants. Ms. Trudy Coxe Massachusetts Department of Environmental Protection 100 Cambridge Street, Room 2000 (Attn.: MEPA Unit) Boston, MA 02202

RE: W. R. Grace Co. Remediation (RTN) 3-0277 (BWSC-107A) Numerical Ranking System Score Sheet (310 CMR 40.1511) (BWSC-1 10) Alewife Center Development EOEA #5869 Cambridge, MA

7 February 1996

Dear Ms. Coxe:

I am writing to you in reference to a 21-E process recently conducted at the W. R. Grace site at 62 Whittemore Avenue in Cambridge (RTN) 3-0277. I have been an abutter to the W. R. Grace property for quite a number of years and have felt that as a neighbor, Grace Co. has been both reasonable and friendly.

Recently though, it has come to my attention that section IV C of an LSP evaluation claimed a score of "0" with respect to private water supplies within 500 feet of the "disposal site." In fact, I do possess an operating well on my property which is located significantly less than 500 feet from the W. R. Grace property. As an agricultural/residential well (non-ingested water), It is my understanding that the LSP should have entered a score of "15."

As this is my property, I want to make sure that any representations regarding it are full and accurate. I would thus appreciate any and all necessary corrections with regard to the LSP's evaluation, particularly as it affects the Tier classification.

Sincerely,

Edward F. Norberg 12 Whittemore Avenue Cambridge, MA 02140

cc: David B. Struhs, Commissioner, Massachusetts DEP Edward J. Weagle, Massachusetts DEP /

Ls..

N r

itri

LZI no

'.Z 0

f z" P1K

_ _-I At,

___ - j-T q, u-Il __7,1

L9t /N t~ft' r Ci ~\ y5 "

Si~ \ Y '- L

- -- -

- L - i \

---1- i -

--1

-N-*1 C JLJ

IDA ,jii

1r --3Dn -~-zCL\ -tdC] -- LJIIiL . II 1 I~U~ r U

-7a1-11.1 T~ ------E*9 990-900t

9 0 lEE---3 0

FINAL DRAFT PUBLIC HEALTH RISK EVALUATION FOR W.R. GRACE SITE IN CAMBRIDGE, MASSACHUSETTS

Prepared For:

Ms. Elizabeth Epstein Deputy Director Community Development Department 57 Inman Street Cambridge, MA 02139

Prepared By:

Environmental Health & Engineering, Inc. 60 Wells Avenue Newton, MA 02159-3210

EH&E Report # 95.415 April 23, 1996

P:\95,41SFINLRPT2.OOC

1.0 EXECUTIVE SUMMARY...... 1 2.0 BACKGROUND ...... _.....4...... 4 3.0 GENERAL FINDINGS...... 7 4.0 RECOMMENDATIONS...... 11 5.0 EVALUATION OF THE SUFFICIENCY AND ADEQUACY OF DATA FROM SOIL AND GROUNDWATER SAMPLES ...... 12 5.1 THE DATA...... 12 5.2 METHODOLOGY ...... 16 5.3 GENERAL FINDINGS ...... 17 6.0 EVALUATION OF THE 1988 AND 1994 HEALTH RISK ASSESSMENTS...... 20 6.1 EXPOSURE SCENARIOS...... 22 6.2 GROUNDWATER...... 23 6.3 SO IL...... ~...... 23 6.4 EXPO SURE G RO UPS ...... - ...... - . -...... 23 6.5 EXPOSURE PATHWAYS...... 24 6.6 EXPOSURE FACTORS...... 24 6.7 TOXICITY VA LUES...... --...... 25 - 6.8 CONCLUSIONS ...... 26 7.0 EVALUATION OF HYDROGEOLOGIC DATA ...... 28 8.0 RELATED ISSUES ...... 31 8.1 TIER CLASSIFICATION...... --...... 31 8.2 HAZARDOUS MATERIALS MANAGEMENT AND REMEDIAL ACTION...... 35 8.3 MBTA TUNNEL ...... -...... - - --...... 36 8.4 RUSSELL FIELD ...... 37 9.0 REFERENCES ...... 39 LIST OF APPENDICES

Appendix A Evaluation of Soil and Groundwater Samples Appendix B Supplemental Information - Soil and Groundwater Data: Spatial and Distributional Displays Appendix C Limitations

LIST OF TABLES

Table 5.1 Compounds included in the Cambridge Environmental Inc. risk assessment and those included in statistical analyses discussed in this report

Table A.1 Compounds included in the Cambridge Environmental Inc. risk assessment and those included in statistical analyses discussed in this report

Table A.2 Percent of differences less than zero for soil duplicate samples

Table A.3 Paired differences analysis for duplicate soil samples

Table A.4 Qualitative evaluation of soil duplicate samples based on detection category

Table A.5 Soil - Comparison of within duplicates and between duplicate variances

Table A.6 Comparison of variation in concentrations between sites and within sites for groundwater well samples-log transformed data

Table A.7 Number of samples, means, and standard deviations for samples with a measurable concentration of the compound for soil and groundwater samples

Table A.8 Comparison of variation in concentrations between sites and within sites for groundwater well samples-untransformed data

Table A.9 Soil samples - Summary of categorization of samples into non-detect, detect (detected, but concentration not .quantified), and measurable (detected and concentration quantified)

Table A.10 Comparison of the distribution of soil concentrations to the MADEP Reporting Standard

Table A.1 Groundwater - Estimated probabilities for three categories non-detect, detect, and measurable for a sampling visit

Table A.12 Comparison of the distribution of groundwater concentrations to the MADEP Reporting Standard Table A.13 Comparison of observed and estimated probability of measuring a .compound at a groundwater well site

LIST OF FIGURES Figure 1 Proposed Building Footprints Figure A.1 Spatial Map and Empirical Distribution Function for Naphthalene in Soil Figure A.2 Spatial Map and Empirical Distribution Function for Formaldehyde in Soil Figure A.3 Spatial Map and Empirical Distribution Function for Naphthalene in Groundwater Figure A.4 Spatial Map and Empirical Distribution Function for Formaldehyde in Groundwater

LIST OF ABBREVIATIONS & ACRONYMS

C02 carbon dioxide EH&E Environmental Health & Engineering, Inc. EPA U.S. Environmental Protection Agency IRIS Integrated Risk Information System MADEP Massachusetts Department of Environmental Protection MCP Massachusetts Contingency Plan MWRA Massachusetts Water Resources Authority NTP National Toxicology Program OHM oil or hazardous materials PAHs polycyclic aromatic hydrocarbons PCBs polychlorinated biphenyls ppb parts of vapor or gas per billion parts of air by volume ppm parts of vapor or gas per million parts of air by volume 1.0 EXECUTIVE SUMMARY

Environmental Health & Engineering, Inc. (EH&E) is pleased to present this summary of our review of public documents and data describing environmental measurements and risk assessments for the W.R. Grace site located at 62 Whittemore Avenue in Cambridge, Massachusetts. The site is a 27-acre, irregularly-shaped parcel of land that is directly east of the Alewife Brook Parkway and Route 2 interchange in Cambridge. Redevelopment of this site to office or retail use as proposed by W.R. Grace, Inc. has been considered. Information considered include reports and data collected by Haley & Aldrich, Inc., consultants to W.R. Grace. Site development is likely to occur in coordination with further remediation of soils contaminated with petroleum products. Details of the soil remediation techniques were not considered but were presumed to be approved by the Massachusetts Department of Environmental Protection (MADEP). Hotel development on the former Liegh Metals site, which now belongs to W.R. Grace, was not considered. Public health issues addressed for this evaluation included potential impacts of airborne compounds generated by excavation and movement of soil during site development, transport of site-related compounds through groundwater and surface water to the site and vicinity, and potential exposures related to the site as it currently exists.

Based in available data there is no reason to consider the W.R. Grace site, as it currently exists, to be a health concern to the neighboring community, which includes residents and recreational users of the Russell Field Facilities. Redevelopment, conducted under proper precautions, should not cause unacceptable health risks from exposures to contaminants present on site. This includes slab-on-grade, as well as below-grade construction. Nevertheless, there are unresolved issues that warrant further investigation. Even if further investigation determines that conditions are other than what has been represented in this and previous assessments, remedial actions are available to safeguard the environment and the community. During construction and remediation on the site, implementation and enforcement of a comprehensive hazardous materials' management plan is required. Public participation in this

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23,1996 Environmental Health & Engineering, Inc., 95.415 Page 1 of 39 management plan should ensure neighbors that all public health risks are thoroughly considered.

The general findings and recommendations of EH&E's review are summarized as follows.

1. Monitoring of groundwater should continue to provide long-term assurance to residents bordering the W.R. Grace site regarding potential changes in the levels of contaminants. The low levels of compounds reported in offsite well 604 near the Alewife Brook do not present a health risk. Results of multi-year monitoring from three wells along Whittemore Avenue indicated that site contaminants have not moved offsite in this northerly direction. However, direct monitoring rather than groundwater modeling can provide the best assurance that contaminants have not migrated toward residential areas.

Groundwater flow may be altered by development, repairs to the MBTA tunnel, variations in surface recharge rates, and other factors. Surveillance of groundwater for evidence of site-related compounds should continue after site development. Selection and use of analytical methods that detect very low levels of contaminants will provide adequate response time to ensure that public health and economic interests are protected.

2. Questions remain regarding how fast and in what directions the groundwater is moving. Quantifying the groundwater transport of site-related contaminants is uncertain based on current assessments. Modeling groundwater flow at this site is complicated by the MBTA tunnels and lack of hydrogeologic information east of the tunnel toward Clifton Street. Additional hydrogeological data and analysis is required. While groundwater movement toward Clifton Street is not expected, we could not confirm this based on the information provided. Some Clifton Street residents attest that basement flooding has occurred more frequently since the MBTA tunnel was built. Additional data (groundwater elevations, permeability) collected east of the MBTA tunnel, along with measurements taken from existing wells, will determine with more certainty direction and speed of hydrogeologic

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23. 1996 Environmental Health & Engineering, Inc., 95.415 Page 2 of 39 pressure driven groundwater flow. Following a review, recommendations about the extent and frequency of continued mohitoring of groundwater could be reconsidered.

3. EH&E is satisfied that the chemical compounds identified on the site currently do not and will not (with anticipated construction and future site use) constitute a risk to public health. The risk assessments conducted for this site used conservative methods to examine both the cancer and non-cancer risks and determined them to be below levels of concern established by the MADEP. Groundwater monitoring at the site boundary, the planned soil remediation, and the mitigation of construction impacts will further ensure that risks are maintained at acceptably low levels.

4. MADEP audit of the Tier Classification of the site is underway. A change in classification from the current 11to a IA, lB, or IC would require varying degrees of State oversight or permitting. At a minimum, the State should review and approve soil remediation activities.

Although the issue concerning the storage of contaminated soil on Russell Field is only marginally related to the proposed development, the city (and/or MBTA) should resolve the remaining uncertainties. This may include sampling of surface or subsurface soils, groundwater, or providing verification from manifest records that contaminated soils were handled appropriately.

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23,1996 Environmental Health & Engineering, Inc., 95.415 Page 3 of 39 2.0 BACKGROUND

The primary health concerns of the City of Cambridge regarding the proposed development of the W.R. Grace site are based on its former use for chemical manufacturing and the compounds that remain on site as a result of these previous manufacturing activities. (See Figure 1) The site is currently listed with MADEP based on 1984 and 1985 evaluations of subsurface and hydrogeological conditions that indicated the presence of volatile and semi-volatile organic compounds, petroleum products, and metals.

The Dewey and Almy Chemical Company developed the site in 1919 for the manufacture of rubber products used for sealing compounds, drum and pail cover gaskets, and bottle cap gaskets. One of the major products manufactured on site was naphthalene sulfonate (trade name DAXAD), a compound used to facilitate the dispersion of rubber in water. During the period of DAXAD manufacture, several lagoons on the site were used for settling ponds and sources of cooling water. This activity is the presumed major source for the continued presence of naphthalene in soils ) at the site. Evaluation of the map of the storage areas (Haley & Aldrich 1995) indicates storage of a number of chemical compounds, as well as fuel oils, on the site during the Dewey and Almy operations. Based on the 1988 health risk assessment by Meta Systems, Inc. and a 1994 update by the same company now named Cambridge Environmental, Inc., the compounds detected on site at levels that pose potential health concerns are naphthalene, formaldehyde, fluorene, and several petroleum-based compounds.

EH&E's evaluation of the history and extensive database associated with this site, which was purchased by W.R. Grace in the early 1940s, involved several broad categories of activities.

Evaluation of the sufficiency and adequacy of measurement data collected by Haley & Aldrich' at the W.R. Grace site.

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 4 of 39 Figure 1 Proposed building footprints overlaid on previous Dewey and Almy Building/use locations

Proposed Building Footprints Overlaid on Previous art Dewey and Almy Building/Use Locations

+ I IL!1 a -N- - __~ 7

/ ".0

This map is an approximation of the actual building locations., 1Proposed building locations shown ameas of December 1995. oAf!~~i~I~1'iZ 0

Public Health Risk Evaluation ror W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering. Inc., 95.415 Page 5 of 39 " Evaluation of the 1988 health risk assessment and its 1994 update. e Evaluation of the groundwater model and the potential for transport of site-related compounds to neighboring properties.

- Evaluation of the hazardous materials management plan.

- Communication with representatives from the City of Cambridge, the community, and the Grace Site Advisory Committee regarding the potential health impacts related to current and future conditions at the site.

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 6 of 39 3.0 GENERAL FINDINGS -

Extensive sampling of soil and groundwater was performed between 1984 and 1988 in anticipation of development plans for the site proposed in the late 1980s. Soil and water samples were analyzed for more than 125 analytes, including volatile organic compounds (VOCs), pesticides, polycyclic aromatic hydrocarbons (PAHs), metals, and polychlorinated biphenyls (PCBs) among others. The data set provided to EH&E had 78 compounds listed as well as total cyanide, total sulfates, total phenol, and grease/oil. According to Haley & Aldrich, the remaining 47 compounds were never detected in any of the samples.

Sixteen of the compounds or metals tested in the soil exceeded reporting levels established by MADEP. Eighteen compounds or metals tested in the groundwater were at concentrations above the MADEP-required reporting levels. The MADEP reporting levels, used here simply as a reference, apply to soils and water at residential sites or sites with unrestricted access. All of these compounds exceeding the stricter reporting levels were included in the 1988 risk assessment. These compounds, plus oil, grease, petroleum hydrocarbons in the soil, and formaldehyde and phenanthrene in the water, were examined statistically. Haley & Aldrich, Cambridge Environmental, Inc., W.R. Grace, and City employees were cooperative in providing us prompt access to data and documents as well as candid responses to our inquiries. The following are EH&E's general findings in support of the recommendations.

1. Considering that the proposed soil remediation and additional boundary line well monitoring takes place, EH&E does not foresee health impacts resulting from contaminants that originated from former industrial use of the site.

2. Data from soil samples, including the duplicates, suggest that the selected analytic methods were adequate to discriminate differences in concentrations between sampling locations and variations attributable to laboratory and sampling procedures. Evaluation of all soil sample duplicates, although limited in number, supports this conclusion.

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 7 of 39 3. Soil samples in the area of the proposed supermarket and parking lot show that contaminants are not uniformly distributed. Based on the distribution patterns, the locations identified for further remediation are apparent and those locations should be addressed during construction.

4. Soils in the vicinity of the proposed retail development on the eastern side of the parcel have not been surveyed as thoroughly as the rest of the site. While additional samples would be useful, we do not think they are absolutely necessary. Review of site plans and facility history suggests that chemicals were not stored, used, or deposited on this area. Oversight during construction should identify deposits of oil, grease, naphthalene, and perhaps other odorous compounds, if they exist. Only petroleum hydrocarbons appeared somewhat elevated in this area. The risk assessment anticipated a more extensive disruption of soils from the area where chemicals and fuels were stored and used than currently proposed. However, the exposure scenarios used conservative methods to estimate assumed activities onsite and dispersion of materials offsite independent of a specific location. Therefore, results of the risk assessment would apply to the development of a sub-parcel on the eastern side of site, provided contaminants in the disturbed soils were similar to those reported.

5. Between 1984 and the present, 44 monitoring wells were drilled in and around the W.R. Grace property. Information about groundwater elevations and bulk water samples were collected from these sites. There were too few well and surface water duplicate samples to draw conclusions about the analytic precision of these samples. Confidence in the well water methods was assessed by examining variability for those wells over time. Greater variability in concentrations across the property suggests that some wells were located in areas of higher concentrations, which was the intent. Furthermore, the monitoring methods were specific and sensitive enough to identify movement of contaminants offsite. This observation, if substantiated, is at variance with the speed of groundwater transport described in the model. It implies that

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 8 of 39 downgradient movement of contaminants might continue and warrant continued monitoring.

Nine monitoring wells were selected by Haley & Aldrich for trends monitoring: three were located along Whittemore Avenue to the north of the property, two wells were along the western border, three wells were near the eastern MBTA entrance and in the vicinity of known naphthalene deposits, and one well was across the road west of the property near Alewife Brook. Measurable concentrations of naphthalene were reported at the offsite well, which, from a hydrogeological perspective, indicates that naphthalene is moving from the site toward the Alewife Brook. While in absolute terms the concentrations were low (below MADEP-reporting values), they suggest that site-related contaminants are moving offsite.

6. The groundwater model was not sufficiently described or documented in reports to substantiate the claims that, "the simulated existing groundwater conditions reasonably reflected measured existing groundwater conditions."

Uncertainties about the recharge rate of water from the surface and the influence of the MBTA tunnel and portals need to be resolved before specific inferences can be derived from the current analysis. Changes in site development plans reduces the usefulness of the simplified hydrogeological model used.

The rates at which contaminants were moving offsite can be inferred either from the modeling or the measurements. At this time we have greater confidence that materials have not left the site on the northem boundary (Whittemore Avenue), but this can not be said about the other directions because no direct evidence exists.

7. Overall, we found the risk assessment to be reasonable and conservative. Estimated health risks were below 1 in 100,000 for cancer and below the reference dose or concentration guidelines. Even assuming naphthalene as a possible human carcinogen and summing the impacts of all the PAHs, the likely

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 9 of 39 risk to workers and neighbors would be small and within acceptable guidelines. The risk assessment considered below grade excavation of soils. When considering that some of the soil with higher amounts of petroleum hydrocarbons to other contaminants will be remediated before construction, risk would be further reduced.

8. The MBTA tunnel is affecting groundwater flow; it is likely that some site contaminants enter the tunnel. Air and water emissions from MBTA facilities at Alewife do not pose health hazards to neighborhoods or future users of the site.

9. Questions related to storage of contaminated soil at Russell Field are separate from the issues specifically related to development of the W.R. Grace site. If modeling or monitoring indicate that groundwater is moving under Russell Field in the direction of homes on Clifton Street, then it would be another matter. Staged groundwater and possible soil tests are recommended to help resolve this issue.

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 10 of 39 4.0 RECOMMENDATIONS

1. Groundwater well monitonng should continue in order to provide long-term protection of residents bordering the W.R. Grace site regarding possible changes in the concentrations of contaminants in the groundwater. Well B204 and at least two additional wells east of the MBTA tunnel should be included along with the nine previously established wells. Composite samples might be screened for the presence of potential site-related compounds as a less expensive strategy that provides greater spatial coverage.

2. A groundwater model reflecting the proposed development, drainage into the MBTA tunnel, and additional hydrogeological data is required to establish the rate, direction, and variations in flow. As an alternative approach, existing hydrogeological and chemical data along with additional permeability information could be used to assess groundwater flow. Following independent review of the results by a party selected by the City of Cambridge, the recommendation for expanded monitoring of groundwater contaminants could be reconsidered.

3. MADEP audit of the Tier Classification of the site is underway. A change in classification may require additional oversight by the State of Massachusetts. If the current Class 11is changed to.lA, IB, or IC, at a minimum, the MADEP should review and approve soil remediation activities.

4. While the issue of storage of contaminated soil on Russell Field is only marginally related to the proposed development, the city (and/or MBTA) should resolve the remaining uncertainties. This may include sampling of surface soils or providing verification of manifest records.

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 11 of 39 5.0 EVALUATION OF THE - SUFFICIENCY AND ADEQUACY OF DATA FROM SOIL AND GROUNDWATER SAMPLES

This evaluation examined the patterns of chemical concentration measurements in soil and groundwater samples at the W.R. Grace site in Cambridge, Massachusetts. Specifically, EH&E has:

1. Examined the consistency of the data between samples and their duplicates 2. Summarized concentrations in relation to MADEP soil and groundwater standards 3. Mapped the spatial pattern of chemical concentrations on the site

5.1 THE DATA

The soil samples' data set contains the results of soil analyses collected mainly in 1986 and 1987 with a few preliminary samples from 1984 and 1985. There were 127 sites sampled in and around the W.R. Grace property. Each site was sampled only once, except for the collection of duplicates. However, many of the collected samples were fairly close to others Collected at different times.

Groundwater samples were taken from 44 wells in and around the W.R. Grace property from 1984 to 1988 with the bulk of the samples taken in 1986 and 1987. From these wells, 29 were sampled two to four times during this time period. Sampling of nine wells continued through 1994 and each of these was sampled 10 and 15 times. The data set corresponding to the samples collected between 1990 and 1994 was not integrated into the main database. Instead, the data from these nine wells are discussed separately.

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 12 of 39 groundwater samples collected between 1990 and 1994 were analyzed for VOCs and naphthalehe only. A subset of these compounds found in the data files were selected for the statistical analysis described here. A further description of the methods for choosing the compounds for analysis is given in Section A.3 of Appendix A.

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23. 1996 Environmental Health & Engineering, Inc., 95.415 Page 13 of 39 Table 5.1 Compounds included in the Cambridge Environmental, Inc. risk assessment and those included in statistical analyses discussed in this report

Soil analysis Groundwater Compound Risk Duplicate Distribution Duplicate and assessment distribution 1,1,1 -trichloroethane 1 1,1-dichloroethene 1 1 1,2-dichloropropane 1 2,4-dimethylphenol 1 2-butanone 1 2-hexanone 1 4-methyl-2-pentanone 1 1 Acenaphthene 1 2 Acenaphthylene 1 Acetone 1 1 Anthracene 1 Antimony 1 Arsenic 1 1 2 Barium 1 2 Benzene 1 1 Benzo (a) anthracene 1 1 1 1 Benzo (a) pyrene 1 1 1 1 Benzo (b,k) fluoranthene 1 1 1 1 Benzo (ghi) perylene 1 2 1 Beryllium 1 1 Bis (2-ethylhexyl) phthalate 1 1 Butyl benzyl phthalate 1 Cadmium i 1 1 Carbon disulfide 1 Carbon tetrachloride 1 Chlorobenzene 1 Chromium 1 1- Chrysene 1 1 1 Copper 1 Di-n-butyl phthalate 1 Di-n-octyl phthalate i Dibenzo (a,h) anthracene 1 1 1 Diethyl phthalate 1 2 1 Ethylbenzene 1 Fluoranthene 1 1

Blank means not used, 1 means included in analysis, and 2 indicates compounds less than reporting limits, but larger than half the reporting limits.

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 14 of 39 Table 5.1 Continued

Soil analysis Groundwater Compound Risk Duplicate Distribution Duplicate and assessment distribution Fluorene 1 Formaldehyde 1 1 1 1 Indeno (1,2,3-cd) pyrene 1 1 1 Iron 1 Lead 1 1 1 1 Mercury 1 1 1 Methylene chloride 1 1 1 n-Nitrosodiphenylamine 1 Naphthalene 1 1 1 1 Nickel i 1 1 1 Oil and grease 1 1 p-Chloro-m-cresol i Pentachlorophenol 1 Petroleum hydrocarbons 1 1 Phenanthrene 2 1 Phenol 1 Pyrene 1 1 Selenium 1 1 Silver i 0i Styrene 1 Tetrachloroethene I Toluene 1 1 Total Cyanide 1 Total Xylenes I Trichloroethene 1 1 Vinyl Acetate 1 Zinc 1 1 1 1

Blank means not used, 1 means included in analysis, and 2 indicates compounds less than reporting limits, but larger than half the reporting limits.

Results of a sample's lab analysis can be placed in four categories:

1. Not available - compounds not analyzed for the sample.

2. Not detected - sample analyzed for compound, but value was below detection limits.

3. Detected, but not quantified - sample analyzed and compound detected, but not in amounts that can be reliably measured.

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 15 of 39 4. Detected and quantified - sample analyzed and compound detected in amounts that could be reliably measured.

The last three categories separate samples on the basis of the qualitative description of the presence of a compound at a site. Let these categories be represented by the sets A (absent), D (detected), and M (measurable), respectively. The response for samples that fall in the first two categories are non-numeric, but tell us a great deal about the concentration levels of a compound at a site.

5.2 METHODOLOGY

We were interested in determining the reliability of the monitoring data. A comprehensive evaluation would have included a review of laboratory records and chain of custody documentation for the samples. This could not be done because of time and expense involved and due to the fact that many of the samples were analyzed by laboratories no longer in existence. Therefore, we proceeded to examine the statistical behavior of the data.

Duplicate soil and water samples can be used to determine the precision of sampling and analysis methods. A small difference between the reported values of duplicate samples relative to the overall mean concentrations provides confidence that the methods are capable of detecting larger differences across sites and across time. Unfortunately, these analyses can not answer the question of accuracy. Displaying the distribution of concentrations can be used to compare reported values to expected distributional patterns. Plotting data spatially and examining the concentration patterns with knowledge about historic operations, chemical use, fuel storage, spills, settling ponds, and likely groundwater movement can also be useful. These techniques, along with trends analyses of samples collected over time, provide a sense that the sampling and analyses were comprehensive and provide a reasonable database for risk assessment.

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 16 of 39 5.3 GENERAL FINDINGS

A comprehensive description of the statistical analysis is included in Appendix A. The following is a summary of the general findings.

* The methods used both for field sampling and laboratory analyses are standard.

* The number of analytes evaluated is a comprehensive list that includes pesticides, PCBs, metals, and numerous other organic and inorganic compounds. Of the 125 analytes, only 78 were detected at least once at quantifiable levels. The other 47 were never detected. MADEP established reporting levels for soil, water, and air contamination. Using the most conservative MADEP reporting guidelines set for residential property use, there were 16 compounds or metals in the soil exceeding those levels. Eighteen compounds or metals tested in the groundwater were at concentrations above the MADEP-required reporting levels.

* Our analyses also included these compounds plus oil, grease, and petroleum hydrocarbons in the soil and formaldehyde and phenanthrene in the water.

* For the compounds found in the soil with a sufficient number of duplicates, the precision was 30% or better. The spatial differences between sites were substantially greater than 30%, so spots with higher concentrations are readily identified. This is important in order to have confidence that further soil remediation will be effective in removing soils with the higher concentrations.

* There were a few soil test pits dug in the area of the commercial/retail site proposed for the eastern side of the property. Only petroleum hydrocarbons were found in these samples. This is reasonable, based on historic use of the site.

* The higher concentrations of soil contaminants were reported for subsurface instead of surface samples.

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 17 of 39 * Unfortunately, there were not a sufficient number of groundwater duplicate samples to draw firr conclusions about precision. As. an alternative, the multiple measurements collected at a well were used to calculate the within well variability. By comparing statistical variance of repeated measurements at a well to the variance obtained by contrasting concentrations reported for different wells, a degree of reliability for the overall analytical performande was obtained. We reached the conclusion that, because across well variance greatly exceeded the within-well variance, well data could be interpreted to show trends and spatial differences.

* Based on the above reasoning and examination of the data, we see groundwater contaminants in higher concentrations onsite in locations that reflect historic use.

* Except for small amounts of a few VOCs found in well water samples collected more than ten years ago, there is no contemporary evidence that site-related contaminants have moved offsite in the direction of Whittemore Avenue.

* The same can not be said about well 604 between the Parkway and Alewife Brook. Samples containing naphthalene suggest that site contaminants have or are being transported via groundwater. These values do not constitute a health risk. First, they are found in the groundwater at low levels and second, water and sediment samples found no trace of site-related contaminants.

* Because there is very limited data available for groundwater or soils east of the MBTA tunnel, we were unable to formulate findings relevant to the Clifton Street neighborhood.

* Haley & Aldrich prepared responses to comments and recommendations raised in our previous review in 1987. While Haley & Aldrich provided maps showing sewer and utility connections, there were no additional sampling data in response to the original concern. The plan to analyze samples along existing or historic sewer and utility lines during excavations and only from within the building footprint is not fully responsive to the original concerns. The point of the original comment relates to the possibility that contaminants could be leaving site by traveling both within and

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 18 of 39 adjacent to sewer and utility lines. It is our understanding that the MWRA has upgraded sewer and storrh drains along sections of Whittemore Avenue since 1987. The City should examine construction records to determine the reported condition of the previous-system and to establish the extent of repairs/replacement. Further, the location of all the groundwater wells along Whittemore Avenue should be determined with respect to their proximity to sewer and utility lines. If, as we suggested, groundwater monitoring is continued, an alternative set of wells may be more appropriate to safeguard the community.

Appendix A contains a more detailed evaluation of data. We have also included in Appendices A and B graphical presentations of the soil and groundwater well data. Concentrations are shown graphically as cumulative distributions. The reader should note that only values at quantified concentrations are included. Table A.9 shows in the last column the fraction of total samples that had measurable quantities. Table A. 11 provides similar information for groundwater. It is from these fractions that the empirical or cumulative distributions were drawn. Where applicable, vertical lines are drawn on the empirical distribution graphs to indicate values used in the risk analyses (RA) and as the MADEP SI reporting level.

Appendix B provides spatial maps and empirical distribution functions for selected contaminants found in soil and groundwater samples.

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 19 of 39 6.0 EVALUATION OF THE 1988 AND 1994 HEALTH RISK ASSESSMENTS

EH&E evaluated the appropriateness of the data and risk assessment methods used by Meta Systems, Inc. in their 1988 health risk assessment for the W.R. Grace site and a 1994 update by the same company, now named Cambridge Environmental, Inc. Since 1994, new development plans for this site have been presented and some new toxicological information regarding a few key compounds found on the site have been presented by MADEP and the U.S. Environmental Protection Agency (EPA). Therefore, the present analysis also evaluated the sufficiency of the original risk analysis calculations in light of recent changes in exposure methods, toxicological data, and planned development.

During the course of this review, a number of questions or points of clarification were raised. To address these questions and issues, Dr. Hal0k Ozkaynak of EH&E met with Dr. Edmund Crouch, the scientist at Cambridge Environmental, Inc. who was responsible for the risk assessment performed for the W.R. Grace site. Many technical issues were resolved and an electronic file copy of the available onsite -environmental and meteorological data used in the risk assessment was obtained.

In addition to a technical review of the risk assessment documents, we wanted to be responsive to citizens' concerns that were expressed during meetings with the Grace Site Advisory Committee regarding the potential toxicity of onsite contaminants. One such concern was the toxicity of naphthalene. Naphthalene is a white solid that evaporates easily and is found in several consumer products, including moth balls, moth flakes, and toilet deodorant blocks (ATSDR 1995). Fossil fuels, such as petroleum and coal, contain naphthalene and burning tobacco and wood can release naphthalene into the air. Naphthalene has a strong, distinctive odor that individuals can detect in the air at concentrations as low as 85 parts per billion (ppb). Once released into the air, moisture and sunlight can break down naphthalene within a day. MADEP currently lists an allowable ambient level (24-hour exposure) and threshold effects limit (annual average) of 2.72 ppb for naphthalene in outdoor air.

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc.. 95.415 Page 20 of 39 SNaphthalene binds weakly to soils and, as a result, it Can pass through sandy soils and reach groundwater. This groundwater can then flow into other areas along its flow patterns. However, microorganisms in healthy soils can help break down naphthalene into carbon dioxide (CO 2), thus reducing the amounts of naphthalene that enter groundwater supplies.

The EPA currently categorizes naphthalene in Class D, which indicates that it is not classifiable as to human carcinogenicity due to inadequate evidence. In an October 1995 draft report, the MADEP proposed a relative potency factor for naphthalene based on some recent evidence that inhaled naphthalene produced cancer in animals. Data from a 1992 National Toxicology Program (NTP) report indicated an increased tumor incidence in female mice that inhaled 30 parts per million (ppm) of naphthalene for two years (NTP 1992).

These issues were also discussed with Dr. Crouch, who was very familiar with NTP studies and their extrapolation to human populations. Further information on the most recent listing and carcinogenic potency value of this compound was solicited from Dr. Lauren Zeiss at the California Department of Health Services. In addition, an online toxicity profile search was performed using the EPA's Integrated Risk Information System (IRIS).

Finally, a limited re-analysis of the site-specific data using alternative (e.g., air quality dispersion) modeling techniques and exposure or chemical toxicity values was conducted to determine how sensitive the results of original risk analysis were to modifications to exposures or potency values.

We have organized our findings under several categories.

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 21 of 39 6.1 EXPOSURE SCENARIOS

1. The potential human exposures considered in the risk assessment included inhalation of dust and vapors both onsite -and- offsite, ingestion of soil, and groundwater seepage into basements. It should be recognized that these exposures are hypothetical and were most often designed to represent extreme conditions so that the maximal levels of risk could be assessed. The expectation is that actual health risks are substantially below these values.

2. Emissions or volatilization of VOCs from soil have been modeled using conservative assumptions that are consistent with upper bound estimates.

3. The pollution dispersion model (AVR) did not use site-specific meteorology, but assumed uniform winds in all directions. When we used representative meteorology and a recent EPA model (ISCLT), we could demonstrate that the techniques used by Dr. Crouch were quite conservative. The impacts predicted by Dr. Crouch were about ten times greater than using current models and actual Boston meteorology.

4. Excavation, soil storage, and windblown dust impacts have been modeled using reasonable physical models. Emission rates of soil-related contaminants had to be assumed (estimated). Recently, EPA has developed models of fugitive dust generated during construction. The emission rates estimated for W.R. Grace site development should be compared to those derived from the EPA methods. The analysis performed for workers incorporated conservative exposure assumptions and selected high soil concentrations. However, if the basic emission factor currently used by the EPA would result in risk and methodology estimates increasing by a factor of five or more, then previous risk assessments should be reconsidered.

The risk assessments reviewed did not address impacts of particulate emissions resulting from trucking activities over paved or unpaved surfaces. This may not be an important shortcoming, depending on truck routes and construction site dust suppression practice. Proper dust suppression practices during the course of construction should minimize potential dust exposures.

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 22 of 39 6.2 GROUNDWATER

1. An ingestion route was not considered in the risk assessment because groundwater will not be used as drinking water. In addition, dermal contact with surface water was not considered.

2. Inhalation of naphthalene originating from the groundwater was considered inside homes. The risk assessment assumed that the highest concentrations of naphthalene would be present in groundwater that intruded into basements. This was obviously a very conservative approach, because the highest levels were reported only in water samples from wells that were several hundred meters from the nearest home.

6.3 SOIL

The updated risk assessment estimated the risk to visitors who might ingest small quantities of soil/dust from the site. All values (detect and non-detect) were averaged together to estimate risks. This is a reasonable approach, particularly when considering additional remediation of soils that will take place. Although an upper 95th percentile value of the arithmetic mean could have been used, this factor should not appreciably change the conclusions.

6.4 EXPOSURE GROUPS

Exposure scenarios for most of the critical groups (e.g., neighborhood residents, construction workers, office workers, and transient visitors) have been addressed in the risk assessment. Trespassers during the construction were not considered in the risk analysis. Also, children and adult shopper scenarios might be examined by different age groups because assumptions about ingestion, length of visit, etc. would result in different estimates. This refinement could be addressed without extensive re-analysis or simply addressed by scaling potential impact that might result from using default inhalation and ingestion values and contaminant levels before and after soil remediation.

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 23 of 39 6.5 EXPOSURE PATHWAYS

Inhalation, soil ingestion, and dermal absorption pathways have all been considered as the primary routes of exposure. However, small exposures might occur due to ingestion of homegrown fruits and vegetables that may be contaminated by deposition of dusts from the site or absorption of groundwater transported offsite. In the unlikely event that contaminants intruded into basements, dermal contact could occur if building occupants touched the water. Similarly, dermal or ingestion uptake might occur if populations come in contact with contaminated surface water. However, although the data are limited, they do not suggest that these pathways would contribute substantially to human health risks.

We mention these omitted pathways for completion. If the risk assessment were to be updated, we encourage the qualitative discussion of these other pathways that present an upper bound to the relative importance. W.R. Grace has stated that during construction, chemical analyses of landscape soil around Jerry's Pond will be conducted. At this time, additional surface and sediment samples might be required by MADEP. Continued trends monitoring of groundwater wells along Whittemore Avenue will provide advanced indications that contaminants may be leaving the site.

6.6 EXPOSURE FACTORS

Risk assessments of this type have to make assumptions about the frequency and duration of dermal contact, inhalation, and ingestion. While the assumptions used appear quite reasonable, suggested current EPA default values, in some cases, are actually higher. It is quite easy to scale the risk since it will be proportional to the amount ingested or the time of dermal contact and assumed proportion absorbed. Using higher values will obviously increase the estimated risk.

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 24 of 39 6.7 TOXICITY VALUES

The risk assessment used published potency and reference dose values. We find no fault in the application of these values. However, since the first risk assessment in the 1980s, new information has been published on naphthalene. Also, MADEP has drafted guidelines for assessing the several PAH compounds that do not have established cancer potency values. In light of these developments, we have sought clarification about naphthalene and other PAHs.

According to EPA (IRIS) and the State of California, naphthalene is still not classified as a human carcinogen. However, in a review of the EPA/IRIS database in March 1996, the description of naphthalene includes the following note:

NOTE ADDED IN JULY 1995: Subsequent to the verification of this cancer assessment in 1990, the National Toxicology Program completed a two-year cancer bioassay (1991); its results suggest that naphthalene may be more appropriately classified as a possible human carcinogen (Group C under current EPA guidelines). The NTP concluded, "Underthe conditions of these 2-year studies, there was no evidence of carcinogenic activity of naphthalene in male B6C3F1 mice exposed by inhalation to concentrations of 10 or 30 ppm for 6 hours daily, 5 days per week, for 103 weeks. There was some evidence of carcinogenic activity of naphthalene in female B6C3F1 mice, as pulmonary alveolar/bronchiolar adenomas."

Naphthalene, a chemical on this site, was treated in the Health Risk Assessments of 1988 and 1994 as a non-carcinogen based on contemporary evidence. To address concerns regarding a potential reclassification of naphthalene to Group C, possible human carcinogen, the relative potency factor for naphthalene proposed in the MADEP document concerning risk assessment for PAHs (October 2, 1995) was used by us to calculate human risk levels. Our evaluation indicated that the projected lifetime cancer risks for residents, mall visitors, and workers would still be below the I in 100,000 target limit set by MADEP.

There is inconsistent treatment of naphthalene at this time. Naphthalene is still not classified as a human carcinogen by EPA and the California Department of Health. It is not listed among the California Proposition 65 compounds. As of October 1995 MADEP

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23,1996 Environmental Health & Engineering, Inc., 95.415 Page 25 of 39 considered naphthalene as a potential carcinogen based on evidence of lung cancer in one gender of one animal species only. They use a cdnservative mouse-to-man extrapolation method to estimate potency in humans.

The existing risk assessments have adequately considered both the cancer and non- cancer risks from other PAHs. Recent revisions or modification to relative toxicity of PAHs should not affect the previous predictions that indicated a small contribution of the analyzed PAHs to total risks.

6.8 CONCLUSIONS

Estimated lifetime cancer risks of less than 1 in 100,000 and a total hazard index of less than 1 (i.e., total exposures are below the reference concentrations or assumed safe limits for non-cancer effects) are projected. These projections are below the MADEP guidelines and other agency criteria for acceptability.

Analysis was done by a competent and experienced individual using available data and mostly new methods to predict concentrations. Methods were developed to predict concentrations and exposures prior to detailed guidance from EPA and MADEP. In general, however, either realistic or conservative assumptions were made to estimate exposures and risks.

It is usually desirable to update a risk assessment when new concentrations, exposures, or toxicity data are made available. In this case, given the conservativeness of the existing risk assessment methods and based on what we already know, it is unlikely that the predicted risks would change appreciably if updates were conducted. Recent proposed revisions or new information on naphthalene and PAH toxicity values are unlikely to increase either the cancer or non-cancer risk estimates above the acceptable limits.

New development plans for the site differ from the earlier version and include an area near the northeast comer of the site where there is limited soil and groundwater data. In absence of soil concentration data for this area, we took the upper (95th percentile) bound estimate based on the site-wide concentrations. Using this approach, the

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 26 of 39 projected risks (e.g., from naphthalene) could increase somewhat (by 40%) but not beyond the accepted MADEP target limits.

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 27 of 39 7.0 EVALUATION OF HYDROGEOLOGIC DATA

Hydrogeologic data collected at this site were assessed for quality and adequacy. Analytical methods selected for the water analysis at the site were EPA methods commonly used at hazardous waste sites. The quality of these data could be partially assessed as discussed earlier. General issues relating to environmental data are discussed in this section before considering the groundwater model in more detail.

Review of the series of long-term monitoring reports was completed. Based upon the review of this data, the following observations and recommendations are made.

Water and sediment data were collected primarily during the springtime when surface water levels would have been highest due to runoff. A better measure of worst case conditions could have been made during the summer or fall when conditions are drier. In addition, only one location at Jerry's Pond had been monitored on a regular basis. This may not adequately represent conditions at Jerry's Pond and, therefore, may affect scoring for Tier Classification, as discussed later.

Groundwater monitoring data indicated that flow patterns and direction displayed some variation over time at the site. Flow patterns to the east of the site, in the vicinity of the MBTA tunnel and Russell Field, have not been well characterized; this is the area where the greatest degree of variability was observed. No monitoring points were located east of the tunnel, which reportedly has a significant impact on flow.

The April 1988 Environmental Data Report (Volume 7 of 7) (Haley & Aldrich 1988) was reviewed to assess the groundwater modeling conducted at the site. Observations are general at this time and concerns might be resolved by discussions with the modelers and/or review of primary data. More specific comments would require a detailed analysis of site data and possibly additional field testing.

The model selected for evaluation of the previously planned development seems appropriate. The boundary conditions and orientation of the model were consistent with

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 28 of 39 site conditions. Grid spacing was sufficient for the project objectives and was within the model's limitations. Use of a steady-state, two-dimensional simulation, although a simplification, was nevertheless appropriate for assessing the impact of the proposed foundations of the original development plan. However, sensitivity analysis of the initial boundary conditions was not performed, as far as we could discern. Therefore, the influence of boundary conditions' assumptions could not be evaluated, and their impact on groundwater flow patterns could not be assessed.

The documents provided did not present sufficient information supporting model assumptions and applications to allow independent reassessment. For example, information that indicates how values for certain model parameters were determined was generally not provided in the documentation, nor was information provided on the error criterion for model closure.

Parameters that are of primary concern include the permeabilities assigned to the subway tunnel and the passageway nodes and the surface recharge rates. Since the sensitivity analyses indicated that the model was most sensitive to these parameters, justification for the values assigned should be provided. We have no current understanding of how the subway tunnel and passageway node permeabilities were calculated. In addition, our opinion is that the recharge rates seem much lower than would be expected for the site area.

Information contained in the well construction logs and methods used during the in-situ permeability tests could possibly be used to evaluate the representativeness of aquifer permeabilities used as model input. Given the descriptions of the aquifer material, the permeability used appears within the typical ranges commonly observed for sandy outwash material. Current methods generally employ a different analytical technique than Hvorslev's method (which was used) to estimate aquifer permeability from slug test data. Evaluation and re-analysis at this level of detail was not undertaken.

Without an understanding of how adjustments to the saturated thickness, permeability, and recharge rates were made from measured data, EH&E can form no opinion as to how accurately data represent site conditions during model calibration. We agree that

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23,1996 Environmental Health & Engineering, Inc., 95.415 Page 29 of 39 the comparison of the measured historical groundwater conditions with simulated c6nditions indicates only reasonable similarities, with notable differences in the upgradient area of the site. However, we believe that the simulated existing groundwater conditions do not reasonably reflect measured existing groundwater conditions. Finally, in order to support model verification, a mass balance calculation is typically reported. In the absence of these data, we can not form an opinion as to the accuracy of the calibration and verification runs.

In our opinion, comparison of the simulated future groundwater contour plan with the existing groundwater contour plan showed significant differences in the rate and direction of groundwater flow. We believe that, because the conclusion derived from the groundwater modeling was based on previous development plans, they can not be used to evaluate conditions under the current development proposal. We can not say with confidence that it is unlikely that groundwater flow directions or water table elevations will be significantly altered in the site vicinity or north of the development as a result of the newly proposed construction. However, if the new construction does not include significant alteration of the subsurface or recharge pattems, impacts to flow patterns and rates may not be as significant. Detailed analysis of construction plans would be necessary to assess potential impacts to groundwater flow. In addition, changes in groundwater flow directions and gradients that could result from the repair of the MBTA tunnel are potentially significant.

Additional characterization of site hydrogeology is necessary to resolve these questions. Installation of additional wells east of the MBTA tunnel, groundwater monitoring in this area, and additional assessment of groundwater flow rates across the site are recommended.

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 30 of 39 8.0 RELATED ISSUES

While the majority of EH&E's effort was involved with the review of the numerous documents previously prepared by Haley & Aldrich, several related items were mentioned at the citizen meetings and in written correspondences. We could not address all of these points, in fact the City, Haley & Aldrich, and others were more appropriate responders. However, we did consider the Tier Classification, MBTA Tunnel, Russell Field, and the recent data on naphthalene (previously discussed).

8.1 TIER CLASSIFICATION

We support the decision of MADEP to conduct an audit of the Tier Classification process for this site. We believe that the interests of the City, neighborhood, and the developer would be better served if site construction and further remediation were subject to some additional oversight by MADEP.

The following observations are offered to assist the audit process.

8.1.1 Surface Soil and Sediment

Surface soil in the zero- to six-inch zone reportedly had been sampled at 14 locations on the site (J1, J2, and SS1 through SS12). Sediment reportedly had been sampled at five locations in Jerry's Pond (Jerry's Pond, J3, and SD11 through SD13), two locations in Alewife Brook (SD6 and SDB), and one other location of apparent sediment accumulation (SD14). It has been assumed that the applicable reporting category for the site is RCS-1 due to the proximity of Russell Field Park, residences, and Jerry's Pond. Exceedances of the RCS-1 concentrations have been noted at locations SS1 through SS3, SS5, SS6, SS9, SS10, SS12, SD4, SD6, and S08.

The Numerical Ranking System indicated that areas where surface soil or sediment concentrations of oil or hazardous materials (OHM) exceeded applicable reportable concentrations constituted a potential exposure pathway for soil (and sediment) as

Pubic Hental HEaluation for W.R. Grace Site - FINAL DRAFTP April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 31 of 39 defined in MADEP CMR 40.1512(1). The Tier Classification and Numerical Ranking submitted for the site indicates that the OHM is located beneath paved surfaces and at depths greater than six inches (due to pre-construction paving or re-grading that occurred subsequent to the collection of these data), thereby constituting evidence of contamination for soil (and sediment) as defined in MADEP regulations. Additional documentation of the regrading and paving was requested, but was not received at the time this report was prepared. The significance of this point is that if site conditions actually constitute a Potential Exposure Pathway rather than Evidence of Contamination, the Numerical Ranking Score would be increased by 85 points.

It was also noted that some of the greater exceedances of RCS-1 concentrations in subsurface soils in the test pit programs completed at the site were at locations where no surface soil samples were obtained. This may not be an issue if the remediation and construction plans include replacing top soil with clean material or covering the surface with a foundation and/or parking area.

The site-wide database should be reviewed to assess that samples of surface soil and sediment (i.e., zero to six inch) were collected at a representative number of locations on the site, based upon site history and current knowledge of the nature, extent, and distribution of contamination.

A comparison of the locations where the RCS-1 exceedances noted were observed should be made with actual site conditions to verify that all these locations had been regraded or paved over, including sediment sample locations. It should be determined if MADEP definitions refer to the sediment above and/or below water surfaces. We have been unable to obtain information from MADEP regarding this issue at the time this report was prepared.

8.1.2 Private Water Supply Well

A letter from a resident in the site vicinity, Mr. Edward Norberg, to Secretary Trudy Coxe of the Executive Office of Environmental Affairs, dated February' 7, 1996, indicates that Mr. Norberg has a private water supply well for agricultural/residential (non-ingested)

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23,1996 Environmental Health & Engineering, Inc., 95.415 Page 32 of 39 use at his property. Subsequent conversations with Mr. Wesley Stimpson of Haley & Aldrich and receipt of a letter written by Haley & Aldrich to MADEP regarding this issue indicated that Mr. Norberg does not use this well at all and, in fact, does not have a pump in the well. This may be a non-issue as long as the well is never activated.

The Numerical Ranking System indicates that when a private drinking water well is located within 500 feet of any portion of a disposal site where OHM has been identified in groundwater at concentrations equal to or exceeding applicable risk-based concentrations promulgated in MADEP regulations, this constitutes a Potential Exposure Pathway for groundwater as defined in the regulations. Such exceedances were reported in the Numerical Ranking Score determined for the site. However, the Numerical Ranking indicated that no drinking water wells were known to exist in the site vicinity at the time the Numerical Ranking Score was determined, thereby constituting Evidence of Contamination in groundwater. Please note that Haley & Aldrich indicated that, based on prior experience in Massachusetts, an unpermitted well, as the Norberg well is reported to be, is not eligible for consideration in Numerical Ranking in the Massachusetts Contingency Plan (MCP). MADEP must make a firm determination on this matter. The significance of this point is that if site conditions actually constitute a Potential Exposure Pathway rather than Evidence of Contamination, the Numerical Ranking Score would be increased by 80 points.

8.1.3 Surface Water

The Numerical Ranking indicated that OHM has been identified in site surface water at concentrations constituting Evidence of Contamination. Part of the basis for the score provided for this section appears to be that the surface water indicating the presence of OHM is not used for drinking, boating, or swimming. MADEP regulations indicate that conditions constitute a Potential Exposure Pathway for surface water if it is known to be used for drinking, swimming, boating, or fishing. Information provided in historical reports for the site indicates that Jerry's Pond was used for swimming, boating, and fishing. It is not clear whether the locations where OHM was observed were used for any of these purposes. However, information provided in Section VI of the Numerical Ranking indicated that a Long-Term Monitoring Report, dated 1994, provided data

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 33 of 39 supporting the conclusion that surface water and sediment contamination do not exist in Jerry's Pond. However, the Long-Term Monitoring Report provides information at one location at Jerry's Pond once a year (springtime). These data may not adequately characterize conditions at Jerry's Pond. The significance of this point is that, if site conditions actually constitute a Potential Exposure Pathway rather than Evidence of Contamination, the Numerical Ranking Score would be increased by 80 points.

8.1.4 Disposal Site Characteristics

State regulations set forth methods for determination of scores in many categories. The sum of all the categories is the final Tier Classification score. It appears that the methods used to determine the OHM Toxicity Score (CMR 40.1511, Section lIlA.) and the OHM Mobility and Persistence Score (CMR 40.1511, Section Ill.C.) do not include use of the methods defined and required by in the regulations, specifically, the Human Health-Based Toxicity Value Matrix (CMR 40.1513(3)) or the OHM Mobility and Persistence Factors (CMR 40.1514(4)) for site-related OHM are not found in the listed Human Toxicity Values (CMR 40.1513(2)) and Mobility and Persistence Scores (CMR 40.1514(2)) and (3)), respectively. The significance of these points is that it is possible that use of these methods could slightly increase the total site ranking and could potentially change the Tier Classification. However, the outcome would be uncertain until the procedures are completed.

8.1.5 Ecological Population

As with the Disposal Site Characteristics Scoring, a method defined in and required by the regulations was not used for the ecological population scoring. It appears that the methods used to determine the Environmental Toxicity Score did not include use of the Environmental Toxicity Value Matrix for site-related OHM not found in the listed Environmental Toxicity Values. The significance of this point is that it is possible that use of this method could slightly increase the total site ranking. However, the final outcome would be uncertain until the procedures are completed.

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc.. 95.415 Page 34 of 39 8.1.6 Mitigating Disposal Site-Specific Conditions

The first mitigating condition referenced in the Numerical Ranking indicated that, since no surface water or sediment contamination existed in Jerry's Pond, the score for the presence of a Fish Habitat under Ecological Population was reduced by 10 points.

The second mitigating condition referenced in the Numerical Ranking indicated that, since no surface water contamination existed in Alewife Brook and since there was no opportunity for surficial contamination from the site to impact Alewife Brook Reservation, the score for the presence of a Protected Open Space under Ecological Population was reduced by 10 points. Regional groundwater flow from the site toward the Reservation had been shown. Further, naphthalene and some VOCs had been reported for well 604, adjacent to Alewife Brook. The potential for site impact on Alewife Brook Reservation exists. However, EH&E does not believe that the numerical ranking should be changed because of lack of supportive evidence in surface and sediment samples.

8.2 HAZARDOUS MATERIALS MANAGEMENT AND REMEDIAL ACTION

In accordance with the MCP, this site must be remediated within five years of Tier Classification, that is, by the year 2000, with or without redevelopment of the site for any use. Remedial action plans have not yet been developed by Haley & Aldrich, but they will likely be incorporated into any redevelopment project. If the proposed shopping center is built on the site, limited soil excavation will be required for development and additional soils will be excavated for remediation. Management of hazardous materials will be necessary to minimize impacts to the surrounding community and onsite workers during remediation and construction.

Under the MCP, rigorous health and safety and contingency planning must be completed prior to the initiation of remediation and construction. Environmental oversight will be required during any construction that occurs concurrently with remediation. It is recommended that the City of Cambridge thoroughly review all plans governing hazardous materials management, remedial action, health and safety, and emergency contingencies at the site, when these documents become available. This

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 35 of 39 review will help ensure both the short-term and long-term site risks are minimized and that thorough remedial action is completed at the site.

8.3 MBTA TUNNEL

In February EH&E gained access to the MBTA tunnels at Alewife Station. Visual - inspection of several hundred meters of tunnel both east and west of the passenger platform were made. It was obvious from the damage to the concrete retaining walls and ceiling that water seepage had been occurring for some time. The tunnel walls on both sides were wet and seeping water in numerous spots along the entire section.

A 1992 report by Stone & Webster, Inc. for the MBTA characterized the health risks for employees at this station. Drainage into the tunnel by groundwater was identified as the primary route for low level exposures to VOCs. The Stone & Webster, Inc. report referred to the 13-year history of investigations that had been carried out in an attempt to explain the reported objectionable odors and to resolve the health and safety fears of the employees. EH&E's review did not include monitoring nor could EH&E review the consultant reports referred to in the Stone & Webster, Inc. document, which were not provided, with the exception of the W.R. Grace reports prepared by Haley & Aldrich.

Presented here is EH&E's perspective. Based on the similarity between chemical compounds found in tunnel aqueous samples and those reported for soil and well water samples at the site, it is likely that the site is the origin. However, because oil and grease are used on switches and trains, and because various cleaning solvents are used on the trains and in the Alewife station, multiple sources for the contaminants are likely. A limited number of air measurements made in 1985 in the tunnel indicate low airborne concentrations of several compounds. During the tunnel inspection, we did not detect chemical odors in the air or when smelling the discolored surfaces. However, other individuals reported a chemical odor from the pump room on a previous visit.

Inspections by others, as recounted by Stone & Webster, Inc., reported that both the sewer sump and drain sump vented through a common vent, which could be responsible for sewer smells from the track drainage and floor drain system.

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 36 of 39 The relevance of the MBTA to the'proposed development has to be put into perspective. The MBTA drainage system and air exhaust system would be the only avenues for contaminant exposure to the community. Routine and continuous monitoring of the Parkway Pond, where the subway pump empties, has not revealed contaminants, according to Haley & Aldrich, Inc. Limited air sampling in'the tunnel conducted by GZA reported low concentrations of a few VOCs. VOCs volatizing from the seeping groundwater would be greatly diluted both in the high volume airflow through the tunnels and upon dispersion in the outdoor air. As a result, this would not be an important exposure pathway.

The tunnels may have significantly altered the groundwater movement in the vicinity of the proposed development. The combined impact of development, paved surface areas, and new surface water drains needs to be assessed. It is conceivable that, as groundwater flow into the tunnels is reduced, aqueous concentrations of site contaminants could actually increase. Although this would have insignificant impact on the neighborhood, it could be important for MBTA employees.

8.4 RUSSELL FIELD

Environmental data is not currently available for the Russell Field area. This information is important from two perspectives.

First, groundwater quality and flow data in this area would provide a more complete understanding of potential groundwater impacts from the W.R. Grace site onto properties to the east (as discussed in Section 7.0). Based upon the available information, it appears that this area is largely uncharacterized.

Second, there are community concerns about past activities at Russell Field. Specifically, it has been reported by community members and in file documentation that contaminated excavate soil was stored on portions of the Russell Field property during excavation of the MBTA tunnel. Detailed information on the methods of excavation, materials handling, storage, and disposal has not been available for review, No

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 37 of 39 information on the chemical nature of contamination in the excavate has been available. In addition, records of the reported offsite disposal (hazardous waste manifests), which are required by Federal and State regulations, have not been available for review.

Given the many areas of uncertainty, it is recommended that an environmental investigation of this area be conducted. This should include characterization of soils and groundwater. It is estimated that a minimum of four to five wells would be necessary east of the tunnel to characterize flow in this area; actual locations should be selected based upon field conditions and a review of boring logs from the investigation of the W.R. Grace site. Permeability testing is recommended at selected representative wells. It is reported that clean fill was placed on top of existing materials at Russell Field. This should be verified by analyzing pooled soil samples obtained for the top few inches. In addition, subsurface soil should be characterized to assess any potential impacts of storage of contaminated excavate. While subsurface soils do not generally pose a direct exposure hazard (unless excavated), they can provide a source of contamination to groundwater. Therefore, there are two options: either analyze bulk water samples from new wells located between Russell Field and Clifton Street houses, or collect soil core samples down to the level of the original grade. 9

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 38 of 39 9.0 REFERENCES

Agency for Toxic Substances and Disease Registry. 1995. Toxicological Profile for Naphthalene (Update). U.S. Department of Health and Human Services, Agency for Toxic Substances and Disease Registry: Atlanta, Georgia.

Cambridge Environmental, Inc. 1994. Update of Health Risk Assessment for the WR. Grace & Co. Property, Cambridge, Massachusetts as prepared by Meta Systems, Inc. (same company, new name) in 1988.

Haley & Aldrich, Inc. 1988. Environmental Data Report for the WR. Grace & Co. Property in Cambridge, Massachusetts, Volumes 1-7.

Haley & Aldrich, Inc. 1995. Public Involvement Plan DEP RTN 3-0277 for WR. Grace 62 Whittemore Avenue, Cambridge, Massachusetts.

MADEP. October 1995. Petroleum Hydrocarbon Toxicity Project Report: Polycyclic Aromatic Hydrocarbon Cancer Risk Evaluation Methods. Massachusetts Department of Environmental Protection, Office of Research and Standards: Boston, Massachusetts.

Meta Systems, Inc. 1988. Health Risk Assessment for the W.R. Grace & Co. Property, Cambridge, Massachusetts.

NTP. 1992. Toxicological Carcinogenesis Studies of Naphthalene (CAS No. 91-20-3) in 9 B6C3F Mice Inhalation Studies. Technical report series No. 410, NFH Publication No. 92-3141. National Toxicology Program, U.S. Department of Health and Human Services, Public Health Service, National Institute of Health: Research Triangle Park, NC.

Public Health Risk Evaluation for W.R. Grace Site - FINAL DRAFT April 23, 1996 Environmental Health & Engineering, Inc., 95.415 Page 39 of 39 9 9

p APPENDIX C

LIMITATIONS

U di Ii LIMITATIONS

1. Environmental Health & Engineering, Inc.'s (EH&E) assessment described in the attached report number 95.415, Public Health Risk Evaluation for WR. Grace Site in Cambridge, Massachusetts, (hereafter "the Report"), was performed in accordance with generally accepted practices employed by other consultants undertaking similar studies at the same time and in the same geographical area; and EH&E observed that degree of care and skill generally exercised by such other consultants under similar circumstances and conditions. The observations described in the Report were made under the conditions stated therein. The conclusions presented in the Report were based solely upon the services described therein, and not on scientific tasks or procedures beyond the scope of described services, nor beyond the time and budgetary constraints imposed by the client.

2. Observations were made of the site as indicated within the Report. Where access to portions of the site was unavailable or limited, EH&E renders no opinion as to the presence of chemical residues, or to the presence of indirect evidence relating to chemical residues in that portion of the site.

3. The observations and recommendations contained in the Report are based on limited environmental sampling and visual observation, and were arrived at in accordance with generally-accepted standards of industrial hygiene practice. The sampling and observations conducted at the site were limited in scope, and therefore cannot be considered representative of areas not sampled or observed.

4. Where sample analyses were conducted by an outside laboratory, EH&E has relied upon the data provided, and has not conducted an independent evaluation of the reliability of these data.

5. The purpose of the Report was to assess the characteristics of the subject site as stated within the Report. No specific attempt was made to verify compliance by any party with all federal, state, or local laws and regulations. 9

p Q Ii.

0 APPENDIX A

EVALUATION OF SOIL AND GROUNDWATER SAMPLES

1k 1 EVALUATION OF SOIL AND GROUNDWATER SAMPLES

This evaluation examined the patterns of chemical concentration measurements in soil and groundwater samples at the W.R. Grace site in Cambridge, Massachusetts. Specifically, EH&E has:

A.1 THE DATA

Samples collected from 1984 to 1988 were analyzed for 125 analytes and several other types of measurements, such as pH. The data sets (provided by Haley & Aldrich) were examined and found to contain 78 compounds as well as other summary *values. According to Haley & Aldrich the remaining 47 compounds, were never detected in any of the samples. From these compounds 59 were chosen for inclusion in risk assessment by Cambridge Environmental, Inc. and are listed- in Table A.1. The groundwater samples collected between 1990 and 1994 were analyzed for VOCs and naphthalene only. A subset of these compounds found in the data files were selected for the statistical analysis described here. A further description of the methods for choosing the compounds for analysis is given in Section A.3. 9 Table A.1 Compounds included in the Cambridge Environmental, Inc. risk assessment and those included in statistical analyses discussed in this report

Soil analysis Groundwater Compound Risk Duplicate Distribution Duplicate and assessment distribution 1,1,1-trichloroethane 1 1,1-dichloroethene 1 1 1,2-dichloropropane 1 2,4-dimethylphenol 1 2-butanone 1 2-hexanone 1 4-methyl-2-pentanone 1 1 Acenaphthene 1 2 Acenaphthylene 1 Acetone 1 1 Anthracene 1 Antimony 1 Arsenic 1 1 2 Barium 1 2 Benzene 1 1 Benzo (a) anthracene 1 1 1 1 Benzo (a) pyrene 1 1 1 1 9 Benzo (b,k) fluoranthene 1 1 1 Benzo (ghi) perylene 1 2 1 Beryllium 1 1 Bis (2-ethylhexyl) phthalate 1 1 Butyl benzyl phthalate 1 Cadmium 1 1 1 Carbon disulfide I Carbon tetrachloride 1 Chlorobenzene 1 Chromium 1 1 Chrysene 1 1 1 Copper 1 Di-n-butyl phthalate 1 Di-n-octyl phthalate 1 Dibenzo (a,h) anthracene 1 1 1 Diethyl phthalate 1 2 1 Ethylbenzene 1 Fluoranthene 1 1

Blank means not used, 1 means included in analysis, and 2 indicates compounds less than reporting limits, but larger than half the reporting limits. Table A.1 Continued

Soil analysis Groundwater Compound Risk Duplicate Distribution Duplicate and assessment distribution Fluorene 1 Formaldehyde 1 1 1 1 Indeno (1,2,3-cd) pyrene 1 1 1 Iron 1 Lead 1 1 1 1 Mercury 1 1 1 Methylene chloride 1 1 1 n-Nitrosodiphenylamine 1 Naphthalene 1 1 1 1 Nickel 1 1 1 1 Oil and grease 1 1 p-Chloro-m-cresol 1 Pentachlorophenol 1 Petroleum hydrocarbons 1 1 Phenanthrene 1 2 1 Phenol 1 Pyrene 1 1 Selenium 1 1 Silver 1 Styrene I Tetrachloroethene 1 Toluene I I Total Cyanide I Total Xylenes 1 Trichloroethene 1 1 Vinyl Acetate I Zinc 1 1 1 1

Blank means not used, 1 means included in analysis, and 2 indicates compounds less than reporting limits, but larger than half the reporting limits.

Results of a sample's lab analysis can be placed in four categories:

1. Not available - compounds not analyzed for the sample.

2. Not detected - sample analyzed for compound, but value was below detection limits.

3. Detected, but not quantified - sample analyzed and compound detected, but not in amounts that can be reliably measured. 4. Detected and quantified - sample analyzed and compound detected in amounts that could be reliably measured.

A.2 THE MODEL

The model used for this type of mixed data can be described as follows. Let X(s) be the true concentration level at a site. Given a random sample of the study area, define the probability that X(s) is in one of the three categories as:

pA = P (non-detect) pD = P (detected, but not quantified) pm = P (detected and quantified)

Given that a sample is in one of these categories, the probability distribution of the true concentration level for samples within the category needs to be determined. The distribution of the sample depends on the category. Define the conditional cumulative distributions for the three categories to be FA, FD, and Fm respectively.

Estimates of the distributions for the non-detect and present categories are not possible since we can not get any measurements. We can assume without much loss of generality that the distribution FA is Uniform on [0, xo], where xD is the detection limits of the method of sample analysis and FD is Uniform on [xD, XM], where XM is the limit of the method of sample analysis that produces reliable numerical results. The cumulative distribution FM is estimated from the samples,. but it is assumed Fg~x) = 0, for x < xM. Now the distribution of X(s) can be written as: F(X(s)< x) = PAFA(x) + PD*F(X) + pMFM(X).

A.3 THE ANALYSIS

The statistical analysis of the soil and groundwater data from 1984 to 1988 is composed of three parts: duplicate analysis, univariate distribution estimation, and spatial mapping of concentrations. A brief discussion of the nature of the analysis and choice of compounds studied is given here.

There were 78 chemical compounds analyzed for at least one site. Subsets of these chemicals were chosen for duplicate and distribution analyses. Sixteen compounds that had a high number of samples with detectable concentrations were chosen for duplicate analysis for the soil samples. For distribution estimation, compounds were chosen if any samples had concentration values higher than the MADEP standards for groundwater (GW2) and soil (Si). Other compounds included were oil and grease and petroleum hydrocarbons for soil samples and phenanthrene and formaldehyde for groundwater samples. A total of 18 and 20 compounds were included in the soil and groundwater analyses, respectively. There was considerable overlap between compounds included in analyses of soil and groundwater distributions. A secondary list was developed for compounds that had maximum observed values less than the MADEP standards, but greater than half of the MADEP standards. For 47 of the 78 compounds studied, no samples had concentrations greater than half the MADEP standard reporting categories GW2 and S1. Table A.1 contains a list of the compounds included in the statistical analyses and in the Cambridge Environmental, Inc. risk assessment for the site.

Analysis of the duplicate sample data was conducted to determine the validity of the samples themselves. Two main questions were:

1. Do data from the duplicates indicate any sampling bias?

2. Is the variability between duplicates at a site relatively small compared to the variability in concentration levels between sites? Only soil samples with 15 duplicates had a large enough sample size for true duplicate analysis to be performed. The number of duplicate samples for groundwater and surface water were eight and three, respectively.

Duplicate analysis, in which groundwater samples collected over time from the same . site were treated as replicates, was conducted. Even for this strategy, only 13 compounds had enough replicates to perform the analysis. To overcome possible non- normality, analyses were also carried out on log transformed data.

Univariate distribution estimation included estimates of probability samples belonging to the three categories A, D, and M. Empirical distribution functions are given for the distribution of concentration values (i.e., the empirical distribution function for F). Other relevant statistics, such as mean and variance, were also computed. Spatial distribution of concentration levels were also supplied.

A.4 DUPLICATE ANALYSIS

Duplicate samples were field duplicates and not lab duplicates. In this situation, duplicates were not necessarily expected to generate nearly identical results, particularly for soil samples, because soil composition can naturally vary even within a few inches. It is really a test to see how representative a sample may be of the neighboring area, particularly compared to the variability across the entire study site.

The number of soil, groundwater, and surface water samples that had duplicates was small. Maximum possible sample sizes were 15, 8, and 3, respectively. For many compounds, actual sample sizes were typically smaller because samples were not analyzed or did not have detectable levels for one of the samples in the duplicates. The number of soil duplicate pairs was just large enough to carry out a few basic analyses.

One assumption about the collection of field duplicates was that the samples were randomly selected at-the site. To investigate this assumption let d = X(s) - Xd(s), where Xd is the duplicate sample at the site. Table A.2 states the frequency that d is less than zero for each compound. Table A.3 gives the mean of d for each compound. If duplicates were taken randomly, the frequency in both tabres should be around 50%. Looking over all compounds listed in Table A.2, the variability in these frequencies is in line with what occurs if samples were selected at random. The results show no indication of non-random sampling behavior.

Table A.2 Percent of differences less than zero for soil duplicate samples

Compound n #d

Mean Std. Std. err. n Mean rel Std. dev. rel. Compound difference dev.(d) (d) diff. diff. Methylene chloride 10.00 21.7 9.7 5 0.20 0.19 Acetone -40.00 - - 1 0.19 - Benzene -20.00 - - 1 0.09 - Toluene - - - 0 - - Fluoranthene 11,120.00 19,629.3 13,880.0 2 1.07 0.21 Naphthalene -1,532.83 6,126.3 2,501.0 6 0.21 0.22 Benzo (a) anthracene -1,705.00 2,100.1 1,485.0 2 0.42 0.44 Benzo (a) pyrene -2,835.00 - - 1 0.97 - Benzo (b,k) fluoranthene -5,950.00 7,396.3 5,230.0 2 0.59 0.72 Pyrene 1,780.00 13,821.0 7,979.6 3 0.98 0.19 Arsenic -0.52 3.0 0.8 15 0.20 0.14 Chromium -0.71 2.5 0.6 15 0.10 0.09 Mercury 0.00 0.1 0.02 9 0.22 0.22 Nickel 4.77 20.5 5.3 15 0.17 0.30 Lead -3.23 26.5 6.8 15 0.24 0.35 Zinc -74.26 214.6 57.4 14 0.18 0.16 Formaldehyde -48.09 118.3 44.7 7 0.40 0.49 Oil and grease 6,093.17 23,440.0 6,766.5 12 0.53 0.35 Petroleum hydrocarbons -331.93 809.6 216.4 14 0.34 0.36 9 Besides mean difference, Table A.3 gives estimates of variability- in measured differences, both in absolute terms and relative terms. The mean relative difference is the mean of the coefficient of variation for all duplicate pairs for a compound. The coefficient of variation for a particular pair can be written as v, = /|x, - x,,/(x, + xi,). Then the mean relative difference is the mean of v, over all duplicate pairs, etc. Absolute mean difference and its standard deviation show no indication that the mean difference is not zero. The decision on whether the variability within duplicates is high is a subjective one and left at the reader's discretion. The mean relative difference indicates that, for most of the compounds, the standard deviation was usually less than 30-40% of the mean. The largest mean relative errors also had very small sample sizes and were not reliable estimates. Of those compounds with larger sample sizes, formaldehyde and oil and grease had the highest mean relative difference and precision may be of concern for them. Next, the duplicate pairs were identified by whether both pairs fell in the same detection 9 category. This is a useful test for those compounds that have a high percentage'of samples with no measurable concentrations. Clearly, if one sample shows no detectable amounts of a compound and the area is fairly homogeneous, the duplicate sample should also show no detectable amounts. Table A.4 gives the total sample size, the correct number of matches, and the percent correct. All results were over 67% and 15 of the 19 compounds matched on more than 80% of the samples. Metals had very high rates, while the other compounds had lower rates. Note that due to small sample sizes just one mismatch more or less causes about a 6% or 7% change in the correct categorization rate. These results were fairly subjective, but indicated that field samples were representative of the neighboring area, at least on a qualitative level.

Table A.4 Qualitative evaluation of soil duplicate samples based on detection category

Compound Total samples # Correct matches % Correct Methylene chloride 14 13 0.93 Acetone 14 11 0.79 Benzene 14 13 0.93 9 Toluene 14 11 0.79 Fluoranthene 15 11 0.73 Naphthalene 15 13 0.87 Benzo (a) anthracene 15 12 0.80 Benzo (a) pyrene 15 10 0.67 Benzo (bk) fluoranthene 15 12 0.80 Pyrene 15 13 0.87 Arsenic 15 15 1.00 Chromium 15 15 1.00 Mercury 15 14 0.93 Nickel 15 15 1.00 Lead 15 15 1.00 Zinc 14 14 1.00 Formaldehyde 14 13 0.93 Oil and grease 14 13 0.93 Petroleum hydrocarbons 14 14 1.00

For those duplicate pairs that had measurable concentrations in both samples, a simple analysis of variance was used to compare the variability between duplicate samples and the variability between sampling locations. Small variability within duplicates compared to variability between locations was another indication that samples were fairly representative of the neighboring area. Let a 2 and a be the within duplicates and between sampling location variances. Table A.5 contains estimates of these variances for all compounds with a suitable sample size. The ratio of variances for within duplicates and between sites can be used to get relative size of variances. Smaller p- values indicate the strength of the hypothesis when the ratios of the two variances is not equal. to one, a p-value less than 0.05 is frequently used as a cut-off point. For compounds with a reasonable sample size, only nickel, formaldehyde, and oil and grease show within variability as large as between site variability. However, deletion of a questionable value for one of the duplicates for nickel changes its p-value to 2*1011. This analysis indicates that for compounds with a reasonable sample size, all but formaldehyde and oil and grease showed a much greater variation between sites than within a site. For many reasons, most notably non-normality and possible lack of independence of samples, it is not recommended to use the p-values given in the table as a true test statistic. However, they may still be used to judge relative variability. Results were carried out on log transformed data and results were qualitatively the same. Table A.5 Soil - Comparison of within duplicates and between duplicate variances

Compound -n } 2 a j p-value Methylene chloride 5 237.80 7,488.35 0.0001 Acetone 1 800.00 - - Benzene 1 200.00 Toluene 0 - - Fluoranthene 2 1.58E+08 1.53E+08 0.43 Naphthalene 6 1.68E+07 4.058E+08 0.001 Benzo (a) anthracene 2 2.56E+06 2.58E+06 0.42 Benzo (a) pyrene 1 4.02E+06 - Benzo (b,k) fluoranthene 2 3.14E+07 532,900 0.90 Pyrene 3 6.53E+07 3.71E+07 0.62 Arsenic 15 4.388787 51.35 0.0000 Chromium 15 .3.056 37.28 0.0000 Mercury 9 0.00167 0.0222 0.0004 Nickel* 15 208.0623 206.65 0.5 Lead 15 332.7477 26,635.6 0.0000 Zinc 14 2.41E+04 2.41E+06 0.0000 - Formaldehyde 7 8,344.165 7,191.3 0.56 Oil and grease 12 2.7E+08 2.42E+08 0.56 Petroleum hydrocarbons 14 3.59E+05 1.31 E+07 0.0000

* - p-value would be 3*10- if site SIT3 TPI5 S2 is deleted

Repeated measurements over time were used as replicates for groundwater in place of standard duplicate analysis to try and get an estimate of relative variability within and between sites. The results of this analysis is given in Tables A.6 and A.7 for the 10 compounds with enough samples for this analysis. Again, small p-values indicated that variability over time at a particular well was small compared to the variability between wells. The large p-values were not surprising for many of the compounds because of the small sample sizes involved. Except for naphthalene, there was general agreement in tests for untransformed and log transformed data. For naphthalene, the log transformed results were more appropriate. Most compounds with reasonable sample sizes indicated concentration levels varied across the property. Table A.6 Comparison of variation in concentrations between sites and within sites for groundwater well samples-log transformed data

Compound site d.f. err. d.f. MS(site) MS(w/in) p-value Naphthalene 17 17 9.55 1.42 0.00 Benzo (b,k) fluoranthene 6 1 0.84 0.00 0.01 Chrysene 5 1 0.82 0.08 0.24 Phenanthrene 5 3 0.36 0.30 0.47 Cadmium 9 3 4.34 0.77 0.09 Nickel 14 3 1.43 1.07 0.46 Lead 14 2 1.31 0.87 0.47 Selenium 4 1 1.34 6.80 0.91 Zinc 35 18 4.31 1.60 0.01 Formaldehyde 14 6 4.60 0.81 0.02

Table A.7 Number of samples, means, and standard deviations for samples with a measurable concentration of the compound for soil and groundwater samples

Soil Sample Summary Gro undwater Summary Compound n Mean St. Dev. U!nits n Mean St. Dev. Units Methylene chloride 38 86.78 71.83 ppb - - - 1,1-dichloroethene - - - 3 5.47 3.92 ppb Trichloroethene 1 1,200.00 - ppb - - - 9 Carbon tetrachloride - - - 2 22.50 13.44 ppb 4- methyl-2-pentanone 4 333.00 579.92 ppb - - - Naphthalene 43 11,265.8 24,985.8 ppb 35 2,838.21 5,596.53 ppb Benzo (a) anthracene 35 4,404.46 8,704.15 ppb 5 8.00 4.98 ppb Benzo (a) pyrene 20 3,140.75 5,490.82 ppb 4 17.10 18.04 ppb Benzo (b,k) fluoranthene 41 9,073.00 29,079.4 ppb 8 13.68 13.07 ppb Chrysene 15 4,734.67 6,649.04 ppb 7 9.30 11.97 ppb Benzo (ghi) perylene - - - 2 46.30 56.71 ppb Phenanthrene - - - 9 22.32 11.15 ppb Dibenzo (a,h) anthracene 17 2,367.59 6,194.62 ppb 1 4.4 - ppb Indeno (1,2,3-cd) pyrene 27 6,008.74 18,753.5 ppb 3 30.47 38.57 ppb Bis (2-ethylhexyl) phthalate - - - 7 162.37 185.30 ppb Beryllium 39 0.51 0.45 ppm 1 31 - ppb Cadmium 71 2.82 7.12 ppm 13 59.43 151.67 ppb Mercury - - - 2 0.75 0.64 ppb Nickel 102 18.08 63.24 ppm 18 107.00 200.41 ppb Lead 98 190.22 555.50 ppm 17 110.47 123.31 ppb Selenium - - - 6 113.33 158.20 ppb Zinc 99 441.31 1,330.23 ppm 54 906.37 1,945.53 ppb Formaldehyde 40 14.36 44.65 ppm 21 0.55 1.01 ppm Oil and grease 70 7,871.39 14,237.6 ppm - - - Petroleum hydrocarbons 74 789.69 1,321.12 ppm - - - A.5 ANALYSIS OF RANGE OF COMPOUND CONCENTRATION LEVELS

As described previously, a complete description of the range or distribution of concentrations for each compound consists of two parts:

1. Estimating the probability that a sample has a detectable concentration of a compound.

2. For those samples with measurable amounts of a compound estimating the distribution or range of concentrations present.

Table A.8 gives estimates of the means and standard deviations for those compounds with a measurable quantity studied from the soil and groundwater samples. Tables A.8 and A.9 contain the probability of non-detect, detecting at non-measurable amounts, and detecting at measurable amounts of a compound for soil and groundwater samples, respectively. Most soil samples detected at least some amount of elemental compounds, while other compounds studied occurred in less than 40% of the samples. In descending order, zinc, naphthalene, formaldehyde, nickel, and lead were the most frequently occurring compounds in the groundwater samples. Nickel and lead were present in 25% of the samples. The overall mean can roughly be calculated as the probability a sample has a measurable concentration times the mean of those samples with a measurable concentration. This overall or grand mean is what is used in the Cambridge Environmental, Inc. risk assessment for soil analyses. Tables A.10 and A.1 1 contain the quintiles and maximum observed values for soil and groundwater samples respectively. For comparison these tables also contain the MADEP S1 and GW2 standards, respectively. Table A.8 Comparison of variation in concentrations between sites and within sites for groundwater well samples-untransformed data

Compound Site d.f. Err. d.f. MS(site) MS(wlin) P-value Naphthalene 17 17 2.33E+07 3.93E+07 0.85 Benzo (bk) fluoranthene 6 1 199.45 0.01 0.00 Chrysene 5 1 171.85 0.85 0.05 Phenanthrene 5 3 84.52 190.89 0.80 Cadmium 9 3 30,433.91 718.22 0.01 Nickel 14 3 21,267.21 128,358.3 0.99 Lead 14 2 16,287.16 7,625.00 0.36 Selenium 4 1 12,270.83 76,050.00 0.93 Zinc 35 18 5.58E+06 2.87E+05 0.00 Formaldehyde 14 6 1.31 0.37 0.06

MS(site) is variance between sites and MS(wfin) is variance within sites. P-value is for F-test. Results for log transformed data and untransformed data.

Table A.9 Soil samples - Summary of categorization of samples into non-detect, detect (detected, but concentration not quantified), and measurable (detected and concentration quantified)

Probability of Compound Total n Non-detect Detect Measurable Methylene chloride 101 0.62 0.00 0.38 Trichloroethene 101 0.98 0.01 0.01 4-methyl-2-pentanone 102 0.95 0.01 0.04 Naphthalene 117 0.50 0.14 0.37 9 Benzo (a) anthracene 112 0.48 0.21 0.31 Benzo (a) pyrene 112 0.62 0.21 0.18 Benzo (b,k) fluoranthene 112 0.42 0.21 0.37 Chrysene 112 0.64 0.22 0.13 Dibenzo (a,h) anthracene . 112 0.72 0.13 0.15 Indeno (1,2,3-cd) pyrene 112 0.57 0.19 0.24 Beryllium 103 0.62 0.00 0.38 Cadmium 103 0.31 0.00 0.69 Nickel 103 0.01 0.00 0.99 Lead 103 0.05 0.00 0.95 Zinc 100 0.01 0.00 0.99 Formaldehyde 88 0.55 0.00 0.45 Oil and grease 78 0.10 0.00 0.90 Petroleum hydrocarbons 77 0.04 0.00 0.96 -9 Table A.10 Comparison of the distribution of soil concentrations to the MADEP Reporting Standard

Quantiles for the following percentiles of FN MADEP u jS-1 Compound n 20th 40th 60th 80th 90th Max. Standard Methylene chloride 38 19 47 76 160 200 250 100 Trichloroethene 1 1,200 1,200 1,200 1,200 1,200 1,200 400 4-methyl-2-pentanone 4 3 19 19 110 1,200 1,200 500 Naphthalene 43 680 1,640 4,800 14,000 20,000 150,000 4,000 Benzo (a) anthracene 35 610 980 1,480 4,000 8,700 41,000 700 Benzo (a) pyrene 20 570 660 1,100 3,000 6,700 24,000 700 Benzo (b,k) fluoranthene 41 480 950 1,630 8,740 13,000 182,900 700 Chrysene 15 800 940 2,900 7,200 10,000 26,000 7,000 Dibenzo (a,h) anthracene 17 151 331 500 1,410 2,000 25,700 700 Indeno (1,2,3-cd) pyrene 27 417 600 1,100 3,600 6,700 97,500 700 Beryllium 39 0.26 0.34 0.45 0.6 0.82 2.8 0.7 Cadmium 71 0.6 0.91 1.3 2.3 3.3 54 30 Nickel 102 6.1 7.8 10 14 19 640 300 Lead 98 8.5 22.9 78 260 351 4,900 300 Zinc 99 18.4 42 110 440 801 11,975 2,500 Formaldehyde 40 0.6 1.1 1.8 3.5 5.1 220 100 Oil and grease 70 527 1,580 4,950 9,930 18,700 81,700 - 9 Petroleum hydrocarbons 74 10 94 384 1,109 2,118 7,950 - F. computed from empirical distribution function. Reporting limits are given by the City of Cambridge Table A.11 Groundwater - Estimated probabilities for three categories non-detect, detect and measurable for a sampling visit

Compound # Sampling Probability of Probability of Measurable - visits no detect detect 1,1-dichloroethene 101 0.97 0.00 0.03 Carbon tetrachloride 101 0.98 0.00 0.02 Naphthalene 94 0.56 0.06 0.37 Benzo (a) anthracene 94 0.90 0.04 0.05 Benzo (a) pyrene 94 0.88 0.07 0.04 Benzo (b,k) fluoranthene 94 0.85 0.06 0.09 Chrysene 94 0.87 0.05 0.07 Benzo (ghi) perylene 94 0.95 0.03 0.02 Phenanthrene 94 0.88 0.02 0.10 Dibenzo (a,h) anthracene 94 0.98 0.01 0.01 Indeno (1,2.3-cd) pyrene 94 0.93 0.04 0.03 Bis (2-ethylhexyl) phthalate 59 0.83 0.05 0.12 Diethyl phthalate 94 0.99 0.00 0.01 Cadmium 70 0.81 0.00 0.19 Mercury 70 0.97 0.00 0.03 Nickel 70 0.74 0.00 0.26 Lead 70 0.76 0.00 0.24 Selenium 67 0.91 0.00 0.09 Zinc 58 0.07 0.00 0.93 4, Formaldehyde 60 0.65 0.00 0.35

See Table A.12 for the probability that a well had at least one detect

Samples with measurable concentration levels can be used to estimate the frequency that concentration levels occurred at sampling locations. For groundwater, the average over time is used for wells with multiple samples. These estimates, called empirical distribution functions, are plotted in Figures A.1 through A.4 for soil and groundwater samples for naphthalene and formaldehyde.

S. Figure A.1 Spatial Map and Empirical Distribution Function for Naphthalene in Soil

Naphthalene ppb in soil

A 1+ 3 ++ 4+ + + 2 z + ++ I 5+ + V1+ ZP + + 4 G+~+ + 14 2 3 ++ 3 3 + 4 + 14 P + +

12 g 2 4 ++2 p p G+ 55 F+ + ++ + ++westemn Grace border No detect = + Present = P Conc. < 680 1 Conc. < 1640 = 2 Conc. < 4800 = 3 + Conc.< 14000= 4 Cone. < 150000 = 5

9 <--N

DEP S-i

a E

0 50000 100000 150000

Corr of Naphthalene ppb in soil Figure A.2 Spatial Map and Empirical Distribution Function for Formaldehyde in Soil

Formaldehyde ppm in soil

A +

+ + + + 4. + 4. z + 23 *+ .9. 4. + 0 2 +G 4 3 2 5 + g 34 41 ++ + N +. + + + 5 + + 2 + + 1 + + +S G~4 + F 3 2 + + western Grace borer No detect = + Present = P Conc. C 0.6 = 1 Conc.< 1.1 = 2 Conc. < 1.8 = 3 Conc. < 3.5 = 4 4 Conc. < 220 = 5

<- N 91

DEP S-I

RA C 0

U- EL

E Lu C3

0 50 100 150 200

Conc. of- Formaldehyde ppm in soil Figure A.3 Spatial Map and Empirical Distribution Function for Naphthalene in Groundwater

Naphthalene ppb in ground water

+ + P B. + G + M +9 C + 3 I- + 4

4~ +odetqct-=+ olnc' onc - -n5

<- N

DEP GW-2 C

C C 6

V 6 i E w 6N

C 6

0 2000 4000 6000 8000

Conc. of Naphthalene ppb in ground water Figure A.4 Spatial Map and Empirical Distribution Function for Formaldehyde in Groundwater

Formaldehyde ppm in ground water

4. 4 + + 0 + G 3 Eo + N54 M 2± N +. + +. FS + S 3 G+ ft + western- Grace border

reel= P zpn.' 1 Otc.d e 0.0 0AC.X42 K1C r 0110 < =

N 94

DEP GW-2 q0

N CL E 0U

0 2 4 6 8 10

Conc. of Formaldehyde ppm in ground water A.6 SPATIAL AND TEMPORAL ANALYSES

Spatial maps of the concentration levels for groundwater and soil samples have been generated. Figures A.1 through A.4 show the maps for soil and groundwater samples for naphthalene and formaldehyde. The characters on the map represent the following: + is a non-detect, P is a detect, 1-5 indicate whether the measurable concentration value observed at the site is less than or between the 20th, 40th, 60th, 80th, or 100th percentile concentrations observed. Locations of storage facilities are also given. The codes for these are: A = acetone, M = methanol, F = formaldehyde, G = fuel, N = naphthalene, z = zinc, and T is for tanks that held a number of different compounds.

A simple representation of time trends is given in Figure A.3 for naphthalene in groundwater. The nine wells that were sampled from 1984 to 1994 are circled in Figure A.3. Inside these circles are a pair of numbers separated by a comma. The meaning of these numbers is the same as the others on the plot; however, the first number represents the mean of samples from 1984 to 1987 and the second number represents the mean of samples from 1990 to 1994. No samples were taken in 1988 and 1989. The two wells changed from non-detect to a 1, but this change was less than indicated. This is because there were only one or two samples at these wells in 1984-1987, but nine samples in 1990-1994, of which only two or three samples had detectable levels. If the earlier period had been sampled as frequently as the latter period, it is possible low concentration levels may have occurred.

The probability of at least one detection in repeated groundwater samples of the same wells can be used to indicate differences between wells. It is assumed that the probability of detection is equally likely at any well at any time. From this assumption, the expected probability a well had at least one detection can be computed using the estimate of the probability that a sample had a detectable level of a compound. If the observed probabilities were considerably less than the expected probabilities given in Table A.12, this indicated that samples with detectable concentrations were being observed at certain wells rather than randomly over the W.R. Grace property. This was another indication that concentration levels of these compounds were different across the W.R. Grace property. Analysis of concentrations that were analyzed for VOCs and naphthalene over time were only available for nine well sites along the north and west borders of the W.R. Grace property from approximately 1985 to 1994. A total of 90 well samples were spread out fairly evenly among the nine well sites. Five compounds, benzene, ethyl benzene, naphthalene, methylene chloride, and total xylenes, had 26, 27, 49, 10, and 10 detects out of the 90 possible visits; all the rest had less than 10. Only naphthalene had observations above MADEP GW2 standards and the maximum concentrations observed for the other compounds were less than 10% of MADEP GW2 standards.

Naphthalene was consistently present in four of the nine sites: B212, 6707, B708, and 6604. Except B604, which is outside the W. R. Grace property (near the rotary), all sites were close to previous storage sites on the property. None of the sites showed any apparent time trends in concentration levels of naphthalene. It is possible there was an increase over time at well B604. However, one outlier and too few observations preclude a definite assessment. The fact that well B904 is between B604 and the others and showed no detectable concentration levels further weakens any migration hypothesis for naphthalene from the W.R. Grace property. The increase in concentration levels was slight, roughly 20 ppb per year and the maximum concentration level, 950 ppb at well B604, was considerably less than the MADEP GW2 standards (6,000 ppb).

Benzene and ethyl benzene also had a fair number of detects, but were scattered over many sites. Sites B212 and B604 had more detects than other sites, but detection was not consistent from one time to the next. No samples were above MADEP GW2 standards and there was an indication that concentrations were decreasing over time.

In summary, results from soil samples including duplicates indicate that the analytical methods were adequate to determine concentration differences among sites. However, this finding applies only to a few compounds due to the limited number of available data. 9 Table A.12 Comparison of the distribution of groundwater concentrations to the MADEP Reporting Standard

Compound 20th 40th 60th- 80th 90th Max. MADEP I I GW2 Naphthalene (ppb) 13.1 66.3 600.5 2,153.5 4,983.33 9,060 6,000 Benzo (bk) fluoranthene 3.9 8.7 10.6 21.9 21.9 42.4 7 Chrysene 3.25 4.8 5.7 6.5 6.5 36.3 3 Phenanthrene 5.9 19 23 27.67 27.67 29 50 Bis (2-ethylhexyl) phthalate 6.6 61 74 400 400 460 30 Cadmium 0.85 2.7 10 28 36.6667 560 10 Nickel 13 24 34 61 120 342.5 80 Lead 29 50 60 195 290 430 30 Zinc 48 130 380 850 2,900 9,600 900 Formaldehyde (ppm) 0.02 0.05 0.085 0.525 1.9 3.1 10

Only compounds with at least six sites with measurable concentrations are included. The mean value for each site does not include non-detects in estimates. Last column is the MADEP GW2 standards.

0 9 Table A.13 Comparison of observed and estimated probability of measuring a compound at a groundwater well site

Compounds # Sites Observed Expected 1,1-dichloroethene 44 0.07 0.07 Carbon tetrachloride 44 0.05 0.04 Naphthalene 43 0.42 0.67 Benzo (a) anthracene 43 0.12 0.19 Benzo (a) pyrene 43 0.09 0.23 Benzo (b,k) fluoranthene 43 0.16 0.29 Chrysene 43 0.14 0.25 Benzo (ghi) perylene 43 0.05 0.11 Phenanthrene 43 0.14 0.23 Dibenzo (a,h) anthracene 43 0.02 0.05 Indeno (1,2,3-cd) pyrene 43 0.07 0.15 Bis (2-ethylhexyl) phthalate 36 0.19 0.25 Diethyl phthalate 43 0.02 0.02 Cadmium 38 0.26 0.30 Mercury 38 0.05 0.05 Nickel 38 0.39 0.40 Lead 38 0.39 0.38 Selenium 38 0.13 0.15 Zinc 37 0.97 0.96 Formaldehyde 35 0.43 0.49 First column is the number of wells that had at least one sample over time sampled for the compound. Second column is the observed probability that a well had at least one detect. The last column is the expected probabilities based on random distribution, when observed was less than expected indicating non- random spatial distribution of compound across the site. I II

APPENDIX B

SUPPLEMENTAL INFORMATION

SOIL AND GROUNDWATER DATA: SPATIAL AND DISTRIBUTIONAL DISPLAYS

A 4-Methyl-2-Pentanone ppb in soil

A +

+ +- +4+- + + CD + P + G + + + ++ +3 +++N ++ +

++ + + + + 5N 2+ ++

+ western Grace boder No detect =+ Present = P Conc. < 3 = 1 Conc. < 19 = 2 Conc.< 19=3 Conc.< 110 =4 Conc.< 1200=5 9

<- N 9 Methyl Chloride ppb in soil

A +

+ + + +1

+ + 0 23 521 2 5 3 3 2 *++ + + + 3 5G + E 5 53 +3+ + N +. +

4 + 1 + +F 2 2 3 4 4 4 +i- ++ 4 4 5 + + + 2 4 3 +G +r + + western Grace bordAr No detect = + Present = P Conc. < 19 = 1 Conc. < 47 = 2 Cone. < 76 = 3 Conc. < 160 = 4 + Conc. < 250 = 5 p <- N

DEP S-1 a1

0- RA C

C. E

50 100 150 200 250

Corn. of Methyl Chodde ppb in so Indeno (1,2,3-cd) pyrene ppb in soil

4 1++ +1

< z + + 0 5+ P+ p~ 53 4. ++ o 5 4G P + E ++ p + + + + +2 + + I: |b 2 1+ !!: 53 +~ +N 3p+ 2 + + P+ P+P + m 3+ + p p p + + F 2 ++ +5 p P p +G T+ + 4 + western Grace bordar No detect + Present = P Conc.< 417= 1 Conc. < 600 = 2 Conc. < 1100=3 +. Conc. < 3600 = 4 + Conc. < 97500 = 5

<- N 9

DEP S-1 . O

*c C4. E

o 20000 40000 60000 80000 100000

Conc. of Indeno (1.2.3-cd) pyrene ppb in soil Naphthalene ppb in soil

A 1+, 3 +. + ++ + + 0 2 z I 5+ + ++ + 0 1 41 ++4+ + + pP +. + 0 4 3 G+ + + 14 F 2 C, 3 .+ 3 + 4+ +. q.P -- 3 1 +1% 1 2 +1 FP 2 2 4 1 Sc + P+P+ R 5 I- 5+ ++2 + P 5 5 P 21G + 5 F P +2 P + P. 2 rq + + western Grace bordtr No detect = + Present = P Conc. < 680 = 1 Conc. < 1640 = 2 Conc. < 4800 = 3 + Conc. < 14000 = 4 + Conc.< 150000=5

<- N

DEP S-1

C 0 FA

(0 LB C

-i5CL 0 w|

01 0

0 C

0 50000 100000 150000

Conc. of Naphthalene ppb in soil Benzo (a) anthracene ppb in soil

A - ++ 4 + ++ ++1

z *32 + T4 p p+- + P + + + 5 4 G p + + + +P E + + b 2 p +3 4+ + 33 5+ ++ < ++ + + 3+3 p 2 1 + F ++ +r + F+ + 5 + western Grace bordhr No detect = + Present = P Conc. < 610 = 1 Conc. < 980 = 2 Conc. c 1480 = 3 Conc. < 4400 = 4 3 Conc. < 41000= 5

<-N 9

DEP S-1

-RA . 0o A

CL L.

Cm O - E U123

0000 00 00 00

Conc. of Benzo (a)anthracene ppb in soil Benzo (a) pyrene ppb in soil

A ++

4 +2 +$ +

z + ++ * + o 5 +4 P+G + p Z+++ +++ + +p E E 5 + + + 2 43 +) + + + ++ +2 + 5+ N

+ + P+ P + 4 + p p + + F ++ 1+ P P p + g+ + + + western Grace bordAr No detect = + Present = P Conc. c 570 = 1 Conc. < 660 = 2 Conc.< 1100=3 + Conc. < 3000 = 4 + Conc. < 24000= 5

<- N

DEP S-I

C - FA -

.00 C c~ - LL 6

0 5000 10000 15000 20000

Cone. of Benzo (a) pyrene ppb in soil Benzo (b,k) fluoranthene ppb in soil

A t 4 1 I

+ z + 2 P5 P + g++ +1 + 0 Spp-+ + P E 5 4 GP 4.334 4+ + 53 1 + + 2 4N3 44 < p + 2 4 + 1 +G + F FJ 25 o P P & + + western Grace bardtr No detect = + Present = P Conc. < 480 = 1 Cone. < 950 = 2 Conc. < 1630 = 3 + Conc. < 8740 = 4 + Cone. < 182900 = 5

<- N

DEP S-1

C 0 O

CL 6C4

E w 0

0 50000 100000 150000

Conc. of Benzo (bk) fluoranthene ppb in soil 9 Chrysene ppb in soil

A ++ 4 + 4.4. + + +

z 0 + + + pP++ 44++ + + 3 pG P P -OG+ + 4 + + +434.+ :E +4+. + 3 +b1 p + + 2

1- P1+ p+ + + F+ PP4 +G + ++

+ + + western Grace border No detect = + Present = P Conc. < 800 = 1 Conc. < 940 = 2 Conc. < 2900 = 3 4. Conc. < 7200 = 4 4. Conc. < 26000 = 5

<- N

DEP S-1

RA C 0

LL CC C

CL EA C n 0

C 0

0 5000 10000 15000 20000 25000 S Conc. of Chrysene ppb in so Dibenzo (a,h) anthracene ppb in soil

4 + 2+

Pz + ++ 4+ + D5+ p+ + + Z+ + + ++

+ +G + ++ 44+ + + + + + +e p + + +P+ + + +

++ p+G+ + F + + + + F +5 +,+ P IP T+ + + + western Grace bordr No detect = + Present = P Conc. < 151 = 1 Conc. < 331 = 2 Conc. < 500 = 3 + +Conc.< 1410=4 Conc. < 25700 = 5

<- N

DEP S-1

C 0

020 E C LU

0 5000 10000 15000 20000 2500

Conc. of Dibenzo (a.h) anthracene ppb in soil Beryllium ppm in soil

A ++ + 55 ++

Z t+ + 5 1 4 + + +

1 5 1+34+ + tG+ +++ +~ +4 +~ +N < + 1 + 22 2 25G3 3 F ++ ++ 1 5 1 + 2 G+ + + western Grace border No detect = + Present = P Conc. < 0.26 = 1 Conc. < 0.34 = 2 Conc. < 0.45 = 3 2 Conc. < 0.6 = 4 Conc. < 2.8= 5

-N

DEP S-1 .0

o. AC

0 6

0.0 0.5 1.0 1.5 2.0 2.5

Conc. of Beryllium ppm in soil Cadmium ppm in soil

A 2'

~ 5( 1 '4 6 1 2 1 >2, z 2 1 5 5 ++ 2 +G+ 3 1 2 2 5 5 G + 3 + 2 5 2 M3 3 1 3 5 N3 44 2 5 45 4 + + + + + +4+ 3 ++ 5 +G+ + F 3 44+4 2_4 +G T + 5 3 western Grace borar No detect =+ Present = P Cone. < 0.6 = I Cone. < 0.91 = 2 Conc. < 1.3 = 3 + Cone. < 2.3 = 4 3 Conc. < 54= 5

<- N

DEP S-1

LL CL 6

O.. E w C4

0 10 20' 30 40 50

Conc. of Cadmium ppm in soil Nickel ppm in soil

21 1I 1 2 2 z 45 2 2 3 3 41 3 21 5 5 G S3 3 4 3 3 5 5 2543 3 1 I . 4 34 Sc 3 2 I- 23 +4 3 4 ) F 2

3 ' western Grace No detect = + Present = P Conc. < 6.1 = I Conc. < 7.8 = 2 Conc.< 10=3 2 Conc. < 14 = 4 4 Conc. < 640 = 5

c- N

DEP S-1

q -

C 0

(0 LI.

wE 0 0

L 0 100 200 300 400 - 500 600 0 Conc. of Nickel ppm in soil Lead ppm in soil

42 25

0 z 4 31 5 G 4 35 C1 1 2 2 3 13 E344 5 S35 44 3 5 N3 31 3 z . 1 2 45 4 1 2 + 51 7 3 + 11 5 13G 2 F 35 55 ,144 24 8 5 western Grace bordir No detect = + Present = P Conc. < 8.5 = 1 Conc. < 22.9 = 2 Conc. < 78 = 3 2 Conc. < 260 = 4 4 Conc. < 4900 =5

.- N

DEP S-1

0. -

CL ria

E 0 100 20'00P0050 C1

Conc. of Lead ppm in soil Zinc ppm in soil

A 22 2 21 1 1 C z 4 5 5 1 2 13 2 0 5 5G 3 13 E 3 4 1 4 4 31 2 44 4 N3 2 55 3 I C- 3 3 2 143 2 m 2 12G F 5 4 5 3 5 westem Grace bozr No detect = + Present = P Conc. < 18.4 = 1 Conc. < 42 = 2 Conc. < 110 =3 2 Conc. < 440 = 4 4 Conc. < 11975 = 5

<- N

DEP S-1

0 U C = CL C C

C *1 U E w

I 6 0 2000 4000 - 6000 8000 10000 12000 Sr- Conc. of Zinc ppm in sod Formaldehyde ppm in soil

A +

++4

z + + + 2 + 1 + ++ S2 3 G54 3 E 2 5 Nt 4 41 ++ N + + + ~4+ + + 5N + + 3 1 14 5 cn .+ + 12 + 1 4 5 F + + . + 3 2 + 4G 5 -

+ western Grace bordtr No detect =+ Present = P Conc. < 0.6 =1 Conc.< 1.1 = 2 Conc.< 1.8 =3 Conc. < 3.5 = 4 + Conc. < 220= 5

- <--N

DEP S-1

.RA

E o

0 50 100 150 200

Conc. of Formaldehyde ppm in soil Oil & Grease ppm in soil

A 1 + 2 + 4 z 3 4 4 4 + 43% 5 2 0 5 3 G 3 5 3 p 1 55 E 4 5 1 N + M 2 5 4 42 1 IN < 2 2+21 2 5 + 1 2 ;!,1 3 5 F .2 4+

westem Grace No detect =+ Present = P Conc. < 527 = 1 Conc. < 1580 = 2 Conc. < 4950 = 3 Conc. < 9930 = 4 4 Conc.< 81700= 5

<- N

* C a- I

CL I to

[I 0

0 20000 40000 60000 80000

Conc. of Oil & Grease ppm in sot 0 No DEP S-I Standards. Not used in risk assessment - Petrol Hydrocarbons ppm in soil 9

A 4 5 5 4 z 51 1 1 1 5 3 3 0 4 433 4 3 E 4 G 2 2 3 T1 g21 5 3 555 N 3 3 4 2 1N M4 2 1+2+ 2 4 12 32 G 2 2 F 2 3 2 3 2 2G i 44 4 western Grace bordir No detect = + Present = P Conc.< 10 =1 Conc. < 94 = 2 Conc. < 384 = 3 Conc. < 1109 = 4 5 Conc. < 7950 = 5

<- N 9

CI 1* * I

U- 0 / a. II 0 E w~ C4

0 I 1I 0 2000 4000 6000 8000

Conc. of Petrol Hydrocarbons ppm in soil

No DEP S-I Standards. Not used in risk assessment Trichloroethene ppb in soil

A +

++ +

0 ++ + +++ + ++ ++++ + + + E + + + + + + + ++ ++

++ + + + + in+ ++ ++ + + F 2+ + +4++-G* + + westem Grace boider No detect = + Present = P 1 has Conc. = 1200

<- N Arsenic ppb in ground water

A 3

5D 4 + 0 5 Ec G2 G 4 3 N31 M i I N 1 4 5 1 2 + A. G + 5 5 western Grace border

onc. < onE:.

<- N 9

DEP GW-2 q9-

- (0 C

S CL C

C" 0

I j I j i 0 100 200 300' 400 Conc. of Arsenic ppb in ground water a, Cadmium ppb in ground water

*1-

4 4.

+ + S + 0 4 G + E 4. 2 M ZC N + < + 2 4. F-2 4. + G + 1, 1 3 westerih Gracelborder o detect= + one. ~onc.< -onc<

<- N

DEP GW-2

c0 6]0

O 0L C 0

0a 100 200 300 400 500

Conc. of Cadmium ppb in ground water Chromium ppb in ground water

* 4 +

+ -4. 5 G + 2*Z M + N22 Et +4. N+ 3 4 + +. + 2 G0+ 4 5 western Grace border o detqct< + onc.s0c 2 nc. < =5

<- N 9

DEP GW-2

co c

U- 2D .

5 O.O-C. CL E

0 500 1000 1500 2000 Conc. of Chromium ppb in ground water 4, 9 Copper ppb in ground water

A +

+ 0 5 3 G + S + N14 M 31 3 N 1 5 5 1 F+ 2 +4 + A G3 5 5 westerh Grace border odtect =+ oresent = cncc = nCnc

9 <- N

DEP GW-2

. CD U-

0 20000 40000 60000 80000 100000

Conc. of Copper ppb in ground water Naphthalene ppb in ground water 9 I

p A +

0 + P 'C .4- 0 G + 2 C M + N25 1 * N4 < + + 3 4 + IS 2 *1 Q_3 13 + westeA Grace border o detect + 4 + resent onc. . onc. = 3 2 one.< 1 4 <- N 9 DEP GW-2

c 0 0

. c -

E w 04 0 -

0 0 I i 0 2000 4000 6000 8000

Conc. of Naphthalene ppb in ground water p0 Nickel ppb in ground water

St A-

+ + 5 0 m G + E + N2+ 0 M +I N3 < 3 4 I 2 G-+ .. 2 5 western Grace border Vode~t =+ nc onc. onc < onc.< 2.5 5

<- N p1

DEP GW-2

CL E *1

N 0

S 0

0 100 200 300

Conc. of Nickel ppb in ground water Lead ppb in ground water

A. 2 +

0 4 ES 2- G +1 + M N+5 m +t N+ < 1 I-- 3 G+ T. 2 5 westen Grace border o detect +

onc.< Onc. 5 onc<.c iE -

<-N 49

DEP GW-2

(0 IL 0 C a.

E N LU

0 100. 200 300 400

Conc. of Lead ppb in ground water Selenium ppb in ground water

A- + 2* + + 4.

0 +- Q+. G + EoC N+4 + 2* N+ < +. +4 B $ 3 *1 + W [i + + westemh Grace border

o endetectre=en+ o~nc.onc:. < Ig0gIn:

<- N 0

DEP GW-2

C 0

(D U.- c 0 * .. E I LU C

C 0

I I I I 50 100 150 200

Conc. of Selenium ppb in ground water Zinc ppb in ground water

A 3 2 1 3 0 5 G 2 E M 1 N 22 S 3 N 1 4 .5 03 I I 3 G 4 4 5 western Grace border o detect = + Sresent = cnc. oono <4 1 on. 9 onc. <

<- N

DEP GW-2

Co LL

CL e -E C, .

0 .

0 2000 4000 6000 8000 Cone. of Zinc ppb in ground water 0 9 Formaldehyde ppm in ground water

A- + 4 + 2 t + a1 G 3 E M + N54 2 ± + N + P- 3 + A G+ 5 + westemn Grace border o detect + oe. < one

9 <- N

DEP GW-2

.a (0

CL (0

E 0 (Li

I 0 2 4 6 8 10

Conc. of Formaldehyde ppm in ground water 1,1 -Dichloroethene ppb in ground water

+ + +

6I G + 0 E- M +N++

G-+ F - + -I- A- ++ *estem Grace border odetect=-.:+ + + rese =P as §onC. = 1.8 Us~g gn.. 9P +

<- N

0i Carbon Tetrachloride ppb in ground water

t + + +

G + 0 E M + 4* N+ + + + + +

U- ++ WesterIGrace border o detect =+i + rese +4 (3e &~*

<- N

Sp Benzo (a) pyrene ppb in ground water

A, + + +

+ -+ G +I + E M NP+ a +4 NP + + p P + Fl .5- ++ *resterit Grace border o de ct=+ + + rese = p as onc. = as onc. = as onc. = as lonc. = 0

<- N Benzo (ghi) perylene ppb in ground water

+ +

+ G + 0 + N++ . +E+ NP < + + p + T ++ westem Grace border o detect =+ + + seSe onc. 91$4

c-N Dibenzo (a,h) anthracene ppb in ground water

* +

+ + + G + 0 E M -'S N+i + +- -+ m + P RI 4. ++ . 4western Grac border o detect = + +- + rhas onc. = 4.4

<- N

4, 0 Indeno (1,2,3-cd) pyrene ppb in ground water

* 4 +

+ 4-

+ 0 + E M N+ NP + '1 I- + P + P s-i -fl ++ estem+Grace border 0o datoct =+ + + Sresent =P jas Qonc. =77 as uonc. = 5 as "cc=W5 +

<-- N Diethyl phthalate ppb in ground water 9

4 +

+ +

0 + 4 a+ G + E M N++ CD 4* *1- + 4- CO R- + + + - L ++ 'Western Grace border o detect = + + + has onc. = 31 + 9p

<- N 0* Mercury ppb in ground water

4 +

+ 4- E*

G + M + N++ +0 NI + + + + I-2 + .8 G+ , + lvesterriGrace border o det ct + regCsonc.= Sas uonc.=

<--- N Benzo (a) anthracene ppb in ground water

A- +

.4. + +- 01 G + E + + N++ IP < + + + p (. 2 p 2 ++ + westeri Grace border o detect = + + + resent = P ono. 64 oc onG c £ +

<- N 9

DEP GW-2 9-

C a 0 Ca 0 C,

CL C E w 01~ 0

0 C

4 6 8 10 12 14 16

Conc. of Benzo (a) anthracene ppb in ground water Benzo (b,k) fluoranthene ppb in ground water

X. 4. + 0 +

+ G + E M + NP+ 12 0: NP +- +- I- 4. +. P G03 11 ++ + westeri Grace border o detect = + +- + resent =P

onc- 4 4. onc. < 4 .4 =5

0 <- N

DEP GW-2

q |

C Co

N LC

Cl 0

E W e

II I I

10 20 30 - 40 b Conc. of Benzo (b,k) fluoranthene ppb in ground water Chrysene ppb in ground water

A- +

4i 4. +

G+4. S+ + G +. M + NP1 33 NP < + + c- P + 4 ++ + westeif Grace border o detect 4. resen P onc . Uoflc,on

<- N

DEP GW-2

c 0

'I- O -

E e ul C4I

10 20 30 Conc. of Chrysene ppb in ground water S- Phenanthrene ppb in ground water

0 '4 + +

+ A+ G + E M + NP2 +'P 2 N5 4: + + +. I- 3 + + 6I '" II ++ + westerr Grace border o detect +. + resen onc-< . 6 6 onc. on~c. - A Oflc. < 6.64 6666666667=4 4. ol'C. < -1 -

<- N

DEP GW-2 q -

C O a LL o C

*1 E

I I i I 10 20 30 40 60

Conc. of Phenanthrene ppb in ground water Bis (2-ethylhexyl) phthalate ppb in ground water

p A- +

0 4- 2 + 0* 0 + G S S M + N

+4 western2 Grace border resent 4- + onc.< 66=1 ono.

<- N 9

DEP GW-2

C 0

U- u.- 6 -t CL

6 Q6. E

0 - 100 200 300 400

Conc. of Bis (2-ethythexyl) phthalate ppb in ground water EOEA #5869

ALEWIFE CENTER Cambridge, Massachusetts

Volume ] of 2

- prepared and submitted by:

S aulding and 125 gh.Street Boston, Massachusetts 02110 617/523-8000

compiled by:

Abend Associates 265 Winn Street Burlington, Massachusetts 01803-2616 617/273-5383

January 16, 1996 I I TABLE OF CONTENTS

Transmittal Letter - Notice of Project Change

Table of Contents List of Figures List of Preparers Distribution List

MEPA Documentation. Waiver Certificate October 15, 1984- ENF January 27, 1986 MEPA Certif cate on ENF March 13, 1986 MEPA Certificate onDraft EIR March 12, 1987 MEPA Certificate on Final EIR January 20, 1988 MEPA Certificate on Supplemental Final EIR July 1, 1988

Technical Section 1. Project Summary 2. Project Description

4.Hnaadous Mateuials 5. Infrastructure 6. Wetlands S0 7. Flooding and Drainage 8. Transportation 9. Mitigation Summary 10.-Air Quality

Appendix - Materials in Volume I ITE Trip Generation Excerpts Vehicle Occupancy Data Trip Calculations and Backup Data Material Directional Distribution - Pass-By Trips MHD Section 61 Finding Mitigation Summary from Final EIR. Appendix - Materials in Volume 2 Traffic Count Data Level of Service Calculations Air Quality Appendix

Note: Volume 2 is a separate document of approximately 500 pages. If your copy of the report does not include Volume 2 and you want a copy, please call 617/273-5383 (Ann Cummings).

i List of Figures

3-1 Site Plan 3-2 Market Retail - Northern Elevation 3-3 Restaurant and Market Retail - Eastern Elevation 3-4 MBTA, Terrace and Restaurant - Southern Elevation 3-5 General Retail - Western Elevation 8-1 Intersection Identification Map 8-2 1995 Weekday PM Existing Peak Hour Volumes 8-3 1995 Saturday Existing Peak Hour Volumes 8-4 2000 Weekday PM No Build Peak Hour Volumes 8-5 2000 Saturday No Build Peak Hour Volumes 8-6 Comparison of Trip Generation - Original Project vs Currently Proposed 8-7 Trip Generation Projections 8-8 Converting Vehicle Trips to Person Trips 8-9 Employee/Customer Person Trips 8-10 Truck Trip Projections 8-11 Total Person-Trips by Type 8-12 Modal split of Various Trip Types 8-13 Person-Trips by Mode 8-14 Converting Person-Trips by Automobile Back to Vehicle-Trips 8-15 Pass-By vs New Trips - Customer Automobile Trips Only 8-16 Existing Traffic Distribution 8-17 Competing Opportunities for Shopping 8-18 Directional Distribution - New Trips 8-19 Weekday PM Project-Related Peak Hour Volumes 8-20 Saturday Project-Related Peak Hour Volumes 8-21 2000 Weekday PM Build Peak Hour Volumes 8-22 2000 Saturday Build Peak Hour Volumes 8-23 Level of Service Descriptions Signalized 8-24 Level of Service Descriptions Unsignalized 8-25 Level of Service Summary - Weekday PM Peak Hour Volumes 8-26 Level of Service Summary - Saturday Peak Hour Volumes 8-27 Pedestrian Routes at Alewife Center 8-28 Bicycle Routes in the Alewife Center Area 8-29 Bicycle Routes at Alewife Center

- - r 4 I- U III S U C

0 0 0 in I

L.J -

4 0 20 in taN

cc0~ z. a I- 0 0 -4 B EIR SCHEMATIC SITE PLAN ATTACHMENT

raURE ercs ,Area Descrip-tig1 I

( CURRENT (NPC) SCHEMATIC SITE PLAN ATTACHMENT C HAZARDOUS9 MATERIALS

si e is listed with the DEP as a Non-Priofity Confirmed Disposal Site as a result of volatile and semi-volatile organIcs, petroleum products, and metals found to exist in the environment during evaluations of subsurface and hydrogeological conditions for the Alewife Center Master Plan Study conducted in 1984 and 1985-. A'Notice of Responsibility (NOR) was issued for the site on 9 February 1987. The site is intermittently paved, and access to the majority of the exposed ground surface is restricted by fencing; however, access to some-open areas is unrestricted. The site has been assigned Release Tracking Number (RTN) 3-0277, with a transition date into the revised MCP on or prior to August 1995, and is in Phase IV of the MCP compliance process.

The redesign of the MCP allowed for the transitioning of disposal sites listed in the "old" system to the 'new" system within a time frame set forth in the regulations. In compliance with the Transitions Provisions of the MCP, a Tier Classification Form (BWSC-107A), Numerical Ranking System Scoresheet (310 CMR 40.1511), LSP Evaluation Opinion Transmittal Form (BWSC-1 10), and supporting documentation for the W.R. Grace & Co. property were submitted to DEP on 4 August 1995. Based on the available data presented, the site was judged to be classified as a Tier II (non- priority) site, indicating that continued work at the site could be conducted under the direttion of a Licensed Site Professional (LSP), and did not require oversight by the DEP.

Current development plans will result in a significant reduction in the e cavation and

d nf kno soisand groundwatrtihe lowest floor wi e approximately at or above theT6west site grade m the building footprint. Foundation support will be provided by piles driven into the ground without exposure to contaminated soils. No construction below the groundwater table is proposed. There will be no need to pump, treat and discharge groundwater to surface waters at the property.

Construction of pile caps. grade beams and site utilities il u in minimal excavation into soi know..o be conta.minatd h;ffis~ISin-sharp contrast to the hi-indreds of ousandsof cubic yar sSTEco'ntaminated soils previously proposed to have been' Cexcavated for the initial project.

t Site characterization and risk characterization studies completed for the property have been reviewed and accepted by the Department of Environmental Protection. There is currently no significant risk posed by the level ofcontamination present at the site. S :pplemental risk' characterization studies have been completed to supplement the prior DEP-approved risk characterization studies for compliance with the current regulatory program. This updated work also indicates no'significant risk under the present conditions and currently proposed conitruction. As part'of the MCP Phase IV compliance activities, additional field investigations and, chemical analyses have been undertaken to determine if portions of the property where oil and grease were previously detected a* elevated levels exceed the current standards for petroleum products. Those areas where the concentrations of Total Petroleum Products (TPH), determined by DEP- approved methods, exceed the Upper Concentration Limit (UCL) will be remediated to allow the property to obtain a permanent solution under the current MCP. The remediation program will be designed during the Phase IV studies, which remain to be comple ted. The program presently envisibned uses on-site asphalt stabilization of the petroleum contaminated soils and on-site reuse as subbase material under portions of the development project to be paved parking.

A Licensed Site Professional (LSP) will issue a Response Action Outcome (RAO) statement for a site in the MCP, indicating that a permanent solution has been obtained when the TIH materials exceeding the UCLs have been remediated. The permanent solution will include an Activity and Use Limitation (AUL) applied to deed which.will restrict certain activities on the property to preserve the current condition of "no significant risk".

The proposed development activities will be allowed by the AUL with the use of an Excavated Materials Management Plan (EvMrrP). The EMMP will be similar to the Hazardous Materials Management Plan (HMMP) developed for the prior site construction activities. However, since the current construction will not be excavating into significant quantities of known contaminated materials, the EMMP will be structured to provide contingency actions to be undertaken in the event that unexpected contamination is discovered during construction. It also will require the implementation of Health & Safety programs and construction management programs to provide safe conditions for the workers on site and public near the site during construction. This program wvill include management of construction vehicles, odor controls and dust controls, as well as requiring the use of personal protection equipment for on-site workers if shon-term exposure conditions warrant. NUS CORPORA TION INTERNAL CORRESPONDENCE SUPERFUND DIVISION C-583-6-6-106

TO: DON SMITH, EPA DATE: SEPTEMBER 5, 1986

FROM: GRETA D. READE COPIES: FILE SUBJECT: REVIEW OF HALEY & ALDRICH REPORT - "ENVIRONMENTAL ASSESSMENT FOR THE ALEWIFE CENTER MASTER PLAN, W.R. GRACE & CO., CAMBRIDGE, MASSACHUSETTS" TDD No. FI-8601-04 Reference No. $300MA575I

The TDD issued for this project (F1-8601-04) directed NUS/FIT to perform a standard Site Inspection of the W.R. Grace & Co. facility. However, since several studies and extensive sampling had already been performed, the EPA Project Manager directed NUS to visit the facility to obtain photodocumentation of current conditions and to review the April 1985 Environmental Assessment prepared by Haley & Aldrich. NUS/FIT has read and evaluated the Haley & Aldrich report dated April 1985 and titled "Environmental Assessment for the Alewife Center Master Plan, W. R. Grace & Co., Cambridge, Massachusetts." The report presents a large volume of data and presents conclusions which are favorable to the development planned for this property. Although it is apparent that considerable field work and ef fort werp put into this report and although the data presentation is reasonably good, the report does not clearly substantiate all of the conclusions presented. In addition, NUS/IFIT is concerned that the portion of the site chosen for development coincides with the most heavily contaminated areas.

In brief, the major comments on the Haley & Aldrich report are:

1. This report presents numerous conclusions. However, the basis for these conclusions is unclear. This is largely due to the fact that the data are presented and then the conclusions are listed with little or no discussion or interpretation in between. .This is particularly true of -the data and conclusions in Volume I (Subsurface and Hydrogeological Conditions).

2. Volume 3 (Environmental Risk Assessment) contains more interpretation, but the writer's opinion that, in general, chemical hazards are overstated is quite apparent. The final conclusion that "no actual or potential hazard to human health is presented by current or proposed development conditions" is not supported by either the data or the toxicological assessment presented.

3. The method that was used to evaluate the potential risk of this site did not take into account all of the possible routes of contaminant migration nor all the potential receptors. A cumulative risk for all receptors should be calculated. An accepted methodology for such a calculation is identified in Federal Register Volume 50, Number 6, pages 1170-1176 -

utS 064s112 C-583-6-6-106

MEMO TO: DON SMITH SEPTEMBER 5, 1986-PAGE TWO

(Proposed Guidelines for the Health Risk Assessment of Chemical Mixtures). Other useful guidelines are identified in Federal Register Volume 49, Number 227, pages 46294-46301 (Proposed Guidelines for Carcinogen Risk Assessment) and pages 46304-46312 (Proposed Guidelines for Exposure Assessment).

4. The method used to evaluate the potential risk to construction workers at this site hinges on the control of fugitive dust levels. Volatile organic compounds may be released at any time they are exposed to the ambient air. The approach used in Volume 3 does not take into account the total volume of soil that will be disturbed to generate the volume of fugitive dust expected in the ambient air.

5. More attention should be given to non-carcinogenic effects, particularly in the main text of Volume 3.

6. Many of the toxicological evaluations are based on concentrations found in composite samples. These do not accurately reflect concentrations which will be encountered on site since they are, in effect, average concentrations over a fairly wide area rather than concentrations for discrete areas on site. The actual value at any one point could be higher than the reported concentration.

7. Key details of the composite sampling procedures are not explained.

8. PAHs are considered as one toxicological group. They should be considered individually or in groups with similar toxicological properties.

9. The high levels of PAIs, naphthalene,. aid phthalates found in fill after construction are de-emphasized.

10. There is no discussion of the changes at the site which occurred as a result of the MBTA tunnel construction, and the patterns of contamination before and after tunnel construction are not discussed. These changes include the treatment and removal of a large amount of sludge, earth removal due to tunnel construction, and backfilling over the tunnel and in the areas where sludge material was removed. In particular, the report asserts that all source areas have been removed even though there is no discussion of the areas of removal or interpretation of sample results. The MBTA will state only that all visible waste contiguous to tunnel construction was removed. C-583-6-6-106

MEMO TO: DON SMITH SEPTEMBER 5, 1986-PAGE THREE

11. The text should clarify when sampling was conducted: both in absolute time and in relation to other events on site.

12. Russell Field was used as a staging area during tunnel construction. There is no discussion of possible contamination and no sampling has been done to substantiate the absence of contaminants in the staging area.

13. An inconsistent level of detail is used. This leads to confusion over what the authors think is important. Value-laden words such as "significant", "only" and "primary" are used without definition. This, combined with other types of lax word usage and a stilted style, causes problems with the conveyance of ideas. For example, "significant" can mean most common occurrence, highest concentration(s) or greatest threat to public health.

14. Much more could have been learned from the large volume of data gathered and presented. For example, the data indicate that there are still some pockets of high contamination left on site. The presence of these pockets of contamination was not identified. As a result, the risks posed by these pockets have not been completely evaluated.

Overall, the data presentation in this report is reasonably good; however, since a discussion of the data is lacking, the conclusions seem to be unsupported. Only a full-scale toxicological assessment could provide a complete evaluation of the validity of the methodology and conclusions presented in Volume 3. However, some comments are presented in this memo and.its attachment.

Recommendations:

1. The data generated from this report and previous reports should be validated and evaluated and interpreted in greater detail.

2. The data interpretation should be used to identify where further sampling needs to be done to identify remaining pockets of high contamination.

3. More sampling of the sediments in Jerry's Pond will be needed if the pond is to remain accessible to the public.

4. Due to its proximity to the former tank farm area, the cause of. the iron oxide occurrences in Parkway Pond should be identified. This anomaly might be the result of deteriorating metal receptacles and may presage the release of other substances. A magnetometric survey might be useful here and should be considered. C C

C-583-6-6-106

MEMO TO: DON SMITH SEPTEMBER 5,1986-PAGE FOUR

5. A baseline air quality study should be performed before the start of any construction.

6. Volume 3 should be evaluated or a Risk Assessment should be performed by a public sector toxicologist. As part of this activity, the public health and safety recommendations presented should be evaluated. In addition, the need for more detailed safety precautions for construction workers on the property should be evaluated (for example: air monitoring, dermal protection, respiratory protection).

Although NUS/FIT recommends that the above measures be incorporated into any further studies, these recommendations are not a commitment by EPA or NUS/FIT to conduct any further activities at this site.. Furthermore, these recommendations do not advocate which party or parties (EPA, NUS/FIT, State, Potential Responsible Party, etc.) should be responsible for conducting any further activities at the site.

Attachment

Reviewed and Approved By: _ . __ '"R. DNitto, RPM Date: - '- rC C 3.

ATTACHMENT

Detailed Comments on "Environmental Assessment for the Alewife Center Master Plan, W. R. Grace & Co., Cambridge, Massachusetts," by Haley & Aldrich, April 1985.

NOTES: The notation "Pg 23, P2" indicates that the comment refers to page 23, paragraph 2. If there is no bullet (@) in front of a new line, the comment is on the reference listed immediately above.

- Comments do not acknowledge work planned by W.R. Grace which is not mentioned in this report.

- Some comments are suggestions for improving the communication of ideas and facts to the reader.

- Also, some comments are likely to be attributable to different perceptions of the intent of the report.

DETAILED COMMENTS - Executive Summary

* Pg 3, PI - When did all manufacturing activities end?

* Pg 3, last P - How is "significant" defined? Formaldehyde is present somewhat less often than naphthalene and other PAHs but at similar concentrations.

* Pg 4 - Points 3 and 4 have little significance since most of the site and most of the samples are north of the tunnel.

Pg 4, Point 5 -

There are lead concentrations on the site as low as 3 ppm; in this context, those concentrations over 100 ppm represent contamination and are not typical of the area.

-There are several "pockets" of high, atypical concentrations of zinc and one value for copper which is an order of magrnitude larger than the other values.

What is a "'filled urban site"?

* Pg 5, P2 - Naphthalene is a PAH found in groundwater. The statement that PAHs are not migrating with the groundwater is not substantiated.

* Pg 5, P3 - The occurrence of 1,000 ppb acetone at B502 is not explained.

* Pg 5, P4 - This conclusion is not substantiated: there are 100 ppb formaldehyde, 26 ppb 1,1,1-trichloroethane, traces of naphthalene and

I phthalates, and high zinc at 8501; there are high metal concentrations at B3 and 88; there are no monitoring wells near Whittemore Ave. between B8 and B501; there is no attempt in this report to define what is or is not moving or at what depths (ie. contaminant plumes); finally, B3 and B8 are screened in the middle of the sandy layer while 8501 is screened near the bottom of this sandy layer. * Pg 5, P5 - One sediment sample and one surface water sample hardly justify such a sweeping statement for a pond of approximately 5 acres. Also, consideration is not given to the effect which use of the pond after development might have; could the sediments be stirred up, thereby releasing these compounds?

* Pg 5, last P - Not true: benzene, formaldehyde, phthalates and naphthalene were also detected.

* Pg 3-6 - The report is not consistent with what is reported: "substances tested for," "priority pollutants," "chemicals," ... some of these are the same and some aren't, it isn't immediately obvious to the reader.

NOTE: "Priority Pollutants" is no longer an EPA-defined phrase. The current terminology is "Hazardous Substance List (HSL) and Task I and 2 Metals".

* Pg 6, P3 - Where are air data and ground surface monitoring data to back this conclusion? The report does not clearly state that the test pits were done after sludge removal by the MBTA. Nevertheless, the concentrations found in the fill indicate a potential problem beyond construction.

* Pg 6, P4 - There is no contaminant migration analysis; how is it known where the contaminants are or where they're going?

There are no sections on water usage in the area; what evidence is there that there are "no routes for human exposure"? Which potential routes were looked at?

* Pg 7, P2 - As comments above and to follow indicate, this strong conclusion is not substantiated.i

@ Pg 7-8 - Recommendations - These recommendations contradict the strong statement made above in point 6. They imply that there are potential hazards to human health or the environment.

* Pg 7, last 2 P's - It would be helpful to set out general guidelines for use allocations (i.e., 'minimize excavation in areas ... , pave areas where ... I.

* Pg 7, last P - Detailed sampling for volatile organic compounds and acid and base/neutral compounds should not be characterized as a "normal procedure".

* Pg 8, P2 - A baseline air quality study should be done prior to the start of construction activities.

2 C C

* Pg 8, last P - Heavy metals in groundwater should also be monitored.

Proposed locations are good; however, care should be taken to ensure that the new wells are screened deeply enough to intercept any contamination which may be migrating along the top of the clay layer. This is a limitation in the use of data from B8. Also, a new well between 8210 and S2 would be helpful as there may be contamination migrating off site to the south of B210.

3 ( C

w DETAILED COMMENTS - Volume l

Text

* The transition from Dewey and Almy to W. R. Grace needs to be discussed. As the text stands, it appears that approximately 30 years of history (under W. R. Grace) are missing. What changes in production did this transition entail?

* Composite sampling of test pits does not yield very informative data since the actual value at any one location could be zero or up to four times the reported concentration. This point is not discussed.

* The act of compositing may have released some portion of the volatile contents of the samples.

* How were the test pit samples collected? Why were certain test pit samples composited with others? What was the rationale behind the groupings?

* No volatile organic compounds were detected in the composite samples even though there were volatile organics detected in nearby boreholes. What does this indicate? How were the composite samples collected and prepared?

* Pg 1, P3 - It is misleading to state that "all data from previous reports has been included" because the tables and interpretive statements of this report do not incorporate all previous.data.

* Pg 4-6 - The raw materials are listed, do these include processing agents, intermediates and catalysts? A table of all substances used on the site would be helpful.

* Pg 7, P1 - These comments are part of the EPA process which determines whether or not a site is a potential Superfund site. The statement that the site is not yet on any list seems irrelevant and inaccurate since it is being considered by this EPA process.

* Pg 7, P2 - Was the "DAXAD material" referred to here the finished product or its waste products?

* Pg 7, last P.- The statement that "all waste materials were removed from the site" is not substantiated. There is neither a complete definition of the waste that was deposited, (amount, locations and types) nor a description of the wastes that were removed.

Disposal was at Kingston, Massachusetts, not Rhode Island.

Are MBTA groundwater monitoring results discussed? Where?

* Figure 28 indicates that there were two types of latex produced, but the text makes no mention of this.

4 (

* Pg 8, PI - When was subway tunnel construction completed?

Was the quality of the dewatering water analyzed? What was the pattern of dewatering (i.e., locations and amounts/rates): this type of information might help explain the water table configuration after construction was completed. What month and year did dewatering cease?

* Pg 8, last P - Has sump water been collected and analyzed since the subway was installed? Discuss or refer to discussion.

* Pg 9, P2 - Who certified that the tanks were empty? On what basis?

* Pg 9, last P - What type of development is planned for Jerry's Pond? What kind of access is there to Parkway Pond? Will the new buildings have basements?

* Pgs 10, 11 - What types of analyses were done on samples from BI-B10 and B101-BIOS? I

* Pg 14 - The limitations of the HNu are not adequately explained:

- some compounds would not be detected by the HNu probe used.

- what are the optimum and/or generally expected sensitivities of the HNu?

- what are the benzene equivalents of the chemicals found on the site?

What was the purpose for doing HNu screening? Was it for worker protection/safety, to identify zones of contamination, both of these reasons, or some other reason?

* Pg 14, P4 - What is a "specially prepared" vial? Does this mean that it was labelled, that it was sterilized, that a preservative was added or ?

* Pg 20 - What is found between the depths of 31 and 55 feet? At what depth does argillite occur?

* Pg 21, P3 - Have upward or downward gradients been observed? Where? What magnitude?

* Pg 21, P6 - What kind of "indicator tests"?

What is the basis for the statement that "the majority of the groundwater and chemical movement occurs in the shallow sand and silt"? Is it site specific knowledge or general hydrogeologic expectations?

* PG 22, P3 - What are the elevations of the bottom and top of the tunnel?.

5 ( C

* Pg 22, P4 - Concluding that the groundwater passageway is not operating properly is premature until.the effects of dewatering have been investigated. This flow pattern could be a remnant of effects from dewatering. * Pg 22, last P - "An increased rate of flow ..." increased from what? previous visit? upgradient point?

* Pg 23, PT, 4th sentence - unclear.

* Pg 23, P2 - A figure is really needed to clarify the text.

* Pg 23, last P - It is unusual to have methylene chloride lab contamination above 100 ppb. Data from field and lab blanks should be used to determine whether or not a substance is a lab contaminant.

* Pg 24, PS - Concentrations of lead and zinc as high as 260 and 440 ppm hardly qualify as "typical of urban sites," particularly when there several concentrations lower than 20 and 40 ppm, respectively.

* Pg 24, P6 - What is the significance of the two HNu readings that were singled out for mention?

* Pg 25, among others - The concentration of lead is not "less than 570 ppm" if there is a concentration equaling 570 ppm.

* Pg 25, P2 - Why is acetone called the "primary" compound? "Most common" would be more accurate.

* Pg 25, P6,7 - The separation of "fill"and "naturally deposited soils" is awkward without interpretation. The use of "naturally" here seems to imply that acetone, MEK and MIBK are naturally occurring as well.

* Pg 25, last P - What is a "prominent" heavy metal? Which ones are referred to?

* Pg 26, PI - 93 and 130 ppm lead cannot be dismissed as typical urban values when nearby values range from 3 to 54 ppm.

* Pg 26, Area E - Internally inconsistent: "No ... volatile organic(s) ... found", then the text proceeds to discuss volatile organic compounds of 0.5 ppm and formaldehyde up to 9.8 ppm.

* Pg 26, P4 - The concentration of zinc is I LO ppm in Jerry's Pond sediment, not 'below 100 ppm'.

* Pg 27, P3 - Benzene to 311 ppb does not appear in Table III.

There are numerous other compounds listed on the data sheets but not -in the tables, especially for wells B211 and B212, at concentrations that warrant presentation and discussion.

6 ( C

* Pg 27, P 4,5 - Arsenic concentrations are worth mentioning.

* Pg 27, last P - The arsenic and chromium in this area should be mentioned, too.

* Pg 27-28 - There are a few values mentioned here that differ from the values shown in Table Ill. These discrepancies should be corrected.

Apparently only half of the groundwater wells were sampled for water quality. Why?

* Pg 28, last P - Is the sample at Si surface water or is it groundwater?

* Pg 30, P1 - There is little justification presented for the statement proclaiming that "All wastes ... disposed at the site ... have been removed..."

Laboratories generally use hazardous chemicals. It would be useful to explain what kinds and amounts of waste the current lab activities produce and what is done with it.

* Pg 30, P2 - Some of the figures have been mistyped. Also, the use of "up to" is inaccurate when the subsequent figure came from a composite sample.

* Pg 30, P3 - Most of these statements should have been discussed earlier rather than being presented first in the conclusions section.

* Pg 31, P3 - What are the implications and significance of these results?

* Pg 31, P4 - This paragraph is unclear. Where is groundwater being pumped now? Where will groundwater discharge? Prior work (GZD 1978) indicates that it discharges to Alewife Brook, a surface water.

* Pg 31, PS - The data indicate the probable presence of additional contaminated soil that may need to be removed and properly disposed of prior to development. However, the text does not discuss the areal extent of waste removal, the filling activities associated with the tunnel construction or the current patterns of contaminant concentrations so that this potential need can be evaluated. * Pg 32, P2 - Along with the recommended steps, another set of groundwater levels should be taken to define trends in the water table changes. Also, consideration might be given to investigating whether any of the measuring point elevations could have been changed during construction or related activities.

* Pg 32, P3 - Because of the composite nature of the test pit samples, these results are insufficient to justify onsite disposal of fill materials. In addition, there are probably fill materials left which perhaps should NOT be disposed of onsite. At the very least, this recommendation needs discussion and justification in the text.

7 C (

* Pg 32, P4 - This recommendation needs discussion and justification in the text.

* Pg 32, P5 - This recommendation should precede P3 and P4.

* Pg 32, PS - Sampling should not be confined strictly to building locations since future occupants of the buildings may be more at risk from open areas.

* Pg 32, last P - Groundwater quality during any pumping should be monitored and any required permits should be obtained.

* Pg 33, P2 - What "utilities" are anticipated to possibly disrupt the groundwater flow path?

Figures and Tables

* Sampling dates should be on tables.

* Figure 2B should be labelled to indicate the period of time this figure covers. Currently, it appears to neglect operations under W. R. Grace.

* Figure 3 - Buildings are illegible.

* Figure SA - Should refer to the source of this data.

* Table II would be more useful if actual values were listed. The analytical results of previous investigations should be tabulated; identification of results as 'pre-construction' or 'post-construction' would be helpful.

* There are more groundwater analysis locations depicted on Figure 8 than are listed in Table 111.

* Table I - It would have been helpful to have grouped these readings by compositing groups.

* Table 11 - Of some use, but all data should be in Table 3 style - including that from prior studies.

* Table II - Sampling date(s) should be reported. Was sampling pre- or post- waste removal?

* Table III - Phenolics and formaldehyde should be reported in ppb as are the other organic compounds.

8 ( (

DETAILED COMMENTS - Volume 2

* Appendices B and C - The log information in Appendix C is incomplete and some of it doesn't agree with Appendix B information.

* Appendices D, E, F, G, H and Figure 5B-- Where are A and DW series located?

* Appendix M Where are the new series A wells? Where is the data interpretation?

* Appendix N - There is no key to Arnold Greene lab data; what sample locations do the lab numbers refer to?

* Appendix N - Several compounds are found often enough and/or at high enough levels that they should be mentioned: most notably, methylene chloride (4 values not likely to be attributable to lab contamination), 2,4-dimethy[phenol, ethylbenzene and 2-hexanone (MBK). All of these appear at levels greater than 100 ppb and should not be neglected.

DETAILED COMMENTS - Volume 3

Text

* The discussion of how these guidelines were derived diverts the reader from a clear understanding of the conditions at this site. Only a brief outline of method, major judgements, and results should be in the main body of the report. An appendix discussing the derivations and the reasoning behind the guidelines might be an improvement. In particular, Sections 6.1.1 through 6.2 belong in an appendix. The level of detail included in these sections is informative, but is not directly pertinent to this specific site.

* The level of detail in the discussion of the areal extent of compounds (Section 2) is inconsistent: the occurrence of some compounds is discussed nearly borehole-by-borehole while other compounds (notably chromium, copper and zinc in water samples) are not mentioned.

As a minimum, this section should state for each compound whether it appears to be widely distributed or localized in a few areas. If there is no apparent pattern or correlation, that should be stated, too. (This is the type of discussion/interpretation lacking in Volume 1.)

* -There are several errors in the concentrations reported in the text.

* There are no groundwater samples downgradient and offsite. There are some wells which might be upgradient wells, but there is no undisputable upgradient well.

9 ( (

* There is no estimate of the amount of sludge deposited over the years, its composition(s), or how much was removed.

* Water and soil guidelines derived from TLVs are not valid as they don't account for any differences caused by the exposure routes, and this use is not in accordance with the intended use of the TLVs (next comment).

* The report is inconsistent in portraying the water solubility of naphthalene. - Both the Merck Index and Sax say that naphthalene is insoluble in water. Appendix E (pg 3) states that naphthalene is "fairly water soluble" at 30 mg/l; Table 4-1 states the solubility as 20,000 ppm and Table 4-2 calls it "moderately soluble." (References: The Merck Index. Ninth Edition. 1976; Sax, N.I. 1984. Dangerous Properties of Industrial Materials. Sixth Edition).

* Risk is assessed only for construction workers above ground or groundwater consumers. What potential hazard is there for workers in trenches? There is no attention to potential effects on long-term occupants of future development and little attention to surface water pollution. Potential risks to residents need to be more thoroughly assessed before being dismissed. In particular, this risk assessment should address the potential for of fsite contaminant migration.

* One surface water sample and one sediment sample are not adequate to characterize Jerry's Pond, particularly if the pond will become more available to public use after development. What are the plans for Parkway Pond?

* All PAHs should not be grouped for consideration: there are four known carcinogens found onsite; they should not be mixed with non- or potential carcinogens.

* Non-carcinogenic effects should receive more attention.

* References should be cited in the text of Volume 3.

* In the discussion of compound occurrences, the author infers judgements as to the importance of various compounds ("only" so much was found). This is inappropriate prior to the discussion of the derivation of the guidelines. * Pg 12, P2 - "these sites are close to original acetone storage tank." Only one of the listed sites is near and downgradient of 'the Acetone storage tank in the tank farm. Several concentrations, including the highest value of 680 ppb at BI, were omitted. Acetone contamination locations are over 500 feet apart; is this "close"?

0 Pg 13, P3 - "No other PA H was detected; thus. . ." The statements following the "thus" mislead the reader by appearing to draw conclusions which are not substantiated by subsequent paragraphs.

* Pg 13-15 (Section 2.1.6) - The basic results of the PAH analyses are lost in the discussion. These results are: (1) that there were several different samplings for PAHs which came up with a total range of ND to 356.9 ppm total PAHs and (2) that the PAHs appear to occur in pockets of high concentrations rather than evenly across the site.

10 ( C

" Pg 20, P1 - "... very few instances in which any chemical found in soil was detected in groundwater..." This statement is false. It only appears to be true because of the low number of groundwater samples collected. A comparison of the number of compounds found as a function of the number of times compounds were analyzed for indicates the opposite: groundwater samples were more likely to show contamination than soil samples. "The chemicals found in both include..." The rest of this paragraph is false. The error appears to be confusing presence or occurrence with concentrations: a trace concentration is an occurrence. Also, l,1,1-trichloroethane was found in groundwater but not in soil.

* Pg 20-21 - The discussion of detection limits and benzene would be helped if a detection limit (or range of detection limits) was given in the text or table. Benzene is no longer commonly used in laboratories due to its carcinogenicity. Unless benzene was detected in blank samples, its presence in the environmental samples should be accepted. * Pg 21, P3 - Samples S2 and 53 are not from Alewife Brook.

* Pg 21, last P - "measurable" concentrations: This implies that trace amounts are not there. The locations of trace concentrations should at least be mentioned; they are different findings than "not detected."

* Pg 22, P5, 6 - ".... the only concentration ... above a ... criterion" etc. True, but two other arsenic values are at or near the criterion.

Other metals should be discussed, especially those which were detected at or near criteria levels. In addition, drinking water criteria are not the only type of criteria which could be used for the purposes of comparison.

* Pg 22, P6 - A table of drinking water criteria would be helpful.

* Pg 22, last 2 P - Heavy metals (particularly Hg, Cr and Pb) should also be compared to typical values for the area (such as regional values or background samples).

* Section 3 - A sentence for each compound describing the use of each at this location and whether it was a raw material, waste product or end product would be helpf ul.

For EACH compound, discuss its fate in the body (ie.. is it cumulative, metabolized or eliminated?) Discuss what is known about synergistic or additive effects.

* P8 26, P2 - Are/were there underground or above ground pipelines transporting acetone or other chemicals? These should be discussed.

* Pg 28, P1 - What exposure route(s) are most common for carbon disulfide (inhalation, ingestion ... )? What type of exposure does the 10 ppm refer to ?

11 C C

* Pg 28, P3 - What is known about exposure to formaldehyde via ingestion?

* Section 4 - Need to define, briefly, each of the Partition Coefficients and what different values signify (i.e., higher than x means ..., lower than x means ... )

* Pg 38-39 - "... the half-life in soil would be on the order of 15 days ..." This statement suggests that the 680 ppb of acetone found at B! will degrade to less than 1 ppb in less than 6 months. This presentation ignores local conditions such as pH, hardness, other chemicals present, saturated vs unsaturated conditions, and soil characteristics. Also, it is unclear, but this suggested half- life of 15 days appears to be derived from degradation rates in water exposed to the atmosphere. These rates would not be applicable to groundwater conditions.

When was the last known new introduction of acetone to the site? How does this confirm or refute the 15-day half-life?

What does acetone degrade to? What compounds are produced when acetone "binds to fats, oils, etc."?

* Pg 39-40 - Where does the value for the water solubility of carbon disulfide come from? Verschueren (pg. 340) states water solubility as 2,300 mg/l. What is/might the effect of pH, etc., be on water solubility? (Reference: Verschueren, K. 1983. Handbook of Environmental Data on Organic Chemicals. Second Edition).

* Section 5 - Discussion revolves around basis for proof of adverse effects and amounts needed for serious and permanent damage. "Mild" reactions are discounted as being trivial and unimportant. Acute, chronic, synergistic and additive effects should be discussed, at least briefly.

* Section 6 - Some of the chemicals found at the site have explosive characteristics. This should be discussed since there might be a possibility that a construction crew could expose a pocket of high concentration.

* Pg 77 - The risks presented in Table 6-2 apply to particular sports or occupations and can be influenced by the safety habits of the participant. These voluntary, risks -should not be compared to risks posed by involuntary exposure to environmental contaminants.

* Pg 83, P2 - Define "significant" and "substantial margin of safety." A. risk acceptable to the developer may not be acceptable to future occupants of the development or to public officials.

* Section 6.4 (pg 87+) - Regarding the TLVs, the ACGIH states that: "They are not intended for use, or for modification for use, (1) as a relative index of hazard or toxicity, (2) in the evaluation or control of community air pollution nuisances, (3) in estimating the toxic potential of continuous, uninterrupted exposures or other extended work periods ..." This report uses the TLVs in a manner for which they were not intended to be used. (Reference: ACGIH (American Conference of Governmental Industrial Hygienists). 1984. TLVs: Threshold Limit Values for Chemical Substances and Physical Agents in the Work Environment and Biological Exposure Indices with Intended Changes for 1984-85. Pg. 2). 12 C (

The use of permissible exposure levels (PELs) for dusts to set exposure criteria for chemicals contained in site soils is not obviously valid. The question for volatile chemicals is not how much will be inhaled as it is attached to dust, but how much will be released into the breathing zone by construction activities and inhaled.

* Pg 87 - The rationale behind the assignment of the safety, factors is not adequately explained. Since a change in some of the safety factors changes the comparison between guidelines and soil concentrations, the rationale should be clear and solid.

* Pg 88, P2 - The discussion of the number of samples exceeding a guideline is incomplete: need to add discussion of composite samples and total number of samples ("only 7 samples" means one thing when the total is 700 samples and -another when the total is 8 samples).

* Table 6-5 (Pg 89) - Many of the high soil concentrations come from composite samples; these numbers do not represent a true high value since 3 or 4 samples were mixed. Some of the samples would have higher concentrations than the average (i.e., reported) value, and some would have lower concentrations. If the derivation of the soil guidelines were acceptable, this point could be critical for evaluating PAH and copper concentrations, among others.

Why was cyanide omitted?

* Pg 91, PI - This.paragraph is inaccurate:

.a) Acetone is both volatile and water soluble, and it is found in high concentrations in water. Table 4-6 is not an accurate list of physical properties.

b) It is apparent from the water quality in wells B210, B211, B212 and B502 that naphthalene is not the only substance likely to migrate off the site.

c) There is no conclusive evidence that ALL sulfonated naphthalene sludge has been removed: in fact, the high values of naphthalene found in 4 of the 6 composite soil samples indicate that naphthalene may be present in large amounts'across the entire site.

d) Even if all sources of naphthalene have been removed, large concentrations have already migrated from the source(s) and will continue to migrate for some time. Migration directions and probable rates of migration should be discussed.

* Pg 92, p 2, 3 - Dust control is important; however, monitoring and proper protective clothing may be equally important.

13 Figures and Tables

* The arsenic value for B3 is incorrect on Table 2-2; there are several similar errors on this table.

* pH and specific conductivity values should be tabulated.

* Table 2-2 - Should use consistent units. For example, cyanide and formaldehyde are listed as ppb on one page and as ppm on another. The values presented are not always consistent with the data presented in Appendix N.

* Tables 4-1 and 4-2 - The properties aren't consistent between the two tables and in the appendices.

How is zinc biodegraded?

* Table 6-4 - Total cyanide was found at 10 ppb; the guideline should be included.

* Table 6-6 - Are these Recommended or Recommended MAXIMUM Soil Levels?

PAHs shouldn't be grouped together - their properties vary too widely.

Appendices

* Seation 6.4 - The derivation of water guidelines from the TLVs is not a standard and accepted method.

* The use and purpose of conversion factors are not discussed.

14 REVIEW OF THE DRAFT EIR AID RELATED ENVIRONMENTAL ASSESSMENT DOCUMENTS FOR THE PROPOSED ALEWIFE CENTER DEVELOPMENT AT THE W.R. GRACE AND CO. PROPERTY IN CAMBRIDGE. MASSACHDSKITS

* * eDRAFT VINAL REPORT * *

John D. Spengler and C. Mark Smith Harvard School of Public Health Dept. of Environmental Sciences and Physiology 665 Huntington Ave. Boston. MA 02215

Haluk Ozkaynak and Donald J. Fingleton Harvard University Energy and Environmental Policy Center 65 Winthrop Street Cambridge. MA 02138

Prepared for: City of Cambridge Dept. of Health. Hospitals, and Welfare 1493 Cambridge Street Cambridge. MA 02139

FEBRUARY 19. 1987

- I TABLE OF CONTENTS

I. Introduction ...... 1

II. Summary of Findings ...... 2

III. . Site Assessment Evaluation ...... 3

111.1 Chemical contamination: composition. concentrations, and distributions ...... 3

111.2 Site hydrogeology and surface water *...... 5

111.3 Risk assessment ...... 5

111.4 Mitigating measures ...... 7

IV. Recommendations ...... 8

IV.1 Chemical contamination: additional sampling requirements ...... 8

IV.2 Site bydrogeology and surface waters ...... 11

IV.3 Exposure and risk assessment ...... 12

IV.4 Mitigating measures and other recommendations.. 18 I. INTRODUCTION

As part of an ongoing evaluation of the potential environmental and

health implications of the proposed Alewife Development Project. the City of

Cambridge has retained the services of researchers affiliated with the Energy

and Environmental Policy Center (EEPC). Harvard University and with the

Harvard School of Public Health (RSPH) to evaluate the draft EIR and related

site assessment documents. Harvard staff involved in this effort include

individuals experienced in risk assessment, toxicology, hazardous waste

management, and air pollution monitoring. The review and assessments were

conducted under the direction of Prof. John D. Spengler (HSPH) and managed by

Dr.. Haluk Ozksynak (EEPC). Principal scientists working on the project also

included Mr. Mark Smith (HSPH) and Mr. .-Donald J. Fingleton (EEPC). a Harvard's evaluations included the undertaking of two tasks. The

first task was the general review of the recent Environmental Assessments

documents and the draft EIR for the purposes of outlining a risk assessment

study relevant to the proposed commercial development of the former 1.R. Grace

site near the Alewife Brook Parkway in Cambridge. The second task consisted

of the evaluation of recent monitoring and test data and the December 1987

draft EIR prepared by the project proponents and its contractors. Our

multidisciplinary review attempts to address the concerns regarding the

adequacy of the measurement programs conducted to date as well as the health

risk assessments performed by the project consultants.

The following comments summarize an extensive evaluation of the site

assessment of the proposed Alewife Development Project. We have focused

exclusively on the human and environmental heaith risks posed by the chemical

wastes found on the site and have not considered the potential health risks

-I- associated with other aspects of the development. Our evaluation includes a

summary critique of the material presented in Monacelli Associates Inc. draft

EIR and the three-volume Haley and Aldrich. Inc. Environmental Assessment

report for the proposed Alewife Center Development Project (December 1985).

In addition to these primary reports, we havei also evaluated the following.

1. Correspondance to Don Smith (EPA) from Greta D. Reade (NUS Corp.)

on June 20. 1986 providing review comments on the Haley and

Aldrich report "Euvirotmental Assessment for the Alewife Center

Master Plan, W.R. Grace and Co., Cambridge. Massachusetts."

2. W.R. Grace and Co. response to comments of Greta D. Reade (NUS

Corp.) dated October 27. 1986.

3. Various inter-office correspondances from the City of Cambridge

summarizing highlights from project-related meetings with DEQE,

the developers and their consultants, and the public.

4. Report on Long-term Chemical Monitoring Program, Alewife Center,

Cambridge, Massachusetts by Haley and Aldrich, Inc. (February

1986).

5. Supplemental Soil and Groundwater Data, Draft Environmental Impact

Report. Alewife Center. Cambridge. Massachusetts by Haley and

Aldrich, Inc. (January 7, 1987).

6. Notice of Responsibility (based on 1985 Haley and Aldrich report).

from the Massachusetts Dept. of Environmental Quality Engineering

(DEQE) and transmitted to W.R. Grace and Co. on.February 9, 1987.

II. SUMMARY OF FINDIGS

Based on our review, we conclude that the draft EIR and associated materials do not provide an appropriate analysis of potential health hazards

-2- posed by this site as it currently exists, or as it will exist during

construction or following completion of the proposed project. Therefore,

stated claims that development of the site will present no risks to the health

and safety of the public are not adequately supported., Furthermore, this

draft does not adequately address the concerns voiced in the Certificate of

the Secretary of Environmental Affairs on the Environmentil Notification Form.

reSarding hazardous materials, in that it does not summarize nor discuss the

EPA evaluation of the site assessment. We recommend additional data

collection and formal exposure and risk assessment studies be performed as

part of the finalization of the EIR.

III. SITE ASSESSMENT EVALUATION

DBQE's recent Notice of Responsibility, prepared for the proposed

development site, addresses the requisite site actions necessary for the

evaluation of the potential hazards and the remedial action plans associated

with the manufacturing wastes disposed within the former W.R. Grace property.

We find all of DEQE's information requests, in terms of gathering additional

data and conducting further assessments, quite appropriate. In this section,

we discuss a number of issues similar to those raised by DEQE and additional

areas of concern regarding the existing information bases, chemical

contamination, site hydrogeology and surface waters, risk assessment, and

mitigating measures.

III.1 Chemical Contamination: Composition, Concentrations, and Distributions

The site assessment includes an extensive data base generated from

numerous samples and detailed chemical analyses of many of these. In general. aI the chemical analyses performed appear appropriate in light of the past

-3- history and known chemical contamination of soils and groundwater at the site.

These analyses clearly indicate the widespread occurrence of a variety of chemical contaminants, in both the groundwater and soils of the site. unfortunately, the usefulness of much of this data is questioned because, in many instances, chemical analyses were performed on composited samples. In addition, many areas on the site were not covered in adequate detail. The most recent set of samples (i.e.. Supplemental Soil and Groundwater Data.

Draft EIR. Haley and Aldrich, Inc, January 7. 1987) provide a better coverage of the limited areas tested and detailed chemical analyses of non-composited samples. However, these samples still are restricted to the so-called

"footprints" of the development. Although we realize that it is impractical to test all areas of the site, we believe additional sampling is needed to adequately evaluate the nature of and .distribution of chemical astes on the site. In general, we believe that it is appropriate to concentrate detailed sampling to the "footprints" of the development, but we do not believe that it is appropriate Lo restrict detailed sampling to only these locations.

Obviously, excavation of soils and dewatering of the "footprint" areas will pose the greatest possibility of mobilizing chemical wastes from the site.

However, construction is very likely to result in significant site alternations and disruptions extending beyond the "footprint" areas. These alterations could result in changes in surface water and groundwater flow as well as mobilzation of contaminated soils. Furthermore, the definition of

"footprint" areas must be expanded to include utility and sewer line access routes and construction staging areas. Additional comments and specific recommendations regarding additional sampling needed are presented in Section

IV.1.

rn_-h .1112Site Hydrogeology and Surface Water

The potential for water mediated migration of these chemical wastes from the site needs further evaluation. Although several groundwater flow studies have been completed, the nature of groundwater movement on the site is confusing and requires clarification. Contradictory statements appear to be made between the draft EIR. and the most recent supplementary data provided by

Haley and Aldrich. The first reference indicates a northerly flow of groundwater while the second indicates the flow is radially in all directions.

This appears to be in conflict with the recent experience of groundwater seepage into the MTA tunnel. Additional information is needed to evaluate the current situation before attempting meaningful predictions of the impacts of the proposed development on groundwater flow.

Additional consideration of surface water flow also is needed, especially with respect to potential outcomes of flooding on the site which lies on the 100-year flood plain of the Alewife Brook. Impacts of construction, excavation, movement of contaminated soils on-site, and other aspects of the development project on flooding of the site and the potential for flood water mobilization of contaminants should be addressed.

Additional comments and recommendations regarding these issues are given in Sections IV.2 and IV.3.

111.3 Risk Assessment

Volume 3 of the Environmental Assessment: Proposed Alewife Center

Development, cited in the draft EIR. presents what is described as a "Risk

Assessment" of the health risks posed by development of this site. At best it is a qualitative risk assessment and we are critical of many aspects of this document. A report which lists detailed comments on this assessment will be

-5- made available to the City of Cambridge, Department of Health and Hospitals.

In summary, this risk assessment presents an inadequate assessment of potential exposures which might occur at this site before, during, and after construction. This makes it impossible to assess the levels to which the public might be exposed from contaminants found at the site. The document also fails to consider the potential impacts of a number of compounds found.at appreciable levels in the soils or groindwater at the site. .

A discussion regarding our concerns with this document follows. In the risk assessment, concentration guidelines, or threshold levels, for a number of compounds are derived. These are estimates, of the concentration in water or soil at which no significant hazard to human health is posed. The estimates, however, are not always based on appropriately conservative assumptions when considering the protection of public health. Nonetheless. sample data indicate that four contaminants at this site are found in concentrations exceeding these guidelines. In each instance these findings are said to be insignificant and that no health threat is expected. The author argues that since the guideline values incorporate a safety factor. no significant health risks are posed by concentrations that do not substantially exceed the guideline values. This ignores the rationale behind using safety factors in the first place. Safety factors attempt to account for the uncertainties involved in calculating guideline or threshold values and the existence of sensitive subgroups or individuals in the population (elderly, children, etc.)

In conclusion, we believe an appropriate risk assessment of the site has not been performed. Such an assessment should be required and will be useful in determining how this -site should be developed. Specific methodologies for such an assessment should be determined in consultation with

-6- the City of Cambridge. DEQE, and other appropriate groups. We present a number of suggestions for such a study in Section IV.3.

III.4 Mitigating Measures

A variety of mitigating measures, to minimize the potential for adverse health impacts, are proposed in the draft EIR and related documents.

It is clear from these proposals that the consultants have identified many of the problems which must be dealt with at this site to insure public safety.

However, in many instances, insufficient detail is presented in these documents to evaluate the adequacy of the proposed mitigating efforts. - These limitations and recommendations to improve this situation are detailed in

Section IV.4.

-7- I. RRCOMMENDATIONS

IV.1 Chemical Contamination: Additional Sampling Requirements

1. The "footprints" of sewer and utility connections must be determined and

detailed chemical analyses performed on soil and groundwater samples

taken at intervals along these routes. At a minimum this will be needed

to determine appropriate disposal alternatives for the materials

excavated.

2. Construction staging areas should be specified and detailed chemical

analyses performed on soil samples from these areas.

3. Additional surface and sediment samples should be collected and analyzed

from Parkway Pond and Jerry's Pond. This is of particular concern if

alterations to either pond are undertaken and if these alterations result

in movement or mobilization of sediments.

4. Few data from long-term chemical monitoring of surface and groundwater

outside the development area indicate the presence of certain volatile

organic compounds, some of which are known to be toxic. Additional

sampling (spatially and temporally) needs to be undertaken to be able to

resolve the sources and pathways of pollutant transport to areas away

from contaminated soils.

5. Any soils to be used as fill for any alternations of these ponds should

be sampled and subjected to detailed chemical analyses.

-8- 6. As a test for contamination of Alewife Brook. a number of surface water

samples have been collected from this waterway. However, it is likely

that a number of compounds (which might derive from th: W.R. Grace site),

would be found preferentially bound to bottom sediments. Therefore, we

suggest that sediment samples of Alewife Brook be collected and tested.

Samples should include controls taken upstream of the site, a sufficient

distance to insure that little or no inputs from the site could reach the

sample location, and samples immediately downstream from the site.

7. To provide a measure of compounds migrating with the groundwater, it

would be useful to sample leachate collected at the MBTA tunnel. The

possibility that contaminated groundwater is moving off this site via the

tunnel cut needs to be evaluated as well.

8. Surface and groundwater samples from the Russell field area, the site

used a staging area during the MBTA station construction, will be useful

to examine the potential contribution of other sources to the present

soil and groundwater contamination.

9. Additional sampling of former waste lagoon areas should be done to

confirm that the wastes previou3ly stored there have, in fact, been

adequately removed.

10. Additional sampling outside of the "footprint" areas and those additional

locations noted above may be required to characterize the distribution of

compounds on the site. As mentioned above, many of the previous samples

were composities of materials from a number of locations making it difficult to identify hotspots of contamination on the site outside of

the "footprints." An appropriate sampling regime to identify any such

hotspots should be developed in consultation with DEQE. Once a better

understanding of groundwater movement on the site is obtained additional

groundwater monitoring stations may also be needed.

11. It is very difficult to access, in a clear and comprehensible fashion,

the large amount of sample data already existing for this site. It is

often difficult and sometimes impossible to correlate sample numbers with

sample locations. The consultants to Grace/Hines should be required to

summarize this information in a clear fashion including results of

previous sample analyses. Acetate overlays of sample locations and

levels of contamination, color coded, would be useful. This would allow

individuals reviewing the sampling data to determine distributions of

compounds on site.

12. Results from other monitoring efforts in this area, in particular those

conducted by the )BTA should also be obtained and presented in the EIR.

13. Air sampling for volatile organics compounds (VOCs) should be carried out

both before and during the excavation phase of the project. Since it is

critical to determine the location and the emission rates of the various

contaminants, we recommend exploratory monitoring of VOCs in the

excavation pits after a small amount of soil has been removed.

Generation of spatial profiles of the concentration of compounds of

interest will be helpful in developing empirical ambient emission rates

for the toxic compounds that are of concern to the health of workers and

-10- population living nearby. Monitoring plans during the construction

should include collecting short-term VOC samples downwind of the site as

well as real-time odor detection methods which could be used for

implementing immediate work stopage and/or other actions needed to remedy

the source of emissions or odor problems.

IV.2 Site Hydrogeology and Surface Waters

1. The directions and rates of current groundwater and surface water

movement on the site must be clarified.

2. Groundwater modeling may be needed to investigate the effects of

construction on groundwater flow patterns and rates. Should such

modeling be performed it is important that model limitations, rationale

for input parameters, and uncertainties be explicitly and clearly

presented. Sensitivity analyses should also be included to investigate

the effects of differeing sets of assumptions on outcomes. Additional

consideration of surface flow patterns and rates is also needed.

3. The potential migration of hazardous materials from the site by the above

routes requires additional attention. The groundwater modeling effort

should be extended to include modeling of pollutant transport in soil.

groundwater, and surface waters. Appropriate variables regarding

pollutant migration and decay (e.g.. distribution coefficients based on

fractional organic carbon content, decay constants/hydrolysis rates.

infiltration rates. etc.) need to be considered in such model-based

evaluations.

-11- 4. Possible penetration of neighborhood basements by groundwater originating

from the site, potentially carrying hazardous compounds, should receive

further consideration. It would be desirable to develop a baseline data

set of the current situation, that is, the current prevalence of basement

flooding problems in the community durrounding the proposed development.

Such a baseline might be obtained'through consultation with DBQE and the

City of Cambridge. Should additional groundwater work suggest movement

towards peripheral communities, additional groundwater sampling,

especially of shallow groundwater that might enter basements or reach

surfaces, needs to be performed.

5. The possibility that sewer and utility line connections might serve as

conduits for the flow of contaminated ground and surface water from the

site should be addressed.

6. The possibility that construction on the site may connect shallow

groundwater with deeper aquifers beneath the clay layers must be

analyzed. Penetration of the natural clay barrier could result in

contamination of deeper groundwater.

7. Since the site lies on a 100-year flood plain, possible impacts of

flooding (and of development on flooding) on mobilization of contaminants

needs consideration.

IV.3 Ezposure and Risk Assessment

It is imperative that a comprehensive population-based exposure and

-12- risk assessment study be performed for the Alewife Center Project. The

information provided by an exposure and risk analysis may then be used in the

regulatory process to decide upon the nature and extent of remedial actions

that must be taken at this site prior to. during, and after construction to

protect public health. Such a risk assessment must be performed using

scientifically aceptable protocols (for example, EPA's exposure and risk

assesment guidelines published in the Federal Register within the last 3

years), and should specifically address the technical issues noted in this

report, in the DEQE Notice of Responsibility, and the concerns voiced by

members of the community near the site. In addition, the assessment should

consider the types of information and format of presentation required by or

best suited to the various regulatory bodies involved (e.g.. DEQE and City of

Cambridge).

In the following, we provide the essential elements of an exposure and

risk assessment for this commercial development. It is also important to

recognize the necessity of explicitly accounting for the sources and, where

possible, the magnitudes of the uncertainties associated with the

exposure/risk calculations Additionally, the analysis should identify

situations and potential problems that might significantly alter projected

health effect estimates, and identify additional data needed.

Components of a recommended exposure and risk assessment

A. Identification of hazardous materials/source terms

1. Identification of the types of hazardous/toxic materials on the site, or

potentially on the site, based on sampling and chemical tests as well

as information relating to past and current uses of site. 2. Determinations of the concentrations of these compounds on the site

a) average concentrations

b) maximal concentrations, these may be based on extrapolations from

soil to water and the converse, when samples from one media suggest

higher concentrations than sampled in the other. Must use appropriate

partition coefficients and site conditions.

3. Determination of distribution of compounds on the site

a) environmental compartment contaminated

b) areas of maximal concentration-hotspots

c) gradients of distribution

d) possible sources of continuing and future contamination-storage

tanks, barrels, transfer pipes, etc.

e) projected effect of development on above

This determination should extend to the entire site not just the area

to be built upon. Construction may disurb adjacent areas. may alter

runoff and subsurface water flow.

4. Analysis of potential for and possible routes of migration of

contaminants off the site sins this is very important considering the

population density of the area and its proximity to drinking water

supplies. Projected effects of development on altering the migration

routes and amounts of contaminants from the site.

B. Determination of health effects and risk potency terms db1. Identification of potential health effects of compounds that are either

-14- found on the site or could be found in the future through mobilization

of wastes still buried in the site

a) initially, this should extend to all compounds found or expected to

be found, not just those detected at highest concentration

b) should consider carcinogenic and non-carcinogenic health effects of

both acute and chronic nature

2. Determination of possible real health effects and their "seriousness"

necessitates consideration of potency terms

a) potencie./exposute limits etc. used, for a site like this, should be

the most conservative scientifically defensible. Sources should

include reviews of EPA, DEQE, other state lists, and the literature.

Limits should involve safety factors, depending upon nature of data

used, 10-100x is generally considered advisable in cases where

threshold of effects are known to exist.

3. For carcinogens and suspected carcinogens available EPA/CAG potencies

supplemented by the NTP bioassay data should be used in developing and

using cancer unit risk estimates for oral and inhalation routes. Other

federal or state guidelines and standards (e.g.. EPA's water quality

and Massachusetts' air tozics guidelines) should also be used in

selecting and applying risk/potency coefficients or limits for the

chemicals studied. In these determinations distribution or range of

values for source strengths and concentrations should be used in

yielding worst case as well as expected or typical health impact

estimates. Finally, for non-carcinogens sources and basis for choosing

a certain threshold value should be explicitly and clearly stated.

-15- C. Exposure and dose predictions

1. Consideration of all individuals and populations at risk. Exposure

estimates need to be developed for construction workers, neighbors.

occupants, and site users after construction, children, and others who

presently may have access to the site. and non-neighboring communities

which may be affected (e.g.. exposed population downstream of Alewife

Brook, consumers of well water that might be contaminated, recreational

users of the ponds impacted, etc.). All possible exposed groups and

not exclusively the major ones should be addressed. The rationale for

concluding that some potentially exposed groups will not be exposed

should be clearly stated and supported.

2. Consideration of all possible routes of exposure, such as ingestion.

inhalation, and through dermal contact, need to be quantified.

Determinations must be made about the individual factors that affect

time spent in each microenvironment by different populations and age

groups. Chemical-specific integrated exposure and dose estimates need

to be developed using conservative assumptions about bioavailability.

lung deposition, retention, and clearance by the target organs, skin

absoption rates, among others. An attempt should be made to develop

exposure estimates for various population groups, including sensitive

individuals such as the elderly, children, and persons with pre-

existing health conditions. Both ambient outdoor and indoor exposures

to possible contaminants released from the site should be quantified

using monitoring data and acceptable modeling methods. In particular,

possible pollutant exposures in homes through airborne releases from

vet basements should be evaluated.

-16- 3. At a minimum, exposure estimates for the following compounds need to be

developed; naphthalene, polyaromatic hydrocarbons (PAH) and phtbalates

(with complete breakdown), acetone, methylene chloride, carbon

disulfide, formaldehyde, cyanide, chlorobenzene. etbylbenzene. benzene,

toluene. phenol. styrene. N-nitrosodiphenylamine, acenapthene, 1.1-

dichloroetbene. .1l-dichloroethane.tetrachloroethylene, and all heavy

metals.

4. Assuming a worst case situation, estimates of doses received by the

members of the groups identified before should be determined. The

extent that the construction is expected to alter the exposure patterns

and dose estimates must be determined. In addition to worst case and

"likely to occur" impact scenarios, sensitivity analysis involving each

of the key calculation steps need to be performed.

D. Risk Projections

Based on the estimated doses and the potency factors prediction of risk estimates for (1) the maximum exposed individual, and (2) different groups of affected population. Risk projections should be presented for each exposure pathway as well as based on total exposures. Carcinogenic and non- carcinogenic risks including allergic responses and other sensitization effects should be individually treated. Because of inherent uncertainties in each step of the risk calculation, a proper error analysis including formal statistical error propagation methods should be included. The predicted health outcome probabilities should be contrasted with other non-voluntary

(preferably environmental) health risks. An evaluation should be made whether

-17- the predicted risks are significant and/or unacceptable, using criteria

employed by EPA and other regulatory agencies such as FDA. Finally, risk

estimates should also be developed and analysed for alternatives to the project, in particular, construction versus no construction scenarios.

E. Remedial Measures

It is appropriate to consider various alternatives or remedial measures that might minimize the possible health and odor impacts of the site during and after construction. Even if it is concluded that the likelihood of adverse effects is small, it is still advisable to consider certain mitigative measures to address specific health (and welfare) concerns of the public.

IV.4 Mitigating Measures and Other Recommendations

1. The project -proponents should provide more extensive documentation

confirming that all chemical storage containers and transfer pipes have

been removed from the site or appropriately emptied. The continuing.

rather high levels of acetone contamination on certain areas of the site

is troubling and raises the possibility of continued acetone inputs to

these areas, possibly from unidentified leaking transfer pipes or other

containers still buried.

2. Contingency plans should be formulated to deal with unexpected

developments during construction. Such events might include the

discovery of previously unidentified chemical containers, transfer pipes.

or pockets of highly contaminated soils. These plans might include

-18- requirements that any such events be promptly reported to DEQE and the

City of Cambridge and that construction activities cease until such time

as the materials are safely removed and, if necessary, chemically

analyzed.

3. Steps to protect workers during construction need to be specified in -

greater detail. The consultants to the proponents correctly point out

that such measures area needed due to .the levels of contamination at the

site. They indicate that "the Contractor will be required to provide a

comprehensive worker health and safety program" for the site. It would

appear that sufficient information exists at this time to address this

problem in greater depth. It would be desirable that additional details

on the nature of any anticipated risks and possible mitigating measures

be presented in the final EIR. It- should be noted that measures which

appear sufficient to protect worker health, for example, respiratory

protective devices, often in fact do not provide adequate protection

because compliance by employees during actual working conditions may be

difficult or impossible. Because of this, we suggest that worker safety

requirements include training/educational sessions be provided to workers

to inform them of the chemical hazards at the site and to train them in

proper use of any suggested safety devices or procedures. The overall

worker safety program should be reviewed and approved prior to.the start

of construction.

4. Excavation work on the site is likely to result in the generation of

significant chemical odors, which are likely to be noticable in the

surrounding community-. Although this possibility was correctly

-19- I.antified in the site assessment documents, no mention of this is made

in the draft EIR. Although it is likely that such odors will be

predominantly due to the naphthalene contamination on-site, other more

toxic volatile compounds may also be released, a possibility which needs

additional analysis. In any case, chemical odors are likely to be strong

enough to be significantly annoying to the surrounding community, and

should be minimized to the extent feasible. Measures to achieve this are

identified in the draft EIR but should be addressed in more detail in the

final EIR. These measures include limiting the amounts of soil excavated

at any one time, promptly covering excavated materials, and limiting

excavation to periods of favorable weather conditions. To insure

compliance, we also suggest that a mechanism be established whereby

complaints from the community regarding noxious odors, dust, and other

aspects of the site development can be made and officially registered and

investigated.

5. Soil treatment and disposal issues need significant clarification. On-

site treatment of contaminated soils is proposed with no elaboration of

the approaches to be used. Should these treatment processes involve

stripping of the volatile compounds from the soil, additional exposures

to airborne contaminants will likely occur. This possibility is not

addressed. Off-site disposal and on-site use of contaminated materials

as fill are also suggested, but no criteria are presented. Also, how

soils will be choosen for the various treatment/disposal options

mentioned is much less supported. The determination of disposal options

should be based on objective criteria such as chemical analyses of

appropriate samples of the excavated materials. Maximum allowable

-20- contaminant limits should be developed for the use of contaminated soils

on-site. More detailed guidelines for the use of contaminated materials

on-site should also be developed. Contaminated soils should be isolated,

to the extent feasible, from the open environment as soon as possible

after excavation. Stockpiling of contaminated soils, as suggested in the

draft EIR, could lead to their mobilization through wind and water

erosion. Give" the high water table, contaminated soils could easily be

placed into the saturatee zone. The developer should be required to keep

detailed records of how the contaminated excavated soils are treated or

of where they are disposed of both off-site and on-site.

6. Groundwater treatment criteria and methods should be specified in greater

detail. Sufficient information on the types and concentrations of

contaminants in the gzoundwater of the region to be dewatered is

available to allow for a more detailed analysis of the most suitable

treatment techniques. Air or surface water discharges resulting from the

proposed treatment process should be considered in the risk assessment

for the site. For any treatment process, intermittent, random sampling

should be done to determine the levels of compounds in air or surface

water discharges.

7. Due to groundwater contamination and the high water table, special care

must be taken to avoid entry of noxious chemcials into the buildings once

constructed. Watersealing of the foundations may not be sufficient (just

about everything waterproof that we have ever dealt with has eventually

leaked). We recommend that below grade space be isolated as much as

possible from higher floors in the buildings. For example, separate

-21- ventilation systems should be installed. Office or other long-term work

space should, if possible, not be placed on these belowgrade floors. If

workers will be expected to use this space, additional ventilation may

ultimately be required.

8. hould the proposed construction be undertaken in stages, where one or

tore buildings are occupied while excavations are done on the remaining

sites. special work procedures may be needed. These might include

prohibiting earth moving activities on the site at certain times of the

day. Building occupants might also be advised to restrict outdoor

activity at the site until construction is completed.

9. Air quality monitoring should be conducted on-site during construction.

Measurements should be made in excavation pits as well as outside to

monitor the levels of organics that may be toxic to humans. When

concentrations are observed to exceed pre-selected "safe" levels. DEQE

and the City of Cambridge health officials need to be informed

immediately. In addition, appropriate control measures should be taken

while those who may be affected are alerted about the situation.

-22- U-'7 . 0 CHEMICAL CONTAMINATION OF WATER: The Case of Acton, Massachusetts

DEPT.of URBAN & ENVIRONMENTAL POLICY TUFTS UNIVERSITY MEDFORD, MASS. 02155 S a

ACKNOWLEDGMENTS

We would like to thank Saul Slapikoff who' supervised a student project in his course on Environental Toxicology that was coordinated with our study. The following students in his course wrote a report titled "Literature Review on the Toxicity of Chemicals Found in Acton, Massachusetts Water Supplies and Protocol Analysis": Bruno Chevallier, Ed Coe, Jennifer D. S. Derby, Jon Golub, Wendi Shafir, David Sturdevant, and Ray Vautour. The toxicology research project provided Important background to our investigations. Professors James Hume and Charles Stearns of the Geology Department also contributed their expertise.

We want to express our appreciation to those individuals in the town of Acton, at the State Department of Environmental Quality Engineering, at the U.S. Attorney's Office of the Department of Justice, and the U.S. Environmental Protection Agency who attended our class discussions or provided us with useful information: Joan Gardner, Margaret Korde, Carolyn Grace, Steve Calichman, Christopher Farrell, William Pope, Larry Goldman, Michael Parise, and Dr. Thomas Spittler.

We are also grateful to the Fund for the Improvement of Post Secondary Education for providing part of the funding that made this publication possible (Grant No. 6007804773).

Finally, the students express a special thanks to Sheldon Krimsky for his patience, encouragement, and guidance throughout the project.

The authors alone are responsible for the contents of this report.

The contents of this report or any part thereof shall not be copied without the permission of its authors. a

CHEMICAL CONTAMINATION OF WATER:

THE CASE OF ACTON, MASSACHUSETTS

This report was prepared by graduate students in the

Department of Urban and Environmental Policy,

Tufts University,

under the supervision of Dr. Sheldon Krimsky

June, 1981

Student Team

Robbin Ciccio Kathryn F. Henderson Stephen A. Conant John R. Lewis Cheryl Cooke John L. Loconte James J. Evans Mark R. Lyons Howard M. Gold Richard B. Mahoney Christy A. Murphy TABLE OF CONTENTS Page Preface...... 1

1.0 Introduction ...... * ...... 3

2.0 Historical Background...... *...... 4 2.1 Demographics ...... 4 2.2 Town Government...... 7 2.3 State Government...... 7 2.4 The W. R. Grace Company...... 8 2.5 Genesis df the Problem...... 9 Notes to Section 2...... 11

3.0 Closing the Wells...... 13 Notes to Section 3...... 18

4.0 Regulatory Action Begins...... 20 4.1 Formation of ACES...... 20 4.2 Possible Effects of the Discovered Chemicals...... 21 4.3 Applicable State Laws...... 22 4.4 DEQE Begins Active Involvement...... 23 4.5 Further Local Actions...... 25 Notes to Section 4...... 26

5.0 EPA Enforces RCRA...... 29 5.1 The Goldberg, Zoino, and Dunnicliff (GZD) Study...... 29 5.2 Federal Involvement...... 30 5.3 State Withdraws from the Federal Suit...... 31 Notes to Section 5...... 32

6.0 Conflicting Groundwater Studies...... 34 6.1 Camp, Dresser, McKee (CDM) Study...... 34 6.2 Comparison of Consultant Studies...... 34 Notes to Section 6...... 47

7.0 Legal Resolutionsi ...... 48 7.1 EPA Complaint...... 0 ...... 48 7.2 Separate State Action...... 48 7.3 EPA: The Consent Decree...... so Notes to Section 7...... 51

8.0 Policy Analysis.. -...... -...... 52

(continued) TABLE OF CONTENTS (continued)

APPENDICES

I. Chronology of Events...... 55

II. The W. R. Grace Company...... 59

III. Odor Complaints in Acton, Massachusetts: 1973-1980...... 71

IV. Toxicology of Chemical Contaminants...... 73

V. Description of an Aquifer...... 86

LIST OF MAPS, FIGURES, AND TABLES

MAPS

A. Acton in Eastern Massachusetts...... -...... 5

B. Sinking Pond Aquifer, Acton, Massachusetts...... 6

C. The Study Area...... 10

D. Aquifers in Acton, Massachusetts...... 40

E. Simplified Groundwater Flow Field in Sinking Pond Aquifer...... 41

F. Concentrations of 1,1-Dichloroethylene in the Study Area...... 42

FIGURES

1. Cross Section of Sinking Pond Aquifer...... 38

2. Cross Section of an Aquifer, Showing Groundwater Flow...... 38

3. Cross Section of Sinking Pond Aquifer, Showing Concentrations of Total Hydrocarbons ...... 39

4. Groundwater Flow and Contaminant Dispersion from Source...... 39

5. Odor Complaints Registered at the Acton Department of Public Health...... 72

(continued) TABLES Iffe

I. Chemical Contaminants and Their Probable Sources Found by GZD and CDM...... 36

II. Results of 11 Independent Water Quality Sampling Round; in the Assabet Wells...... 37

III. Comparison of Chemical Analyses of GZD and CDM...... 44

IV. W. R. Grace Co.: International Locations...... 60

V. W. R. Grace Co. Markets...... - .... 60

VI. U.S. Operations of W. R. Grace...... 62

VII. Groups/Divisions, Products of W. R. Grace for Massachusetts... 63

VIII. Ambient Water Quality Criteria: Benzene, 1978...... 77 1

Preface

The issue of hazardous waste has been called the most serious environmental problem of our time. Many believe that the discoveries of chemical contamination to :?te '.re only the "tip of the iceberg." So while the cover of Time magazine displays the "Poisoning of America," and a congressional subcommittee labels 250 sites in the U.S. as possessing a great potential threat to drinking water supplies, one has been able to watch the story unfold from the likes of Love Canal in New York State to the "poison town" of Lekkerkerk in Holland. Incidents as severe as Love Canal may be rare, but the disposal of toxic wastes is an everyday occurrence. The Environmental Protec- tion Agency (EPA) estimates that close to 90 percent of all hazardous wastes generated in the United States, representing about 10 percent of all industrial wastes produced, are handled improperly. The wastes are held in some 30,000-50,000 sites throughout the country. Some fraction of these sites represent a potential hazard to human health and the environment. The effects of toxic chemicals may not be obvious or dramatic. Nobody actually knows the scope and intensity of the hazardous waste situation, such as how many toxic waste sites exist, where they are located, and what they contain. However, the American consumer uses products daily which are made by manufacturing processes which generate this waste. Plastic wraps, vinyls, saran films, coated paper, aerosols, paints, dyes, inks, plastics, styrenes, detergents, shampoos, hairsprays, and even certain food products are processed using one or more potentially harmful chemicals. There are over 65,000 chemicals in industrial use, with estimates that 1,000 new substances enter commercial production each year. In a recent report to the Senate, the Surgeon-General of the U.S. stated: "The public health risk associated with toxic chemicals is increasing and will continue to do so until we are successful in identifying chemicals which are highly toxic and controlling the introduction of these chemicals into our environment." Toxic chemicals present a threat to the environment which is long lasting and pervasive. Our society is only beginning to consider proposals for the safe disposal of chemical wastes. New England still does not have a single licensed chemical dumping area. " While nearing the close of its second session, the Ninety-sixth Congress passed the "Superfund Legislation," which provides 1.6 billion dollars in federal monies to clean up abandoned hazardous waste sites and chemical spills. The eventual cost of a proposed national cleanup is currently estimated to be between $20-50 billion. However, this cost estimate may end up being quite conservative. There is much uncertainty about past disposal practices. Moreover, the scope of present day hazardous waste dumping and its impact remains uncertain. 2

Probably the most worrisome aspect of the hazardous waste problem * is the potential for toxic chemicals to migrate into and contaminate groundwater. For this reason, waste disposal sites are often charac- erized as "ticking time bombs." Half of the urban dwellers and as much as 95 percent of the rural residents in the U.S. depend on groundwater for their drinking supply. This means that a significant number of people may be taking some risk simply by drinking water. The chairman of the Council on Environmental Quality wrote in this year's annual report that "from a variety of perspectives the nation's water and resources associated with it are in trouble." According to a report issued in 1979 by the Special Legislative Com- mission on Water Supply, over one-third of Massachusetts communities have been affected to some degree by chemical contamination. The problems of hazardous wastes fall into distinct categories that warrant different solutions. These include state certified waste sites which are misused or overtaxed, unauthorized sites, private commercial landfills, lagoons, and dumping grounds which affect ground or surface waters. Also, the resolution of any particular problem depends upon where liability rests. Some chemical deposits have existed for nearly a hundred years. Firms have long since disappeared from the area or have gone out of business. Other sites have come into existence before restrictive legislation went into effect. For only a small fraction of the total waste sites is it possible to determine a responsible party upon which liability for damages may be placed. The case study of Acton, Massachusetts is such an example. In 1978, the town of Acton discovered that two of its wells were contaminated with organic chemicals. The wells are located in close proximity to the W. R. Grace Company, a firm which employs chemicals in its industrial operations. W. R. Grace was using landfills and lagoons on its own property as disposal sites for its chemical effluent. Evidence appeared that two town wells contained hazardous organic chemicals, and the W. R. Grace Company was subsequently identified as a generator of some contaminants. After two years of negotiation, the issuance of administrative orders and the filing of a federal suit, an out-of-court settlement was reached. The study which follows chronicles these events and traces the decision-making from the genesis of the problem to the signing of the consent decree.

For the Environmental Protection Agency (EPA), the negotiated settlement represents an important precedent for future cases under the Resource Conservation.and Recovery Act (RCRA). The settlement also ensures that long-term monitoring of future plant activities will take place. However, the townspeople of Acton have no guarantee that the aquifer can be restored as a source of drinking water. The research for this study was a collective effort of students enrolled in a seminar in Planning Theory, offered through Tufts Univer- sity's graduate department in Urban and Environmental Policy. The students were divided into investigative teams, each with responsibility for researching a different aspect of the case analysis. it was an unusual opportunity to combine a socially useful role for students with a valuable educational experience. Sheldon Xrimsky, Project Supervisor Tufts University Department of Urban and May 1981 Environmental Policy ( 3

1.0 Introduction

On October 21, 1980, the United States Environmental Protection Agency (EPA) and the W. R. Grace Company signed a consent decree, representing an out-of-court settlement of a federal suit filed against the company to remedy an iminent and substantial endangerment to health and to the environment under provisions of the Resource Conser- vation and Recovery Act (RCRA). The settlement calls upon W. R. Grace to clean up and restore the quality of the drinking water of Sinking Pond Aquifer in Acton, Massachusetts. The contamination of the aquifer has been attributed to industrial operations of W. R. Grace's plants in this suburban Massachusetts comunity. According to the decree, the EPA has the authority to supervise cleanup operations and oversee future handling of toxic wastes resulting from W. R. Grace's industrial activities. A monitoring period of thirty years has been agreed upon. For each day the W. R. Grace Co. fails to meet the scheduled steps of the cleanup, they can be fined up to $2500. This unprecedented settlement was reached after considerable negotiation. For the citizens of Acton, the consent decree is another step toward resolving a problem that consumed town energies for over two years. Acton is a moderately affluent suburb of Boston. Problems such as pollution, adverse industrial impacts, and state and federal bureaucracies were thought to be left behind in the urban centers. And yet, the town became involved in complex negotiations that included a multinational corporation, state and federal agencies, and its own citizen activists. Since December 1978, two of Acton's wells have been closed as a precautionary measure, because of the presence of chemical contamination. At the time, the well closings reduced the town's drinking water supply by forty percent. It was a problem that took the community by surprise, although there were early indications that the environment was under assault. The problem is still far from over. Whether the requirements of the consent decree are adhered to remains to be seen. Although the settlement calls for cleaning up the aquifer and returning the water to potable quality, there is no assurance that the contaminants can be removed thoroughly enough for that goal to be achieved. With so many cases of contaminated water supplies in the U.S., there may be something to be learned from the Acton case. It illustrates the complexities of modern decision-making: determination of risk under conditions of uncertain knowledge; state vs. federal enforcement of environmental regulation; the question of liability in a pollution case; the role of citizen advocacy in raising public con- sciousness; the limits of local authority. C 4

2.0 Historical Background

This first section of the report gives a brief description of the Town of Acton, its geography, its citizens, and its government. It also introduces some of the main actors in the case, including the Massachusetts Executive Office of Environmental Affairs (EOEA) and the W. R. Grace Company. Finally, a short history highlights early concerns about water and air pollution in the area surrounding W. R. Grace's facility in South Acton.

2.1 Demographics

The Town of Acton is located 25 miles west of Boston, Massachu- setts (see Map A). At an elevation of 200 feet above mean sea level, this hilly Boston suburb covers a land area of about 21 square miles and receives an average annual rainfall of 43 inches. Soils in the town are generally moist, rough and stony, with large areas of sandy loams. Wet soils are associated with the many stream valleys in the area.1 The Assabet River runs through the extreme southern section of South Acton (see Map B). South Acton is where the W. R. Grace Com- pany and the Sinking Pond Aquifer are located. Also, 17 percent of Acton's population lives in South Acton.2 Over the past 20 years, Acton has undergone a significant growth in its population. From 1960 tS 1970, there was a 104% population increase, from 7,238 to 14,770. This growth continued after -1970, and in 1979 the population reached 20,142.4 Much of the town's growth can be attributed to an increase in the numbeg of apartment units, which rose from 190 in 1960 to 2,400 in 1976. This growth in population has been paralleled by an increased demand for water. The amount of water pumged by the Acton Water Supply District increased 113% from 1961 to 1971. As mentioned earlier, Acton is a moderately affluent town. The average price of a home in Acton is between $80,000 and $90,000. The price of a small, ranch-style home begins at about $60,000. Prices for newly-built homes start in the range of $130,000. Monthly rent for apartments starts at about $345 per month, while prices for con- dominiums begin at about $60,000.7 The people who live in these dwellings are mostly white, well- educated, upper-middle class, technical and professional people. The most recent U.S. Census figures available (1970) indicate that the average family income was $14,151; over 50% of the families earned $15,000 or more per year, and 37% of the persons 25 and older had completed college. For comparison, the average family income in Middle- sex County (of which Acton is a part) was only $9,733; less than 32% of the families earned $15,000 or more per year, and only 17% of the persons 25 and older had completed college. 5

wra. r------...... e./2 , -. 4-- - ..- - .. - - -unor"-

.- meo

--.-- -... - \ c -4

4 4 -- .. ,flq st E I~ Bi- * -. * uL .... . - -N *~W1 %rS" aa %..Lnor

* .-

rw .;.4 N ..

urir

- mro- -** - uS - - - e w - - - - c. 4 --.

- cEon an E - *A . I - -

I %S-flafltr -- -... r

. - t. e - . --. PIN ------.0, - -\.- %.ap

* Actonfs i t E t M s h e

* ., *IMU * Sr, C ~ .

' - *IbbJ

6001W *C. Ao 'IaW'.A o * 4 .. .* .J . . I I .?

v- 1134 V AU tc.

-. a Map-A Acton in Eastern Mascuet 6

'Map B Sinking Pond Aquifer, Acton, Massachusetts

I 7

2.2 Town Government

The three town governmental bodies with leading roles in the water contamination episode were the Board of Selectmen, the Board of Health, and the Acton Water Supply District. The municipal government of Acton follows the town meeting plan, common in Massachusetts. At the center of the decision-making process is the Board of Select- men. The five-member board is elected for a three-year term on a staggered basis. The selectmen handle the town's business at weekly sessions that are open to the public. The board is responsible for reviewing site plans, allocating funds that are not reserved for town meeting, and numerous other daily concerns of the community. A full- time time town manager implements policies set by the selectmen. As the primary elected body of the town, the board works with state, county and federal governments. The town manager appoints the three members of the Board of Health, which enfQrces sanitation codes and health standards for res- taurants, septic tanks, and the town landfill, and oversees the general environmental health of the public. The town hires the director of the Board of Health who administers programs and reports to the selectmen about health conditions within the town. The citizens of the town also elect the Acton Water Supply Dis- trict Commissioners. The water district functions as an autonomous body. It determines water policy, sets rates, controls its own budget, and conducts separate town meetings. The activities of the district are supervised to some degree by the Division of Water Supply of the Massachusetts Department of Environmental Quality Engineering. The water commissioners are responsible for providing water for Acton, maintaining the water quality, and locating new supplies when needed.9 In 1971, Assabet Wells #1 and #2 were opened in response to Acton's increasing demand for water. Eight years later it was discovered that these wells were contaminated with organic chemicals attributed to waste disposal practices of the W. R. Grace Company.1 0

2.3 State Government

The executive branch of state government in Massachusetts contains a cabinet level structure consisting of ten executive offices. In 1975, the Commonwealth's environmental programs were reorganized into the Executive Office of Environmental Affairs (EOEA). This arrangement placed environmental regulatory and management programs under a single administrative director, the Secretary of Environmental Affairs. The EOEA includes five departments and the Massachusetts Environ- mental Policy Act (MEPA) unit. The Department of Environmental Quality Engineering (DEQE) is the state agency primarily responsible for improving Massachusetts' environmental quality and ensuring compliance with numerous state and federal environmental statutes. - The DEQE is made up of several divisions; among these are the Division of Air Qual- ity Control and the Division of Water Pollution Control. 8

The DEQE has found that the most effective environmental management and regulatory system is one consisting of various permit programs. In addition, DEQE has been granted police power, and thus has the statutory authority to issue administrative orders and bring law suits against violators through the state Attorney General's office. The MEPA unit derives its power from the Massachusetts Environ- mental Policy Act. Under the Act, any company or person which has a project that requires state funding or a state permit must file an Environmental Notification Form (ENF). The public is informed of this by the Environmental Monitor, a publication of EOEA. The MEPA unit then determines whether the proposed activity will have a significant effect on the environment. Subsequent to review of the ENF and all relevant information, EOEA may request that the permitting or funding agency prepare an Environmental Impact Report (EIR), in which the proposed project and several alternatives are evaluated as to their adverse environmental and/or social impacts. The EIR is usually prepared by the person or company requesting the permit or funding.

2.4 The W. R. Grace Company

The W. R. Grace Company is a multinational corporation with operations in North and South America, the Pacific and the Far East, Africa, Europe, and the Caribbean. Begun in the late nineteenth century as a Peruvian shipping line, 1 1 the company has grown to where, in 1979, it was listed as one of the leading chemical producers worldwide. In that year, the W. R. Grace Company was listed fifth among chemical companies with earnings of 5.3 billion dollars.12 One of W. R. Grace's chemical plants .islocated in Acton, Massa- chusetts, at 150 Independence Road. The W. R. Grace Company acquired this site in 1954 when it bought the Dewey and Almy Chemical Company. Dewey and Almy had been situated in Acton since 1945. Prior to that, the American Cyanamid Company used the area for a munitions plant. 13 Today, four types of manufacturing processes take place at the W. R. Grace plant in South Acton. These include the manufacture of (1) air entraining agents, water reducers, and water retarders for use in the production of concrete; (2) container sealing compounds; (3) latex products; and (4) paper and plastic battery separators. 14 These operations evolved from the original Dewey and Almy Company, which manufactured synthetic rubber products. In 1950, plasticizers were made on the site; a year later, the first battery separator plant was built. Expansion in both the organic chemical plant and the battery separator plant took place in the decade 1950-1960. After 1960, there were no additions until the DARAMIC battery separator plant was built in 1979.15 It was the expansion of this plant which prompted the investigations that linked the W. R. Grace Company to the contamination of Acton's drinking water. 9

2.5 Genesis of the Problem

In order for the W. R. Grace Company to build an addition to its battery separator plant in South Acton, it had to obtain a site plan approval from the Acton Board of Selectmen. The hearings on the approval of the site plan made town officials suspect that the W. R. Grace plant was polluting the Sinking Pond Aquifer. Yet, prior to these bearings, several signs indicated that the operations at W. R. Grace were adversely affecting the environment. High levels of nitrates, sulfur compounds, and inorganic chemicals were found in the Sinking Pond Aquifer as early as 1954, when the W. R. Grace Co. conducted water quality tests after purchasing the Dewey and Almy chemical plant. Some of these substances may have been generated by the American Cyanamid Company.1 6 For a number of years, residents of South Acton have identified periodic odors and irritants in the air around the vicinity of the W. R. Grace plant. Complaints about the air quality were the first signs that chemical effluent was being discharged into the environment. Until the town established Assabet Wells #1 and #2 in close proximity to the chemical plant, there were no signs that W. R. Grace's industrial processes had any effect on water quality. As mentioned, Assabet Wells #1 and #2, located in South Acton, southwest of the Massachusetts Broken Stone Property (see Map C), came into operation in 1971. Two years later, in 1973, the.Acton Water Supply District undertook preliminary well explorations around the Massachusetts Broken Stone Property.1 7 The site contains deep deposits of sand and gravel and bears large amounts of groundwater Test wells showed depths of over 90 feet of water-bearing material.lh However, the water drawn from this aquifer had odors which indicated significant chemical contamination. The Acton Water Supply District chose to explore areas with better quality water for future town wells. Although these test wells were in close proximity to Assabet Wells #1 and #2, no further investigation was undertaken.1 9 That same year, Board of Health Director Steve Calichman, responding to odor complaints near the W. R. Grace facilities, visited the site with inspectors from the State Division of Air Pollution Control. Air quality tests for the area were unreliable because of the non- continuous emissions. Calichman suspected that the odors originated from the W. R. Grace plant. (They were later confirmed to be caused by phenol formaldehyde, a chemical used in the drying process of battery separator plates.) Citizen complaints began to be registered at the Acton Department.of Public Health (ADPH) in November 1973, but no action was taken on the odor complaints by the town or by the State Office of Environmental Affairs. To date (November 1980), almost. three hundred complgints have been received, and they continue to be logged at the ADPH. 0 (See Appendix III.) The number of complaints actually exceeds those logged, since many people try unsuccessfully to report odor problems after the Board of Health has closed. 2 1

I, 10

/ 11

By 1977, when further exploration had not located potential well sites, a more extensive examination of the water was made at the Massa- chusetts Broken Stone Property. Since it is a large source of groundwater, the thinking at the time was that it might be worth improving its quality. In June 1978, a forty-eight hour pumping test was conducted on three 2-1/2 inch wells to obtain more definitive water quality data. State officials from the Department of Environmental Quality Engineering (DEQE) reported that the water samples had a strong chemical odor.2' Specific chemicals could not be identified because the state did not have the necessary analytical instruments, such as a gas chromatograph/mass spectrograph. However, the 3QE advised the water district not to install a permanent well there. At that time, no further investigation was undertaken to determine the source of the pollutants.

Notes to Section 2

,Massachusetts Department of Commerce, Division of Research, Town and City Monographs, #169, Acton, 1956-1976.

2Personal communication with Acton Town Clerk's Office.

3 Acton Growth Policy Committee, Answers to Growth Policy Ques- tionnaire (State Planning Office, 1976), p. 1.

Acton Minuteman, 7 June 1979.

5 Growth Policy Questionnaire, p. 1.

6 Annual Reports pf the Acton Water Supply District, 1961-1971.

7 Personal conunication with Harry Foote, realtor in Acton.

8 Town and City Monographs, #169, Acton, 1956-1976.

9 Kennedy School of Covernment, Harvard University, Massachusetts Hazardous Waste Management: Building the Local Role, June 1980, pp. 57-58.

1 0 Annual Report of the Acton Water Supply District, 1979.

11Moody's Industrial Manual 27 (May 1980), p. 1227.

1 2Business Week, March 17, 1980.

1 3 Goldberg, Zoino, & Dunnicliff, Groundwater Investigations of Assabet Well Fields, Acton, Massachusetts, Vol. 1, January 1980, pp. 5-6. (Hereafter, GZD Report.) 12

14Response of W. R. Grace to the first set of Interrogatories submitted by Plaintiff, U.S.A., to the Defendant, Civil Action #80-748-6, U.S.A. v. W. R. Grace, U.S. District Court of Massachusetts, docketed July 21, 1980, pp. 16-17.

GZD Report, pp. 5-6. 16 ZD Report.

17Annual Report of the Acton Water Supply District, 1978, p. 6.

18Letter from Gilbert Joly, DEQE, to William Hicks, Executive Office of Environmental Affairs (EOEA), August 24, 1978. 19GZD Report.

2 0Odor Complaint Log, Acton Department of Public Health.

2 1Letter from Jacob C. Diemert, Attorney, Sherburne, Powers and Needham, to Stephen Calichman, Acton Board of Health, September 17, 1980.

22Annual Report of the Acton Water Supply District, 1978, p. 6.

2 3 Letter from Harry B. Morse, to Kathy Henderson, November 2, 1980. Closing The Wells 13

3.0 Closing the Wells

With the proposed expansion of W. R. Grace's Acton facilities in 1978, concerns about the company's waste disposal practices crystal- lized. The necessary site review process, associated with the proposed expansion, resulted in a more detailed examination of company activities by local and state officials. As a result of these examinations, two municipal wells were eventually closed. When the W. R. Grace Company filed site plans with the Board of Selectmen on July 23, 1978 for a proposed expansion of their battery separator plant in South Acton, it generated a considerable amount of concern throughout the town. The site plan spurred questions from the Planning Board, the Board of Selectmen, the Acton Water Supply District, and the Board of Health, about the air and water quality around the W. R. Grace facility. The site plan also aroused the interest of the Massachusetts Execu- tive Office of Environmental Affairs (E0EA). The W. R. Grace Company was required to obtain a state air pollution permit from the Division of Air Pollution Control (DAPC). So, on July 24, 1978, the company filed an Environmental Notification Form (ENF) which was published in the state's Environmental Monitor. This notified the public and state officials that W. R. Grace planned to construct a new battery separator plant in Acton. On August 21, Secretary of Environmental Affairs Evelyn Murphy determined that no EIR was required. The project was excluded from MEPA environmental review, because the new plant would produce less than 100 tons of air pollution per year.1 The DAPC permit was also granted. The same week W. R. Grace filed its ENF, the Acton Planning Board received site plans for review. Town Manager Christopher Farrell informed the Board of Selectmen of W. R. Grace's intended expansion. Normally only one selectman handles such a case, but this one appeared unusually complex. Fred Kennedy and Joan Gardner were assigned the duty of obtaining the comments and evaluations of town officials and citizens in regard to the permit application. The Board of Selectmen believed that an extensive review process would provide answers to previous queries about W. R. Grace's air pollution. The Planning Board found that the W. R. Grace plan cmplied with setbacks, lot coverage, and industrial zone requirements. However, a section of the zoning bylaws reads that "No land or structure shall be used in any manner so as to create dangerous, injurious, noxious or otherwise objectionable conditions . . . ." The Planning Board questioned whether this section could apply to W. R. Grace because of the noxious odors and waste discharge that were byproducts in its manufacturing process. 14

The Planning Board's report to the selectmen, stating their zoning approval of the site plan, included a recommendation to contact the Acton Water Supply District because the town wells were in the vicinity of the new plant site. As a separate and autonomous body from the selectmen, the Water District Commissioners were not usually involved in a site review process, but the unique problems of this case made their involvement a necessity. Af ter the Acton Water Supply District Commissioners were informed on August 1, 1978 that W. R. Grace intended to build a new plant, they expressed concern to the Board of Selectmen that the data supplied did not "adequately address itself to the potential for contamination of [the town's] wells and that the existing operations of W. R. Grace may have contaminated some of the groundwater in the area." In an August 23rd letter to Town Manager Christopher Farrell, the selectmen, prompted by a request from the Water Commissioners, asked that a limited study be undertaken to determine the slope of the groundwater table and the extent of any existing contamination. The Water Commissioners and engineers from the Massachusetts Department of Environmental Quality Engineering (DEQE) conducted a study of the hydrology of the Sinking Pond Aquifer. The tests were conducted on the aquifer in an attempt to locate a site for a new municipal well. The tests indicated that the area was rich in groundwater, and that groundwater sloped from Sinking Pond to the Assabet Wells. Therefore, any contamination in Sinking Pond might flow toward the wells. 3 The tests did detect chemical odors, as had previous tests in 1973. In an August 24, 1978 letter to William Hicks of the Executive Office of Environmental Affairs, Gilbert Joly, a DEQE engineer, expressed concern that any groundwater contamination could pose a threat to the two municipal wells, Assabet #1 and #2. He requested that a hydrogeological study be conducted to determine the extent of the contamination.4 At this point, no local or state officials had a chemical analysis of the water from Assabet #1 and #2. In fact, no samples were taken from the municipal wells to test for organic contaminants until October 20, 1978. Because of questions it had about the effects of W. R. Grace's expansion would have on the environment, the Board of Health Also became more involved than usual in the site review process. The Board of Health had received numerous complaints of air pollution near the W. R. Grace plant. Steve Calichman inspected the site at the existing plant on August 22, 1978. In a September 1 memo to town officials, Calichman questioned whether the lagoon was leaching, and thus affecting groundwater quality. 5 He also agreed "totally" with the concerns of the Water District and DEQE engineer Gil Joly. Finally, Calichman recommended that "the (site] plan be taken under advisement until all 6 questions are satisfactorily resolved." Four days after Steve Calichman sent his memo to the Board of Selectmen, the Acton Planning Board also sent a memo recommending that "approval of such plans [the addition to the W. R. Grace plant] be denied until several potentially serious environmental air, land and water pollution problems surrounding the current and proposed opera- 15 tions are properly assessed and solved." That same day, W. R. Grace representatives presented their site plan In a public hearing. A large, vocal audience attended the standing-room-only meeting which lasted for three hours. Although the public hearing was called to discuss the site plan, much discussion centered around the existing plant and the air pollution it was generating. At the next selectmen's meeting on September 12, residents of Acton and Concord again voiced concern about air and water pollution. Residents living near W. R. Grace complained about odors and emissions from the present plant, and questioned the possibility of contamination of Assabet Wells #1 and #2. A decision on the site plants was again delayed, pending further information on air and water pollution. The town had a 90-day period in which to act. At the meeting, the selectmen requested a hydrogeological study of soil conditions and water quality, as well as safety and pollution control equipment proposed and in use, and the estimated amount of waste which would be going to the town's landfill.7 On October 6, Town Manager Christopher Farrell received the results of tests which were conducted by the Acton Water Supply District. The accompanying letter from the District Commissioners indicated that: * the current disposal methods of W. R. Grace were contributing to groundwater contamination; * the concentration of organics in the groundwater was greatest near Sinking Pond; * the water quality of W. R. Grace's wells was inferior to that of Assabet #1 and #2; 1additional testing was necessary to determine if the contaminants were migrating toward town wells; * evaluation of the above indicated probable future contamination of Assabet #1 and #2; and * if disposal operations at the new plant were conducted in a manner similar to the existing procedures, an already serious problem would be compounded.8

The commissioners' feelings were expressed by Chairman Harry B. Horse: "(T]he proposed plant brought the matter to a head and these problems should have been resolved before W. R. Grace expanded." 9 The Water District's next action was to send the Board of Select- men a letter on October 20, recommending five conditions for approval of the site plan: (1) require W. R. Grace to fund a hydrogeological study of the area to determine, among other things, water quality and possible organic contaminants; (2) require that, should the plant be found to be contaminating the wells, the existing means of disposal of wastes should be stopped and corrective action taken; (3) require future lagoons to be lined; (4) monitor all waste water to satisfy EPA standards; and (5) improve safety measures against possible chemical spills during tanker unloadings.10 16

On the same day, the DEQE took water samples from the municipal wells, Assabet #1 and 92, to test for organic chemicals. This was the first time any local or state official had performed a chemical analysis on the drinking water. Because the state laboratory in Lawrence did not have the equipment to undertake such tests, DEQE officials delivered the samples to the U.S. EPA Laboratory in Lexington, Massa- chusetts. The results of EPA's analysis were made available to John Delaney, Director of the State Laboratory, on November 6, 1978.11 The next day, town officials were notified of the results by phone. The tests showed the presence of organic chemicals, several of which were known carcinogens.12 During this time, the Board of Selectmen and other town officials were negotiating the site plan with representatives from W. R. Grace. The selectmen faced the imposing task of being a broker of the public interest in negotiations with a multinational company. Simultaneously, they had to coordinate state and local officials' actions and solve the contamination problem. There were individuals, -acting within the jurisdiction of local laws, who had to be satisfied. In an article describing that period (co-authored by Selectman Joan Gardner and John Ayres), the primary questions the selectmen had to consider were stated:1 3 * Did the town want to encourage further industrial development in an already endangered environmental area, and if so, how? " Was the chemical manufacturer responsible for the contaminated condition of the town well? * If so, would they be willing to make a long-term financial commitment to the town on these environmental concerns?

Here, the strategies of the Water District and the Board of Selectmen conflicted: the selectmen felt that they could not disap- prove the site plan because they lacked proof that W. R. Grace was responsible for the well water contamination; the commissioners, on the other hand, opted "for cleaning up the present condition before allowing expansion."1 4 At this point in the board's consideration of the permit, the limitations of their authority became an important factor. The selectmen had preliminary information that the water supply was contaminated, that W. R. Grace's lagoons contained organic materials, and that the aquifer sloped from the W. R. Grace property to the wells. However, the selectmen felt that without an established causal relationship between W. R. Grace and the contaminants in the well water, this was not a legitimate basis for denying the site permit. Neither were the odor emissions from W. R. Grace viewed as a reason for denying the permit. Town Counsel Acheson Callaghan advised Selectman Gardner that the town had to have proof in order to enjoin W. R. Grace from polluting. Also, the zoning bylaws, which were cited earlier by the Plan- ning Board, did not give the selectmen sufficient authority to deny the application. Since they believed there was no technical reason for withholding the permit, the selectmen unanimously approved the site plan in a public meeting held on November 14, 1978. 17

There were conditions attached to the site plan- approval, however. Acting on the tenuous edge of their authority, the selectmen negotiated an agreement with W. R. Grace along guidelines that the Water Commis- sioners suggested. The company agreed to fund a $90,000 hydrogeological study by a firm of the town's choosing. Should the study show that the plant's operations were contaminating the wells and/or the aquifer, "existing means of disposing of the plant wastes would be stopped or - other appropriate action taken to prevent pollution of such subsurface aquifers and town wells."15 According to some town officials, the goal of expanding industry and that of protecting Acton's water supply were both served by the site plan agreement. Harry Horse, of the Water Supply District, said that the Commissioners "[had] no quarrel with [the selectmen's] decision as long as the Board of Health monitors the site." 16 The proposed plant, however, was to be situated over Sinking Pond Aquifer and its operations included the disposal of twelve tons of hexane per year.

Discussion

The granting of the site plan permit in 1978 had been criticized by many town residents, particularly members of the citizens action group, Acton Citizens for Environmental Safety (ACES). As ACES member Margaret Korde explained it, the selectmen gave away their "ace in the hole" by signing the site plan permit. She criticized the selectmen far holding meetings In executive session, thereby keeping the public from learning about what was going on in the negotiations between town officials and W. R. Grace. The Board of Selectmen maintained that holding closed sessions would enable them to gain the best agreement for the town and avoid a volatile and unproductive confrontation. Another point of contention by ACES was the fact that the town officials knew the wells were polluted before the site plan was approved but did not inform the public until a month later when the negotiations between W. R. Grace and the town had been completed.

For the following month, the Acton Water Supply District Commis- sioners and the Board of Selectmen debated whether to close the wells or leave them in operation. The commissioners were concerned about the loss of forty percent of the water supply contributed by the wells and they were concerned about the difficulty of re-opening the wells once they were closed. On the other hand, "the Board of Selectmen did not want to make this possible problem known to the public until more data Iwere] collected and did not want a panic situation to arise." 1 7 Using the information which DEQE supplied about contaminants in the wells, the a ectmen persuaded the commissioners to close Assabet Wells #1 and #2. Although the Water District had no guidelines on how much consumption of the contaminated water could adversely affect human health, the decision was made to close the wells on December 19, 18

1978,19 over one month after the town received news of the contamination. This was also the first time citizens learned of the'polluted wells. The comissioners now had two choices: one was to clean up the Assabet Wells; the other was to replace the forty percent water loss by an extensive test well exploration program. Two different types of treatment methods were recommended: (1) biological reclamation which involves culturing microorganisms that will degrade the organics to carbon dioxide and water; and (2) activated carbon which will absorb the contaminants. Although both of these treatment methods were tried to some degree, neither proved successful. Fortunately, an intensive exploration for new well sites, which was undertaken at great expense, was successful. A new well was found and installed at Lawsbrook Road, due north of the W. R. Grace Company, yielding 400,000 gallons per day. Additional sites were found and pump-tested in North Acton, which, when added to the Lawsbrook site, made up for the loss at the Assabet Wells. However, this failed to happen before strict water conservation measures were imposed on the town in the summer of 1979.

Notes to Section 3

lInterdepartmental memorandum, Sam Mygatt, E0EA, to Secretary John Bewick, January 24, 1979.

Kennedy School of Government, Harvard University, Massachusetts Hazardous Waste Management: Building the Local Role (Cambridge, MA, June 1980), p. 59.

3Annual Report of the Acton Water Supply District, 1978, p. 6.

4Joly letter to Hicks, August 24, 1978.

5Memorandum from Steve Calichman, to Board of Selectmen, Christo- pher Farrell, and Building Commissioner, Don Johnson, September 1, 1978, p. 4.

6 Ibid.

7Assabet Valley Beacon, September 14, 1978, pp. 1, 12. 8Letter from Harry B. Morse to Kathy Henderson, November 23, 1980, pp. 2-3. 9Ibid.

10Letter from Water Supply District of Acton, to Board of Select- men, October 20, 1978, p. 1. 19

1 lLetter from Edward Taylor, EPA Lab, to John Delaney, Director, Lawrence Experimental Station, November 16, 1978.

12Ibid.

1 3 Joan N. Gardner and John Ayres, "Acton, Massachusetts: A Groundwater Contamination Problem," Proceedings of the 1980 Hazardous Waste Spill Conference, Louisville, Kentucky, Vanderbilt University, p. 40.

1 4Letter from Morse to Henderson, pp. 4-5.

1 5 Letter: Site Plan Approval between W. R. Grace Company and Acton Board of Selectmen, Condition 9, November 15, 1978.

6 1 Letter from Morse to Henderson, pp. 4-5.

1 7 Board of Health Executive Session Minutes, December 5, 1978.

8 1 Letter from Morse to Henderson, p. 3.

1 9Ibid. 4 20

4.0 Regulatory Action Begins

Subsequent to the closing of Acton's wells, citizen involvement became more organized, with the formation of the Acton Citizens for Environmental Safety (ACES). While ACES proceeded to request assistance from the state, this citizens group concentrated its earliest efforts in two principal areas: the potential adverse effects of the chemical contaminants, and the applicable state laws. The .following section discusses the formation of ACES, its interaction with DEQE, and its efforts to acquire information and press for enforcement of existing laws.

4.1 Formation of ACES

After Assabet Wells El and #2 were closed in December 1978, two community meetings were held in Acton with participants from EOEA, DEQE, local officials, and W. R. Grace. The purpose of those meetings was to discuss the MEPA process and the company's request for DEQE approval of its plant operations. Several concerns were raised at the meetings, including the existing air pollution problem and the lagoon waste disposal system.1 As a result of these meetings, Samuel Mygatt, Director of the EOEA MEPA unit, issued a memorandum on January 24, 1979, to the new Secretary of Environmental Affairs' John Bewick.2 In his memorandum, Mygatt stated that citizens in Acton, who were still dissatisfied with the office's EIR determination of August 1978, could file suit at their own discretion. Furthermore, Mygatt declared that DEQE was content with its control of the air emission problem. However, the situation of the discharge into the lagoons was still not being formally addressed. Increasing dissatisfaction with the actions of town and state officials concerning the closing of the contaminated wells led to the formation of Acton Citizens for Environmental Safety (ACES) in January 1979. From the beginning, ACES encountered opposition from members of the community who felt their actions were "overzealous," but many residents found ACES to be a highly effective organization, relentless in its attempts to uncover the facts of the case. The members saw themselves as "watchdogs" of the local and state governments, and drew upon professional expertise "in order to bring pressure to bear on the W. R. Grace Company to cease dumping hazardous 3 wastes in Acton." The group began attending all public meetings to focus on the issues, raise questions to town officials, and monitor W. R. Grace's activities. Margaret Korde, ACES' spokesperson, described the group's concern: "We had questions about what all the chemicals meant, what laws could deal with the situation, what we should do, and neither local, state, 21

nor the federal government had the answers."4 ACES began its own research into all aspects of the problem, from the determination of the possible effects of the chemicals in the water to the applicable statutes and legal jurisdictions.

Discussion

After the wells were closed and because EPA priority pollutants such as vinylidene chloride and benzene were discovered in the drinking water, ACES pressed for information on whether V. R. Grace was still using these chemicals in its operations. According to ACES' Margaret Korde, W. R. Grace refused her request for a complete list of the chemicals used in its industrial operations and that the company denied it was still using vinylidene chloride. Korde later photo- graphed a tank car marked 19l-dichloroethylene on the W. R. Grace property and recognized that it was the chemical name for vinylidene chloride. ACES contended that the company was still using the chemical after the company stated it had ceased using it. Officials of W. R. Grace maintained that the tank car was necessary to remove remaining stocks of the chemical from the plant.

4.2 Possible Effects of the Discovered Chemicals

The town hired the Newton, MA firm of Goldberg, Zoino & Dunni- cliff Associates (GZD) to undertake the hydrogeological study which was part of the site plan agreement. The study included tests for organic chemicals at different locations in the aquifer. GZD found that the Assabet Wells were contaminated with several chemicals on EPA's list of priority pollutants. In addition to 1,1-dichloroethylene and benzene, GZD also found trichloroethylene, 1,1,1- trichloroethane, methylene chloride, chloroform and ethyl benzene. An in-depth analysis of each of these chemicals is provided in Appendix IV, which summarizes the concentration of organic chemicals detected in the Acton wells, explains some terminology in toxicology, and describes the toxicological effects of the chemicals. The possible adverse health effects of these chemicals are highlighted below. Vinylidene Chloride (1,1-dichloroethyleneiVDC). VDC has long been suspected of being a carcinogenic agent because of its known mutagenic activity (causes genetic mutations). Numerous studies using animal systems have shown significant correlations between exposure to VDC (in air, water, or through skin) and cancers of the kidney, liver, stomach, and lungs. 5 In humans, VDC has been shown to cause depression of the central nervous system, liver function impairment, and kidney damage at concentrations near 100 parts per million (pgm), over 1,000 times the concentration found in Acton drinking water. 22

Benzene. Benzene is a kpown human carcinogen and therefore, it is widely believed, there is no safe level in drinking water. It also has been shown to be extremely toxic to the central-nervous lystem at relatively low doses, such as 1,000 parts per billion (ppb). However, since benzene is also very prevalent in our environment, and an ideal concentration of zero ppb is unfeasible, the EPA has assumed incremental risks for ingestion of trace levels in food and drinking water. Trichloroethylene (TCE). The prominent effects of TCE at higher concentrations (up to 5,000 ppm) are depression of the central nervous system, abnormal cardiac rhythms (arrythmias) and liver and renal toxicity.8 Highly significant increases in liver cancer were observed in a "long-term" animal test by the National Cancer Institute (1976).9 1,1.1- Trichloroethane. Trichloroethane has been found to cause nervous system depression and liver depression at high doses. Because this chemical has been found to be a mutagenic agent, there is a strong possibility that it may also be a carcinogen. However, only one animal study has been conducted thus far, and it showed no significant association between increased cancer risks and exposure. 10 Methylene Chloride. Methylene chloride is absorbed by humans and metabolized to carbon monoxide and other products. Carbon monoxide 1 1 poisoning has been observed in some inhalation studies on humans. While data for carcinogenicity of methylene chloride is notably absent, this chemical is a known mutagenic agent, and a suspected carcinogen. Chloroform. Chloroform was implicated as a carcinogen in animal studies as long ago as 1945. Studies on humans have shown that chloroform is extremely toxic to the liver, kidneys, and central nervous system. Over-exposure may cause death by heart failure. 1 2 Ethylbenzene. Ethylbenzene is toxic to mucous membranes and the central nervous system in high doses (1,000 ppm). 13 Some experts feel that a high carcinogenic potential exists, but this substance has yet to be studied in depth. 14

4.3 Applicable State Laws

In addition to the Acton zoning bylaw, three state laws were applicable to W. R. Grace's disposal practices: (1) Massachusetts General Law (MGL), Chapter 21, Sections 26-53; (2) MGL, Chapter 111, Section 17; and (3) MCL, Chapter 21 C. The following is a summary of these laws and how they apply to the Acton case. (1) MGL. Chapter 21, Sections 26-53. The Massachusetts Clean Water Act of 1966 prohibits the discharge of pollutants into the waters of the Commonwealth (including groundwater) without a permit from DEQE's Division of Water Pollution Control (DWPC). This Act also empowers the director of the DWPC to both issue cease and desist orders and requests that the Attorney General seek injunctive relief. In addition, construction and operation of any discharge outlet or treatment works is prohibited without first obtaining a permit from DEQE/ 23

EPA. A 1973 amendment to Section 42 provides for a fine of $2,500- $25,000 per day or a civil jenalty of not more than $10,000 per day for violations of the Act.19 (2) MGL, Chapter 111, Section 17. This state law was enacted in 1886 and is included in the section on state statutes dealing with public health. The legislation states that DEQE shall, in the case of "any manufacturing or other business whose drainage or sewage may tend to pollute any inland water," recommend the best method for preventing such pollution. This act also contains language prohibiting the installation and operation of such a drainage system without approval from DEQE. 1 6 It was under this law that the agency first attempted to control W. R. Grace's discharges. (3) MGL, Chapter 21 C. The Massachusetts Hazardous Waste Man- agement Act of 1979 mandates that DEQE regulate the collection, transportation, storage and disposal of hazardous wastes. This legislation was drafted in order to implement regulations and standards created by the EPA in response to the Federal Resource Conservation and Recovery Act of 1976 (RCRA). The Act states that "no person shall establish, construct, or operate a facility for the landfill disposal of hazardous waste in a location overlying an actual, planned, or potential underground drinking water source as described on the groundwater maps of pertinent U.S. Geological Studies and the Massachusetts Water Resources Comission."1 7 The W. R. Grace's landfill operations were allegedly in violation of this state law.

4.4 DEQE Begins Active Involvement

After the preliminary G2D report was released in May 1979, DEQE became actively involved in the Acton case. Prior to the release of GZD's preliminary findings, DEQE has assumed a relatively passive pos- ture. There are a number of reasons why it took so long for DEQE to take effective regulatory action. Hundreds of plants in operation prior to the enactment of the 1966 State Clean Water Act have never obtained permits or come into compliance. Therefore, it was argued by agency officials that by issuing a cease and desist order or levying a fine, the state would- be unfairly singling out W. R. Grace's facility in Acton. Furthermore, until July 1980, the Division of Water Pollution Control was a semi-autonomous state regulatory agency. Although it was an administrative.division within DEQE, its enforcement decisions and actions were separate from those of the department. In addition, enforcement of the State Clean Water Act (MGL, Chaper 21, Sections 26- 53) was the sole responsibility of the DWPC. Since the DWPC had never Implemented a permit system for point source discharges into groundwater, the division decided it would be improper to force W. R. Grace to comply with the statute, despite the apparent seriousness of the 8 situation.1 Thus, the most appropriate regulatory action that DEQE 24 could initiate without the DWPC was under Chapter 111, Section 17-a less effective statute that was originally enacted in 1886. Further insight into the initial lack of effective enforcement taken by the DWPC and DEQE may be provided by a memorandum sent to the current Secretary of Environmental Affairs, John Bewick, from Samuel Mygatt of EOEA. In the July 11, 1979 letter, Mygatt acknowledged that W. R. Grace's waste water discharges were in violation of the Massachu- setts Clean Water Act, which prohibits any discharge of untreated pollutants into waters. of the Commonwealth (including groundwaters). The letter further notes that "any tough measures taken against W. R. Grace will evoke intense concern from the company and from the commerce/ development section of state government."I The preliminary results of the GZD study did prompt DEQE to act more decisively. In May 1979, Gilbert Joly of DEQE made an informal, non-binding request to W. R. Grace to eliminate all discharge of waste water so that zero-levels could be achieved. Joly suggested resource recovery or waste water treatments as remedies. W. R. Grace did not respond to his request. 20 On July 13, 1979, the Commissioner of DEQE, Anthony Cortese, issued an Administrative Order proposing that a two-year timetable be established within which W. R. Grace would study, design, and build a waste water treatment facility pursuant to MGL, Chapter 111, Section 17. It called for recommendations for reducing the waste as much as possible, but it did not provide for aquifer cleanup or monitoring. Through this order, DEQE left the design of the facility to W. R. Grace, requiring only a submission (not a review) of its plans to the agency. A local newspaper reported that Cortese feared an order demanding W. R. Grace to stop all discharges of hazardous wastes 2 would result in lengthy litigation. 1 This Administrative Order, the first of two issued by DEQE, indicated that liquid industrial wastes were being discharged by W. R. Grace without DEQE approval. The firm was ordered to retain the services of an engineering consultant to determine the scope of industrial waste generation and effluent discharge. The company was also required to formulate a plan for treatment of its waste water discharge, and to implement the plan within one year of the order. 2 2 W. R. Grace responded to this order in a letter to Gilbert Joly of DEQE on July 30, 1979.23 The firm stated that it was not convinced that its waste disposal practices had resulted in the water contamination, and that it was waiting for definitive results of the final GZD report. W. R. Grace stated that they found the order's timetable unrea- sonable, and also voiced an objection to bearing the costs of compliance. Joly answered W. R. Grace's letter on August 3. The engineer informed W. R. Grace's Vice-President of Manufacturing Herbert M. Luz that despite the uncertainty of its contribution to the groundwater contamination, the firm was still operating an unapproved waste treatment facility and therefore was in violation of state public health laws. 2 4 Thus, Joly emphasized that no matter what the outcome of the 25

GZD study, the state would still insist that W. R. Grace devise an enviromentally approptiate waste disposal method. On July 27, 1979, an official with DEQE's Division of Water Pol- lution Control (DWPC) also sent a letter to W. R. Grace concerning the firm's violation of the Clean Water Act. The letter informed the company that its landfill operation was illegal according to state regulations which require that hazardous substances be disposed in approved landfills. In the same letter, the DWPC requested that W. R. Grace divulge the contents of its lagoons and specify disposal methods for liquid materials and dredged solids. In addition, it was suggested that W. R. Grace retain the services of a registered professional engineer to determine the most environmentally appropriate disposal method. The DWPC also asked that the engineer submit a time schedule for completion of the necessary corrective work, and indicated "the corrective action to be taken."25 The W. R. Grace Company did not comply with the requests outlined in the DWPC letter.

4.5 Further Local Actions

While negotiations with W. R. Grace were taking place throughout the summer, the company filed for an occupancy permit for its newly completed battery separator plant. On July 10, 1979, three days before DEQE issued its first Administrative Order, the Acton Board of Select- men denied that permit. Two selectmen advocated withholding the permit unless W. R. Grace would pay $25,000 (beyond the $90,000 already given) to complete the hydrogeological study.26 Reacting to another concern, W. R. Grace agreed to post a $75,000 bond to ensure completion of the surrounding landscape. In response to this decision and DEQE's order of July 13, the president of Local 324 of the International Chemical Workers Union (ICWU) sent a formal complaint to Governor King on July 20. He asked that the Governor's office investigate the DEQE Commissioner's action which "contradicts assurances of cooperation of state officials to 'encourage' industrial expansion." He was concerned that ACES would prevent W. R. Grace from obtaining the occupancy permit, adding that "they appear to have unlimited power and are answerable to no one." ACES, however, was unable to stop the selectmen from reconsider- ing the permit. On July 24 the occupancy permit was approved. Once again, the actual legal authority of the selectmen was ambiguous. Town Counselor Acheson Callaghan did not say whether the site plan document required the selectmen to withhold the occupancy permit; the issue was, in his words, "complicated by the fact that the [GZD] study (went] over the original $90,000."27

( 26

ACES began working through the political process to get town officials to take stronger action against W. R. Grace. In a special town election in September 1979, ACES helped elect Hayden Duggan as selectman. Voter turnout, normally around eight percent, doubled. The following spring, ACES also supported Bill Walsh for Water District Comissioner who replaced long-time member Kevin Sweeny. 28 At a special town meeting on October 9, ACES introduced a resolution that passed unanimously which instructed the Board of Selectmen, the Board of Health, the Water District Commission, and the Commissioner of DEQE to "notify any company found to be illegally disposing of hazardous waste in Acton to cease immediately such disposal." No immediate action was taken on this resolution. Despite ACES' input, town officials did not always view such efforts as a positive force in the process. Selectman Joan Gardner wrote: "Diverse public and political pressures, however, have often jeopardized the cooperative spirit of these efforts to settle with W. R. Grace."2 9 Some, like Gardner, viewed ACES' challenge to local authority as an overreaction to the situation, but its members continued their investigations and advocacy for strict enforcement of the law. Another successful action by ACES was the writing of a series of letters in November 1979 to the Board of Selectmen, the State Attorney General, Senators Edward Kennedy and Paul Tsongas, and EOEA Secretary Bewick, detailing the lenient treatment of a company they felt was endangering the health of the town. Their request for a halt to W. R. Grace's discharge practices was a factor in EPA's decision to enter the case.

Notes to Section 4

Interdepartmental memorandum, Samuel Mygatt, EOEA, to Secretary John Bewick, January 24, 1979. 2Ibid.

3Acton 1979 Town Report, p. 23.

4 lnterview with Margaret Korde at Tufts University, September 22, 1980. 5 C. Maltoni,"Recent findings an the carcinogenicity of chlori- nated olefins," Environ. Health Perspect. 21 (1977): 1-5; also, C. C. Lee, J. C. Bhandari, J. M. Winston, W. B. Rouse, P. J. Peters, R. L. Dixon, & J. S. Woods, "Inhalation toxicity of vinyl chloride and vinylidene chloride," Environ. Health Perspect. 21 (1977): 25-32. 6 J. A. Prendergast, R. A. Jones, L. J. Jenkins, Jr., & J. Siegel, "Effects on experimental animals of long-term inhalation of trichlor- ethylene, carbon tetrachloride, 1,1,l-trichloroethane, dichlorodifluoromethane, and 1,1-dichloroethylene," Toxicol. App. Pharmacol. 10 (1967): 270-289. 27

7 I. S. Gusev, Comparative Toxicity Studies of Benzene, Toluol, and Kylol by the Reflex Activity Methods in Biological Effects and Hygienic Importance of Atmospheric Pollutants, Book 10, U.S.S.R. Liter- ature on Air Pollut:on Occupational Diseases 17(60) (1968).

aK. Bergman, "Whole-body autoradiography and allied tracer techniques in distribution and elimination studies of some organic solvents," Scand. J. Work Environ. and Health 5, Suppl. 1 (1979): 263; also, J. White and G. Carlson, "Influence of alterations in drug metabolism on spontaneous and epinephrine-induced cardiac arrhythmias in animals exposed to trichloroethylene," Toxicol. App. Pharmacol. 47 (1979): 515-27.

9 D. J. Thompson, S. D. Warner1 & B. B. Robinson, "Teratology studies on orally administered chloroform in the rat and rabbit," Toxicol. App. Pharmacol. 2g: 348-57.

0 1IARC, IARC Monographs on the Evaluation of the Carcinogenic Risk of Chemicals to Humans 20 (Lyon, 1979): 515-33; also, National Cancer Institute, Bioassay of 1,1,1-Trichloroethane for Possible Carcinogen- icity, DHEW Publication No. 77803 (Washington, D.C.: U.S. Department of Health, Education and Welfare, 1977).

1Richard D. Stewart, Terrance N. Fisher, Michael J. Hosko, Jack E. Peterson, Edward D. Baretta, & Hugh C. Dodd, "Carboxyhemaglobin elevation after exposure to Dichloromethane," Science 176 (1972): 295-6.

12F. J. Bowman, J. F. Borzelleca, & A. E. Muson, "The toxicity of some halomethanes in mice," Toxicol. Arp. Pharmacol. 44 (1978): 213- 15; W. W. Storms, "Chloroform parties, ' J. Am. Med. Assoc. 225 (1973): 160; S. Winslow and H. Gerstler, "Health aspects of chloroform-a review," Drug and Chem. Toxicol. 1 (1978): 259-75. F. Gamberale, G. Annwall, & Hultengren, "Exposure to Xylene and Ethylbenzene: Effects of the Central Nervous System," Scand. J. Work Environ. & Health 4 (1978): 204-11. J. Angerer and G. Lehnert, "Occupational chronic exposure to organic solvents. Phenolic compounds--metabolites of Alkylbenzene in man. Simultaneous exposure to Ethylbenzene and Xylenes," Int. Arch. Occup. Environ. Health 43 (1979): 145-50.

15MGL, Chapter 21, Sections 26-63.

16MGL, Chapter 111, Sections 17-53.

1 7MGL, Chapter 21 C.

18 Interview with Willard Pope, DEQE, November 13, 1980. 28

19Memorandum from Samuel Mygatt, to Secretary Bewick, July 11, 1979. 20 Assabet Valley Beacon, May 10, 1979. 21Ibid.

2 2EQE Order to W. R. Grace, July 13, 1979. 23 Letter from Herbert Luz, W. R. Grace, to G. Joly, DEQE, July 30, 1979.

24 Letter from G. Joly, DEQE, to Herbert Luz, W. R. Grace, August 18, 1979. 25 Letter from Sabin.Lord, DEQE, to James Murphy, W. R. Grace, July 27, 1979. Jim Schuh, "W. R. Grace Co. plant may get a second chance," The Middlesex News, July 18, 1979.

27Ibid.

28Korde interview, September 22, 1980. 29 Gardner and Ayres, "Acton, Massachusetts: A Ground Water Con- tamination Problem," see note 13, Section 3. gas B aoom

Blow =o n wasgg S.FPM ga Am~annam

ACTON -

EPA Enforces RCRA 29

5.0 EPA Enforces RCRA

On December 10, 1979, the final results of the Goldberg, Zoino, and Dunnicliff (GZD) report were released. As mentioned, the study was commissioned to fulfill a site plan condition of W. R. Grace's new battery separator plant. The report provided the first solid evidence that W. R. Grace's waste disposal practices were polluting Acton's town wells, Assabet #1 and #2. This evidence, together with letters sent by citizens, prompted federal involvement.

5.1 The Goldberg, Zoino, and Dunnicliff (GZD) Study

The GZD report, titled "Groundwater Investigation, Assabet Well Field, Acton, Massachusetts," presented the findings of a study commissioned by the Town of Acton in early 1979. The purpose of the study was to identify organic compounds and their distribution in the Sink- ing Pond Aquifer in South Acton, the probably sources of those chemicals, and to appraise the condition of the aquifer and its potential for future use as a municipal water supply. (The reader unfamiliar with hydrogeology may want to read Appendix V for a brief explanation of an aquifer.) The GZD study has received wide acclaim as a "state of the art" investigation. The firm used computer analysis to model groundwater flow under a variety of pumping conditions. GZD made borings and sunk test wells to determine the physical characteristics of the aquifer, such as the nature and distribution of underlying materials and the direction of groundwater flow. GZD then constructed a three-dimensional "picture" of the aquifer to determine if the chemicals could be traced from their source to the town wells. To get information about the distribution -of contaminants in the aquifer, the two town wells, which had been inactive for some time, were pumped for forty days. Samples were taken for chemical analyses to Energy Resources Company (ERCO) of Cambridge, Massachusetts. The report, issued in final form by January 1980, identified W. R. Grace's primary and emergency lagoons as the principal sources of dichloroethylene, chloroform, trichloroethylene (TCE), ethylbenzene, and methylene chloride found in the drinking water supply. The secondary lagoon was found to be a probable additional source for some organic contaminants. The W. R. Grace property adjacent to the lagoons was considered a possible source for benzene and toluene; the Assabet River was also identified as a possible source of TCE and methylene chloride. Nine EPA priority pollutants and two other organic compounds present in the Assabet #1 and #2 wells were found to be widely distributed throughout the aquifer. The highest concentrations of chemicals were in the deepest portions of the aquifer, proximate to the W. R. Grace site.

( 30

The report stated that in order to restore the municipal water supply, discharging wastewater into the aquifer would have to stop. It recommended that other possible sources should receive further investigation. These other sources included an abandoned petroleum storage tank on the Massachusetts Broken Stone Property, W. R. Grace chemical storage tanks, the Assabet River, and solid wastes in the lagoon bottoms and in the landfill.

5.2 Federal Involvement

The results of the GZD report prompted-action by local, state, and federal officials. Since the report indicated that W. R. Grace was polluting the aquifer, the Acton Board of Selectmen ordered the company to abide by the site plan agreement, which required W. R. Grace to stop its method of waste disposal should it be found to be "endangering Acton Water District wells and adjacent aquifers."I In December 1979, the Enforcement Division of the U.S. Environ- mental Protection Agency (Region I) received a copy of a letter sent to the State Attorney General Francis Bellotti from ACES spokesperson Margaret Korde.2 In the letter Korde outlined W. R. Grace's wastewater treatment practices and the groundwater contamination results to the extent possible. Prior to the letter's arrival, EPA officials in Wash- ington were shifting priority from air and water pollution enforcement to hazardous waste enforcement under the 1976 Resource Conservation and Recovery Act (RCRA).3 Section 7003 of the statute mandates that EPA, upon receipt of any evidence that past or present disposal practices are presenting an "Iminent and substantial endangerment to public health or the environment," may bring suit in U.S. District Court and seek injunctive relief. About the time that EPA Enforcement Branch Chief Lawrence Gold- man was considering ACES' letter, the findings of the GZD report were released to the town. The results of the GZD report led Goldman and his colleagues to the conclusion that W. R. Grace's activities constituted an iminent hazard to the citizens.of Acton. Under Goldman's leadership, the Enforcement Division developed the case for EPA's involvement, and then referred the case to the U.S. Justice Department for a complaint to be brought under Section 7003 of RCRA.4 Assistant U.S. Attorney Carolyn Grace was assigned to the case. As a result of a December 20 meeting among representatives from EPA, DEQE, the U.S. Attorney's Office (Department of Justice), and the Massachusetts Attorney General's Office, it was agreed that the EPA and the DEQE would file a joint suit in Federal District Court. 5 In a December 31, 1979 letter to the Acton selectmen, Carolyn Grace outlined eight major provisions required of W. R. Grace to settle the federal government's claim. According to the Assistant U.S. Attorney, "any agreed plan must insure W. R. Grace's corpora e and financial comitment to at least the following undertakings":

( 31

e Cessation of the ongoing contaminating discharge; * Development of an alternative water source to Assabet Wells #1 and #2; * Renovation, restoration, and long-term monitoring of Assabet Wells #1 and #2 and of the aquifer; e Complete survey, investigation, and decontamination of the W. R. Grace landfill; * Collection and disposal of contaminated ground in the vicinity of W. R. Grace's disposal lagoons; * Collection, disposal and/or treatment of any pumped well water used to intercept contaminated groundwater; and * Investigation and monitoring of any long-term health consequences of the contamination of Assabet Wells 01 and #2 and of the aquifer, with an enforceable time schedule.

With these enforceable performance conditions, the U.S. Attorney began negotiating an out-of-court settlement with W. R. Grace. The firm requested that the federal government delay all legal proceedings until release of the results of the company's own study. In the meantime, the U.S. Attorney, EPA, DEQE, and the State Attorney General's Office were developing a draft consent decree containing the previously discussed provisions.7 On February 1, 1980, representatives from all involved federal and state agencies met with Acton and W. R. Grace officials to discuss the company's discharge into the lagoon system, and how it had affected the aquifer and the two municipal wells. W. R. Grace representatives maintained that the plant had ceased discharging chemical effluents, including 1,1 dichloroethylene, in mid-1979, and ethylbenzene as of February 1, 1980. They stated that the remaining discharge to the lagoons consisted solely of process water and non-contact water from the polyvinyl acetate operations and rain and stormwater drainage. 8 W. R. Grace officials maintained that the Acton plant did not produce hazardous wastes, and therefore no hazardous wastes had ever been deposited at the firm's on-site landfill. It was decided at this meeting that any "special wastes" generated by W. R. Grace must be stockpiled on site until a suitable landfill was located by DEQE for their disposal. 9

5.3 State Withdraws from the Federal Suit

DEQE officials met with representatives from the W. R. Grace Com- pany on February 4 at the firm's request. EPA officials were not invited to this meeting, and no written records or minutes pertaining to this encounter are available to the public. So exactly what happened at this meeting was not recorded. However, unofficial sources indicated that W. R. Grace's intent was to persuade DEQE to refrain Q

6.0 Conflicting Groundwater Studies

In addition to stimulating action by local, state, and federal officials, the Goldberg, Zoino, and Dunnicliff report prompted W. R. Grace to commission a second hydrogeological study by Camp, Dresser, and McKee (CDM). The company also requested that the EPA withhold its suit until the results of the second study were released. When the study was finally completed, it differed in many ways from the GZD report. Notwithstanding the differences, the EPA and the U.S. Attor- ney' s Office found significant areas of agreement to support their enforcement action.

6.1 Camp, Dresser, McKee Study

The CDM report, titled "Review of Report on Groundwater Contami- nation at the Assabet Well Field, Acton, Massachusetts," was commissioned by W. R. Grace after the company received the GZD preliminary report. The purpose of the CDM study was to determine if all pollutant sources had been identified. An introductory letter in the-CDM report states that the evaluation of the GZD data might be used "in order to assist in preparation for possible litigation or for negotiations to settle suits." CDM performed a minimal amount of additional field studies, which included taking limited water quality samples. Laboratory analysis was performed by the Geophysics Corporation of America, Inc. (GCA) of Bedford, Massachusetts. CDM acknowledged that the GZD report represented a comprehensive data profile, but added that it failed to resolve important questions pertaining to the source(s) of contaminants.

6.2 Comparison of Consultant Studies

There were three major areas of conflict between the GZD and CDM studies. These were: (1) exactly which chemicals are present in the aquifer; (2) what the sources of pollutants found in the wells were; and (3) how the chemicals get from source(s) to other parts of the aquifer. There were also technical questions involved in the studies which directly relate to these three issues, such as (a) the reliability of field and laboratory data; (b) whether chemicals in the aquifer were broken down by natural biological agents; and (c) the details of groundwater flow. Both the areas of conflict and relevant technical questions are addressed in detail in the following sections. 35

1. Chemicals Present Table I shows the chemicals identified by the two consultants in the town wells. The presence of 1,1-dichloroethylene (VDC) was acknowledged by both consultants. The presence or absence of other chemicals was a point of disagreement. GZD maintained that at least four other chemicals originated from the W. R. Grace property (found in high concentrations in the waste lagoons). Table II presents the results of eleven independent water quality sampling rounds performed between December 1978 and October 1979 on the town wells. The determination of the extent of contamination of the municipal wells was not limited to the GZD and CDM interpretations. The table illustrates that at least eleven contaminants were identified repeatedly during this period.

2. Sources of Pollutants Table I shows how the consultant reports differ as to probable sources of eight primary pollutant chemicals found in the wells. GZD focused on sources within the W. R. Grace plant site, and CDM emphasized other possible sources, such as the abandoned petroleum tank on the Broken Stone property and the Assabet River. Disagreements as to sources can be traced to differences in the interpretation of groundwater flow and the accuracy of data collected by GZD.

3. Distribution of Chemicals in the Aquifer A major disagreement centers around distribution- of the pollutants in the aquifer as it relates to probable sources. For instance, CDM claimed that because ethylbenzene and toluene are found in discontinuous concentrations, they do not travel the entire distance from the primary lagoon beyond W. R. Grace's well #3 to Assabet Well #2. If an aquifer were composed of a uniform material throughout, one would expect contaminants to move from the source in the direction of groundwater flow under the force of gravity (see Figures 1 and 2). One would expect, furthermore, to find pollutant concentrations highest near their source, and gradually diminishing as a function of distance from the source as the chemical spreads out and becomes more diluted in the groundwater. This pattern was clearly shown for 1,1-dichloroethylene, as Map F shows. Not surprisingly, this chemical caused less dispute than any other. CDM agreed with GZD that the W. R. Grace site was the source, and W. R. Grace agreed to discontinue use of the chemical. For other chemicals, the pattern of concentrations was discontinuous and did not clearly indicate sources. The two reports differed widely in their attempts to explain these discrepancies. For instance, GZD attributed the concentration of chemicals at the bottom of the aquifer (see Figure 3) in part to the fact that they were heavier than water. CDM argued that this was not the case, that the chemicals simply dissolved in the water and that heavier concentrations at depth in the aquifer were due to ground- 36

*r4 "4 r. 4 C 0 C C C 0 co to A, c 9 u .. -% a a 4 r O : w C 0m M M. M. Wir. 0 -r4 C9 09. Cw MC 9 to Co 00 e0 00 00 0 0i 'r c 0C " t C &1. 0 Co C~$ - 0 94 .W 1W .W 0 V

C o0a C CMo. CM aSM a V 0 r4Ca$c to so c CA m iv CCMOa

Uiol - 1 .001 4J41'C T

M C C c 0 O C C 0 C o o o* m4 cc C -0c m; u u a g 90)x1: z D t - 4 = cc c tr).cwc Ai C. V 0 V t * C * 0r- 0 0 0 c o 0 Ai 0 4J W c

0 0 4 C4 C O 04 4 .- C 0 0 Ik 4 'o:C: -A CmV o 0>" 0 0 "0 4 a a 0 0. C cc 9A o o v le m mi A 04.1 Z A ew e 0 % a .-4 = vac a . . = a a)944 u 4 0 .0 d ) 0 |' .0 c cc M WS 00 to C v .0. CO ~ M o. "a a - .. ~ tv aa a WO Is4 0 c) 0 -st

to~~ ~ ~ 04ws 0VC m9iot 0, Mt% C C

'AV.0 0 "MW d In ci 3a -awC ea 0i go 0 " C

0. C . U - 0- ol 00)o "4u1o c a t,V,

0 CC Vtc .9 rW4 u 0 C C e I 1Nto o = 0 N c N 0

"4a u - *s 1-sP4 > 40-- IV 00 - C"4 * to c .g 0 . a Q N O M 4 C ... . 4 L)X I 37

C d to '4 3 I I- 8~~~~ 2RRn. 2: 0 C t42 to 4 .4 C

z I-I Co z 0

8 - C, 4.-' z -3

* 4 1t0 is T 4 + + I 1 * I I '-4 C p i-I -3 IC at 0'

*~ C Ii2 3 -4 -4 II04- C.. 0 to f-rn it t 'LI -3 3 Ni to ae w 6 6

6 38 39

meu..- -:siULV PCyMo eu PI 0,4 ArA

-46 ...gjt..*~aN di

-- /- TT- - N- -

Fig.3 Cross Section of Sinking Pond Aquifer, Showing Concentrations of Total Hydrocarbons

sawrtwaTRm

01 t54eer46iE

000

Fig.4 - - Groundwater Flow and Contaminant Dispersion frm Source 40

C %t r4

Lr Sa 0

C.-

oso 73* -A

seuQ6 O sw -'E J (e fig P * (z

W4b

taxs X COVD 4t~

( 43 water flow patterns. GZD also related uneven distribution of chemicals to the fact that W. R. Grace introduced chemicals into the aquifer at different times, so that one would expect to find pockets of higher concentrations. CDM disputed this hypothesis but did not offer an alternative explanation.

(a) Reliability of Chemical Testing In an effort to establish the extent of groundwater contamination and the configuration of contaminants in Sinking Pond Aquifer, GZD used a total of 75 sampling stations, including three surface and 72 groundwater samplers. Samples were collected during the last nine days of a 40-day pump test to simulate maximum smmer usage of the municipal wells. Specialized samplers were used by GZD to reduce agitation of volatile chemicals during collection (which could alter results of chemical analyses) and to be certain that outside sources of contamination of samples were avoided. Two samples (duplicates) were collected from each sampler and transported to the Energy Resource Company (ERCO) laboratory where they were analyzed by gas chromatograph/mass spectrometer for trace quantities of volatile organic compounds. Results were reported in parts per billion (ppb). The U.S. Environmental Protection Agency (EPA) recommends that standard analysis of volatile organics in groundwater should include a prescribed quality control program. GZD followed these recommended procedures. The role of CDM in the chemical analysis in the aquifer was not nearly as comprehensive as GZD's. CDM had set out to conduct only those tests necessary to challenge GZD findings, and to address alleged "unresolved questions and inconsistencies" in the GZD report. CDM focused its study on potential sources of contamination other than from the W. R. Grace property. Six groundwater and ten surface water samplers were used by CDM during the February sampling round. In a situation analogous to GZD/ ERCO, CDM collected and transported samples to GCA labs where analytical work was performed. CDM/GCA also used a quality control program similar to that used by GZD/ERCO, but did not employ the sophisticated sampling methodology of the previous study. Table III below illustrates the key similarities and differences between the two chemical analyses.

Discussion

This comparison'of the technical studies Illustrates some of the important differences between the two engineering firms on the approaches taken to the problem of identifying the types and locating the sources of organic pollutants in the aquifer. The contamination of "blank" samples by GZD/ERCO technicians raised some doubts about possible inconsistencies with GZD analytical procedures. However, a general consensus was reached by government 44

Town Study by GZD/ERCO W. R. Grace Co. Study by CDM/GCA

1. 75 sampling stations, 1. 17 sampling stations, 86 samples analyzed 21 samples analyzed

2. Pump test simulating 2. No pump test performed actual aquifer conditions

3. Specialized equipment to 3. Samples agitated and reduce loss of volatile aerated during collection chemicals in collection

4. Surface water samples 4. Surface water samples collected 1 ft. off bottom collected through hole in ice near the surface

5. Quality control program; 5. Quality control program some contaminated "blank" samples observed

TABLE III

COMPARISON OF CHEMICAL ANALYSES OF GZD/ERCO AND CDM/GCA 45

officials that these anomalies did not detract from the overall value of the study. Generally speaking, we can conclude that the GZD analysis was .the more rigorous and comprehensive of the two. CDM used only a fraction of the number of sampling sites, did not use collection methods which would avoid "out gassing" of volatile chemicals to the air by agitation (which would change the results of chemical analyses), and used a crude method to collect surface water samples.

(b) Biodegradability of Pollutants in the Aquifer CDM maintained that, although the W. R. Grace Company had been discharging extremely large quantities of contaminated water (70,000 gallons per day from one lagoon) into the aquifer via the lagoons, natural biodegradation of these chemicals by bacteria would remove much of the contamination from the aquifer. In the opinion of Dr. Saul Slapikoff, Associate Professor of Biology at Tufts University, virtually none of the conditions which would favor such biode radation have been shown to exist in the case of the Acton town wells.± (See discussion below.)

Discussion

Comments by Dr. Saul A. Slapikoff of Tufts University on the biodegradation of organic chemicals:

There is evidence that suggests that many, if not all, organic chemicals can be biodegraded under some sets of conditions. Organic chemicals may be degraded to other more oxidized organic chemicals or converted entirely to inorganic products (carbon dioxide, water, nitrate, etc.)--a process called mineralization. For biodegradation to occur in the environment or the laboratory, a number of requirements ordinarily must be met: an active organism or organisms must exist or be available that can metabolize the chemical of interest; the chemical involved rust not be toxic to the degrad- ing organisms; the concentration of the chemical in water must be high enough for effective biodegradation to occur (on the order of 00 ppm); in addition to the chemical itself, sufficient nitrogen and phosphorous must be present to support the growth of the active organism; conditions of oxygen availability, acidity or alkalinity of the water, tem- perature, etc., suitable for the growth of the organism. As a paper cited in the CDM report points out, wells that had been contaminated with gasoline had to be "injected with ammonium sul- phate, monosodium phosphate, and disodium phosphate while air was sparged into the injection wells" for one and one-half years until the odor of gasoline was removed from the well water.* (Reference at end of Discussion section.) 46

Since virtually none of the conditions noted above, other than sufficient concentrations of benzene, toluene and ethylbenzene, were shown to have been met in the case of the Acton wells, CDM's assertion that the "biooxidation studies published by Raymond et al (sic3" make wit . . . clear that benzene, toluene and ethylbenzene detected beneath the W. R. Grace Company lagoons are not contaminating the municipal production wells" is, at best, a guess.

V. W. Jamison, R. L. Raymond and J. 0. Hudson, "Biodegradation of High Octane Gasoline," Proceedings of the Third International Bio- degradation Symposium, J. Miles Sharply and Arthur M. Kaplans, eds., Applied Science Publishers, London, 1976.

(c) Groundwater Flow Patterns Pollutants are assumed to be transported by groundwater flowing through the aquifer. If groundwater can be shown to flow from a known pollutant source directly to the wells, then responsibility for contamination is easily assigned to that source. A major task-of each study, then, was to show the pattern of groundwater flow for the aquifer. GZD used computer modeling to show several flow patterns, depending on which of the five wells (two town and three W. R. Grace) were pumping. Pumping wells can change the direction of flow. Figure 2 shows how, when in operation, Assabet Well #2 can pull water from the Assabet River. CDM arrived at a different flow model which would explain why some, but not all, of the contaminants originating from the Grace site flowed away from the town wells. Map E shows a general groundwater flow scheme for the aquifer.

Discussion

Each consultant study has a stated purpose or agenda, as discussed in the above summaries. Each also has a less specific agenda, unwritten or implied. The GZD report was designed to determine whether the W. R. Grace Company was a major source of contamination. Sampling sites were clustered in the area between the Grace plant and the Assabet Wells; other parts of the study area were poorly represented by sampling sites. Likewise, the only cross-sectional map prepared by GZD (similar to our Fig. 1) shows the W. R. Grace plant at one end and Assabet Well #2 at the other, with groundwater and chemicals appearing to flow from one to the other in a direct line. GZD did not make a great effort to explore other possible sources of contamination.

( 47

CDM's unspoken agenda was to find weaknesses in the GZD report by questioning the validity of data and the accuracy of analytic techniques. Furthermore, CDI attempted to reduce W. R. Grace's responsibility for contamination by focusing on other possible contamination sources. CDM said of GZD, "The report appeared to unduly focus on the W. P. Grace Company as a poiluter."2 CDX attributed differences in water quality data on GZD laboratory misidentification or contamination. 3 There is a message here about the degree of subjectivity applied to consultant studies. Did GZD treat W. P. Grace unfairly? Was it reasonable for GZD to suspect that V. X. Grace was the primary source of contamination, and, given limited funds, to act on that suspicion? Did CDM's client relationship with W. R. Grace affect the consultants' objectivity? Consultants, not unlike lawyers, are caught in a double bind. They must serve two masters: the client and the ethics of their pro- fession. The scientific method of inquiry is intended to eliminate personal preference and insists on objectivity. Nowever, scientists, like lawyers, may not agree on the interpretation of their data, no matter how objectively that data has been generated. It is the nature of the client to seek out a professional who can support his case. To decicion-makers, a report in which the consultant is able to identify and articulate the limitations of his study is the most useful.

Notes to Section 6

t Saul Slapikoff, Instructor of Environmental Toxicology, Tufts University, Medford, Massachusetts, personal interview, November 25, 1980.

2 Camp, Dresser & McKee, Inc., Review of Report on Groundwater Contamination at the Assabet Well Field, Acton, Massachusetts, April, 1980.

3lbid., pp. 16, 60. ; 0,

THE REsoURCE CONSERVATION AND RECOVERY AcT

Public Law 94-580 94th Congress

October 21, 1976

As Amended

by the QUIET COMMUNITIES ACT OF 1978

Legal Resolutions 48

7.0 Legal Resolutions

The EPA granted W. R. Grace's request to await the results of the CDM report before filing their complaint. So, the complaint was not filed until April 14, 1980, one month after the CDM report was released. The complaint resulted in a consent decree between W. R. Grace and the EPA on October 21, 1980. Also, since the DEQE had decided not to join the EPA suit, it issued a second administrative order to W. R. Grace. The EPA complaint, the second DEQE order, and the consent decree will each be discussed in the following sections.

7.1 EPA Complaint

On April 14, 1980, the U.S. Justice Department filed a complaint against the W. R. Grace Company for the EPA in the U.S. District Court of Massachusetts. The complaint stated that the waste disposal practices of W. R. Grace in Acton presented "an imninent and substantial endangerment to the health and/or the environment, within the meaning of Section 7003 of the Resource Conservation and Recovery Act, 42 U.S.C. §6973."1 The complaint also identified six of the previously mentioned chemicals as migrating from W. R. Grace's property in Acton to the groundwater in concentrations which are hazardous to human health and the environment. The EPA complaint listed eleven "Prayers of Relief" which were similar to those which Assistant U.S. Attorney Carolyn Grace had outlined for the Acton Board of Selectmen. When the complaint was filed, however, the town chose not to become intervenors; the selectmen were dubious of EPA's control over the resolution of the issue and did not feel it was necessary to become partner to the suit. Later in the summer, though, they reconsidered their position, and on September 30, 1980, they voted to join the suit as "the best protection for the town," 2 on the heels of the negotiated settlement. ACES and the Sierra Club had petitioned to join the suit earlier. Prior to a court decision on the standing of these organizations, they agreed to withdraw their petition in support of the consent decree.

7.2 Separate State Action

The decision by DEQE not to be party to the complaint, originally drafted by this agency and the EPA, necessitated their pursuing a different course of action. The DEQE maintained that it could deal more quickly and effectively with W. R. Grace through another administrative order, but this time with one of greater scope and comprehensiveness than that issued in July 1379. This second order was based on a draft of the EPA consent decree. 49

The DEQE order, issued on July 14, 1980, begins with a brief summary of W. R. Grace's waste disposal practices and violations of state law, including the Hazardous Waste Management Act, the Solid Waste Disposal Act, and the Clean Waters Act. In the order, DEQE acknowledged W. R. Grace's denial of all but two of the various allegations listed. W. R. Grace was ordered to Immediately cease (1) the disposal of any wastewater on the site, except as approved by the DEQE (W. R. Grace claimed to-have already done this, as of February 1, 190 4); (2) the usage of the landfill; and (3) the disposal of any hazardous chemicals upon the grounds of the site from any source. W. R. Grace was ordered to design and implement, within a two- month period and with the DEQE's approval, a collection and diversion system for all liquid wastes and runoffs that were being discharged into the primary, secondary, and emergency lagoons. A monitoring system for hazardous wastes was also required. Extensive investigation of chemical contamination of land and water at the W. R. Grace site, through a sampling and analysis method, was mandated with a timetable and subsequent approval by the DEQE. Once the extent of the contamination of the lagoons, landfill, and surrounding areas was determined and approved by the DEQE, a complete engineering analysis was required for a cleanup of the site, with particular emphasis on disposal alternatives for all liquid and solid hazardous wastes. Based upon the results of the engineering analysis, W. R. Grace was required to come up with a plan for the cleanup. The plan was to include cost estimates and a timetable, together with Implementation of a thirty-year follow-up monitoring system for verification. Monthly progress reports to the DEQE were required throughout the process. Aquifer cleanup and restoration were also addressed, and a similar sequence of investigation, analysis, cleanup and monitoring of the aquifer was mandated. W. R. Grace was requested to work, when necessary, in cooperation with the Town of Acton and the Acton Water Supply District and to finance all restoration measures. Finally, the order stated that the DEQE, the town selectmen, and the Acton Water Supply Commissioners (and their hired consultants) may inspect the W. R. Grace facility for general compliance with the order, as well as to verify information submitted by W. R. Grace. Moreover, the company was not to sell any of its Acton property without providing for the fulfillment of the order. The DEQE left open the possibility of initiating judicial proceedings at W. R. Grace's expense, in the event that it objected to compliance with any part of the order and failed to come up with an acceptable alternative. 5 50

Discussion

W. R. Grace did not admit to the allegations contained in the DEQE order.6 Indeed, admission to the allegations would clearly incrimi- nate the company with respect to the EPA complaint--a document from which the state order was modeled. The DEQE was primarily concerned with starting cleanup of the site. In this light, then, getting V. R. Grace to accept the terms of the order without admitting guilt or requesting a hearing (which would have further delayed the cleanup process) was evidently a worthwhile tradeoff for the DEQE. The threat of rejoining the federal suit if it felt that the negotiating process was not proving fruitful, may well have been an additional bargaining lever for the state agency.

7.3 EPA: The Consent Decree

On October 21, 1980, the EPA announced in a news conference the resolution of its suit against the W. R. Grace Company in the form of a consent decree. The settlement called for W. R. Grace to clean up and restore its Acton facility property through a sampling analysis and cleanup procedure, each step requiring EPA review and approval. A similar procedure is required for cleanup and restoration of the aquifer. A thirty-year monitoring program is to follow the cleanup. W. R. Grace can be fined up to $2500 a day for each day it is late in complying with the various steps of the decree. The terms of the decree are, to a large degree, similar to those of the second DEQE order. Differences could be found in the treatment of the lagoons, the aquifer cleanup, and the procedures for dispute resolution. One provision calls for W. R. Grace and the EPA to coordinate their efforts with the implementation of the DEQE order. The EPA was able to settle the lawsuit, obtaining all of the "Prayers of Relief" in its April 14 complaint, with the exception of two: the provision of alternative water sources for the Town of Acton and a health study. The consent decree is an important step in dealing with hazardous waste issues, especially one as complex as the Acton case. The EPA managed to obtain most of its demands as stipulated in the complaint, and the negotiation process was undoubtedly influenced by several factors. An important precedent was the outcome of The United States vs. Solvents Recovery (1980), where the federal court in Connecticut ruled that the EPA could sue parties under the Resource Conservation and Recovery Act for their past waste disposal practices. The finding that a disposer of hazardous wastes can be held liable for its past as well as present waste disposal methods had obvious significance for W. R. Grace. Per- haps the most important factor in bringing about an out-of-court settlement was the setting of an early trial date (November 1980), which placed W. R. Grace in the position of having to prepare a for- midable defense within a short period. 51

At aDiscussion

Although the EPA and the Justice Department were willing to resolve the matter without filing suit, V. R. Grace consistently was unable to satisfy federal officials during the negotiation process. The EPA desired a specific proposal from the firm that could be enforced by the court. V. R. Grace promised the agency it would have specific extensive proposals by the first of the month in both February and March. When the company failed to do so, EPA decided to file suit contingent upon the results of the CDM study. When, in the opinion of the EPA, the study was found to be deficient, the decision was made to initiate court action. The complaint submitted was worded in general terms in order to be comprehensive but flexible. Yet it is questionable whether several of the remedial measures requested by the EPA would have been granted by a court. It is unclear whether Section 7003 of RCR has such broad authority as to require W. R. Grace to provide an alternate water supply and fund an epidemiological health study.

Notes to Section 7

Complaint brought by the United States Department of Justice against the W. R. Grace Company, April, 1980. 2 Letter from Selectman Hayden Duggan, to Chairwoman Joyce Foley, August 18, 1980, p. 2.

3 Interview with Willard Pope, DEQE, November 13, 1980.

4Response of W. R. Grace to first request for production of documents submitted by plaintiff, United States of America, to the defendant. Aid Action No. 80-748-C.

5DEQE order to W. R. Grace, July 14, 1980.

Pope interview. C

( 52

8.0 Policy Analysis

As hazardous waste sites continue to be discovered, communities throughout Massachusetts and the country will be deciding how to resolve the complex problems associated with them. Whether or not one views the Acton case as a model for other communities, it does offer some lessons and insights into the decision-making process. In this final section, we shall discuss some of the significant features of this episode through the following categories of analysis: the role played by the citizen group; information; state, federal and local agencies; and the element of time. These interrelated factors reveal the forces which impeded and impelled the decision-making process and resulted in a legal settlement of the case. Let us begin by considering the role of citizen advocacy. Can it make a difference? In the case of Acton, individual and collective action was effective, and the reasons why this happened could apply to any community. The role ACES played as watchdog and investigator was particularly important in the Acton case, because all the issues involved were not being brought into the public forum for discussion. Through the grass- roots efforts of ACES, the decision-making process became publicized and somewhat more self-conscious. The key to ACES' success was in its ability to organize, to establish "pressure points," to develop a network of contacts in various agencies, and finally, to maintain an active presence with media attention. Perhaps the crucial factor was ACES' ability to make use of available resources, and to work tenaciously to find information that was not readily accessible. They made use of the Freedom of Information Act; they were constantly questioning the decisions of public officials (such as the right to hold executive sessions); and they monitored, to the best of their ability, the governmental decisions and the activities of the W. R. Grace Company. This leads us to an important issue raised by the case: how is the public right to know defined? What are the limits to citizen requests for information? And what tradeoffs are involved in keeping knowledge from the public in order to best represent its interests? Our purpose here is not to reach a conclusion, but rather to emphasize that such a tradeoff was made in the Acton case, and is made in other similar situations. The Board of Selectmen knew that the wells were contaminated when it approved the W. R. Grace site plan, but did not make that knowledge public on the grounds that it would have broken down negotiations and prevented the sensitive agreement through which the company paid for a hydrogeological study. Throughout the two years, much of the negotiations took place in executive sessions despite opposition by citizens who wanted to be part of the process. While the delicate legal nature 53 of the case may have justified some of these sessions (for instance, W. R. Grace was able to speak more openly), the grounds for closing many others were questionable. Selectman Joan Gardner insisted that exclusion of the public was essential in order to bring about a settlement-and indeed she felt that ACES, at times, hindered rather than helped the process. There is no way to know what would have happened had the process been opened up and public participation encouraged. There are those who argue that the right of citizens to know and affect policy super- sedes the potential benefits of private negotiations. But Selectman Joan Gardner stated that her re-election was an affirmation of public confidence-despite the executive sessions. (Another selectman was not re-elected.) Executive sessions also meant that knowledge was kept from the public-knowledge which ACES was determined to acquire. They felt that the public had the right to be told about the complicated technical and legal issues facing the town; they believed that officials were not fulfilling their obligations to explain those issues to the people. At this point, the effectiveness of public agencies becomes an important consideration. Agencies at all levels work within certain limits; understanding those limits gives one a better perspective on the "bureaucratic red tape" stereotype. The state regulatory agency (DEQE) in particular was constrained by many factors: intra-agency conflicts, political pressure, the ability to gather technical information, and staff and funding shortages. Just as the agency responded to the citizens' external pressure for positive action, it was restrained to some degree by the significance of W. R. Grace's influence in the state. The DEQE was vulnerable to political repercussions if it took actions against W. R. Grace that were "unduly harsh" or dis- criminatory. Aside from political and economic considerations, the necessary reliance on scientific knowledge seriously Impaired the DEQE's ability to act. Initial delays resulted from a lack of definitive evidence that could have been provided by a mass spectrometer/gas chromatograph. Then there was the uncertainty over whether W. R. Grace caused the contamination. To this end, the GZD report was of primary Importance. This information not only took considerable time to gather, but also raises the problem of handing responsibility to consultant firms which are subject to the pressures of client-employer relationships when vital data is at stake. Overall, the state agency took action on the case after long periods of delay when the local pressure began to build. As in many similar cases, a strong local initiative preceded state and federal actions. Moreover, state action became more aggressive when federal authorities took an active role in the case. Underlying all the activities was the key element of time, a critical factor in shaping the decision-making process. For citizens groups, it may mean (as it did for ACES) a long-term commitment to achieving their goals, as well as the possibility of losing momentum the longer the negotiations go on. 54

Time worked both for and against W. R. Grace. The company wanted the new plant built, and so was in a position to reach a quick agreement on the hydrogeological study. The company would not benef t from a protracted well-publicized litigation with the U.S. Justice Department, and so had reason to settle out of court-even though the court may have ruled in favor of W. R. Grace on some issues if the case had been tried. The U.S. Attorney's success in obtaining an early court date put additional pressure ouW. K. Grace, giving the company little time to prepare a defense. There is also the question of agency priorities changing over time. The EPA was ready to act on ACES' request because dealing with hazardous wastes was the new national focus. The ability to take a case like this to court rests in the substance of technical evidence. The EPA became involved after the release of the GZD study, but waited until the CDM report was completed before filing its complaint. On one hand, the CDM report could have weakened EPA's case, but on the other hand, EPA had to give the W. R. Grace Company sufficient opportunity to respond to the GZD study. If it hadn't, the court may well have done so. As it turned out, EPA found sufficient agreement in the two studies to justify aggressive enforcement of RCRA. It was, in the final analysis, a constant push and pull of factors acting on all the various parties that shaped the outcome of the process. A recognition of these factors and their concrete manifesta- tions by local citizenry can determine whether they are able to control the issues confronting their community or are controlled by them. i ( 55

-amp :acb APPENDIX I - no Ju CHRONOLOGY OF EVENTS rh ani the 1945 Dewey and Almy plant built in South Acton

1954 W. R. Grace acquires Dewey and Almy plant; W. R. Grace tests water and discovers nitrates, A-5 1: sulfur, and inorganic chemicals e-:1 In i 1971 Acton Water Supply District (AWSD) opens Assabet 9 z ter Wells #1 and #2 cou. 1973 Odor of contaminants detected in water near the ,re r Massachusetts Broken Stone property north of the Assabet wells; Complaints about air pollution surrounding the W. R. Grace plant begin to be registered at the 01 Acton Board of Health

1978 June Water tests near the Massachusetts Broken Stone - -- property by the AWSD, Massachusetts Department of LI Environmental Quality Engineering (DEQE), and the Division of Water Supply again show strong chemical odors

July 23 Board of Selectmen receives site plans for the expansion of the W. R. Grace battery separator plant

July 24 Environmental Notification Form filed by W. R. Grace under the Massachusetts Environmental Policy Act

Aug. 1 AWSD receives notification that W. R. Grace intends to expand

Aug. 21 Secretary of Environmental Affairs, Evelyn Murphy, determines that an Environmental Impact Report (EIR) is not needed

Aug. 22 Steve Calichman, Director of the Acton-Board of Health, conducts a site inspection of the W. R. Grace plant

( 0 56

1978 Aug. 23 AWSD sends letter to Town Manager Christopher Farrell requesting a study of the Sinking Pond Aquifer

Aug. 24 Gilbert Joly of DEQE requests hydrogeological study

Sept. 1 Steve Calichman sends memo to Board of Selectmen recommending conditions for site plan .

Sept. 5 Board of Selectmen conducts site plan hearing for W. R. Grace's proposed expansion; a standing-room- only crowd of citizens attends the hearing

Oct. 6 AWSD sends Christopher Farrell the results of well tests done in the Sinking Pond Aquifer

Oct. 20 AWSD sends letter to Board of Selectmen suggesting conditions for site plan approval; EPA tests Assabet Wells #1 and #2 for organic chemicals

Nov. 6 EPA results indicating organic chemical contamination of wells reported to DEQE by phone

Nov. 7 Informal reports made to town officials of chemical contamination of Assabet Wells #1 and #2

Nov. 14 Board of Selectmen approves W. R. Grace's site plan under the condition that the company fund a hydrogeological study

Dec. 5 Board of Selectmen, Board of Health, and Water District Commission meet to discuss well contamination

Dec. 19 Assabet Wells #1 and #2 closed as a precautionary measure; Hydrogeological study is begun by Goldberg, Zoino, Dunnicliff, and Associates (GZD); News of EPA results concerning well contamination reported to the public

1979 January Acton Citizens for Environmental Safety (ACES) forms; GZD mnd EPA perform additional water tests

February GZD and EPA tests completed

March 8 Results of latest water tests made public-they show no contamination of Assabet Wells #1 and #2; Second set of water tests begins 57

1979 May Various studies done on how to remove contamination from water; Preliminary report of GZD indicates chemicals found in municipal wells; Gilbert Joly of DEQE requests that W. R. Grace stop discharging

July Attempts made with carbon filtration to reduce dichloroethylene in drinking water

July 10 Board of Selectmen denies W. R. Grace an occupancy permit for their new battery separator plant

July 13 Anthony Cortese, Commissioner of DEQE, sends first administrative order to W. R. Grace, informing them that their disposal methods are illegal and proposing a two-year timetable for compliance

July 24 Occupancy permit reconsidered and approved by the Board of Selectmen

November ACES writes a series of letters to the Board of Selectmen and various other public officials, requesting them to order a halt to W. R. Grace's discharge practices

December Enforcement Division of EPA receives a letter from Margaret Korde of ACES, via the Massachusetts Attorney General's Office; Camp, Dresser, and McKee (CDM) begins a study of the Sinking Pond Aquifer for the W. R. Grace Company

Dec. 10 GZD study preliminary results indicate W. R. Grace is polluting the aquifer

Dec. 18 Board of Selectmen orders W. R. Grace to stop disposal practices

Dec. 20 Representatives from EPA, federal Justice Department, DEQE, and the State Attorney General's Office meet at the U.S. Attorney General's Office in Boston to discuss and coordinate agency actions

Dec. 31 U.S.- Attorney Carolyn Grace sends letter to Acton Board of Selectmen, outlining eight major provisions of Department of Justice complaint 58

1980 January Final GZD report released

Feb. 1 Representatives from federal and state governments meet with representatives from Acton and W. R. Grace; W. R. Grace claims ethyl benzene has stopped being discharged into lagoons; CDM report is completed

Feb. 4 DEQE officials meet with representatives from W. R. Grace (EPA is absent)

Feb. 8 DEQE informs EPA they no longer intend to join suit

March CDM report is released; A draft agreement between W. R. Grace, Acton, and DEQE is rejected by federal officials (EPA and U.S. Attorney)

April 17 U.S. Attorney files complaint for EPA under the Resource Conservation and Recovery Act (RCRA) against W. R. Grace

June 16 DEQE orders W. R. Grace to cease certain chemical disposal practices and to take a number of actions regarding the cleanup of hazardous waste

July Trial date set for November 10, 1980

July 14 DEQE issues second administrative order

August Sierra Club Legal Defense Fund and ACES vote to file a motion to intervene as a party in the suit against W. R. Grace

Sept. 30 Selectmen vote to join EPA suit; the town never moved to intervene

Oct. 21 Consent decree reached between EPA and W. R. Grace, with the company agreeing to a scheduled cleanup and monitoring of the polluted aquifer; Sierra Club and ACES withdrew their motion to intervene 59

APPENDIX II

THE W. R. GRACE COMPANY

A. A Multinational Corporation

To the people of Acton, the W. R. Grace Company is a local industry that contributes taxes, offers some employment opportunities, and cre- ates products. More recently, this company has become involved in a protracted debate over water quality that consumed much of the town's attention for two and a half years. But the W. R. Grace Company is substantially more than what the people in Acton have seen. It is a company of considerable size, with many directions and a corporate image that is still in the making. We offer a portrait of the company to place its Acton operations in a larger perspective. The W. R. Grace Company was first established in the late nineteenth century as a Peruvian shipping line. Incorporated under Connec- ticut laws in June, 1899, W. R. Grace today is a multi-billion dollar, transnational conglomerate with subsidiaries and operations in many countries. Currently, W. R. Grace operates fifty-six companies in twenty-four states in the United States, and has subsidiaries or wholly- owned companies in South America, the Pacific and Far East, Africa, Europe, and the Caribbean (see Table IV). In all but three locations, the operations are owned and controlled by W. R. Grace. The exceptions are those facilities in Trinidad and Tobago and Jamaica, where W. R. Grace controls less than fifty percent of the appropriate stocks. In the early 1960s, W. R. Grace was not included in the list of the top ten chemical producers. However, less than twenty years later, the company was listed as the fifth largest chemical corporation with sales of 5.3 billion dollars. 1 In 1979, W. R. Grace increased its sales (over 1978) by 18 percent. Likewise, operating income *fter taxes rose from $221 million in 1978 to $284 million in 1979. J. Peter Grace, president of W. R. Grace, has indicated a growth potential of ten billion dollars within the next four- years. 3 In the first quarter of 1980, W. R. Grace had increased sales by more than 17 percent.4 As a multi-billion dollar corporation, W. R. Grace is broken up into three main industry segments: chemical, energy/natural resources, and consumer. The basic markets are given in Table V. The expansion of W. R. Grace's activities and interests has been dramatic and diverse. As- an example, W. R. Grace announced in September of 1980 that more than $35 million was designated to be spent "to expand its flexible packaging materials operations in Great Britain, France, Italy, West Germany and Spain." Attempting to capture a major portion of the lucrative European market for maintenance-free batteries, W. R. Grace decided, in June 1980, to build a $20 million plant in France for the manufacturing of the battery separators utilized in the production of maintenance-free batteries-. 60

North America: Canada, United States of America

0. South America: Brazil, Chile, Colombia, Venezuela

Caribbean: Aruba (Netherlands), Bermuda, Jamaica (49%), Puerto Rico, Trinidad & Tobago (49%)

Europe: Belgium, France, Germany, Italy, Netherlands, Spain, Sweeden, and the United Kingdom (England, Scotland, Ireland and Wales)

Africa: Lybia, South Africa

Pacific & Far East: Australia, Hong Kong, Japan, New Zealand, Singapore, and South East Asia

TABLE IV

W.R. GRACE COMPANY: INTERNATIONAL LOCATIONS

(Source: Moody's Industrial Manual, March 1980, pp. 1228-31.)

Automotive/Auto Parts Home Centers Construction Sporting Goods Environmental Jewelry Health Care Coffee Shops Animal Husbandry Dinner Houses Crop Production Cocoa Products Development & Exploration Specialty Textiles Chemicals

TABLE V

W.R. GRACE COMPANY MARKETS 61

As a final example of the range of W. R. Grace's interests and activities, the corporation recently announced the formation of a $400 million, 50-50 joint venture with the International Minerals and Chemi- cals Corporation for the production of phosphate rock in central Florida. This most recent venture will enhance the position of W. R. Grace in the international fertilizer market. What will the W. R. Grace Company of the future look like? Perhaps the most fundamental change in the corporation's activities will be a significant shift in its present sales/profit structure. In 1979, W. R. Grace's profit-mix was 58% chemical, 29% energy/natural resources, and 13% consumer. According to a recent interview with the president of W. R. Grace, we are likely to see "energy become 60% of the company simply because we have a chance to make it so large that it may dwarf all others." 5 Indeed, it appears that W. R. Grace is undertaking this shift in priorities. Complementing W. R. Grace's existing reserves of 100 million barrels of oil equivalent will be the estimated production in 1980 of 112 million barrels of oil. In addition to its oil and natural gas holdings, W. R. Grace has coal reserves of close to 240 million tons. Although W. R. Grace is attempting to change its sales/profit mix, its multinational behavior should remain consistent with past practices. In addition to strategically locating production operations near available and instrumental raw materials, W. R. Grace will continue to invest only in politically stable countries. Like other multinational corporations, W. R. Grace has fallen victim to political upheaval. Conse- quently, W. R. Grace has withdrawn capital from areas exhibiting political instability. For example, W. R. Grace recently extracted 75% of its net worth ($165 million) from Latin American countries. 6

B. Chemical Activities

The W. R. Grace chemical sector, besides being the most established division of the company, is also the largest in terms of sales and profits. For example, in 1979, chemical sales were 53% of the total sales, while the chemical division commanded 65% of the company's operating income after taxes. 7 The chemical division consists of three components: specialty chemicals, "Chemed" (which for purposes of this study will be treated as a sub-division of the specialty chemicals group), and agricultural chemicals. The specialty chemicals sales in 1979 reached $2 billion, with operating income after taxes totalling $152 million. The agricultural chemicals division had.sales of $683 million in 1979, with an after-tax income of $33.6 million. 8 W. R. Grace's chemical operations include 52 plants- located in 21 states and several foreign countries (including five plants in Massa- chusetts: Acton, Adams, Canton, Cambridge, and Lexington; see Tables VI and VII). Sales operations for the division span five continents. W. R. Grace is currently investing heavily into the battery separators market overseas, having recently announced intentions to construct a $20 million plant in Europe. 9 62

Agricultural Chemicals: Florida, Illinois, Indiana, Kentucky, Louisiana, Michigan, Missouri, North Carolina, Ohio, Puerto Rico, South Carolina, Tennessee, Texas

Industrial Chemicals: Maryland, California, Massachusetts, Louisiana, Ohio, Tennessee .

Organic Chemicals: Ohio, Kentucky, New Hampshire, New York

Technical Products: Georgia, Illinois, Indiana, Iowa, California, Massachusetts, Pennsylvania, New Jersey, Wisconsin, Texas, South Carolina

Polyfibrin: Pennsylvania, Massachusetts, Georgia, Wisconsin, Kentucky

TABLE VI

U.S. OPERATIONS OF W.R. GRACE

(Source: 1978 Directory of Chemical Producers - U.S.A. SRI Inter- national.) K

W. R. Grace is also investing heavily in the fertilizer component of their agricultural chemicals division. In June of 1980, the company announced the formation of a $400 million, 50-50 joint venture for the production of phosphate rock in central Florida.l' Perhaps the largest potential outlet for Grace's products exists on a different continent. The Overseas Chemical Division has recently acknowledged its intention to court the Chinese in anticipation of China's presumed needs in the heavy chemical industry.1' The following is a brief outline of the chemical division's activities and products. Special emphasis is given to W. R. Grace's industrial activities in Massachusetts. (See Table VII.) Agricultural Chemicals. The principal market for the segment's products is the United States. However, approximately 29% of fertilizer products, principally phosphate rock, concentrated phosphates, and amonia is placed in world export markets. 12 All of the principal raw materials needed for the company's agricultural chemical operations in the United States are produced by the company in the United States, with the exception of potash, which is imported primarily from Canada; sulfur, purchased from domestic sup- ( .63

GROUP/DIVISION PRODUCTS (MASSACHUSETTS LOCATIONS) Industrial Chemicals Group -chemically-based specialty products for industrial commercial, highway, heavy & residential construction, horticultural fertilizers, soil mixes & conditioners Organic Chemicals Group -dispersing agents (Acton, Cambridge) -chelating agents -elastomers (Acton) -plastics & resins (Acton) -organic sulfur compounds Technical Products Group Cryovac Division -plastic packaging materials Dewey & Almy Division -container sealants (Cambridge, Canton) -compound application equipment (Acton, Cambridge, Lexington) -dielectric materials (Canton) -microwave & flotation products (Canton) Polyfibron Division -printing plate systems (Acton, Adams, Lexington) -printing blankets & high velocity dryers for the printing industry (Acton, Adams, Lexington) -battery separators -saturated & specialty papers for pressure sensitive & gumed tapes Chemed Group -water, waste treatment & air pollution control products & services -health care products & services, such as environgermicides & skin cleansers -institutional food service chemicals, including detergents, rinse additives & other products for dishwashing & kitchen maintenance -cleaning & maintenance compounds -sanitation chemicals -paint strippers -laundry products -specialty lubricants for use in the manufacturing, transportation & food & beverage processing industries

TABLE VII

GROUPS/DIVISI.NS, PRODUCTS OF W.R. GRACE FOR MASSACHUSETTS 64 pliers; and amonia, which is supplied to certain of the company's U.S. plants from the company's Trinidad operations. The agricultural chemical division currently has over 20 plants, with 18 of them in the United States. There are no agricultural chemical plants in Massachusetts. Some of the principal products manufactured by this division are: fertilizers (mixed, blended, and fluid), lawn and garden products, ammonia, and nitrates.

Specialty Chemicals. W. R. Grace's activities in the specialty chemicals sector is far more extensive in both resources and locations than the agricultural chemicals sector. In both sales and operating income after taxes, the specialty chemicals division maintains more than twice the totals of the agricultural division. Specialty chemicals are differentiated products designed to meet specific performance standards. Unlike commodity or bulk chemicals, they are produced in relatively small amounts and formulated to the specifications of industrial customers. These formulations are based on patented or in-house technology. Similar to the agricultural chemical division, the majority of the raw materials consumed by this division are either produced by W. R. Grace in the United States or are purchased from domestic sources. The specialty chemicals division currently has over 40 plants, 39 of which are in the United States. There are five specialty chemicals plants in Massachusetts and one in New Hampshire.1 3

C. Operations in Acton, Massachusetts

The site of the W. R. Grace plants in Acton, Massachusetts has been subject to previous industrial activities. Originally utilized by the American Cyanamid Company for a munitions plant, the present site was obtained by the Dewey and Almy Company in 1945. Seeking to expand its synthetic rubber operations and to accomodate the demand for latex products, the Dewey and Almy Company, in 1949, constructed the chemical facility occupied by W. R. Grace today. In 1951, the first battery separator plant was added to the company's complex. Largely as a result of W. R. Grace's acquisition of the Dewey and Almy Company in 1954, there was expansion of both the organic chemical plant and the battery separator plant in the late 1950s. There were no additions to the property until the new Daramic battery separator plant was built in 1979.14 The following description of industrial processes may have changed in the past two years, because of new restrictions placed on the plants' operations. The W. R. Grace facilities in Acton have utilized four processes. The first production operation is a simple mixing technique employed in the manufacturing of air entraining agents, water reducers and retarders. The materials are used in the making of concrete. 65

Another production operation, the "Z" process, is used by W. R. Grace in the manufacturing of container sealer compounds. The production of these compounds involves 51 different raw materials. Among these are: polyvinyl chloride (PVC), toluene sulphonamide, formaldehyde resin, trichloroethylene (TCE), hexane contaminated with ethylbenzene, and styrene or butadiene. Waste from the "Z" process flows by gravity to W. R. Grace's Primary Lagoon, and any supernatant which forms there is then pumped to the company's Secondary Lagoon. 1 5 The third manufacturing process, the latex operations, also involves a variety of chemicals. These include: butadiene, styrene, and polyvinyl acetate (PVA). Product lines known as Copol-, Daran and PVA are manufactured 'using these chemicals. Another dispersing-agent product, DAXAD, is manufactured by aqueous solution polymerization. Hypol, a polyurethane prepolymer, is manufactured here also by conden- sation polymerization. Effluent from these latex processes were discharged to the Primary Lagoon in the Acton facility by a gravity flow system. The volume of waste varied from 25,000 to 350,000 gallons per day, during peak production periods. However, over the past three years the volume has been generally 30,000 to 40,000 gallons per day. 1 6 This effluent contains many chemicals, such as styrene contaminated with ethylbenzene, 1,1-dichloroethylene, and vinyl acetate. In the Primary Lagoon, solids settle out and supernatant fluid is pumped to the Secondary Lagoon. From the Secondary Lagoon an estimated 70,000 to 75,000 gallons per day entered the groundwater. 1 7 Pumping was done several times per week. Each July the Primary Lagoon was dredged of solids, which were then trucked to the W. R. Grace industrial landfill. About 250 cubic yards of solids were discharged annually. Reports by W. R. Grace officials suggested that this material contains the substances polyvinyl acetate and butadiene,sstyrene copolymers. 1 8 The fourth manufacturing process involves the manufacturing of both plastic and paper battery separators. Paper separators are made by taking paper sheets and impregnating them with phenol formaldehyde resin and wetting agents. These sheets are then dried in a hot air oven where clay-filled PVC ribbing compounds and more curing agents are added. (This is probably the source of -odors which drew complaints from residents adjacent to the Acton plant.) Plastic separators are made by mixing several raw materials which are formed into pellets. The pellets are then extruded and made into sheets. Next, the sheets pass through an extractor where oil is extracted into hexane. 1 9 Discarded materials from the battery separator operations were placed just north of the Cellulose Building in three interconnected lagoons. Floor drains also enter the lagoons. These effluents came from non-contact cooling waters, which were used for cooling the air compressor and rollers used in Impregnating operations. Other contaminated effluents came from flushing a caustic tank system and intermittent water scrubbings of gaseous exhausts. Traces of phenol formaldehyde and sodium hydroxide were found in the effluent. At one point in the operation of the plant, occasional flushings of the Impregnator 66 bather were also part of the effluent. This has been curtailed, however, and now the flushings are either recycled or removed. Also, underground raw material storage tanks were-at one time- flushed once per year. These were flushed to the west of the boiler room. Approximately 60,000 gallons of flushing effluent containing water and phenol formaldehyde (concentration unknown) were discharged during these operations. More recently, every three or four days, about 10,000 gallons of cooling water were discharged from the battery separator operations. This effluent contains less than 10 ppm hexane.20 In addition to the discharge of wastes from W. R. Grace's on-site operations, waste from Grace's Cambridge plant were at one time trucked to Acton. The exact contents and quantities of these wastes are not known. The transport of this waste was not stopped until February 4, 1980.21 Finally, there were other miscellaneous raw materials and wastes which have been used at W. R. Grace in Acton. Grace admitted to generating waste from Building #13 which contains styrene and 1,1-dichloroethylene. According to the company, 1,1-dichloroethylene was last used as a raw material in May 1979. Another chemical, benzene, was used as a raw material up until 1968. Also, the battery separator operations generate a large amount of solid waste in the form of trim scrap containing phenol formaldehyde. This amounts to approximately 500 pounds of material per day. The material has been stored in a field from 1955 to the present. 2 2

D. Other Controversies

W. R. Grace, like many large multinational corporations, is con- tinually involved with legal matters and proceedings concerning the company's manufacturing processes and operations. Due to both its rapid expansion in consumer products, as well as a heightened public awareness of hazardous waste problems involving chemical operations, W. R. Grace has been tested on several fronts. For the year 1979, eight environmental proceedings involving W. R. Grace were adjudicated. By year's end 1979, W. R. Grace was a party to eleven administrative or judicial proceedings (ten of which concerned water pollution) involving the discharging of materials into the environment or other environmental protection matters. 23 (See section E, Appendix II for a listing of recent Environmental Protection Agency actions involving W. R. Grace for the southeast region of the United States.) In addition to the Acton case, there has been at least one other chemical-dumping instance involving W. R. Grace operations in Massachu- setts. Since 1978, W. R. Grace has been involved in a well-publicized controversy resulting from the Massachusetts Bay Transportation Authority's (MBTA) extension of the rapid-transit system from Harvard Square to Alewife Brook Parkway in Cambridge, Massachusetts. 2 4 In September of 1978, consulting engineers working on the MBTA extension discovered 67 deposits of acid underlying W. R. Grace property. Soil samples from the site were delivered to the testing labs of the Department of Environmental Quality Engineering (DEQE), but due to a backlog at the laboratories, these tests were never completed. Again in February of 1979, additional soil analyses on W. R. Grace property in North Cambridge revealed an extensive contaminant plume of acid. The level of agidity registered pH 2 in the contaminated soil (pH 7 is neutral). 2 3 There appeared to be disagreement among MBTA officials concerning the extent of the contaminant plume. However, they did agree that it had a high sulfate content, and it was concluded by the MBTA officials that the contaminants presented no direct health hazard at that time. Meanwhile, W. R. Grace's attorneys recognized that the contamination was derived from a neutralization lagoon used by the company between 1965 and 1970. By-products from the production of DAXAD, an industrial dispersing agent, were deposited into a rubber-lined outdoor lagoon filled with a neutralizing chemical. Periodically the lagoon was dredged and the treated by-products were spread on the ground surface near the proposed tunnel construction site. However, the acid which was allegedly neutralized apparently leached through the soil. At that time, the Cambridge Water Department indicated that there was no evidence that these acidic contaminants had infiltrated the city's water supply at the nearby Fresh Pond Reservoir. Almost six months after the discovery of the contaminants material at the Cambridge facility, state and federal engineers were still unable to identify its contents. Further testing had revealed the contamination to be 50% organic but had done little to determine the toxicity of the sludge. The DEQE, however, has classified the material as a "special waste" to be disposed of at a hazardous waste dump, and has determined that the sludge was "too dangerous for ordinary landfill disposal.,T26 Goldberg, Zoino, Dunnicliff & Associates (CZD) undertook groundwater tests at the site as a part of an engineering study commissioned by the MBTA. The results of the testing indicated that the area's groundwater "had traces of organic chemicals not normally found in the environment." 2 7 These findings prompted the DEQE to order that the contaminant source be removed to prevent further leaching into the groundwater and placed the responsibility of cleanup on W. R. Grace. W. R. Grace hired the engineering consulting firm of Camp, Dresser and McKee, Inc. (CDM) in July 1979 to investigate the contamination and to determine the most economical method of neutralizing and/or removing the acid sludge from their property. After completing their testing, the CDM1 project engineer reported that it was apparent that "some contamination had occurred," but they had not "detected any contamination of groundwater off the site."2 8 However, it was later found by the Metropolitan District Commis- sion (MDC) that Parkway Pond, adjoining W. R. Grace property, was also contaminated by acid. MDC requested that the pond be fenced off because it posed a potential danger to public health. The pond is the first area outside W. R. Grace property shown to be affected by the acid- 68

plume created by waste from the chemical company. Parkway Pond lies on municipal property about one-half mile from the Fresh Pond Reser- voir, a major source of Cambridge's water supply.2 9 In September 1980, the W. R. Grace Company and the HBTA agreed on disposition of the 10,000 cubic yards of contaminants. The MBTA and W. R. Grace proposed to share the costs of neutralizing the chemicals on-site before depositing the soil in a normal landfill. Thus, the neutralization process began in late November of 1980 and was expected to be completed by January 1, 1981. As yet, a landfill for the treated sludge has not been located.

E. Water Enforcement Activities Involving W. R. Grace30

Civil Actions

W. R. Grace, Chattanooga, Tennessee: Violations of Clean Water Act. Civil Action filed September 18, 1975. A Consent Decree was filed in November 1975 with a penalty of $4,000.

W. R. Grace, Wilmington, North Carolina: Violations of Clean Water Act. Civil Action filed February 17, 1977. Final Consent Decree & Judgment filed June 13, 1977. A penalty of $3,300 was paid.

Administrative Orders

W. R. Grace, Owensboro, Kentucky: Issued October 12, 1977, for excessive biological oxygen demand (BOD) effluent. Administration Order closed June 5, 1978, after report received April 24, 1978 on BOD final effluent results.

W. R. Grace, Owensboro, Kentucky: Issued October 6, 1975 for exceeding effluent limits of BOD5, TSS, phenols, and oil and grease. Closed February 1, 1977.

NPDES Permit - Notice of Violation

W. R. Grace, Bartow, Florida: Issued August 14, 1980. Closed August 29, 1980.

W. R. Grace, Owensboro, Kentucky: Issued July 21, 1980 for violations of permit in February and April 1980. 69

W. R. Grace, South Pittsburg, Tennessee: Issued July 20, 1977 for failure to submit written notification of compliance or noncompliance.

Spill Prevention Control & Countermeasure (SPCC) - Notices of Violation

W. R. Grace, Owensboro, Kentucky: Issued November 21, 1974 for failure to have SPCC plan certified. Consent Agreement signed January 15, 1975, with penalty of $30.

W. R. Grace, Memphis, Tennessee: Issued April 27, 1980, for failure to have an SPCC plan and failure to have a plan Implemented. Consent Agreement signed December 1, 1980. A penalty of $300 was paid.

W. R. Grace, Charleston, South Carolina: Issued October 10, 1980, for failure to have an SPCC plan and failure to have a plan implemented. A penalty of $1,500 was assessed. This violation has not yet been closed.

Notes to Appendix II

1 Chemical Week (March 26, 1980), p. 31. 2 Standard NYSE Stock Reports (June 19, 1980), p. 1036.

3 Chemical Week, ibid.

4 New York Times (February 12, 1980), p. 5. 5 Chemical Week, ibid.

6 Wall Street Journal (August 15, 1980), p. 21.

7 Standard NYSE Stock Reports, ibid. 8Grace Company 10-K Annual Report (March 23, 1980), p. 29.

9 Moody's Industrial News Reports (June 3, 1980), p. 3490. 10Ibid., p. 3952.

llChemical Week, ibid.

1 2Moody's Industrial Manual, 01 I, M (May.27, 1980), p. 1229. 70

131980 Directory of Chemical Producers, pp. 159-63.

1 4 Goldberg, Zoino, Dunnicliff, Groundwater Investigations of Assabet Well Field, Acton, Massachusetts, Vol. 1 (January 1980). (Hereafter cited as GZD Report.)

15Response of W. R. Grace and Company to the first set of Inter- rogatories submitted by Plaintiff, U.S.A., to the Defendant, Civil Action #80-748-C, U.S.A. v. W. R. Grace, U.S. District Court of Massa- chusetts, docketed 21 July 1980, p. 27. (Hereafter cited as Inter- rogatories.)

16Interrogatories, p. 21. GZD Report, p. 5.

18Interrogatories, p. 21.

19Ibid., p. 17.

20Ibid., pp. 23-24.

2 1Ibid., p. 27.

22 Ibid., pp. 26-28.

2 3 Grace Company 10-K Annual Report, ibid., p. 13.

24 Cambridge Chronicle (February 15, 1979), p. 1.

2 5Ibid.

2 6Cambridge Chronicle (June 21, 1979), p. 1. 2 7Ibid.

2 8Cambridge Chronicle (September 20, 1979), p. 1.

29 Ibid. r

3Information received from officials at EPA, Region IV. 71

APPENDIX III

ODOR COMPLAINTS IN ACTON, MASSACHUSETTS: 1973-1980

Odor complaints have been registered at the Public Health Build- ing since November 1973. To date (November 1980), 291 complaints have been received. The total number of complaints annually from 1973 to 1980 are as follows: November and December 1973, 6; 1974, 47; 1975, 28; 1976, 34; 1977, 27; 1978, 19; 1979, 32; and January to November 1980, 104. Figure 5 is a graph of the total number of odor complaints annually from 1974 to 1980. Some important things to note are: (1) about one-third of all complaints were made by members of the Department of Public Health; (2) the Department of Public Health and one resident were the only complainants logged in 1973; (3) the Department of Public Health and one resident on Heritage Road were accountable for over one-half of the 1974 complaints; (4) complaints are fewest in the coldest months; (5) over one-half of the complaints in 1980 were from residents on Druer Road and Meetinghouse Lane; (6) there is a dramatic increase in the number of complaints in 1980, beginning in June-which may be related to the opening of the new facility that summer; and (7) complaints could only be logged during the office hours of the Department of Public Health, so early morning, night, and weekend complaints were not recorded. 72

110

100 - 104

90-

70.

so - 47 40

30 - 34 3 28 27 20

1019 14

0 .

Fig. 5

TOTAL NUMBER OF ODOR COMPLAINTS REGISTERED AT THE ACTON DEPARTMENT OF PUBLIC HEALTH ANNUALLY, 1974-1980

* Data from Jan.-Nov. 3, 1980 73

APPENDIX IV

TOXICOLOGY OF CHEMICAL CONTAMINANTS

Vinylidine chloride; benzene; trichloroethylene; 1,1,1-trichloroethane; methylene chloride; chloroform; ethylbenzene - we may not immediately recognize any of these chemical substances by name, but U.S. manufacturers, commercial sectors, and consumers utilize over five billion pounds of these seven chemicals each year. American manufacturers use these substances as starting material for a wide variety of products that frequently have a multiplicity of uses for society. The American consumer is exposed to these products daily in one form or another. Plastic wraps, vinyls, saran films, plastics, coated paper, aerosols, paints, dyes, inks, styrenes, detergents, shampoos, hairsprays, and even certain food products are processed using one or more of the chemicals listed above. Exposure may also result, as it did in Acton, Massachusetts; Mon- tague, Michigan; Jackson County, New Jersey; Harden County Tennessee; Woburn, Massachusetts; Gray, Maine; Lowell, Massachusetts;Al and many other communities, from ingestion of contaminated groundwater-often resulting from the careless disposal practices of chemical companies. The ingestion of chemicals from these sources is usually in trace quantities (in the parts per billion level); and although these concentrations seem infinitesimally small, their effects on those exposed may be significant over long periods of time. In 1945, A. B. Eschenbrenner and E. Miller, in early experiments using animals, observed that mice exposed repeatedly to chloroform developed cancerous tumors in the liver.3 2 It was later conjectured that other halomethanes (methane+Cl 2 , Br 2 , 12, etc.) may also have similar adverse health effects, 3 3 but these clues seem to have generated little interest for over 30 years. The federal government, the scientific community, and the American public are just beginning to realize the "costs" associated with the proliferation of man-made (synthetic) chemicals in our environment. The "costs" cannot be calculated with dollar figures in cost- benefit analyses, but instead, "costs" must account for the adverse effects of these chemicals on the health and welfare of society whose safety is being jeopardized. It is unfortunate for all of us that these hidden costs are just beginning to be realized. Cancer, heart disease, and respiratory diseases have been caused or exacerbated by the pervasiveness of these chemicals in our drinking water, our food products, our air and our soil. Recently a report of the Council on Environmental Quality reported that: "It is generally agreed that environmental, that is, exogenous nongenetic factors, contribute to as much as 80 to 90 percent of can- 74 cers." 3 4 Statistics also show that the frequency of cancers per unit population is on the rise, and the number of new cases each year is increasing by more than one and one-half percent.35 In raw numbers, this translates to an increase in new cancers in the U.S. from some 600,000 in 1979 to over 800,000 projected new cases in 1981, and a chance that one of every four Americans is expected to get cancer in his or her lifetime.3 6 In response to these statistics and revelations about the chemical connection to cancer, the federal government, through the EPA, the Occupational Safety and Health Administration (OSHA), the National Institutes of Health (NIH), and the National Cancer Institute (NCI) have reoriented cancer research priorities to determining which of the thousands of potentially harmful synthetic substances are toxic to humans. Current research efforts focus on the "chronic" phenomena (such as cancers, mutations, and birth defects) resulting from exposures to very low doses over time. Dr. David Ozonoff, Assistant Professor and Chief, Environmental Health Section, Boston University School of Public Health, explains how trace levels of these chemicals, and even single molecules, represent a potential harm to man: In theory it might take only a single molecule to cause a mutation in the DNA of a body cell ("one hit" theory). Practically speaking, a single carcinogen molecule in a liter of water would have an extremely small probability- of causing such a change. But'when a chemical contaminant reaches the level of detectability of our most sensitive instruments (about 0.1 parts per billion), it is already present in a liter of water in orders of hundreds of trillions or quadrillions of molecules (1014 to 1015 molecules). What seems an insignificant exposure is in reality an occasion for an enormous number of damaging encounters between a carcinogen and its DNA target in our body cells. 3 7 Presently, criteria for toxicological evaluations are accumulated from three lines of evidence: the study of human populations' exposures (epidemiologic); study of exposures in animals; and "short terin" study of bacterial exposures. The first line of evidence would be ideal, but is often impractical due to the rarity that the human populations, exposed to a single chemical, can be isolated for controlled study. Inherent in epidemiological studies are the various problems associated with control of external factors, such as levels of exposures, durations of exposures, chemicals involved, other chemicals in the environment, adequate numbers for significance, and so forth. Since it is often impossible to control for these variables, research efforts have been concentrated on refining the type of evidence derived-from animal and bacterial systems. The animal models, also known as "long term," involve exposing animals (usually mice or rats) to synthetic chemicals in food, water, air, or applied to the skin. Animals are exposed to contaminants in 75 varying doses up to the lethal dose in order to produce cancers at a high enough rate to be detectable in populations of a practical size. According to epidemiologist, David Ozonoff: If a substance is not a carcinogen and most are not, it will not increase tumor risk at any dose. The only serious question is whether a chemical can be a carcinogen at high dose and not at low dose,-i.e., whether-a safe threshold exists. A great deal of independent biological evid ence suggests that there is no such safe threshold.3 8 As others have pointed out, it is not as though lower doses will not cause cancers; they will merely cause cancers in fewer individuals. 3 9 "Short term" bacterial tests such as the Ames test 4 0 are inexpen- sive, rapid, and reliable methods that can identify chemicals that cause mutations in genetic material (mutagenic) and subsequently those of suspected carcinogenic potential. Studies show that 90 percent of those substances found to cause mutations in bacteria have also been shown to cause cancer in animals. 4 1 The following section discusses the toxic potential of the seven chemicals detected in the drinking water supply from the Acton municipal wells, Assabet #1 and #2. These chemicals had been detected on three or more occasions during the year following4 2 the shut-down of the Assabet wells, from December 18, 1978 to October 16, 1979. For each chemical, the possible exposures, metabolic parameters, and known and suggested toxic effects will be discussed. The commonly used name of each chemical is given first, then other names by which the chemical can be identified are listed- in parentheses. First, however, several terms will be defined which clarify the effects of the seven chemicals.

Toxic Agent. Any substance that the body assimilates and that adversely affects the body and/or any of its systems. Teratogen. Any substance that causes abnormal development of the fetus. Mutagen. Any substance that causes a permanent change in the chromosome structure or number. Carcinogen. Any substance that causes malignant unrestrained growth or reproduction of body cells (as opposed to germ cells).

There should be some clarification between terms here. A teratogen, for example, may not be a toxic agent from the viewpoint of the mother's system, but may be deadly for the fetus. A mutagen may cause a permanent change in some chromosome, and may induce cancer as well. This substance would be considered mutagenic, carcinogenic, as well as being more broadly defined as a toxic agent. 76

VINYLIDENE CHLORIDE (VDC; 1,1-dichloroethylene; 1,1-dichloroethane) Exposures to Product Material. 1979 figures estimate that the annual U.S. production of VDC was 240 million pounds. VDC's major utility is in the production of copolymers for the manufacture of films, fibers, plastics, paper coatings, and modacrylic materials. VDC has also been detected as residuals on household and industrial saran films. 4 3 In Acton, VDC was found in the Assabet municipal wells in eleven of eleven tests over a ten-month period. The highest concentration ("worst case") of this chemical found in Acton was 56 parts per billion, detected on August 6, 1979.44 Metabolism. Several animal studies have shown that VDC is absorbed through the lungs or gastro-intestinal tract. Although the exact metabolic pathway is tentative at this time, there is some evidence that the break down products (metabolites) of VDC are also very toxic to humans.45 Toxicity. VDC has been shown to cause depression of the central nervous system, liver function impairment, and kidney damage at concentrations near 100 parts per million, over 1,000 times that found in Acton drinking water.4 6 Teratogenicity. VDC has not been shown to cause adverse effects to the health or maturation of the developing fetus. Mutagenicity. VDC has repeatedly been shown to cause mutations (mutagenic potential) in bacterial (Ames test) and animal systems. 4 7 Carcinogenicity. VDC has long been suspected of being a carcinogenic agent, due to- its known mutagenic potential. Numerous studies using animal systems have shown significant correlations between exposures to VDC (in air, water, or through the skin) and cancers of the kidney, liver, stomach and lungs. 4 8

BENZENE (benzol; cyclohexatriene; phenylhydrine) Exposures to Product Material. Benzene is a versatile organic chemical used by industry as a general solvent and as starting material for other products, such as plastics, detergents and pesticides. Benzene is also used in the manufacture of styrene, a component of plastics and latexes. Exposures to benzene may also result from diet- ary intake of several foods, including some meats, fish, poultry, eggs, some vegetables, fruits and beverages.4 9 In Acton, benzene was found in the Assabet municipal wells in six of nine tests over a nine-month period of time. The highest concentration was 1 to 10 parts per billion. Metabolism. Benzene is readily absorbed and broken down (metabolized) by the body. There is evidence to suggest that once absorbed, this chemical is accumulated in lipid tissues, such as fat or bone marrow.50 77

Toxicity. Benzene has several toxic effects to humans, including irritation of skin and mucous membranes; and it has been shown to be extremely toxic to the central nervous system at relatively low doses (1000 ppb).5 1 Other toxic effects noted in several studies include reductions in numbers and function of red and white blood cells 5 2 (hematological toxicity) and possible impairment of other immunologi- cal function. 5 3

Teratogenicity. There are some. indications that benzene exposure during pregnancy adversely affects fetal development.5 4 Mutagenicity. Benzene has been shown to be mutagenic in animal systems and in humans. 5 5 Carcinogenicity. Benzene has been shown to cause cancer in humans. Epidemiologic studies on Italian and Turkish shoe factory workers show a significant increase in leukemias of up to twenty-fold when exposed to benzene.5 6 Benzene is a known carcinogen, and therefore there is no safe level in drinking water. However, since benzene is also very prevalent in our environment and the ideal concentration of 0 parts per billion is unfeasible, the EPA has assumed incremental risks for ingestion of trace levels in food and drinking water. (See Table VIII.)

Risk Levels and Exposure Assumptions Corresponding Criteria (per day) 0 ()-7 16-6 10-5 2 liters of drinking water and consumption of 18.7 g 0 0.15ppb 1.5ppb 15ppb fish and shellfish * Only six percent of exposures to benzene results from consumption of fish or shellfish, whereas 94 percent is derived from drinking water. A risk of 10- 5 indicates one-additional cancer for every 105 (100,000) people exposed; a risk of 10-6 indicates one additional cancer for every 106 (1,000,000) people; etc.5 7

TABLE VIII

AMBIENT WATER QUALITY CRITERIA: BENZENE, 1978 78

TRICHLOROETHYLENE (TCE; TRI; 1,1,2-trichloroethylene) Exposures to Product Material. In 1977, the world annual usage of TCE was estimated to total over 1,500 million pounds, while approximately 300 million pounds were produced in the U.S.A. alone. TCE's major use has been as a fat solvent (vapor degreaser) for degreasing metal parts prior to painting, and electroplating. In the recent past, TCE was used as an extraction solvent in the manufacture-of decaffein- ated coffee and the extraction of spice oleoresins, hop, and other food products. 5 8 In Acton, TCE was found in the Assabet municipal wells in seven out of eleven analyses during 1978-1979. Concentrations of 1-10 parts per billion were repeatedly detected in these water samples. Metabolism. TCE can be readily absorbed by humans by inhalation, ingestion, and through skin contact. Once absorbed, TCE may be accumulated in fatty tissues or may be converted enzymatically to more water soluble metabolites. Some of these metabolites may react with nucleic acids (building blocks of DNA) and proteins. 5 9 TCE has been detected in body tissues and fluids more than sixteen days after exposure.6 0 Toxicity. The prominent effects of trichloroethylene at higher concentrations (up to 5000 ppm) are depression of the central nervous system, abnormal cardiac rhythms (arrhythmias), and liver and renal toxicity. 6 1 Teratogenicity. Results of recent animal studies show no significant adverse effects to fetal development due to TCE. However, study results released in 1979, measuring teratogenic effects in chicken embryos, did show a clear dose dependent toxicity to developing embryos and a 600 percent increase in embryonic malformations. 62 Mutagenicity. A metabolite of TCE has been shown to induce genetic mutations in bacterial systems (Ames test). Two additives used as stabilizers in industrial grade TCE also exhibit marked mutagenic potential. 63 Carcinogenicity. Highly significant increases of hepatocellular carcinomas (primarily malignant tumors of the liver) were observed in a "long-term" test in a National Cancer Institute study (NCI, 1976); other animal models using a different 6 pecies of rodents did not, however, corroborate these NCI findings. From the existing evidence, it would seem that the carcinogenic potential of TCE and its metabolites are both sex and species dependent.

1,1,1-TRICHLOROETHANE (chloroethane; methyl chloroform; trichloroethane; methyltrichloromethane) Exposures to Product Material. In 1976, over 550 million pounds of this chemical were produced in the U.S.A. alone. This chemical is used in the metals and metal coatings industries, and as a chemical intermediate by the chemical industry. 79

In Acton, 1,1,1-trichloroethane was found in the Assabet municipal wells on seven of nine occasions from March 26, 1979 to October 16, 1979. The highest concentration found was 1-10 parts per billion in March and June of 1979. Metabolism. 1,1,1-trichloroethane is absorbed through the lungs, gastro-intestinal tract and the skin. After absorption it may accumulate in tissues in the liver, brain and kidneys.6 5 Toxicity. This chemical has been found to cause nervous system depression and liver damage at higher doses. 6 6 Teratogenicity. Limited studies indicate no apparent adverse effects on the fetus. Mutagenicity. 1,1,1-trichloroethane was found to be mutagenic by the Ames test. 6 7 Carcinogenicity. Since this substance has been found to be a mutagenig agent, there is a strong possibility that it may also be carcinogenic. However, only one animal study has been conducted thus far, and it showed significant association between increased cancer risks and exposure. The relatively small amount of information available on health effects of 1,1,1-trichloroethane makes the predictions of the effects on humans relative guesswork. No case reports or epidemiological studies are presently available.

METHYLENE CHLORIDE (dichloromethane)

Exposures to Product Material. In 1976, the U.S. produced about 538 million pounds of methylene chloride. It is used widely as an industrial solvent, as a paint remover, and in aerosol propellents for insecticides, hairsprays, shampoos, and paints. Methylene chloride is presently being used as an extract for food products, the major use being to extract caffeine from coffee. Metabolism. Methylene chloride is absorbed by man and metabolized to carbon monoxide and other products. Toxicity. Carbon monoxide poisoning has been observed in some inhalation studies on humans (COHb complexes).6 9 Teratogenicity. No demonstrative effects on the fetus have been observed. Mutagenicity. Methylene chloride has been shown to be a mutagenic agent in several studies using the Ames test. 7 0 Carcinogenicity. Data for carcinogenicity of methylene chloride is notably absent. Two studies conducted thus far are inconclusive. However, because this chemical is a known mutagenic agent, the Inter- agency Testing Committee of the federal government has recommended that testing continue ii all areas, particularly for carcinogenicity and teratogenicity. 80

CHLOROFORM (methane trichloride; methenyl trichloride; methyl trichloride; trichloroform; trichloromethane)

Exposures to Product Material. Chloroform is primarily used in industry as a solvent; it is used as a pesticide; and, it has varying uses in the pharmaceutical industry. At one time, it was also used in the production of cosmetics and as flavoring in toothpaste and mouthwash.7 1 In Acton, chloroform was found in the Assabet municipal wells on three of eleven occasions over a ten-month period (December 18, 1978 to October 16, 1979). The highest concentration found was 1-10 parts per billion on March 26, 1979. Metabolism. Chloroform is completely absorbed when ingested. It is metabolized mainly in the liver and kidneys, but has been found in high concentrations in the peripheral nerves. Toxicity. Studies on humans have shown that chloroform is extremely toxic to the liver and kidneys and central nervous system. Over-exposure may cause death by cardiac arrythmia (heart failure).7 2 Teratogenicity. In some studies, chloroform has been shown to cause increased incidence of fetal mortality and decreased fetal weight. 7 3 Mutagenicity. Although chloroform has been shown to cause cancer in humans and animals, there is no evidence at present showing this chemical's mutagenic potential. Carcinogenicity. Chloroform was implicated as a carcinogen as far back as 1945. In numerous animal studies, chlororoform has repeatedly been shown to cause tumors. 74

ETHYLBENZENE

Exposures to Product Material. Ethylbeuzene is used in the manufacture of cellulose acetate, synthetic rubber and styrene. It is also a comon aromatic solvent used in industry. In Acton, ethylbenzene was detected in the Assabet wells on three of ten occasions over a nine-month period in 1979. The highest concentration detected was 23 parts per billion on August 2, 1979. Metabolism. Up to 90 percent of ethylbenzene ingested or inhaled may be absorbed by humans. This chemical is normally metabolized rapidly, but it has been found to accumulate in body tissues under some circumstances.75 Toxicity. Ethylbenzene is toxic to mucous membranes and the central nervous system in higher doses (1000 ppm).7 6 Teratogenicity. Although ethylbenzene has not been shown to have teratogenic effects, other xylenes (similar structure and metabolites) have been shown to cause malformations. 7 7 81

Mutagenicity. Limited studies in animals report no significant mutagenic effects. Carcinogenicity. Some experts feel that a high carcinogenic potential exists, but this substance has yet to be studied in depth.78

Notes to Appendix IV

3 1Environmental Quality: Tenth Annual Report of the Council on Environmental Quality (Washington, D.C.: U.S.G.P.O., December 1979), pp. 178-79.

32A. B. Eschenbrenner and E. Miller, "Induction of Hepatomas in Mice by Repeated Oral Administration of Chloroform, with Observations on Sex Differences," J. National Cancer Institute (1945) 5: 251-255.

3 3F. A. Patty (ed.), "Industrial Hygiene and Toxicology," Toxi- cology 1259 (1963); B. B. Paul and D. Rubinstein, "Metabolism of Carbon Tetrachloride and Chloroform by the Rat," J. Pharmcol. Exp. Ther. 41 (1963).

3 4Rice Odell, Environmental Awakening (Conservation Foundation, Ballanger Publishing Co., Cambridge, MA, 1980), p. 133.

3 5 Information supplied by the National Cancer Institute, Division of Cancer Cause and Prevention, Office of Field Studies and Statistics, May 1979. Cancer mortality and incidence figures are for 1969-76, for whites only. The average annual increase in cancer mortality for blacks during the same period is 1.3 percent; incidence data for blacks are incomplete. Age adjustments are based on the age distribution of the U.S. population in 1970. 3 6 American Cancer Society, Cancer Facts and Figures: 1981, American Cancer Society Inc. (1980). 37David Ozonoff, Testimony for U.S. EPA vs. W. R. Grace Co., Response #11.

38 ibid., response #15.

39Charles F. Wurster, Environmental Defense Fund Letter (January 1973).

40For detailed discussion of the Ames test, see J. McCann et al., "Detection of Carcinogen as Mutagen in the Salmonelia Microsome Test: Assay of 300 Chemicals," Proc. Nat. Acad. Sci. USA 72: 5135-39 (1975).

41U.S. Department of Health, Education and Welfare (Public Health Service), "Everything Doesn't Cause Cancer," NCI/NIH Publication No. 80-2039 (April 1980), and the "Delaney Clause Update," Washington, D.C. 82

4 2 See Table II, Section 6: Chemicals Found in Assabet Wells.

43T. J. Birkel, J. A. G. Roach, and J. A. Sphon, "Determination of Vitylidene Chloride in Saran Films by Electron Capture Gas-Solid Chromatography and Confirmation by Mass Spectrometry," J. Assoc. Off. Anal. Chem. 60: 1210-13 (1977); T. R. Blackwood, D. R. Tierney, and M. R. Piana, Status Assessment of Toxic Chemicals: Vinylidine Chloride, EPA-600/2-79-219. U.S. Environmental Protection Agency, Washington, D.C., 1979; C. Drevon and T. Kuroki, "Mutagenicity of Vinyl Chloride, Vinylidene Chloride and Chloroprene in V79 Chinese Hamster Cells," Mutation Research 67(2): 173-82 (1976); Internaticial Agency for Research on Cancer (IARC), Monographs on the Evaluation of Carcinogens, Risk of Chemicals to Humans; Vinylidenechloride and Vinylidtne chloride-vinyl chloride Copolymers, Vol. 19 (1979), pp. 439-59.. (Yereafter cited as IARC Monographs.)

4 4 See Table II, Section 6: Chemicals Found in A3sabet Wells.

45D. Reichert, H. W. Werner, M. Metzler, and D. Henschler, "Mole- cular Mechanisms of 2,2-dichloroethylene toxicity: Excreded Metabolites Reveal Different Pathways of Reactive Intermediates," Archives of Toxi- cojg 4 2(3 ): 159-69 (1979); R. J. Jaeger, L. G. Shoner, and L. Coffman, "1,1 Dichloro-Hepatotoxicity: Proposed Mechanism of Action and Distri- bution and Binding of 14C Radioactivity Following Inhalation Exposure in Rats," Environmental Health Perspective 21: 113-19 (1977).

4 6J. A. Prendergast, R. A. Jones, L. J. Jenkins, Jr., and J. Siegel, "Effects on Experimental Animals of Long-term Inhalation of Trichloroethylene, Carbon Tetrachloride, 1,1,1-Trichloroethane, Dichlorodifluoromethane, and 1,1-Dichloroethylene," Toxicol. App. Pharmacol. 10: 270-89 (1967).

4 7A. J. Garro, J. B. Guttenplan, and P. Milvy, "Vinyl chloride Dependent Mutagenesis: Effects of Liver Extracts and Free Radicals," Mutation Res. 38: 81-88 (1976); B. K. Jones and D. E. Hathway, "The Biological Fateof Vinylidene Chloride in Rats," Chem.-biol. Interact. 20: 27-41 (1978).

4 8C. Maltoni, "Recent Findings on the Carcinogenicity of Chlori- nated Olefins," Environ. Health Perspect. 21: 1-5 (1977); C. C. Lee, J. C. Bhandari, J. M. Winston, W. B. House, P. J. Peters, R. L. Dixon, and J. S. Woods, "Inhalation Toxicity of Vinyl Chloride and Vinylidere Chloride," Environ. Health Perspect. 21: 25-32 (1977).

4 9M. Duroir, A. Fabre, and L. Derobert, "The Significance of Benzene in the Bone Marrow in the Course of Benzene Blood Diseases," Arch. Mal. Prof. 7: 77 (1946), as cited in Haley (1977).

5 0 "Relation of Benzene Metabolism to Benzene Toxicity," in Symposium on Toxicology of Benzene and Alkylbenzenes, D. Braun (ed.), Industrial Health Foundation 44 (Pittsburgh, 1974), as cited in Synder (1975). 83

5 1 I. S. Susov, "Comparative Toxicity Studies of.Benzene, Toluol, and Xylol by the Reflex Activity Methods in Biological Effects and Hygienic Importance of Atmospheric Pollutants," Book 10, U.S.S.R. Literature on Air Pollution Occupational Diseases 17: 60 (1968), as cited by Haley (1977).

52 C. A. Snyder, 3. D. Goldstein, A. R. Sellakumar, I. Bromberg, S. Laskin, and R. E. Albert, "The Inhalation Toxicology of Benzene: Incidence of Hemapoletic Neoplasms and Hematotoxicity in AKR/J and C57BL/6J Mice," Toxicol. App. Pharmacol. 54: 323-31 (1980). 53 A. Lange, R. Smolik, W. Zatonski, and J. Szymanska, "Serum Immuno-globulin Levels in Workers Exposed to Benzene, Toluene and Xylene," Int. Arch. Arbeitsmed. 31: 37-44 (1973), as cited in EPA (1978).

5 4 G. I. Wanatabe and S. Yoshida, "The Teratogenic Effects of Benzene in Pregnant Mice," Act. Med. Biol. 19: 285-91 (1970); V. A. Gofmekler, "Effect in Embryonic Development of Benzene and Formalde- hyde," Hyg. Sanit. 33: 327-32 (1968). 55 D. J. Kissling and B. Speck, "Chromosome Aberrations in Experi- mental Benzene Intoxication," Helv. Med. Acts. 35: 59-66 (1972), as, cited in EPA (1978); A. Koizumi, Y. Dobashi, Y. Tachibana, K. Tsuda, and H. Katsunuma, "Cytokinetic and Cytogenetic Changes in Cultured Human Leucocytes and Hela Cells Induced by Benzene," Ind. Health 12: 23-29 (1974); M. Diaz, A. Reiser, L. Braier, and J. Diez, "Studies on Benzene Mutagenetisis," Experientia 36: 297-99 (1980).

56M. Aksoy, K. Dincol, T. Akgun, S. Erdem, and G. Dincol, "Haema- tological Effects of Chronic Benzene Poisoning in 217 Workers," Brit. J. Ind. Med. 28: 296-302 (1971); E. C. Vigliani and A. Forni, "Benzene and Leukemia," Env. Res. 11: 122-27 (1976); E. C. Vigliani and G. Saita, "Benzene and Leukemia," The New England Journal of Medicine 271: 872- 76 (1964).

5 7 See Table II, Section 6: Chemicals Found in Assabet Wells.

G. Bronzetti, E. Zeiger, and D. Frezza, "Genetic Activity of Trichloroethylene in Yeast," J. Environ. Pathol. Toxicol. 1: 411-18 (1978); IARC Monographs, Vol. 11 (1976), and Vol. 20 (1979), Lyon (ed.). 59 Bronzetti et al., 'ibid.; M. Shahin and R. von Borstel, "Mutagenic and Lethal Effects of Benzeae Hexachloride, Dibutyl Phthalate, and Trichloroethylene in Saccharomyces Cerevisiae," Mut. Res. 48: 173-80 (1977); D. Henschler, W. Romen, H. Elsasser, D. Reichert, E. Eder, and Z. Radwan, "Carcinogenicity Study of Trichloroethylene by Longterm Inhalation in Three Animal Species," Arch. Toxicol. 43: 237-48 (1980). 60 Ibid. 61 K. Bergman, 'Whole-Body Autoradiography.and Allied Tracer Tech- niques in Distribution and Elimination Studies of Some Organic Solvents," Scand. J. Work Environ. and Health 5 (suppl. 1): 263 (1979); J. White 84

and G. Carlson, "Influence of Alterations in Drug Metabolism on Spon- taneous and Epinephrine-Induced Cardiac Arrhythmias in Animals Exposed to Trichloroethylene," Toxicol. App. Pharm. 47: 515-27 (1979).

6 2 E. Elovaara, K. Hemminki, and H. Vainio, "Effects of Methylene Chloride, Trichloroethane, Trichloroethylene, Tetrachloroethylene, and Toluene on the Development of Chick Embryos," Toxicol. 12: 111-19 (1979).

63H. Bartsch, C. Malaveille, A. Barbin, and G. Planche, "Mutagenic and Alkylating Metabolites of Balo-Ethylenes, Chlorobutadienes and Dichlorobutenes Produced by Rodent or Hn-an Liver Tissues," Arch. Toxi- col. 41: 249-77 (1979); D. Henschler et al., Ibid.; D. Henschler, E. Eder, T. Neudecker, and M. Metzler, "Carcinogenicity of Trichloroethy- lene: Fact or Artifact?" Arch. Toxicol. 37: 233-36 (1977).

64 National Cancer Institute, "Carcinogenesis Bioassay of Trichloro- ethylene" (Tech. Rep. Series No. 2), DHEW Publication No. (NIH) 76-802, Washington, D. C., U.S. Dept. of Health, Education and Welfare (1976); P. Cooper, "Trichloroethylene: Hepatic Effects, Metabolism and Elimina- tion," Food Cosmet. Toxicol. 16: 491-2 (1978). 65B. Holmberg, I. Jakobson, and K. Sigvardsson, "A Study on the Distribution of Methylchloroform and n-octane in the Mouse During and After Inhalation," Scand. J. Work Environ. and Health 3: 43-52 (1977). 66E. M. Adams, H. C. Spencer, V. K. Rowe, and D. D. Irish, "Vapor Toxicity of 1,1,1-trichloroethane (Methylchloroform) Determined by Experiments on Laboratory Animals," Arch. Id. Ey. 1: 225-36 (1950).

67 V. F. Simmon, K. Kayhanen, and R. G. Tardiff, Mutagenic Activity of Chemicals Identified in Drinking Water (Amsterdam, Elsevier/North Holland, 1977), pp. 249-58.

8ARC Monographs (1979), pp. 515-33; "Bioassay of 1,1,1-Trichloro- ethane for Possible Carcinogenicity," DHEW Publication No. 77803, Washington, D.C., U.S. Department of Health, Education and Welfare.

6 9Richard D. Stewart, Terrance N. Fisher, Michael J. Hosko, Jack E. Peterson, Edward D. Baretta, and Hugh C. Dodd, "Carboxyhemaglobin Elevation After Exposure to Dichloromethane," Science 176: 295-96 (1972). M. 70W. F. Jongen, G. M. Alink, and J. H. Koeman, "Mutagenic Effect of Dichloromethane on Salmonella Typhimurium," Mutation Research 56: 245-48 (1978); T. Kanada and M. Uyeta, "Mutagenicity Screening of Organic Solvents in Microbial-Systems," Mutation Research.S4: 215 (1978).

71 IARC Monographs 20: 449-65 (1979); ibid., pp. 401-27; C. Jabs, "Chloroform, Linked to Cancer, Fading Out," New York Times 3: 1 (1976); F. J. C. Roe, A. K. Palmer, A. E. Street, A. N. Worden, and N. J. VanAbbe, "Safety Evaluation of Toothpaste Containing Chloroform," J. Environ. Pathol. Toxicol. 2: 821-33 (1979). 85

7. J. Bowman, J. F. Borzelleca, and A. E. Muson, "The Toxicity of Some Halomethanes in Mice," Toxicol. App. Pharmacol. 44: 213-15 (1978); W. W. Storms, "Chloroform Parties," J. Am. Med. Assoc. 225: 160 (1973); S. Winslow and H. Gerstler, "Health Aspects of Chloroform-- A Review," Drug and Chem. Toxicol. 1: 259-75 (1978).

73 D. J. Thompson, S. D. Warner, and B. B. Robinson, "Teratology Studies on Orally Administered Chloroform in the Rat and Rabbit," Toxicol. App. Pharmacol. 29: 348-57 (1974).

74 H. Bomski, A. Sobolewska, and A. Strakowksi, "Toxic Damage of the Liver by Chloroform in Chemical Industry Workers," Arch. Gewerbepathol. Gewerbehyg. 24: 127-34 (1967); A. B. Eschenbrenner and E. Miller, "Induc- tion of Hepatomas in Mice by Repeated Oral Administration of Chloroform, with Observations on Sex Differences," J. Nat'l. Cancer Inst. 5: 251- 55 (1945); I. D. Capel, H. M. Dorrell, M. Jenner, M. H. Pinnock, and D. C. Williams, "The Effect of Chloroform Ingestion on the Growth of Some Murine Tumors," Europ. J. Cancer 15: 1485-90 (1979).

75I. Astrand, J. Engstrom, and P. Ovrum, "Exposure to Xylene and Ethylbenzene: Uptake, Distribution, and Elimination in Man," Scand. J. Work Environ. and Health 4: 185-94 (1978); Z. Bardodej and E. Bardodejova, "Biotransformation of Ethylbenzene, Styrene, and alpha-Methylstyrene in Man," Am. Ind. Hyg. Assoc. J. 31: 206-9 (1970).

7 6F. Gambepale, G. Annwall, and Hultengren, "Exposure to Xylene and Ethylbenzene: Effects of the Central Nervous System," Scand. J. Work Environ. and Health 4: 204-11 (1978).

A. Hudak and G. Ungvary, "Embryotoxic Effects of Benzene and Its Methyl Derivatives," Teratology 11: 55-63 (1978). 78J. Angerer and G. Lehnert, "Occupational Chronic Exposure to Organic Solvents. Phenolic Compounds-Metabolites of Alkylbenzene in Man. Simultaneous Exposure to Ethylbenzene and Xylenes," Int. Arch. Occup. Environ. Health 43: 145-50 (1979). 86

APPENDIX V

DESCRIPTION OF AN AQUIFER

The two consultants confined their investigations to that portion of the Sinking Pond Aquifer which is located in Acton. The parts of the aquifer which are located in Concord and Maynard were not considered in either study. The Sinking Pond Aquifer is small in terms of area, compared to other basins in the town (see Map D), but it is important in terms of its ability to yield high volumes of water. An aquifer is an area of underground water contained in spaces between particles of aquifer material (usually sand and gravel). (See Figure 1.) Some materials have more spaces and can hold larger quantities of water. The larger and more uniform in size the material is, the better its storage capacity. The water table forms the surface of the underground water and follows the general contours of the land surface. The water table is usually at the surface where surface water occurs. In South Acton, this would be the Assabet River. Water is not just stored in an aquifer, but moves through it by force of gravity toward a point where it is.discharged to a body of surface water. The highest points in an aquifer are called groundwater divides and form the boundaries of an aquifer. Solid rock, called bedrock, lies under the looser water-bearing aquifer materials. In the Sinking Pond Aquifer, bedrock is found at depths of 30 to 120 feet. Small amounts of groundwater also seep into the cracks in the bedrock. S. RUSSELL SYLVA 5 o mnca/ JZcenze& Commissioner

935-2160 February 9, 1987

W.R. Grace & Comvanv- RE: CAZBRIDGE-W.R. Grace 62 Whittemore Avenue Cambridge, NAssachusetts 02140 NOTICE OF RESPONSIBILITY PURSUANT TO H.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 environmental conditions in order to determine the potential impact upon development plans. 6 Site History According to Ealey and Aldrich, the site was developed in the 1600'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.

0 .. 1. ' I * - W.R. Grace Page 2.

Currently, the W.R. Grace property is mostly vacant, with several V.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 MBTA 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/1 (ppb) naphthalene, 4,500 ug/l acetone, 1,100 ug/1 methyl ethyl ketone, 640 ug/1 methylene chloride, 470 ug/l ethyl benzene, 380 ug/1 methyl isobutyl ketone, 300.ug/l carbon disulfide, 310 ug/1 hexanone, 140 ug/l dimetbylphenol, 125 ug/l formaldehyde, 74 ug/1 bia-2-ethyl-hexyl phthalate, 85 ug/1 di-n-octyl phthalate, 26 ug/1 trichloroethane, 21 ug/l vinyl acetate, 15 ug/1 benzene and 2,900 ug/l zinc. Analysis of soil samples showed maximum contaminant levels of 20,000 ug/kg (ppb) naphthalene, 16,600 ug/kg formaldehyde, 356,900 uglkg 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 metbylene 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.

(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 bydrogeologic conditions on the site, and focused on sulfate contamination.

(4) A "Memorandum for the Record- dated February 14, 1979 written by Peter Logan of WFTC. 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 V.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. 4dditionally, 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/i 2,2' thio-bis-propane 200-400 ug/1 phenol, 1,000-3,000 ug/1 methyl phenol, 400-1,500 ug/1 benzamides, 400 ug/ 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/1 phenol and and 50 ug/I 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/1 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 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 adfditional 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. 1f 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 an 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. V.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 MBTA 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 HBTA 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 aide 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 Remedial Action Plan for groundwater treatment. C

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 aa 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. 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. 1pin Deputy Regional Environmental Engineer RJC/NB/ae

cc: DEQE/DSEW, 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 - rA79. - ~ - INTERNAL CORRESPONDENCE

C-583-7-S-59

TO: DON SMITH FAOM. HERB C9 - susaE PRELIMINARY ASSESSMENT OF W.R. GRACE AND COMPANY, CAMBRIDGE ) TDD NO. F1-304-12 30B NO. MA38-PA

The W.R. Grace and Company, Cons ction rod ts Division7'iis located 800 feet west of the Route 2, Alewife P wa r at 62 Whittemore Street in Cambridge, Massachusett ' , A per! eter survey of the site (Figure 2) was performe May 17, 35, b er Colby and Barbara Felitti (NUS/FIT). A chain lin fence encom e e ire 27 acre site. Gates are guarded and access throug restrict altho access appears not to be i difficult due to numerous holes in the fence. Grac bulldings are located In . the northeast portion of the site j to Whi mn 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 vel aqjs cc vered ith asphalt or gravel, with little or no vegetation growing. The'jifre n u ace Is a result of the recent demolition and removal of many bu ding on e site, and the construction of the Massachusetts Bay Trans* it (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 area aoearlzr.be ably neat and well maintained (4).

- The site is bot p so by 'ndge Avenue and the Rindge Towers Apartments, to ly w' ooak Parkway and Lehigh Metals, to the north by Whitti ue d residential properties, and to the east by Russell Athio* nd re ' ential properties (Figure 2). The North Cambridge/ res R'q h vily populated with multiple family dwellings and highr' aun t complexes. In addition, there are a number of shoppin ent(. f ices and Indus tries In the area.

Fresh P a I rvoir for Cambridge's water supply, is located 0.5 miles to thekbu. les water to approximately 102,000 people (5).

Site History N Much of the North Cambridge area is underlain by extensive clay deposits. In the 1800's, these deposits were mined extenasively for the manufacture of brlcks. 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

W& am =11= h I

C -- .4

C 'S C

* m * 0

a 2 Sri EC U C'

:U U

ie s I. - C- zR

.4 A- S - - -

- u~

q: a- 0-4 * d

* . - b

10 9

ccn

li 0;!- I~i

T la. C-383-7-5-59

MEMO TO: DON SMITH JULY 8, 1985 - PAGE TWO

gaskets, latex sealants and adhesives, air-entraining a nts f r concrete, silicone sealants, synthetic leather-type materials, sodi h nate (trade name DAXAD) and SodaSorb, a material used to al w the use of anaithetics (3)."'E

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 ot ' ite to acetone, jmma,-ne, st rene vinyl a e, methyl aceta , me nol, ibutyl maleate, isobuty eTerFhe en glycol, naphthalene, rmal e, sulfuric acid, sodium hydroxide, potassium hydroxide, methyla ate, a monla, fuel oil, taluw., hexane, alcohol, zinc chloride, calcium lignos te, a line and diesel fuel (3). Wastes were treated and/or dispse numbe oons and settling ponds (Figure 2). Figure 3 shows the I tion of e capacity (where known) and contents.

Prior to the construction of the h\TA "ed in Extension through the site, a number of soil, groundw drolgy an waste contamination studies took place. The first, perf med by Gold rg, oino, Dunniclif fe and Associates in N'-V 1978 indicated the pr enc of D D as materials and also areas.of low pH along the proposed a nm ent. ther Investigation into the nature and extent of the ,ast mat wa sprfor ed by Haley and Aldrich in 1979, prior to the start of tunne co tru ' - As a result of the investigations and discussions between Gra the MBTA and the Massachusetts Department of Environme I Engin ring (DEQE), waste materials (sludge) were excavated were disp e of i ingston, Rhode Island during 191 and 1982. Groundwa r r ning 1s ere also installed and monitored by the MBTA (3). Sofol ed or e t nel construction was stockpiled on the site. Some of the clean xcav ed oil was transported. t-afils in nert shore

certain arn cont nated siil was trucktdto Davis Sqare, Somervilli for use as bar kfill air-&kVthe tunnel . ten -st~rens-became aware of the situaun 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, 4 Massachusetts, is proposing to construct several multi-story buildings on the site. Reference % I 1) !.JSGS, Lexington, MA, 7.5 Minute Topographic Map (1971). I

2) USGS, Boston North, MA, 7.5 Minute Topographic Map (1971, photorevised 1979).

3) Haley and Aldrich, Inc. for Hines Industrial, 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,

3) Massachusetts Departrne't of Quality Fngineering, "Identificatior and Preliminary Asses Grace and Company", 1980.

6) Cambridge Historical CornnCsln The MIT Press.

7) with Herb Colby, NUS/FIT on May 2,_1985.

8) Letter to )f lice of Public Relations, US EPA, Region I, fromW mnbridge Toxic Alert Coalition, Cambridge, MA, ece Project files.

0 FROM. North Cambridge Stabilization Committee RECEIX/ED c/o Community Development Department JA I C 57 Inman Street Cambridge, MA 02139 - 1O Om ': ,i:-t'YOF

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

RE: EOA #5869, Alewife Center Final Environmental Impact Report

ENCL: 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

4 DATE: January 12, 1988

Dear Secretary Hoyte:

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 commnity '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 Alewife Center FEIR January 12, 1988 site cleanup and development -in 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.-

CONTMINATION ISSUES

Our primary focus is that questions and concerns relative to contaminated soil, contaminated ground water, and contaminant emissions 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 I

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

Acetone up to 4500 ppb's up to 12,000 ppb's + 2?0%

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

PAR's 22 ppb'S 221 ppb's + 1000% (Polycyclic - Aromatic Hydrocarbons) (2 of 12) .aEA #5869 - NCSC Response 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 K&A2 )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 (SpenglerSmith,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 ictual or potential hazard to human health is presented by current or proposed development conditions." (3The 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 EPA 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 constructbn activities at the site."(6) In another section of Volume 2 of the FEIR, NIS recommends that additional "samples shoud be collected and analyzed for comparison with the Haley and Aldrich data."(7)

(3 of 12) EOFA # 5869 - NCSC Response to Alewife Center FEIR January 12, 1988

In light of the large discrepancies of contamination levels 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 followings 1. Is the ongoing soil and water testing by H&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. 9)Should 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.(10)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) oEA #5869 - NCSC Response to Alewife Center FEIR January 12, 1988

CONTAMINATION ISSUES - Foot Notes

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

(2) Volume 1, FEIR - IX-20

(3) Volume 1, FEIR - IX-20

(4) Volume 1. FEIR - IX-22

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

(6) Volume 2, FEIR - Appendix Vt-Potential Hazardous Waste Site Site Inspection Report - Part 3

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

(8) Volume 1, FEIR - IX

(9) Volume 1, FEIR - IX-21

(10) Volume 1, FEIR - Xf-2

(11) Volume 1, FEIR - Xf-2&3

(5 of 12) EA #5869 - NCSC Response to Alewife Center FEIR January 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 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 abttting 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' MBTA passes" or to providing "bus service to the western suburbs". 03We 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 committmentt 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, We are also encouraged that the developer further agrees to "promote the minimization of traffic in the Whittemore Avenue residential area." (6) The NCSC recommends that traffic studies.be ongoing throughout both construction and occupancy. It further recommends that mitigatin measures relative to the traffic impact, be taken promptly by the developer, whenever and wherever needed.

(6 of 12) fEOEA #5869 - NCSC Response to Alewife Center FEIR January 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 - Cbtrespondede from-Alice K. Wolf Cambridge -City Couneillor'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 & 4 Developer Response - (22.21) & (22.22)

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

(7 of 12) COEA # 5869 - NCSC Response to Alewife Center FEIR January 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."(1IThe 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.(35 The Committee is generally oppos'ed.to this option.' The N.orth Cambridge-Stabilization.Committee approves of the Planning-Boardis.decisibh "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) OZA # 5869 - NCSC Response to Alewife Center FEIR January 12, 1988

UTILITIES AND OTHER 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 Sgttem 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 - Monacelli Associates, Inc., Meeting Minutes dated July 8 & 21, 1987.

(9 of 12) t zA #5869 - NCSC Response to Alewife Center FEIR January 12, 1988

I4OUSING ISSUES

Housing issues and concerns raised in the NCSC response to the DEIR, have not been satisfactorily addressed in the FEIR. Aside f-om the proposal to develop 20 housing units on Whittimore Avenue, project proponents have remained consistently insensitive to housing issues.i)

HOUSING ISSUES - Foot Notes

(1) Volume 1, FEIR - III-16&17 Volume 2, FEIR - Appendix IV - NCSC Correspondence & Developer Response - (22.30) & (22.31)

WETLAND ISSUES

Concerns in this area remain unchanged from the DEIR.

(10 of 12) OEA #5869 - NCSC Response to Alewife Center FEIR January 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 su,.ficient 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. Notablyt 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 85' height limitati

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 organizatio 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) EA #5869 - NCSC Response to Alewife Center FEIR January 12, 1988

Respectfully,

Olivia Golden, Chair North Cambridge Stabilization Committee

Peter V. Cignetti III

Peter C. Kasch ec 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

(12 of 12) 0

V 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 t.

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? W1. 4-.tf wiio-k'sa& y be 1ifired.tia wwn.euftwwrrratwtreitu. Wa2s tbstwr i-tupknrrfor nwaA

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: t

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 reports dating from 1980, 1982, and 1985. The figures are therefore out of date as well as being inferred rather than actual.

3. The forecast projections come from yet other sources than the estimates of current traffic. The result is that the existing traffic figures and the forecasted figures are inconsistent, sometimes to the point of being nonsensical. Often the "no build" figures for 1995 are actually lower than the "existing" figures for 1985, suggesting that background traffic levels will decrease over the next decade.. This is clearly not going to occur. For example: Figure West on South on Rindge at Sherman Parkway at Rindge IV.4 existing AM peak 1985 368 2339 IV.8 no build AM peak 1990 350 2031 IV.12 no build AM peak 1995 330 2028

4. The "full build" traffic analyis cannot be accurate since the traffic generation of Alewife Center was added to the deflated base traffic count projected for 1995 as noted above.

5. The benefits of the LeHigh Metals access drive are not apparent. Although this will, as stated, relieve some of the burden of Alewife Center on the Route 2 intersection, it seems only to shift that burden to another intersection. The left turn out of this access drive will not be free-flowing, but rather restricted by the red light at the Rindge/Alewife intersection. The result will be enhanced gridlock at an already overly congested area due to the queuing of cars through the intersection attempting to make that left turn.

6. There are other anomalies in the traffic numbers of the report. For instance, the numbers exiting the site at the Route 2 interchange in Figure IV.15 do not add up. All of the numbers must be checked for accuracy.

7. It is now very difficult to get through the Alewife Corridor. With the Alewife Center development, the amount of time during which this artery is functioning at level F will increase, which in turn will increase the average commuting time of all drivers in the Corridor. This should not be discounted: it is a problem in itself and produces a further problem for the neighborhood as it changes the incentives of all drivers in the Alewife Corridor (not just those coming to the Alewife Center development) and encourages them to find routes on neighborhood streets. And possibly, the increased time may end up discouraging rather than encouraging use of the Alewife T station by drivers with Boston destinations, if reaching and entering the garage becomes ever more time-consuming. How long will it take a driver to get through these intersections in the future as compared to now? t-

There are additional mitigation measures that 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 t

enhancing public safety in these open spaces relate to this comment as well, since more street-level activity at a human scale will contribute to public safety.

We suggest the following additional mitigation measures:

1. Pedestrian access to the T station should be as direct as possible, preferably walking in a straight line from the neighborhood rather than having to walk around buildings.

2. Pedestrian access during construction must be strictly maintained.

3. A community design review process should be established to review each building as it is designed during the ten year build out. The building forms now are far too vague not to have such a process, which must be able to produce significant design modifications.

Wetlands

The principal concern of the community is that these areas be properly maintained. This particularly includes those areas to be owned by the MDC, whose record in the area for maintenance is poor: for example, the MDC pool nearby is rarely operational while the need for such recreational facilities is tremendous.

Utilities and Other City Services

We want to know that no additional services are required for this development, or if any are required, that they will be paid for by the developer. This includes any police (including MDC) or fire details which become necessary not only at the site but in the area due to the development.

Housing

Given the extremely tight housing market in Cambridge and specifically North Cambridge, we find the Draft EIR section on housing to be inadequate. In particular:

1. The draft EIR fails to address the development's impact on housing. The proposed figure of 20 units appears to be determined by convenience, not by any estimate of development impact. The final EIR should include an estimate of the effect of the development on housing demand and a specific plan to provide the number of units required to meet that increased demand.

2. The housing plan should specify the method of providing the units (direct construction by the developer, funding to enable the City of Cambridge to construct units, etc.), the timetable for the units to be available, and income levels (low, moderate, market rate). Because of the extreme need for affordable housing in North Cambridge and because additional 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 and we appreciate the r We wish to see the -site cleaned up, 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.

Res fully,

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

ivf$a Go 1tQ

Peter Cignetti In

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 -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 Iasch,

Peter V. Cignetti, III on behalf of the North Cambridge Stabilization Committee Y/(2 rnmise ie f/red

gSodon, eAsataeettls 62202 MICHAEL S. DUKAK;S GOVERNOR

JAMES S. HOYTE SECRETARY January 20, 1988

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

PROJECT NAME Alewife Center PROJECT LOCATION Cambridge EOEA NUMBER 5869 PROJECT PROPONENT - F Gerald. D. 'Hines 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 adequatply and, properly comply.with -the Massachusetts Environmental Policy Act (G.L-., c.30, *.61-62H) -and with its implementing-regulations (301 CR 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 compl-iance.. I- appreciate the' proponents willingness to allow the Final EIR additional review time during the holiday season. The preparation of a Supplemental Final EIR (SPEIR) 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 brieflv outlined below.

- FLOOD MANAGEMENT

I am aware of particular questions related to the flood profile 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

N EOEA #5869 FETR Certificate .January 20. 1988

recuire that compensatory flood storage have an unrestricted hydraulic connection to the same waterway or water body (310 CMR 1.057(4)(a)1]. 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 Supplemental 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 ROTC 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 such summary was included in the Final EIR and must be included in the Supplemental Final EIR. The North Cambridge Stabilization Committee has expressed many legitimate and

2 ht

EOEA #5869 FEIR certificate January 20. 1988

important concerns. These can be resolved in a auestion and response format in the Supplemental Final EIR. The Cambridge Conservation Commission also raised some imoortant 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 ' DATES SH E!S'L . RETARY

Comments received: 12/17/87 MWRA 1/6/S8 DEQE 1/13/88 DEM 1/13/88 T. Maguire 4 1/13/88 MAPC 1/14/88 S. Kaiser 1/14/BB 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

I I.

ENVIRONMENTAL DATA REPORT FOR THE W.R. GRACE & CO. PROPERTY IN CAMBRIDGE, MASSACHUSETTS

Volume 7 of 7 Section V Groundwater Flow Monitoring Section VI Source Identification Procedure and results Section VII Neighborhood Survey

Prepared for

W.R. Grace & Co. Cambridge, Massachusetts

File No. 611802 April 1988

-.. ~ SECTION VII. NEIGHBORHOOD SURVEY

7-01. Introduction

A Haley & Aldrich hydrogeologist conducted interviews with home owners near the Grace facility in Cambridge, Massachusetts, to assess the present and past history of basement flooding. The survey encompassed approximately 35 homes located within an area bounded by Seagrave Road and Columbus Avenue on the north and west, Whittemore Avenue on the south, and Harrison Avenue on the east (Figure VII-1). Letters of introduction were sent to the residents before the start of the survey. The letter explained the purpose of the survey and listed the information that would be collected during the interview. The interviews were completed between 20 May and 1 June 1987.

7-02. Information Obtained During Interview

During each interview, information obtained on the building's flooding history was recorded on forms that have been included in Appendix VII-A of this section of the report. Specific data included the frequency and duration of flooding, the association of flooding with heavy rain storms or plumbing leaks, the use and frequency of operation of a sump pump, how and where water enters the basement, distinguishable water marks, elevation data on selected basement floor slabs, and depths and conditions of dry wells.

7-03. Survey Results

Reaction to the interviews was generally positive. Many of the home owners have been life-long residents of the neighborhood and have had a long association with Grace. Due to this long association, many of the residents did not seem to feel overly concerned with the proposed developments at Grace. In general, the residents understood that it was to their benefit to answer the questions as thoroughly as possible. Those residents who did express concern about the activities of Grace were cooperative in answering questions. The few people who were uncooperative were not expecting the interview because they did not recall receiving the letter of introduction or did not receive one.

VII-1 The frequency and severity of basement flooding was reported to decrease with distance from Alewife Brook. Water occurred most equently in the basements of homes on Seagrave Road and Wb lumbus Avenue which front on Alewife Brook Parkway and Alewife Brook. The majority of these residences had a sump pump in the basement. The home owners felt that the sump pump was usually sufficient for keeping the basement dry; though during heavy spring rains, they indicated it was common to have several inches of water in the cellar for periods of time up to a day. Several persons explained that flooding had been more common before a sump pump was installed in their basements and before the walls along Alewife Brook were built after World War II. Most of those questioned believed that the flooding was due to surface water runoff which either entered through the walls or came up through the drywell and basement floor.

Residents located on Whittemore and Harrison Avenues, Kassul Park, and Kimball Street did not generally have problems with water entering their basements. Many of those interviewed had a sump pump installed in their basements though it was rarely, if ever, used. They experienced flooding of their basements only when a very major rain storm occurred, such as a hurricane.

None of the residents interviewed during the survey indicated / any unusual discoloration or odor in the water entering their basement. A few residents commented that the water was occasionally cloudy. This is probably due to suspended sediments in the water. However, some indicated that overflow S on storm drains and even sewage lines had seeped into their llars once or twice.

Elevation data were obtained on the basement floor slabs in about half of the residences. The floor slab elevations in the residences along Seagrave Road were in the range of El. 107.5 to 108.6 with a median of El. 108.3.

The floor slab elevations in three of the residences along Columbus Avenue (Nos. 28, 36 and 42) were El. 107.8, 106.1, and 107.4. The floor slab elevations in the other houses included in this study ranged from El. 108.8 to 109.8 with a median of El. 109.4.

Groundwater elevations in the wells along Whittemore Avenue have been measured at El. 106.9 or less during the course of this study. Groundwater elevations north of Whittemore Avenue are expected to be lower as the groundwater flows toward Alewife Brook which is at about El. 105.

VII-2 7-04. Discussion

The frequency of basement flooding in the neighborhood immediately north of the Cambridge Grace facility depends on the residence's basement floor slab elevation, their methods of handling surface runoff, and the condition of the sewer system pipes.

The basement floor slabs of residences along Seagrave Road are at least 0.6 ft. above the maximum groundwater elevation. This was determined using the highest groundwater elevation measured in the wells along Whittemore Avenue. The floor slabs of residences along Columbus Avenue are at least 0.5 ft. above the groundwater elevation except at 36 Columbus Avenue. The other residences are at least from 1.9 ft. to 2.9 ft. above the groundwater table.

Most of the residences believed the water entering their basements was due to surface water runoff. One residence stopped basement flooding after extending the edge of the roof further from the house.

C.E. Maguire, Inc issued a report to the Cambridge Department of Public Works on the condition of the sewerage and drainage systems in the neighborhood and in other parts of Cambridge. They reported the sanitary sewers in the neighborhood were in poor condition. Some of the pipes were crushed and/or cracked. At one place the pipe had collapsed which forced the ewage into the storm drain pipes. The storm water drain system is reported to be in fair condition. The storm drain lines need to be cleaned to remove debris.

7-05. Conclusions

Water flooding the basements of the residents in this survey is primarily surface water with some groundwater mixed in. During heavy rain storms, rainwater discharging from downspouts and flowing near the foundation walls infiltrates the more permeable soil that is present along the foundation wall and under the basement floor slab. This water increases the groundwater table under the basement and causes surface water to then flow into the basement. This situation results in flooding of basements after a significant period of rainfall which is the scenario some of the residences described.

The poor condition of the sewer pipes probably causes sanitary sewage to leak to the groundwater. When the storm drain lines handle high volumes of rainwater, the sewer pipes probably leak sewage and rainwater to the groundwater at a higher rate. This condition would locally and temporarily increase the groundwater table.

VII-3 k

In the NOR, DEQE requested Grace to evaluate the possibility of contaminated groundwater from the Grace site entering off-site residential basements. The results of the survey indicate the water flooding the basements is primarily surface water. Shallow wells have been installed along Whittemore Avenue. Contaminants detected in the groundwater on site have not been detected in the groundwater obtained from these wells.. Sewage, which is probably leaking from the sewer pipes, contains the same compounds as found on the Grace site. If these compounds were detected in the groundwater in the neighborhood, it would not be possible to determine their source. Based on this information, we believe that, at this time, shallow wells are not necessary in the neighborhood north of the Grace facility. If contaminants are detected in the shallow wells located along Whittemore Avenue in the future, then the need for wells in the neighborhood can be reevaluated.

0211R

VII-4 I.l

sor

So-3

=e - -*

se a

2- '

co SLID 0N 1ud ~niururrijm" JilL wwr ThAl rIke -t e COMMONWEALTH OF MASSACHUSETTS EXECUTIE OFFICE OF ENVIRONMENTAL AFFAIRS - DEPARTMENT OF ENVIRONMENTAL PROTECTION ---METROPOLITAN BOSTON - NORTHEAST REGIONAL OFFICE WILLIAM F. WELD Tku z CCQXE Governor Secretary

ARGEO PAUL CELLUCCI DAVID B. STRUHS Lt. Governor Commissioner

By CERTIFIED MAIL RETURN RECEIPT REQUESTED SEP 2 0 1996

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

NOTICE OF AUDIT FINDINGS NOTICE OF NONCOMPLIANCE INTERIM DEADLINE LETER

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

Dear Mr. Wightman:

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

VIOLATIONS EXIST THAT REQUIRE FURTHER ACTION

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

10 Commerce Way a Woburn, Massachusels 015C.1 FAX (617) 932-615 * Tleiphone (617) 932-7600 * TDD # (617) 932-7579

C0P- Ir d MP.Rn,! "Iprl W.R. Grace & Co. - Conn. Notice of Audit Findings Page 2

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

DEADLINE FOR RETURNING TO COMPLIANCE

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

DEFICIENCIFS EXIST THAT REQUIRE FURTHER ACTION

A. Deficicies that Require Further Action. The Department has identified the deficiencies listed below. Steps which should be taken tc ctrrect each deficiency are also listed.

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

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

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

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

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

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

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

CONCLUSION

DO NOT IGNORE THIS NOTICE. Failure to correct the violations and deficiencies identified and provide documentation of such action to the Department may subject you, your officers,and other involved individuals to enforcement action by the Department. The Department may conduct a follow-up audit to determine whether the required actions have been taken. If the Department finds that the violations and deficiencies have not been corrected, then the Department may issue a Notice of Noncompliance (NON) , Notice of Intent to Assess a Civil Administrative Penalty (PAN), administrative enforcement order, Notice of Responsibility (NOR), Notice of Intent to take Response Action (NORA), Administrative Consent Order, Unilateral order, or seek a Judicial Judgement as appropriate. You may also be subject to cost recovery under 310 CMR 40.1200 for failure to perform response actions at the disposal ah site. -=7- - -

FHWA-MA-EIS-87-01-D I ROUTE 2/ALEWIFE BROOK PARKWAY PROJECT Draft Environmental Impact Statement/Report Submitted Pursuant to 42 U.S.C. 4332(2)(c) and 49 U.S.C. 303 by the I U.S. Department of Transportation Federal Highway Administration and Massachusetts Department of Public Works Cooperating Aaency U.S. Fish- and Wildlife Service 71

J February 10, 1987 Date of Approval Division Administrator 711 The following persons may be congacted for additional information concerning this document: -J Mr. Clement Dunkley Mr. Frank Bracaglia Federal Highway Administration Massachusetts Department of Public Works Transportation Systems Center 10 Park Plaza 55 Broadway, 10th Floor Room 4261 Cambridge, MA 02142 Boston, MA 02116 Telephone Number: (617) 494-2515 Telephone Number: (617) 973-7484

The Route 2/Alewife Brook Parkway project area, located in Arlington, Belmont, and Cambridge, Massachusetts, has long been in need of transportation system improvements. The abrupt transition from an eight-lane Route 2 expressway to a four-lane Alewife Brook Parkway has caused significant traffic congestion, particularly during peak commuter periods, and vehicular and pedestrian safety problems. Recent completion of a major transit station and 2000-car garage, as well as continuing development in this area, are increasing the traffic demands imposed on this roadway network. The environmental sensitivity of the corridor is also a major concern, because it includes publicly-owned recreation areas, extensive wetlands and water resources, and a shallow floodplain. This document analyzes four alternatives, plus the No Federal Action Alternative, aimed at improving the transition between the expressway and the parkway, improving vehicular and pedestrian safety in the corridor, and accommodating access to area development.

Send comments to the following individuals by May 4, 1987 at the respective addresses listed above.

Federal Highway Administration Massachusetts Dept. of Public Works Mr. James A. Walsh Mr. Robert H. Johnson Division Administrator Chief Engineer

This document is also prepared in accordance with the Massachusetts Environmental Policy Act (MEPA), EOEA No. 4539. 1. lamp and Bridge Design -- The ramps and bridges should he designed to take advantage of advances in structural technology. This will allow the elevated alignments to be more structurally efficient with less depth of structure, and to be less obtrusive than older - structural prototypes.

2. Landscape Buffers -- Trees, particularly of large caliber, should be planted adjacent to elevated ramps and bridge ebutments to mask their size and break up their linearity.

3. Ground Level Landscaping and Lightinr -- Ramps and bridges should be designed with landscaping and lighting which highlights points of passage under the roadway and integrates the pedestrian and landscape patterns as part of the active urban environment.

4.5 FLOODPLAINS

4.5.1 OVERVIEW || As discussed in Section 3.4, the study area is within the Alewife Brook watershed which has a history of frequent flooding. The limit of the 100-year floodplain in the study area as defined by the Federal Emergency Management Agency (TEMA) was presented on Figure 16. The occurrence of ignificant flooding has increased over the past several decades as a result of development in the floodplain area, and open water courses biffra~Ted by cloed culvir~Tiallow floodplain, along with the very flat slope of the Little River and Alewife Brook, result in backflow of flood waters from the downstream Mystic River into the study area during major storms (storms in excess of the 50-year event).

Because of the flooding history of this area, impacts on flooding from the build alternatives have been carefully considered. The build alternatives were compared to Alternatives 0 and 1 to determine the net increases in impervious roadway pavement area and the resultant increases in peak stormwater runoff rate. The reduction in the amount of flood storage from constructing the proposed roadway improvements in this area on embankment was also estimated.. To mitigate the effect on flooding, measures were investigated to compensate for the floodplain displacement and increases in the rate and amount of runoff.

4.5.2 STORM WATER RUNOFF

A summary of existing and future impervious roadway areas within the project area, as well as estimates of existing and future peak storm water runoff rates for each alternative, are presented in Table 38. Alternative 0 results in a slight decrease in impervious roadway area and runoff compared to Alternative 1 (-4.2 percent), while Alternatives 2, 3, and 4 increase the impervious roadway area and runoff by 20 to 22 percent. As indicated, the increased impervious area will increase the amount of storm water runoff to ara waterwayse

-161- 6 4:

I Unless measures are provided to control this increased runoff rate, additional runoff will increase the extent of flooding at the project site as well as downstream of the project site. The storage capacity of the floodplain will be reached sooner during major storm events, prolonging the duration of flood conditions. Increasing the rate of runoff could also increase the elevation of the 100-year flood, depending on the flood stage downstream in the watershed area when the storm occurs.

To mitigate the effects on flooding due to higher runoff rates, retention of the storm water runoff was investigated. The area best suited to increase-runoff retention capacity is within the southeast quadrant of the Route 2 and Lake Street interchange--the site of an abandoned MDC skating rink. Approximately 50 percent of this area presently consists of pavement or roof area, and also contributes runoff to the northeast corner of Little Pond.

For each of the build alternatives, a new system of ramps will require removal of the skating rink and associated pavement areas. This construction will also provide an area of about 3 acres which could be used for storm water retention. The fill material located within the infield of the proposed ramp system in this area can be excavated to contain stormwater runoff. Upstream roadway drainage systems could be directed toward the retention area, and storm water runoff from the roadways in this area would also be retained at that location. Preliminary analyses indicate that approximately 15 acre-feet of storage volume could be made available by depressing the infield areas of the proposed ramp system. (A basin with one acre-foot of storage volume has a surface area of 43,560 square feet and a depth of one foot.) As was discussed ection 2.7.5, and is discussed further in this section, the build Wernatives would displace about 12 acre-feet of floodplain.

Based upon a total 100-year, 24-hour rainfall depth of 6.6 inches, 15 acre-feet of storage volume would accommodate 100 percent of the runoff from a surface area of about 27 acres. That is, a retention basin having an available storage volume of 15 acre-feet has the ability to retain all runoff from at least 27 acres of pavement during a 100-year, 24-hour storm. Since the build alternative's maximum total impervious pavement area is approximately 21 acres (refer to Table 38), a retention basin at the Route 2/Lake Street interchange would reduce the peak rate of roadway runoff to less than the present rate. This retention basin would include a control structure(s) which would limit the rate of discharge from the basin into Little River or Little Pond. The control structure(s) could consist of small diameter pipes or culverts which would restrict the discharge rate from the basin, or it could be designed to allow storm water to build up to a specified level before flowing through the discharge pipe to the receiving waterbody. The retention basin is proposed as a measure to mitigate increased storm water runoff rates of Alternatives 2, 3, and 4. The basin also will be developed as a wetland area to mitigate wetlands impacts as discussed in Section 4.6. Alternative 0 will reduce slightly the amount of stormwater runoff from the Route 2 corridor, but will not necessarily reduce flooding potential as stormwater retention facilities are not provided; Alternative 0 would result in conditions similar to those which existed prior to the construction of the interim access project.

-163- twistn Qarmcn's Jntn, Ututsfun No. 509 211 Congress Street em Boston, Mass.( 542-8212 N9 7170 1= GRIEVANCE REPOI F312 Date 1K ~.ii A iA Name -La OF Address -9D/ ( ,

I' Telephone NoP% / r 71 Div. Sta. Dept. 7 / Classification Location r / Date of Grievance or Accident Statement of Violation XA 9C 1 cL \ Nk E es 041c Lms.' -~ U v ILTh1, USSQ vu , Lf l ocrs "-ro c F1.,".t i s<,T The z Fr -kr4 )/ 6-.. , A 4

LfriIKI / I

Sr Signatu ALL" svt t 'S

(1) Name (optional) U9 r Y

(2) Age . -

(3) Years at the NBTA

(4) What jobs do you work at for the HBTA and how long have you been at that job? (a) 6 for 2L years (b) C for years.

(e) for years.

(5) On average, how much time do you currently spend in each of the forllowing areas? Hours per week in the station (not in a train) Hours per week riding/driving a train

-0, Hours per week walking in the tunnels

Hours per week outside of the station or tunnels

(6) If most of your time is spent in one station, what station is that? Y T v

(next page) (7) While at work do you experience any of the following symptoms (check all that apply)?

) Eye irritation Breathing problems

(d) Nose and throat problems

Dizziness &i) Headaches

il g)-Nausea

h) Tiredness - (i) Hearing problems

(M) Other

(8) For each symptom that you checked above, put the letter corresponding to that symptom in the one space next to the commerjt that most closely describes when that symptom appears:

( - (M) Appear only while you are in the tunnel.

/0 - 4U (ii) Appear on days you have been in the tunnels and then symptoms go away.

(iii) Last through the week and symptoms go away on weekends and during vacations.

(iv) Come only during one season (summer, winter, etc...)

.(v) Are there all the time. (vi) Come and go, but not related to when you are in the tunnel.

(vi) Other j2M Pk5 Cn O (A/'1 vortin . tF i

0 (next page) 0 r .

(9) Have you been diagnosed by a doctor or nurse with any illnesses since you began work in the tunnel (please list)?

(10) Are you exposed to any chemical mists, vapors, dusts or smoke on the job (please describe the exposure, if you can)?

Yes No

Description (what and where)

(11) Have you been trained to recognize and protect yourself from any hazardous materials that you work with, please indicate 4 the length of the training you received?

Yes No

Length of training _ hours or _ days

(12) Has anyone ever inspected your job for health and safety hazards?

Yes - No - Don't know

(13) Do you have access to Material Safety Data Sheets (NSDS's) for the chemicals you work with?

Yes No Le. Not sure

(next page) .*

(14) Protective equipment: F. Check any of the following which are provided on the Job; please also chec-k those that you think you need (but do not yet have) to do your Job safely: Have Need

Rubber gloves

Eye goggles

Respirators

Rubber boots

Hearing protection Other

(16) Please list any health and safety concerns you have that were not raised in the survey:

I - XS-6/4) e. 0 #/ / A ALE tP m A cresW4X4aL VAgA ( Rf $ Cf- . t4R fAt A LrJT Ly - T jjswEs ISs 9154Af so6i- of 4vetyw 4- o ) -e' Qk ,ttt)C/ 6K ZA't/FAI+('- cif erv Co//ec1c1,C U49tc

#| SIf '6/4 F- 0 /,,,-/,,,,c 7&l/=' Xut'ho~

F-A-' tQ|{ p'|i gy7 e 6DZ I§f2 Aov' A'c ,, M/X07'4,% to /41ZlE1i/47S 71e P r I LOCAL DIVISION 589 - AMALGAMATED TRANSIT UNION, AFL-CIO-CLC BOSTON CARME2N'S UNION

GENERAL OFFICERS & EXECUTIVE BOARD MEMBERS

RICHAED M !,'LFPHY ... .1 .. . 4sPn, s e Agent RC ERT J. ECAES. Deegae... HeadruatIers ...... I 1.. 295 DEVONSHIRE STREET JAMES W. DLCHA\EY ...... Vice-Piesdent CHARLES HURLEY, Delegate ...... D..in 3 {5:h Floor) EDWARD F. Si-EC-:LETON . F.arc al Sec-e!a-y-Treaswer WILLIAM P. KELLEY, Delega:e ...... Rapid Txans1Dvis.c, BOSTON. MA 02110 JAMES E. LYDON ...... :ng Secre:ay ROERT F. GOSNELL. Delegate ... Shps and CawhouseEmpicy*es Tel. 542-8212 Fax ES5-99E2 D EL Kr FLTC:.... . Ass swri See etway DANIEL J. CYKENS. DIE-gae ...... Maintera-ce or waf

March 10,1994 F-a

Mr. Robert L. Mabardy Chief of Staff, MBTA 10 Park Plaza Boston, Ma. 02116

Dear Mr. Mabardy:

The members of the Boston Carmen's Union that are working at

Alewife Station have been complaining to us about becoming sick

from working at that location. Our members also have been

complaining about structure erosion and falling debris. Your

immediate attention is needed before one of our members and your

employee becomes seriously injured or -sick. Thank you in advance

for your cooperation.

ncerely,

J desE. ydon .cording Secretary

CC: F. McDonough F. Goodine 0

a E2' 'Im '.RiVNC A & E&CnR,D IAt GRIEVANCE APEAL.RECORD

DATE: - -P

A= Of GRIEVANT: / Ctss:

SWHIARY OF GRIEVANCE ; 0

AseAi.. M ls9 c( ./t

.1t SOMITTE BY UNION DELEGATE 47/74//-- I

1 GRIEVANCE DECISION # ) ALLOWED): DATE: & 9' 23Y:.

GRIIVANCE DECISION (DuEDI, M10VEDi

DAEI 31:

GRIEVANCE DECISION (DENIED, ALLOWED):

DATE: BY: DIRECTOR OF OPERATIONS

* C 1*

t 1' **f~ ft

IA MASSACHUSETTS BAY TRANSPORTATION AUTHORITY Thomas P. Glynn General Manager Transportation Buliding Ten Park Plaza Boston, Massachusetts 02116

September 5, 1989

Mr. Richard J. Guiney Recording Secretary Local Division 589, Boston Carmen's Union Amalgamated Transit Union, AFL-CIO 80 Boylston Street Room 430 Boston, Massachusetts 02116

SUBJECT: James Josselyn, Motorperson #4804 - Three (3) Day Suspension

Dear Mr. Guiney:

Please be advised that after hearing all the evidence presented by President/Business Agent Romano and Delegate Madden at the meeting on. August 22, 1989, the captioned grievance is denied.

On Tuesday, April 25, 1989, Mr. Josselyn appeared in the Red Line Supervisor's office to complain about the air at Alewife Station. After discussion with the official, who had agreed to check on Mr. Josselyn's complaint, the Motorman agreed to comply with orders and run his trip. However, without notice or permission, he left the premises and failed to make his scheduled trip. Based upon these circumstances, the three (3) day suspension is for just cause.

Sincerely,

Thomas P. Glynn General Manager LOCAL DIVISION 589 AMALGAMATED TRANSIT UNION. AFL-CIO-CLC BOSTON CARMEN'S UNION

GENERAL OVVICERS -XECVTIVE UOARD MEMBERS

TONY ROMANO ...... PresleentusingU Agent % JAMES . .Y N ...... Dision Readquarters JAMES W. DUCMANEY...... Vku-Presien$I GE904S =. CAYPBEL ...... s 80 COYLSTON STREET JOHN J. O*LEAV...... Pingesast kecretaryVTreaturet * PRANK X.MAVOEN ...... Resi itS: Division (Room 430) RFCNAR J. GLIINEY...... iACt ing SeCretary STANLEY V. STEARNS . . 5no4s ae Carmos Em:::s BOSTON. MA 0E116 Tel. 542-8212 RICHARD M. MURPHY...... ,Assitent S~cetary - JAMES 9. FPAMEPITY ...... MaitEnmnce of Aly

*~s :&

Boston, Mass. July 7.1qPA 19

Mr. Joseph Sisk Manager of Safety MBTA (Cabot Center) 275 Dorchester Ave. Dorchester, Ma. 02127

Re: Alewife Station Dear Mr. Joseph: 46 Local 589 requests the Authority investigate the cause of several complaints of our members working at Alewife

which was built on the W.R. Grace site. Our members are

complaining of Skin, and Eye Irritations.

Please contact Frank Madden at 542-6212 to discuss the problem. Thank you for your cooperation on

this matter.

Sincerely,

* ~1/l rt C:j 1 {L§'Zt~ 'K C ~ MASSACHUSETTS BAY TRANSPORTATION AUTHORITY John K. Leary, Jr. Deputy General Manager for Operaons Transportation Building Ten Park Plaza Boston, Massachusetts 02116

June 20, 1969

Mr. Richard . Guiney. Recording Secrei.ary Amalgamated Transit Union, Local Division 569 £0 Bovston Street, Room 430 Boston, MA 02116

Dear Mr. Gu.iney;

RE: Grievance Appeal for Motorperson James Josselyn. #4804. Area 113

This letter is to inform you that after careful review and analysis of the pertinent data in the subject caSe, together with the Unicn's appeal on May 22, 1989. 1 concur with the Chief Transportation Officer's decision o± May 9. 1989. to uphold the three (3) day suspension imposed on the above-referenced individual.

Therefore, this grievance is denied at the Director s level.

Sincxely.

/. 'Dohn K. Lear). Jr. Deputy General fanage: for Operations

JKL5S/ i bsc c: P. Lennon J. Killgoar F. Madder S. Ho:.es D. Bacchus Iastn Qumen's num. Utuistan No. 519 N on 80 Boylston Street e Room 430 Boston, MA 02116 542-8212 GRIEVANCE REPORT

Da ApriI 6(

Name .J t Z6osje Address 7 L 4 -c Telephone No. Employee No. YJr 0 Location Dept. Date of Grievance or Accident

Statement of Violation Sz4 77:e-e v~le f 6r,'z>

9 / L-n /V e.r /7 r

SRgnatu4~ 4 /

Report of Barn Committeeman

1.6' Report of )elegate {

*.s4-~ It-7 aan(c41461L4at27*1 (CA ~? wqe womuonweUaQ 01 massacquams DEPARTMENT OF INDUSTRIAL ACCIDENTS - Deppartment 101 600 Washington Street - 7th Floor, Boston, Massach usetts 02111 DIA NO: EMPLOYER'S FIRST REPORT OF INJURY FOR OFFICE USE ONLY Do Not File This Form Unless An Injury Has Resulted in 5 Or More Lost Work Days a RUCTIONS AND CODES ARE ON THE REVERSE SIDE. PLEASE PRINT OR TYPE: 1* 71... - -n.------*- Vr 1. Employee Name (Last. First, MI). 2 home Tefephone 3.Social Security Number -. .. t0 "r'C(PIL. .Jam rc IOUL If . 67-)4717- Z , -033 -,-4Y-7AS7 No. of Dependents____ E dres'1 (No. & Street, City,.- .. State. Zip Code) 5. MaritalitI.u stat s5 6 No. at Dependents PESingle

Y 7.Date of Hire (MM/DDNY) 8. Date of Birth {MM/DDNY) - 9. Sex 10. Hourly Wage 46177 q031r3J / S7 -mate O Female 11.Piece or Hourly Worker? 12. Hours Worked Per Day 13. Days Worked Per Week 14. Avg. 52-Week Wage: S 0 Piece D Hourly t2 , 63 . Estimated or C Actual

15. Employer Name 16, Self-insured? M Yes C No 18. Federal Tax ID 17. Self nsurer No.: ) E 19. Employer Address (No. &Street, City, Site, Zip Code) 20. Employer Telephone 21. Industry Code (See Back of Form) P L 0 22. Workers' Compensation insurance Carmer Name and Address of Branch Responsible for This Case (Not Local Agent or Adjuster) Y E R

23. Workers' Compensation Policy Number 24. OSHA Case File Number

25. Date of injury (MM/DDNY) 26. Time of Injury 27.1i Injured Has Died. Enter Dt of Deat (MMIDDN /fD :I ]A.M O P.M. 4 28. Address Where Injury Occurred (IfDifferent From #19 Above) 29. On Employer's Premises? 30. Employer Location Code

31. Did Employee Lose More Than 4 Hours of W rk on Date of Injury? 32. Has Employee Lost 5 Days of Work? Yes No D Yes o (It"No". DO NOT file this form.) N 33. First Lost Work Day (MM!DDNY /v61 ' 34,FifthLostWorkDy(MDD I 35. Source of Injury or Illness (e.g., Machine, Tool, Substance, etc.) 36. Regular Occupation. 37. Reglar Occupation When Injured? CZP IC e)o rsrjrt 5atPABV[IeONo 38. To Whom Was injury or Illness Repoled? 39. Date Reported (MM/DfYY)

F 40. Nature of injury(ies) or Illness (Burn. Fracture, Cut, etc.) 41 Nature of Injury or Illness Code(s) Injud o. By Pt Ce b 4242. Injured s) Description (Arm, Leg. ack, etc.) A S dy Ptis) I (See Back ofForm) a 6 bc 44. Physician Name and Address 4. ame and Adoress

46. Describe How injury or Illness Occurred (e.g., Struck by ....., Fell from ...... , Exposed to.

47. It Employee Has Retumed to Work, Returned to Regular Occupation? of Return 27.DatenMNVDjued Ha Di Et D? f

*Disclcsr; Sc:al Security Nurrter is voluntary. It will be used to coordinate 0i !ings wan the Deparrent o! Inoustrial Accidsnts and to process your report POEM 093417 MASSACHUSETTS SAY TRANSPORTATION AUTHORiTY A113 QUADRUPLICATE INTERVIEW SLIP - of, DA TAILIESMPL Cts gE

Motorman James Josselyn is being interviewed concerning Rule #12 - RPORING 7OR AND RE(AINNG ON DUTT, which states: Employees must report for and remain on duty as directed unless excused by proper authority. (See also Rule 15, General Ruleis), and Rule #5 - OBEDIENCE TO ORDERS, Section (a),, which states: Esployees must willingly ad respectfully yall orders of those In authority. When working In, or -pasing through any section of the system, they must obey the or4srs of the officials of that section.

Tuesday, April 25, 1989, at approximately 3:35PM you eae to th Red Line Supervisor's Office and requested to speak with me.

EMPLOYEE SIgNATURE SIGNATURE FOR MANAGEMENT I

FORN On."1 MASSACHUSETTS BAY TRANSPiOATION AUTHORfTY A117 QUADRUPUCATE INTERVIEW SLiP P. 2 of &

DA MPL CLAS T NO &A J L

You voiced concerns about Benuine in the air at Alewife Station and Asbestos at Davis Station. You determined LAlevife dead ani was a hazard to your health and because of this you would not lay up trains at Alewife. I responded that I would look into your concerns, however, you would have to continua your assigned work. In fact I ordered you to perform your next trip out of braintree the 3:45PM trip (Run 41). You were instructed to p&a up tbis trip at Quincy Center. You agreed i I promised you wouldn't have to lay up trains at Alewife Station. You were told you would have to do as your assigned work required. You were given another order to met the 3:45PM trip at Quincy Center. You agreed to do this, however you left the er office end did not operate the trip as directed. You did not

EMPLOYEE SWNATUREK SIGNATURE FOR NANAIENENT rn CnS.aI MASSACHUSETTS BAY TRANSPORTATION AUTHORITY Al13 QUADRUPUCATE INTERVIEW SLIP p. 3 of 3

DATA k PL CLASL0- NOAn G Nl-5 B r

explain to any Authority Official that youvould not operate the trip.

This is the basis for your interview.

loye* statest - See statement dated today (4/26/89)

SIGNATURE FOR MANAGEMENT EMPLOYEE SIGNATURE

P4 MASSAUSETTS DAY TANSPORTATION AUTHORITY QUADRUPLICATE DISCIPUNE SLIP

4 /26 /8,IEpL cLASk0 NOcL0A3 a i7m - Sec interview slips same date and prior record. You are found in violation of the rules cited in your interview of this date. For e ations and '.in conjunctiziht you will be suspended threelt days as follows: Mon. 5/23/89, Tues 5/23/89 and Wed. 5/24/89. You are warne that anylfuure violations 00 these rules or any other Authority rules, regulations or S1 ieial orders will result in more severe and pro- gre.ss ve discipline. Alt be advised Employee Co risell4n Services are available to'you.

EM? tE A E .SI.NATURE FOR NAGEMET MASSACHUSETTS BAY TRANSPORTATION AUTHORITY Thomas P. Glynn General Manager Transportation Building Ten Park Plaza Boston, Massachusetts 02116

September 5, 1989

Mr. Richard J. Guiney Recording Secretary Local Division 589, Boston Carmen's Union. Amalgamated Transit Union, AFL-CIO 80 Boylston Street Room 430 Boston, Massachusetts 02116

SUBJECT: James Josselyn, Motorp-erson #4804 - Three (3) Day Suspension

Dear Mr. Guiney:

Please be advised that after hearing all the evidence presented by. President/Business Agent Romano and Delegate Madden at the meeting on August 22, 1989, the captioned grievance is denied.

Sincerely,

Thomas P. Glynn General Manager MASSACHUSETTS BAY TRANSPORTATION AUTHORITY

Ten Park Piaza, Boston, MA 02116

August 11, 1989

Mr. Richard J. Guiney Recording Secretary Local Division 589, Boston Carmen's Union Amalgamated Transit Union, AFL-CIO 80 Boylaton Street Room 430 Boston, Massachusetts 02116

SUBJECT: Grievance Appeal of Motorperson James Josselyn, #4804 - Three (3) Day Suspension

Dear Mr. Guiney:

Please be advised that after hearing all the evidence presented by Delegate Madden at the meeting with Gayle G. Simmons, Labor Relations Representative, the above captioned grievance is denied.

On Tuesday, April 25, 1989, Motorperson Josselyn was ordered to continue his assigned work and run the 3:45 P.M. trip out of Braintree, picking it up at Quincy Center. Mr. Josselyn agreed to run the trip, but then left without permission or notification. Based upon the severity of the incident, the three (3) day suspension is appropriate.

Sincerely,

Director of Human Resources

GGS:mW cc: J. Leary, Jr. J. Killgoar F. Madden 2 Area 113 Masachueetts Day Tranporaton Authority

Asst. Supt. Surf. Lms Statement made to Sipenntenent of R.T. Lircs Tran5p. Pate 199. By /b/A CAmA-Ar Occupation TArr-e>rrar 5adge # /g22AZ. Concnring s Occunna At 9-& AM PM Pate J-2~1-9Z 199 C

,VK.J pe A r.lAc ds7 tcerr

11 a/cc AJue Zeen tor>7 - a~r Aec/ s-o./ etmn,

/ve- IJrwy>~7ye unne w7]2;g .. .. h $ur is m

A> , Ni2 J oe , > A~ril.fi. elrv' ,it nyj An ee n I IPrly. , I nir CZ// t<4 A(il47/§/7

2 e -lal fr. unb trs. (luren U.Miller Jr. 2111 (omit uf Praiirts, anrliustts 02184

cgceotc-t

oZ;c-7 1t~n= 5 ML~

2%4ceti

4 Wvkxtrpn. A ( 4 I #rz~, ,4C4C-~ 6%c-~k ~ ~AZ~aC iro-

I.,

PA. i ~ 4L~4JL $r (J9ZCCU

0- 2 A ~ ~,4C4az 73vt elo-

kid 4'-y - C'/.7 -.-. MASSACHUSETTS BAY TRANSPORTATION Ad HORITY

Ast .rsupt Surf. . .o Statement mod, to Superintendent of R. T. Lines Trwwsp. Dte..lj.L...~L...... 1 By .7I2m A-paio r.JS~

Concerning Tc4 Pcc /d

______-Occurring .t&L..4...... p.i. Dit. l&prrs A*74 a

J-. , . / 0s 1. . ,.. n .A n i Q

4 SCrOiNc /yw4.n r y AAAau Ir'ZAOr. pere T0 ' ing 1:61"A'-eds," p9-p c4ei/ t-In isnewA Ae.lt,$ AJ

cka c A carshue 46z 4 bsiriy -) _t(tAokILeyp-eto

AMArumokl g~e-oWVI t1'chn4r1e. da4 ~CPn k~a-In /4"o Ply j eA cus~pk rflur fir t&,ef dy q-4tr 4 " iLnyd1 "p A74'0" Zr cthr-A S in eb0v a st' irmaokit oAm psn&MA uh My eye-C r4 *rwA pe.se persris4A1 asuk A cbrsenAc44 Ac. ( i ascdny l/\yi? nSt 510 ai aP't& / 4$A 4<- 4 Mov&cekt d'Piy rdc0v2rrr eM .A!fy

mi gmet impl'' A4 W 4 nne -T n A 44e evuuirs * -46 voce mtg rentVS ok a, doe c,4Ai TrA&s 401i4 MOw .1!- 04..t i. 4 hea rot] 8 h could Jellt Mtu4 b .- cr comA ig w--k wI, kwM A l 4wvt, 4'9 ,nu/kr A /r sid~-heL-- cwsr _tyheir se e 4 A L,$~~r adc K/oknlc d dSicA IV f ir tCdli u t -rco OWay >41 r eI# M exet40p/d /4.a erefpcndid d 4kt Ca T codbL 4 hy

r ' / r CAMP DRESSER & McKEE INC. C DM Injj:s.tIl EngiroPimq Do siU

One Ctr: Poa En MWssc nj':- 02108 017 /42-5151

July 27, 1979

Mr. Van T. Boughton, Vice President W. R. Grace & Company Grace Plaza 1114 Avenue of the Americas New York, NY 10036

Dear Mr. Boughton:

Thank you for the opportunity to meet with you and your staff on 13 July 1979 regarding the filter cake residue that has been spread at the Dewey and Almy site in Cambridge, MA. Apparently, concerns about the site have been primarily generated by the proposed MBTA tunnel construction through the site itself. As we understand the situation, a sulfanated-napthalene sludge has been dumped at the average rate of about 2 cubic yards per working day for the past fifteen to twenty years. Some of this material may have been placed below the elevation of seasonal high groundwater. In years past, this material was acid-washed prior to its final disposition and has, therefore, caused the discharge of a low pH, (acidic) leachate to the soils and, possibly, groundwater which make up the site substrata. The MBTA's specific concern is the potential effect of this acidic leachate on the concrete construction of i proposed tunnel and headhouse. The breadth of concern has reached both City of Cambridge officials and the State Department of Environmental Quality Engineering (DEQE), and they both will, undoubtedly, be considering potential on-site groundwater contamination and the-possible migration of this contarina- tion to off-site surface and groundwaters.

We have reviewed the site soils investigation performed by Goldberg, Zoino, and Dunnicliffe Associates, Inc. (GZD) for the MBTA. Several borings were taken and conductivity tests carried out. The conductivity contours and profiles indicate distinct low-pH leaching both vertically and horizontally. Ver- tical leaching has apparently reached to a deposit of low-permeability clays at an average of 30 ft below the sludge placement. Intermediate strata of permeable, sandy soils has influenced the horizontal leaching in a general Northwesterly direction, the general direction of flow of groundwater as indicated in the. GZD report. No apparent leaching was indicated from the sedimen- tation (settling) basin adjacent to the sludge area, but only from the sludge area itself. We feel the precision of these data should be reviewed in detail and reinforced with additional investigation before any major action is taken at the site by W. R. Grace. i CAMP DRESSER & McKEE INC. Mr. Van T. Boughton July 27, 1979 -2-

We have discussed the situation, at your behest, with William St. Hilaire of DEQE's Metropolitan Boston-Northeast Region. He stated that although no local approvals are in-place and no operational plans have been submitted by W. R. Grace in the past, he would be willing to accept, and review for approval, plans to do remedial work at the site to alleviate the -contamination apparently caused by the existing sludge mass. Further dumping at the site, however, will not be acceptable, and therefore, our project approach will address remedial site work only. It will not consider any continued placement of sludge at the site. We discussed regrading the sludge to control surface runoff and subsequently applying low-permeability soil as a cover material to minimize infiltration due to precipitation and runoff. Mr. St. Hilaire stated that, while necessary, this, at a minimum, would not be considered adequate action. He will insist that, in some way, contact of sludge with the groundwater is not to be permitted.

CDM has developed a project approach which we feel will address the major environmental concerns of the City and DEQE and should permit consideration of the MBTA proposal to continue. The initial tasks of our work program will further define the date base, including topography, perform on-site soils work to aug- ment the GZD work, consider previous operational information, and address many of the specific concerns of local and state officials. Subsequent tasks will develop plans and an attendant report for submission to DEQE.

Task 1. Topography. *A topographic survey of the sludge dumping site will be performed and a plan prepared. This plan will serve as a base plan for any anticipated regrading and construction at the site. We have been in contact with the surveying firm of Allen & Demurjian, who have done work in the site area in the past. They will perform an update of existing topographical information to the level of detail required for the work proposed herein.

Task 2. Hydrogeologic Investigation. A hydrogeologica investiqatjn will be conducted at the site by our subconsultant Haley and Aldrich, Inc. (H&A) of Cambridge, to verify the work done y GZD and to supply additional detail to better define the extent of the p'a'3DJt problem. r The investigation will include a two day test pit effort, 8 sTallow- single sample wells, and the installation of ten multi-level wells. Water and soil samples will be analyzed to determine the extent of contamination and potential effect on downgradient water quality. - mc- n- Configuration of well placement will differ greatly from GZD investi- - C. f I''A K e .'-~ gation in that our investigation must consider soil conditions, especially depth to low-permeability clay, in the potential area or groundwater.diversion structure construction. H & A will produce a report for us detailing the results of their investigation and make hydrogeological recommendations regarding potential courses of remedial action.

/ - 4,

/ 7 V.-. , - K: -j ~ - - . *7~/ t)-~.

- Q-:--n---r-L ~ &&t ~

7 '"~~ -, *1 - kzrt~ (~ Lrnrnrn~rcrua - - - F -' - CAMP DRESSER & McKEE INC. Im jinial Eninrr ny O lvrmIcn Mr. Van T. Boughton July 27, 1979 -3-

Task 3. Job Informational Meeting. CDM staff will attend a job informational meeting with W. R. Grace staff and other appropriate parties, to review the Task 1 and 2 investigations, obtain and evaluate responses, and determine a reasonable course of action. .MBTA and DEQE participation is crucial at this point to be certain that site design work meets the specific requirements of DEQE and will allow for the needs of the MBTA proposal. Specific design requirements will be defined at this meeting so that site design may proceed as efficiently as possible. It is suggested that, to assure openness and local cooperation, Grace consider participation by the City of Cambridge Conserva- tion.Commission.

Task 4. Preparation of Preliminary Plans/Select Approach. Using data compiled in Tasks 1 and 2, and based on information and requirements determined in the Task 3 meeting, CDM will prepare preliminary plans for remedial site work. Two general scenarios exist: as outlined above, the site may be regraded and recovered, and groundwater diversion structures built to minimize infiltration and prevent lateral intrusion of groundwater into the sludge mass. However, if hydrogeologic conditions are not amenable to this type of development, or if economic factors are negative, the sludge may have to be removed altogether from the site (second scenario). This decision will be primarily a regulatory one and, as such, will likely be made at the Job Informational Meeting. If the first scenario is regulatorily acceptable, the economic question will remain. Therefore, the plans to be prepared for the groundwater diversion configuration will first be schematic in nature and only of such detail that costs for construction and regrading can be estimated. These estimates will be submitted to W. R. Grace staff for review. For comparison, outline estimates of sludge removal (excavation, haul, and disposal) will be provided. A final configuration df remedial site work will be selected at this point by CDM and W. R. Grace staff. Task 5. Preparation of Site Development Plans. CDM will prepare site development plans and construction details for the selected site work configuration. If the first scenario is selected, the plans will include site regrading and drainage facilities and location, sections, and details of groundwater diversion structures. The plans will be prepared primarily to meet the requirements of DEQE, but will also be configured, as practically as possible, to conform with the project design requirements of the MBTA tunnel proposal. The plans will be prepared to a level of detail for cost estimation and construction by a competent, experienced construction contractor, but will not be set-up to serve as a competitive bid-type document.

If the second configuration is selected, a sequential plan for sludge removal will be developed, along with a listing of licensed disposal sites prepared to accept the sludge to be removed from the site. CAMP DRESSER & McKEE INC. IndusI', Ennggn':M 0.osC Mr. Van T. Boughton July 27, 1979 -4-

Task 6. Cost Estimates. Total costs for the selected scenario will be estimated. If the first scenario is selected, cost estimates will include site regrading, installation of drainage facilities, placement and compaction of low-permeability cover material, seeding, and construction of groundwater diversion structures. In the case of sludge removal, costs will include excavation, haul, and ultimate disposal. In determining ultimate disposal costs, CDM shall contact potential sites, by telephone, to determine disposal fees. It will be assumed that the work shall be performed by a private contractor. Task 7. Report Preparation. CDM will prepare a report including all appropriate text, tables, maps, appendicies detailing the prepared plans, and cost estimates and will include recommendations as to site-work procedures. Additionally, the recommendations shall include implementation and maintenance of a water quality monitoring system, for the first scenario. It is highly likely that DEQE will require engineering inspection and supervision during remedial site work, especially in the case of the first scenario. CDM is available to provide these services.

We estimate that the cost for these services, including limited inspection would be $60,000. We estimate that the report could C / be completed-within150 days of our receipt of a notice to proceed. If sludge removal, is the selected site work approach, this fee may be reduced by $3,000. The completion schedule above indicates time required for delivery of the plans and report to W. R. Grace. Inspection services will be provided when construction is underway. This proposed scope of work is submitted to you as our understanding of the effort which is likely to resolve the apparent sludge disposal problem at your Cambridge site. As developed, it seeks to minimize further potential contamination of groundwater. It does not address any contamination or acidifloation of groundwater outside the immediate area of sludge disposal. Obviously, this scope is not absolute, but is negotiable (along with the attendant fee), within a broad range of services. CDM's level of effort and plan detail must meet not onlythe requirements of the regulation agencies, but also the intent of W. R. Grace. After your review of this proposal, please contact our Mr. Ira Cohen for any questions you may have, or to discuss any changes in, or additions to the proposed scope of work.

Very truly yours, CAMP DRESSER & McKEE INC.

Paul W. Prendiville Senior Vice President PWP/mk 0

0 UNIT )STATES ENVIRONMENTAL PROTE )ON AGENCY

DATE: May 12, 1981

SUBJECT: Solid Waste Disposal at W.R. Grace Cambridge Facil ty

FROM: James D. Okun, Engineer Air Compliance Section

TO: Gerald M. Levy, Acting Chief Enforcement Branch

I contacted Dr. Peter Matonis of W.R. Grace Co. for information regarding the disposal of waste material at the Cambridge Grace facility. He said there were two principle areas of waste disposal work underway at this time. Both of these involve the pelletized encapsulation of waste material in a unleachable glassy matrix by a process called Solid Teching.

The first area addressed is a filter cake material used to - filter an aqueous solution of Napthalene sulfonic acid formaldehyde co-polymer, the result of a Daxad process. Due to a 100 ppm residual napthelene in the filter cake, and some type of sludge, the. material is classified as a hazardous waste by Mass. DEQE. The ilter cake is encasulated by the Solid.Teck process and re red unleachable. DEQE has O.K.'d the resulting material for sanitar.y landfilling, this sounds reasonable. *+ 0A0tQt. The :secon srett4 ca on wher Gra e historY lumped acid washings. This has lead to a pocket of acid soil (pH=3). This soil is being treated by Grace for the MBTA (who now owns the land for a public transportation project). The resulting material is being stored on site, awaiting removal by MBTA. k

- wwA-3 %A&,4 %t. (t0. 40&'tui"7 4 EELA PAS FC*& Snn1306(ev-

T: t A~ ^9),,L1, d 0

EPA Form 1320-6 (Rev. 3-76)

.a. 0 iii :

'p 1'

Massachusetts Bay Transportation Authority Red Line Extension Northwest

STATUS REPORT ON THE MONITORING PROGRAM FOR GROUNDWATER QUALITY IN THE SLUDGE SOLIDIFICATION AREA

prepared by

Sverdrup & Parcel and Associates, Inc.

March 1983

0 TABLE OF CONTENTS

I Introduction ...... II Original Monitoring Program ...... 2 III Data Readings Obtained ...... 3 IV Current Status of Monitoring Equipment ...... V Proposal for Further Testing ...... 6 Appendix - Data Reports ...... 8

LIST OF FIGURES

Figure 1 Readings at Observation Well A2 ...... 4 Figure 2 Location of Proposed Observation Wells ...... 7

]

]I ]i ] I INTRODUCTION

The proposal for the solidification of the sludge material disposed of on W. R. Grace property and lying on the proposed alignment of the Red Line Extension Northwest was formally presented to the Cambridge Conservation Commission in a Notice of Intent, as required by the Massachusetts Wetlands Protection Act, on August 29, 1980. The proposal called for the sludge material, a waste product from W. R. Grace's manufacturing operation classified as a "special waste" by the Massachusetts Department of Environmental Quality Engineering, to be converted to an insoluable, inert material by a chemical process. The processed material would then be removed to a site outside the City of Cambridge which whould meet any requirements set by the Department of Environmental Quality Engineering. A public hearing regarding the sludge solidification program was held on September 2, 1980. The Cambridge Conservation Commission agreed with the intent of the program in principal but wished to Include some restrictions on the operation and some provisions for monitoring the long term affects of the sludge materials. These restrictions and monitoring, requirements were reflected in the Order of Conditions of October 9, 1980. Two of the conditions, number 16 and number 17, related specifically to groundwater issues. These are as follows: "16. Prior to the commencement of any work hereunder, the applicant shall develop a monitoring program, in consultation with the Water Department of the City of Cambridge, and submit to the Commission, and- the Conmission shall have approved said program, which program shall assure that the groundwater on the site, which potentially may flow from the site, will not contain any water contaminants. 17. If said monitoring as provided in paragraph 16 indicates that water, which potentially may flow from the site, will contain water contaminants, the applicant shall take such reasonable measures as the Commission may require to ensure that said water will not contain contaminants." The sludge was solidified during the spring of 1981 and the material was later removed to a sanitary landfill in Kingston., Massachusetts. Construction of the subway tunnel is currently taking place on the site under the Massachusetts Bay Transportation Authority's Construction Contract 091-508A and Construction Contract 091-601. The remainder of this report briefly describes the program which was originally proposed to meet the groundwater moitoring requirements of the Order of Conditions, subsequent developments as the program was carried out, and continuing efforts to monitor groundwater in the sludge solidification area as the construction process has taken place.

-1- II THE ORIGINAL MONITORING PROGRAM

Because of the extensive soil and groundwater analysis program carried out for the design of the tunnel by Goldberg-Zoino & Associates, geotechnical consultant for the project and the analysis of the sludge problem ,by both Goldberg-Zoino & Associates and by Haley and Aldrich, who were retained independently by W. R. Grace and Co., several monitoring locations were in existence in the general area of the sludge solidification operation. It was determined that only one additional observation well in addition to those - monitoring locations already existing would be sufficient to provide information as required in the Order of Conditions. It was realized at this time that some of the existing monitoring locations would eventually be destroyed during the construction of the tunnel across the site. Since the groundwater quality was anticipated to improve significantly when the sludge was removed, it seemed likely there would be no need to replace these monitoring locations. It had been determined in previous analyses by both Goldberg-Zoino & Asssociates, and Haley and Aldrich that the sludge materials contained large amounts of sulfates and, consequently, that the groundwater contaminated by the sludge contained relatively high degrees of sulfate ions. The degree of sulfate concentration is related to the electrical conductivity of the groundwater and it was anticipated that once this relationship was definitively- established testing for conductivity alone would be sufficient to assess the changing quality of the groundwater. The collection and testing of samples was to take place on the following schedule:

o Just prior to the removal of the sludge material to provide a base level or existing conditions measurement. o Just after complete removal of the sludge material. o Monthly for six months subsequent to the removal of the sludge material.

o Every other month for the next six months. It was anticipated that sufficient improvement in groundwater quality would be shown in the year after the removal of sludge material that no further testing would be required.

-2- 4 III DATA READINGS OBTAINED

Unfortunately, the proposed monitoring program was not able to be successfully carried -out. The construction activity associated with the sludge solidification operation destroyed most of the monitoring instrumentation and subsequent tunnel construction activity destroyed all except one of the observation wells. As a result of this unanticipated loss, continuous readings are available for only one observation well, number A2 located adjacent to Alewife Brook Parkway and the south of the tunnel. These readings are shown in Figure 1.

The readings from one location cannot be considered as representative of the entire site especially since observation well AZ is located in an area of previous high contamination. In any case, the conductivity of the samples, which is indicative'of the sulfate ion content of the groundwater, despite some intermediate fluctuations, shows no lessening from the levels measured in 1978, 1979, and 1980 prior to the removal of the sludge material.

Other readings, taken before the -sludge material. was removed, are included in the Appendix. ] 4

] I

p -3- READINGS AT OBSERVATION WELL A2

Date . Conductivity (, A MHO) At Elevation 103 (approximately 10' below ground level): 9-78 6.5 2500 9-79 .2200 9-80 6.5 2000 4-81 17000 6-81 1500 11-82 6.3 2500

At Elevation 95 (approximately 18' below ground level): 9-78 6.2 10000 . 9-79 28000 9-80 6.2 6000 4-81 3000 6-81 2500 11-82 5.4 22500

At Elevation 86 (approximately 27' below ground level): 1.1 9-78 2. 8.1 400 9-79 400 9-80 8.1 . - 600 4-81 650 6-81 300 11-82 7.3 500

0, FIGURE 1 -4- IV CURRENT STATUS OF MONITORING EQUIPMENT

Observation Well A2 is still in existence and is still available for monitoring purposes. None of the previous monitoring locations are still In existence. It was considered impractical to try to replace any of the monitoring equipment as they were destroyed since the operations that had eliminated them in the first place were still ongoing. At this - point construction has progressed for enough so that replacement of some of the observation wells and resumption of monitoring can be undertaken.

] ]

I-5 V PROPOSAL FOR FURTHER TESTING

It is recommended that three new observation wells be installed in the near future to supplement the very limited information provided by the one existing observation well. They are proposed to be located in the more average contamination areas, that is east of the sludge piles on the north and south sides of the tunnel alignment. An additional well should be located in the highly contaminated area on the north side of the tunnel opposite A-2, the existing observation well, to assess dilution of the contaminates down gradient of the tunnel. These locations are shown on Figure 2. These wells would allow an approximate evaluation to the degree of aquifer restoration via flushing. I]

-6- ~miii Sum - IN

APPENDIX Data Reports

-8- mks.

09 0

Cd 3 a'

- - I

0 a /

/ 1%~ - I' Ii / / I C. 'I I

h. C

.- .-

=S .2 'I S 0. I - '

* 'I

C"C S C

C -7-. File 1745-W-1.9-C January 14, 1981

TEST RESULTS - PARKWAY POND WATER SAMPLES

Sample Temp. Conductivity Salinity pH (C) ( mhos) (parts per thousand)

..TP #1 Parkyay Pond 18' 1650 0.5 5.25 TP #2 Parkway Pond 19* 6000 3.3 4.20 TP #3 Parkway Pond 19* 2700 1.5 3.41

Note: Water samples bailed from bottom of test pits. ] ]I ] ] U

-10-

jJ -I .e" --- - I~ - C

*- - * - - -

'---

- e...*-

~- -- II,. - ,i:4I j~--I -- -

ta. .60

- - :

---- . -III *I-- *AA

u - - **- - - -g-- -~t-T

-9- i ]

] 11

j A,6'

3 6* 9. I I

~ ill t~~U

MBTA RED LINE EXTENSION CONDUCTIVITY VEP.SUS TIME .DAVIS SOUARE TO ALEWIFE

01zx AUGUST, 1981 '7'TP.E NO. 1 /

I a..'

nEt) * -\ AI J

J £TaaM J ca

I S r - -.. ~5*~* 4. a ~ :. .~ a... .5 *~;.. A J . -. *~y,. *~-4 ..j4, -, '-C smVTU -MuTLn *~**~ ~

mWww .5'.. I I ft I-

41S I 4W

AA &?IA iu .r.

Nb "

I 5" I

S.- - - r .!.. !.'t.... x -

- -- * a

7Tr .OW d'oS at dlll~ lav mi * I" P, w

.bTIC OCfh moNs e= boa&* v~a mm~a S TICcn m. MVI- ZA n= -00 MnUM W lrMBTA RED LINE EXTENS W DAVIS SO. V ALEWiFE 7g ApfaS a Iba ar tp4 LOCATION PLAN

-11- [clrr v..zoou~sNcufra assccAur. a GEJTECGnh.CAL CONS.LTANrS ANALYTl'1 **VCEcas LASOReAYCeY .. avEnwE . .. TnS&..Mn.. 18203o ,-; -aQ-a-e -reSaO CO=~lRAON

-3 ac a olvistom* . dcles M. Amelotti 7RDRW a PARCEL a ASSOCIATES, INC. 3 North 12th boulevard . Iouis, mo 63101 30-79 .. a... 4-3-79 nam.e... 5-25-79

Test "mas rond in mglitw wns etherwise ntd,

e0s1

'040106 sw A-1-2 The following coupovmds were identified by GC/M in the sample foLlowing EPA priority pollutant protocol procedures (P) for sample preparation: % Qaucentration, - Volatile Organic Cmpotrnds ag/liter PP$ AMethylene Chloride 1300, SChlooform 60 s 1.1, 1-Trichloroethane 1 Trichloroe thylene 1 .. -Benzene '4 S . To luene Ethylbenzene 4 b 2, 2*-Thio-bis-propane 500 Freon Tr 20 2-Propanol 10 Extractable Organic Acid Compounds Phenol 32 2,4-Dimethyl Phenol 96 "Methyl Phowls" 400 "lmethyl Phenols" 1000 senzoia Acid 2000 :. thyLbenzo i Acids" 5000 *senamide and Methylbensaides" 1500 Naphthalene 250 Extractable Organic gave Neutral Compounds :apbthalene 10 Dimethyl Phthalate 20 Diocty Phthalate S bMthyl Anilines" 400 "e?4thyl Phenols" 200 "Dimethyl Phenmls" 3000 ": ethyl Senzasidars" 400

Extractable Pesticide !":mpounds :;cnm Zetected by EC w''------. -14-

- . ... .--. -- - - - *-- - anan . tmrSaumcn. PA. IsM - (SaI ss-cos "i

-0

-v

L- .

L- d. LaJ~

- L -

-V == I 9' E

46Ris I d * , 4 I i

MBTA RED T.NE- EXTENSION CoFDDCTIVITY VERSTTS TIKE 01\ DAVIS SOAP. 9O ALEWIFE I ATUST, 1981 WIMPTPE NO. 2 * 2

I I-

GROUNDWATER QUALITT DATA SUMMARIES PLATE NO. AGR-C-1 UNCASED AUGER HOLES PLATE NO. AG1-C-2 ThROUGR SINGLE-LEVEL OBSERVATION WELLS PLATE NO. AGR-C-S PLATE NO. AGR-C-6 THROUGH. MULTI-LEVEL OBSERVATION WELLS PLATE NO. AGR-C-9

-16- . .9 9. .. r~ 4 .4 . . C rj

or. Charles W. Amelotti I. ;Page 2 -b may 25, 1979

19040106 ssP A-1-2 (cont'd)

Static headspace was sampled with a 5.0-al gas-tight syringe, the syringe was connected to the purger in the usual manner and the PP procedure followed. The following compounds. were identified by GCMa 4 Concentration Headspace Volatile Organic Compounds uw/liter of air methylane Ctloride 550 Benzene 6 Tetrachloroethylene 3 2.2' -Thio-bis-propane 300 Freon Tr 15 Carbon Disulfide is

The headspace was sampled again at a later date. The sample was I run by GC/TC. There was indication that it-contained methane and formaldehyde.. However these compounds were not confirmed.

A 500-ml portion of the original sample which had been filtered- thrnugh glass w-e (pH 3.9) was serially etracted wi-:1 t.hree lC:-ml portions of methylene :hloride. The dissolved mt:.ylar.e .chloride was removed by heating on the steam bath. Ferrous iron, farric ] oxide and calcium sulfate were positively identified in the water. After removal of the iron and calcium with sodium carbonate a pale yellow solution remained.

The yellow solution was allowed to evaporate at approximately 40*C. Solids formed were removed by filtration at two different times. The infrared spectra of the solids indicated sulfonic acid (sufonate), bonded hydroxyl. imido, or aside groups, and substituted benzene rings. Nto positive identification of any compound was made.

By lowering the pH of the solution to below 1.0 the color became a purple-red.

it is suspected that the solution contained a mixture of sulfonates and water soluble "tar* acids.

-15- S S~ a II I - En II ha is U 3' *1 a~t L U a~c ('4 U 3 U 1Pft. II U a. ht a U a ac fob Ut n ~. *1i S.%a SON a I. I I' C 0 g he U a I- *1 Si S iii ma 'I Vt CA U N S C Vt Ii a a 'C I a

I -4 I U I a a S in ~n - U -f-- pa S 4 Sq U a 4 Is ,aa 0 Wh a -0 a 1q 44 a U r-6 LO U aa ma re a 8~ I P% ma LI ad a a S C a C 4 '.4 U .5 S -4 C 4 I~ x z = hi to 'I a 3 ~ = 2 2 2'' a C4 P% L a SC a U a In 0 a 4 ie ' U 3 .0 8--2

P- on lo % A - as SC. a U a, ma I -S

'I Si I. 4m\ oh oPt S ote o S a bsId a 2 SC a c. S :3 .4. a Pt Si IN a C Vt a a a 'U S I-a a 3 a in a - S 3 3 i I. a I.333 old = E = S 1 M S Umii GROUNDWATER QUALITY DATA SUMMARY

UNCASED- AUGER HOLES

Ground Water Water; water p1 Conductivity Salinity Table Table$ Date Wel T Odor (Field) AM o/cm 0 /o Dth Elev. Reark

8/28/78 A-101 17.6 None 6.1 880 0.0 3.7 108.3 8/28/78 A-102 18 None 6.0 1080 0.1 3.5 108.5 8/28/78 A-103 16.7 None - 178 0.0 3.5 110.5 8/28/78 A-104 18.2 None - 580 0.0 4.4 108.6 8/28/78 A-105 15.5 - - 2520 0.8 5.5 112.5!

8/28/78 A-106 18 Slight 5.5 850 0.1 :41 10 9.5 1 8/28/78 A-107 19 Strong 7.4 1850 0.6 ,. 110.0. 8/28/78? A-108 17 Slight 5.8 1780 0.1 4.0 110.0 18/28/78 A-109 15.8 Strong 5.3 2000 1.0 4.9 l08.1;Pals orange brown 8/28/78 A-110 19.5 Slight 6.1 3500 1.8 4.5 108.5 Palo orange brown 1 8/28/78 A-Ill 19 Mod 600 0.0 2. 109.4 'ofticoo 0 9/7/78 A-10 18 None 6.5 750 0 9/7/78 A-102 18 None 6.2 950 0 9/7/78 A-103 16.2 None 6.8 IS0 0 3.5 1083, 9/7/78 A-104 19 Slight 6.2 520 0 4 108.3 9/7/78 A-105 16.4 Slight 6.9 3000 1.5 5.7 1112.3

9/7/78 A-106 Bole collapsed - No .smple - 9/7/78 A-107 Role caved - No sample -

9/7/78 A-108 Hole caved - No sample - 9/7/78 A-109 Hole full of mud - 4.1 108.9 9/7/78 A-110 19 Slight 5.9 600 3.7 3.0 110.01 9/7/78 A-ll1 19.2 Slight 6.7 780 0.1 2.9 109.11

TABLE NO. 1745-W-1.9.4 December 20, 1978 PLATE NO. AG.-C-I -17- S f p c ho 4& t 'aa 88 j 99 .9 "'Pd a a t 9, o a0 1m I I a

mia * - || 2,i i n vi* a - C4 It en en " n f" f" 6nS W C ! 0:*

ad WO ad * ad 0 0 9 0-S 0 9 9 I; - c a U' opm I a W0 O. 92

C atl a I a a a| I * u* *.. Pz Ui a 30 Pt a a'. a a I Cd 4c C .2 cc N -4 1 4z hi m '6 -ac 4 No S

0 A a 1~ to a a~~t C I I P fIn f C I - W k W Wee II * a* a C fl '1 - 6 -nc i

S. 5 I S-O fiiI I a. I Pi ||

Pt a a S in 0 Ut So r% 9% Pt a S a o * 50 t %. Pt I -It goa 6 C Pt cc PtPt_'. -- t at Ch Pt a P -I.. U 0 Iii -6 -3 Ia cc as W go nO I- -C~ APtC Pt - * C deS S&C d Pt4 m.im -20 ga. Ii i

* S. .h. 9

CL . - U ca a on all 0; 18 ii : ww

T . SC6 .5 '91

ha I d4 (4 SM U t -u - -L, U a la soo p. * = Eat U' -Sq i, 4 a SI N S 4 C. .S p4 L- S - be p *" a I-. a 4c C a I. *e - C ii - V U ~ a C U I I-- - - I C . 3 -4 C3S C; p S

m U - I~I U a I. I 8-

Ci -1 Ema * s

I.. o . 0 %. %h 'aC C O. 0%

- I a S - V I Si St rat a * U' SI C a K - ha -3 --U a - S 4 I- mu - -U

F GROUNDWATER QUALITY DATA SUMMARY MULTI-LEVEL OBSERVATION WELL A-1

SAMPLE INVENTORY AND FIELD ANALYSIS Ground Water Ground i Salinity Conductivity pR Depth Water Date Well Color Odor */oo a hos/cm rflg) (Ft.BGS) Elev. 5/27/78 A-1-1 - Moderate 3.6 109.0 5/27/78 A-1-2 - Very Strong 3.0-5.5 - 5/27/78 A-1-3 - Slight 5.0-5.6 - 7/27/78 A-1-1 - Very Strong - 3.0 a 7/27/78 A-1-2 - Very Strong - 5.0 - 7/27/78 A-1-3 - None6.5 8/28/78 A-1-1.Orange Brown Moderate 2.2 4.200 3.3 2.8 109.8 8/28/78 A-1-2iOrange Brown Moderate 3.8 11.000 5.7 8/28/78 A-1-3 - None 0.0 620 8.2 - 9/7/78 A-1-1 Orange Brown Strong 3.0 4,850 3. 109.4 9/7/78 . A-1-2 Orange Brown strong 6.9 10,900 5.7 9/7/78 A-1-3 - I None 0.0 490 8.4 108.7 9/25/78 A-1-1 Orange Brown Strong 3.0 5,000-=50n.6-- 3.8 3.9 9/25/78 A-1-2 Orange Brown Strong 6.8 10,900 5.8 - /25/78 A-1-3 ' Very Slight 0.0 500 7.8 0/11/78 A-1-1 - - 3.4 109.2 10/17/78 A-1-1 2.8 109.8

NOTE: Sampling intervals: - _ - - . 3.3. 0. A-1-1 - 2.5' to f2.5' 3.below ground4,5 surface (Elev. 100.0 to 110.1) A-1-2 20' to 22' below ground surface (Elev. 90.6 to 92.6) A-1-3 :30' to 32' below ground surface (Eiev. 80.6 to 82.6) 0.0 620lS: - .--

LABORATORY ANALYSIS ' 0.0 5077.8 Conductivit.y ..... 2 :4,00A-1-3~ 3. ~ 20- ~ 9 56 0 -4 .8623- 09 2.8 .5'0 beoLron7ufa.(l0.100to101 5300. 50 13 509005 .0 (1)-1 All concntra n r t i0 p per milli.4 ( a(2)~blo c.0 grucolced92/7-ndyssufc5,000 (Elev/7.906t92) 3/7.- 31

T..e 1 0 PLATE N. - A-~~ ~ ~~~ABRTR ecmer2,ANALYSIS- 98PIT N.AG-

-22- -4 ra7 tf% N U C C C a a .2 U S ha - P I. S a' a * 'U - N as so U S 45. I a S a a a he -I- a a A a I go i 4 'U

I 9p p S I. C a a S ,am *1 a te a a2c .C ii 0! S hi 'I ! -V I Ut .1 7* . I .4 t - U Iii

MN Oi Gm Ca in. t~ranU 'I5' C.. H Ii C C

*4 "!I ITb n t 0004 c ac Ba.0 a asp 0 P UCg-N cU acC , 14 -0cn 9 a a a a 4- am a - - - aso' S M a e a a% am U ro Ag ;9.; w Nf -- & A

aNj OC~~i 4C tISP4 f4 S Mc 0 0 4K 0% a jop *r* ~f' I 4* a I" c hi N A at S m. in; a. fl 'Mn nvi CD PS a.U

N~~~ ~a,cc:'0--)2

C I; I,

aI a A * a1 6 Si ia a .a -a a i a U .S I a- Si 'Ii S - S - C .. a a It .0 U a a U 2

to %% -% . t% % %..t% "%bt . %. *o a 10 a4 Nm ma -0aE faa UQ C a 1. ~. -% -. '- % %% % *A- %f.: a c a ' -c 0% ac0c o c

qf C -w a a- 0% ci'O 4 4 4 4 4

flU En. I

GROUNDWATER QUALITY DATA SUMMARY MULTI-LEVEL OBSERVATION WELL A-3 7- SAMPLE INVENTORY AND FIELD ANALYSIS Ground Water Ground ,d Sality Conductivity pH Depth Water I Date well * Color Odor /oo Anhos/cm (Field) (Pt.BCS) Elev. 9/14/78 A-3-1 yellow None 0.1 1020 6.9 6.6 108.1 9/14/78 A-3-2 Pale Cray None 0.0 560 8.4 - - 9/14/78 A-3-3 Palo Gray None 0.0 580 8.5

9/25/78 A-3-1 Pal Yellow Ve" 811gbt I7.0.4 144060 6.5 7.0 107.70107.7 9/25/78 A-3-2 - None 0.0 860 - I" 9/25/78 A-3-3 Light Gray None 0.01 900 8.4 - - -d 10/11/78 A-3-1 - - - - - 6.6 108.1 10/17/78 A-3-1 - - - - 6.3 108.4

NOTE: SaMpling intervals: A-3-1 -+0 2' to 121 bole ground (Elev. 112.6) 9~ surface 102.6 to A-3-2 20.5' to 22.5' ble ground surface (Elev. 92.2 to 94.2) A-3-3 -+ 30' to 32' below ground surface (Elev. 82.7 t6 64.7)

*1~ LABORATORY ANALYSIS - d Conductivit n q Field Pial I Well Lab Lab Acidi Alkalinity Chloride Calcium Manesium Iran Sulfate

I A-3-i 1,4 40 0 6.5 - 380 133 240 14.59 6.29 302.6 S 27.96 81.1. I A-3-2850 8.2 - 236 148 16 4.86 1 A-3-3 900 8.5 389 103 14.4 0.97 36.35 17.6

NOTES: (1) All concentrations reported in parts per million. (2) Sample collected 9/25/78; analyzed 11/15/78.

TABLE NO. 1745--1.9-11 December 20, 1978 PLATE NO. AGR-C-8

-24- - I I U

a - 4.- I m ' g.. Fi aaz . - SB . *-4

- t I.' - - ...0 O0 . *8iU,- - ~ -a I , I I AIIZ -

MP -- " .h 0m "2 S - AS Is mC a . 8 *p C Si. ii K 4 4 I - 1 ". = - = Ii: a C ii: 0 ha aa 3 4 a" a e -" 4 C C 9- I 5-N CP..a. no - no I - - a PS 4 I" PS a - C S N 'a ma C o 4 am Ii C a * L.t. C E .- I - 6 S "3 'I ma ma - - of '0. a.. 'p d 4 N - ow c mw 3 a' t . W C * .0- ~ : a 9- C gig C .4 A C K C U S hi ' C C C

. a -

a '?i I i'

* ci

o g- 0

8 . ,, - Cd P I I ' I ECd ro 4*

oh Pt.C ft. La at. ~ ~ ~ at. 0 at. tfl r en - C Z -at at. at. at~ .t. -~ C a.. 0' @~ 0' a.' - .23.

S a

0 I I. GROUNDWATER QUALITY DATA S'MMARY MULTI-LEVEL OBSERVATION WELL A-4

SAMPLE INVENTORY AND FIELD ANALYSIS Ground Water Crowid Salinity Conductivity PH Depth watner Date Well 0 ColorOdr00 wso/m (il)Q BS Eev 9/14/78 A-4-1 Pale Yellow Moderate 1.0 1920 6.6 5.3 109.1 9/14/78 A-4-2 Faint Yellow Slight 0.1 970 8.0 - - 9/14/78 A-4-3 None None 0.0 8.2 - -

9/25/78 A-4-1 Pale Orange Moderate 1.0 2350 65 5.6 108.8 9/25/78 IA-4-2 None Slight 0.5 1560 79 - 9/25/78 A-4-3 none eysih 00.2 .

10/11/78 A-4-1 -5 108.9 10/17/78 jA-4-1 4.0 110.4s P.H Nodutiit 408. NOTE: Sampling interve: A-4-2 24 to 21' bel ground surface (ev. 921.2 to 194.2) A--2 )24.' to 1 ' below ground surface (6lev. 10 .3 109.) A-4-3 - 33.8' to 35.8' below ground surface (Elev. 78.6 to 80.6) S LA5ORAT0RT ANALYSIS

1018A-4-Field - Fielv -2 -- -93 -. . 0 1 10.4 . WelFLab Lab Acidit Alkalinity Chloride [Calcium IM~gu'to Sulfate

n- 39 1 66 64 25.3 '23.1

Moa e 2" 103 140 36.5 2.1 422.2 1t70igh2Z15Z7.L -

OTES: (1) All concentrations reported In parts per million. (2 3Sa3p. collected8 9/235/78; awlyed 11/15/78.

TABLE NO. 1745--1.9-12 DacAber 20, 1978 PLATE NO. AGR-C-9

.U -25- 4 0

0 S

S CITY OF CAMBRIDGE 57 INMAN STREET. CAMBRIDGE. MASSACHUSETTS 02139 . TEL 498-9048

CONSERVATION COMMISSION February 17, 1988

Mr.~Donald J. Kidston, Project Manager - Development Massachusetts Bay Transportation Authority Ten Park Plaza Boston, MA. 02116

Re: DEQE File No. 123-24 Acid Sludge Solidification

Dear Mr. Kidston:

The Cambridge Conservation Commission has reviewed the groundwater and water quality data provided by your consultants to fulfill conditions numbered 26 - 31 for DEQE File No. 123-24 (see. attachment for a copy of the original order). The Commission feels that the conditions have not been adequately complied with for the following reasons:

1) Condition no. 26(a) required that ."Surface water quality information for samples from the south side and north side of Jerry's Pond, Yates Pond (at BL-2) and Alewife Brook (BL-4V" be provided to the Commission. Copies of the water quality tests indicate that only Yates Pond and Alewife Brook were tested (see attached copy). Why was Jerry's.Pond excluded from the testing?

2) Condition no. 27 required that "All water samples shall be analyzed for sulfates and napthalene content, pH, conductivity and chlorides, using acceptable procedures". Why then was napthalene and chloride not included in the groundwater testing?

3) The following samples from the groundwater tests indicate an increase in sulfates and higher conductivity in the- last sampling round compared with the level of sulfates and conductivity in earlier sampling rounds. They are samples A1-3, A3-3, A4-3, and A11-2. What is the explanation for this? Is there a relationship between -the increased levels of sulfates and conductivity with MBTA construction activities at the time of testing? These anomalous results are particularly relevant because condition no. 31 states that "Any degradation in groundwater quality due to MBTA construction activities shall be cause for the Cambridge Conservation Commission to require remedial and mitigating action consistent with DEQE/EPA recommendations." Unless an acceptable reason to explain the results of the last round of groundwater sampling is provided to the Commission, a Certificate of Compliance can not be issued. L$'2&~e

Mr. Donald Kidston -2- February 17, 1988

The Conservation Commission looks forward to your agency's response (with a verifiable explanation) to the issues brought forth in this letter. If you have any further questions, feel free to contact me at 498-9048.

Sincerely,

Nancy Lin, Director

enclosures: Copy of Order of Conditions for DEQE File No. 123-24 Copies of MBTA's water quality and groundwater data

cc: DEQE Northeast Regional Office File 0

0 S

0 I MASSACHUSETTS BAY tcvld yo help vs TRANSPORTATION AUTHORITY

Ten Park Plaza. Boston, MA 02116

March 4, 1987

Cambridge Conservation Commission 57 Inman Street Cambridge, Massachusetts 02139

Attention: Ms. Nancy Lin

SUBJECT: DEQE No. 123-24 MBTA Contract No: EICN18 (091-601) Davis to Alewife

Dear Commissioners:

In accordance with Orders 26-29 of the above referenced Order of Conditions, transmitted herewith is a report on surface and groundwater testing on the project site. This report contains the results of the final round of testing conducted on October 5, 1984, as well as a selected summary of previous tests.

I apologize for delay is transmittal of the enclosed information. It apparently had been misplaced in transmittal from the consultants to the MBTA.

Please let me know if you would like clarification of any of the information contained in the enclosed report.

Sincerely,

Donald J.Ck idston Project Manager-Development

DJK/lan cc: W.J. St. Hilaire, P.E., DEQE GOLDBERG - ZOINO & ASSOCIATES. INC. GEOTECHNICAL-GEOHYMROLOGICAL CONSULTANTS

November 7, 1984 File No. G-1745-C G-1745-601-W-6.0

Sverdrup and Parcel & Associates, Inc. 38 Chauncey Street Boston, Massachusetts- 02111

Attention:' Mr. E.J. Perko

Re: Groundwater Monitoring MBTA Contract 091-601-Alewife

Gentlemen: .

Detailed herein are data tables and data plots for the groundwater quality monitoring wells at the above-referenced project. The sample round of October 5, 1984 represents the final set of data, per the Ammended Order of Conditions established by the Cambridge Conservation Commission.

In addition to the previously submitted data; a summary of napthalene data for wells A-1 and A-ll are presented.

It should also be noted that the following wells were replacements and were installed in the vicinity of the initial well locations. These replaced monitoring wells are identified - as A-1, A-2, A-3, and A-ll, and were installed during early July 1984. These instruments had been rendered inoperable by the general contractor's construction activities.

We are presently assessing the current groundwater flow regime in the area since completion of construction activities. Any conclusions relating to this subject will be transmitted at a later date.

THE GEO BUILOING * 320 NEEDHAM 57EE T e NEWTON UPPER FALLS MASSACHUSETTS 02164 * (A17',59-50 2 =AL2 Y*.ErJ ** 4

Sverdrup & Parcel Associates, Inc. - November 7, 1984 File No. G-1745 - Page 2

In the meantime, if you should have any questions. with respect to the enclosed data, please do not hesitate to call.

Very truly yours,

GO( B -ZOINO & 4JSOCLATtfZNC.

Geotechnical Engineer

Matthew J. Barvenik Senior.Geotechnical Engineer FMG/MJB:bjm Attachments: Groundwater Quality Data Tables Groundwater Quality Data Plots S

0n GROUNDWATER MONITORING

DATA REPORT

MBTA CONTRACT 091-601

Prepared for: Sverdrup and Parcel & Associates, Inc. Boston, Massachusetts

Prepared by: Goldberg-Zoino & Associates, Inc. Newton Upper Falls, Massachusetts

November 7, 1984 File No. G-1745 0 6a

0T 21V

GROUNDWATER QUALITY DATA TABLES

rL\ . - '...2r.jI rZ~.

v- DATE GRD.EL. A-1-1 A- I-2 A-1-? pH pH p H

5/11/3 110.0 f2.1 12.4 110.0 8.40 5.70 S. 70 11/30/83 110 .00 S. 00 6. 40 12/30/53 110.00 7.40 6.10 1 .2: 2/2/84 110.00 7.40 S.4 14/84 110.00 7.7 5.:? 8.10 10/5/34 110.00 6.S0O 5.5') 5.20 I INSTRUMENT LOCATIONS AND ELE'-T IONS A-l-i EL.102

It. A-1-2 EL.SS A - !- - E L. 75

L DATA OUTPUT TABLE 0 CONDUCTIVITY A-1

DATE GRD.EL. A-1-1 A-1-2 A-1-3 uMHO/cm uM-HO/cm uMHO/cm

5/11/S.? 110.00 6385.00 11650 .00 800 .00 ,/26/S3 110.00 410 .00 6810.00 1760 .00 1 0 /2S/S3 110.00 11/30/83 110.00 120.00 7100.00 1570 .00 12/30/3 3 110 .00 3000.00 1 70.00 2-2//B4 110 .00 250 .00 :31)0: .00 3/i 4/S4 11 0 . 0IO 430 .00 7200.00 520 .00 4 06 S4 110 .00 4SOC . 0 0 1 0/5./S4 110.0 1' 4750.00 - - -

INSTPRMENT LOCATI AND ELETI OS

I --1 EL.102Z A-1-2 EL.S '-i-3 EL.75 I

I DATA OUTPUT TAE:LE

ILFATE A-I

DATE GRD.EL. A-1-1 A-i1 -2 A-1-3 PPM. PPM. PPM.

J/11/83 110.00 71.00 1510.00 42.00 110 .00 60.00 5100.00 600 /26/83 110.00 I1I1/3D/"a 110.00 60.00 4500 .00 700.00 110.00 6 .0.IO 8200 .00 500 .00 110.00 63.00 sC00.00 2/2/S 4 (-,--73-0 0 /5/CS4 110 . 01 0 00 .00 2400.00

I NEl RLIMENT LOCATINS AtD ELE')ATIONJS

A-1-1 EL.102 A-1-2 EL.SS I A-1-3 £L.75 I I

I o D-7, 06TRUT T-,

1NFTHALENE A-1

DATE GRD.EL. A-1-2 PP2.

9/26/83 1 1 0.00 30'.00 11/30/S3 1:0 .00 0.00 12/7/83 11cr.00c 12Cr.0 S/13/.4 I130.00 55.00 110/5/84 11Cr0i)r 12:r00 INSTRUNENT LOCATI ON AND ELEYwTIONES I

Gix DATA OUTPUT TAeLE

DH A-2 I/ DATE GRD.EL. A-2-1 A-2-2 pH F'H PHi- 3.30 6.e0 15/1.1/83 110.00 110.00 10/26/83 110.*00 1 1/30/83 110 . 00 110.00 5.20 5.70 11 0.0C 5.70 570 12/34 C -0 110.00 7.00 7.10 8 4 11 0 c. 00 5.60 6.40 4i-c161/ 11 0. 00 5 .0 : 7.50 :.00

INSTRUMENT LOCATIONS AND ELEYATIONS

A-2-1 EL.S I A-2-2 EL.:5 I 9

GZ * *1* C.TA OUTPUT TALE

CONDUCTIVITY A-2.

I DATE GRD.EL. A-2-1 A-2-2 A-2-3 UMHO/cm uMHO/cm uMHO/cm

J5/11/o3S 110.00 14850 .00 7.10.00 110.00 '--- 12/30/83 110.00 2600.00 1 2/2/84 110'.00 4400.00 265.00 3/14/84 110.00 2e-s'o .bo 4450.00 1240.00 4/6/,34 267.70.00 4320 .00 4670.00i 10/5/S4 11 0 0 I 27S 0 .00 579.00~I ItSTRUMEJT L'JCMT IONS AND ELEVAT I ONS

A-2-1 EL.S A-2-2 EL.E'5 1 .1

I ria .7~ I. DATA OUTPUT TASLE

ULFATE A-2

DATE GRD.EL. A-2-1 A-2-2 A-2-3 PPM. PPM. PPM.

5/11/63~ 110.00 76.00 12/30/83 1 10.00 5000.00 2600.00 60.00 2/2/e4 1 10.00 3:B0'. 00 2000.00 e0 .00 3//84 110.00 4700.00 3300.00 30.00 4/6/S4 1 10.00 450-0.00 3600.00 100.00 10/5/S4 1 1 0 00 2200.00 600.00 110.00 I INETRUMENT LOCATIONS AND ELEVATIONS

A-2-1 EL.?S I A-2-2 EL.M5 A-2-3 EL.76

a I t S

0 GZX .1 DAT'.A OUTPUT TBLh E 0 pH A-3 j DATE GRD.EL. A-3-1 A-3-2 pH pH pH

19/26/S3 110.00 7.50 6.00 6.00 10/26/S3 1 10. 00 7.90 6.S0 I 1/20/83 110.00 7.50 S .40 6..30 12/30/84 110.00 6.70 6.,30 2/2/t 4 110 - C0 6.20 6.10 3/1 3/S4 110.00 .5'0 9.20 4/6/S4 110.00 60 6.30 10/5/S4 I .00 7.20 6.30 8.40 I INST RUMENT LOCATIONr4 S AND ELE'.'ATIONS A-3-1 EL.?5 A"-3-2 EL.84 I -3 .73 J I

I A-TA CUTPUT TALE

NDUCTIVITY A-3

DATE ARD.EL.A-3-1 A-3-2 A-3-3 uMHO/cm uMHO/cm uMH/ cm

110.00 715.00 1675.00 1060 .00 19/26/83 110.00 F?0 .00 1270.00 ?80 .00 110.00 600.00 1650.00 I 10 C'.. 0') S12/30/83 110.00 500.00 2400.00 110.00 450.00 230.00 2/2/84 110.00 110.00 770.00 199o .'0o 4/6/s4 11 0 .0 805.00 1926.00 10 5S/4 110.00 14S6.00 1612.00 I INETR'UMENT LOCATIONS AND ELE'.ATIONS A-3-1 EL.95 A-3-2 EL.S4 I A-3-3 EL.73 I 4 II I I 1

I z DAT.-' OUTPUT TALE

SULFATE A-3 I DATE GRD.EL. A-3-1 A-3-2 A-S-3 PPM. PPM. PPM. J9/26/83 110.00 30.00 140.00 10.00 10/26/83 110.00 60.00 130.00 55. CC 11/30/83 110.00 55.00 180.00 12/30/83 110.00 100.00 250.00 2/Z/84 110.00 100.00 250.00 .00~I 3/13/84 110.00 130.00 80.00 4/6/S4 11 0 .000 110.00 90.00 10/5/84 110C'.0ci 80.00 120.00 *1 INSTRUMENT LOCATIONS ;ND ELE.TIONS A-3-1 EL.M5 -3-2 EL.S4 I A-3-3 EL.73

cia 'ci :.TA OUTPUT TABLE

DATE GRD.EL. A-4-1 A-4-2 A-4-3 I pH pH pH

110.00 6.50 6.50 7.10 110.00 6.20 6.10 6.6o 10/26/3 110.00 7.10 6.70 7.10 --- . I1l1/30/83 110.00 105/84 110.00 8.20 6.30 7.30

INSTRUMENT LOCAT ioN AND ELE.wTIONS

)I o-4-1 EL.99 A-4-2 EL.91 A-4-3 EL.73 i I 9 I

Got\ DATA OUTPUT TAE:-E

CDc;TIi.TY A-4

DATE GRD.EL. A-4-1 -A-4-2 UMHO/cm uMHO/cmn U 5m

k/11/s 3 110.00 1400.0 720 .00 650.00 110.00 1190.00 6220 .00 .300 .uu 9/2A/C34 110.00 1260.00. 6:30 .00 445.00 110 .00 11 0.00 E47.00 1249.0 103- I1 INSTRUMENT LOCATIONS AN-lD ELE'VwTI JNf

A-4-2 EL. 9*1 A-4-3 EL.7

I I I

I oin DATA OUTPUT TABLE

SULFATE A-4

DATE GRD. EL. A-4-1 A-4-2 A-4-3 PPM. PPM. PPM.

5/11/e3 110.00 485.00 4000.00 2.00 9/26/83 110.00 570.00 6200.00 55.00 10/26/83 110.00 490.00 6300.00 25.00 11/30/83 1 10.00 10/5/84 1 10.00 330.00 500.00 290.00 I INSTRUMENT LOCATIONS AND ELEVATIONS A-4-1 EL.?? *1 A-4-2 EL.91 A-4-3 EL.73 I I

9 ton -V

DATA OUTPUT TABLE

pH OiA-4

DATE GRD.EL. OW-4-1 OW-4-2 OW-4-3 pH pH pH

110.00 5.50 6.20 20 1 10 . 0 6.90 7.20 7.00 11/30/63 110.00 6.50 6.40 6., 12/3i05/B34 110.00 6.70 6.40 110.00 6.90 110.00 6S.60 10//, 4 : 110 . 00 7.00 6.50 6.70 110 .00 5.00 6.10

NE ,MEN L:CI ATION AND ELEY&wT10NS*J3

-1 OW-4-1 EL .97 06W-4-2 EL.87 W-4-3S EL.75

rjzS

± *1- DATA OUTPUT TAELE

ONDUCTIVITY OW-4

DATE GRD.EL. OW-4-1 OW-4-2 OW-4-3 bMHO/cm -uMHO/cm uMHO/cm

9/$26/S3 110.00 845.00 5sa.00 500.00 1 0/26/3 110.00 745.00 530.00 S?90.00 1 1/30/S3S 110.00 600.00 650.00 470.00 I12,/30/' 3 110.00 220.00 380.00 -0 2/2/84 110.00 39,0.00 380.00 500.00 3/13/S4 110.00 270.00 590.00 ---~o 4/6 84 110.00 260.00 70.00 10/5/S4 110.00 315.00 613.00 I INSTPUMENT LOCATIONS AND ELE-T IONS OW-4-1 EL.97 OW-4-2 EL.S7 i OW-4-3 EL.75. I 4 Ia

Ijz 1" DATA OUTPUT TASLE

SULFATE OW-4

DATE GRD .EL. OW-4-1 OW-4-2 QW-4-3 PPrMi. PPM. PPM.

26/s3 110 .00 406.00 110.00 54.6.0 10/26/83 110 .00 100.00 110.00 85.00 11/20/S3 110 .00 ISO.00 200.00 180.00 12/30/83 110 .00 120.00 110.00 2/2/34 110 .00 190.00 120.00 160.00 3/12/84 110 .00 150 .00 140 .00 4/6/54 110 .00 190.00 210 .00 150.00 10/5/14 110 .00 10 0 . 00 122.010- -I INSTRUMENT LOCATIONS AND ELEVATIONS

0I-4-1 EL.?? O!-4-2 EL.87 QW-4-3 EL.75

I 0Zx t ~1* SATA OUTPUT TAE:LE

pH A-7

"ATE GRD.EL. A-7-1 A-7-2 A-7-3 pH pH pH

15/11 /93 110.00 6.70 5.40 1/26/83 110.03 5C SO 10/26/83 110.00 6.30 5.40 11/30/s3 110 .00 6.30 5.80 12/30/83 110.00 6.50 6.30 6.80 110.00 6.50 6.20 /I ":I':/QS4 110 .00 10.00 4/6'/74 110.00 6.50 6.40 590 10/-,5/---4 il0.00 7 .3S0 6. 30 5.50

I-ISTRUMENT LOCATIONS AND ELEVATIONS

A-7-1 EL.102 I A-7-2 EL.S9 A-7-3 EL.73 I

1 ?on - DATA OUTPUT TASLE A

pH A-8

DATE GRD.EL. A-S-1 A-S-2 A-S-3 pH pH pH

110.00 6.20 6.40 10/26/M3 110.00 7.00 7.00 11/30/33 110.00 6.70 6.90 12/30/83 110.00 6.90 7.00 I2/2/84 110.00 6.50 6.40 3/13/34 110.00 10.20. 10.60 416/S4 110 . 00 6.60 6.60 6.70

INSTPUMENT LOCATIONS AND ELEVATIONS

I A-S-1 EL.93 A-S-2 EL.90 I 4-8-3 EL.75 I I I t I

0 & -S CtL\ .1 5QTA OUTPUT TABLE

*OUNDUCT1I.TY A-S

DATE GRD.EL. A-S-1 A-S-2 A-S-s I1 uMHO/cm uMHO/cm uMHO/cm

110.00 675.00 600.00 1025.00 10/26/S3 110.00 7s0.00 705.00 1060.00 11/30/83 110. . 00 550 .00 550 .00 600 . 00 12/30/S3 110.00 800.00 500.00 S00.00 2/2/84 110.00 500.00 700 .00 110.00 770.00 1060.00 $16-/4S 110.00 ??5.00 760.00 9S5.00 N TRUMENT LOCATIONS AND ELEVATION:43

*1~ A-S-1 EL.?8 A-S-2 EL.? i A-S-S EL. 75 I 0

GS\ ,1I DATA OUTPUT TAKE

SULFATE A-a

I DATE GRD.EL. A-B-1 A-8-2 A-e-3 PPM. PPM. PPM.

126/W3 110.00 210.00 240.00 360.00 10/26/23 110.00 210.00 250.00 310 -00 11/30/83 110.00 190.00 ISO.00 220.00 12/30/83 110.00 620.00 250.00 380.00 110.00 --- 100.00 180.00 3/13/84 110.00 1?0.00 210.00 110.00 200.00o 150.00 44 IsC.00 INSTRUMENT LOCATIONS AND ELE'VATIONS

EL.98 .90o .1 I I 0 I

Al I CVL\ 0