'V 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.