NO 'C a t j sOle C ONWEALTH OF MASSACHUSETT EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION Metropolitan Boston - Northeast Regional Office

ARGEO PAUL CELLUCCI Governor TRUDY COXE Secretary

DAVID B. STRUHS Commissioner

October 30, 1998

Dr. Sandra Korrick RE: Air Data Channing Laboratory RTN 3-0277 W. R. Grace and MBTA Brigham & Women's Hospital 181 Longwood Avenue Boston, MA 02115

Dear Dr. Korrick:

Pursuant to our telephone conversation of October 5, 1998, please find enclosed the materials which you requested. Included is air sampling data and a risk characterization related to air in the MBTA Alewife Station tunnel, and ambient air monitoring data for the adjacent W. R. Grace site in Cambridge.

If I can provide additional information which might benefit your investigation, please contact me at (978) 661-7730.

VeYtruly yours,

triciaM. Donahue Chief, Audit Section Bureau of Waste Site Cleanup

cc: Data Entry/Files

This information is available in alternate format by calling our ADA Coordinator at (617) 574-6872.

205a Lowell St. Wilmington, MA 01887 @Phone (978) 661-7600 * Fax (978) 661-7615 * TDD # (978) 661-7679

1) Printed on Recycled Paper t -it 43or

MBTA ALEWIFE STATION HEALTH RISK CHARACTERIZATION STUDY

DRAFT FINAL

April 1992

prepared for

Massachusetts Bay Transportation Authority Boston. Massachusetts

prepared by

Stone & Webster Civil and Transportation Services. Inc. Boston. Massachusetts Arfher 0. LMie. Inc ;:fl Part - ~.r' r-eve. Mass:

-:e ~ :c e ' 5 ~- Sepremherj11, 1990

Mn Ravnad Apkariza Facibne En.neering Manager Massacnuseas Bay Transpornuun Ad'arity Baiding #2 '1 Arlinga Avenue Chariestown, MA 02129

Re: 64891

Dear Rav-

En response w the rcuesr of tie MBTA Gxneral Manager. Thomas Gen. .ta D. Lric, - - Inc.. is alesed to subtr the foUowing inrem reort of our oingOu enrronmeMi oacr wMestganon a: AewWin Saion. Program Status To dar, the Athur D. Lie project team has coipleted five odor survevs ar Alewife Stot The wre couductd on Apii 2, April 5, April 24. May 25 and July L. 1990 diring both nora1 operating hors and off-hoam Samples of air and war we cancnred dnring several of thee sr-veys and remmed to ou labormones for both scensry and - - chariel analysis. A smmnary of samples collected and me pi-pose or which they were colected is provided as Table 1. As a rzesit of these efforts, we have: (1) charctetized the types of odors present -Eini the Station Comle- (2) associated a subsr of these odors with dhe workers' - .- desmpdons of complint odors; (3) identified isopropyl sulfide as the pacipal oarooond assomed with the "crpLait odorz nd (4) deerined that his cxocand is present in both the waer inflranng the anoe wall and that conmined in the mnnel drainage system. Subsequent rddirinnal efforn andertaken at your request have icludad the following:.

- The coilecion and analysis of the tap water from the employee lunch --c to help the MBTA kddress the Cnen's Union's coner regrting possible contminadon of the staon's poable water supply.

- A compur-idni serh of the chemical limrat reports about the propctas, cccaurce and halth effects of isopropyl sulfide to determine wheter or cot this compond, by iself, reprmes a potad ttat to the health of the MBTA cmployces and ridexs

- A nrg was held ax Arthur D. Lnit on May 30, 1990 to discuss our progress inrrim ndimngs and progrm direno This rrding was requested by the MBTA on behalf of the Commonwealth of Masmchnsem, Deparunent of Labor & ndnties, Division of Occupaional Hygine, Mr. Joel Weddig. an Industial Ju -2 / -9 3: 21 P UorcionA I r-Jua i I ty buLA o/U Iz.)a

GORDON AIR QI JALrTY CONSULTANTS, INC. P.O. Box 5239 - 6 Minton Road Billerica, Massachusetts 01821-5239 Tel (978) 663-9213* Fax (978) 670-1332

December 17, 1997 Project No. Boston Carmen-01 Mr. Frank Madden Boston Carmen's Union Local Division 589 295 Devonshire Street Boston, MA 02110

Dear Mr. Madden:

On November 19, 1997, representatives of Gordon Air Quality Consultants, Inc. performed a series of air, water and sludge tests in selected locations of the MBTA/Alewife subway. Co- located testing was performed alongside with Rizzo Associates who are the MBTA industrial hygiene representatives.

The purpose of the testing was to determine the presence and the concentrations of a list of target compounds in the air, the water and the sludge.

The following sections of this report outline the scope of work, the methodologies used to sample and analyze the air, water and sludge and presents the results of the tests along with our comments and general recommendations.

I. scope Of Work

The scope of work was well defined. Specifically it involved performing the following tasks:

1. Test the air in 2 locations to determine the presence and concentration of the following compounds:

Acetone Benzene Chloroform Ethyl acetate Hydrogen sulfide Methylethyl ketone Naphthalene Trans,1,2-dichloroethylene Trichloroethylene Toluene Vinyl chloride

I- -- --a.-:.7

Massachusetts Bay Transportation Authority

SAFETY DEPARTMENT 21 ARLINGTON A VENUE BUILDING 2 CHARLESTOWN, MA 02129 FAX #617-222-5127 FACSIMILE TRANSMITTAL

TO: AI T bMi Ht-u:

COMPANY/DEPARTMENT: -be--P/ 6 kJ Q

FAX PHONE: 0c7y ) WC 7 6S

FROM: F I CY y,ke13mzO

TELEPHONE #: (K n-) 2ZU- S 'K / .C - \

COMMENTS: IwY~ SVqGLQy

PAGE / OF L DA TE: /

T Y~tqr~o~c Q,-. rrr7rr,? J,,r '-' To P,r W-2..t Ptrtn fnS 7t9C_ 7J juN ItM

DEP/NC;THEAST v2 GION WWUYIURN, MASS.

RESULTS OF THE AMBIENT AIR SAMPLING AT THE ALEWIFE PROPERTY

Prepared for W. R. GRACE & COMPANY CAMBRIDGE, MASSACHUSETTS

TRC Project No. 3816-F31-00

Prepared by:

Richard T. DeCesar, Ph.D.

Walter A. Klinger Project Manager

Eric A. Pearson Senior Consulting Engineer

February 1988 TC Environmental Consultants

800 Connecticut Boulevard East Hartford, CT 06108 (203) 289-8631

A TX Company I

DEP/NORTHEAST VEGIY WOSURN, MASS,

AMBIENT MONITORING AT W.R. GRACE ALEWIFE PROPERTY

Prepared For:

Haley & Aldrich, Inc. 58 Charles Street Cambridge, MA 02141

Prepared By:

Samuel Cha Project Manager

Greg Taylor Field Engineer

TRC Project No. 5248-C31

TC February 1, 1989 Environmental Consultants

800 Connecticut Boulevard East Hartford, CT 06108 (203) 289-8631

A TX Company 3u1-'27-98 03:23P GordonAirQuali ty 508 670 1332 P. 01

11 1

gORDON AIR QUAUTY CONSULTANTS, INC PO. Box 5239 - 6 Minton Road Billerica, Massachusetts 01821-5239 Tel. (978) 663-9213 - Fax (978) 670-1332

FAX C O V E R S H E E T

DATE: MONDAY, 7127/98 TIME: TO: Pat Donahue PHONE: DEP/BWSC FAX: (978) 661-7615 FROM: David Gordon PHONE: (978) 663-9213 GAQCI FAX: (978) 670-1332 RE: REPORT

Number of pages including cover sheet: 16

Message

Dear Pat:

Attached, please find the report from November 19, 1997 tests performed by Gordon Air Quality Consultants.

Should you have any questions, please contact me.

Very truly yours,

David Gordon P.E., ClH. QEP *Jul-27-98 03:23P GorconAirfQuality 508 670 1332 P.02

GOR DON AIR QUALITY CONSULTANTS, INC. P.O. Box 5239' 6 Minton Road Billerica, Massachusetts 01821-5239 Tel (978) 663-9213 - Fax (978) 670-1332

December 17, 1997 Project No. Boston Carmen-01 Mr. Frank Madden Boston Carmen's Union Local Division 589 295 Devonshire Street Boston, MA 02110

Dear Mr. Madden:

On November 19, 1997, representatives of Gordon Air Quality Consultants, Inc. performed a series of air, water and sludge tests in selected locations of the MBTA/Alewife subway. Co- located testing was performed alongside with Rizzo Associates who are the MBTA industrial hygiene representatives.

The purpose of the testing was to determine the presence and the concentrations of a list of target compounds in the air, the water and the sludge.

The following sections of this report outline the scope of work, the methodologies used to sample and analyze the air, water and sludge and presents the results of the tests along with our comments and general recommendations.

I. scope of Work

The scope of work was well defined. Specifically it involved performing the following tasks:

1. Test the air in 2 locations to determine the presence and concentration of the following compounds:

Acetone Benzene Chloroform Ethyl acetate Hydrogen sulijde Methylethyl ketone Naphthalene Trans,1,2-dichloroethylene Trichloroethylene Toluene Vinyl chloride

1 ul-2'-98 03:23P GordonAir-Quality 508 670 1332 P.03

2. Take 2 water samples and analyze the samples for the following target list:

Acetone Benzene Chloroform Ethyl acetate Total Sulf ides Methylethyl ketone Naphthalene Trans,1,2-dichloroethylene Trichloroethylene Toluene vinyl chloride

3. Take 3 sludge samples and analyze the samples for the following target list:

Acetone Benzene Chloroform Ethyl acetate Total Sulfides Methylethyl ketone Naphthalene Trans,1,2-dichloroethylene Trichloroethylene Toluene Vinyl chloride

4. Take swab samples from selected surfaces inside the tunnel to determine the presence and identity of microorganisms.

In addition to the target listed compounds, we asked the laboratories performing the analyses to identify and quantify all of the organic compounds present in the samples.

Also, we were authorized to take swab samples from selected locations to determine the presence and identity of mold.

II. Methodology

i. Airborne Volatile organic compound (VOC) Identification and Quantification

The identity and concentration of airborne Volatile Organic Compounds (TVOCs) was determined by drawing a sample of the air to be tested through a tube filled with a specially purified tri-matrix media which efficiently collects VOCs. The samples were thermally desorbed into a gas chromatograph which separates the compounds and 2 GORDON A IR QUALITY CONSULTA NTS, INC, *Jul-E7r-98 03:24P GordonAirQuality 508 670 1332 P.04

passes them Into a mass spectrograph which breaks down the VOCs into their individual components. The data is analyzed by a computer program which identifies the compounds. The chromatographic data is then used to determine how much of each compound is present. The samples were analyzed by ESA Laboratories, an AIHA and EPA accredited laboratory.

2. Airborne Hydrogen Sulfide

The presence and concentration of hydrogen sulfide was determined by drawing a sample of air through a glass tube filled with a specially treated charcoal media. The samples were capped and taken to ESA in Chelmsford, Massachusetts for analysis.

3. Surface Microorganisms

Swab samples were taken in selected locations throughout the tunnel to determine the presence and identity of surface fungi. The spores were transferred from the swab to a culture plate. Sabouraud-Dextrose (SD) agar was used to promote the fungi growth. The plates were incubated and the colonies grown, identified and counted.

4. Waterborne Organic compound Identification and Quantification

water samples were taken from the water running under the tunnel by lowering a specially prepared glass bottle into the flowing water stream. The samples were transported to AEN, an EPA Certified laboratory for analysis of the targeted organic compounds using EPA Method 8260a. The data was analyzed by a computer program which identifies the compounds.

5. Organic Compound Identification and Quantification in Sludge Samples

Sludge samples were taken from selected locations in the tunnel. The samples were transported to AEN, an EPA Certified laboratory for analysis of the targeted organic compounds using mass spectroscopy. EPA Method 8260B was used for the analyses.

6. Waterborne Total Sulfide Concentration

Water samples were taken from the water running under the tunnel by lowering a specially prepared glass bottle into the flowing water stream. The samples were transported to AEN, an EPA Certified laboratory for analysis of Total Sulfides.

3 (IORL)N AIR QUALITY CONS UTANTS, INC -Jul-27i-98 03:24P GordonAirQuality 508 670 1332 P.0s 00

7. Total Sulfide Concentration in Sludge Samples

Sludge samples were taken from selected locations in the tunnel and stored in appropriate glass containers. The samples were transported to AEN, an EPA Certified laboratory for analysis of Total Sulfides.

III. Results

1. Target Airborne organic Compound Test Results

Table 1 presents the results of the VOC testing performed to determine the presence and concentration of targeted organic compounds.

TABLE 1 Airborne Targeted Volatile Organic Compound Identity and Concentration

Sample Compound Concentration Location Identification micrograms per cubic meter

325 Acetone 11.0 Benzene 10.1 Chloroform 0.1 Ethyl acetate 0.5 Methylethyl ketone 4.4 Naphthalene 31.0 Trans,1,2-dichloroethylene 0.2 Trichloroethylene 6.3 Toluene 24.5 Vinyl chloride 0.2

330 Acetone 19.7 Benzene 7.5 Chloroform 0.3 Ethyl acetate 1.0 Methylethyl ketone 11.0 Naphthalene 16.6 Trans,1,2-dichloroethylene 0.5 Trichloroethylene 4.1 Toluene 25.2 Vinyl chloride 0.7

2. Comprehensive Analysis of Airborne organic Compounds

Table 2 presents the results of the comprehensive VOC testing performed to determine the presence and concentration of airborne organic compounds.

4 (;)R[X.)N AIR QUALITY CONSUITANTS, INC, S -Ju]-27-_9803:24P GordonA-rqua1ity 508 -- .... 670 1332 P.06 S

TASLE 2 and organta Compound IdentitY All Airborne VolatilS CoCcnrtraattion tamp compound n Location Identification micrograms per

Site 325 benzene 10.1 1,4-dichlorobenzene 0.5 ethyl benzene 4.7 isopropyl benzene 0.5 (p)-isopropyltoluene 0.3 t naphthalene 31.0 (n)-propylbenzene 1.2 styrene 1.3 toluene 24.8 1,2,4-trimethylbenzene 6.9 1,3,5-trimethylbenzene 2.3 m/p-xylene 15.5 o-xylene 5.7 bromomethane 0.4 t carbontetrachloride 0.9 chloromethane 4.9 * (t)-1,2-dichloroethylene 0.2 x methylenechloride 3.9 x tetrachloroethylene 3.2 x 1,1,1-trichloroethane 1.0 x trichloroethylene 6.3 Y trichlorofluoromethane 1.6 x vinylchloride 0.2 x acetone 11.0 x methylethylketone 4.4 X dichlorofluoromethane 8.0 r-pentane 31.2 x 1,1,2-trichloro-1,2,2- trifluoro ethane 1.6 ethanol trace 2-propanol 4.8 MTBE 38.0 cyclohexane 4.2 x chlorodiflucromethane 0.7 ) 1-chloro-2-fluoroethene 0.3 2-methyl-1-propene 2.0 Unidentified compound 2.5 1,3-butadiene 0.5 unidentified compound 1.0 1-butene 0.7 1,1-dimethylcyclopropane 0,6 2-methylbutane 26.3 ethylcyclopropane 0.8 2-pentene 3.4 x dichlorofluoroethane 2.3 2-methyl-2-butene 3.5 5 GORDON AIR QUALITY CONSI JLTANTS, INC Jul-27-98 03:24P GordonAirquality 508 670 1332 P.07

(Table 2 continued)

2,2-dimethylbutane 2.0 1,1,2-trichloro-1,2,2- trifluoro ethane 2.3 2,3-dimethylbutane 3.5 2-methylpentane 16.9 2,3-dimethyl-1-butene 1,4 3-methylpentane 9.4 2-methyl-1-pentene 2.0 hexane 9.0 3-hexene 2.9 2,3-dimethyl-2-butene 1.1 3-methyl-2-pentane 0.7 methylcyclopentane 8.5 1-ethyl-1-methyl-cyclopentane 1.3 X ethylacetate 0.5 1-methylcyclopentane 1.9 2-methylhexane 7.7 2,3-dimethylpentane 6.7 3-methylhexane 7.2 2,2,4-trimethylpentane 17.8 2-methoxy-2-methylbutane 6.0 heptane 6.4 methylcyclohexane 4.9 2,5-dimethylhexane 2.3 2,4-dimethylhexane 3.3 ethylcyclopentane 1.4 1,2,4-trimethylcyclopentane 1.4 2,3,4-trimethylpentane 6.1 2,3,3-trimethylpentane 5.2 4-methylheptane 2.7 2-methylheptane 5.8 3-methylheptane 5.5 1,3-dimethylcyclohexane 3.0 1-ethyl-3-methylcyclopentane 1.1 octane 4.3 1,3-dimethylcyclohexane 1.3 2,6-dimethylheptane 1.4 unidentified compound 2.5 X acetic acid, butyl ester 2.6 1,2,4-trimethylcyclohexane 2.0 2-methyloctane 3.9 3-methyloctane 2.3 nonane 8.1 1-ethyl-3-methylcyclohexane 3.0 3-methylnonane 3.4 unidentified compound 4.2 K a-pinene 5.9 2-methylnonane 7.1 unidentified compound 5.3 1-ethyl-3-methylbenzene 14.0 decane 12.6 1-ethyl-2-methylbenzene 5.9 6 GORDON AIR QUALITY CONSUITANTS, INC. *ul-2-7.-98 03:24P GordonAirQuality 508 6 70 1332 P-08

(Table 2 continued)

1-ethenyl-3-methylbenzene 2.4 unidentified compound 3.7 d-limonene 4.4 1,2,3-trimethylbenzene 5.4 3,4-dimethyldecane 5.4 2-propenylbenzene 2._7 1,3-diethylbenzene 2.9 2-ethyl-1,4-dimethylbenzene 2.8 indane 1.4 tndecane 9.2 4-ethyl-1,2-dimethylbenzene 4.7 2-ethyl-1,3-dimethylbenzene 2.8 unidentified compound 0.9 1,, 3,4-tetramethylbenzene 1.0 1,2,3,5-tetramethylbenzene 1.9 3-methyl-5-propylnonane 2.0 2,3-dihydro-4-methyl-1H-indene 0.6 unidentified compound 2.1 dodecane 1.7 unidentified compound 0.8 1,2,3,4-tetrahydro-l- methylnaphthalene 0.7 ethyl-1,2,4-trimethylbenzene 0.9 benzothiophene 1.2 unidentified compound 0.7 tridecane 0.4 2,3-dihydro-4,7-dimethyl- 1H-indene 0.4 unidentified compound 0.3 2-methylnaphthalene 10.7 1-methylnaphthalene 6.1 biphenyl 2.2 1-ethylnaphthalene 1.5 2,6-dimethylnaphthalene 0.9 1,2-dimethylnaphthalene 0.6 2,3-dimethylnaphthalene 0.6 1,3-dimethylnaphthalene 0.3 acenaphthalene 3.2 dibenzofuran 0,7 fluorene Total 612.9

Site 330 benzene 7.1 1,4-dichlorobenzene 0.7 ethyl benzene 4.1 isopropyl benzene 0.7 (p)-isopropyltoluene 1.5 naphthalene 15.7 (n)-propylbenzene 0.9 styrene 1.0 toluene 23.7 1,2,4-trimethylbenzene 4.8 7 GORDON AIR QUALITY CONSULTANTS, INC, *Jul -2-7-98 03:25P GordonAirrQuality 508 670 1332 P.09

(Table 2 continued)

1,3,5-trimethylbenzene 1.5 m/p-xylene 13.5 o-xylene 4.6 bromomethane 1.3 carbontetrachloride 1.2 chloromethane 21.3 (t)-1,2-dichloroethylene 0.5 methylenechloride 2.8 tetrachloroethylene 2.8 1,1,1-trichloroethane 1.1 trichloroethylene 3.9 trichlorofluoromethane 2.4 vinylchloride 0.7 acetone 18.6 methylethylketone 10.3 dichlorofluoromethane 15.2 n-pentane 20.3 1,1,2-trichloro-1,2,2- trifluoro ethane 2.1 ethanol 51.0 2-propanol 7.2 MTBE 21.0 cyclohexane 3.8 chlorodifluoromethane 1.8 unidentified compound 3.4 unidentified compound 0.4 2-methylbutane 17.3 2-pentene 1.3 2-methyl-2-butene 1.4 dimethoxymethane 5.2 2,3-dimethylbutane 4.0 2-methylpentane 17.2 3-methylpentane 11.2 hexane 8.9 methylcyclopentane 6.0 ethylacetate 1.0 unidentified compound 0.9 1-methylcyclopentane 1.9 2-methylhexene 5.5 2,3-dimethylpentane 4.9 3-methylhexane 5,7 2,2,4-trimethylpentane 12.0 2-methoxy-2-methylbutane 4.2 heptane 5.0 methylcyclohexane 4.3 2,5-dimethylhexane 2.2 2,4-dimethylhexane 2.5 unidentified compound 1.2 2,3,4-trimethylpentane 4.6 2,3,3-trimethylpentane 3.5 4-methylheptane 2.0 2-methylheptane 4.3 8 GOklX)N AIR QUALITY (ONSUITANTS, INC. aJul-2.7-98S 03:25P GordonAirQuality 508 670 1332 P-10

(Table 2 continued)

3-methylheptane 3.8 1,3-dimethylcyclohexane 1.6 octane 2.9 diisopropyl sulfide 2.5 unidentified compound 0.7 unidentified compound 2.1 3-nonene 1.4 1,2,3-trimethylcyclohexane 1.2 2-methyloctane 3.3 3-methyloctane 1.6 nonane 5.5 3-methylnonane 1.8 unidentified compound 2.6 a-pinene 2.7 2,5,6-trimethyloctane 12.6 2,2-dimethyloctane 2.B i-ethyl-3-methylbenzene 11.0 decane 13.0 i-ethyl-2-methylbenzene 3.8 a-methylstyrene 36.0 unidentified compound 5.1 pentamethylheptane 14.9 2,2-dimethyldecane 8.3 6-ethyl-2-methyloctane 45.9 1,2,3-trimethylbenzene 3.4 3-methyldodecane 6.2 2,6,7-trimethyldecane 33.0 2,9-dimethylundecane 21.9 unidentified compound 15.8 pentylcyclopropane 47.0 unidentified compound 7.6 3-methyldecane 8.6 2,4-dimethyldecane 8.6 4-ethyl-1,2-dimetbylbenzene 8.0 1-ethyl-3,5-dimethylbenzene 2.7 acetophenone 13.0 3-methyl-5-propylnonene 2.6 2,3-dihydro-4-methyl-1H-indene 1.2 dodecane 1.0 unidentified compound 0.8 benzothiophene 1.1 unidentified compound 0,3 2-methylnaphthalene 0.4 1-methylnaphthalene 0.4 unidentified compound 0.4 Total 782.2

3. Airborne Hydrogen Bulfide Test Results

The concentrations of hydrogen sulfide were all below 2 micrograms per cubic meter which is the limit of detectability of the method. 9 (GOR[DON AIR QUAITY CONS!.) TANTS, INC. u -2'7.- 98 03: 27 P GorcionA i rQua l i ty 508 670 1332 P -01

4. Sludge Sample Test Results

Table 3 presents the results of the sludge testing for the presence of organic compounds.

Table 3 Organic Compound Analyses of sludge Samples

Sample Location Compound Concentration micrograms/kilogram (dry)

Site 325 Acetone <3,600 Benzene < 180 Chloroform < 180 Ethyl acetate <1,800 Methylethyl ketone <3,600 Naphthalene <1,800 Trans,1,2-dichlorcethylene < 180 Trichloroethylene < 18O Toluene < 180 Vinyl chloride < 360

Site 308 Acetone < 380 Benzene < 19 Chloroform < 19 Ethyl acetate < 190 Methylethyl ketone < 380 Naphthalene < 190 Trans,1,2-dichloroethylene < 19 Trichloroethylene < 19 Toluene < 19 Vinyl chloride < 38

Site 330 Acetone <2,500 Benzene < 125 Chloroform < 125 Ethyl acetate <1,250 Methylethyl ketone <2,500 Naphthalene <1,250 Trans,1,2-dichloroethylene < 125 Trichloroethylene < 125 Toluene < 125 Vinyl chloride < 250

5. Water Sample Teat Reaults

Table 4 presents the results of the water testing for the presence of organic compounds.

10 GORDON AIR QUAlITY CONSUlTANTS, INC. Ju1--'7- 98 03:27P GordonAirQuality SO8 670 1332 P. 02

Table 4 Organic Compound Analyses of Water Samples

Sample Location Compound Concentration micrograms/liter*

Site 325 Acetone <20 Benzene < 1 Chloroform < 1 Ethyl acetate <10 Methylethyl ketone <20 Naphthalene <10 Trans,1,2-dichloroethylene < 1 Trichloroethylene < 1 Toluene < 1 vinyl chloride < 2

Site 330 Acetone <20 Benzene < I Chloroform < 1 Ethyl acetate <10 Methylethyl ketone <20 Naphthalene <10 Trans,1,2-dichloroethylene < 1 Trichloroethylene < 1 Toluene < 1 Vinyl chloride < 2

All samples were below quantitative limits for the targeted compounds.

6. Water Sample Test Results for Total Sulfides

Table 5 presents the results of the total sulfide analyses of the water samples.

Table 5 Water Sample Test Results for Total Sulfides

Sample Location Concentration micrograms/ liter

Site 325 <1 Site 330 <1

11 CORDON AIR QUALITY CONSULTANTS, INC -Jul-C7-98 03:28P GordonAirQuality 508 670 1332 P 04

IV. DiscusSion of Results

1. Airborne volatile organic Compounds (VOCs)

The original scope of work as defined in the Rizzo proposal included sampling the air for 9 selected VOCs.

The results indicated an unusually high concentration of naphthalene. This compound is not normally found in the atmosphere in the concentrations reported in Tables 1 and 2. The source of the naphthalene should be located.

Toluene is normally found in the atmosphere in concentrations which were measured.

Acetone and methylethylketone are commonly found in the atmosphere- However, the concentrations that were measured were well above those that are normally found. Besides being used as solvents, these compounds can be formed as a byproducts of fermentation.

The benzene concentrations were also somewhat above what one would expect to find in the background atmosphere. Benzene has been shown to be a carcinogen. More comprehensive testing is required to determine whether benzene is a health problem in the tunnel.

Chloroform, was not an issue at the time of the testing.

Ethyl acetate was not an issue at the time of the testing.

Trans,1,2-dichlorOethylene was not an issue at the time of the testing.

Trichloroethylene is a suspected carcinogen. The concentrations were above those that are normally found in the atmosphere.

Vinyl chloride was not an issue at the time of the testing.

The literature states that the concentrations of each of these compounds, individually, should not cause a health problem. However, some literature also reports that there are times when the synergistic effects of the combination of all of these compounds, not to mention the hundreds of other compounds that were identified and quantified at the site, could cause adverse health effects, particularly in people that are sensitive (allergic) to VOCs. The total VOC concentrations (the summation of all of the VOCs) were well above those that have been shown to cause people to feel ill.

Typical outdoor total VOC concentrations usually are below 100 micrograms per cubic meter. Typical indoor office 13 OORDON AIR QUALITY CONSULTANTS. INC, KJul-27-98 03:28P Gor-donAirQuality 508 670 1332 P-05

concentrations range from 100-300 micrograms per cubic meter. Concentrations above 1,000 micrograms per cubic meter have been reported to cause even people that are not sensitive to VOCs to complain of headaches, sore throats, red eyes, odors, nausea and other adverse effects.

Short of locating the sources of the VOCs and eliminating them (which is the best solution), we recommend that the tunnel be efficiently exhausted. The existing exhaust system's operation should be checked and upgraded as required to reduce the concentration of the airborne contaminants. Efficient exhausting of the tunnel will reduce the airborne contaminant levels to an acceptable concentration even if the source of the contaminants is not abated.

2. Hydrogen Gulfi4e

The hydrogen sulfide concentrations were all below 1 microgram per cubic meter. However, there was a distinct sulfide odor in one area of the tunnel. The sulfides causing the odor were probably organic in nature. The original scope of work, as generated by Rizzo, did not include testing for sulfide containing VOCs. This requires special sampling and analytical techniques.

3. Water Samples

The water samples didn't contain any (below the quantitative limits) of the target VOCs. The water samples were also devoid of sulfides. The water does not appear to be the source of the odors or the elevated organic compounds in the tunnel.

4. sludge Samples

The sludge samples didn't contain any (below the quantitative limits) of the target VOCs. However, there was a significant amount of sulfur present in the sludge samples, particularly the sample taken at the 325 sample site. Note that the samples were analyzed for non-sulfur bearing organic compounds. Sulfides are found in both organic and inorganic compounds.

5. microorganism Samples

All of the samples were loaded with bacteria. However, the bacteria appeared to be mostly soil bacteria which is generally harmless. Air testing will determine whether the microorganisms are becoming airborne.

In conclusion, the airborne VOC levels were elevated at both sample locations. However, only 2 air samples were taken, To accurately determine the degree of the problem, further testing

14 GORDON AIR QUALITY (ONSULTANTS, INC. "Jul-07-9B 03:2eP GorconAirQuality 508 670 1332 P.06

should be performed, particularly to identify airborne organic sulfides.

If you have any questions concerning this report or would like to have a meeting to discuss the results, please contact me.

ly yours,

v ord ,P.E.,

rdon Air ality Consul - Inc.

15 GORDON AIR QUALITY CONSULTANTS, INC. -- 23-1998 1:39PM FROM MBTA SAFETY 671 222 6127 P-1

I4! 0 0 Massachusetts Bay Transportation Authority

SAFETY DEPARTMENT 21 ARLINGTON AVENUE BUILDING 2 CHARLESTOWN, MA 02129 FAX #617-222-5127 FACSIMILE TRANSMITTAL

TO: ;A T oNNH0 uj2

COMPANY/DEPAR TMENT: M E R I 6 kJi i

FAX PHONE: (?7? ') M I\ 7615 ) C (c 7 Y FROM: -V caw~-0 Lurv B3OO4

TELEPHONE #: (4 n) 2 L- S 1

COMMENTS: w V0 S& Q mQsA

PAGE / OF'7 DATE: 7 z 5 r

Massachusets Bay Transportation Auhority. Ten Park Plaza. Boston MA n,11 10 71 7-23-1998 1:d2PM FROM MBTA SAFETY 671 222 8127 P 2

Summary Report Limited Investigation - Alewife Rapid Transit Tunnel 4 Cambridge, Massachusetts

3.0 Sampling Program

A sampling program was conducted at a total of five locations in the Alewife Rapid Transit Tunnel on November 19-20, 1997. Three ambient air samples, two water samples, and three sludge samples were collected between location 308+50N and location 330+15N within the Alewife Tunnel. Samples were collected simultaneously with David Gordon Associates, the laboratory representative of the local employee union. See Figure 1 for a site map and sampling locations,

3.1 Sampling Locations Sampling point 308+50N is located on the north side of the tunnel just east of the outbound track switches This site was chosen for sampling since from observation it appears that it contains the largest.accumulation of "wall sludge" within the Alewife Tunnel. One sludge sample was collected at this location_

Sampling point 325+OON is located on the north side of the tunnel near the 325+OON Track Drain. The open grated track drain discharges a steady flow of drainage water to the sump. This site was chosen for sampling as it has the highest potential for organic volatilization due to the drainage water free fall into the sump. Air, water, and sludge samples were collected at this location.

Sampling point 327+50N is located on the north side of the tunnel in the storage switchover area, This site was chosen for sampling since it is reported to be the area with the most consistent odor, according to MBTA employees. One air sample was collected at this location.

Sampling point 329+OOM is located in the middle of the tunnel at the southern signal light pole for the train storage area. This site was chosen to assess the impacts from water and sludge at location 330+15N. Direct air sampling at location 330+15N was not conducted because the trains stored adjacent to this area routinely discharge blowoff from air compressor systems. Air samples were collected at location 329+OOM, the closest representative to location 330+15N.

Sampling point 330+15N is located on the north side of the tunnel directly adjacent to the northernmost train, storage track. The site was chosen for sampling as it contains the largest standing pool of water in the Alewife Tunnel. The pool of water is contained within a utility trench and the

Rxzzo Ass OCIA TES, INC. 7-23-1998 1:40PM FROM MBTA SAFETY 671 222 6127 P.3

Summary Report Limited Investigation - Alewife Rapid Transit Tunnel Cambridge, Massachusetts 5

concrete "curb" alongside the tunnel. Water and sludge samples were collected at this location

3.2 Air Sampling and Analyses Air sampling for organic compounds was conducted at two locations in the tunnel, 325+OON and 327+50N, using evacuated Surna Canisters and carbon tubes with associated pumps. The sampling for organic compounds was conducted for a period of 24 hours at each sampling location.

Samples of airborne naphthalene were collected using carbon tubes, Naphthalene was collected for approximately eight hours at locations - 325+00N and 329+00N.

Air sampling for sulfur compounds was conducted at two locations in the tunnel, 317+OON and 325+OON, using glass-lined evacuated Summa Canisters with a glass-lined critical orifice. Sampling for sulfur compounds was conducted for eight hours at each location.

The air samples were transported under chain of custody to Air Toxics Ltd. of Folsom, California. The samples collected for organics analysis were analyzed for VOCs by EPA method TO-14, the samples collected for naphthalene were analyzed by TO-2, and the samples collected for sulfur compounds were analyzed for sulfur gases by ASTM D-5504. The results of the laboratory analyses are presented in Section 4.0.

3.3 Water/Sludge Sampling and Analyses

Samples of water and "wall sludge" were collected in the tunnel concurrently with the air monitoring activities on November 20, 1997. Three samples of "wall sludge" were collected at locations 308+50N, 325+OON, and 330+15N. water samples were collected at two of the "wall sludge" sampling locations, 325+OON and 330+15N, respectively.

The "wall sludge" and water samples were submitted under chain of custody to Toxikon of Bedford, Massachusetts, and analyzed for purgeable organics by EPA Method 8260 and total sulfides by EPA Method 376.2. The results of the laboratory analyses are presented in Section 4.0.

Rizzo ASSOCIATES, INC. 7-23-1998 1:41PM FROM MBTA SAFETY 671 222 6127 P-4

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S0 0 -. CLr_ - n 0 UNDERGROUND I ENGINEERING & ENVIRONMENTAL SOLUTIONS

Haley & Aldrich, Inc. I 465 Medford Street Suite 2200 Boston, MA 02129-1400 Tel: 617.886.7400 4 February 1999 Fax: 617.886.7600 HALEY & File No. 10063-066 Email: [email protected] ALDRICH

Department of Environmental Protection 205 Lowell Street Wilmington, Massachusetts 01887

Attention: Ms. Patricia Donahue

Subject: Notice of Delay W. R. Grace & Co. - Conn. Cambridge, MA RTN 3-00277

Ladies and Gentlemen:

On behalf of W. R. Grace & Co. - Conn. and in accordance with Section 40.0550(5) of the Massachusetts Contingency Plan (MCP), this letter is to inform you of a delay in submitting the Phase III Feasibility Study report for the subject RTN which is due 13 February 1999. As you know, numerous recent events at this site have caused us to assess the current schedule for MCP compliance. The events, all of which have an impact on the preparation of the Phase III report, include the discovery of low levels of asbestos in the soil at the property, the recent conclusion of the rezoning of the property and the near-term availability of OFFICES additional VPH/EPH soil quality data that will be used to evaluate the existence of UCL exceedances. Cleveland Ohio We are committed to finalizing the Phase III report as soon as there is a clearer indication of Denver Colorado the implication of each of these events on the remedial alternative feasibility evaluation process. We anticipate that we can submit the Phase III report by 1 August 1999. Hartford Connecticut Sincerely rs, Los Angeles California HA RICH, INC. Manchester New Hampshire Wesly . on, P Newark Senior Vice President New Jersey Portland c. W. R. Grace: Mr. John Wardzel Maine PIP Repositories and Notification List Rochester New York :/F:\10063\066\IIDELAY.WPF San Diego California San Francisco California Washington District of Columbia

Prid emrecyded paper. - r1~# V INFORMATION SHEET 28 December 1998 01

PUBLIC INFORMATION REPOSITORIES

Department of 1gnvironmental Protection Northeast Regional Office 205A Lowell Street Wilmington, Massachusetts 01887

Contact: Ms. Holly Migliacci Telephone: (978) 661-7600 File Review Hours: Monday through Friday, 9:00 a.m. to 12:00 p.m.

Cambridge Main Library 494 Broadway Cambridge, Massachusetts 02138 ATTN.: Susan Flannery

Telephone: (617) 349-4044 File Review Hours: Monday through Friday, 9:00 a.m. to 9:00 p.m. Saturday, 9:00 a.m. to 5:00 p.m. Sunday, 1:00 p.m. to 5:00 p.m.

North Cambridge Library 70 Rindge Avenue Cambridge, Massachusetts 02140 ATTN.: Jessie Rabban

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

W.R. Grace & Co.-Conn. Contact: John Wardzel 62 Whittemore Avenue Telephone: (617) 498-4983 Cambridge, Massachusetts 02140 File Review Hours: 9:00 a.m. to 4:00 p.m.

City of Cambridge Contact: John Buldoc Community Development Dept. Telephone: Telephone: (617) 349-4628 57 Inman Street File Review Hours: 9:00 a.m. to 4:00 p.m. Cambridge, Massachusetts 02139

Contact Changes: New W.R. Grace Contact: New Haley & Aldrich Contact, Address and Phone Numbers: John Wardzel Amy Church W.R. Grace & Co.-Conn. Haley & Aldrich, Inc. 62 Whittemore Avenue 465 Medford Street, Suite 2200 Cambridge, Massachusetts 02140 Boston, Massachusetts 02129-1400

Telephone: (617) 498-4983 Telephone: (617) 886-7394 Fax: (617) 886-7694 F:%10063\072\]NFOSHT.WPF UNDERGROUND ENGINEERING & S ENVIRONMENTAL SOLUTIONS

Haley & Aldrich, Inc. 465 Medford Street Suite 2200 Boston, MA 02129-1400 Tel: 617.886.7400 4 February 1999 Fax: 617.886.7600 Email: [email protected] HALEY & File No. 10063-066 ALDRICH

Department of Environmental Protection 205 Lowell Street Wilmington, Massachusetts 01887

Attention: Ms. Patricia Donahue ------Subject: Notice of Delay us Wl W. R. Grace & Co. - Conn. A I1-a Cambridge, MA g - RTN 3-00277

Ladies and Gentlemen:

On behalf of W. R. Grace & Co. - Conn. and in accordance with Section 40.0550(5) of the Massachusetts Contingency Plan (MCP), this letter is to inform you of a delay in submitting the Phase III Feasibility Study report for the subject RTN which is due 13 February 1999. As you know, numerous recent events at this site have caused us to assess the current schedule for MCP compliance. The events, all of which have an impact on the preparation of the Phase III report, include the discovery of low levels of asbestos in the soil at the property, the recent conclusion of the rezoning of the property and the near-term availability of OFFICES additional VPH/EPH soil quality data that will be used to evaluate the existence of UCL exceedances. Cleveland Ohio We are committed to finalizing the Phase III report as soon as there is a clearer indication of Denver Colorado the implication of each of these events on the remedial alternative feasibility evaluation process. We anticipate that we can submit the Phase III report by 1 August 1999. Hartford Connecticut Sincerely yours Los Angeles HAL CH, INC. California . -P Manchester New Hampshire Wesl . on, LSP Newark Senior Vice Presi nt New Jersey Portland c. W. R. Grace: Mr. John Wardzel Maine PIP Repositories and Notification List Rochester New York :/F:\10063\066\IIDELAY.WPF - San Diego California San Francisco California Washington District of Columbia

Prntledo recydd paper UNDERGROUND Ar - ENGINEERING & 0 ENVIRONMENTAL SOLUTIONS

Haley & Aldrich, Inc. 465 Medford Street Suite 2200 Boston, MA 02129-1400 Tel: 617.886.7400 Fax: 617.886.7600 Email: [email protected] HAL EY & 30 January 1998. ALDRICH File No. 10063-066 62 Apot-WeO As City of Cambridge Community Development Department 3-2-7-7- 57 Inman Street Cambridge, Massachusetts 02139

Attention: Ms. Susanne Rasmussen Environmental and Transportation Planning Director

Subject: Russell Field and W.R. Grace Groundwater Sampling Programs 62 Whittemore Avenue Cambridge, Massachusetts

Ladies and Gentlemen:

Haley & Aldrich, Inc. (Haley & Aldrich), on behalf of W.R. Grace & Co. - Conn. (W.R. Grace), extends permission for the City of Cambridge to collect surficial soil samples on a portion of the W.R Grace property. It is our understanding that four surficial soil samples will be collected along the MBTA easement that bisects the W.R. Grace property. The collection date is tentatively scheduled for 5 February 1998. A Haley & Aldrich representative will be on site at the time of sampling and will collect split samples of the four OFFICES discreet samples collected by the City of Cambridge. Cleveland Ohio The proposed Groundwater Monitoring Program will utilize 15 monitoring wells located on Denver and adjacent to the W.R. Grace property. Nine of the monitoring wells to be sampled, B212- Colorado OW, B604-OW, B707-OW, B708-OW, 1801-OW, B802-OW, B803-OW, B807-OW and Hartford B904-OW, were sampled for W.R. Grace's 1986-1994 Long-Term Monitoring Program. In Connecticut addition, four monitoring wells, 1204-OW, B411-OW, B502-OW and 1503-OW, Los Angeles recommended for long-term groundwater monitoring in Environmental Health & California Engineering's report titled "Public Health Risk Evaluation For W.R. Grace Site in Manchester Cambridge, Massachusetts," dated 26 April 1996 will be included along with two wells to be New Hampshire determined after our evaluation of existing well conditions. It is anticipated that the wells will Newark be located along Whittemore Avenue or on the W.R. Grace porperty. New Jersey

Portland Maine Rochester New York San Diego California San Francisco California

Washington District of Columbia

Prirntd onreyded .per City of Cambridge 30 January 1998 Page 2

Included in this package is the Goresorber Location Map, to be returned to John Bolduc. If you have any questions or comments please do not hesitate to call.

Sincerely Yours, HALEY& ALDRICH, INC.

esley .timpson Senior Vice President c:. Massachusetts Department of Environmental Protection; Ms. Patricia Donahue W.R. Grace & Co. - Conn; Mr. Mario Favorito

FA10063\066\CAMBRIDG.WPF £

Robet Sorrenino, Vce Prese Engineamg & Mnufocuding Suppod Grace Conrucion Product

W.. Grace & Co.Conn. 62 Whi~nore Avenue Cambricg.. Mass. 02140-1692

(617) 49-4983 Tel. (617) 491-2029 Fax

August 12, 1998

Commissioner David B. Struhs Commonwealth of Massachusetts Executive Office of Environmental Affairs Department of Environmental Protection Metropolitan Boston - Northeast Regional Office One Winter Street Boston, Massachusetts 02108

Dear Commissioner Struhs:

This will acknowledge receipt of a copy of a letter dated July 29, 1998 from Representative Alice K Wolf to you urging that an advertised public meeting be held with respect to any plan for further asbestos sampling on the Grace site in Cambridge.

First, let me assure you that Grace takes the presence of asbestos on its site very seriously.

Grace has and will continue to take into consideration the neighborhood's interest in activities on the Grace site relating to the presence of asbestos and has and will continue to seek public comment on its plans. Grace also has a responsibility to its own employees who work on the site.

In response to DEP's letter to Grace dated July 3, 1998, Grace developed a proposal for additional soil sampling to address its MCP compliance obligations relating to the discovery of asbestos at the site.

A public involvement plan ("PIP") (DEP RTN-3-0227) was developed and approved for other releases of oil and hazardous materials at the site by DEP in December 1995. Although the asbestos found on the site has a different release tracking number (RTN 3-17014) Grace has requested its consultants to closely follow the Public Involvement Activities requirement of the PIP as if it were applicable to the asbestos issue. Commissioner David B. Struhs Dept. of Environmental Protection Page 2 August 12, 1998

In this connection, Grace:

" Placed copies of the proposed asbestos sampling plan in the designated Public and Local Information Repositories which include the Cambridge Main Library and the North Cambridge Library.

" Sent copies of the proposed sampling plan to DEP, and hand delivered copies to the City of Cambridge and to representatives of two neighborhood groups, including Mr. David Bass of Alewife Neighbors, Inc. and Mr. Joseph. J. Joseph of the Alewife Study Group.

* Sent a notice of availability of the proposed sampling plan to all persons (112 in all) who requested information about the site when the PIP was prepared. This notification was sent to, among others, Representative Wolf and other state, local, and federal officials, neighbors on the surrounding streets and the press. The asbestos on the site has been the subject of a number of press articles in recent weeks.

* Participated in a public meeting which was held on Tuesday evening, July 28, 1998 at the Cambridge City Hall Annex to review the proposed sampling plan. Present at the meeting were representatives of the DEP, the City of Cambridge and its environmental consultants and the neighborhood groups (Alewife Neighbors, Inc. and Alewife Study Group) and the neighborhood's environmental consultants as well as Representative Wolf.

Since the July 28th meeting, we have considered the concerns raised by those in attendance at that meeting as well as the written comments received (many of which comments were also copied to your office) and we have also consulted with DEP to receive its informal comments on the proposed sampling plan. As a result, we have requested that Haley & Aldrich make modifications to the proposed asbestos sampling plan (which is attached). This revised soil sampling plan includes sampling of the Lehigh metals site requested by the neighborhood groups even though Grace never operated on that site and did not even acquire this property until February, 1988. The data derived from the sampling plan, which involves the collection of at least 410 samples from approximately 238 locations, would be used for initial risk characterization and conceptual development of a soil management program.

During the data collection phase of our work, Grace will consult with DEP and the environmental consultants to the City of Cambridge and the neighborhood groups regarding potential methods for conducting the risk characterization and on soil management techniques. i I I *

Commissioner David B. Struhs Dept. of Environmental Protection Page 3 August 12, 1998

Grace, hopefully with the involvement of a moderator supplied by DEP, would schedule a public meeting with a formal presentation of the results of the sampling, initial risk characterization data and the conceptual soils management techniques proposed. We appreciate the efforts which Laurel Mackay and her staff have made to reach common ground, but Grace sincerely believes that the approach suggested in this letter would make for a more meaningful public meeting.

We agree with the comments of Representative Wolf and others that the presence of asbestos on the site means that the development of the site needs to be properly handled and managed to minimize any health risk and we assure you that Grace does not intend to go forward with development of the site until the level of risk relating to the presence of asbestos has been properly characterized and a soils management plan appropriate to the risk has been developed.

As with past environmental issues related to the site Grace will cooperate with DEP and obtain input from the community. In this connection, Grace will make an even wider notification of the availability of the revised sampling plan than was followed in the earlier sampling plan notification which will include publication of a notice of availability of the revised sampling plan in a newspaper with circulation in Cambridge.

As a result of the changes to the plan proposed by Grace, the public comment period relating to the proposed revised asbestos sampling plan would be extended until September 4, 1998. Assuming a start date right after Labor Day, we would anticipate that data from the sampling plan would be available by early in November and that a public meeting would be held soon thereafter.

Please note that Grace has conducted ambient air sampling at the Grace site, the results of which indicate that the air sampled was within normal ambient background fiber levels as measured by the EPA AHERA and the Massachusetts DLWD criteria. The report of such findings is included with the revised proposed sampling plan. At the request of the neighborhood Grace has also fenced certain areas of the Grace site.

Grace, as always, will continue to cooperate with all concerned.

Sincerely,

Robert Sorrentino

RaseRUHMMrU98 cc: P. Donahue - Dept. of Environmental Protection J. J. Joseph L. A. Mackay - Dept. of Environmental Protection A. K. Wolf - House of Representatives '3, ambridge1it1field gets eletn bill aof chemicals not"eaitiahazard; more testing set I a

ByTheoEmery- GLOBE CORRESPONDENT 7ests tndicate that one zone'of (I £ playing field abutting W.R. Initial testing at Russell Field W1 Usee &-Co. property does contiln' frmine whetler the MBTA tunnels dieates theit *ek to-health *NW. etroleum-based -chemicas' have changed the flow of ground wa- from chemlial 4oripounds at.the above reportibleevel ao. e inthe area.- pjpular North' Cambridge athletic , irg to Rasmussemwfo cmn- 'In the second round of testing at that the bee-hid ue Russell ieild, the city will use data However, the city and nei m only found in urban -from 171 soil gas samples to deter- hoo grops plwa second phase of tktbug to analyze one slightly con- Jo addition, sediment sanvip mine where to extrat subsurface the banks of Parkway Pond, il:g9j samples and where -to locate ground &te area and probe for sub- on the western edge of the Grace- u hfW chemical&.- water monitoring weil Slated to be- property that was once used as a dis- gin next month, testing is expected #. )onsultants hired by the city and ,posal site for chemicals, indicate the Alewife Neighbors Inc. have found to yield final results in April. zones 21resence of contaminants above 1ev- that in the majority of testing M-secepted by the Massachusetts on thefeld, chemicals in the top 6 I-. inches of surface soil are below re- epartent of Environmental Pro- portable concentrations setby state W. Grace spokesman Chris -Wguidelig- Lawson According. to Susanne Rasmus- said that until final data are available, "Comment would be pre- sen, director of environmental and transotation planning in the Cam- mature at this tune. We're continu bddge Community Development De- ing to coopert %th the city on the, indicate clean fill testing program both on and off the jartment, the tests , - - .- wasplaced on the field. Qmeproperty. at one - .here's me major news , The Grace property was - tne..owned here," Rasrlussen said. "In the by Dewey & Almy, a zones where we completed testing, chennieal manufacturing company we found nothing, which should be bought by W.R. Grace in 14. vey comforting to the- neighbor- - he Cambridge City Council hood" gal ed for the testing in 1996 to allay Neighborhood residents ex- njghborhood concerns about conta- pressed -relief about the findings. jmjants from the Grace propertj, "The results are very promising, .,gwhich is listed with the state Depart- very posidve," said.David Bass, an . qit of Enviromniental Protection environmental engineer and a neigh- ,w-a "Non-Priority Confirmed Dis- borhood resident. "For all these -joal Site" because of contamination years, our children in the neighbor- Ifrom volatile and semi-volatile or- hedd -have not been exposed to gahics,, petroleum products, and I_ r

MBTA used Russell Fe to store ontaminated soil excavated from the Grace property during the Red Line extension to Alewife. Though the field .wis capped with clean fill, the tests are to ascertain whether the stored soil or underground water movement had contaminated the site, according to Rasmussen. The company is also drawing up plans for a hydrology analysis to de- Gotn'oc\~sc~. UNDERGROUND u..Ynx V~ ttO%.~A ENGINEERING & 0 ENVIRONMENTAL ~- O~flL SOLUTIONS I i i Haley & Aldrich, Inc. 465 Medford Street Suite 2200 Boston, MA 02129-1400 Tel: 617.886.7400 Fax: 617.886.7600 Email: [email protected] HALEY & 9 February 1998 ALDRICH File No. 10063-066

Ms. Patricia Donahue Department of Environmental Protection Northeast Regional Office 10 Commerce Way Woburn, MA 01801

Subject: Notice of Placement of Work Plan in Public Repository W.R. Grace Site RTN 3-0277 Cambridge, Massachusetts

Dear Ms. Donahue:

This is to inform you that W.R. Grace is proposing to undertake a subsurface exploration and testing program to characterize soil for the possible presence of asbestos at the W.R. Grace site. In accordance with the Public Involvement Plan (PIP) prepared for this site, copies of the Sampling Plan for this work, dated 12 January 1998, will be available at the public repositories listed on the attached Information Sheet on 10 February 1998. As outlined in the PIP, W.R. Grace welcomes public review and comments on the proposed work. Comments OFFICES may be provided to the Haley & Aldrich representative indicated on the attached Information Cleveland Sheet until 3 March 1998. Ohio Denver If you no longer wish to be informed of the various activities at this site outlined in the PIP, Colorado please contact us and we will remove your name from the contact list. Hartford Connecticut Sincerely urs, Los Angeles HALEY LDRICH, INC. California Manchester New Hampshire Newark Wesley E. Stimpson, LSP New Jersey Senior Vice President Portland Maine F:\10063\O66\MERGE.WPF Rochester New York

San Diego California San Francisco California

Washington District of Columbia

PriHed on ecycIed p INFORMATION SHEET 10 February 1998 -3 Public Information Repositories

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

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

Cambridge Main Library 494 Broadway Cambridge, Massachusetts 02138

Telephone: (617) 349-4044 File Review Hours: Monday through Friday, 9:00 a.m. to 9:00 p.m. Saturday, 9:00 a.m. to 5:00 p.m. Sunday, 1:00 p.m. to 5:00 p.m.

North Cambridge Library 60 Rindge Avenue Cambridge, Massachusetts 02138

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

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

Contact: Robert Sorrentino Telephone: (617) 4984983 File Review Hours: 9:00 a.m. to 4:00 p.m.

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

Contact: John Buldoc Telephone: Telephone: (617) 3494628 File Review Hours: 9:00 a.m. to 4:00 p.m.

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

Telephone: (617) 498-4983 Telephone: (617) 886-7394 Fax: (617) 886-7694 Robert Sorrentinb Vice President, gineering- and Manufactu rng9 it -

Grace Construction Products R G W.R. Grace & Co.-Conn. 62 Whittemore Avenue Cambridge, Mass. 02140-1692

(617) 498-4475 Tel. (617} 491-2029 Fax.

January 13, 1998

David B. Struhs Commissioner Commonwealth of Massachusetts Executive Office of Environmental Affairs Department of Environmental Protection Metropolitan Boston - Northeast Regional Office One Winter Street Boston, Massachusetts 02108

Dear Commissioner Struhs

I am writing with regards to the November 20, 1997 letter sent to you by the Alewife Study Group. That letter concerns property now or formerly owned by W. R. Grace & Co. on Whittemore Ave. in Cambridge. Since 1984, Grace has worked in cooperation with DEP and the City of Cambridge regarding its property, and we will continue to do so. Because many of those who received the Alewife Study Group letter are unacquainted with the background of previous studies at this site, we thought it would be helpful to provide you with this summary of relevant events at the site since 1984.

In 1984, after the cessation of large-scale manufacturing at the Whittemore Avenue location, Grace voluntarily initiated a program of soil, groundwater and surface water sampling at the site. The company shared the results of these studies in a series of public meetings at its plant and elsewhere in Cambridge and made the reports publicly available through the Cambridge Public Library system.

In 1986, the City of Cambridge asked for assistance from Massachusetts DEP in reviewing the Grace studies under the then newly adopted 21E program. Grace welcomed DEP's participation and has cooperated fully with DEP in its review of the site and in addressing all requests for additional data 9 0

David B. Struhs/DEP Page 2 January 13, 1998

made by the department. As part of this process, Grace identified historic on- site disposal areas as well as above and below-ground chemical storage areas for its major raw materials. On March 2, 1990, DEP approved Grace's Phase II Comprehensive Site Assessment, including a Risk Assessment (see Tab 1). In its March, 1990 letter, DEP stated:

"The Department has reviewed the assessment report submitted on behalf of W. R. Grace & Co. and concluded that environmental conditions at the site have been sufficiently characterized and the procedures employed to estimate exposures and evaluate risks have been adequately documented".

The site is currently classified as a Tier IC site under the 21E program.

Since 1984, Grace and its consultants have:

- completed 299 borings and test pits with associated soil samples - collected and analyzed 245 groundwater and surface water samples - conducted an extensive air monitoring program - investigated basement flooding conditions in the Whittemore Avenue neighborhood - conducted a full risk assessment of the site - instituted a long-term groundwater monitoring program - participated in over 20 public meetings - made all analytical results available to the public

In its initial studies, Grace requested that laboratories analyzing samples look for all 125 EPA-listed hazardous substances, as well as compounds such as formaldehyde and vinyl acetate that were not on the usual regulatory analyte lists, but which were used in large quantities at the Grace site and which could have been released to soil and/or groundwater.

The extent of Grace's sampling program is shown on the attached plan (see Tab 2).

In addition, the City of Cambridge retained Dr. John Spengler of Environmental Health & Engineering, Inc. (EH&E) to conduct an independent review of the data generated by Grace and its consultants in characterizing the site. Dr. Spengler's letter, dated March 20, 1996, states, in part, that: David B. Struhs/DEP Page 3 January 13, 1998

"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."

EH&E also noted that Grace and its consultants "were cooperative in providing us prompt access to data and documents as well as candid responses to our inquiries".

Dr. Spengler's letter as well as the Executive Summary from his final draft report, dated April 23, 1996, can be found at Tab 3.

EH&E made recommendations regarding continued groundwater monitoring and for obtaining additional information on groundwater flow east of the MBTA tunnel toward Clifton Street. Grace will continue its monitoring program and is in the process of obtaining further information on groundwater flow toward Clifton Street. Attached is Grace's letter of January 12, 1998 (see Tab 4) to the City of Cambridge regarding both the groundwater study and granting of access to the City's consultants to take additional samples on the Grace property.

Grace has reviewed the attachments to the Alewife Study Group letter and other available records concerning operations by both Grace and its predecessor at the site, the Dewey and Almy Chemical Company (D&A), and has found no indication that asbestos is being released at the site, or that a threat of such release now exists. Nevertheless, in continuation of the cooperation demonstrated by Grace over the past 13 years, we have asked Haley & Aldrich to develop an asbestos soil sampling plan which Grace is preparing to implement. As always, the results will be made available to DEP, the City of Cambridge and the public and the City's Consultants are invited to split samples.

More detailed comments on the November 20 letter follow:

1. In 1930, D&A decided to enter the brake lining and automobile clutch business by purchasing the majority of stock in the Multibestos Company of Walpole, Massachusetts. D&A sold its investment and left the brake lining and automobile clutch business in the fall of 1935. In 1954, D&A merged into W. R. Grace & Co. In 1989, when the USEPA and MADEP requested that Grace become involved in remediation activities at the former Multibestos David B. Struhs/DEP Page 4 January 13, 1998

Company property in Walpole, Grace cooperated promptly and fully with both agencies and successfully completed an asbestos removal action under the provisions of the Federal Superfund law.

2. During the years when D&A owned the stock of Multibestos, its Cambridge property was significantly smaller in area than the Grace Cambridge property as it exists today. With the exception of a small sliver of land used for parking, D&A owned no land south of the B&M railroad track and, thus, did not own or operate on any of the land adjacent to, or on which, Russell Field is located. A lumber company under non-D&A ownership lay between the D&A property and Russell Field. Attached is a plan of land drawn from applicable deed and title records dated October 1, 1938 showing the extent of the land area actually owned by D&A at that time (see Tab 5). Furthermore, D&A did not start acquiring ownership of the land later used after World War II by D&A and Grace for on-site disposal of wastewater and sludges until 1941, a date well after the time when D&A ended its investment in Multibestos.

3. We have been unable to find any justification for the statement in the Alewife Study Group letter that the Cambridge plant was "the subject of special attention by the Department of Labor and Industries (DLI) Division of Occupation due to a high incidence of asbestosis complaints resulting in both awards of workmen's compensation claims and related legal actions".

While the Alewife Study Group assertion appears to be based upon a 1934 memo by Dr. Hervey Elkins of DLI which it attached to its letter, both that letter and other available information tell a different story. Available in the same DLI files in which the Elkins memo was located are two other documents (see Tab 6) which provide the full, and accurate, context for Dr. Elkins' visit to D&A. The first is a letter of October 31, 1934 from Manfred Bowditch, Director of the Division of Occupational Hygiene, to Bradley Dewey of the Dewey and Almy Chemical Company. Mr. Bowditch's letter asks permission for Dr. Elkins to visit Dewey and Almy as part of his training program in the newly established Division of Occupational Hygiene. The letter contains no mention of any special attention paid by DLI to practices at D&A nor any reference to asbestosis complaints.

The second letter is the November 8, 1934 response from Mr. Dewey to Mr. Bowditch in which Mr. Dewey writes: David B. Struhs/DEP Page 5 January 13, 1998

"Of course, we shall be delighted to have Dr. Elkins with us and to have him spend just as much time as he wants to in the two places where we may be said to have industrial hazards; to wit: in our Solvent Room in Cambridge and at the plant of the Multibestos Company in Walpole".

"The next time you have a job of this kind, don't think you have to write us so long and arduous a letter. Just call up on the telephone and tell us what you want us to do."

Finally, Grace is unaware of the existence of any asbestosis claims related to the use of asbestos at the Cambridge facility.

4. Based upon our review, we believe that some asbestos was used in 1933 and 1934, and possibly earlier in the 1930s, in Buildings 11 and 12 (location shown on the plan at Tab 5), both of which were constructed in 1929 and were taken down in 1984. Building 11 was constructed by D&A for experimental process development and contained pilot scale operations during this time period. Among these processes, we believe that D&A worked on pilot, or model production line, processes for manufacturing a new type of brake lining, to be molded, rather than woven, with rubber material and asbestos. This molding process involved the mixing of asbestos with latex. Building 12 may have been used during this period for, among other activities, manufacturing latex- impregnated asbestos sheets which were then shipped to the Walpole facility for cutting and shaping. However, Walpole, and not Cambridge, remained the location for substantially all of the manufacture of brake linings.

The scale of the Cambridge operations is noted by Dr. Elkins in his 1934 memo where he writes that "Items which it is believed may not be general practice are marked with an asterisk". Dr. Elkins used an asterisk in his description of the "rubber bonded brake lining materiar' which contains the only reference to asbestos in his Cambridge report. Although his visits occurred on weekdays, Dr. Elkins also mentions that "none of these processes were in operation" during those visits. Based upon this information, it would be incorrect to equate asbestos-related operations at Multibestos in Walpole with the activities in Cambridge as the Alewife Study Group letter appears to do.

The only other asbestos-related activity that Grace has been able to identify at the Cambridge location occurred in the late 1960s and early 1970s when occasional laboratory analysis and research was conducted on small amounts of asbestos containing fireproofing materials. David B. Struhs/DEP Page 6 January 13, 1998

5. Grace has no information regarding a release or threat of release of asbestos in the area formerly occupied by Buildings 11 and 12 which were located in the general area now covered by the parking area immediately to the south of the Alewife One Building. However, in order to address any questions on this matter, Grace has asked Haley & Aldrich to develop a soil sampling plan (see Tab 7) which Grace is preparing to implement in February 1998. We will give prior notice to DEP and the City of the specific days scheduled for sampling, and both DEP and the City are invited to obtain split samples.

We look forward to continued cooperation with MADEP and the City of Cambridge on this matter.

Very truly yours,

Robert Sorrentino

RS/struhs.doc Attachments cc: Cambridge City Council John DeVillars, USEPA Karen Stromberg, DEP Northeast Regional Office Patricia Donahue, DEP Northeast Regional Office State Senator Warren Tolman State Representative Alice Wolf State Senator Robert Havern U.S. Senator Edward M. Kennedy U.S. Senator John Kerry U.S. Representative Joseph P. Kennedy Addresses for Struhs Letter

Cambridge City Council City of Cambridge Cambridge City Hall 795 Massachusetts Avenue Cambridge, Massachusetts 02139

John DeVillars Regional Administrator U.S. Environmental Protection Agency Region 1 John F. Kennedy Federal Building 10th Floor Boston, Massachusetts 02203-0001

Karen Stromberg Department of Enivronmental Protection Northeast Regional Office 10 Commerce Way Woburn, Massachusetts 01801

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

State Senator Warren Tolman State House Room 424 Boston, Massachusetts 02133

State Representative Alice Wolf State House Room 473G Boston, Massachusetts 02133

State Senator Robert Havern State House Room 513 Boston, Massachusetts 02133 Addresses for Struhs Letter (Continued)

U.S. Senator Edward M. Kennedy 2400 Kennedy Federal Office Building Boston, Massachusetts 02203

U.S. Senator John Kerry 1 Bowdoin Square 10th Floor Boston, Massachusetts 02114

U.S. Representative Joseph P. Kennedy (Congressman) 529 Main Street Charlestown, Massachusetts 02129 UNDERGROUND ENGINEERING & ENVIRONMENTAL SOLUTINS

Haley & Aldrich, Inc. 465 Medford Street, Suite 2200 Boston, MA 02129-1400 Tel: 617.886-7400 Fax: 617.886-7600 Email: [email protected] HALEY & Letter of Transmittal ALDRICH

Date 10 February 1998 File Number 10063-066 From Wesley E. Stimpson

To Department of Environmental Protection Northeast Regional Office 10 Commerce Way Cambridge, Massachusetts 02138 Attention Ms. Holly Migliacci Copy to Cambridge Main Library; North Cambridge Library; City of Cambridge; W.R. Grace & Co.-Conn. Subject W.R. Grace & Co.-Conn.

Copies Date Description 1 -Sampling Plan Evaluation for Asbestos in Soil W.R. Grace & Co.-Conn. I RTN 3-0277 6 2 A--o Cambridge, Massachusetts 12 January 1998

Remarks SAMPLING PLAN EVALUATION FOR ASBESTOS IN SOIL W.R. GRACE & CO.-CONN RTN 3-0277 CAMBRIDGE, MASSACHUSETTS 12 JANUARY 1998

I. INTRODUCTION

This Sampling Plan, prepared for W.R. Grace & Co.-Conn in Cambridge, Massachusetts, documents the objectives, rationale and procedures to be used for characterization of soil in the vicinity of past areas of operation that may have included the use and handling of asbestos and asbestos containing material at the W.R. Grace & Co. property (the Site).

II. BACKGROUND

Since 1985, a number of investigations have been performed to characterize the nature and extent of soil, groundwater and surface water contamination at the site. Extensive analytical data has been submitted to the Massachusetts Department of Environmental Protection (DEP) to date.

Description of W.R. Grace & Co. Disposal Site

The Grace Disposal Site (RTN 3-0277) consists of an approximately 27-acre irregularly shaped parcel of land directly east of the Alewife Brook Parkway/Route 2 Interchange in Cambridge, Massachusetts. The Site is bounded on the north by Whittemore Avenue, on the east by residences and Russell Field Park, and on the south by Rindge Avenue. Wetlands exist on the southwestern portion of the site. Prior usage has been documented to be primarily chemical manufacturing, administrative offices, and shipping and receiving. The Site is intermittently paved or covered by structures, and access to the majority of the exposed ground surface is restricted by fencing; however, access to some open areas is unrestricted.

The Site is listed with the DEP 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 has been assigned Release Tracking Number (RTN) 3-0277. RTN 3-0277 is currently a Tier IC disposal site in Phase III of the MCP. W. R. Grace & Co.-Conn is the listed potentially responsible party. Brief Review of Historical Use

The Site has been in use as industrial or commercial property since the 1800's. Prior owners of the property include mining companies, which mined clay from portions of the site, the Boston & Maine Railroad, Dix Lumber Company, the Smith Brickyard Co., an ice cream manufacturing facility and the Dewey & Almy Chemical Company. The Dewey and Almy Chemical Company was founded in 1919 for the manufacture of rubber products. In 1954, the Dewey and Almy Chemical Company merged with W.R. Grace & Co. to become the Dewey & Almy Chemical Division of W.R. Grace & Co.

It is believed that asbestos was handled in Buildings 11 and 12 in the early 1930's. Buildings 11 and 12 were once located on the site as shown on Figure 1. An account of this use of asbestos is more fully described in the attached letter from W.R. Grace.

Building 11 was constructed by 1929, and was used for experimental process development, non-asbestos containing product manufacturing and warehousing from 1929 until the building's total demolition in 1984. A section of Building 11 was razed in 1980.

Building 12 was also constructed by 1929. During 1930 to 1935 its use included the manufacture of solvent-based jar sealing compound. From 1946 to 1961 the building was used for the manufacture of air-entraining agents for concrete, a silicone masonry sealant, and a dispersant. From 1961 through 1979, Building 12 housed chemical tank churns. From 1979 to the building's demolition in 1984, the building was used for various chemical manufacturing processes.

During the 1930's, the Dewey & Almy owned property was bounded by active railroad right- of-ways, the southern right-of -way serving as the major rail transportation route to Boston. Land to the north and south of the railroad tracks was owned by others as shown- on Figure 2.

III. OBJECTIVE

The sampling program is designed to provide sufficient data on the quality of soil existing in the vicinity of former Buildings 11 and 12 to determine if the past handling of asbestos at these locations resulted in a condition that requires response actions under current regulations.

IV. APPROACH

A systematic sampling and analysis program designed to obtain samples of fill materials through a series of test borings, conducted at various locations in the vicinity of the former locations of Buildings 11 and 12 will be undertaken. A test boring contractor will obtain soil samples in the vicinity of former Buildings 11 and 12 at the approximate locations shown on Figure 3. To date, numerous test pits and other explorations have been completed as part of the Phase II MCP studies throughout the area. None of these investigations have uncovered any visible signs of bulk asbestos or artifacts that may contain asbestos.

2 Sampling Locations

Sample locations have been selected based on the criteria discussed below. Unsuccessful attempts have been made to determine the relationship between the current site grade and the ground surface grade existing in the early 1930's. Therefore, it is proposed that fill material existing to a depth of 8 ft. be tested in 2 ft. intervals. This depth can be demonstrated to be below the ground surface grades existing in the 1930's.

A total of nine GeoProbe0 soil borings will be completed in the vicinity of former Buildings 11 and 12 to obtain information on subsurface conditions and samples of subsurface fill. The GeoProbes6 will extend to approximately 8 feet below the ground surface, to the lower known depth of fill material in the area.

Four samples will be collected from each boring, continuously at two-foot intervals to a depth of 8 feet below ground surface, for a total of 36 samples.

GeoProbe0 locations were selected based on the following: o No soil borings are proposed beyond the open area that existed within the triangle property limits, bounded by the railroad right-of-ways, in 1935. This was the only open area near Buildings 11 and 12 under the control of Dewey & Almy at the time of the possible asbestos use. Land beyond the "triangle," now owned by W. R. Grace, was owned by others not associated with Dewey & Almy. o One soil boring will be completed within the footprint area of former Building 11, where the pilot scale development of asbestos-containing materials and manufacturing operations would have occurred. o Four soil borings will be completed in the area identified as a scrap yard to the west and south of Building 11 in 1935. A Fire Insurance Association map, dated 1970, of the W.R. Grace & Co., Dewey & Almy Chemical Co. Division, indicates three exits existed from Building I1 to the scrap yard. Soil in the area of the scrap yard may will be evaluated to determine if it contains asbestos handled within Building 11 or accidentally spilled. o Four soil borings will be completed in the area surrounding the former location of Building 12. The soil around Building 12 will be evaluated to determine if it has been impacted by asbestos use in the building.

Analytical Parameters

Soil samples will be prepared for analyses following methods outlined in EPA Region I Protocol for Determining Asbestos Content in River Sediment and Soil Samples.

The soil samples will be analyzed for asbestos using EPA method 600/M4-82-020, polarized light microscopy. Asbestos analysis will be conducted by a DEP certified laboratory and reported as percent asbestos.

3 Sample Collection and Custody

Soil samples will be collected based on the assumption that they contain asbestos using Health and Safety protocols designed to comply with state regulations. However, it is not considered necessary to have the soil samples collected by persons certified by Massachusetts to sample asbestos containing material.

The collection of soil samples will be documented to create a permanent record of the conditions under which the samples were obtained. Custody of the samples from the time of sampling to the time of analyses will be documented by chain of custody records. Custody of the samples will also be documented on a Field Activity Daily Log record. Upon completion of sample collection, the samples will be labeled and delivered to the analytical laboratory, with a chain of custody form.

Evaluation of Results

Soil is regulated as an Asbestos Containing Material if it contains more than one percent asbestos fibers. If data obtained indicates a soil sample contains less than one percent asbestos, it will be concluded that a release of asbestos into the environment has not occurred. If the criteria is exceeded, additional investigation will be undertaken, initially including the collection of urban background samples beyond the property limits.

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Haley & Aldrich, Inc. 465 Medford Street Suite 2200 Boston, MA 02129-1400 Tel: 617.886.7400 Fax: 617.886.7600 Email: [email protected] HALEY & 12 January 1998 AL DRICH File No. 10063-066

Office of City Manager City of Cambridge 795 Massachusetts Avenue Cambridge, Massachusetts 02139

Attention: Mr. Robert Healy

Subject: Groundwater Table Determination Russell Field, Cambridge, MA

Gentlemen:

At the request of W.R. Grace & Co. - Conn., we have reviewed your letter responding to Grace's proposal to determine the direction of groundwater flow in the vicinity of Russell Field using temporary wells. You have expressed concerns about the applicability of temporary wells to characterize the groundwater flow direction. Because of these concerns, you request that permanent wells be installed. You have also raised concerns about the condition of the wells currently existing on the Grace property and have requested modifications to Grace's original proposal.

OFFICES To evaluate your concern that temporary wells may not be suitable for determining Cleveland groundwater flow direction, we have again reviewed subsurface soil and depth to Ohio groundwater information available from previous studies in the area. In general, water levels Denver in wells installed in granular soils, such as sands and gravels, will stabilize quickly with the Colorado surrounding groundwater table. The time required for stabilization and concerns for water Hartford levels in wells being representative of surrounding conditions increase as the soils get finer, in Connecticut the silt and clay size ranges. Los Angeles California It appears that the underlying soils containing the groundwater table beneath Russell Field are Manchester primarily granular. They are expected to consist of fine sands ranging to a mixture of fine to New Hampshire coarse sands with varying amounts of silt. These materials are very conducive to the use of Newark small-diameter, temporary wells and there should be little to no stabilization time required to New Jersey obtain accurate measurements of depth to the groundwater surface in these wells. Therefore, Portland we believe that use of temporary monitoring wells will provide the required data. Maine Rochester To demonstrate that the groundwater levels have stabilized, we propose that the field work be New York scheduled such that all of the wells are installed in the morning and abandoned at the end of San Diego the day. Depth to groundwater levels will be obtained at two or three times over the course California San Francisco California Washington District of Columbia

Prninedon recyclt prr. City of Cambridge 12 January 1998 Page 2 of the day. Repeatable depth to groundwater data will be used to demonstrate that the groundwater levels in the wells have come to equilibrium and are representative. The work could still be completed in one day, so there would be no concern about possible tampering and vandalism.

The use of temporary wells does limit the collection of groundwater table information to only one point in time. Approximately ten years of groundwater level monitoring at the Grace site, however, indicates that while the groundwater levels do vary seasonally by approximately two feet, the overall direction and pattern of groundwater flow do not vary. It is Haley & Aldrich's opinion that the direction of groundwater flow will not change seasonally to be from the Grace property to Russell Field. To confirm this, Grace is willing to use temporary wells to again determine the groundwater flow pattern at a future time to be mutually agreed to by the City and Grace.

Your letter also expresses concerns for the integrity and reliability of the existing wells that have been proposed to be used to obtain a complementary groundwater flow pattern data set for the Grace property. We agree that, since it has been more than three years since the wells have been used and there are some wells with marginal cover systems, it would be prudent to recondition the wells before use. The wells will be redeveloped by systematic bailing and surging and the protective covers be reconditioned or restored, as necessary, prior to collection of groundwater level and water quality data.

The City has requested the opportunity to collect groundwater and soil samples during Grace's well installation program. We believe that the data gathering program proposed by Grace can be completed in substantially less than 8 hours. Grace is willing to make the GeoProbe subcontractor's remaining time available to the City. The City should be able to collect a substantial number of soil samples and groundwater samples in this remaining portion of the day.

You also requested permission to sample soils along the portion of the Grace property currently providing access to the MBTA headhouse. The details of this sampling program were not provided. It is assumed that the samples will be composite, surficial soil samples, similar to those proposed for the playing field. Grace will authorize this sampling upon confirmation that the sampling program is as we have assumed. We also request the right to split samples collected.

Lastly, we want to confirm that Grace will implement the long-term groundwater quality monitoring program recommended by Dr. Spengler for the Whittemore Street neighborhood when this work is executed. This activity will be undertaken on an annual basis and will incorporate the well locations suggested in his report. City of Cambridge 12 January 1998 Page 3

We believe this letter responds to your concerns and provides you with sufficient justifications to allow us to proceed with the proposed work using temporary wells. If you have any questions or require additional information, please do not hesitate to contact us.

Sincerely , ' HALE RICH, INC.

Wes ey E. 'so Senior Vice President c: W.R. Grace & Co. - Conn.; Attn: Mr. Robert Sorrentino

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JAN0 9 1998 Commissioner

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

Mr. David H. Bass 23 Norris St. Cambridge, MA 02140

Joseph J. Joseph . 20 Columbus Ave. Cambridge, MA 02140

RE: CAMBRIDGE - W.R. Grace Facility 62 Whittemore Street RTN 3-0277

Dear Sirs:

Thank you for your letter and petition dated November 20. 1997 regarding potential asbestos contamination at the former W. R. Grace facility in Cambridge, Massachusetts. Your letter requests that the Department require: an accounting of asbestos use and manufacture at the Cambridge facility: additional soil sampling and analysis for asbestos: and reevaluation of the regulatory status and potential risks posed by the site. You also raise concerns about disclosure of information by the Potentially Responsible Party (PRP) and the Licensed Site Professional (LSP).

As you know, the Department has privatized many aspects of the 21E Waste Site Cleanup program, leaving the direction of site assessment and cleanup activities at many sites under the purview of an LSP. Direct oversight by DEP is reserved for only the highest priority cases, those which pose the greatest risk to the public or the environment. One mechanism to provide a "check and balance" of the work being conducted under the redesigned 21E program, was the establishment of an Audit Section in each regional office. After receiving your letter. I asked the Chief of our Audits Section, Patricia Donahue, to contact the Licensed Site Professional overseeing response actions at this site and inquire into the status of investigations of the issues you raised. It is the Department's understanding that an evaluation of historical operations which may have used asbestos materials at the Whittemore Street facility is being conducted. Based upon the historical review, a sampling program will be initiated to determine if asbestos may have been released into the surrounding environment. It appears that W.R. Grace is being responsive to the communiry's concerns and that a complete audit of response actions is not necessary at this time. However, the Department wishes to keep in communication with the Alewife Study Group and W.R. Grace to resolve this particular issue.

10 Commerce Way Woburn, Ma. 01801 e Phone (781) 932-7600 9 Fax (781) 932-7615 * TDD # (781) 932-7679 ( Proted on Recycled Paper Alewife Study Group page 2

If your group has concerns regarding the Rules of Professional Conduct regarding the actions of an LSP. then the appropriate complaint forum is the Massachusetts Board of Registration of Hazardous Waste Site Cleanup Professionals ("LSP Board"). You may contact the LSP Board directly at (617) 556- 1091 for further information.

Meanwhile. I hope that the Alewife Study Group w ill continue its participation in the Public Involvement Process to ensure that the interests of the citizens of Cambridge are addressed. If you have any questions or comments, please do not hesitate to call Patricia Donahue at (781) 932-7730.

Very trui1 yours,

Laurel A. Mackay Deputy Regional Director Bureau of Waste Site Cleanup

cc: DEP/NERO/Files/Data Entry DEP/Boston. Commissioner's Office Cambridge City Council, Cambridge City Hall, 795 Massachusetts Ave., Cambridge, MA 02139 John DeVillars, U.S. EPA, JFK Federal Bldg., Boston. MA 02203 Karen Stromberg, DEP/NERO W.R. Grace Co., One town Center Road, Boca Raton. FL 33486-10 10 Attn: Mark Stoler, Chief Environmental Counsel W. R. Grace & Co., 62 Whittemore Ave., Cambridge. MA 02140 Attn: Robert Sorventino, V.P. Haley & Aldrich, Inc.. 465 Medford St., Suite 2200. Boston. MA 02129-1400 Attn: Wesley Stimson, LSP State Senator Warren Tolman, State House. Boston. MA 02133 State Representative Alice Wolf, State House, Boston. MA 02133 State Senator Robert Haven, State House- Boston. MA 02133 U.S. Senator Edward M. Kennedy, 2400 JFK Federal Bldg.. Boston. MA 02203 U.S. Senator John Kerry, I Bowdoin Square - 10th Floor. Boston, MA 02114 U.S. Representative Joseph P. Kennedy, 529 Main St.. Schraffis Bldg., Charlestown, MA 02129 Cambridge Main Library. 494 Broadway, Cambridge. MA 02138 North Cambridge Library. 60 Rindge Avenue. Cambridge. MA 02138 COMMONWEALTh OF MASSACHUSeTTE MASSACHUSETTS SENATE- STArE HOUSE, UO7ON 02ts-105a

SENAT H WAAWE L TCLMAN MiaoSNasu AND SungLI TAXATION (CCA.R OI6TNIC? INKSM AP40 SA'mC!%Q Room 434 $CST Ai.,o' AD Onfts1o- T1- t 17) 722-1 1W 7January 1998-A PAX jo 17; 7Un-I MV

David B. SAus, Conoissioner Department of Environmental Protection One Winter St, 3' floor Boston, MA 02108

Dear Commissioner Struhs:

I am writing on behalf of the Alwife Study Group, an organization which includes many constituents of mine, to ask for your assistance concerning problems at the former W.R. Grace site in Cambridge.

As you know, under the Massachusetts Contingency Plan process, this site was originally classified as a Tier II site; last year, an audit of the work done by the Licensed Site Professionai resulted in reclassification of the site as a Tier IC site, While I commend the work W.R. Grace, the LSP (Haley & Aldrich) and your department have done thus far, new evidence has surfaced which suggests tat asbestos manufacturing occurred on the site. According to Alewife Study Group members, no information concerning asbestos manufacturing appears in the repors and other data produced during the many previous examinations of this site. In light of this new information, and given the health hazard asbestos contamination could pose, I would ask that the Department reopen its examination of the site to Phase Ii, and consider reclassification of the site, so that the community can be sure that appropriate remediation takes place in the future.

Thank you for your attention to this matter. I understand the Alewife Study Group has sent you information concerning this matter, however, if I can be of further assistance, please call my office.

Sincerely,

Warren E. Tolman EDWARD M. KENNEDY

WASINGTON, DC 20510-2101

January 7, 1998

Honorable Trudy Coxe, Secretary Executive Office of Environmental Affairs 100 Cambridge Street, 20th Floor Boston, MLA 02202

Dear Secretary Coxe:

I am forwarding to you correspondence and information I have received from residents of north Cambridge. These residents are concerned about the area surrounding the Alewife T-station in Cambridge.

The residents are particularly concerned because of the proximity of the Alewife station, ard surrounding environs, to the W.R. Grace plant in Cambridge. It recently came to the attention of the community that asbestos manufacturing took place at the Grace facility in Cambridge. The residents feel that the testing in the area associated with the construction of the Alewife station done in the 1980's was incomplete. With the discovery of asbestos manufacturing, the citizens feel that more testing is warranted, especially to safeguard the health of the community and the employees of the MBTA.

Any assistare you may be able to render these residents would be greatly appreciated. If you have any questions. please feel free to contact Suzanne Morse in my Boston offce at (617) 565-3170. Thank you for your prompt and careful attention to this matter.

With best wishes,

-I cerei,:

Edward M. Kennedy

2400 JFK Federal Building Boston, MA 02203 - I

20 Chowa Avenue Cambridge, MA 02140 November 20, 1997

Senator Edward M. Kennedy United States Senate RSOB Washington D.C.

Dear Senator Kennedy:

You probably do not remember me. I worked for yo dining the 1980 primary. I'm wondering if you might help out people here in North Cambridge with a somewhat complex problem.

In 1919. the Dewey and Alm%Co. established a manufacturing facilit' for specialt chemicals at the present location of the W.R. Grace facility at 62 Whittemore Ae. here in Cambridge. Grace Co. took control of Dewey and Almy in 1954. and has continued the Dewey and Alm> operation through to the present day. manufacturing operations hase been reportedly ceased since 1983. Betw een that date and the present. it has been the objective of the company to develop the site.

BN 1985. the Alewife leg of the.MBTA subu ay system was built. In the process of construction. an adjacent playing field w"as utilized for storage of contaminated materials. Some neighbors believe that the field may have been a staging area for the solidification of acidic sludge. According to the rules of the MCP. the disposal area should now include the playing field. Without explanation of why its own rules do not apply. the DEP has refused to extend this boundary. When the sludge removal and solidification process was approved. it was done so with the condition that benchmark testing be conducted before. during and after construction. Although some of the original wells were destroyed. one survived. and according to the results. the sulfate conductivity levels increased steadily instead of decreasing at least until 1987 when the testing protocol was abruptly ended and the certificate of compliance was signed by the local conservation commission. We haN e Net to receive a specific answer as to why this the testing w\as ended or upon what basis the certificate was issued. Though suggested repeatedly b\ the conservation commission itself. no further remediation was done by the MBTA. We have met several times with Carmen's Union officials and T-workers who despite fearfulness with respect to privatization reprisals. conunue to gather information about their health related problems at the Alewife facilir\. The DEP shows no nclination to address this problem. If xe could obtain a copy of the original contract for the enure construction process we beliexe that it w ould answer many of the thus far unanswered questions concerning this matter. This contract. MBTA contract 901-508A is apparently. according to state and local officials nowhere in existance even though it was perhaps the largest single construction contract in Middlesex Count' in fifteen years. Neither the MBTA. nor the DEP. nor the City Manager of Cambridge. nor the Cambridge Conservation Commission (itself a party to the contract). nor the Cambridge DPW. nor the Cambridge City Law' Department. nor the Cambridge Community Development Department have a cop> of this contract. We have filed freedom of information requests and appealed the non-answers to the Secretan of States office all with no result. We believe that further construction at this site. pamcularly if it involves excavation will result in a "sick building" The owner. Grace Co.. holds a purportedly valid permit for 1.25 million square feet of construction with excax ated underground parking.

It has recently come to our attention that asbestos manufacturing occured at the W.R. Grace fazility. Although we are still gathering information about this. we feel that the included attachments with the letter to the MADEP Commissioner presents enough appropriate file documentation to xalidate the re!atcd assertions and justify the request. It is possible that the response from the DEP will be similar to their earlier response regarding the sulfate issue. Not desiring this, we would respectfully request that your office communicate with the MADEP and urge them to reopen the MCP to the Phase Two benchmark. In aitiom would it be pos e fr yaur office to request that de US EPA re4oWlve itself in the site in light ofthis ro t information. In 1985, EPA was involved in the site and did om excellent preliminary assessment and review of material stmitted to DEQE (now DEP) by the NUS Corporation. We wer disappointed to find that three quarters of the way through their work. they were withdrawn from the project with no substantial explanation as to why.

We would appreciate any and all assistance your office might proide us in this matter and are hopeful that we may be successful in obtaining more accurate Site characterization. Given the unusual risk factor associated with asbestos exposure. ne feel that this request is ncither unreasonable nor unusual. Please direct an%and all responses to the following persons:

Vicki Paret. Co-chair Alewife Study Group 122 Montgomery St. Cambridge. MA 02140

Joel Nogic. Co-chair Alewife Study Group 94 Clifton St. Cambridge. MA 02140

Thank 'ou for your attention to this matter.

r the Committee;

Joseph Josgph 0.'

0 'IT .1 5A CAMBRIDGE CITY COUNCIL CITY HALL, CAMBRIDOE, MASSACHUSETTS 02139 (617) 349-4280 FAX (617) 349-4287 Katherine Triantafilou TY'TDD (617) 349-4242 City Councillor

January 6, 1998

Commissioner David Struhs Department of Environmental Protection One Winter Street Boston, MA 02108

Dear Commissioner Struhs:

The matter of possible asbestos contammation at the W.R. Grace site (former Location of Dewey and Amy on Whittemore Avenue) has been brought to my attention by the Alewife Study Group. As you know, asbestos friction products were indeed produced by the Dewey and ALmy plant, and it is my understanding that ubestos testing has not been conducted at the site.

I am wfiting to lend my firm support to the Alewife Study Group's request for additional soil and asbestos testing at the site, in order to determine :there is any danger posed to our residents and our envirorment.

Thank you for your attention to this request.

Yourytruly, -14

kATHERINE TRIANTAFILL

kt;mh

cc: Alewife Study Group November 20, 1997

David B. Struhs M7 Commissioner Commonwealth of Massachusetts Executive Office of Enviromnental Affairs Department of Environmental Protection Metropolitan Boston - Northeast Regional Office

Dear Commissioner Struhs:

It has come to the attention of members of the North Cambridge community that the history of chemical processing and production by W.R. Grace at the 62 Whittemore Avenue facility provided by Hales and Aldrich for their client W.R. Grace (RTN #3-0277) in their Environmental Data Report is substantially incomplete. It is clear from historical records that extensive manufacture of asbestos friction products occurred at this facility. but nowhere in any data assessment submitted by W.R. Grace to the DEP, including their multi-volume Environmental Data Report completed in 1988 and the LSP's 1995 Compliance Historv Summary. is there any mention of such activity and no field testing for asbestos has ever been done. The purpose of this letter is to request that the Phase 11of this site be re-opened and that additional and extensive soil sampling and analysis for asbestos be conducted at the Whittemore Avenue site.

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

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

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

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

Specific asbestos friction products manufactured

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

"Certain brake linings. especially those for heavy work. are made from asbestos to which carbon black and other substances may be added. and rubber latex. The various materials are mixed in a paper beating machine, spread on a wire screen and the water sucked out, then pressed in a hydraulic press. cured and brought to the proper thickness with a sanding machine." (see page three 'Notes on visit to Dewey & A /mv Chemical Co., on November 27, 1934 and December 1, 1934 and to Multibestos Company, Walpole, on November 28, 1934 "; document;= 2). File documentation included with this letter reflects that the Walpole Multibestos facility did in fact supply or at least partially supply the Cambridge facility with raw asbestos. On page 6 of the Workman's Compensation Report to the Industrial Accident Board filed by John Lightbody in 1933, the following description is given:

"When he left the weave room on June 26. 1925, he went to work on the truck immediately. At times witness would be in contact with asbestos dust for a half a day - that would be when he would bag it up and bring it to Cambridge." (see document 24 page 6)

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

Request for additional and extensive soil sampling and analysis for asbestos

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

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

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

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

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

Required disclosure by the Licensed Site Professional

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

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

Requested action by W.R. Grace

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

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

Submitted on behalf of the Alewife Study Group.

-IIt

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

cc: Cambridge City Council John DeVillars. U.S. EPA Karen Stromberg. DEP David Wightman. W.R. Grace Co. Wesley Stimson. LSP State Senator Warren Tolman State Representative Alice Wolf State Senator Robert Havern U. S. Senator Edward M. Kennedy U. S. Senator John Kerry U. S. Representative Joseph P. Kennedy 12/02/97 17:29 GRACE LEGAL CAMBRIDGE * 'V NO. 858 [02

crTY OF CAMBRIDGE CAMBRIOt MASANKUSrSO*02" TEA 349-4300 0 A % faz 349-437

EMECU'Ra OIPARIMENT Rosen? W. HSALY city ManboBr

R10HARD 0. POSM 0eputy Oity Manugof

November 25, 1997

Robert Sorentino Vice President, Engineering and Manufacturing Support Grace Construction Products W.R. Grace & Co.-Conn. 62 Whittemore Avenue Cambridge, MA 02140-1692

Re: Proposed groundwater study

Dear Mr. Sorentino:

I am writing in response to David Wightman's November 1996 letter to the Ciy of Cambridge and subsequent discussions with W.R. Grace's Licensed Site Professional regarding your proposed plan to complete groundwater contours in the Russell Field and Clifton Street areas as required by the Department of Environmental Protection (DEP). The City has some concern regarding the adequacy of the proposed program, and we would like to recommend some modifications of the program in order to uly meet the requirements set forth by DEP in its audit findings report. We would also like to coordinate the scheduling of the groundwater flow assessment to be done by WJL Grace with other City environmenal investigations scheduled to take place in January 1998 at the adjacent Russell Field. Finally, we would like to clarify the City permitting requirements for work on City property.

We understand that your plan proposes installation of 5 to 7 temporary punch wells on public property and measurement of groundwater elevations in those wells. In addition, your consultant will survey groundwater levels and collect water quality samples from 12 existing monitoring wells on the W.R. Grace property. The City's concerns are detailed below: 12/02/97 17:30 GRACE LEGA CAMBRIDGE N0.858 6U4

Page 3 Letter to W.R. Grace, 11.25.97, re: Groundwater Study

As you are likely aware, the City will be collecting soil gas, groundwater, soil, and sediment samples in the Russell Field area starting on December 1, 1997. In connection with this sampling program, we request your authorization to take samples from locations controlled by W.R. Grace for the following:

o Water samples from several W.R. Grace site wells to complemet testing of the Russell Field property. The purpose of this sampling is to establish baseline data for comparison purposes. a Both soil and groundwater samples from wells installed by W. Grace on City property. The site LSP for the Grace property has previously indicated that conducting this sampling would not likely be problematic, but stated that final approval would have to come from W.R. Grace.

* Surface soil samples along the MBTA easement that bisects your property. I hope that the groundwater work proposed by W.R. Grace and the City's testing program will complement each other. Working cooperatively, our common objectives of assuring public health and safety can be met.

If you have any questions, please contact Susanne Rasmussen, Environmental and Transportation Planning Director at 349-4607.

Robert W. Healy City Manager

/JBDos/RusSELLHEI/SORENrmoIBW.DOC P Ob3 965 724 US Postat Service Reteipt for Certified Mall No insurance Coverage Provided. Do not use for International Mail (See reverse)

Strel& umber Post Office, State, &ZIP Code (

Postage $ Cered Fee

Special Delvery Fee

Restricted Delivery Fee Return Receipt Showing to Whom & Date Delivered 6n 0 Reton Receit lrWtr toWioN, Dale, &Addessee cc TOTAL Postage & Fees $ Postmark or Date

C U.. &/1ZO1?7 fk *O

COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECION METROPOLITAN BOSTON - NORTHEAST REGIONAL OFFICE

WILLIAM F. WELD TRUDY COXE Governor Secretary

ARGEO PAUL CELLUCCI DAVID B. STRUHS Lt. Governor Commissioner

CERTIFIED MAIL 7 IbI RETURN RECEIPT REQUESTED

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

Attn: Mr. David Wightman

RE: CM4BRIIOGE - W. R. Grace Company ,62 Whittemore Avenue RTN 3LO277 Permit Number: 118529 PERMIT EFFECTIVE DATE

Dear Mr. Wightman:

Attached please find the first page of the Permit for the above referenced site, indicating the Permit's Effective and Expiration dates. Please attach this page to the Permit Statement already in your possession.

The Department is urging you to review and familiarize yourself with the Permit's terms and conditions and the Massachusetts Contingency Plan (MCP), 310 CMR 40.0000, in order to complete the required response actions within the timelines set forth therein.

Please note that the Department may perform an audit of this site in the future, in order to ensure compliance with the terms and conditions of the Permit and the requirements of the MCP. Should this site become a candidate for an audit, you will be notified promptly.

10 Cormmerce Way 0 Woburn, Massachusetts 01801 1 FAX (617) 932-7615 0 Telephone (617) 932-7600 0 TDD # (617) 932-7679 (W.R. Grace & Co.-CS.) Page 2

If you have any questions, please contact Ida Babroudi at the letterhead address or by telephoning (617) 932-7600.

Very truly yours,

ris W. Davis, Section Chief (7g Permits/Risk Reduction Bureau of Waste Site Cleanup

Attachment- first page of Permit

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

List of Petitioners/Public Commenters:

cc: Alma Balonon-Rosen, Key Petitioner, 51 Madison Avenue, Cambridge, MA 02140 Joseph Joseph, Key Petitioner, 20 Columbus Avenue, Cambridge, MA 02140 Peter V. Cignetti III, 5 Theriault Ct., Cambridge 02140 Craig Kelley, 6 St. Gerard Terr., Cambridge 02140 Hanna Goodwin, 94 Clifton St., Apt. #2, Cambridge 02140 Steve Schnapp, 32 Clay St., Cambridge 02140 (continued)

EFF.DAT/1-17-96 (W.R. Grace & Co.-Ci.) Page 3

Lewis Weitzman, 124 Montgomery St., Cambridge 02140 Vicki Kocher Paret, 122 Montgomery St., Cambridge 02140 Susan Maguire, 125 Jackson St., Cambridge 02140 Elizabeth W. Birk, 20 Columbus Ave., Cambridge 02140 Paul Miranda, 125 Jackson St., Cambridge 02140 Aram Hollman, 15 Clifton St., Cambridge 02140 Susan & Victor Polsinski, 104 Clifton St., Cambridge 02140 Patricia A. Casola, 364 Rindge Ave, Apt. 17B, Cambridge 02140 Joel Nogic, 94 Clifton St., Apt. #2, Cambridge 02140 Alison Dowd, 115 Harvey St., Cambridge 02140 Helen Flynn, 111 Clifton St., Cambridge 02140 Janet Malenfant, 16 Harrison Ave, Cambridge 02140 Don Abrams, 17 Day St., Cambridge 02140 Sylvia Barnes, 196 Harvey St., Cambridge 02140 Malvina Montero, 85 Harvey St., Cambridge 02140 Lisa Burk, 28 Magoun St., Cambridge 02140 Catherine E. Koletsky, 50 Churchill Ave, #133, Cambridge 02140 Ann Barns, 50 Churchill Ave, Cambridge 02140 Richard D. Clarey, 15 Brookford St., Cambridge 02140 Carolyn Mielt, 15 Brookford St., Cambridge 02140 Resident, 16 Seagrave Rd., Cambridge 02140 Resident, 29 Harrison Ave, Cambridge 02140 Massachusetts Sierra Club, Greater Boston Group, 3 Joy Street, Boston, MA 02108 Attn: Cindy DelPapa, Conservation Chair

EFF.DAT/1-17-96 0 Q Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup (BWSC) TIER I PERMIT

This Permit is issued to: For DEP Use Only Effective Date: 2/13/1997 Permittee X One Expiration Date2 13/2002 El More than One Permittee*

*A list of all Permittees is attached.

One Permittee:

Name of Organization: W.R. Grace & Company - Conn. Permittee Name: W.R. Grace & Company - Conn. Title or c/o: Mr. David Wightman Street: 62 Whittemore Avenue City/Town: Cambridge State: MA Zip code: 02140-1692 Telephone: (617) 498 - 4983

DEP Findini Concemin2 Tier Classificadon

: Tier IA (BWSCO1) o Tier IB (BWSCO2) X Tier IC (BWSCO3) Permit No. 118529

This permit authorizes the performance of comprehensive remedial response actions it:

Disposal Site Number: 3-0277 Disposal Site Name: W.R. Grace Co. Street: 62 Whittemore Avenue City/Town: Cambridge State: MA Zip code: 02140

Unless a request for an adjudicatory hearing is made pursuant to 3 10 CMR 40.0770, this permit shall be effective 21 days after the date of issuance by the Department and the receipt of the signed Permit Acceptance Statement, whichever is later. The Permittee has 30 days from the date of issuance of this Tier I Permit to sign and submit the completed Permit Acceptance Statement to the Department.

This permit shall expire 5 years from its effective date.

Tier I Permit 1/02/96n 0 0 Permit Conditions; Pursuant to 310 CMR 40.0740:

(1) The permittee(s) performing response actions pursuant to this Tier I Permit shall comply at all times with M.G.L. c. 21 E, 3 10 CMR 40.0000, the terms and conditions of the permit and any other applicable federal, state or local law.

(2) In every proceeding, the burden shall be on the Permittee to demonstrate compliance with the terms and conditions of a permit at all times.

(3) Each Permittee shall comply with: (a) submittal of a Class A, B or C Response Action Outcome Statement within five years of the effective date of the permit, unless otherwise provided in the permit; (b) submittal of a copy of the signed and completed Permit Acceptance Statement required by 3 10 CMR 40.0750(2) to the Chief Municipal Officer(s) and the local boards of health for the communities where the disposal site is located, and to any member of the public identified in the Department's Statement of Basis. (c) notification in writing to the Department: 1. as required in 310 CMR 40.0500; 2. upon gaining knowledge of any technical, financial or legal inability to perform any necessary response action, in accordance with 3 10 CMR 40.0172; 3. upon a decision by a permittee who is performing response actions as an Other Person to not proceed as required by the permit; and 4. of any change in the LSP of Record for the disposal site no later than ten days after the effective date of such change through the filing of a Minor Permit Modification by the permittee in accordance with 3 10 CMR 40.0725; (d) compliance with: 1. all applicable submittal requirements, including but not limited to, scopes of work, Status Reports, Completion Statements, Phase Reports, and RAOs; 2. all requirements for record keeping and document retention, including but not limited to 3 10 CMR 40.001 4, 3 10 CMR 40.0022 and 310 CMR 40.0023; 3. the Notification Regulations, 3 10 CMR 40.0300, in the event of discovery of new releases located at the disposal site, threat of release or Imminent Hazard; 4. the management procedures for excavated soils and wastes and requirements for remedial air emissions set forth in 3 10 CMR 40.0030 and 310 CMR 40.0040; and 5. all public involvement activities required by 3 10 CMR 40.1400 through 40.1406; (e) inclusion of the Disposal Site Number and the permit number on documents submitted to the Department with respect to the disposal site; (f) certification of documents submitted to the Department as required by 3 10 CMR 40.0009; (g) evaluation of the need to perform Immediate Response Actions in accordance with 3 10 CMR 40.0400 as new or additional information about the disposal site is obtained;

Tier 1 Permit 1/02/96n 2 'II

(h) modification or cessation of any response action as necessary to maintain compliance with any permit condition or to prevent an actual or potential threat to health, safety, public welfare, or the environment; (i) notification, orally or in writing, to the Department within seventy-two hours of obtaining knowledge of the need to modify or cease any response actions for the reasons in 310 CMR 40.0740(3)(h); provided that any such oral notification shall be confirmed by the permittee in writing within sixty days of such oral notice and any written notice shall include a Status Report prepared by an LSP; and timely remediation of any adverse impacts to health, safety, public welfare or the environment that result from the performance of response actions; (i) at disposal sites where groundwater investigation is necessary, delineation of the vertical and horizontal extent of contamination, identification and confirmation of groundwater flow directions, identification of groundwater migration pathways, including but not limited to, the identification of possible partitioning of dissolved volatile organic compounds at the water table interface which may lead to vapor transport into subsurface structures, homes or other occupied or unoccupied buildings, and monitoring of groundwater wells, discharges and/or other monitoring points in a manner which provides for the timely development or representative information about conditions and changes in conditions at the disposal site; (k) acquisition of all required federal, state and local permits; (1) proper operation and maintenance of all treatment, storage, abatement or control systems and of all equipment required to continue or complete response actions; (m) authorization for personnel and authorized agents of the Department to enter, at reasonable imes and upon the presentation of credentials, any premises owned or controlled by the permittee for the purpose of investigating, sampling, or inspecting any records, conditions, equipment, practice or property relating to response actions at the disposal site, or protecting health, safety, public welfare, or the environment; and (n) notification upon a change of the Primary representative as required by 310 CMR 40.0703(7), if one is designated.

(4) A Tier I Permit does not grant any property rights or exclusive privileges, nor does it authorize any injury to private property or invasion of property rights.

Special Conditions; Pursuant to 310 CMR 40.0740(3)(o):

Each permittee shall comply with all Special Conditions if attached to this permit in Attachment A. Special Conditions are included within this permit:

Yes* X No

*Note: Pursuant to 310 CMR 40.0722(6)(c). a "Statement of Basis" for this pemit decision has been prepared by DEP if special conditions are included with this Pemit. DEP Authorization Issued by the Department of Environmental Protection:

Name (Print): 7. Date of Issuance: /9 7

Signature pat

Tier I Permit 1/02/96n 3 Notice of Appeal Rights

Any person aggrieved by a decision of the Department with respect to any Tier I permit application may request an adjudicatory hearing before the Department in accordance with M.G.L. c. 21E and 310 CMR 40.0050 and 40.0770, within 21 days of the date of issuance of the Tier I permit, if:

a) the Department issues a permit for a classification higher than that stated in the LSP Tier Classification Opinion; or b) the Department denies the applicant a permit, unless the Department notifies the applicant in the permit decision that the Department intends to undertake or arrange for the performance of necessary response actions at the disposal site; or c) The Department imposes conditions pursuant to 310 CMR 40.0730(1)(h) and 40.0740(3)(o) without the applicant's consent.

Tier I Permic I 1'02/96n 4 This Attachment will be completed by DEP

ATTACHMENT A TO PERMIT NO. 118529

Each Permittee shall comply with the following special conditions:

X Check here if not applicable to this permit.

6 ATTACHMENT 2 P 063 965 638 US Postal-Service Receipt for Certified Mail No Insurande Coverage Provided. Do not use for Intemational Mal See rover) Sent to & (I- Stree & Number

Post Office, State, & ZIP Code

Postage $

Certified Fee

Special Delivey Fee

Restricted Delivery Fee Lo SRetun ReceiptShowing to Whom & Date Delivered I L Retun Recet Shmwngto Whom, Dale, &Addressee's Address TOTAL Postage & Fees $ Postmerk or Date t1iL U), CL )46ch. COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION METROPOLITAN BOSTON - NORTHEAST REGIONAL OFFICE

WILLIAM F. WELD TRUDY COXE Governor Secretaty

ARGEO PAUL CELLUCCI DAVID B. STRUHS Lt. Governor Commissioner

23 1997 CERTIFIED MAIL RETURN RECEIPT REQUESTED

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

Attn: Mr. David Wightman

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

DECISION TO GRANT PERMIT

Dear Mr. Wightman:

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

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

10 Commerce Way 0 Woburn, Massachusetts 01801 0 FAX (617) 932-7615 * Telephone (617) 932-7600 * TDD # (617) 932-7679 W.R. Grace & Co.-Conn. Decision to Grant Permit Page 2

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

Any request for an adjudicatory hearing must be made within twenty-one days of the date on which the Department issued the permit. Please refer to 310 CMR 40.0770 and 310 CMR 40.0050 for conditions under which an adjudicatory hearing may be requested.

If no request for an adjudicatory hearing is made, this permit shall become effective twenty-one days after the date on which the Department issues the permit and the Department's receipt of W.R. Grace's signed Permit Acceptance Statement, whichever is later.

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

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

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

* A risk assessment addressing all potentially affected receptors;

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

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

GRANT/1-17-96 W.R. Grace & Co.-Conn. Decision to Grant Permit Page 3

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

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

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

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

In accordance with 40.1405 and other provisions for Public Involvement Plan (PIP) sites, W.R. Grace shall solicit, consider, address and, where relevant and material to the response action, incorporate into decisions regarding response actions at the disposal site, concerns, information and comments from the public.

With respect to the adequacy of the Phase III Feasibility Evaluation previously provided to the Department, this report has not been approved by the Department, and therefore the site is still considered in Phase III. As required by 310 CMR 40.0550 (2) (b), W.R. Grace shall complete the Phase III report, prepared in strict accordance with 310 CMR 40.0850 of the 1993 MCP (as amended), within two (2) years of the effective date of this permit. As part of the Phase III Remedial Action Plan, W.R. Grace

GR.ANT/1-17-96 W.R. Grace & Co.-Conn. Decision to Grant Permit Page 4

must consider the community's concern with the adequacy of the existing Feasibility Study.

W.R. Grace is hereby reminded that the MCP requires that the feasibility of reducing the concentrations of oil and hazardous material in the environment at the disposal site to levels that achieve or approach background must be determined. In consideration of the provisions outlined at 310 CMR 40.0860, if such a reduction is feasible and beneficial, then the implementation of necessary Comprehensive Response Actions to approach or achieve background levels of contamination shall be undertaken.

Numerous comments were also submitted concerning the potential for contaminated groundwater to impact the Harvey Street/Clifton Street neighborhood. To address this concern, W.R. Grace notified Kathleen Brown from the City of Cambridge's Community Development, Environmental and Transportation Planning Department, in writing, that W.R. Grace will be completing an elevation survey of groundwater levels in this area in the very near future. A facsimile of this letter was submitted to the Department on January 10, 1997. Should such a survey indicate a potential for contaminated groundwater to migrate toward and potentially affect residences in this neighborhood, then additional investigations and if necessary, response actions shall be conducted to mitigate such conditions by W.R. Grace. It should also be noted that in accordance with 310 CMR 40.0411 (7) W.R. Grace must continually assess and evaluate site conditions in order to determine if an Immediate Response Action is required.

With respect to concerns regarding the stockpiling of material at Russell Field, this concern was addressed by the Department in the September 20, 1996 Notice of Audit Findings to W.R. Grace. The Notice of Audit Findings stated that based on the photographs documenting the reconstruction of Russell Field, the conclusion is that the observed sandy fill was brought to Russell field from a location other than the disposal site. However, to definitively resolve the issue, a test pit/boring and environmental testing program is recommended. It may be prudent to do this testing program as part of activities associated with the improvement of the Russell Field recreational facilities.

The Department believes that sufficient information exists to adequately characterize the potential for flooding in the area of the disposal site. The storm of October 1996 demonstrated that the disposal site and the surrounding community are located in the flood plain of Alewife Brook. However, the presence of contamination at the disposal site neither lessens nor increases the potential for flooding in the Alewife area. The issue of preventing future flooding should be addressed,to the extent possible, by the City of Cambridge in concert with those potentially affected.

GR.ANT/1-17-96 W.R. Grace & Co.-Conn. Decision to Grant Permit Page 5

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

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

Sincerely,

SEdward J. Weagle Iris W. Davis Environmental Analyst Section Chief, Permits/Risk Reduction Bureau of Waste Site Cleanup

Attachments: Permit and Permit Acceptance Statement (2 copies)

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

(continued)

GR.ANT/1-17-96 W.R. Grace & Co.-Conn. Decision to Grant Permit Page 6

List of Petitioners/Public Commenters:

cc: Alma Balonon-Rosen, Key Petitioner, 51 Madison Avenue, Cambridge, MA 02140 Joseph Joseph, Key Petitioner, 20 Columbus Avenue, Cambridge, MA 02140 Peter V. Cignetti III, 5 Theriault Ct., Cambridge 02140 Craig Kelley, 6 St. Gerard Terr., Cambridge 02140 Hanna Goodwin, 94 Clifton St., Apt. #2, Cambridge 02140 Steve Schnapp, 32 Clay St., Cambridge 02140 Lewis Weitzman, 124 Montgomery St., Cambridge 02140 Vicki Kocher Paret, 122 Montgomery St., Cambridge 02140 Susan Maguire, 125 Jackson St., Cambridge 02140 Elizabeth W. Birk, 20 Columbus Ave., Cambridge 02140 Paul Miranda, 125 Jackson St., Cambridge 02140 Aram Hollman, 15 Clifton St., Cambridge 02140 Susan & Victor Polsinski, 104 Clifton St., Cambridge 02140 Patricia A. Casola, 364 Rindge Ave, Apt. 17B, Cambridge 02140 Joel Nogic, 94 Clifton St., Apt. #2, Cambridge 02140 Alison Dowd, 115 Harvey St., Cambridge 02140 Helen Flynn, 111 Clifton St., Cambridge 02140 Janet Malenfant, 16 Harrison Ave, Cambridge 02140 Don Abrams, 17 Day St., Cambridge 02140 Sylvia Barnes, 196 Harvey St., Cambridge 02140 Malvina Montero, 85 Harvey St., Cambridge 02140 Lisa Burk, 28 Magoun St., Cambridge 02140 Catherine E. Koletsky, 50 Churchill Ave, #133, Cambridge 02140 Ann Barns, 50 Churchill Ave, Cambridge 02140 Richard D. Clarey, 15 Brookford St., Cambridge 02140 Carolyn Mielt, 15 Brookford St., Cambridge 02140 Resident, 16 Seagrave Rd., Cambridge 02140 Resident, 29 Harrison Ave, Cambridge 02140 Massachusetts Sierra Club, Greater Boston Group, 3 Joy Street, Boston, MA 02108 Attn: Cindy DelPapa, Conservation Chair

GR.ANT/1-17-96 MEMORANDUM

TO: File

THROUGH: Ida Babroudi, Environmental Engineer IV

FROM: Edward Weagle, Environmental Analyst

DATE: January 14, 1997

SUBJECT: CAMBRIDGE - W.R. Grace Co., 62 Whittemore Avenue RTN 3-0277, PERMIT # 118529

TECHNICAL REVIEW FOR PERMIT APPLICATION

The purpose of this memorandum is to review the activities conducted at the above-referenced location (the site) as part of the Department's review of a permit application for the site.

Background

Please refer to the Department's Notice of Audit Findings dated September 20, 1996, as well as other file documentation, including various other correspondence and memoranda prepared by the Department, for a description of site conditions, including geology, groundwater hydrology, contamination sources, potential receptors, and a history of response and Department required actions.

Also contained in the Department's Notice of Audit Findings are the Department's observations during a May 3, 1996 site inspection, and a review of the Department's evaluation of Mr. Wesley Stimpson's (the LSP-or-Record for the disposal site) scoring of the site pursuant to the Numerical Ranking System, 310 CMR 40.1500.

Required Review Criteria

Section 40.0730 (1) of the 1993 MCP 310 CMR 40.0000 outlines the criteria to be considered in the review of all Tier I Permit Applications. In accordance with 310 CMR 40.0730 (1), the Department has considered the following criteria in the issuance of this permit:

a) existence, source, nature, and extent of release;

The existence, source, nature, and extent of release are discussed in the Department's Notice of Audit Findings, as well as in various other correspondence and memoranda prepared by and present in the Department's files. CAMBRIDGE, RTN 3-0277, W.R. Grace Co. Technical Review for Permit Application Page 2

b) nature and extent of danger to health, safety, public welfare and the environment posed by the disposal site;

The nature and extent of danger to health, safety, public welfare and the environment posed by the disposal site are evaluated in the Risk Assessment approved by the Department.

c) magnitude and complexity of the actions necessary to assess, contain, or remove the OHMs in question;

Assessment activities to be performed at this site may likely include the installation of additional soil borings and/or monitoring wells and the collection of soil and groundwater samples, if necessary. Remedial activities could include soil excavation and treatment/disposal, soil vapor extraction and treatment, air sparging, and/or groundwater recovery and treatment. These assessment activities and remedial alternatives are straight forward and well understood.

d) the extent to which there are legally enforceable standardized methods and criteria available for response actions;

Cleanup criteria for the contaminants at the site are established in the MCP (310 CMR 40.0000) and other Departmental policies.

e) the extent to which DEP is persuaded that the applicant has the ability and willingness to perform necessary response actions;

The applicant has demonstrated a willingness to perform necessary response actions by historically working with the Department to define the extent of and the risks posed by the contamination at the disposal site. In addition, the applicant has certified in accordance with 310 CMR 40.0703 (9) (a) that the applicant has the ability and is willing to perform necessary response actions at the disposal site.

f) applicant's compliance history with 21E and other regulations;

No outstanding issues of non-compliance are noted. Previous issues of non-compliance have been addressed by W.R. Grace to the satisfaction of the Department. CAMBRIDGE, RTN 3-0277, W.R. Grace Co. Technical Review for Permit Application Page 3

g) the extent to which DEP oversight is necessary to ensure compliance with the new MCP;

All response actions previously implemented by W.R. Grace have been done so under the supervision of the Department. Based partially upon the work completed under Departmental supervision, direct Departmental oversight at this time is not necessary to ensure compliance with the MCP. All future response actions would have to be overseen and approved by a Licensed Site Professional.

h) any permit conditions developed pursuant to 310 CMR 40.0740 (3) (o) to which the applicant has consented; and

None are recommended.

i) any other factor the DEP deems relevant to the decision.

No other factors are deemed relevant to the issuance of this permit. 01/19/97 1w:-. CAMBRIDGE ENVIRONMENTIL PROGRAM - 14137941100 NO. 226 002

nvdI W'ighrmcr. Vice Preodent, Admiritroton - Producs Grace Costucion

W,/,EP.R. 412 0a& ,Co-Cnn. Cambridge, Mai 02140-1692

ol'!-) -4983 Tel 16 17) 491029 Fox.

Novernber 26, 1996

MS. Smsal B. SUlIlesr;:-r A ssuttant Cisty Managei ro Cumunity' Devr.lnpmnenr City Hell Anne: S7 Inman Street Canbridge, MA O2l

Dear Ms. Scdle~iuio.

Atiuced i a plan prepared by our geo-technical conulrints, Hmley & A ldrich. designed to provide sufitcient gromiudwarer level dam to enable the completion of -roundwater crntoutt in the areas of Kusell Field 1nd the Clifton Street neighborhoid. This plan inckides the establishment of S tc I temporary "punch wells" on Russell Field which, together with the pround watc levels deiesnir&d fnom emsing permanent wells locared on Grace pmprry. will fully ctin rmrre the groundwater flow pattern in the subject ar4 , ; e]l ak clowing the impuct if any, of tho MBTA tumu 1 ui: this flow paLlrn. A the plan indicates, ny groundwater levelq will be determined. No chemical analyeun of water :amples will be perforned b" Grace upon groundwatcr cxtractcd frmin these temporary wells.

SimulTaneously with this effort, Grace will conduct its normal annual "Long-'erm Monitoring Program" and publish the total findings in a singlc report so as custcnmaIy 0uvcmmument -gencia Mid tie geieral public will haue tull access to the developed information. We believe this voluntary action on the part of Grace to dccimie rIe guluuilwaui fluw pamaieri under uur City oif Cmhriger prprn-ry fmlfilk nur rnmrniitnen.t to you and complies with thu r, onunendnionu ofbotb Dr. Spangler i hi3 Envromcntal I-eth and Enginecring Repurl and the Mam:whirs OFP ir their Norice ofAudir Findings

We intend to complete thlis resting between now and the end of the ycar ubjecr to availability of equipment and your approval to access Russll Ficld forTthe purpose of this tCstIng. We would appreciate your written approval for access to Russell Field to conduct tis testing. Once recewm d, representaives of Haley and Aldrich will contact you to arrange for a utually cumcuicIu date 0tcoiduct hcetesting.

Ifysi reqiirr any furher infnrmanton piease contact mr directly pt 4.401.

:hn'errly,

id..vi i an Allt

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CIT Y OF CAMBRID GE M I NIT V D EVELOPMENT DEP A RTMENT hf'H/iK('NI \I Ai :, SRAN )I0KTA]J i N L NN ' En K N 'I PA L TT PL A N NTITN GHE

FAC lMILE TR ANSMITTAL SHEET

PRO. Ed "Xcaglc Kathleen Brown A n y 1 DEP January if), 19)9/

iSE N Ot.1WR Tt( VAX NUMBER: 413-.7f?-- 1 4 349-4633 VHI )NI NIILI K PHONE NI'UMT: 411-7X4-1 10 x 221 349-462R

ro o riA . N). OF PALAI lNLLtDiNG CuVEU:

fl T1C.G [ R REVIEW 1 L'LEASE COMMENT 0 PLE ASG REPLY U PLEASE RECYCL.E

NUTF.' .MM' 7''T5:

This is the Iper n ln w received ii m W.R Gnc for proposed groundwater work by Haley & Aldich. Also FY [ :m fGxing y ou an areUCI on the lawsuit filed by Grace as well &Is an editorial on the subject. I hope ths iner idn i helpful. Since it appcars your involvemflent with the site is winding down, is there oeon. NRRO I should contact in the fuun? Fee l frie to call or email me (kwbrownpcicambridg mi). Thanks for your help.

- Kathleen

57IwJAN STREL'. r mu.&4FKIItr MA 2IJn EMAIL: KWB.UWNGC.CAMIERIDCI-IA.US THE HALEY AND ALDRICH STUDIES OF THE W.R. GRACE SITE IN NORTH CAMBRIDGE

A CRITIQUE AND CALL FOR NEW RESEARCH

LEWIS WEITZMAN

DECEiEBER 1996 Critique of the Haleg and Rldrich Studies:

I believe the Haley and Aldrich studies concerning contamination at the W.R. Grace site in North Cambridge are flawed and therefore unreliable. The DEP ought to reevaluate its position vis a vis this site and order a new round of independent testing. To support my position I will examine one aspect of the Haley and Aldrich studies-- subsurface soil sampling-and will show that there are enough flaws in this one area alone to discredit the research. I will show that the Haley and Aldrich studies have produced a much smaller pool of viable data than previously thought and that they have misstated this number within their own report. I will also show that what data exists cannot be relied upon to represent the whole picture of chemical pollutants on the W.R. Grace site.

(1) The 1984-85 Soil Sample Tests Have Been Widely Discredited

Haley and Aldrich conducted two series of studies of the Grace site. The first was performed in 1984-85 in conjunction with their master development plan' and the second was performed in 1986-872 in response to concerns about their first study. DEQE led all other critics of the 84/85 study by issuing a 'notice of responsibility' (NOR) requiring among other things more scientific data. Dr. John Spengler of Environmental Health Engineering. appears to represent other professionals in the field of environmental science who question the credibility of this data. In his 1996 review of research on the Grace Site for the city of Cambridge he referred to the Haley and Aldrich 1984/85 report as "a few preliminary samples from 1984-85".3 Among the many criticisms leveled at this report Is the use of composite

1Haley and Aldrich, Subsurface and Hydrogeological Conditions for the Alewife Center Master Plan Study, 1985 2Haley and Aldrich Inc., Environmental Data Report For the W.R. Grace and Co. Property in Cambridge, Massachusetts , April 1988. 3 Environmental Health Engineering Inc., Final Draft Public Health Risk Evaluation For W.R. Grace Site in Cambridge, Massachusetts by , April 23, 1996, p.12.-

2 0 0 sampling (the combining of several soil samples in an effort to arrive at an average sampling). The 1986/87 studies are really the first serious attempt to generate meaningful data therefore I will concentrate my analysis on the data generated by these studies.

(2) The 1986/87 Database is Smaller Than Suggested in the Report

The maps and illustrations in the Haley and Aldrich 1988 Report suggest that the soil on the Grace site has been exhaustively sampled and analysed. A first look at the numbers also suggests this: 120 test pits were dug. In each test-pit up to 3 soil samples were taken for a total of more than 300 soil samples. 4. Had all of these soil samples been carefully analyzed there would have been a strong database from which to work. This was not the case. Less than one quarter of these soil samples were completely analyzed for priority pollutants, volatile organic compounds (voc's) and other contaminants. The rest went through a simple screening for grease and were then thrown out. This procedure led to some inexplicable gaps in information. 92 test-pits had been dug to test the soil in areas where the proposed buildings were to sit, however only 54 of those test-pits had been completely analyzed for soil contaminants! The other 38 test-pits were essentially untested. 28 test-pits had been dug in areas outside the proposed building footprints In an attempt to identify sources of contamination throughout the site. 2 of these test-pits received only a grease screening while 3 were composite sampled. That makes 5 of these 28 test-pits Incompletely and/or invalidly analyzed. Haley and Aldrich state that"approximately one sample per test-pit was submitted for this full suite of analysis".5 It is difficult to see how they can make this claim given the Information I have presented above.

Here then is the existing database for completely analyzed, valid sub-surface soil samples from the W.R. Grace site in North Cambridge as generated by the Haley and Aldrich research firm during a five year series of studies:

---54 soil samples on the proposed building sites 7 7 S. 1 -23 soil samples outside the proposed building sites Ja7yJ

4 Haley and Aldrich, 1988, p.IV-1 5 Haley and Aldrich, 1988, p.IV-2.

3 (3) The Siting of the Test-Pits was Flawed.

Of the 120 total test pits Haley and Aldrich state that, "ninety-two of these test pits were excavated to evaluate soil quality within proposed building sites 2 to 7". In other words the location of the test-pits was intended to best facilitate the planned development rather than provide the best location to evaluate the Grace site as a whole. To make up for this deficit Haley and Aldrich conducted a series of tests outside of the building sites called the ' source identification' tests. Improbably there were only 28 test pits dug during this round of tests and only 26 of the soil samples were completely analyzed. Considering that the source Identification tests were intended to study the majority of the W.R. Grace property it is unclear why so few test-pits were dug. Certainly Grace by performing 92 tests on their development sites understood how many tests were necessary to test a desired area and would have understood that atleast that many would. have been necessary to test an area much larger than that.

(4) The Protocols of the Studies Allowed for Flagrant Loopholes

There is clear evidence from the documents within the Haley and Aldrich studies that test-pits showing obvious signs of contamination were either partially or completely shut out of the final data base. For example test pit #6 at building site #6 was listed as having, "a slight odor.....very dark black water...(and) a corroded barrel at 7.5 ft."6 This test pit was among the nearly one-half of the test pits that did not receive a complete chemical analysis. No attempt was made to open or test the contents of the corroded barrel. In another example one of the 26 source identification test-pits (test-pit#317) was dug open but then abandoned due to an, "overpowering petroleum odor beginning at above 2 ft. depth, the operators, "Abandoned test pit without further examination or sample collection".7 Test-pit 317 had no samples taken from it. It does not appear in the database.

(5) The Correlation Between Historical Useage and Hotspots is not Complete.

6 Haley and Aldrich,1988,Test-Pit Reports, see attachment A for enclosurie. 7Haley and Aldrich, 1988, Test-Pit Reports, see attachment B for enclosure.

4 The site maps provided in the Haley and Aldrich reports are poorly marked. It Is therefore difficult or impossible to make a completely accurate correlation between past activity on the site and present day contamination based on. the information contained in the reports. It does appear possible to make broad predictions as to the location of hotspots of contamination as Haley and Aldrich have done however this is not the same thing as knowing where all the hotspots are and how widespread the contamination is. Backing up this contention is the fact that Haley and Aldrich found substantial aniouai of contaaination in areas where there was no previous reason to suspect it. For example portions of proposed building sites five and six appear to be in areas that had no former chemical storage or process waste and yet chemical contaminants have been JoUnU thece. Source idJentLification test-pit #306 is clearly in an area with no history of activity by the chemical plant and yet reportable amounts of chemical contaminants were found there. The test-pit that produced the corroded drum referred to above is in an area far away from the main axis of activity at the former chemical plant and within about one hundred feet of a city-owned football field. It is highly likely that this drum is one of the thousands of similar drums used to store chemicals at the former chemical company while it was in operation. If chemical drums could have found there way to this remote location it is clear that past history is not sufficient to identify all areas of contamination on the site.

(6) Duplicate Analysis Shows Weaknesses

For the 1986-87 studies, nineteen duplicate analysis were performed. One was dismissed as Invalid. Since this is more than five percent of the duplicates there is already some grounds for doubting the duplicate process. Of the eighteen remaining valid duplicate tests, five appear to show significant differences in chemical amounts. These differences may or may not pass a statistical muster but certainly appear to be grounds for doubt about the chemical analysis employed.

(7) Split Analysis Not Used

There was no split analysis testing performed. Split analysis is considered a benchmark for an objective, well-designed scientific

5 study especially in a case such as this where all scientific data have been generated by the owner of the property.

Lew Weitzman 124 Montgomery Street Cambridge, Massachusetts December 17, 1996

6 ATFACHMENTA

TEST-PIT REPORT

7 TLIEST PIT REPORT a H a I c y & A I d r h, n c. TPIT NO. SIT6 TP6 Cm.nskint Gnacih al F nascen.Geok. s i and Hydrnstkipsis

FILENO. 611802 PROJECT: ALEWIFE BUILDING SITE ASSESSMENT LOCATION: ALEWIFE.... I LIENT: W. R. GRACE & CO. ELEVATION: 115. 7 CONTRACTOR: J. MARCHESE & SONS EXPLORATION DATE: 10/21/87 EQUIPMENT USED: CASE 680 K RUBBER TIRE BACKHOE H&AREP: J. LINCHAN SCALE STRATA SAMPLE SAMPLE HNU I IN REPTH DESCRIPTION OF MATERIALS FEET CHANG IRANGE . REMARKS J gray silty fine SAND and CLAY 1. SlightREMARKS odor from Tan to - CLUMPS I pit and pile.

-FILL- 2. Background HNU = 0.5 ppm. -2- Little fine to medium gravel. 2. 3. Groundwater gush- Tan silty medium SAND. ing in at 7.5 ft. -FILL- 3.5 4. Water very dark Brown and black silty fine to coarse SAND, black but no oil -4- little clay. Misc. brick, glass, wood, sheen. iron, concrete. 5. Corroded barrel -FILL- at 7.5 ft.

6. Slight froth to water surface.

7. 7. Piles don't reg- C ister above back- Black sandy PEAT mixed with rubble FILL, ground exept for bricks, wire, asphalt, barrel. one asphalt - a cluster @ 2.0 ppm -FILL- 8. Dark gray silty medium to fine SAND.

-MARINE-

-10 -I BOE = 10.0 ft.

HNU Background 0.5 ppm.

-12-

GROUNDWATER APPROXIMATE PIT DIMENSIONS SUMMARY DATE I TIME DEPTH FT. 10 3 10 10/21/871 14:15 1 7.5 300 DEPTH 10-0 JAR SAMPLES 3 BOULDERS BAG SAMPLES 8" 10 IS" DIAM: No, - Vol Cu. Fl. GROUNDWATER 7 . 5 ~4R5AflfR] Over NOT ENCOUNTERED I *A ,EgnEn 18' DIAM: No - Vol. Cu. Ft, TErST PIT NO SIT6 TP6 IE!~~~~PI OST P ATTACHMENT B

TEST- PIT REPORT

8 V. AIIIIIII&I

CNSULTING SLDRE NGNEER EST PIT REPORT TEST PIT NO. TP317

PIL E NO. 611802 PROJECT: Alewife Source IDLO. SeePla

CLIENT: W.R. Grace & Co.

ELEVATION: CONTRACTOR: J' Marchese & Sons EXPLORATION DATEt21 Dj.- 87 EQUIPMENT USED: Case 680K INSPECTOR:B. Kickham

$CAL STRATA SAMPLE S&.PL T 11 CHANGE NuMBER OEP HNU DESCRIPTION OF MATERIALS REMARKS

Overpowering petroleum odor beginning at above 2 ft. depth. HNU readings over 5 ppm in the breathing zone. Peak readings in air space over 20 ppm. Soil sample in pile 100 ppm. Abandoned test pit without further examination or sample collection. Inspectors and contractor unable to upgrade to level C without respirators. -4-

I. -6- II

II

- 80 - I

- 12 -

h j* ______= ______I: GROUNDWATER PIT DIMENSIONS SUMMARY DA F TIME I EPIti VT, X - = Cu. Ft. DEPTH Approx. 8 ft. IL) (W) (D) JAR SAMPLES BOULDERS BAG SAMPLES 1" to 1" DIAM: No, = Vol. C., F 0. GROUNDWATER O.er 18" DIAM: No. ::I L N. IN ERFII it * z Vol. _ Cu. Ft, TEST PIT NDTFP317 Mr. Edward Weagle - Mr. Steve Johnson Massachusetts Department of Environmental Protection 10 Commerce Way Wobum, MA 01801

RE: W.R.Grace MCP Permit Application for Alewife Site in Cambridge

19 December, 1996

Gentlemen:

We, the undersigned, would like to bring your attention to the follow discrepancies which we believe affect the MCP permit for the W. R. Grace, Co. site in North Cambridge (RTN 3-0277). In particular, we believe that the application is based on an incomplete Phase II comprehensive site assessment and does not, therefore, meet the requirements of 310 CMR 140.08. These are serious data gaps that must be addressed before any permit can be issued.

I. PHASE 11

As stated above, we do not believe that the Phase II Comprehensive Site Assessment satisfies either 1988 or current MCP requirements. The following are data gaps that we have identified:

a, Groundwater Flow is not adequately characterized. A much more detailed analysis of groundwater flow in this area is imperative to any remediation project, especially given the massive amounts of flooding that occurs in the area. According to EH&E Report #95.415 dated 23 April, 1996 (Appendix A-3, page 2), "modeling groundwater flow at this site is complicated by the MBTA tunnels and lack of hydrogeologic information east of the tunnel toward Clifton street." Page 30 of this Report states "we believe that the simulated existing groundwater conditions do not reasonably reflect measured existing groundwater conditions," indicating significant peer concerns about the adequacy of groundwater characterization at the site. Further, the Spengler/Smith Report dated 19 February, 1987 (Appendix A-6, page 5) states that "the nature of ground water movement on the site is confusing and requires clarification."

b. The Phase II and Phase III reports adequately address neither the issues of basement flooding in the area nor the potential of site contaminants entering neighborhood basements. As the Spengler/Smith Report (A-6, page 5), states, the "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." The Report also states on page 12 that "Possible penetration of neighborhood basements by groundwater originating from the site, potentially carrying hazardous compounds, should receive further consideration." Page 12 continues "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 surrounding the proposed development." Subsequently, in late Spring of 1987, Haley & Aldrich carried out a neighborhood survey designed to "assess the present and past history of basement flooding." (See Volume 7, Section 7-01, Appendix B-1). This survey was far too limited in 0

scope and is too antiquated to provide the information needed for a proper Phase II assessment or to support development on the Grace site. The report includes absolutely no data from the neighborhood at the Clifton Street edge of the site and surveys less than 50% of the neighborhood on the Whittimore Avenue edge of the site. Further, the data that the report does include is incorrect. The report, in Figure VII-1 (Appendix B-1), specifically notes that Harrison Avenue, Kimball, Avenue and Kassul Park had either never flooded or only flooded once. Just recently, however, in October of 1996, rains described by National Weather Service staff as having similarly occurred seven other times in the past forty-one years (1955, 1962, 1968, 1979, 1982, 1987, & 1992), caused significant basement flooding on these streets (see North Cambridge News, November/December, 1996, Appendix N-1. Also see Appendix N-2, North Cambridge News, June 1995, for an in depth history of the area). Significant basement flooding also occurred on Magoun Street, upper Columbus Avenue, Madison Avenue, Clifton Street and virtually all other streets near the Grace site. In DEP's Notice of Audit Findings for the Grace Site dated 20 September, 1996 (Appendix B-2, page 2), it was determined that "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." Finally, in the Federal Highway Administration/Massachusetts DPW Report dated 20 February, 1987 (Appendix B-3, page 161) it was noted that "The occurrence of significant flooding has increased over the past several decades as a result of development in the floodplain area ..." Clearly, new comprehensive and accurate basement flood data must be developed before any Phase II report could be considered complete. c. The definition of horizontal and vertical contamination is not adequately defined or modeled and there is no discussion as to the relative correlation between known soil contamination and existing contaminant levels in the groundwater. d. The methodology of the LSP's sampling is questionable. At least two peers have submitted formal comments that the composite samples taken by Haley & Haldrich are of questionable use. See: Appendix A-5, NUS Corporation Report dated 5 September, 1986, page 2, "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." Note: This Report was suspiciously absent from the FEIR for site development and should be reviewed in its entirety. See also: Appendix A-6, Spengler/Smith Report, 19 February 1987, page 4, "the usefulness of much of this data is questioned because, in many instances, chemical analyses were performed on composite samples." e. A variety of areas were not adequately sampled. For example, Parkway Pond is located near the site of a former tank farm, yet very little sediment sampling occurred in Parkway Pond, (See Sampling Maps in Appendix A-2). A report entitled CHEMICAL CONTAMINATION OF WATER: The Case of Acton, Massachusetts, prepared for the department of urban and environmental policy at Tufts University, dated June, 1981, makes reference to Parkway Pond (Appendix A-7, pages 67, 68), stating that "Parkway Pond, adjoining WR Grace property, was also contaminated by Acid... .The Pond is the first area outside WR Grace property shown to be affected by the acid-plume created by waste from the chemical company."

2. 0 0

There has been inadequate sampling on Russell Field, where contaminated excavate was stored and backfilled (see Appendix A-9, page 2 and Sampling Maps in Appendix A-2). Little sampling data exists for the Clifton/Harvey Street edge of the site. (See Sampling Maps in Appendix A-2). Additionally, much anecdotal evidence includes stories of contamination on Russell Field, including recent stories of dogs suffering chemical bums last summer while playing on the northern end of the field area. Grievances filed by the Boston Carmen's Union and other pertinent information (See Appendices F-1 & F-2) give every indication of environmental health hazards existing in the tunnel area under the Grace site and Russell Field. For example, one grievance dated 30 July, 1988 notes the employee experienced "obvious toxic fumes: at the Alewife station, while a memorandum dated 10 March, 1994 notes that union members working at the Alewife station "have been complaining to us about becoming sick from working at that location." Another letter dated 25 July, 1985 notes the writer was "overcome by a sickening odor" in the Alewife station that led to a burning in his eyes, nose and throat. According to Mr. Lew Weitzman's 17 December, 1996 letter (enclosed), there are no existing samples for sites where corroded barrels and strong odors were identified. Clearly, all sites where possible contamination was indicated through color stains, debris, odors or other evidence, should have been analyzed. Failure to do so should invalidate the original site assessment. Finally, the Spengler/Smith Report (Appendix A-6, page 4) states that "In addition, many areas on the site were not covered in adequate detail." f. Supporting data for environmental conclusions has been impossible for us to find. For example, we have been unable to locate any sampling results for Parkway Pond that are of any significance. Yet, the EH&E Report dated 23 April, 1996 (Appendix A-3, page 37) states that "Routine and continuous monitoring of the Parkway Pond, where the subway pump empties, has not revealed contaminates, according to Haley & Aldrich, Inc." We cannot find anywhere in the records on public file the data that supports this conclusion. Further, important materials and information relating to the W. R. Grace's remediation plans apparently have not been made available to the public in a timely manner (see Joseph J. Joseph letter dated 18 December, 1996 - enclosed). Further, according to Mr. Joseph, when some of these materials did appear, it was right before the start of the holiday season. To expect concerned citizens to review these newly received documents, some of which, at least, were several years old, while meeting year-end professional obligations, holiday shopping requirements, holiday parties and religious events is neither reasonable nor fair. If, as seems to be the case, these documents did just appear, the comment period for this permit should be extended by a minimum of an additional sixty days, although we believe at least six months extension is needed for review under TAG-funded activities. g. According to Mr. Weitzman's 17 December letter, fewer than 50% of the soil sample test pits actually produced samples that were tested for contaminants, most of the samples being discarded. Mr. Weitzman goes on to state that 92 of the 120 test pits were dug in areas intended to "evaluate soil quality within proposed building sites 2 to 7" with only 28 being dug (not necessarily analyzed) in the rest of the site. If these numbers and locations are correct, it is clear that the test

3. pit samples taken and analyzed were not organized to properly characterize the entire site from a remediation perspective, but only represented sampling in the footprint of the proposed development, (Note: the North Cambridge Stabilization Committee, NCSC, reached a similar conclusion in their communication dated 12 January, 1988 to the Massachusetts Secretary of Environmental Affairs. See Appendix A-10.) h. The LSP, Mr. Wesley Stimpson of Haley & Aldrich, did not appear to identify all tentatively identified compounds (TIC's). The LSP only identified compounds on their target compound list. Standard industry practice is to identify peaks that are not on this list, but the LSP did not appear to do so. By failing to do so, the LSP did not identify all of the potentially hazardous chemicals that may be on the site. The LSP should have ascertained what is actually on the site, which would mean identifying all spikes in the analyses. i. The LSP did not appear to look for sulfur containing compounds. Naphthalene is not the only environmental contamination issue at this site. Since the facility produced sulfanated-naphthalene sludge, the presence of sulfur compounds should be specifically addressed. Further, a Camp Dresser & McKee Inc. report dated 27 July, 1979 (See Appendix S) commenting to W.R.Grace on MBTA documents indicated the presence of sulfur containing compounds and "distinct low pH leaching, both vertically and horizontally. Vertical leaching has apparently reached to a deposit of low permeability clays at an average of 30 ft below the sludge placement." The CDM report went on to comment that "We feel the precision of these data should be reviewed in detail and reinfbrced with additional investigation before any major action is taken at the site by W. R. Grace." Appendix S represents a history of sulfate and pH testing and dialogue from 1979 -1988 involving the MBTA and other agencies. j. Additionally, it is our understanding that Parkway Pond regularly receives extracted groundwater from in or near the MBTA tunnel system. We have found no discussion about the effect that this regular extraction has on the underlying aquifer , Parkway pond, Yates pond, Little River, or Alewife Brook, which are the receptors for this dewatering process. k. There is no time-phased iso-concentration map which depicts the extent of both on-site and off- site contaminant migration. The potential for off-site migration is significant as evidenced by the increasing concentrations of naphthalene found in a monitoring well on the northeast periphery of the property.

1. Any Phase II must look at all potential source areas before completing a site assessment, yet, as noted above, some potentially problematic areas were not sampled. Additionally, as noted in our supporting documentation, which the DEP has received previously under separate cover dated February 11, 1996 (Appendix A-1, and also A-9, page 2), there is considerable confusion over where the excavated material went, where it was stored on the site and how much of it was backfilled on the site. Because Grace Co. and/or its agents clearly did not understand what happened to the contaminated excavate it seems very improbable that any previous site assessments could be accurate. Perhaps the most accurate summary of contamination issues at the

4. 0 0

W.R.Grace site in Cambridge can be found in the Notice of Project Change document prepared and submitted by the developer Spaulding and Slye, dated 16 January, 1996. In the Technical Section No. 4: Hazardous Materials, the developer states that "hundreds of thousands of cubic yards of contaminated soils", still remain on the site. (See Appendix A-4)

m. The NCSC outlined a series of environmental concerns and issues in their correspondence to the Massachusetts Secretary of Environmental Affairs dated 12 January, 1988. (Appendix A-10) The Certificate of the Secretary of Environmental Affairs on the FEIR dated 20 January, 1988 (Appendix A-11) can be viewed in the same context. The DEQE's Notice of Responsibility dated 9 February, 1987 (Appendix A-8) only serves to bolster these concerns. These issues and concerns as yet have not been adequately addressed.

These deficiencies in the Phase II Comprehensive Site Assessment are major. They will keep the PRP and its agents from having a complete understanding of exactly how contaminated the site is and its potential for offsite migration. With these major factors inadequately addressed, it is impossible to adequately characterize risk associated with existing and future site conditions. Accordingly, the PRP or its agents should augment the Phase II Comprehensive Site Assessment to address these significant data gaps and to meet current MCP requirements.

II. NEW MCP:

The site assessment is almost a decade old. "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.... 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." Although some sampling did continue through 1994, only nine wells were active. (See Appendix A-3, page 12) The new MCP has been the law for three years, and it appears that Grace's previous studies do not meet former or current regulatory performance standards for Phase II and Phase III activities. We have been able to uncover no specific documentation that indicates that the DEP acknowledges that Grace's previous work at the site corresponds to completing Phase II and Phase III of the current MCP.

III. FEASIBILITY STUDY:

Given the wide variety of failings of the Phase II Comprehensive Site Assessment and Risk Assessment, we do not believe that the Phase III Feasibility Study (FS), prepared in the mid-eighties, is accurate, As you know, the FS needs to be based on an accurate and complete Phase II report. Any imperfection in Phase II mean that the follow-up work in Phase III must be similarly flawed. We would also like to point out that the development plans for this site are unknown. At one point a hotel and office park with underground parking was proposed, then it was a slab-on-grade retail area instead of the office buildings, now it appears to be some combination of the hotel and office park is being proposed again, although the status of the building permits is still up in the air. Environmental technology has advanced immensely in the past decade and the economics of various soil treatment and disposal methods have changed drastically. We feel, therefore, a more accurate Phase III feasibility study is

5. -.5 0

necessary and should be based on a Phase 1I report that meets current MCP requirements.

V. FUTURE ACTIONS:

The Alewife Study Group has recently been awarded a Technical Assistance Grant from the State DEP. As we use the TAG funds to help identify areas of concern involving the Grace site, it is possible that further discrepancies may emerge and that we may be able to offer more constructive criticism of the Phase II and Phase III reports for this site. We think it would be wise, therefore, for the DEP to delay closing the comment period and granting a permit to W. R. Grace site for at least six months, until after we have had an opportunity to have a professional review it under our TAG-funded actions.

V. CONCLUSION

For all of the above reasons, W. R. Grace should conduct remedial Phase 11 and Phase III studies before obtaining a permit.

As always, we are sending a copy of this letter to the LSP in the hopes that he may be able to answer some, if not all, of our questions and put our long-held concerns to rest. Because of the confusing lack of documentation in some areas, we are always optimistic that someone, such as the LSP, will uncover new evidence that will help us in our efforts to fully characterize the environmental threat that is still posed by this former chemical factory.

Any questions concerning this letter should be addressed to Mr. Craig A. Kelley, Esq. at 617-354- 8353 or via mail at 6 Saint Gerard Terrace, Cambridge, MA 02140.

Thank you very much for your assistance and we hope that you enjoy the holidays.

Submitted on behalf of the Alewife Study Group by:

Craig A. Kelley, Esq. Peter V. Cignetti III 6 St. Gerard Terrace 5 Theriault Court Cambridge, MA 02140 Cambridge, MA 02140 617-354-8353 617-491-6314

6. CAMBRIDGE PUBLIC LIBRARY pp

MEMORANDUM

TO: Robert W. Healy, City Manager

FROM: Susan M. Flannery, Director of Libraries

DATE: December 18, 1996

RE: W.R. Grace documentation

I was greatly dismayed to receive a copy of the 12/5/96 memo attached, especially since I have never been contacted by anyone from W.R. Grace or Haley & Aldrich to discuss the appropriate and/or legal method for the display and availability of the documents noted in the memo.

The Cambridge Public Library, at both the Main Library and the O'Neill Branch Library, has extensive reports and correspondence regarding the W.R. Grace site. As you can see from the attached memo, W.R. Grace's communication with the Cambridge Public Library was through unidentified "reference librarians" at both the Main Library and O'Neill. There are more than 6 reference librarians at the Main Library and none at O'Neill. This method of communication is hardly appropriate for documents subject to permit application deadlines. In fact, in my communication with W.R. Grace it was disclosed that their standard method of delivery was to "drop off the materials" at the circulation desk of the Main Library. In no instance, were these materals accompanied by a cover letter or instructions for their display. In August, materials delivered to the library were dated 1988 and 1995. The PIP permit application was received at the end of November and was in the process of being catalogued. Had these documents been accompanied by some instructions as to their urgency, they would have been a priority for cataloging. The O'Neill Branch did not receive any recent documentation from W.R. Grace until the first week of December; the same week as the attached memo.

The handling of this matter calls into question W.R. Grace's procedures for the disposition and distribution of this information for public comment. I suggest that all correspondence and communication be through my office and that all materials be accompanied by written instructions as to any restrictions or requirements for their use.

cc: Mr. David L. Wightman, Mr. Edward J. Weagle, Mr. Michael Nicoloro, Ms. Elizabeth Epstein, Mr. Wesley E. Stimpson, Ms. Karen Stromberg, Honorable Robert Haven, Mr. Joseph Josephs

Main Library Boudreau Branch Central Square Branch Collins Branch O'Connell Branch North Branch Valente Branch 449 Broadway 245 Concord Avenue 45 Pearl Street 64 Aberdeen Avenue 48 Sixth Street 70 Rindge Avenue 826 Cambridge Street Cambridge, MA 02138 02138 02139 02138 02141 02140 02141 617-349-4040 349-4017 349-4010 349-4021 349-4019 349-4023 349-4015 December 18, 1996

Mr. Edward Weagle Massachusetts Department of Environmental Management 10 Commerce Way Woburn, MA 01801

Dear Mr. Weagle:

With respect to the Public Comment Period required under 310 CMR 40. 0722, I would like to point out the following issues associated with the W.R. Grace Co. site in North Cambridge (RTN 3-0277).

Originally, the comment period for W.R. Grace's permit application and supporting documents was scheduled to end on December 6, 1996. That closing date was subsequently extended to December 20, 1996 when it was discovered that the most vital materials required for deposit had not been made available as required.

Upon visiting the Main Branch of the Cambridge Public Library, on December 15, 1996, 1 discovered several volumes of materials that had not been there previously for public review. These documents were:

1. Dewatering Report, (Environmental Solutions, Inc., January 24, 1988)

2. Work Plan for W.R. Grace Field Demonstration, (E.S.I.)

3. Status Report: W.R. Grace Field Demonstration Report Vol. I: Technical Report, ( E.S.I., February 27, 1989)

4. Status Report: W.R. Grace Field Demonstration Report Vol. j]: Apnendices, (E.SJ.. February 27. 1989)

5. cita e

iv ninNr- Carndge, and T G::M now fnonrznd t invtf:! ha yr.W. hI

;r&.rv wI h a tTrczsttaf a being ED.aember 4. 199v aa H in net the

adrss 0 indre Av'e, iney~ 2% PWndge Ave ptin~dLiA- :czcily' o2 i'I2 Uoeb15 1P96 raik:4R unt Xt ,rrd Wightima&x; A~ccordi ogl tc the man icarrn it is mpaab. 2W ty wer recIved tie a rhVenmbe dat Canbia Bran5 i brary vre-ed %f numerouLs atquests for spedic e:ness -2- relevant to this comment period have resulted in eventual but untimely compliance. Among the many documents included in the December 4 Transmittal were the following:

1. Environmental Assessment Report for the Proposed Alewife Center Development at the W.R. Grace and Co. Property Cambridge, MA (April 16, 1985)

2. Report on Ground Water Investigation - W.R. Grace and Co. (March 5, 1980)

The second of these two documents contains a lengthy memo from Wes Stimson (current Grace Co. LSP). At the end of page 8, Mr. Stimson says:

"Information provided by the GZD study indicates that the the contamination of ground water extends off-site in the direction of Alewife Brook Parkway."

It is difficult and troubling to attempt to reconcile this statement with the frequent instances of similar admissions attributed routinely in the sub- sequent "Long Term Ground Water Monitoring Reports" to seasonal migrations from unspecified off-site sources. This difficulty is made all the more complex because of the very short window for public comment regarding this document due in part to Grace's negligent inattention to simple detail.

I would respectfully request an extension of the comment period for the purpose of putting these and other materials in proper perspective. Perhaps a closing date of January 14 would be appropriate given that the receipt of these documents at the start of the holiday season effectively precludes any reasonable opportunity for public review and input.

Si erely,

oseph J.Josef 20 Columbus Ave. Cambridge, MA 02140 CITY OF CAMBRIDGE

CAMBRIDGE. MASSACHUSETTS 02139

TEL 349-4300 FAx. 349-4307 EXECUTIVE DEPARTMENT ROBERT W. HEALY City Manager

RICHARD C. ROSSI Deputy City Manager

December 19, 1996 By Facsimile

Iris Davis, Section Chief, Permits/Risk Reduction Edward J. Weagle, Environmental Geologist Bureau of Waste Site Cleanup Department of Environmental Protection 10 Commerce Way Woburn, MA 01801

Re: Application for Permit to Proceed with Response Actions 62 Whittemore Avenue, RTN 3-0277

Dear Ms. Davis and Mr. Weagle:

I am writing in response to the Tier I Permit Application submitted to the Department of Environmental Protection by W.R. Grace & Company on November 15, 1996.

The City and its consultant have reviewed this document and find it adequately addresses the outstanding issues associated with the site Tier Classification. It appears that the Tier Classification re-submitted by Haley & Aldrich, Inc. on behalf of W.R. Grace incorporates the recommendations and scoring as laid out in DEP's Audit Report.

We appreciate the opportunity to comment and DEP's on-going cooperation on this issue.

Vemuly yours,

Robert W. Healy COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECION METROPOLITAN BOSTON - NORTHEAST REGIONAL OFFICE

WILLIAM F. WELD TRUDY COXE Govemor Secretary

ARGEO PAUL CELLUCCI DAVID B. STRUHS Lt. Governor Commissioner

December 13, 1996

Councillor Francis H. Duehay 26 Lowell Street Cambridge, MA 02138

RE: CAMBRIDGE - W.R Grace 62 Whittemore Avenue DEP RTN 3-0277 Public Records Request

Dear Councillor Duehay:

The Department of Environmental Protection ("Department") is in receipt of your letter dated December 3, 1996 in which you raise certain questions relative to the disposal site located at 62 Whittemore Avenue, Cambridge, Massachusetts ("Site"). For your convenience, a copy of your letter and attachment is enclosed herewith.

Upon review of your letter, we must inform you that the Department does not have the resources to make the factual determinations you seek. Site-specific findings, as well as a risk characterization for this Site, will be submitted as part of a Phase II Comprehensive Site Assessment Report pursuant to section 40.0835 of the Massachusetts Contingency Plan ("MCP"), 310 CMR 40.0000 et _e. The MCP sets forth specific timelines for the submittal of site reports and a Phase II Report is not yet due for this Site.

As you are aware, the Department maintains a file on this Site at its Northeast Regional Office, 10 Commerce Way, Woburn, Massachusetts. The Department's file will contain documents pertaining to some of the questions you raised in your letter. Appointments to view this file can be made by contacting Holly Migliacci at (617) 932-7600. In accordance with the

10 Commerce Way * Woburn, Massachusetts 01801 * FAX (617) 932-7615 * Telephone (617) 932-7600 * TDD 1 (617) 932-7679 Councillor Francis H. DOy December 13, 1996 Page 2

Public Involvement Plan ("PIP") requirements, W.R. Grace has also established Information Repositories at the Cambridge Main Library, 494 Broadway Street, Cambridge, Massachusetts and the North Cambridge Library, 60 Rindge Avenue, Cambridge, Massachusetts. These Information Repositories contain reports previously prepared for this Site, work plans, sampling and field-testing plans, technical reports and documents summarizing results and recommendations.

The Department hopes that, in utilizing the information maintained in the Department's own file or in the PIP Information Repositories, you or your environmental consultant will be able to answer the questions raised in your letter. When received, the Phase II Report prepared on this Site will also be of help in addressing your inquiries.

We thank you for your understanding in this matter.

Very truly yours,

i MCarthy Associate Regional ounsel

GAM/ Enclosures cc: DEP/ADM/NERO Attn: William Gaughan (w/ enclosures) DEP/BWSC/NERO Attn: Richard Chalpin (w/ enclosure DEP/BWSC/NERO Attn: Iris Davis (w/ enclosures) CITY OF CAMBRIDGE MASSACHUSETTS 02139 * 617-349-4280 FAX 617-349-4287 Councillor Francis H. Duehay 26 LOWELL STREET CAMBRIDcE, MASSACHUSETTS 02138 617-547-0271

December 3, 1996

Mr. Edward Weagle Bureau of Waste Site Clean Up Department of Environmental Protection 10 Commerce Way Woburn, MA 01810

Dear Mr.Weagle:

Thank you for participating in the meeting of the Committee on Environment of the Cambridge City Council in September.

To follow up that meeting, I have received permission of City Manager Robert Healy to ask you to respond in writing to the enclosed questions. Please provide as comprehensive answers as your professional training and experience permit. Also please indicate where your lack of knowledge does not permit you to respond. Please reply by January 1, 1997, if possible.

I envision that there will be further meetings of the Committee to discuss and analyze these responses and to allow further public input.

Thank you for your cooperation in this matter.

Sincerely yours,

Francis H. Duehay, Chair Committee on Environment

s

cc: Robert W. Healy

enclosure RISK CHARACTERIZATION (For All Respondents)

I. The identification of toxic/hazardous materials on the site

A. Are there hazardous materials currently stored on site?

1. How is this known and are the sources reliable?

B. Do the records provided by Grace and other past users of the site provide a trustworthy guide to what chemicals have been on the site?

1. Are there differences between what hazardous materials have been found on the site and what, historically, is known to have been on the site?

C. Are the experimental/theoretical means for locating hazardous chemicals on the site (including locations in the air, water, at the surface and buried within the soil) sufficient to ensure that:

1. All possible contaminants, both known to have been on the site, as well as those reasonably expected to have been on the site, have been identified?

2. The upper levels of general contamination have been determined with a high degree of certainty?

3. Any localized areas of a high concentration of hazardous material - "hotspots" - have been found or can be said not to exist with a high degree of certainty?

(In all of the above, please discuss the methods used to address CI through C3 along with an evaluation of their appropriateness to this specific situation.)

D. If C cannot be answered favorably, what should be done to ensure that the above criteria (i.e. Cl through C3) can be reasonably met?

1 IL The determination of whether toxic/hazardous materials exist off the site

A. Are the experimental/theoretical means for locating hazardous chemicals off site sufficient to ensure that:

1. All possible contaminants off site have been identified

2. The upper levels of general contamination have been determined with a high degree of certainty.

3. Any localized areas of a high concentration of hazardous material - "hotspots"-have been found or can be said not to exist with a high degree of certainty.

(In addition to the site and surrounding residential areas, please consider the Russell Athletic Field areas)

B. Are there additional sites that should be tested and considered in the analysis?

Im. The evaluation of chemical toxicity

A. How is it known that a specific chemical or compound is injurious to human health?

B. Is it likely that there are chemicals present whose toxicity has not yet been realized?

C. Can the presence of a toxic/hazardous chemical be established based upon an epidemiological study of the local population?

2 RISK ASSESSMENT (For All Respondents)

1. Estimating hazardous sources

A. In determining the risk from exposure to hazardous compounds, what assumptions have been made with respect to the levels of hazardous materials on, or off, the site? Specifically with regards to:

1. The predicted levels of hazardous materials on the site, in different media at various levels.

2. The migration of hazardous materials off of the site

3. Both questions should address, at least: a. how these amounts were determined b. What degree of certainty is attached to these results c. How the level, or routes of migration can be affected by i. Abnormal weather conditions or other natural phenomena. ii. Potential efforts to remediate the hazards. iii. Proposed construction

II. Estimating potential toxicity

A. In evaluating the risk from exposure to hazardous compounds, what assumptions have been made in characterizing the "human" health effects of the hazardous materials on the site?

B. Are the data sufficient to accurately assess these health risks with any degree of certainty?

1. Which compounds, found on the property, have health effects that are not currently well understood or easily related to dose?

2. Which compounds, found on the property, have not been investigated with respect to their toxicological effects?

3 m. Determining exposure

A. Are the exposure scenarios sufficient, even if the probability is low, to cover the worse case possible exposures?

B. Are any of the underlying assumptions unreasonable given the expected use of the site by both builders and the public?

IV. Assessing the risk

A. In the worst case scenario, what adverse health effects can be expected?

B. Are there any reasons to expect that this predication is not accurate or appropriate? In other words, were assumptions used in the analysis that may be subject to criticism?

C. How does this relate to other, more likely, though less hazardous, exposure scenarios?

RISK MANAGEMENT

1. What recommendations would you make to ensure that the assumptions used in the risk assessment are still, and will continue to be, valid and that a new assessment, or projection of health risk, is not necessary

II. Under what conditions, would a new review of the situation be necessary.

III. What, if any, recommendations would you make to reduce possible exposure to residents living or playing at or near the site.

A. Monitoring? 1. Air 2. Water i. i.e. Whittemore Avenue 3. Ground

4 4. What levels of monitoring are appropriate now, during excavation or in the future

B. Changes in construction protocols?

C. Protective barriers?

D. Warnings to resident?

With Regard to the MBTA Tunnel and Russell Field

I. Characterize the current MBTA tunnel drainage system

A. Is it operating as designed? 1. If not, why not? i. Please include the data on ground water/surface water infiltration in a manner consistent with the expertise of the Council and others.

B. If the drainage system is not operating as intended, what changes can be made to raise its performance closer to the initial design objectives?

II. Review and documentation of the MBTA tunnel construction

A. On a map of Russell Field and the area immediately surrounding the field, please mark any and all locations where fill - taken from the he site during construction-was either temporarily stored or dumped. 1. Are there any photographs, staging diagrams, site plans or any other documentation to support these data?

III. Are there any additional aspects of the MBA construction that may have, or will in the future, impact the distribution of toxic materials in the North Cambridge Community.

IV. The reconstruction of Russell Field A. Does the fill material used to reconstruct Russell Field contain any hazardous materials?

5 X.

1. Why or why not? Please include documentation to support your answers.

B. At the time of its construction, was an analysis performed-or a discussion held-to determine whether the existing sewer systems were adequate to handle the additional water run-off? 1. Please provide any supporting documentation.

C. What is the operating condition of the swail and pump station intended to facilitate the drainage of Russell Athletic Field.

V. What effect, if any, will the future sewer separation project in the Clifton Street area have on the drainage of Russell Athletic Field and the surrounding area?

With Regard to Dr. Spengler

I. In addition to your Curriculum Vitae (please provide copy), the following questions are intended to communicate the experience you bring to bear on these issues as well as any potential conflict of interest with W.R.Grace.

A. Is this situation similar to others that you have worked?

1. In what ways? 2. What interests were you representing at the time and whose were they if it isn't self-evident?

B. In general, what do you consider to be the most important issues in this situation? 1. Do you believe that they are being properly addressed? 2. What additional recommendations would you make?

C. With respect to your current work with the City of Cambridge, whose interests are you representing? 1. Who is paying you for your time?

D. Have you ever represented -or have you been paid to perform work for -W.R. Grace or Haley & Aldrich

6 C

1. Does the money you receive from these sources represent a substantial portion of your past, present or future income? 2. What steps do you take to maintain your objectivity in cases where certain parties would clearly prefer you to be more supportive of issues that they are concerned with?

With RWard to Mr. Weale

I. In addition to your Curriculum Vitae (please provide a copy), the following questions are intended to communicate the experience you bring to bear on these issues.

A. Is this situation similar to others on which you have worked?

I. In what ways? 2. What interests were you representing at the time and whose were they if it isn't self evident? 3. How long have you worked for the DEP? 4. What experience and background prepares you for dealing with hazardous and toxic waste clean-up?

B. In general, what do you consider to be the most important issues in the W.R. Grace situation?

1. Do you believe they are being properly addressed? 2. What additional recommendations would you make?

7 -e

David L.Wightman Vice President, Administration Grace Construction Products GRACE W.R. Grace & Co.-Conn. 62 Whittemore Avenue Cambridge, Mass. 02140-4692

(617) 498-4983 Tel (617 491-2029 Fax.

December 5, 1996

Mr. Edward J. Weagle Commonwealth of Massachusetts Executive Office of Environmental Affairs Department of Environmental Protection Metropolitan Boston-Northeast Regional Office 10 Commerce Way Woburn, MA 01801 Re: Cambridge - W. R. Grace & Co. 62 Whittemore Avenue RNG 3-0277 Transmittal #118529 Permit Application Dear Mr. Weagle:

We are in receipt of your letter dated November 25, 1996 extending the comment period on our permit application until December 20, 1996 as a result of a "tardy" submission of supporting documentation into the Public Information Repositories, namely the North Cambridge Public Library and the Cambridge Main Library.

After your phone call of last week, I contacted Haley and Aldrich to follow-up on your request to ensure that the proper documentation was available in the public repositories. I was advised that the information was in fact given to both locations on the same day copies were provided to the Cambridge Board of Health, City Hall, Community Development Department and your office. This is the second occasion that the public libraries had no record of receiving documentation even though they were hand delivered by a representative of Haley and Aldrich. The first occasion occurred with the PIP documentation and as a result we were required to extend the comment period in a similar fashion as your November 25, 1996 letter outlines.

AL IdMEL .44-

-2-

The purpose of this letter is to inform you that a duplicate copy of documentation has been submitted to both public repositories and that signed receipts have been obtained.

We sincerely regret if this misplacement of documentation has caused you or the Department any inconvenience. In the future, signed receipts will be obtained for any documentation required to be deposited in public repositories.

Sincerely,

David L. Wightman

DLW/jag

cc: Mr. Michael Nocoloro, Cambridge Board of Health 831 Massachusetts Avenue, Cambridge, MA 02139

Mr. Robert Healy, Cambridge City Hall, City Manager's Office 795 Massachusetts Avenue, Cambridge, MA 02139

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

Reference Librarian, W. R. Grace Disposal Site, Cambridge Main Library 449 Broadway, Cambridge, MA 02138

Reference Librarian, W. R. Grace Disposal Site, North Cambridge Library 60 Rindge Avenue, Cambridge, MA 02138

Honorable Charles Flaherty, Massachusetts House of Representatives State House, Boston, MA 02133

Honorable Robert Havern, Massachusetts Senate State House, Boston, MA 02133

Mr. Wesley E. Stimpson, LSP of Record, Haley & Aldrich, Inc. 58 Charles Street, Cambridge, MA 02141

Karen Stromberg, DEP NERO Service Center DEP NERO P 119 539 689

US kostal Service 'Receipt for Certified Mail No Insurance Coverage Provided. Do not use for International Mail (See reverse) Sent to q. Street &Number C

Post Otfice, State, & ZIP Code

Postage $ Certified Fee

Special Delivery Fee

Restricted Delivery Fee Retum Receipt Showing to Whom & Date Dervered RetumReceipt Showng toWhom, ccC Dat,& Addressee's Address C TOTAL Postage &Fees $ C Postmark or Date U #V9E~ 0 ?IL-LCOF

COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECION METROPOLITAN BOSTON - NORTHEAST REGIONAL OFFICE

WILLIAM F. WELD TRUDY COXE Governor Secretary

ARGEO PAUL CELLUCCI DAVID B. STRUHS Lt. Governor Commissioner

By CERTIFIED MAIL RETURN RECEIPT REQUESTED

November 25, 1996

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

Attn: Mr. David Wightman

RE: CAMBRIDGE - W.R. Grace Co. 62 Whittemore Avenue RTN 3-0277 Transmittal #118529 PERMIT APPLICATION

Dear Mr. Wightman:

This letter is in regard to the above-referenced Tier I Permit Application currently under review by the Department. It has come to the attention of the Department that the Permit Application and all supporting documentation may not have been placed into the Public Information Repositories in a timely fashion, as required by the Massachusetts Contingency Plan (MCP), 310 CMR 40.0000. Therefore, this notice is to inform W.R. Grace and those persons interested in commenting on the application, that the Department will accept Public Comments pursuant to the MCP until December 20, 1996.

Furthermore, W.R. Grace & Co. - Conn. and their consultants are hereby reminded that W.R. Grace is required to make available, in a timely fashion, the Permit Application and all supporting documentation required by the MCP, 310 CMR 40.0000.

10 Commerce Way 0 Woburn, Massachusetts 01801 1 FAX (617) 932-7615 * Telephone (617) 932-7600 * TDD # (617) 932-7679 W.R. Grace & Co. - Conn. Page 2

If you have any questions regarding this matter, please contact Edward J. Weagle at the letterhead address or by calling (413) 784-1100 ext. 221.

Sincerely,

Edward J. Weagle Iris W. Davis Environmental Geologist Section Chief, Permits/Risk Reduction Bureau of Waste Site Cleanup

cc: Cambridge Board of Health, 831 Massachusetts Avenue, Cambridge, MA 02139, Attn: Mr. Michael Nicoloro Cambridge City Hall, City Manager's Office, 795 Massachusetts Avenue, Cambridge, MA 02139, Attn: Mr. Robert Healy Cambridge Community Development Department, 57 Inman Street, . Cambridge, MA 02139, Attn: Elizabeth Epstein Cambridge Main Library, 449 Broadway, Cambridge, MA 02138, Attn: Reference Librarian, W.R. Grace Disposal Site North Cambridge Library, 60 Rindge Avenue, Cambridge, MA 02138,Attn: Reference Librarian, W.R. Grace Disposal Site Honorable Charles Flaherty, Speaker of the House, Massachusetts House of Representatives, State House, Boston, MA 02133 Honorable Robert Havern, Massachusetts Senate, State House, Boston, MA 02133 Haley & Aldrich, Inc., 58 Charles Street, Cambridge, MA 02141 Attn: Mr. Wesley E. Stimpson, LSP-of-Record Karen Stromberg, DEP NERO Service Center, DEP NERO

List of Petitioners/Public Commenters:

cc: Alma Balonon-Rosen, Key Petitioner, 51 Madison Avenue, Cambridge, MA 02140 Karen Coker, Key Petitioner, 24 Magoun Street, Cambridge, MA 02140 Joseph Joseph, Key Petitioner, 18 Dudley Street, Cambridge, MA 02140 Peter V. Cignetti III, 5 Theriault Ct., Cambridge 02140 Craig Kelley, 6 St. Gerard Terr., Cambridge 02140

( -Continued- ) W.R. Grace & Co. - Conn. Page 3

Hanna Goodwin, 94 Clifton St., Apt. #2, Cambridge 02140 Steve Schnapp, 32 Clay St., Cambridge 02140 Lewis Weitzman, 124 Montgomery St., Cambridge 02140 Vicki Kocher Paret, 122 Montgomery St., Cambridge 02140 Susan Maguire, 125 Jackson St., Cambridge 02140 Elizabeth W. Birk, 20 Columbus Ave., Cambridge 02140 Paul Miranda, 125 Jackson St., Cambridge 02140 Aram Hollman, 15 Clifton St., Cambridge 02140 Susan & Victor Polsinski, 104 Clifton St., Cambridge 02140 Patricia A. Casola, 364 Rindge Ave, Apt. 17B, Cambridge 02140 Joel Nogic, 94 Clifton St., Apt. #2, Cambridge 02140 Alison Dowd, 115 Harvey St., Cambridge 02140 Helen Flynn, 111 Clifton St., Cambridge 02140 Janet Malenfant, 16 Harrison Ave, Cambridge 02140 Don Abrams, 17 Day St., Cambridge 02140 Sylvia Barnes, 196 Harvey St., Cambridge 02140 Malvina Montero, 85 Harvey St., Cambridge 02140 Lisa Burk, 28 Magoun St., Cambridge 02140 Catherine E. Koletsky, 50 Churchill Ave, #133, Cambridge 02140 Ann Barns, 50 Churchill Ave, Cambridge 02140 Richard D. Clarey, 15 Brookford St., Cambridge 02140 Carolyn Mielt, 15 Brookford St., Cambridge 02140 Resident, 16 Seagrave Rd., Cambridge 02140 Resident, 29 Harrison Ave, Cambridge 021401 22 November 1996 File No. 10063-066

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

Attention: Mr. David Wightman

Subject: Work Scope Groundwater Level Monitoring Alewife Property Cambridge, Massachusetts RTN 3-0277

Gentlemen:

At your request, Haley & Aldrich has prepared the following work scope to allow completion of groundwater table profiles and to better characterize the groundwater flow pattern in the area of Russell Field and the adjacent Clifton Street neighborhood. This work scope will satisfy the recommendations provided by the Massachusetts DEP in their Notice of Audit Findings and Dr. Spangler's recommendation in his report entitled "Final Draft, Public Health Risk Evaluation for W.R. Grace Site in Cambridge, MA" dated 23 April 1996.

To provide the data needed for this determination, we propose the installation of five to seven GeoprobesO on the Russell Field property. We would obtain depth-to-groundwater measurements across Russell Field and in existing wells on the Alewife property to allow the calculation of the groundwater table elevations and an evaluation of groundwater flow direction from the Alewife site. The data should also allow an interpretation to be made of the impact of the MBTA tunnel on the groundwater flow pattern.

WORK SCOPE

Based on the purpose discussed above, we recommend that the following be conducted at both the Alewife site and Russell Field:

1. Conduct one-day of Geoprobe* installations in the locations marked on the attached Figure. We anticipate that five to seven Geoprobes* can be advanced in this time frame. The Geoprobes* will extend five feet into the groundwater table. Upon completion of the Geoprobe, a small-diameter (3/4-inch I.D.), factory-slotted, PVC well screen will be temporarily installed in each boring and the groundwater table allowed to stabilize (completion of the probing operations at the property). W.R. Grace & Co. - Conn. 22 November 1996 Page 2

2. Survey the horizontal and vertical locations of the Geoprobes* and obtain depth-to- groundwater measurements on the day the Geoprobes* are conducted. The survey information will be tied into previously obtained survey information at the Alewife property.

3. Remove the temporary PVC well screens, replace probe cuttings, and grout the Geoprobe* borings to ground surface immediately upon obtaining depth-to- groundwater measurements. Obtain depth-to-groundwater measurements in the existing monitoring wells on the Alewife property indicated on the attached Figure. All depth-to-groundwater measurements will be obtained on the same day in order to have an accurate picture of site conditions.

4. Based on the survey data, determine groundwater surface elevations and construct a groundwater table contour map. Provide an indication of the inferred groundwater flow direction based on the groundwater surface contours.

5. Prepare a letter report describing the field effort, including Geoprobe* logs and the groundwater contour map, and provide an opinion as to the groundwater flow patterns at the property and Russell Field.

Haley & Aldrich appreciates the opportunity to provide you with this work scope. If there are any questions or comments, please do not hesitate to call or write.

Sincerely yours, HALEY & ALDRICH, INC.

Wesley E. Stimpson Senior Vice President

F:\0063\066\GWRW.wpf 5 September 1997 File No. 10063-066

Cambridge Community Development Department 57 Inman Street Cambridge, Massachusetts 02139

Attention: Ms. Susanne Rasmussen Director of Environmental and Transportation Planning

Subject: Review of Russell Field Sampling Program Cambridge, MA 29 July 1997 Revisions

Ladies and Gentlemen:

As requested by W. R. Grace & Co. - Conn., we have reviewed the subject sampling plan. This letter provides our observations and suggested changes to the plan so that it may better address our understanding of the purpose of the proposed work.

Our comments are as follows:

0 It is understood that priced proposals will be solicited for the sampling program and the lowest bidder will be selected to do the work. The current requirements detailing sample collection methods, sample handling and storage and sample security are too general to assure high quality test results. Nominal QA/QC protocols such as the use of trip blanks and duplicate samples are provided. However, more detailed QA/QC provisions should be added to the requirements of the program before placing it out to bid so that all of the bidders are assured of providing the same minimum level of QA/QC as part of their price to do the work.

o The proposed sampling program identifies isopropyl sulfide and thio-bis-propane, not usually covered by EPA standard testing protocols, but detected at the Grace property, as target compounds. The sampling program goes on to include, in addition, the first 30 tentatively identified compounds (TICs) for each sample tested. Because TICs are not compounds normally identified by commercial laboratories, the identification of each compound is often very tentative. More importantly, there also is no recognized way of evaluating the implications of their presence in the environment. Since each sample is going to be evaluated for its own individual TICs, it is likely that a very complex, but not very useful, data set will be developed. We suggest that identifying TICs be eliminated as it provides no real scientific benefit. W.R. Grace & Co. - Conn. 5 September 1997 Page 2

? It is very unlikely for the MBTA activities of concern or possible movement of contamination from the Grace property to have impacted the present surficial soils. Despite this, target compounds and evaluation criteria for determining if these sources contributed to certain compounds that may be detected during the surficial soil sampling program, have been developed. This approach is significantly flawed because most of the compounds identified as "target compounds" are present in the general urban environment.

A different approach needs to be developed. The approach should include the collection of "background" samples at locations known not to have been impacted by the MBTA or Grace activities and which are representative of similar urban filling and property use. Draft DEP guidance for sampling to determine background conditions suggests that at least eight locations be sampled. All of the parameters proposed for the site samples need to be included in the background sampling, including the TICs, if they remain in the work plan. o The proposed target compound evaluation criteria are inappropriate. They appear to be arbitrary, negotiated criteria with no relationship to scientific fact. There is no basis to conclude that the detection of any one compound at the detection limit of the test method or twice the background level or at some fraction of an S-1 standard or some other "negotiated" criteria is an indication of a connection of the contamination detected to past MBTA or Grace activities. o No evaluation criteria are provided for the subsurface soil and groundwater data that will be obtained as part of this program. Evaluation criteria should be developed for these data in advance of obtaining the data. The evaluation criteria should not be based on individual compounds. The criteria should be developed as a pattern or combination of compounds. Individual compounds are not unique to the potential sources and thus cannot be used individually. In addition, no trigger level should be below the background concentrations developed by the recommended sampling program. o The plan should include the determination of reference elevations for the monitoring wells installed. This will allow the groundwater flow pattern to be determined in the vicinity of the field. Information on groundwater flow direction provides a critical element for the evaluation of potential on-going movements of contamination from off field locations. o Supplemental survey data should also be obtained off and adjacent to the field to allow evaluation of the surface water runoff patternf. The survey should include the identification and configuration of surface water drainage collection systems. An evaluation should also be made of the adequacy of the surface water drainage collection system to control surface water runoff from the field. W.R. Grace & Co. - Conn. 5 September 1997 Page 3

0 Jerry's Pond has been sampled in the past. Three sediment samples and five surface water samples have been obtained. These data show minimal impact from past activities. It is recommended that the collection of additional sediment samples be deferred until the soil and groundwater data has been obtained. At that time the sampling program proposed can be reevaluated. If there are no new sources or impacts of past activities identified, no new sampling is needed. It may be more appropriate, if a sampling program is determined to be warranted, to collect multiple, distributed samples as opposed to the proposed single targeted samples. Multiple samples will allow better characterization of the potential risks.

If you have any questions or require additional information, please do not hesitate to contact us.

Sincerely yours, HALEY & ALDRICH, INC.

Wesley E. Stimpson Senior Vice President c: W. R. Grace & Co.; Attn: Nisan Usta

:/F:\1OO63W66\RUSSAMP3.WPF COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION METROPOLITAN BOSTON - NORTHEAST REGIONAL OFFICE

WILLIAM F. WELD TRUDY COXE Governor Secretary

ARGEO PAUL CELLUCCI DAVID B. STRUHS Lt. Governor Commissioner

November 15, 1996

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

Attn: Mr. David Wightman

RE: DETERMINATION OF ADMINISTRATIVE COMPLETENESS Application for: PERMIT TO PROCEED WITH RESPONSE ACTIONS

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

Tranmji Ital Number: 118529

Dear Mr. Wightman:

The Department of Environmental Protection (the Department) has completed its Administrative Review of the permit application listed above and has determined that the application is administratively complete. This letter serves to notify you that the Department will proceed with the Technical Review.

According to 310 CMR 4.04, the Department has 75 days from the date of this letter to complete its Technical Review. Pursuant to 310 CMR 40.0722 (2), a Public Comment Period (PC-1) of 20 days shall run concurrently with this T-1 review period for those individuals who have notified the Department of their interest to review the application and submit written comments.

The Department has received notification of interest to review the application by individuals separately listed within the rccr" list of this correspondence. Accordingly, the above referenced permit application is now available for review and comment in the Regional Service Center at the Department's Northeast Regional Office located at 10 Commerce Way in Woburn. Please call the Service Center at (617) 932-7677 to arrange a convenient time to review the application.

10 Conmmerce Way 0 Woburn, Massachusetts 01801 1 FAX (617) 932-7615 * Telephone (617) 932-7600 * TDD # (617) 932-7679 W.R. Grace & Co. - Conn. Page 2

A copy of the permit application and its supporting documents will also be made available for review and comment at the Information Repositories established for this site at the Cambridge Main Library, located at 449 Broadway, and the North Cambridge Library, located at 60 Rindge Avenue in Cambridge.

The comment period for this document ends on Friday, December 6, 1996. When submitting comments to the Department, please include the site name, Transmittal Number, and site Release Tracking Number. Please submit comments in writing to:

Iris W. Davis Department of Environmental Protection, Northeast Region 10 Commerce Way Woburn, MA 01801

The Technical Review (T-1), may result in a decision to grant or deny the permit, a Proposed Permit Decision to grant or deny a permit, the issuance of a Statement of Technical Deficiencies, or a determination that the above site does not need a permit.

The issuance of a Statement of Technical Deficiencies would end the T-1 review period. Pursuant to 310 CMR 40.0722 (2) and 310 CMR 4.04 (2) (b) , the applicant must respond to the Department within 30 days of issuance of such Statement of Deficiencies.

The submission of a copy of this Determination of Administrative Completeness to the City of Cambridge Chief Municipal Officer and the Board of Health, as well as those persons who have notified the Department of their interest to review and comment on this application, constitutes the Department's compliance with the requirements of 310 CMR 40.0721 (5).

Pursuant to 310 CMR 4.04 (2) and 310 CMR 40.0721 (6), a Determination of Administrative Completeness shall not constitute any finding with respect to the technical suitability, adequacy or accuracy of the materials submitted, and shall be no bar to a request to amend, revise, replace, or supplement such materials based on technical suitability, adequacy or accuracy. The Department may request additional information during the course of the Technical Review.

In accordance with 310 CMR 4.04 (2) and 310 CMR 40.0720 (3), the applicant and the Department may, by written agreement, extend any schedule for timely action or any portion, thereof.

Withdrawal of the permit application shall be subject to the provisions of 310 CMR 4.04 (3) (d).

AC1.OK/08-09-96 W.R. Grace & Co. - Conn. Page 3

If you have any questions regarding this matter, please contact Edward J. Weagle at the letterhead address or by calling (413) 784-1100 ext. 221.

Sincerely,

Edward J Weagl Iris W. Davis Environm tal G o ogist Section Chief, Permits/Risk Reduction Bureau of Waste Site Cleanup

cc: Cambridge Board of Health, 831 Massachusetts Avenue, Cambridge, MA 02139, Attn: Mr. Michael Nicoloro Cambridge City Hall, City Manager's Office, 795 Massachusetts Avenue, Cambridge, MA 02139, Attn: Mr. Robert Healy Cambridge Community Development Department, 57 Inman Street, Cambridge, MA 02139, Attn: Elizabeth Epstein Cambridge Main Library, 449 Broadway, Cambridge, MA 02138, Attn: Reference Librarian, W.R. Grace Disposal Site North Cambridge Library, 60 Rindge Avenue, Cambridge, MA 02138,Attn: Reference Librarian, W.R. Grace Disposal Site Honorable Charles Flaherty, Speaker of the House, Massachusetts House of Representatives, State House, Boston, MA 02133 Honorable Robert Havern, Massachusetts Senate, State House, Boston, MA 02133 Haley & Aldrich, Inc., 58 Charles Street, Cambridge, MA 02141 Attn: Mr. Wesley E. Stimpson, LSP-of-Record Karen Stromberg, DEP NERO Service Center, DEP NERO

List of Petitioners/Public Commenters:

cc: Alma Balonon-Rosen, Key Petitioner, 51 Madison Avenue, Cambridge, MA 02140 Karen Coker, Key Petitioner, 24 Magoun Street, Cambridge, MA 02140 Joseph Joseph, Key Petitioner, 18 Dudley Street, Cambridge, MA 02140 Peter V. Cignetti III, 5 Theriault Ct., Cambridge 02140 Craig Kelley, 6 St. Gerard Terr., Cambridge 02140

( -Continued- )

ACl.OK/O8-09-96 r r

W.R. Grace & Co. - Conn. Page 4

Hanna Goodwin, 94 Clifton St., Apt. #2, Cambridge 02140 Steve Schnapp, 32 Clay St., Cambridge 02140 Lewis Weitzman, 124 Montgomery St., Cambridge 02140 Vicki Kocher Paret, 122 Montgomery St., Cambridge 02140 Susan Maguire, 125 Jackson St., Cambridge 02140 Elizabeth W. Birk, 20 Columbus Ave., Cambridge 02140 Paul Miranda, 125 Jackson St., Cambridge 02140 Aram Hollman, 15 Clifton St., Cambridge 02140 Susan & Victor Polsinski, 104 Clifton St., Cambridge 02140 Patricia A. Casola, 364 Rindge Ave, Apt. 17B, Cambridge 02140 Joel Nogic, 94 Clifton St., Apt. #2, Cambridge 02140 Alison Dowd, 115 Harvey St., Cambridge 02140 Helen Flynn, 111 Clifton St., Cambridge 02140 Janet Malenfant, 16 Harrison Ave, Cambridge 02140 Don Abrams, 17 Day St., Cambridge 02140 Sylvia Barnes, 196 Harvey St., Cambridge 02140 Malvina Montero, 85 Harvey St., Cambridge 02140 Lisa Burk, 28 Magoun St., Cambridge 02140 Catherine E. Koletsky, 50 Churchill Ave, #133, Cambridge 02140 Ann Barns, 50 Churchill Ave, Cambridge 02140 Richard D. Clarey, 15 Brookford St., Cambridge 02140 Carolyn Mielt, 15 Brookford St., Cambridge 02140 Resident, 16 Seagrave Rd., Cambridge 02140 Resident, 29 Harrison Ave, Cambridge 02140

ACI.OK/08-09-96 MASSACHUSETTS SIERRA CLUB 3 Joy Street Boston Massachusetts 02108 (617) 227-5339 fax (617) 742-8646

13 November, 1996 DEP Bureau of Waste Site Cleanup, Permit Section Northeast Regional Office 10 Commerce Way Woburn, MA 01801

In reference to a notice in the Environmental Monitor of November 8, 1996; the Greater Boston Group of the Sierra Club-Massachusetts Chapter is interested in reviewing and submitting comments on the Tier I permit application of the Site Reclassification of the W.R. Grace & Co. site on Whittemore Street in Cambridge, (release tracking number 3-0277). The notice requests written notification of the DEP by November 12, 1996 and realize this request is late but for reason beyond our control. The notice appeared in the 8 November Monitor but our monitor was not delivered until 12 November. A notice time of four days, two of which are weekend days and one was a federal holiday seems unreasonable. For this reason we hope this request will still be honored.

Sincerely,

Cindy DelPapa Conservation Chair Greater Boston Group 3 Joy Street Boston, MA 02108

Recycled Paper UNDERGROUND V ENGINRNG &

C ENvIRoNMENTAL SOLUTIONS

Haley & Aldrich, Inc. 58 Charles Street Cambridge, MA 02141-2147 Tel: 617.494.1606 Fax: 617.577.8142' Email: [email protected] Letter of Transmittal HALEY & ALDRICH

Date 22 October 1996 File Number 10063-066 From Veronica Wancho O'Donnell

To Massachusetts Department of Environmental Protection; NE Regional Office 10 Commerce Way Woburn, Massachusetts 01801 Attention Edward Weagle Copy to Subject EnvironmentalMonitor Notification and Publication

Copies Date Description 1 Oct. 1996 Letter requesting publication of Legal Notice in EnvironmentalMonitor W.R. Grace & Co.- Conn 62 Whittemore Avenue Cambridge, Massachusetts RTN 3-0277

OFFICES Cleveland Ohio Denver Remarks Colorado Dear Ed: Hartford Connecticut Attached, please find a copy of the letter and the legal notice sent to the EnvironmentalMonitor for publication. We will provide the Department with a copy of the actual notice when it is published. If there Los Angeles are any questions or comments, please do not hesitate to call or write. Cakfornia Manchester Veronica O'Donnell New Hampshire Portland Maine Rochester New York San Francisco California

Washington District of Columbia UNDERGROUND ENGINEERING & ENVIRONMENTAL SOLUTIONS

Halev & Aldrich, Inc. 58 Charles Street Cambridge, MA 02141-2147 Tel: 617.494.1606 Fax: 617.577.8142 Email: BOS@HalevAld rich.con 22 October 1996 HALEY& ALDRICH File No. 10063-066 Executive Office of Environmental Affairs 100 Cambridge Street; 20th Floor Boston, Massachusetts 02202

Attention: MEPA Unit

Subject: Legal Notification Publication Request Tier Reclassification W.R. Grace & Co. - Conn. 62 Whittemore Avenue Cambridge, Massachusetts RTN 3-0277

Ladies & Gentlemen:

Pursuant to the Massachusetts Contingency Plan (MCP) 310 CMR 40.1406(1), Haley & Aldrich, Inc., on behalf of our client, W.R. Grace & Co. - Conn., is submitting the attached legal notice for publication in the EnvironmentalMonitor. We understand that the deadline for publication is the 15th and the last day of the month, and that the Environmental Monitor will be available 7-10 days after each publication deadline. If there are any questions or comments, please do not hesitate to call or write.

Sincerely yours, HALEY & ALDRICH, INC.

omCES Cleveland Ohio Veronica Wancho O'Donnell Denver Senior Environmental Geologist Colorado Hartford Connetticut F:\l0063\066\TIER1 ENV. wpf Los Angeles California Manchester N.t Hampshire Portland Maine Rochester New1Tok' San Francisco California Washington Districtof Cohnbia NOTICE OF SITE RECLASSIFICATION

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

Pursuant to the Massachusetts Contingency Plan (310 CMR 40.0480), an Initial Site Investigation has been performed at the above referenced location. A release of oil and/or hazardous materials has occurred at this location which is a disposal site (as defined by M.G.L. c. 21E, Section 2). This site has been reclassified as Tier I C (310 CMR 40.0500), and a Tier I C Permit application is being submitted on 11 OCTOBER 1996 to the Department of Environmental Protection (DEP) pursuant to 310 CMR 40.0703. A permit is required to proceed with a Comprehensive Remedial Responses at all Tier I sites.

Anyone interested in reviewing the permit application should notify DEP by writing to DEP, BUREAU OF WASTE SITE CLEANUP, PERMIT SECTION at NORTHEAST REGIONAL OFFICE, 10 COMMERCE WAY, WOBURN, MASSACHUSETTS 01801 by 12 NOVEMBER 1996. If anyone notifies DEP of his or her interest in reviewing or submitting comment on the Tier I permit application, DEP will conduct a public comment review period of twenty (20) days which shall run concurrently with DEP's Initial Technical Review of the application. Anyone who fails to notify DEP in writing of his/her interest in commenting on the application by the above date may be deemed to have waived his/her rights, if any, to appeal DEP's pennit decision or to intervene in an adjudicatory proceeding with respect to this application, pursuant to 310 CMR 40.0770(2).

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

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

F:\10063\066\TIER1FRM.wpf *PluLsC-op

COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION METROPOLITAN BOSTON -NORTHEAST REGIONAL OFFICE

WILLIAM F. WELD TRUDY COXE Governor Secretary

ARGEO PAUL CELLUCCI DAVID B. STRUHS Lt. Governor Commissioner

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

Dear Applicant:

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

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

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

Sin erely,

Iris W. Davis Section Chief, Permits/Risk Reduction

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

0 Printed on RecycledPaper UNDERGROUND ENGINEERING & ENVrRONMENTAL SOLUTIONS

Haley & Aldrich, Inc. 58 Charles Street Cambridge, MA 02141-2147 Tel: 617.494.1606 Fax: 617.577.8142 Email [email protected] Letter of Transmittal HALEY & ALDRICHI

Date IU J File Number /Ool(- 0'l From erVn e 0 ) I bonn(I

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Copies Date Description &-F.

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OFFCES Remarks Cleveland Ohio Denver Colordo, Ha-tford Connecticut Los Angeles California j OCT 996 Manchester New Hampshire

Portland ______DEP/NOllTHEAST 1EGt 1 n Maine WosURN MASS. Rochester New York San Francisco Cahfornia Washington Districtof Columbia Massachusetts Deptment of Environmental Protection rFlhU On&, Li 18529 Permit No ______Transmillal i Transmittal Form for Application ::eview c and Payment Facility 10 (f known) 5 Applicationinformation

B ,W S C _ 0 3 INSTRUCTIONS Permit, Approval or Other Category (seven character code from the from the first page of the directions on How t p amples A P etc.,_

1. Please type or Tier IC _ n print. Use a Category Name separate Transmittal Permit to Proceed with Response Actions Form for each Brief Project Description application. - I I" , 2. Use an original, al Appilcant or Legally Responsible Official 3-part Transmittal L Form for each __. ..._Grace_Lo.-onn_, application. Last Name First Name L uri r Middle Initial Photocopies willnot be accepted for any 62 WhittemoreAvenue application or Address payment. (You may Cambridge MA 02140-1692 use photocopies for City/Town State Zip Code Teehod u1 r)?dinn e a.xtenor) reserve location, Administration where applicable.) David Wiahtman: Vice President of I1. Contact 3. Make check payable to Commonwealth of Facility, Site or IndividualRequiring Approval Massachusets, W.R. Grace & Co.-Conn. Please mail check Name of Facility, Site or individual and yellow copy of Transmittal Form to: 62 WhittemoreAvenue _ Department of Address Environmental Cdsismbteidge _ __MA 2140-1692 Protection, City/Town State Zip Code Telephone Number (including areacode and extension) P.O. Box 4062, Boston, MA, 02211. U Application Prepared By (if different from section B) 4. Both fee exempt and non-exempt Hal & Aldrich, Inc. applicants must Last Name First Name Middle initial mall yellow copy of B Charles Street Transmittal Form to: Address Department of Environmental Cambridge MA 02141-2147 ( 617 ) 494 - 1606 ext. Protection, City/Town State Zip Code Telephone Number (including areacode and extension) P.O. Box 4062, Wesley E. Stimpson 2332 Boston, MA, 02211. Contact LSP Number (for 21E only)

U Other Related Permits: it you are applying for other permits related to this application, please list them below.

Transmittal No. Category |Description

U Amount Due Special Provisions: l Fee Exempt* (city, town, district, or municipal housing authority) (state agency if permit fee is $100 or less) E Hardship Request (payment extension according to 310 CMR 4.04(3)(c) l Alternative Schedule Project Request (according to 310 CMR 4.05 and 4.10) * There are no fee exemptions for 21E sites, regardless of the applicant'sstatus.

Check No. 048420 Dollar Amount $ 3550. Date 10 /11 /96 Make check payable to Commonwealth of Massachusetts. Please mail check and yellow copy of Transmittal Form to: Department of Environmental Protection, P.O. Box 4062, Boston, MA, 02211 WHITE: must accompany application YELLOW: must accompany payment PINK: retain for your records Rev 7/94 -t

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Lul= LoOD p.'t - L0 UNDERGROUND ENGINEEuNG & ENvIRONMEwrAL SOLUTIONS

Haley & Aldrich, Inc. 58 Charles Street Cambridge, MA 02141-2147 Tel: 617.494.1606 Fax: 617.577.8142 Email: [email protected] Letter of Transmittal HALEY & ALDRICH

Date 10 October 1996 File Number 10063-065 Lit OCT P,9 From Veronica Wancho O'Donnell

To Massachusetts Department of Environmental rotectoY'N b Uflit s irtS s. 10 Commerce Way I Woburn, Massachusetts 01801 NO0HJON /d- Attention Edward Weagle Copy to C o Subject Resubmittal of Tier Classification for RTN 3-C

Copies Date Description 1 October 1996 Resubmittal of Tier Classifican for-RTN-3-9277

OMCrs Remarks Cleveland Dear Ed: Ohio Denver Enclosed, please find one copy of the resubmittal of the Tier Classification for RTN 3-0277, the W.R. Colorado Grace & Co. - Conn. facility located at 62 Whittemore Avenue, Cambridge, Massachusetts. We are submitting the original Initial Application for Response Action Permit for Tier I Disposal Sites (BWSC 03), Hartford Connecticut Tier Classification Form (BWSC-107A), and Numerical Ranking System (310 CMR 40.1511) under separate cover. Copies of these documents are provided in this report. Los Angeles California If there are any questions or comments, please do not hesitate to call. Manchester New Hampshire Veronica O'Donnell Portland Maine Rochester New York San Francisco California Washington District of Columbia UNDERGROUND ENGxNEERING & ENVIRONMENTAL SOLUTIONS

Haley & Aldrich, Inc. 58 Charles Street Cambridge, MA 02141-2147 Tel: 617.494.1606 I 10 Fax: 617.577.8142 Email: [email protected] HALEY & Letter of Transmittal - AILDRICH

Date 10 October 996 File Number 10063-065 From Veronica Wancho O'Donnell

To Massachusetts Department of Environne 1rtonot ® r a -.- 10 Commerce Way

Woburn, Massachusetts 01801 Attention Edward Weagle Copyto Subject Resubmittal of Tier Classification for RT 7/N y N

Copies Date Description 1 October 1996 BWSC 03 1 October 1996 BWSC 107A 1 October 1996 Numerical Ranking System Scoresheet

OMCES Remarks Cleveland Dear Ed: Ohio Denver Enclosed, please find the original Initial Application for Response Action Permit for Tier I Disposal Sites Colorado (BWSC 03), Tier Classification Form (BWSC-107A), and Numerical Ranking System Scoresheet (310 CMR 40.1511) for the W.R. Grace & Co. - Conn. facility located at 62 Whittemore Avenue, Cambridge, Hartford Connecticu Massachusetts, RTN 3-0277. The report in support of these documents has been submitted under separate cover. Los Angeles California If there are any questions or comments, please do not hesitate to call. Manchester New Hampshire Veronica O'Donnell Portland Maine Rochester New York San Francisco California Washington District of Columbia Massachuas Department of Environmental' tection BWSC-107A Bureau of Lste Site Cleanup

TIER CLASSIFICATION, TIER || EXTENSION & Release Tracking Number TIER 11TRANSFER TRANSMITTAL FORM 277 Pursuant to 310 CMR 40.0510 and 40.0560 (Subpart E) A. DISPOSAL SITE LOCATION: Disposal Site Name: W R Gare k o -

Street: e2 Whil-t- emnre Avensa Location Aid: _.

City/Town: _Camhri tlge ZIP Code: 02140-1692 Related Release Tracking Numbers That This Submittal Will Address: B. THIS FORM IS BEING USED TO: (check all that apply) Submit a new or revised Tier Classification Submittal for a Tier I Site, including a Numerical Ranking Scoresheet (complete Sections A, B, C, 1,J, K and L). a Numerical Ranking Scoresheet H Submit a new or revised Tier Classification Submittal for a Tier || Site, including (complete Sections A, B, C, F, G, I, J, K and L). Submit a Notice that an additional Release Tracking Number(s) is (are) being linked to this Tier Classified Site and rescoring is not required at this time (complete Sections A, B, J, K and L).If this submittal is for a Tier ISite, you must also submit a Minor Permit Modification Transmittal Form (BWSC-1 09). List Additional Release Tracking Number(s): Submit a Phase ICompletion Statement supporting a Tier Classification Submittal (complete Sections A, B,I, J, K and L). H Submit a Tier || Extension Submittal for Response Actions at a Tier 11Site (complete Sections A, B, D, F, G, I, J, K and L). 310 CMR 40.0630(4) H Submit a Tier i Extension Submittal for Response Actions taken after expiration of a Waiver, pursuant to (complete Sections A, B, D, F, J, K and L, and also complete Sections G and I or Section H).* Actions at a Tier 11Site F1 Submit a Tier || Transfer Submittal for a change in person(s) undertaking Response (complete Sections A, B, E, F, G, I,J, K, L, M, N and 0). Site, pursuant to H Submit a Tier || Transfer Submittal for a change in person(s) undertaking Response Actions at a Waiver 310 CMR 40.0630(6) (complete Sections A, B, E, F,J, K, L, M, N and 0, and also complete Sections G and I or Section H).* You must attach all supporting documentation required for each use of form indicated, including copies of any Legal Notices and Notices to Public Officials required by 310 CMR 40.1400. *NOTE: The Waiver expires on the effective date of this submittal and all further Response Actions must be taken as a Tier || Site. C. TIER CLASSIFICATION SUBMITTAL: Numerical Ranking Score for Disposal Site: (from Numerical Ranking Scoresheet) 1

Proposed Tier Classification of Disposal Site: (check one) Tier IA L Tier lB Tier IC L Tier Il

Check which, if any, of the Tier I inclusionary criteria are met by the Disposal Site, pursuant to 310 CMR 40,0520:

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

E] An Imminent Hazard is present at the time of Tier Classification. Ranking Scoresheet Check here if this Tier Classification revises a previous submittal for this Disposal Site. You must include a revised Numerical R with this submittal. If a Tier I Permit has been issued, you may also need to submit a Major Permit Modification Application (BWSC 10). If incorporating additional Release(s) into the Disposal Site, list Release Tracking Number(s): D. TIER || EXTENSION SUBMITTAL REQUIREMENTS: State the expiration date of the Tier 11Classification or Waiver for the Disposal Site, whichever is applicable: Attach a statement summarizing why a Permanent or Temporary Solution has not been achieved at the Disposal Site. A Tier || Extension is effective for a period of one year beyond the current expiration date of the Tier || Classification or Waiver. E. TIER I1TRANSFER SUBMITTAL REQUIREMENTS: State the proposed effective date of the change in person(s) undertaking Response Actions at the Disposal Site: Attach a statement summarizing the reasons for the proposed change in person(s) undertaking'the Response Actions. All Response Actions must be completed by the deadline applicable to the person who first filed either a Tier Classification Submittal for the Disposal Site or received a Waiver of Approvals. Revised 416/95 Supersedes Forms BWSC-010 (in part) and 014 Page 1 of 4 Do Not Alter This Form Massachu Department of Environmental S tection BWSC-107A Bureau of Waste Site Cleanup

TIER CLASSIFICATION, TIER 11EXTENSION & Release Tracking Number TIER I TRANSFER TRANSMITTAL FORM Pursuant to 310 CMR 40.0510 and 40.0560 (Subpart E) 277 G. CERTIFICATION OF ABILITY AND WILLINGNESS: > If providing either a Tier 11Classification Submittal or a Tier || Extension Submittal, the person who signs this certification MUST be the person named in Section J, or that person's agent. > If providing a Tier || Transfer Submittal, the person who signs this certification MUST be the person named in Section M, or that person's agent. I attest under the pains and penalties of perjury that (i) I/the person(s) or entity(ies) on whose behalf this submittal is made has/have personally examined and am/is familiar with the requirements of M.G.L. c. 21 E and 310 CMR 40.0000; (ii) based upon my inquiry of the/those Licensed Site Professional(s) employed or engaged to render Professional Services for the disposal site which is the subject of this Transmittal Form and of the person(s) or entity(ies) on whose behalf this submittal is made, and my/that person's(s') or entitys(ies') understanding as to the estimated costs of necessary response actions, that/those person(s) or entity(ies) has/have the technical, financial and legal ability to proceed with response actions for such site in accordance with M.G.L. c. 21 E, 310 CMR 40.0000 and other applicable requirements; and (iii) that I am fully authorized to make this attestation on behalf of the person(s) or entity(ies) legally responsible for this submittal. lithe person(s) or entity(ies) on whose behalf this submittal is made is aware of the requirements in 310 CMR 40.0172 for notifying the Department inthe event that lithe person(s) or entity(ies) on whose behalf this submittal is made learn(s) that it/they is/are unable to proceed with the necessary response actions.

By: Title: (signature)

For: Date: (print name of person or entity recorded in Section J or M, as appropriate)

If you are submitting either a Tier || Extension Submittal for a Waiver Site or a Tier || Transfer Submittal for a Waiver Site, you may choose to sign the alternative Ability and Willingness Certification found in Section H in place of providing the certification in Section G and the LSP Opinion in Section I. H. ALTERNATIVE CERTIFICATION OF ABILITY AND WILLINGNESS: > If providing a Tier || Extension Submittal for a Waiver Site, the person who signs this certification MUST be the person named inSection J, or that person's agent > If providing a Tier || Transfer Submittal for a Waiver Site, the person who signs this certification MUST be the person named in Section M, or that person's agent.

I attest under the pains and penalties of perjury that (i) l/the person(s) or entity(ies) on whose behalf this submittal is made has/have personally examined and amlis familiar with the requirements of M.G.L. c. 21 E and 310 CMR 40.0000; (ii) based upon my inquiry of the Consultant-of-Record for the disposal site which is the subject of this Transmittal Form and of the person(s) or entity(ies) on whose behalf this submittal is made, and my/that person's(s') or entity's(ies') understanding as to the estimated costs of necessary response actions, that/those person(s) or entity(ies) has/have the technical, financial and legal ability to proceed with response actions for such site in accordance with M.G.L. c. 21 E, 310 CMR 40.0000 and other applicable requirements; and (iii) that I am fully authorized to make this attestation on behalf of the person(s) or entity(ies) legally responsible for this submittal. lithe person(s) or entity(ies) on whose behalf this submittal is made is aware of the requirements in 310 CMR 40.0172 for notifying the Department inthe event that I/the person(s) or entity(ies) on whose behalf this submittal is made learn(s) that it/they is/are unable to proceed with the necessary response actions.

By: Title: (signature)

For: Date: (print name of person or entity recorded in Section J or M, as appropriate) I. LSP OPINION:

I attest under the pains and penalties of perjury that I have personally examined and am familiar with this transmittal form, including any and all documents accompanying this submittal. In my professional opinion and judgment based upon application of (i) the standard of care in 309 CMR 4.02(1), (ii) the applicable provisions of 309 CMR 4.02(2) and (3), and (iii) the provisions of 309 CMR 4.03(5), to the best of my knowledge, information and belief, > if Secton B of this form indicates that a Tier I or Tier I Classification Submittal which relies upon a previously submitted Phase I Completion Statement is being submitted, this Tier Classification Submittal has been developed in accordance with the applicable provisions of M.G.L. c. 21 E and 310 CMR 40.0000;

> if Section B of this form indicates that a Phase I Completion Statement or a Tier 1 or Tier I Classflication Submittal which does not rely upon a previously submitted Phase I Completion Statement is being submitted, the response action(s) that is (are) the subject of this submittal (i) has (have) been developed and implemented in accordance with the applicable provisions of M.G.L. c. 21 E and 310 CMR 40.0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G.L. c. 21 E and 310 CMR 40.0000, and (iii) complies(y) with the identified provisions of all orders, permits, and approvals identified inthis submittal;

SECTION I IS CONTINUED ON THE NEXT PAGE

Revised 416195 Su e e Frm ICnnC A p- (n pa) V al Page 3 of 4 Do Not Alter This Form Massachu Department of Environmental @tection BWSC-107A Bureau of *Ste Site Cleanup

TIER CLASSIFICATION, TIER 11EXTENSION & Release Tracking Number TIER 11TRANSFER TRANSMITTAL FORM 377 Pursuant to 310 CMR 40.0510 and 40.0560 (Subpart E) 1. LSP OPINION: (continued) > if Section B of this form indicates that a Tier I Extension Submittal or a Tier ii Transfer Submittal is being submitted, the response action(s) that is (are) the subject of this submittal (i) is (are) being implemented in accordance with the applicable provisions of M.G. L. c. 21 E and 310 CMR 40.0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G.L. c. 21 E and 310 CMR 40.0000, and (iii) complies(y) with the identified provisions of all orders, permits, and approvals identified in this submittal. I am aware that significant penalties may result, including, but not limited to, possible fines and imprisonment, if I submit information which I know to be false, inaccurate or materially incomplete.

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

LSP Name: Wescl sy E i- -i mpsan LSP#: 23325 Stamp: OF Telephone: 61 7-494-4 910 Ext.: 7 15 WESLEY FAX: (optional) 7 - A 42 E. 4 STIMPSON Signature: <. 4 No. 232PS Date: 4 01 ( J. PERSON MAKING SUBMITTAL: (For Transfer Submittals describe person currently unde W lnse actions, not transferee) Name of Organization: W,. Grace & Co. - Conn.

NameofContact: David Wightman Title: Vice President Administration

Street: 62 Whitte-more- Avenut-

City/Town: ramr -ir ge State: MA ZIPCode: 02140--1692 Telephone: 6-17-49R-49R3 Ext.: - FAX:(optional) 617-491-2029 K. RELATIONSHIP TO DISPOSAL SITE OF PERSON MAKING SUBMITTAL: (check one) W RP or PRP Specify: q Owner Q Operator Q Generator Q Transporter Other RP or PRP: E Fiduciary, Secured Lender or Municipality with Exempt Status (as defined by M.GL. c. 21 E, s. 2) L Agency or Public Utility on a Right of Way (as defined by M.G.L. c. 21 E, s. 5(j))

L Any Other Person Making Submittal Specify Relationship: L. CERTIFICATION OF PERSON MAKING SUBMITTAL:

Davi d Wightman , attest under the pains and penalties of perjury (i) that I have personally examined and am familiar with the information contained inthis submittal, including any and all documents accompanying this transmittal form, (ii) that, based on my inquiry of those individuals immediately responsible for obtaining the information, the material information contained in this submittal is, to the best of my knowledge and belief, tr , accurate and complete, and (iii) that I am fully authorized to make this attestation on behalf of the entity legally responsible for this subm . 1/th rs entity on whose behalf this submittal is made am/is aware that there are significant penalties, including, but not limited to, possible e d r- ent, for willfully submitting false, inaccurate, or incomplete information.

By: Title: Vi ce Pres-i dent Admini st--ra nn

For: (sgnt Gr .e o - Conn. Date: (print name erson or entity recorded in Section J) Enter address of the person providing certification(s), including Ability and Willingness Certification where applicable, if different from address recorded in Section J: Street:

City/Town: State: - ZIP Code: Telephone: Ext.: - FAX: (optional)

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

Revised 4/6/95 Sunrsade Frrs fWSClJ101 f art)- n Pa A Aor g Do Not After This Form A

SECTION I

Statement of orders, permits and/or approvals on which opinion is based.

Revised Tier Classification is being submitted in response to a Notice of Non-Compliance, dated 20 September 1996, issued by the Department of Environmental Protection after an audit of an initial Tier Classification submittal. 310 *R: DEPARTMENT OF ENVIRONMENTAL PROTE P0N9

MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL PROTECTION Bureau of Waste Site Cleanup

NUMERICAL RANKING SYSTEM SCORESHEET (310 CMR 40.1511)

CLASSIFICATION SUBMITTAL DISPOSAL SITE SCORE

Initial Submittal Re-Classification i I IV V VI TOTAL

120 126 40 100 -25 361

R e-Cascto

Disposal Site Tier Classification I II

Permit Category (Tier I Only) A B C

* **** **** *** *** ***** *** **

L. DISPOSAL SITE INFORMATION

DEP Release 3-0277 N: 4695775 Tracking Number(s) UTM Coordinates DEP Disposal Site E: 323850 Number(s)

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

Disposal Site Address 62 Whittemore Avenue

City: Cambridge, Massachusetts Zip: 02140-1692

Is the Disposal Site classified Tier I because it is located within the boundaries of a Zone It or Interim Wellhead Protection Area and groundwater concentrations equal or exceed RCGW-1 at the time of Tier Classification Yes [] No pursuant to 310 CMR 40.0520(2)(a)1.?

Is the Disposal Site classified Tier I because an Imminent Hazard is present at the time of Tier Classification N pursuant to 310 CMR 40.0520(2)(a)2.? IYes

I attest under the pains and penalties of perjury that I have personally completed this Numerical Ranking System Scoresheet, and have personally examined and am f iliar with the information contained in this submittal, including any and all documents accompanying this submittal, and in my professional opini a d judgment based upon: (i) the standard of care in 309 CMR 4.02(1), (ii) the applicable provisions of 309 CMR 4.02(2) and (3), and (iii) the pr vi ions of 309 CMR 4.03(5), to the best of my knowledge, information and belief, this Scoresheet was developed in accordance with the i r visions of M.G.L. c. 21E and 310 CMR 40.0000. 1 am aware that significant penalties may result, including, but not limited to, possi 1 a imprisonment, if I submit information which I know to be false, inaccurate or materially incomplete 2332 Wa Licens r o I Signature LSP Registration Number Date

Wesley F. Stimpson Haley & Aldrieh, Inc. 617-494-1606 LSP Name (Printed) Company Name bb.A elephone Number

W.R Grace & Co, - ConnO Responsible Party, Potentially Responsible Party, or Other Person who will provide ce 10 CMR 40.0009.

SSTIMPSON C-- NPHo.2 3 32 1/13/95 (Effective 2/1/95) CQ ST S 310 CMR - 1751 310 DEPARTMENT OF ENVIRONMENTAL PROTEC

40.1511 (Continued) U. EXPOSURE PATHWAYS

II. EXPOSURE PATHWAYS

Score according to 40.1512 - Exposure Pathway Designation Ceriteia

DESIGNA2yON

MEDIA NONE or EVIDENCE OF POTENTIAL LIKELY OR NOT CONTAMINATION EXPOSURE CONFIRMED APPLICABLE PATHWAY EXPOSURE PATHWAY

A. SOIL (includes Sediment) 0 100 150

B. GROUNDWATER 0 100 150

C. SURFACE WATER (Includes Wetlands) 0 100 150

D. AIR 0 100 200

Note: Score only the highest value for each media, i.e., score None or Not Applicable or Evidence of Contamination or Potential Exposure Pathway or Likely or Confirmed Exposure Pathway.

IL (A - D) Summary Rationalefor Section II A - D Values and Phase I Report References

A. OHM has been identified in soils at concentrations above applicable RCs (Environmental Data Report (EDR) by Haley & Aldrich, April 1988, Table I) - OHM is located beneath paved surfaces and at depths > 6"

B. OHM has been identified in groundwater at concentrations above applicable RCs (EDR April 1988; Table - No drinking water wells or

Zone II areas.

C. OHM has been identified in surface water at concentrations above applicable RCs (EDR April 1988; Table H) - Surface water is not used for drinking, boating, or swimming.

D. Odors have been identified in the past and are anticipated in the future for intrusive activities at the property.

II.E. OHM SOURCES

1 2 3 Number of OHM Sources 0 25,5

SECTION II SCORE (A. + B. + C. + D. + E.)

A. B. C. D. E. TOTAL: (15 - 700) 15 20 20 15 50 120

Check here if Section VI has been used to amend the score for this Section of the NRS.

1113/95 (Effective 2/1/95) 310 CMR - 1752 310 : DEPARTMENT OF ENVIRONMENTAL PROTE#N

40.1511 (Continued) III. DISPOSAL SITE CHARACTERISTICS

II1.A. OHM TOXICITY SCORE

Highest OHM Toxicity Score From Table HI.A. or Worksheet HILA.1. on Following Pages.

M SToxicity Score (1 - 80) OHM Scored: L.AD

Concentration and Media: 4,900 nm in soil 40

III.B. MULTIPLE OHMs

More Than One OHM With an OHM Toxicity Score of 2 30 No Yes

0 Ctn

ITI.C. OHM MOBILITY and PERSISTENCE

Score according to 40.1514 - OHM Mobility and Persistence

OHM Scored: Score (0 - 50)

III.D. DISPOSAL SITE HYDROGEOLOGY

Score according to 40.1515 - Soil Permeability

DEPTH TO GROUNDWATER SOIL PERMEABILITY

(in feet) LOw Medium High

>25 2 4 8

10.1 -25 4 8 12

5.1-10 8 12 16

0-5 12 20

SECTION II SCORE (A + B + C + D)

A. B. C. D. TOTAL: (3 - 180)

Check here if Section VI has been used to amend the score for tis Section of the NR.

1/13/95 (Effective 2/1/95) 310 CMR - 1753 310 C.DEPARTMENT OF ENVIRONMENTAL PROTECO

40.1511 (Continued)

Table III.A. OHM TOXICITY SCORE

CONCENTRATION (soil/sediment: g/g: surface/groundwaterug/1) OHM s 99 100 -999 1,000 - 9,999 10,000 - > 100,000 NAPL NAPL 100,000 NAPL < 0.5" 0. 5" - 12" > 12"

Arsenic I 30- 4 50 0 Benzene 15('25 35 45 55 65 75 is2ehheyphaae 1031) 40 50 0070

Cadmium 1 20 30 40 50

Cm4i CaboTe'elddTtrchorde_$ 30 40 $0 60 708 jw______

Chlorobenzene 5 is 25 35 45 55 65

ChrosnIumI '1 J0 '2 30 49

Chromium VI 10 20 30 40 50

Coal Tar 5 15_ 25 35 4$ 55 65 Cvanide 5 (II 25 35 45

L1jDichlorocthane ___2__3 _ 40 5______60____ 70 1.2 Dichloroethane (0) 20 30 40 50 60 70

Etybnzn 15 3$ 4$ $5 65 Ethylene Dibromide 20 30 40 50 60 70 80

2ldl OR Neu nne .$ 5 15 25...... 35 45 $. Gasoline (virgin product) 10 20 30 40 50 60 70

Lead 20 ~ 30 ,.4L..} 50 0W______Mercury .Qi) 30 40 50 60 70 80

Methyl Ethyl Ketone 5 15 () 35 45 55 65 MethylTrtButyllr 20...... 3 4x $.... 7...

Nickei 5 25 35 45

Phcnol __0_2_ _ 30__40- 50

PAHs 10 20 30 40 50 60 70

Tetrachloroethylene 10 30 40 50 60 70

L1.1 Trichloroethane 5 25 35 45 55 65

1/13/95 (Effective 2/1/95) 310 CMR - 1754 3100: DEPARTMENT OF ENVIRONMENTAL PROTA N

Table Ill.A. OHM TOXICITY SCORE

OHM CONCENTRATION (soil/sediment: up9 surface/groundwater ygl\) OHM s 99 100- 999 1,000 - 9,999 10,000- > 100,000 NAPL NAPL 100,000 NAPL < 0.5" 0.5" -'12" > 12"

Trichloroethylene , 5/5 25 35 43 35 65 ______75______

Vinyl Chloride 15 25 354555 1 65 75 Xv4Les10 203 4 0 60.

Zinc 1 10 20 ) 40

1/13/95 (Effective 2/1/95) 310 CMR - 1755 310* DEPARTMENT OF ENVIRONMENTAL PROTEMN

40.1511 (Continued)

Use Worksheet HI.A. 1. to determine the OHM Toricity Score for OHM not listed in Table fL.A. See 40.1513for Human Health-Based Toxicity Values for each OHM.

Worksheet HLI.A.1 OHM TOXICITY SCORE

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

< 5 1 10 20 30 40 50 60

5-19 5 15 25 35 45 55 65

20-29 10 20 30 40 50 60 70

30-39 15 25 35 45 55 65 75

40-50 20 30 40 50 60. 70 80

LA. OHM and Concentrations Used in Section ILA. .

OHM Human Concentration Concentration OHM Health-Based (Soil - Ug/g) ppm (Water - pg/I) ppb Toxicity Toxicity Value Score

Chloromethane 22 -ND- 9.9 10

Carbon Disulfide 8 0.18 300 15

1.1 Dichioroethene 28 0.042 9.6 10

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

4 Methyl - 2 Pentanone * 8 1.2 380 15

21Hexanone 25 0.38 310 20

Styrene 20 25 -ND- 10

2.2 Oxybis propane -NA- 28

Bromodichloromethane 25 --ND- 5.5 10

No human health based toxicity value given in MCP

1113/95 (Effective 2/1/95) 310 CMR - 1756 310 DEPARTMENT OF ENVIRONMENTAL PROTE q

40.1511 (Continued)

Use Worksheet IIL A. 1. to determine the OHM Toxicity Score for OHM not listed in Table HILA. See 40.1513for Human Health-BasedToxicity Values for each OHM.

Worksheet 11I.A.1 OHM TOXICITY SCORE

CONCENIRATION HUMAN HEALTH-3ASED Use g/g for Soil and pg/ for Surface Water and Groundwater TOXICITY VALUE s 99 100-999 1,000 - 9,999 10,000- > 100,000 NAPL NAPL I I 1 100,000 NAPL < 0.5" 0.5" - 12" > 12"

< 5 1 10 20 30 40 50 60

5-19 5 is 25 35 45 55 65

20-29 10 20 30 40 50 60 70

30-39 15 25 35 45 55 65 75

40-50 20 30 40 50 60 70 80

HILA..LOHM and Concentrations Used in Section HWLA. L.

OHM Human Concentration Concentration OHM Health-Based (Soil - pg/g) ppm (Water - pg/1) ppb Toxicity Toxicity Value Score

Napthalene 18 150 24,000 35

Nitrobenzene 40 -ND- 3.7 20

Benzo(a)anthracene 28 41 71.5 10

Benzo(a)pyrene 44 24 179 30

Benzo(b,k)fluoranthene 28 182.9 221 20

Chrysene 28 26 36.3 20

Benzo(g,h,i)perylene* 18 82 148.3 15

Chloroform 22 -ND- 12 10

1,2 Dichloroethene 25 -ND- 2.6 10

Phenanthrene 25 69 99.3 10

* No human health based toxicity value given in MCP

1/13/95 (Effective 2/1195) 310 CMR - 1757 310@: DEPARTMENT OF ENVIRONMENTAL PROTEN

40.1511 (Continued)

Use Worksheet lII.A. L to determine the OHM Toxicity Score for OHM not listed in Table XI.A. See 40.1513 for Human Health-BasedToxicity Values for each OHM.

Worksheet II.A.1 OHM TOXICITY SCORE

CONCENTRA7ON HUMAN HEALTH-BASED Use ug/g for Soil and ug/l for Surface Water and Groundwater TOXICITY VALUE s 99 100-999 1,000 - 9,999 10,000- > 100,000 NAPL NAPL I 1 100,000 NAPL < 0.5" 0.5" - 12" > 12"

< 5 1 10 20 30 40 50 60

5-19 5 is 25 35 45 55 65

20-29 10 20 30 40 50 60 70

30-39 15 25 35 45 55 65 75

40-50 20 30 40 50 60 70 80

III.A.J. OHM and Concentrations Used in Section 1II.A.J.

OHM Human Concentration Concentration . OHM Health-Based (Soil - pglg) (Water - pg/l) Toxicity Toxicity Value Score

Dibenzo (a.h) anthracene* 35.8 175.4

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

Butyl benzyl phthalate 20 0.111 10.2 10

Di-n-octyl phthalate* 24 85

p-chloro-m-cresol* 0.217 7.4

2.4 - Dimethyl phenol 18 -ND- 150 is

2.4 Dinitrophenol 25 -ND- 170 20

n-nitrosodiphenylamine 22 0.123 2.8 10

silver 25 3.6 20 10

* No human health based toxicity value given in MCP

1/13/95 (Effective 2/1/95) 310 CMR - 1758 310@ DEPARTIMENT OF ENVIRONMENTAL PRO SN

40.1511 (Continued)

Use Worksheet 1I.A.J. to determine the OHM Toxicity Scorefor OHM not lisied in Table HI.A. See 40.1S13for Human Health-BasedToxicity Values for each OHM.

Worksheet Il.A.1 OHM TOXICITY SCORE

CONCENTRA7ON HUMAN HEALTH-BASED Ise ug/p for Soil and up/I for Surface Water and Groundwater TOXICITY VALUE 99 100 - 999 1,000 - 9,999 10,000- > 100,000 NAPL NAPL 100,000 NAPL < 0.5" 0.5" - 12" > 12"

< 5 1 10 20 30 40 50 60

5-19 5 15 25 35 45 55 65

20-29 10 20 30 40 50 60 70

30-39 15 25 35 45 55 65 75

40-50 20 30 40 50 60 70 80

HILA. L OHM and Concentrations Used in Section HLA.J.-

OHM Human Concentration Concentration OHM Health-Based (Soil - ug/g) ppm (Water - ug/1) ppb Toxicity Toxicity Value Score

Barium 8 611 160 15

Beryllium 38 2.8 -ND- 15

Copper 25 420 90 20

Antimony 40 3.9 -ND- 20

Selenium 25 4.0 400 20

Iron* 16,000 -NA-

Total Phenolics* 28.4 0.06

Formaldehyde 20 320 4.6 20

Oil & Grease* 81,700 464

Petroleum Hydrocarbons* 11,000 -NA-

- No human health based toxicity value given in MCP

1/13/95 (Effective 2/1/95) 310 CMR - 1760 3100 DEPARTMENT OF ENVIRONMENTAL PROTI2RON

40.1511 (Continued) IV. HUMAN POPULATION AND LAND USES

IV.A. HUMAN POPULATION

Residential Population None 1 - 99 100-999 2 1,000 Within M1 Mile 0 5 10

Institutions None One or More Within 500 feet 10

On-Site Workers None 1 - 99 100 - 999 2 1,000

0 5 10 15

IV.B. AQUIFERS

Sole Source Aquifer No Yes

Name: 25

Potentially Productive Aquifer No Medium or High

co 15

IV.C. WATER USE

Proximity of Disposal Site to Not Applicable (NA) Zone A Zone 1I, IWPA, or Public Drinking Water Supply Source SW Intake < 400'

20 50

Persons Served by Public Drinking Water Supply NA 25 - 999 1,000 - 4,999 5,000 - 49,999 50,000

0) | 5 10 20 25

Private Water Supplies Within 500 Feet None Commercial Agriculture Drinking Industrial Residential Food Processing (Not Ingested)

0 10 25

Alternative Public Water Supply Available Yes No (Viable Public Water Supply in Disposal Site Community and Public Water Connection s, 500 Feet from Site)_ 0 25

SECTION IV SCORE (A + B + C)

A. B. C. TOTAL: (0 - 205) 25 0 15 40

Check here if Section VI has been used to amend the score for this Section of the NRS.

1/13/95 (Effective 2/1/95) 310 CMR - 1761 310 0 DEPARTMENT OF ENVIRONMENTAL PROTE]'

40.1511 (Continued) V. ECOLOGICAL POPULATION

V.A. ENVIRONMENTAL RESOURCE AREAS

RESOURCE LOCAION

Area of Critical Environmental Concern > 500 from Site s 500' from Site On-Site

o 20 30

Species of Special Concern, > 500 from Site On-Site or s 500' from Habitat Threatened or Endangered Species Habitat 0 30

Wetlands, Certified Vernal Pool, or > 100' from Site s 100' from Site On-Site Outstanding Resource Water 0 20

Fish Habitat > 500' from Site s 500' from Site On-Site

0 20 30

Protected Open Space > 500' from Site s 500' from Site On-Site (Local/State/Federal/Trustee) 0 )30

SCORE SECTION V.B. ONLY IF SECTION V.A. SCORE IS > 30.

V.B. ENVIRONMENTAL TOXICITY SCORE

HighestEnvironmental Toxicity Score From Table V.B. or Worksheet V.B.1. on Following Pages.

Toxicity Score ( - 35) OHM Scored: Cadmium, Mercury, MPc5, Zinc Txd 20 Concentration and Media: 560 pob (GW). 3.8 oom (S). 4900 Dom (S), .100 ob (GW). 11.975 oom (S)

SECTION V. SCORE (A. + B.)

A. B. TOTAL: (0 - 185) 80 20 100

Check here if Section VI has been used to amend the score for this Section of the NRS.

1/13/95 (Effective 2/1/95) 310 CMR - 1762 31*: DEPARTMENT OF ENVIRONMENTAL PROT N

40.1511 (Continued)

Table V.B. ENVIRONMENTAL TOXICITY SCORE

CONCENTRATION (so ilsediment: ag/; su facegroundwaer ug/I) OHM < 1 1-99 100- 999 1,000 - 9.999 2 10.000 ......

Benzene 0 1 ) 10 15

Cadmium 10 15 25 30

Carbon Tetrachloride ______10______5 _ Chlorobenzene 5 10 15 20 25 ChromiumnIHI 1 5 10 15 20

Chromium VI 5 10 20 25

Ca ar 4 3 __0____3__20__25 _ Cyanide 5 10 20 25 1, itclroetae *5101 02 1,2 Dichloroethane 0 n) 5 10 15 Ethyhbennen 0

Ethylene Dibromide * 5 10 15 20 25 #2 id Oil (virgin product) * * .: 5 2 X

Gasoline (virgin product) * 5 10 15 20 25

Mercury 15 n0 . 25 30 35 Methylene Chloride .;>%t* .:.:..:.:20 25x.~.

Methyl Ethyl Ketone * 5 10 15 20 25 MTert Buy her*: .:::0...3......

Nickel .1 5 115 20 ...... 1 I

PAHs 5 10 15 20 25

Tetrachloroethylene 0 1 10 15

1,1,1Trichloroethane 0 1 5 10 15 Tr~~rhlar~~~oflhviene~~0.. t:§.::.:i:.. ,1 ......

1/13/95 (Effective 2/1/95) 310 CMR - 1763 31&: DEPARTMENT OF ENVIRONMENTAL PRODON

Table V.B. ENVIRONMENTAL TOXICITY SCORE

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

y oride 5 10 i5 20 25

ines * 5 20 . 255 Zinc 15 10 j 15

* Scores derived by default methods 40.1516(2).

1/13/95 (Effective 2/1/95) 310 CMR - 1764 310 DEPARTMENT OF ENVIRONMENTAL PROTE N

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

Worksheet V.B.1 ENVIRONMENTAL TOXICITY SCORE

CONCETRA TION ENVIRONMENTAL TOXICITY VALUE Use ug/g for Soil and gg/l for Surface Water or Groundwater

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

10 0 1 5 10 15

20 1 5 10 15 20

30 5 10 15 20 25

40 10 15 20 25 30

50 IS 20 25 30 35

V B-1. OHM and Concentrations Used in Section V B. 1.

OHM Environmental Concentration Concentration Environwental Toxicity Value (Soil - ug/g) (Water - g/i) Toxicity Score

1/13/95 (Effective 2/1195) 310 CMR - 1766 310 : DEPARTMENT OF ENVIRONMENTAL PROT ON

40.1511 (Continued) VI. MM GATING DISPOSAL SITE-SPECIFIC CONDITIONS

VI. MITIGATING DISPOSAL SITE-SPECIFIC CONDITIONS

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

Under Section IV.C. Water Use, the Norberg well is not currently being used and, in fact, has never been used and is not equipped with a pump. The well

is constructed to withdraw groundwater from fractured bedrock hundreds of feet below the water table aquifer that has been impacted by the site and separated

by a large 80 foot clay layer. Mr. Norberg has no current plans to withdraw groundwater from the well. Therefore, a 15 point deduction has been made in

the score of Section IV.C. Information upon which the presence of the well was determined and the current well status determined was obtained after the

preparation of the written reports and is based on personal communications with Mr. Norberg and a review of site geology information in the Phase n1 reprt.

Under Section V. Ecological Population, Part A, a 10 point reduction has been made in the score of Section V.A. for fish habitat on site based on data

available in the December 1994 Long-Term Monitoring Plan, Tables In and IV. Naphthalene had not been detected in surface water collected from Jerry's

Pond during any of the five sets of surface water samples collected from the Pond (sample location SW-1). The samples were collected in 1990, 1991, 1992,

1993. and 1994. Three sets of sediment samples were collected from Jer's Pond (sample location SD-1). The sample collected in 1990 indicated 13 ppb.

of naphthalene, the sample collected in 1991 indicated 1800 ppb naphthalene, and the samples collected in 1992 had non-detectable levels of naphthalene.

based on the lack of nahthalene in the surface water sediments and the non-detectable levels durig the 1992 sampling event, further sediment sampling

was not conducted.

We have reviewed published values from Long and Morgan (1991) and Guidelines for the Protection and Management of Aquatic Sediment Quality in

Ontario (1993) which indicate an effects range from medium to sever at levels of 2,100 pb to 100,000 ppb, respectively. The nahthalene concentrations

detected in March 1991 as well as the general sediment concentration indicated by the data were below both of these concentrations,

1/13/95 (Effective 2/1/95) 310 CMR - 1767 118529 Bureau Of Waste Site' up Trusmtal BWSC 0 Tier 1A BWSC 02 - Tier 'B BWSC 03- Tier Ic Intl alApplicalon for Response Acton Penmit for Tier I Disposal Sites * Disposal Site Information

0 Check heref there is more than one applicant. [L L Note: 1. Which permit category are you applying for? Tin IA= o Tier IA(Permit Caiegory: BWSC 01) F-- -1 NRSa550* o Tier IB(Permit Category BWSC 02) li Tier IC(Permit Category: BWSC 03) 450t NRS <550: DEP/NC 2. I'j W.R. Grace & Co.-Conn. TinrICS 350ssNRS <450 62 Whittemore Avenue

Cambridge, MA 02140-1692

3. List each release tumcdng number and date of release notification for each release or threat of release that isthe subject of this -permit application. For those sits identified on the Transition List of Sites and Locations (the 1993 Transition List) and any addendum thereto (pursuant to 310 CMR 40.0600) provide the Disposal Site Number in place of the Release Tracking Number (fat addcnal pages if ne&ed:

Release TrLdng Number D&tef Notificaion 3-0277 NOR Date 2/9/87

4. List the map(s) and parcel number(s) of each lot that is the subject of this permit application. Attach a copy of each tax asuuusors map(s) showing these parcels:

Municina Tar sessor Mao) PacNumbers City of Cambridge; Jan. 1978 Nos. 129, 130, 131. scale 1-60'

5. Basis for Tier Classification:

a. M Numerical Ranking Score (NRS) Score: 361

b. O inclusionary criteri

Basis for incluslonary criteria (complefe onty f 5b Isappabek O Evidence of groundwater contamination with OHM exceeding applicable RCGW-1 reportable concentrations and such groundwater is located within an interim Welhead Protection Area or Zone 1l.

O Disposal site at which an immient Hazard is present at the time of Tir Cssffction.

DPOon Page1I f 11 M*wgUCnuSas DM#98IWRaL 01w uaunamia ruai cu 118529 Bureau of Waste $lfhup Timma/ BWSC 0 - TierIA BWSC 02- Tier IB 'therei BWSC 03- Tier IC 0*y one ; InlaJ Application for Response Action Permit for Tier / Disposal Sites applicant, you do not need to cormpl"te this U Primary Representative Information section. 1. Primary Representative 2. f there is more Man one la the Primary Representative also an applicant? O Yes O No applicant, then the Primary Repre- sentative should complete this page.

3. The Primary Represntative for muftiple applicants wlI receive the annual compliance surmne fee sttment for the disposal site. conarauntvau

2. Primary Representative Certification

1 certify under the penaltes f w thatl fIuly authorized to act on behaf of all persons submittig this pernd application for the following purposes:

e to receive orl and written corres nce from DEPwithrespecttothisapplcation; e to receive ora and written corres enee from DEP with respect to the performance of response adions upon bane of a Tier i permit and * to receive any sttement of fee ulred by 310 CMR 4.03(3) upon Issuance of a Tier I permit

I am aware that there ignificnt penalties, including, but not limited to, possible fines and imprisonnent, for wlily submitting false, inaccurate r incomplete inforaion.n

-Wa

- - ,. A - l 0-ne 411 MC==11Wne-rr 1JJ5uDarIn 01 tnnfwMrulaI rnnwawun 1118529 Burau of Waste SI up Truamrftui# BWSC 0 -Tier IA BWSC 02- Tier ID BWSC 03- Tier IC ute: i Inital Application for Response Action Permit for Tier I Disposal Sites ALL applicants must complete this section. * Applicant Information Where there is more than one APPUCANT, make 1. Applicant: copies of this W.R. Grace & Co.-Conn. page, have each a,cant povide this information, David Wightman and then attach all copies to this Vice President of Administration Permit Applica- na tion. 62 Whittemore Avenue

Cambridge MA 02140-1692 wowra Sub 2%7axa (617) 498-4983

Caon rea%

2. Type of applicant (check one):

I3 individual 0 sole proprietorship C patnership El corporation O3 realty trust O stae authority 0 municipality 0 state agency 0 fhder agency O other, please specify:

3. Relationship of applicant to disposal site (drehcalhastapp&i

current owner (as defined k Secon 5(a)(1) ofM.L c21E) current operator (as defined a Sectin 5(a)(1) of AtL c 21E) M past owner (a defnedhk Secion 5(a)(2)f MG.L v21E) past operator (as defned InSecton 5(a)(2) MALAf c 21E) 0 generator (as deflndhi Section 5(a)(3) of M&L c21E) transporter (as defnedin Section 5(a)(4) of MAG.L c21E) 0 otherlegally responsible party (as defined'k Sedbon 5(a)(5) of MAL c21E) 0 other person (as defined kn 310CMR 4=0.0(10))

r _' OA" Pao 3 of 11 aassacnuauus em anurmwnmeman racuon 118529 Bureauof Waste .nP Taowlhul BWSC f- Tier IA BWSC 02- Tier IB BWSC 03- Tier ic Inital Application for Response Acton Pernit for Tier I Disposal Sites * ParceI Informalion Nate: if the current owner(s) or operator(s) as defined InSection Purcel: 5(a)(1) of M.G.L c 21E, Isnot an MapNumber City of Cambridge; Parcel Number Nos . 129. 130.131 Nos 129 130 131 applicant, provide Jan. 1978; scale 1"-60' the following Current Owner (ifdifftrent from the appkant): . SAME AS APPLICANT Information for the owner(s) and operator(s) for each rars that Is the subject of this applIcatIon. Aftch additional copies of this page as na - sary. aft/tn-SW cn

Current Operator (ifdffareant from the owner): SAME AS APPLICANT

-we

flumerar

cas- wssa a.ast

",-, -n-A PI~.dlSM%WV4q A 4i 11 0 --q Maemobnents e unt Envwrsmntsl Prtelction a 118529 Bureau of Waste UP Tsam BWSC 0 - Tier IA BWSC 02- Tier lB BWSC 03- Tier IC Inital Applicaton for Response Action Permit for Tier I Disposal Sites U Appiucant's Compliance History

imate: 1. List each Tier I perm held by the appicant for other disosal sites: Each applicant must complete Release Tacking this section. For BWSC Permit Number Numbeds disposal sites with more than one APPLiCANT, make copies of this section. have each applicant complete this information, and then attach all copies to this Permit Applica- tion. 2. List each Tier i disposal sit where the applicant is conducting response actions: D is a She Name Release Tracking Numbers'

Acton. MA; Indepence Dr. RTN 2-0006 Site is listed as "Priority Confirmed" with site status as "undetermined". Listed as confirmed on 1/15/87. Site listed as being in Phase 3

eForthose sites Identified on the Transition List of Sites and Locations (the 1993 Transition List) and any addendum thrS (pursuant to 310 CMR 40.0600) provIde the Disposal Sit. Number in place of the Release Tracking Number.

3.Ust allother permits or licensee Isued by the Department and hld by theapplicant thatare material to this disposal sf Permit Permit Proaram Faciy ID

e AirQuality NOTE 2

e Haardous Waste (M.G.L c. 210) NOTE 3

e Solid Waste

e ladusbial Wastewatar Management

* Water Supply NOTE 4 e Water Pollution Control: Surface Water Groundwater Sewer Connection - Wetland & Waterways P-M..K "4e Mascmtts Da nant Environmental Protection 118529 Bureau of Waste S it loup8 Transmittalt BWSC 01 -Tier IA BWSC 02- Tier lB BWSC 03-Tier Ic InitalAppfication for Response Acton Permit for TierI DisposalSites a Applicant's Compliance History (cont.)

4. List all other permits, licenses, certifications, registrations, variances, or other approvals issued by other federal, state, or local authorities and held by applicant that are material to this disposal site:

Issuing Identification Date Authority Number ssued

Massachusetts Water Resources Authorit Sewer Use - 09001993

5. Attach a statement which details the applicant's history of compliance with the Department's requirements, includIng, bt not imited to, M.G.L c.21E, 310 CMR 40.0000, and other laws for the protection of health, safety, public welfare and the environment administered or enforced by federal, state and local government agencies, that are material to the disposal Site. Such statement should identfy information such a: action(s) material to the disposal site taken by the Department to odor=s itsrequirements including, but not limited to Notice of Noncompliance (NON), Notice of Intent to Assess Civil Administrtive Penalty (PAN), administrative enforcement order, Notice of Responsibiiity (NOR), Notice of Intent to Take Response Action (NORA); Administrative Consent Order Judicial Consent Judgment similar administrative actions taken by other stlates, federal, or local agencies; and/or civil or criminal actions material to the disposal site brought on behaf of the Depaitmnt or other federal, state, or local agencies and any additional information relevant to the applicant's history of compliance. For each action identified, give the name of the issuing authority and Identification number, Ifavailable, and a description of the noncompliance cited, the current status of the matter, and final disposition, Kany, using the sample format below. NOR

DEQE 2/9/87

RTN 3-0277 0AW

A release of oil or hazardous materials had occurred at the Grace Facility on Whittemore

Ayenge, The NOR requested additional investigations ard assessments to define the impact of

the release on public health and the environment, and to determine what, if any, remedial measures would be necessary.

Phase IV of the MCP

Still in MCP (ADDITIONALLY, SEE NOTE 1) . &Wageon-

(Make additionalcopies of this page as needed.) 0 0

BWSC 03: Initial Application for Response Action Permit for Tier I Disposal Sites Section E 5. (con't)

Action: Audit Findings and NON Issuing Agency: DEP Date: 20 September 1996 ID Number: RTN 3-0277

Description: Audit findings by the DEP stated that there were deficiencies in the original Tier Classification submitted tho the DEP, An interim deadline of 9/27/96 was established for addressing the deficiencies.

Current Status: Extension Requested to Interim Deadline

Final Disposition: see Extension Information below

Action: Interim Extension Deadline Issuing Agency: DEP Date: 1 October 1996 ID Number: RTN 3-0277

Description: DEP granted a request by W.R. Grace to extend the submission deadline to 11 October 1996.

Current Status: Filed on 11 October 1996

Final status: Filed on 11 October 1996 COMPLIANCE HISTORY Y FOR W.R. GRACE & CO. - CONN. ( OFFICE/LABORATORY COMPIANCHISTORYQMAH CAMBRIDGE,ftOR SACHUSETIS BUILDINGS A 62 WHITTEMORE AVENUE, INOTE I - The compliance history information that is enclosed pertains to the office/laboratory buildings that are currently owned by Grace and are located adjacent to the areas subject to 21E requirements. Specifically, Grace has performed a review of its available records to identify current permits/licenses pertaining to these buildings as well as violation notices on file for the previous five years (back to 11/90).

The 21E disposal site sits upon an area that was the site of a former chemical manufacturing facility. The facility operated from 1919 to 1983 when manufacturing was discontinued and the buildings were demolished. As referenced above, Grace stills owns and operates several office buildings located on the site that are used to house administrative workers and contain laboratories that conduct research and development (R&D) and pilot plant work. Grace believes that it would be virtually impossible to reconstruct a complete permit and compliance history for the site's manufacturing facilities that operated for 64 years and were discontinued 12 years ago. Further, Grace believes that such a history is not relevant to the Company's current ability to perform remediation which may be required. Grace has previously submitted to the Department extensive information concerning this site including the seven volume report titled, Environmental Data Reoort for the W. R. Grace & o. Property in Cambridge Massachusetts (Haley & Aldrich, 4/88). Grace requests that the Department contact the facility if it believes that specific additional historic information is required.

NOTE 2 - The facility has an air registration on file with the Department (Application Number MBR-84-COM-001).

NOTE 3 - The facility is not permitted by the Department to store, treat or dispose of waste classified as hazardous under the Resource Conservation and Recovery Act (RCRA). The facility is classified as a hazardous waste generator (identification number MAD00140915).

As a follow-up to a RCRA regulatory compliance inspection the facility received a Notice of Noncompliance (NON) from the Department dated 10/17/91. The NON requested that the facility update.its RCRA contingency plan, revise the labels of some hazardous waste drums and move some hazardous waste drums from a satellite accumulation area to an accumulation area. The facility promptly implemented the requested actions.

] The NON described above concerns the paperwork requirements under the RCRA hazardous waste regulations that apply to the waste materials managed in Grace's current office/laboratory buildings. Grace is aware of no information to suggest that these purported violations resulted in any environmental impairment or that these resulted in a release of hazardous materials onto the property that is subject to 21E requirements.

NOTE 4 - The facility has numerous cross connection permits issued by the Department due to tie-ins to the MWRA water system. These include permit numbers 049170939, 049170242, 049170879, 049170878. 049170877, and 049170244.

NOTE &- Grace's Cambridge facility maintains a sewer use permit from the Massachusetts Water Resource Authority (MWRA) under which ] wastewater from the office/laboratory buildings are discharged into MWRA sewer system. Notices of Noncompliance (NON) concerning this permit that were identified during the facility record review, are discussed below. In each case in which a NON was received, the facility investigated the cause of the purported violation and sought to take corrective actions to the satisfaction of the MWRAL These written NON's fall into several categories.

First, the facility's MWRA permit requires that the facility monitor its sewer discharge for numerous parameters. One such requirement is continuous monitoring for pH with a specified pH discharge limitation range. Based upon Grace's self reporting of pH results, reportable excursions were experienced on the following dates, 11/22/91, 8/19/92, 12/22/92, 3/16/93 and 8/30/93. In spite of the fact that the facility has remained in compliance with its pH limitations greater than 99% of the time, in each case of a reportable excursion Grace promptly contacted the MWRA with its view as to whether a violation had in fact occurred, and its plan to prevent a reoccurrence. Another monitoring requirement is quarterly sampling and analysis for chromium. The facility received a Notice of Violation (NOV) from the MWRA, dated 9/14/93, that cited one purported exceedance of the facility's chromium discharge limit. Although the facility could not identify a basis for this purported violation it reviewed its solids settling procedures to minimize the potential that any such violation would occur. The facility received a Notice of Noncompliance and Order, dated 3/11194, from MWRA citing many of these purported exceedances and requesting submittal of a corrective action plan. Grace submitted the plan and has continued to implement steps to minimize discharge violations.

Second, the facility received an order from the MWRA on 9/30/92 to cease a discharge into the MWRA sewer from a pilot scale manufacturing facility. Grace and the MWRA had a dispute as to whether this discharge was authorized by Grace's then existing discharge permit. Grace immediately took steps to modify its permit to explicitly include this discharge. -Subsequently, in order to resolve the disagreement, Grace signed a Consent Agreement with the MWRA on 1/10/94 in which it agreed to pay a £90,000 penalty without an admission that a separate permit was required. As stated in the Agreement "the payment is made for settlement purposes only and does not reflect a finding or admission that Grace was in violation of the MWRA regulations or orders." Grace is aware of no information to suggest that the discharge that was the subject of the dispute resulted in any environmental impairment.

Third, the facility received an NOV from the MWRA dated 7/26/93 in which it asserted that Grace had failed to submit a result for pH in a required report. Grace had in fact submitted the result in a timely manner but had placed the data on the wrong MWRA form. The facility resubmitted the data to MWRA on the proper form. On early 1994 Grace notified the MWRA that due to personnel error, a 12193 monthly sample and a fourth quarter 1993 sample had not been taken for analysis. At MWRA's request Grace promptly took additional samples and submitted the analyses to MWRA. In addition the facility revised sample scheduling procedures to prevent a reoccurrence. The subsequent MWRA Order of 3/11/94 cited the facility for failure to collect the quarterly sample.

The NOVs described above concern the wastewater discharges of Grace's current office/laboratory buildings to the MWRA sewer system. Grace is aware of no information to suggest that these purported violations have resulted in any environmental impairment or that these have resulted in a release of hazardous materials onto the property that is subject to 21E requirements.

a- Mauel &wifs oft eEnvitkwnmntal Protaction 118529 Burau of Waste Site up TruinAW - BWSC 01 - TierIA- BWSC 02- Tier ID BWSC 03-Tier IC Inilal Application for Response Action Penit for Tier I Disposal Sites fj7ApplicantCertificalions

Nate: Each applicant 1. ion of Submittal must complete David Wightman this section. For 1 catiy under the penalties of law that I have disposal sites with personally examined and am famiar with the infornation more than one contained Inthis submittal, Including any and all docu- APPLICANT, make ments accompanying this ceftification, and that, based on Vice Presi t o dministration copies of this my Inquiy of those individuals immediately responsible page, have each for obtair ing the information, the material information applicant containecl herein is,to the best of my knowledge and complete this belief, true, accurate and complete. I am aware that there inforiation, and ar signifcant penalties, including, but not limited to, then attach all poesible lines and Imprisonment, for willfully submitting copies to this false, inneurate or incomplete information.' 10/10/96 Permit Appiica- tion.

2. Statemen of Abiliy and Wiliinaness David Wightman certify under the penalties of law that Ihave personaly examined and am familiar with the requirements of M.G.L . 21E and 310 CMR 40.0000 and, based upon my inquiry of those Licensed Site Professionals employed Vice Presid nt Affdministration or engage to render Professional Sevices at the disposal site that is the subject of this permit application and my understanling-a to the likely costs and necessary response actions at this site, I believe that I have the technical, inancial and legal ability to proceed with rmsponse ictions at this site in accordance with M.L c. 10/10/96 21E, 310 CMR 40.0000 and other applicable requirements. lam awam of the requirements in310 CMR 40.0172 for notifying the Department Inthe vent that lam unable to proceed with such response acton

O-..e7M 44 MasanUsttsbe t aavenmanw rrtacuon i 118529 Bureau of Waste SRJP TamaWI -BWSC -OF-Tier 1A BWsC 02- Tier 1B BWSC 03- Tier IC Intial Applcation for Response Acton Permit for Tier I Disposal Sites HuRequired Technical Submittals with Permit Application

1. Attachier I Classifiation Submittal to this application.

2. Please indicate which of the following response actions are in progress or have been completed at this disposal site at the time of this permit application:

esrnowg Actions Completed inharess Prelimiaruy Response Actiods Limited Removal Action 0 0 Immediate Response Action (iRA) C 0 Rekase Abatement Masure (RAM) O3 O Utility Related Abatement Measures (URAM) O3 0 Phase I Initial Site Investigation E 0 Othir 0 0

Compreenske Response Actions Phae 11- Comprehensive Site Assessment lD 0 Phase III - Identification. Evaluation and Selection of Comprehensive Remedial Action Alternatives xiM 0 Phase IV- Implementation of the Selected Runedial Action Alternative (Remedy mplementation Plan only) 0 E0 3. Please indicate which of the following Status Reports, Phase Reports, or Completion Statements have been prepared for rssponsu actions that are inprogress or have been completed at the disposal site at the time of this permit application. Am such report, other than LRA documentation, shall be submitted as part of this permit application even I previously submitted to DEP: SubmIted with *SEE ATTACHED

Lkmllsd Removal Action documentation 0 Yes 0 No Immediate Response Action (IRA) Plan(s) D Yes 0 No IRA lat: Report(s) D Yes 13 No IRA Completion Report(s) D Yes 0 No Ralm1se Abatement Measure (RAM) Plan(s) D Yes O0 No RAM Status Report(s) D Yes O No RAM Completion Report(s) 0 No Utility Relied Abatement Moures (URAM) 0 Yes 0 No O3 Yes URAIM Status Report(s) 0 No URAM Completion Report(s) D Yes. 0 No " Ya Pha I Report 0 No 0 YU Phasm I Report Completion Statement D No 03 YU Phas|1 Scope of Work 0 No 0 Yes Pha11l Report 0 No 0 Yes Phasn il Completion Statement 0 No 0 Yes Remedial Action Plan D Yes 0 No Phase [if Completion Statement o Yes O No Remedy Implementation Plan (RIP) 0 No Other 0 Yes 0 No POORRnfji 0

Addendum to BWSC 03 - Tier IC Initial Application for Response Action Permit for Tier I Disposal Sites

G: Required Technical Submittals with Permit Application

3. Please indicate which of the following Status Reports, Phase Reports, of Completion Statements have been prepared for response actions that are in progress or have been completed at the disposal site at the time of this permit application. Any such report, other that LRA documentation, shall be submitted as part of this permit application even if previously submitted to DEP:

Response: As part of the Public Involvement Plan process, a review of the presence/absence of W.R. Grace files at both public repositories and the DEP was conducted during March 1996. Based on the results of the review, copies of all missing reports were made and submitted to the DEP and the repositories. We have attached a copy of the transmittal to the DEP with this Initial Application. Because of the volume of documents and because they were recently re-submitted to the Department, we are considering this fulfillment of this section of the Initial Application.

F:\ 10063\066\tierlapp.wpf UNDERGROUND ENGINEERING & ENviRONMENTAL SOLUTIONS

Haley & Aldrich, Inc. 58 Charles Street Cambridge, MA 02141-2147 Tel: 617.494.1606 Fax: 617.577.8142 Email: [email protected] HALEY & Letter of Transmittal ALDRICHI

Date 26 March 1996 File Number 10063-066 From Anthony J. Bonasera

To Department of Environmental Protection, Northeast Regional Office 10 Commerce Way Woburn, Massachusetts 01801 Attention Ed Weagle Copy to Subject W.R. Grace (RTN 3-0277) documentation

Copies Date Description I. Apr-85 "Report on Subsurface and Hydrogeological Condition for the Alewife Center Master Plan Study"; Haley & Aldrich, Inc. Apr-85 "Environmental Assessment Report for the Proposed Alewife Center Development at the W.R. Grace Property. 1 May-87 Report on Available Environmental Data for Building I of the Alewife Center Project Haley & Aldrich, Inc.; File No. 611802. OFFICES Cleveland May-88 Supplemental Final Environmental Impact Report; Monacelli Ohio Associates, Inc. in association with HMM Associates, Segal Denver DiSarcina Associates, H&A, Paladin CADD Services, Inc., Colorado Hayden/Wegman, Inc. Hartford Connecticut 1 Sep-89 "Work Plan: Building 5 Soil Sampling, Alewife Center, Cambridge, Massachusetts"; Haley & Aldrich, Inc. Los Angeles Calfornia 1 Jan-90 "Hazardous Material Management Plan, Alewife Center, Manchester Cambridge, Massachusetts;" Haley & Aldrich, Inc. New Hampshire 1 Nov-94 "Environmental Risk Evaluation"; Cambridge Environmental Inc. Portland Maine Rochester New York San Francisco Remarks California continued on next page Washington District of Columbia 1w WUNDERGROUND ENGINEEuNG & ENvIRoNMENTAL SOLUrIONS

Haley & Aldrich, Inc. 58 Charles Street Cambridge, MA 02141-2147 Tel: 617.494.1606 Fax: 617.577.8142 Email: [email protected] Letter of Transmittal

Copies Date Description

1 Feb-87 Draft Environmental Impact Statement/Report, Route 2/Alewife Brook Parkway Project; Federal Highway Administration, Massachusetts Department of Public Works. 1 Jan-87 Biological Treatment Simulation for Land Treatment, Volume I, technical report; Environmental Solutions, Inc.

1 Apr-88 Environmental Data Report, Vols. I, and II; Haley & Aldrich, Inc. 1 May-88 Feasibility Study for the W.R. Grace Co. Property, Cambridge, Massachusetts; Haley & Aldrich, Inc.

1 Dec-87 Report on Oil and Hazardous Material Site Evaluation, Alewife Brook Parkway and Rindge Avenue; Haley & Aldrich, Inc.

1 May-88 Health Risk Assessment for W.R. Grace & Co. Property, Cambridge, Massachusetts; Environmental Health & Toxicology Group, MetaSystems, Inc.

1 Aug-89 Addendum to: Health Risk Assessment for W.R. Grace & Co. Property, Cambridge, Massachusetts; Environmental Health & Toxicology Group, Meta Systems, Inc.

1 Oct-89 Alewife Site, Additional Data for the "MCP-ization of the Health Risk Assessment. 1 Jan-87 Supplemental Soil and Groundwater Data, Draft Environmental Impact Report, Alewife Center, Cambridge, Massachusetts.

1 Nov-87 Final Environmental Impact Report; Monacelli Associates, Inc. in association with HMM Associates, Segal DiSarcina Associates, H&A, Paladin CADD Services, Inc., Hayden/Wegman, Inc. *haso Uts Depasaator tuvronmwrrci o 118529 Bureau of Waste Sit up imam a)I BWSC 01-Tier IA BWSC 02-Tier I BWSC 03- Tier IC Inital Application for Response Action Pennit for iar I Disposal Sites * Required Technical Submittals with Permit Application (con.)

4.- Attach LSP Opinion regarding proposed or continuing response actions which describes all response actions that inthe opinion of the LSP, should continue, or which have Department approval during the DEP's review of this permit appiksion. Use the following format:

* Description of the response action * Current status of the response action " Rationale for continuance of the response action NO CURRENT RESPONSE ACTIONS ARE BEING CONDUCTED 5.Specify the pages of either the Phase IReport or Phase I Report (ifcompleted) for purposes of supporting the following information: Report Ehase Phase 11 Eae(u)

a.Disposal site location Information 0 II-1; see att. * Institutions within 500 feat of the disposal site 03 ssee attached *Llsting of natural resource areas 0 0 see attached

b.Disposal Site Locus Map C Fin T.-1

c. Disposal site history 0 V 1-19) e Rese history & abatement measures C VI 1-15 *OHM use and storage history 0 vI 1-15 e Environmental permits and complance history 0 VI 15-16

d.Disposal site hydrogeological characteristics O "Groundwater depth and flow direction 0 V 1-.5& II 6-7 (3 "SoD and bedrock description II 4-6 0 @Disposal site topography E3 Fig. I-- O3 E3 e.Nature and Sdent of COaninaf|on O30 0 TV1.-5.&. Tables "Thicimess of non-aqueous phase liquid, n/a - 013 If encountered 0 "Appradmate horzonal and verticaldent C TV 1-5 & Tables of contamination 0 013 El f. Migration pathways and exposure potential OC O v.-kA.I1 6-7 * Contaminant migration potential O ci as above & see att. * P tlt human aposure -D O0 a,, ahnva & See att. * Pntia environmental receptors 0C O as above & -see att.

g. Evaluation for Immediate Response Action(s) 0 0

h. other 0 3

L Conclusions 0 o 3 VII M..,, 4AP1"' P"q4 P4 11? BWSC 03: Initial Application for Response Action Permit for Tier I Disposal Sites Section G: Addendum a) Institutions within 500 feet of the disposal site and listing of natural resources are provided in the supplemental Tier Classification document that this formis a part of f) Migration pathways and exposure potential are discussed in the May 1988 Health Risk Assessment conducted by MetaSystems, Inc., the August 1989 Addendum to Health Risk Assessment conducted by MetaSystems, and the October 1989 MCP-ization of the Health Risk Assessment g) An Immediate Response Action Evaluation was not conducted during the initial Phase II studies conducted at the Site because the new regulations were not in effect at that time. Furthermore, the Site was under the oversight of the Department during the Phase II/Risk Assessment phases and complied with Department regulations in effect at the time. Pursuant to 310 CMR 40.0412, Sites Where an Immediate Response Action is Required, the W.R. Grace Site does not meet the criteria set forth at 310 CMR 40.0412. UamSchusetts D8*1Dtof EnvrnmnalProtectIon Bureau of Waste Site Cleanup Transmlul BWSC 01- Tier IA BWSC 02 - Tier lB BWSC 03- Tier IC Inlial Application for Response Actfon Permit for Tier I Disposal Sites

0 Licensed Site ProfessionalOpinion

and am familiar "Iatest that I have personally examined Wesley E. Stimpson with the information contained in this submittal, including any and all documents accompanying this attestation, and Inmy professional judgment, the material facts and data that are the subject of this permit application are true and accurate and comply with the provisions of s3.L c. 21A. if 19-19J. 309 CMR. M.G.L c. 21 E 310 CMR 40.0000, and all other laws, regulations, orders, permits, and approvals applicable to such response action(s). Iam aware that significant penalties may result, including, but not limited to, possible fines and imprisonment IfI willfully submit Information which I know to 10 October 1996 be false, Inaccurate, or Incomplete.'

LSP Seal: nemd nete fEnviranM ntaI PIatCUtan 118529 Bureau of Waste UP TraSMal*I BWSC 0 -Tier IA BWSC 02- Tier lB BWSC 03-Tier IC Intl alAppflcatfon for Response Action Penit for 7er I Disposal Sites * ApplicationCompleteness Checkist

Q The DEP Transmittal Form is properly completed. Ca tiltu itslas OplaeSni.8P yA 12 Certification of submittal has been signed by ALL appiicants and attched. 12 Certification of ability and willingness has been signed by ALL applicants and attached.

05f applicable, the certification of the Primary Representative has been signed.

13 A signed LSP Opinion regarding the information contained Inthis Permit Application (Section H)Is included. M An LSP Opinion regarding proposed or continuing response actions pursuant to 310 CMR 40.0704(1)(b) is Included if applicable. Rpar sad 09erSafhrnfk

M Copies of all Status Reports, Phase Reports, or Completion Statements pursuant to 310 CMR 40.0703(1)0) are included. Q Tier Classification Submittal as been Included pursuant to 310 CMR 40.0704(1)(a). OICompliance history pursuant to310 CMR 40.0703(9)(b) completed by ALL applicants and attached. Maps, Ifates, asaairi '

E Acopy of the tax assessor's map(s) showing each parcel that comprises the disposal site has (have) been attached. 20 Affidavit of publication of the legal notice required by 310 CMR 40.0703(8)(a)1, and a copy of such notice IsIncluded.

M Copy of the cover letter and notices submitted to the Chief Municipal Officer(s) and Board(s) of Health inthe communhyges) in which the disposal ite isocated or Inany other community(ies) which is.or is likely to be affected by the disposal sits requiredby 310 CMR 40.0703(B)(a)2 are included.

Ta abemii te wilafh . paaage: M The Application Checidist has been completed.

Q The wke espy of the Tunsmilias Form alng with the erighilandean opy of the Pennit Application tave been sent to the DEP Permit Administrator' In he applicable DEP Regional office. (Sea e back cor of the PenmntAppUcadea Xlt for fe adasu of DEP gional oifts).

12 The yellrow epy of the TansmIal Form and the Permit Applicadon Fee of 33,550 payable to the Commemueaw h of - Massauhusefs hm been sent to:

Department of Ervironmental Protection P.O. Box 4062 Bosotn, MA 02211

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