Wesley Stimpson
C/O Haley & Aldrich, Inc.
465 Medford Street Suite 2200
Boston, MA. 02129

Dear Mr. Stimpson:

These are my comments relative to the PIP process outlined in the Massachusetts Contingency Plan (MCP) regarding the WR Grace site Phase II Comprehensive Site Assessment of April, 1999:

I believe that WR Grace has not fulfilled the requirements of the Phase II Comprehensive Site Assessment. They have not accurately assessed either the amounts or locations of asbestos contamination on their property nor can they explain its presence and distribution in the soil. There is also no reason to believe that future tests proposed by WR Grace will improve the situation.

It is clear from the test results listed in the April documents that there is no clear pattern to the distribution of asbestos on the Grace property. The only conclusions that can be drawn from such results are as follows: a. the total amount of asbestos on this site is significant and probably in the hundreds of thousands of pounds if not millions of pounds; b. asbestos can be found in significant quantities in most portions of the site; c. soils at any given location on the site have a significant chance of containing asbestos. This information is insufficient to base either a risk assessment or a monitoring and management plan on and therefore must fail the minimal requirements of a comprehensive site assessment.

Grace has presented no information that would satisfactorily explain the amount and distribution of asbestos on their property. To the contrary, Grace has presented evidence that would make the present test results unlikely or impossible. The April document includes this statement: "Grace records indicate that neither Grace nor Dewey and Almy used asbestos material for any large-scale industrial purposes at the Cambridge facility." In previous documents Grace has identified areas of historic industrial operations on their property. These areas do not sufficiently correspond to the dispersal of asbestos indicated by the current test results.

In summary, Grace according to their documents cannot explain the amount of asbestos currently known to exist on their property nor can they explain its wide distribution on their property.

This gap in site characterization is significant. First there may be 'hot-spots' of asbestos that could be revealed by a more accurate historical investigation. For example an exhaustive check of company records and surveys of past workers at the site may reveal areas where asbestos is known to have been dumped. Second, there may be more asbestos on the site than even present tests would predict. This might trigger a different level of site-characterization and oversight. Third, accurate information on asbestos may inadvertently shed light on other public health issues at this site. For example knowledge of areas where asbestos may have been dumped may provide new knowledge as to where other chemicals have been dumped including petroleum products. Fourth an accurate historical record and knowledge of the amount and locations of asbestos on the site is essential to assessing both an Imminent Hazard Evaluation (IHE) as well as a future health hazard and it is absolutely essential to an accurate airborne asbestos management and monitoring plan. Fifth, the present gaps in understanding send unintended fears through the community and threaten the public trust on which the MCP is based.

The IHE performed in the April document states that "the areas of surficial soil containing asbestos (including the one sample located in the drainage swale outside the fencing) are generally covered with grass, sparse vegetation or surrounded by berms such that wind erosion in these areas is less likely to occur. Based on the above, an Imminent Hazard to human health as defined in thee MCP, is deemed not to exist under current site conditions". However, it has been demonstrated above that the locations of asbestos contamination on this site are not known. The conclusions of the IHE are therefore not warranted. There may be soil locations containing hot spots of asbestos that are not protected from the wind. In addition none of these airborne monitoring tests were performed during the summer months when dust is most likely to become airborne.

The airborne asbestos monitoring and management is similarly flawed. Areas of lesser and greater contamination have been identified without a full understanding of the asbestos distribution on the site. As noted above there may be significant hot spots of asbestos containing tens or hundreds of pounds of asbestos. A single disturbance of such an area by a major piece of equipment could release enough asbestos as to pose an immediate health threat to children playing on fields as close as fifteen or twenty feet away.

At the community meeting of June. A DEP representative was questioned directly concerning the lack of accurate historical information and the lack of a clear understanding as to the amounts and dispersal of asbestos on the site. The representative noted that the gaps in historical understanding could be overcome by assuming the entire site to contain asbestos. This conclusion is not warranted. As noted above the Imminent Hazard Evaluation and the monitoring plans would be significantly altered were there known to be hot spots of great concentration on the site. Also there may be threats to the community that have not yet been determined due to the lack of historical information. For example, it is a well known epidemiological phenomenon that houses inhabited by workers at asbestos facilities frequently are contaminated with asbestos brought back into the house. Mesothelioma and other toxic health effects have been documented in other family members coming in contact with these 'second hand' asbestos fibers. An accurate historical record may serve to identify such houses in the neighborhood or conversely to allay fears that such houses exist.

To fill in the gaps of information noted above the following information is essential:

(1) Interviews with past employees to determine the exact nature of asbestos operations on the site and the locations of asbestos dumped on the property.

(2) Full public disclosure of all documents pertinent to asbestos operations at the Cambridge facility including: a. amounts and types of asbestos brought into the facility including all trucking manifests and other relevant documentation; b. amounts and types of asbestos products produced at the facility;

(3) Full public disclosure of all documents pertinent to the relationship between the Cambridge facility and the Walpole Multibestos site (both facilities owned by Dewey & Almy) including any information about asbestos trucked between the two sites.

Lewis Weitzman

Cambridge, MA. 02140