June 22, 1999

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June 22, 1999

Amy Church Re: RTN 3-0277
Haley & Aldrich, Inc.
465 Medford Street
Suite 2200
Boston, MA 02120-1400

Dear Ms. Church:

This letter is in regard to the documents: Report on Evaluation of Extractable and Volatile Petroleum Hydrocarbons in Soil (HC Evaluation Report) and Phase III Remedial Action Plan, Petroleum-Containing Soil Area (HC Remediation Plan), both produced by Haley and Aldrich, Inc., for W. R. Grace & Co.-Conn. in relation to the asbestos contamination on their Cambridge site under RTN 3-0277. These comments are pursuant to the Public Involvement Plan (PIP) established for this site under the Massachusetts Contingency Plan (MCP; 310 CMR 40) established by the Massachusetts Department of Environmental Protection (DEP).

I offer the following specific comments.

Please clarify why no action is being taken at or near sample locations B98-9, B98-10, and B98-65 which all exceeded Upper Control Limits (UCL's) by Method 1 S-3 standards of the MCP.

It is stated:

"It is anticipated that a site-specific evaluation of exposure point concentrations for the property, with the proposed redevelopment use and site restrictions, will indicate a condition of no significant risk to human health and the environment exists."

It, therefore, appears that no site-specific evaluation will be performed based on "anticipated" results. Sample location B98-65 was near the TPH limit in the 1995 testing, and was adjacent to sample location B95-62, which had the highest concentration (40,700 mg/kg, far above the UCL) of all samples in the 1995 test. The other two locations (B98-9 and B98-10) are adjacent to location B98-65.

This area is important because it is near the location of an underground petroleum storage tank. Additionally, the TPH concentrations in close proximity to the tank were much higher than the surrounding areas at similar depths (and at other locations throughout the site) indicating that the high TPH levels were not caused by inherent soil characteristics.

In fact, the TPH levels across the site, based on the 1995 test results, were far below the UCL's except for the localized areas where the concentrations were exceedingly high. Even the samples identified as "PEAT" or "FILL/PEAT" had concentrations one or two orders of magnitude lower than the UCL.

In the 1999 testing, the same sample locations that had TPH concentrations above (even far above) or near the UCL were surprisingly "clean," including areas with visual and olfactory evidence of petroleum hydrocarbon contamination.

A rational explanation for the discrepancy is necessary, based on scientifically defensible reasoning, not just speculation, using comparable test methods.
In particular, the area near samples B95-62 and B95-65 should be retested with split sampling, shared with either or both the City of Cambridge and/or the neighborhood group.

With regard to the HC Remediation Plan, there are two areas of concern regarding asbestos in the soil.

The summary of the 1998 Asbestos in Soil Investigation mentioned that "approximately 16 soil samples... were collected and analyzed for asbestos."

The correct number of samples needs to be determined and the sample identification numbers must be reported.

Furthermore, as presented in previous correspondence regarding the asbestos sampling (May 11, 1999, letter to Patricia Donahue of the DEP), the current level asbestos sampling investigation is insufficient to determine if high concentrations of asbestos are present within the proposed hydrocarbon remediation area between the tested sampling locations, and therefore:

It is inappropriate to assume that areas with high levels of asbestos contamination do not exist in within the proposed hydrocarbon remediation area, unless further characterization of the sitewide asbestos contamination provides the basis for such a conclusion.
The remediation process must conform to the standards that will be determined for disruptive soil activities per RTN-17104 on the site regarding the asbestos contamination.

The currently proposed airborne particulate monitoring and control measures for the hydrocarbon remediation consist only of a list of activities which "may" be performed.

Before the hydrocarbon remediation plan can be approved, it must have an explicit list of measures that will be undertaken for any disruptive soil activities.

I would appreciate your careful consideration of these matters.

Sincerely,

Michael Nakagawa

cc: Commissioner Lauren Liss, DEP
Patricia Donahue, DEP
John Miano, DEP
Cambridge Public Library, Main and North Cambridge Branches (re: W. R. Grace Site)
Denise Guerin, Alewife Neighbors, Inc.