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July 2, 1999
Concerned residents:
The Cambridge Public Health Department is submitting for general information a draft of the
comments we have received from our environmental engineering consultants regarding the W.R.
Grace Report on Evaluation for Asbestos in Soil (April 22, 1999). With the rapid turn-around
time forced upon (comments are due on July 7) us we are going to simply attach these consultant
comments and summarize additional comments to be included in our submittal to Grace next
week.
- As indicated in the attached comments, distinctions between contamination levels in various
parts of the site do not appear to be warranted. It is our view that all three mitigation
measures indicated in Appendix D of the report should be employed throughout the site.
Furthermore, additional measures such as the use of temporary structures or shrouding should
be engaged for the added assurance that they would provide to nearby residents. The cost of
such equipment would not be prohibitive in the context of a large commercial development
and may help to address fears that have arisen from the discovery ofpercentage-level
quantities of asbestos on this site..
- Grace has decided that Zone 5 (near the former Lehigh Metals plant) needs no further
characterization for asbestos. This decision was based upon their own data indicating that no
asbestos was present. Split sampling collected by members of Alewife Neighbors, Inc. and
analyzed according to standard EPA protocol indicated that there was some asbestos present
in that zone. We believe that Grace should further characterize that area for asbestos
contamination.
- The exemption of work on uncovered areas of 100 square feet or less is not justified in this
report. That exception can cover large volumes of soil over narrow strips of land and will
exempt many of the construction activities on the site over the course of development. This
does not generate great confidence that limiting exposures to largely uncharacterized soil is
the highest priority. It needs to be given this priority.
- A contingency plan with the City of Cambridge in the event of a measured release of asbestos
needs to worked out in advance. No reference to this type of planning was included in this
report. In general, the steps necessary to suspend of work on the site should be clarified.
The City of Cambridge will finalize its comments by July 7, 1999. These points should be used
as an outline of our eventual submittal to Haley and Aldrich (Grace's consultant for
environmental engineering and cleanup). Please be sure to fax or deliver your comments to us
by noon on Tuesday, July 6. Our fax number is 665-3888.
