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Dear Mr. Favorito:

     The Massachusetts Department of Environmental Protection (the Department or DEP), is
in receipt of a "Report On Evaluation For Asbestos In Soil" and a "Report On Underground
Storage Tank Removal," prepared by Haley & Aldrich for W.R Grace & Co-Conn. (W. R. Grace),
62 Whittemore Avenue, Cambridge, Massachusetts and both dated April 1999. The "Report On
Evaluation For Asbestos In Soil" presents the results of a property wide assessment of the levels
of asbestos in soil at the W.R. Grace site DEP Release Tracking numbers 3-277 & 3-17014).
The "Report On Underground Storage Tank Removal" presents information concerning the
evaluation of the location of a large UST for asbestos levels prior to the removal of the UST. The
purpose of this letter is to provide comments on the Airborne Asbestos Management & Monitoring
Plan, included as Appendix D of the report, and to comment on soil management activities across
the property.

     W.R. Grace proposes to construct office space and a hotel on the site. The conceptual
airborne asbestos monitoring plan was proposed by Haley & Aldrich for the W.R Grace site to
control potential exposures to airborne asbestos in the event of future disturbance to soil at the site
resulting from large scale, intrusive maintenance or proposed development activities. The plan
includes the following elements:

• Daily monitoring of airborne particulates (real-time data collection) and airborne asbestos
  fibers;
  

• A stated goal to prevent exposure to airborne asbestos for on-site workers, nearby public and
  off-site residents;
  
• Air sampling to be conducted (a) at the excavation perimeter by a construction monitoring
  technician, (b) "around the perimeter of the excavation, and (c) depending on the size of the
  excavation, at locations along the perimeter of the site" by "up to two" meteorological
  monitoring stations and "up to three" air monitoring stations;
  
• Three levels of dust control will be used depending on the levels of contaminants previously
  measured in soil and on the results of the air monitoring. If monitoring indicates that dust
  control techniques beyond wetting with water are necessary, wind fences and soil additives
  (surfactants intended to enhance the wetting process) will also be used;
  
• At all excavations, regardless of the level of asbestos measured in soil, water sprays will be
  used to control dust generation in and around the excavation and on soil during loading and
  unloading. At excavation locations where levels of asbestos from trace to 3% were measured,
  both water sprays and wind screens will be used. At excavation locations where levels of
  asbestos 4% or greater were measured water sprays, wind screens and water additives will be
  used; and,
  
• Other dust mitigation techniques will be considered and used if necessary, including: paving or
  treating access roads with bitumen and sand, maintaining vegetation cover and spraying
  exposed soil with slurry or other stabilizing agent. Inactive soil stockpiles will be sprayed with
  a soil stabilizer and covered with anchored plastic tarps.
  

     The Department provides the following comments relative to the implementation of
statutory and regulatory requirements applicable to the W.R. Grace site.

1. The OSHA Permissible Exposure Limit (PEL) of 0.1 asbestos fibers per cubic centimeter of
   air was proposed by W.R. Grace for protection of site workers in the excavation areas. This
   may be an applicable action level for site workers but the PEL is not an applicable action
   level for children and residents in the area. The MCP Imminent Hazard level is an applicable
   regulatory action level for short term exposure (1 to 5 years) at recreational and residential
   boundaries. Pursuant to the MCP at 310 CMR 40.0411(l)(a), if a level of asbestos is present
   in ambient air such that a condition posing an Imminent Hazard exists, an Immediate
   Response Action (IRA) must be taken to abate, prevent or eliminate the Imminent Hazard.
   The levels of asbestos in air that represent an Imminent Hazard condition for exposure time
   periods of 1 to 5 five years are likely to be significantly lower than the PEL. The levels of
   asbestos in air and the levels of dust containing asbestos in air that represent an Imminent
   Hazard must be determined for the site and action levels developed accordingly. The action
   levels for dust and asbestos in air can be used to determine: when additional dust
   management is necessary; when dust management techniques are not adequate; and, when
   work must stop while alternative dust control and soil disturbance activities are evaluated.
2. The objective of the conceptual airborne asbestos management and monitoring plan for the
   W.R. Grace site, as stated by Haley & Aldrich, is to control potential exposures to airborne
   asbestos in the event of future disturbance to soil at the site resulting from large scale, intrusive
   maintenance or proposed development activities. The plan objective should be modified to
   include dust control for any activities that will disturb soil and potentially cause a condition of
   dust and/or airborne asbestos at the site. The plan should not be limited to "large scale"
   activities. The plan includes an exclusion for excavations less than 100 square feet in area. The
   Department believes that this exclusion is not appropriate because, even small excavations have
   the potential to cause a dust condition. The nature of the exposure from such an excavation
   depends on its location, meteorological conditions and the relative locations of sensitive
   receptors including children, residential properties and recreational areas. Due to the possible
   random distribution of asbestos at the site and the uncertainties regarding exposures to asbestos
   and health effects, dust management activities must be implemented whenever activities
   causing soil disturbance occur at the site.
3. The asbestos management and monitoring plan must be implemented across the property at any
   location where there is a potential for asbestos to be present, whether or not those locations or
   soil activities are associated with a DEP release tracking number. Asbestos data from samples
   collected by W.R. Grace, the City of Cambridge and the Alewife Study Group must all be used
   in the determination of the presence of asbestos at the site and taking appropriate precautions.
4. The asbestos management and monitoring plan states that, monitoring will be conducted at the
   perimeter of the excavation and/or the perimeter of the site. The monitoring during site
   development should include a sampling location downwind of the excavation at the site
   boundary closest to the residential properties and the recreation areas.
5. The plan states, if monitoring indicates that dust control techniques, beyond wetting, are
   necessary, then wind fences and soil wetting additives (surfactants intended to enhance the
   wetting process) will be used. The "Actions to be Taken Based on Monitoring Data" section of
   the plan must state that the work will stop and dust management and soil disturbance
   alternatives will be reevaluated before beginning work again if the monitoring indicates that
   dust concentrations continue to exceed the management criteria after all management options
   have been implemented.
6. The plan states, prior to the beginning of excavation activities, further characterization for
   asbestos content will be completed in areas where trace or percent levels of asbestos have
   been detected. This additional characterization should be completed before site development
   and the data used to determine the appropriate level of dust management and personal
   protective equipment during excavation activities.
   
7. The criteria upon which the number of air sampling stations will be based must be stated more
   definitively. The plan states that, air sampling will be conducted "around the perimeter of the
   excavation, and depending on the size of the excavation, at locations along the perimeter of the
   site" by "up to two" meteorological monitoring stations and "up to three" air monitoring
   stations. The plan also states that, meteorological information will be used to establish the
   positioning of monitoring and sampling equipment and stations but it does not state how the
   meteorological information will be used. The plan should state the criteria to determine the
   number and locations of air monitoring stations and meteorological stations and the locations of
   any fixed stations if applicable.
8. The plan states, for vehicles in contact with asbestos containing soil, temporary wheel wash
   stations will be used to prevent mud and dirt on vehicles from leaving the site. The plan must
   discuss the management of water used at the vehicle wheel wash stations.
9. The "Monitoring Methods and Analytical Testing" section of the plan does not state the
   analytical method to be used to determine the levels of asbestos in air. The method reference
   must be included in the plan.
10. The "Report On Underground Storage Tank Removal," prepared for W.R. Grace by Haley &
    Aldrich and dated April 1999, contains asbestos data for soil samples collected in the vicinity of
    the UST excavation. The asbestos data is not included or summarized in the UST report. In
    order to evaluate the asbestos data the reviewer must find the data in Table 1 of the "Report On
    Evaluation For Asbestos In Soil" prepared for W.R. Grace by Haley & Aldrich and dated April
    1999. This is not an appropriate reporting format. When feasible, reports should contain the
    information which is critical to that submittal in summary tables. If this is not feasible, the data
    must, at a minimum, be referenced.
11. There is an inaccuracy in the data reporting for the asbestos sampling at the UST excavation.
    "The Report on Underground Storage Tank Removal," states that, soil samples were
    collected for analysis to pre-characterize the soil in the area of the tank for asbestos content in
    order to determine the level of protection for site workers. A total of24 samples were
    analyzed and "asbestos was detected at a trace level in one sample," the analytical results for
    the remaining 23 soil samples indicated that: No Visible Asbestos was present. However, the
    sample from the UST location which contained asbestos (AB2-355-S1) is reported on Table
    1, page 16, of the "Report On Evaluation For Asbestos In Soil" as containing 1 percent
    asbestos. On this matter, the Department communicated with Haley & Aldrich, Ms. Amy
    Church, and Ms. Church indicated that the sample does in fact contain 1 percent asbestos and
    that this error was an oversight caused by earlier confusion regarding reporting and detection
    limits and a failure to correct this in the final UST report production. Please be advised that,
    accuracy in reporting is a regulatory requirement. Pursuant to 310 CMR 40.0022(2),
    Accurate and Timely Submittal of Documents, no person shall make, or cause any person to
    make, any false, inaccurate, incomplete or misleading statement in any document which that
    person submits, or causes any person to submit, to the Department pursuant to M.G.L. c.
    21E, 310 CMR 40.0000 or any order or determination issued by the Department. Additional
    care must be taken to ensure that reports contain accurate information.
12. The MCP, 310 CMR 40.0018(l)(a), Health and Safety Procedures, requires that any person
    undertaking response actions shall implement health and safety procedures designed to
    protect health, safety, public welfare and the environment during the performance of response
    actions. Such procedures shall include, without limitation, measures to protect sensitive
    human populations from exposure to oil and/or hazardous material. Note that this section of
    the regulations is not discussed with respect to allowable risk levels and simply states that the
    populations must be protected from exposure. When an exposure is occurs, measures must
    be taken to eliminate the exposure. One criteria that can be used to measure airborne
    contaminants from the site is the comparison of upwind and downwind Total Suspended
    Particulate concentrations.
13. The Massachusetts Air Pollution Regulations at 310 CMR 7.00 state that visible dust is a
    condition of air pollution and as such must be prevented.
14. The Primary National Ambient Air Quality Standards, 310 CMR 6.04(2)(a), require that 150
    ug/m³ of Total Suspended Particulates (maximum 24 hour average, measured as PM1O) not
    be exceeded in air.

     If you have any questions or concerns regarding this matter, please do not hesitate to call
Jack Miano, at the Bureau of Waste Site Cleanup in the Northeast Region, at (978) 661-7734.

DEP/Wilmington, Data Entry
Board of Health, 1493 Cambridge Street, Cambridge, MA 02139
     Attention: Sam Lipson
City of Cambridge, 795 Massachusetts Ave., Cambridge, MA 02139
     Attention: Mayors Office
City of Cambridge, Community Development Department, City Hall Annex, 57 Inman
     St., Cambridge, MA 02139, Attention: John Bolduc
Haley & Aldrich, Inc., 465 Medford St., Suite 2200, Boston, MA 02129-1400
     Attention: Wes Stimpson
Alewife Neighbors, Inc., 94 Clifton Street, Cambridge, MA 02140,
     Attention: Hannah Goodwin, President
Cambridge Main Library, 449 Broadway, Cambridge, MA 02139, Attention Reference
     Librarian, W.R Grace Site
North Cambridge Library, 60 Rindge Ave., Cambridge, MA 02140, Attention Reference
     Librarian, W.R. Grace Site
Representative Alice Wolf, State House, Room 473G, Boston, MA 02133-1054