October 26, 2000
William W. Beck, Jr., LSP
Senior Vice president
Haley & Aldrich
465 Medford Street
Suite 2200
Boston, MA 02129-1400
Re: Cambridge
62 Whittemore Ave.
RTN 3-0277
RTN 3-17014
Utility Trench Excavation Release Abatement Measure (RAM) Plan
Dear Mr. Beck:
Thank you for forwarding a copy of the above referenced plan to our neighborhood.
We have taken the liberty of hand-delivering a copy of your plan to the USEPA Region 1 Administrator, who was surprised to learn of its existence. Both you and your client were remiss in not informing neighbors and especially abutters of this intention many months ago. In addition, both you and your client were apparently unaware that you had neglected to inform the USEPA of your plans in the midst of their examination at your site. In the future, we would request that you inform neighbors fully and well in advance of the initiation of these sorts of actions as and when they are being contemplated. Acting as if both the USEPA and a large and dense abutting neighborhood has no interest in this sort of undertaking does little to advance you or your client's standing. We would remind you that exposure to asbestos contamination is not a trifling matter, and despite specious arguments to the contrary, asbestos fiber is a known human carcinogen.
As you know, this site is substantially contaminated with various forms of asbestos. These varieties include amosite, chrysotile, crocidolite, actinolite, and tremolite. A conservative estimate of the total quantity of asbestos at the site is between 600,000 and 1.2 million pounds of loose fiber in soil. There is ample justification to hold that PLM analysis is not adequate for measurement of soils bearing such documented contamination.
As a result of the seriousness of the contamination at this site and your client's reluctance to accurately measure its dispersal two decades ago, potentially harmful exposures have already occurred. In addition, much valuable time has been expended subsequently by reluctant neighbors with respect to securing a more credible level of compliance with Massachusetts and Federal regulations.
When the grid pattern was proposed almost two years ago, and presented to the general public as the Final Asbestos Sampling Plan (FASP), it was taken on good faith that the northern end-line of the sampling grid was established a full 200 ft. from the property line because the presence of existing buildings made it necessary. It was assumed that the presence of these buildings precluded any sampling within this corridor.
This contention has been nullified by your latest unverified sampling within this 200-ft. corridor.
Because you have engaged in additional sampling within this unmeasured area, the Final Asbestos Sampling Plan can no longer be considered final. Had your client's intention to disturb soil in this area been made plain originally, (when your plan was presented for public review and comment), there would most certainly have been a demand to include this area within your sampling protocol.
Unwillingness to be candid and forthright about this matter leads neighbors to question intentions. Without an opportunity to verify results in this area through split sample analysis, the neighborhood is left with no other choice but to consider your data set unacceptable.
Given these circumstances, could you explain the following:
"A licensed site professional shall hold paramount public health, safety, welfare, and environment in the performance of professional services."None of these objectives are achieved through the proposal outlined in the document entitled Utility Trench Excavation Release Abatement Measure (RAM) Plan/Asbestos Soil Management Plan. They are certainly not achieved through secrecy and exclusion.
October 26, 2000
William W. Beck, Jr., LSP
Senior Vice president
Haley & Aldrich
465 Medford Street
Suite 2200
Boston, MA 02129-1400
Re: Cambridge
62 Whittemore Ave.
RTN 3-0277
RTN 3-17014
Utility Trench Excavation Release Abatement Measure (RAM) Plan
Dear Mr. Beck:
After further review of the above mentioned report and in consideration of your client's desire to disturb soils in the most contaminated section of the site (Zone I), I would like to add the following comments.
In my comments on the MASP received by you on October 6, 1998 in Appendix A, page 22, I requested the following:
We would like comprehensive sampling for asbestos across the site, and would like Grace to consult with the DEP and community in revising the plan to include sampling in Zone 1 ….. All Zones should have a spacing of 35' on center, as is the case with Zone 4.Your response simply restated the deficiency pointed out to you and it failed to address the request directly.
This area is currently the developed portion of the property controlled by W.R. Grace Construction Products Division and one Alewife Center. It is generally covered by building, pavement and landscaping materials, and there is no risk of exposure to underlying soils. No intrusive activities are planned nor will they occur without the knowledge of Grace or Spaulding & Slye (One Alewife Center management company) personnel thereby limiting possible near-term exposure of the underlying fill materials.On Page 6 you stated that:
Zone 1 - This Zone is covered by either buildings, blacktop or landscaped areas, and Poses no exposure risk to asbestos in soil.On Page 7 or Appendix A you stated that:
Because Zone 1 is covered with buildings, pavement or landscaping, there is no exposure risk to asbestos in soil in that area.On Page 12 of Appendix A you stated that:
Because Zone 1 is covered with either buildings, pavement or landscaping, there is no exposure risk to asbestos in soil in that area.Taken together, these statements affirm a point of view that is now erroneous. Your most current plan intends to do precisely the opposite of what you have insisted upon on pages 4, 6, 7, and 12(Appendix A). In excavating soil in this zone, as you now intend to do, you will by definition be creating an exposure risk. If this information had been forthcoming in your original FASP, the request originally posed and referred to at the beginning of this letter would have been more difficult for you to ignore. In mischaracterizing your report of two years ago as a 'final plan', instead of a 'current plan', you led neighbors and others to believe that your claims and responses were credible.
Grace is currently reviewing available information on Building #28.This of course does not answer the question. And since you have had two years to gather "available information on Building # 28", could you please now answer the question.
Contact the Alewife Study Group, North Cambridge Massachusetts, by email at information@alewife.org