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Robert F. Jenkins, Ph.D., Vice President
Engineering & Manufacturing Support
GRACE Performance Chemicals
W.R. Grace & Co-Conn.
62 Whittemore Avenue
Cambridge, MA 02140-1692
(617) 498-4476 Tel.
July 27, 2001
Director of Environmental Health
Cambridge Public Health Department
119 Cambridge Street
Cambridge, MA 02139
RE: Grace Utility Trench Work
Dear Mr. Lipson:
On May 7, 2001 Grace submitted its Final Utility Trench Excavation Release Abatement Measure (RAM) Plan/Asbestos Soil Management Plan dated May 3, 2001 (the "Grace Utility Trench Work Plan") to the Cambridge Health Department with an intent to start work on June 7, 2001.
Subsequent to Grace's submission of the Grace Utility Trench Work Plan certain questions arose concerning the abatement measures to be utilized in carrying out the work proposed, As you know the Grace Utility Trench Work Plan has been favorably commented upon by EPA, ATSDR and DEP.
Nonetheless Grace has delayed start of the work pending your receipt of additional information clarifying the proposed work to be performed and the issuance of your final decision pursuant to the Cambridge Asbestos Ordinance, Accordingly, in compliance with your request there follows additional information concerning the proposed Grace Utility Trench Work Plan which supplements the description of the work included in the May 7, 2001 submission.
Underground Utility Maintenance
The Grace Utility Trench Work Plan describes basic utility maintenance work which requires periodic upgrade of electrical and other systems to best practices. This type of maintenance /upgrade activity is the norm and is carried on by many enterprises including the City of Cambridge so as to keep infrastructure current and compliant with best practices. If upgrade to best practices were not included within the concept of maintenance all those entities having responsibility for operation of utilities would be required to keep in place utility systems which over time became older and older relegating them solely to the task of repair of technologically obsolete utilities. Accordingly, the Grace Utility Trench Work Plan falls squarely within the exemptions in Section 8.16.060 (b) of the Cambridge Asbestos Ordinance.
Under Ground Utility Corridor
During your visit to the site last month we indicated that the area between Buildings 29, 23, 22 and 18 (along Whittemore Avenue) and the loading dock, Buildings 3, 1, 2, 8 and 24 (to the south) where the work is to take place was the location of a former rail spur which serviced the site, This fact including supporting commentary is included in the Grace Utility Trench Work Plan,
What was not made clear in the Grace Utility Trench Work Plan is that this former rail spur area is the location of the underground utility corridor used to service the buildings on the site, This 'underground utility corridor has been in existence for many years.
So that you can better understand the area where the work is to be performed we have attached an Underground Utility Site Plan dated June 26, 2001 which identifies all of the utilities which are currently in the underground utility corridor. It also indicates the proposed location of the underground continuation of the electrical service which is the subject of the Grace Utility Trench Work Plan,
Please note that the 13,000 volt electrical service to the Grace site enters the site underground from Harvey Street and connects underground to Alewife 1, and the Cambridge Electric and Lighting substation ("CEL House") and from the CEL House to Building 29, The proposed work (as required by best practice) is the underground continuation of the electrical service which would bring the 13,000 volt electrical feed from its current location underground in the area of the CEL House to two new modern transformers in front of Building 2 which is shown on the Underground Utility Site Plan attached.
Electrical Service to Existing Grace Buildings
Much of the electrical service at the Grace site especially the CEL HOUSE and power distribution therefrom predates 1945 when industrial activities at the Grace site were at their peak, Over the years the Grace site has been slowly modernized from its pre 1945 industrial look to office and research facilities supporting the global business of Grace Performance Chemicals, a unit of W. R. Grace & Co. - Conn. This transformation from industrial use to modern office and research facilities has necessitated modernizing various systems including utilities.
Since the early 1980's Grace as part of its continuing maintenance activities has continually upgraded its utilities. In 1987 came the modernization of building 29, the central research facility for Grace Performance Chemicals and its associated electrical infrastructure which included placing electrical lines underground as well as installation of a 2000 KVA transformer, 2500 amp switch gear, power conditioning equipment, and power factor correcting equipment.
Last year, Grace undertook planning for its second modernization effort. This activity as part of Grace's continuing maintenance program has underscored the need to modernize the power distribution facilities associated with the CEL House to comply with best practices. Representatives of NSTAR have consistently urged that this be done.
In this connection Grace retained the services of BER an engineering design services company to prepare plans and design for the modernization of the CEL House facilities and its associated electrical distribution system.
At present power is supplied from the CEL House through two 1500 KVA 600 volt transformers and switchgear which delivers secondary side 600 voltage (a relic of the industrial past) which is very energy inefficient and requires step down voltage transformers in various sections along its distribution routes. Present day building systems and equipment require 450/277 volt for operations not 600 volt.
BER's plans call for the extension of the 13,000 volt electrical feed routed underground from a new switch in the CEL House area to two new modern transformers (1500 KVA 480/277 and 2000 KVA 480/277) located in front of Building 2. This conforms, to best practices which puts the electrical feed underground and the transformers closest to the point of power use.
Once these actions are completed Grace will be in a position to address removal of the antiquated CEL House.
Above Ground Installation Considered
Because of questions raised by interested neighbors Grace evaluated the appropriateness of running the 13,000 volt line above ground from the CEL House area to the proposed location of the two new transformers in front of Building 2.
This option was ruled out for the following reasons:
Although the Grace Utility Trench Work Plan approvals requested indicate that excavation will be in a trench 5 feet deep, 5 feet wide and extend for a length of 500 feet in point of fact these are the outer perimeters of the proposed soil disturbance and Grace will exert its best efforts to disturb as little soil as possible.
The Grace Utility Trench Work Plan (as can. be seen from its details as further described in this submission) is specifically targeted toward use of Grace's existing business facilities and is not applicable to any future soil disturbing activities at the Grace site since each such activity would have to be separately evaluated under the Cambridge Asbestos Ordinance on its own set of facts,
Grace has put on hold all plans for the development of the site and currently has no plans for development of the site. Grace's current sole interest is in use of its existing buildings for its ongoing world-wide business operations.
As indicated in the information contained in the Grace Utility Trench Work Plan the history of use of the utility corridor confirms its use as a railspur, indicating that no manufacturing operations were conducted thereon,
Asbestos soil sampling conducted in the utility corridor was conducted as approved by the Cambridge Health Department. The results of such sampling indicate that asbestos is not present in the area of the site proposed to be disturbed.
The Grace Utility Trench Work Plan has been favorably commented upon by EPA, ATSDR and DEP and currently reflects the considered judgment of the Cambridge Health Department which has previously reviewed the same.
The Grace Utility Trench Work Plan describes basic utility maintenance work which requires periodic upgrade of electrical and other systems to best practices.
We await your final decision under the Cambridge Asbestos Ordinance.
If there is any additional information or clarification which you require please let me know.
Robert F. Jenkins, Ph.D.
Vice President Engineering
& Manufacturing Support
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