Alewife Study Group > W. R. Grace site > community feedback > Apr. 12 2000, EPA intervention request Search 

Request for EPA to intervene and oversee
asbestos contamination investigation and remediation at W. R. Grace

April 12, 2000
Mindy S. Lubber
Regional Administrator
United States Environmental Protection Agency
Region 1
1 Congress St.
Suite 1100
Boston, MA
02114-2023

Dear Ms. Lubber


On behalf of the Alewife Study Group (ASG) and North Cambridge residents, I request that the United State Environmental Protection Agency (USEPA) Region 1 immediately intervene and directly oversee the asbestos contamination investigation and remediation procedures at the W. R. Grace (Grace) property at 62 Whittemore Ave. and adjacent Russell Field.

The history of this 27-acre site includes decades of heavy industrial activity involving both Grace, and various predecessors in interest. Based upon this history and several publicly disclosed releases, Grace conducted what it claims was an extensive analysis program to delineate environmental contamination at the site. Until 1998 however, there is no public evidence that Grace or its Licensed Site Professional (LSP) bothered to test the soil for asbestos.

On November 20, 1997 information about past asbestos usage at the Grace facility (RTN 3-0277) was sent by the ASG to the Massachusetts Department of Environmental Protection (MADEP). That letter and a follow-up of May 7, 1998 called for W. R. Grace to "provide a full accounting for the omission of asbestos usage in their 1987 data assessment" and to do a follow-up field assessment. In 1998, faced with increasing community pressure, Grace tested its property for asbestos.

The results of the testing were astounding. Amosite, chrysotile and crocilodite fibers were detected in numerous samples at levels ranging from <1 to 20 percent. Based on the combined results of samples and splits, ASG estimates the mass of asbestos fibers in the top 4 feet of soil at this 27 acre site to be in the hundreds of thousands of pounds and perhaps as high as 1.2 million pounds.

Despite neighborhood requests, Grace refused to use transmission electron microscopy (TEM) --the more sensitive asbestos analysis method -- on all but roughly 5% of the soil samples. The decision to rely on the less accurate method, polarized light microscopy (PLM), resulted in what we believe to be an inaccurate representation of the amounts, locations and varieties of asbestos contaminating the site.

Upon learning of extensive contamination issues at Grace's mining and processing facilities in Libby, Montana, and elsewhere, Alewife Neighbors, Incorporated (ANI), a non-profit tax exempt 501c(3) organization, instructed its LSP to send its remaining split samples from the W.R. Grace site to Lab-Cor in Seattle, Washington for TEM analysis.

The Lab-Cor data indicated that one third of these samples contained both tremolite and actinolite. Both of these varieties of asbestos, associated commonly with the vermiculite ores of the Libby, Montana mine, are not indigenous to New England. In addition, during a recent review of soil descriptions from the logs of ANI split samples it was discovered that well over 90% of the split samples taken during the field assessment contain vermiculite.

The high percentage of asbestos "hits" using the TEM method and the detection of new heretofore-unreported varieties of asbestos represents a major shift in sampling results. Under these circumstances, and despite MADEP and Grace claims to the contrary, the environmental analysis of the site cannot be viewed as complete. Therefore, USEPA must intervene and direct Grace to resample and retest the entire site. TEM and an appropriate and experienced laboratory are necessary to determine the magnitude of asbestos contamination accurately and subsequently to assess associated health risks realistically.

In addition to the recent TEM sampling information, ASG has collected anecdotal information from a former plant foreman at the 62 Whittemore Ave. facility that Zonolite, a ceiling insulation product made from Libby vermiculite, was handled at this location. Other facts recently learned from the Region 8 USEPA indicate that raw unexpanded vermiculite from the Libby mine was received by the 62 Whittemore facility. Given Grace's past reluctance to provide a full accounting for all past site activities, it is clear that our understanding of the causes of present conditions is inadequate.

ASG strongly believes that this site needs to be extensively and thoroughly examined by USEPA. In our opinion, MADEP has thus far not provided the aggressive oversight needed for this site and seems unable to do so. In the absence of MADEP oversight and at the urging of ASG, the City Council of Cambridge unanimously enacted a municipal ordinance mandating specific and extraordinary asbestos protections for sites of this nature in the event of planned soil disturbance.

We believe that:

direct review and oversight must occur to assure residents that public health risks now and in the future are not exacerbated.

We therefore request that:

  1. Comprehensive TEM (or SEM) analysis take place on additional soil samples from the entire site to determine the dispersal of both tremolite and actinolite.
  2. TEM analysis is performed on additional samples by a properly certified and suitably experienced laboratory such as Lab-Cor in Seattle, Washington.
  3. A full and credible accounting of all asbestos and vermiculite usage be required of the responsible party. Due to the responsible party's demonstrated unwillingness, this requirement must be enforced.
  4. USEPA review and comment upon both the risk assessment being prepared for the W.R. Grace site itself and the separate risk assessment being prepared for Russell Field (an abutting outdoor recreational facility). It should further provide recommendations for additional sampling at that facility should such sampling be advisable.
  5. USEPA assumes direct oversight of all assessment and remedial activities at the 62 Whittemore Ave. Grace facility.

To date, Grace's attempts to describe its asbestos usage at this site have been entirely unsatisfactory, incomplete, and in our opinion inaccurate. We cannot stress how important it is that USEPA remedy this matter. MADEP has, literally and figuratively, shrugged its shoulders at our various requests for more assistance. Under Massachusetts' privatized remediation programs, the lead MADEP agent stated publicly, that it is up to neighbors to make sure that Grace handles its asbestos properly. Yet, Grace has already disturbed soil at the site without adjusting for potential asbestos-dust releases and plans to construct a huge office park on its property in the immediate future.

Environmental protection should not be the job of neighbors. Nor should it be entirely the responsibility of municipal authorities. MADEP simply cannot, or will not, provide the level of oversight needed to ensure that Grace's future activities at the site will not result in asbestos exposure to people in the abutting residential neighborhood.

Supporting documentation and other useful information about ASG and W. R. Grace can be found at www.alewife.org. Any additional information will be provided as needed. Please let us know if there is anything that we can do, now or in the future, to secure more effective environmental protection at this site.

For the Alewife Study Group,

Joseph J. Joseph
20 Kassul Park
Cambridge, MA 02140
(617) 354-3295
Fax - 864-4749
e-mail JoeWorld2@aol.com

Cc

U.S. Senator Edward Kennedy
U.S. Senator John Kerry
U.S. Congressman Michael Capuano
State Senator Robert Havern
State Senator Steven Tolman
State Representative Alice Wolf
Cambridge City Council
Patricia Donahue, MADEP
John Wardzell, W.R. Grace
William Beck, LSP, Haley & Aldrich



Contact the Alewife Study Group, North Cambridge Massachusetts, by email at information@alewife.org