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CERTIFIED MAIL RETURN RECEIPT REQUESTED
June 5, 2001
United States Environmental Protection Agency
1 Congress St. (RAA)
Dear Mr. Leighton
On behalf of the Alewife Study Group (ASG) and North Cambridge residents, I request that the United States Environmental Protection Agency (USEPA) Region 1 immediately enjoin W.R. Grace from excavating a utility trench at their facility at 62 Whittemore Ave., Cambridge, Mass. scheduled to commence on June 9, 2001.
This proposed excavation would disturb soil in an area that has been proven to contain large quantities of buried asbestos. Such an excavation could result in an asbestos particle release in air, posing a threat to an adjacent tot-lot and playing field and to the dense residential population abutting the area. Only your immediate action will prevent this potential condition.
Grace's excavation plans are in conflict with USEPA's own recent assessment of the contamination. On page 1 of an October 30, 2000 letter to Robert F. Jenkins, Vice President of Manufacturing and Engineering at Grace Construction Products, Mary Ellen Stanton, On- Scene Coordinator for the 62 Whittemore Ave. facility declared that:
"In reviewing the sampling and analysis methods used, I do not consider the "non-detect" results to be valid, because of the way the samples were composited. In performing soil sampling to determine the presence of asbestos, a composite sample taken from depths ranging from 0-5 feet does not provide results that are representative of the various soil contaminants or waste materials. The interval sampled for each boring using standard EPA Removal Program practice would be no greater than one foot (depths of 0-1, 1-2 feet, etc.). This is a special consideration if there may be waste materials present, with a layer of clean soil beneath them, since compositing these materials together will reduce the waste concentration, if waste is present. The large sampling interval used here for compositing the sample (0-5 feet) renders the analytical results meaningless."
Under the circumstances, we would request that you order W.R. Grace to desist in their plan to disturb soil until credible sampling has been done and verified according at least to the existing standards of your agency as explained in Mary Ellen Stanton's correspondence.
In addition, we ask that your public health arm Agency for Toxic Substance and Disease Registry (ATSDR) do a full-blown public health assessment due to the known level of asbestos and other contamination at this site. This assessment should not be done while soil disturbance is underway, but rather prior to its commencement.
During USEPA's site involvement, W.R. Grace's intent to disturb soil has been neither abridged nor abandoned. USEPA has not acknowledged this fact in their analysis. The condition that USEPA itself has declared as necessary for revision of its health statement is and has always been in existence. Moreover, it should be noted that in the report recently issued by W.R. Grace declaring their intent to disturb soil, the detailed (they had an inadequate draft two years ago) site-wide Asbestos Management Plan has come into existence without public or other agency comment as provided for in the MCP.
It is clear that the intent to disturb soil has been in existence during the USEPA investigation. Having been publicly acknowledged to USEPA (according to W.R. Grace), it is difficult to understand why the ATSDR was not notified of this intent as they considered what was submitted to them by the Region 1 Office. In addition to this omission, the aforementioned correspondence regarding sampling inadequacies and other problems was not made available to ATSDR. In its Health Consultation Report of March 20, 2001, ATSDR stated that:
"…. subsurface asbestos contamination does not pose an immediate health hazard as long as the waste remains buried, and is not brought to the surface."
That same report made the clear and unequivocal recommendation on page 4 to:
"Re-evaluate the public health impact of the site if conditions change where exposure to the subsurface soil can occur."
In your press release of March 19, 2001, you claimed that the EPA site investigation was "good news" because detection of asbestos did not exceed a 1% threshold within the first 3 inches of soil. For some reason, the report failed to show concern that 96% of TEM samples showed the presence of asbestos, and that only 20% of the same samples as measured by PLM showed detections in the first three inches of soil. It is more than disheartening that such clear evidence of false negatives was ignored apparently in an effort to exit a site that clearly called for a closer look.
Similar results have been encountered in Region 8 at the Libby, Montana site. An Inspector General's report has pointed out the inadequacy of both PLM and PCM. The difference between the sites is that clear public health evidence due to an abnormally high incidence of asbestosis, pulmonary fibrosis, and mesothelioma has been documented. In the Region 8 Inspector General's report of March 31, 2001 (EPA's Actions Concerning Asbestos-Contaminated Vermiculite In Libby, Montana) they characterized PLM as "limited because it only counts a small fraction of the total fibers," PCM as "limited because it does not distinguish between asbestos fibers and other non-asbestos fibers of similar size" and TEM as "more efficient" but unable to identify "concentrations less than 1% in a bulk sample." (Pages 19-20)
As you may be aware, the situation in Libby has given rise to consideration of changes in how EPA samples are taken and analyzed and possible revision of potency factors with regard to amphiboles, some of which are present in reportable concentrations at the 62 Whittemore Avenue site. Although well intended, your comment of "good news" is at best optimistic.
We would like to express our appreciation to you for your attention to this site and to this particular request. And we hope that you will be an active and visible presence in the safeguarding of this neighborhood. Since W.R. Grace has announced its intent to begin soil disturbance on June 9, 2001, a speedy and meaningful response is essential.
For the Alewife Study Group,
Joseph J. Joseph
20 Kassul Park
Cambridge, MA 02140
Fax - 864-4749
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
William Sweet, ATSDR
John Wardzell, W.R. Grace
William Beck, LSP, Haley & Aldrich
Contact the Alewife Study Group, North Cambridge Massachusetts, by email at firstname.lastname@example.org