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Alewife Neighbors' comments about
Phase II Comprehensive Site Assessment
for the Presence of Asbestos at W.R. Grace site
Alewife Neighbors, Inc.
Cambridge, MA 02140
c/o Michael Nakagawa
(number omitted) Madison Avenue
Cambridge, MA 02140
15 December, 2003 RTN
Tier IC Permit No. 118529
Haley & Aldrich, Inc.
465 Medford St.
Boston, MA 02129-1400
and by Fax: 617.886.7600 and e-mail to email@example.com
on Phase II Comprehensive Site Assessment
for the Presence of Asbestos
W. R. Grace & Co. - Conn.
Dear Ms. McEwen:
On behalf of the residents of North Cambridge, Massachusetts, that it represents, Alewife Neighbors, Inc. (Alewife Neighbors) would like to comment on the public comment draft of the Report on Phase II Comprehensive Site Assessment for the Presence of Asbestos (Phase II Report) dated November 2003, prepared by Haley & Aldrich, Inc. (Haley & Aldrich) for W. R. Grace & Co. (Grace).
In particular, Alewife Neighbors is concerned that the DRAFT Method 3 Risk Characterization for Asbestos at the W.R. Grace Site, Cambridge, Massachusetts, RTN 3-0277 (Draft Risk Assessment) does not accurately represent the risk estimates for neighboring residents under the condition of future excavation of the asbestos contaminated soil, as discussed below.
Furthermore, Alewife Neighbors was surprised to learn that additional soil sampling had taken place in September 2003 without our knowledge. Previous sampling programs as part of the remediation effort for the site had involved the neighborhood to help ensure independent corroboration of the results.
The Phase II Report continues to propose that asbestos in the soil resulted from automotive braking and demolition of buildings that may have contained asbestos building materials. However, there are some areas found to contain particularly high concentrations of asbestos adjacent to areas for which none was detected, calling to question the theory of contamination from adjacent roadways. Furthermore, the September 2003 sampling searched for building materials and found no evidence of such in the samples. Additionally, the report fails to mention that the site is the world headquarters for Grace Construction Products, and that the company is currently under bankruptcy protection because of litigation for asbestos contamination in insulation that the company sold.
Since the additional sampling was not part of the Phase II Scope of Work documentation from 1999, and since the public comment period included the Thanksgiving holidays and significant storms, Alewife Neighbors respectfully asks that you kindly extend the comment period for one week to allow concerned neighbors the opportunity to adequately review and submit comments if desired.
On page 3-10, the report refers to "683 sampling locations" analyzed with Polarized Light Microscopy (PLM) and "71 sampling locations" analyzed with Transmission Electron Microscopy (TEM). In actuality, the Phase II Report indicates samples were taken from 389 sampling locations, although multiple samples were often taken from individual locations. The distinction is important, because the method of sampling affects the ability to detect asbestos, and the presence of asbestos at a particular location scheduled for excavation is more important that the lack of asbestos at a location not planned for excavation.
Unfortunately, a large percentage of the samples were taken with a large depth then composited. The Environmental Protection Agency (EPA), in a letter dated October 30, 2000 from Mary Ellen Stanton, On-Scene Coordinator, to Robert F. Jenkins indicated that the results of such a large depths renders the analysis "meaningless" as quoted below:
In a letter dated October 30, 2000 from Mary Ellen Stanton, On-Scene Coordinator, to Robert F. Jenkins indicated that the results of such a large depth renders the analysis "meaningless" as quoted below:
"Subsurface Characterization of the Utility Trench Area" - pages 9 and 10
"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."
Haley & Aldrich completely ignored the EPA in setting up the September 2003 sampling (using composites of 0.5 to 5.0 feet), rendering data from that study equally meaningless, as are the majority of samples from the previous sampling studies.
However, the Draft Risk Assessment uses the "meaningless" data samples in calculating the average concentration of asbestos when determining the risk to residents and workers.
Additionally, in Section 3.3.2 Groundwater, the report states:
"Purging and sampling a well can easily mobilize colloid particles that would not normally be moving with the groundwater... These colloids could include asbestos fibers sheared off the soil due to the agitation of the water during the well purging. This could account for the presence of asbestos fibers in the groundwater."
But troubling is that washing can apparently liberate asbestos-containing colloidal material. The majority of the soil sampling followed EPA Region 1 protocol, which the Risk Analysis states on page 3-4 under the description: "Other methods and protocols have been proposed and/or adopted in various contexts, but they have not been validated, or their validation status is unclear:"
The Risk Analysis then describes the protocol:
"Region 1 protocol (EPA, 1997).
"... A portion of the sample is thoroughly rinsed to remove colloidal material, fine sand, silt, and other non-fibrous particulates."
Furthermore, page 3-11 of the Risk Analysis says,
"As discussed in the Phase II CSA report (Haley & Aldrich, 2003), the detection of fibers in the groundwater samples is likely attributable to suspended colloid particles in the water sample."
It therefore appears that the Region 1 protocol could be washing away much of the asbestos before microscopic analysis.
Haley & Aldrich criticized the data from the Alewife Study Group testing indicating a suspicion that point counting was used instead of the Region 1 protocol. The Risk Analysis indicates that "point counting" is one of "only two validated measurement protocols for asbestos in solid materials" and does not wash away colloidal material. Although the analysis laboratory indicated that the agreed upon protocol was used, if point counting had in fact been done, it might be more representative of the levels of site asbestos.
Combining the findings that large sample-compositing of soil serves to reduce concentrations of asbestos with the potential washing away of asbestos-containing colloidal material, the risk analysis is based on data that would greatly underestimate the concentration of asbestos in the soil.
Section 6.2.1 of the Draft Risk Assessment states:
"As shown in Tables VIII and IX, PCM analysis of samples indicated total fiber concentrations in air in the range of less than 0.002 and 0.30 PCM f/cc.
"However, the detected PCM total fiber concentrations are consistent with ATSDR Toxicological Profile for Asbestos (update), dated September 2001, indicative of background levels of asbestos in air of 3.0x10-6 PCM f/cc to 3.0x10-3 PCM f/cc."
The levels found on-site are up to 100,000 times higher than the urban background levels referenced in the ATSDR report.
The groundwater sampling protocol flushed the wells 25 times before collecting groundwater for testing. Since asbestos does not dissolve in water and tends to bind to soil, there is very little chance of any free asbestos being found in water taken immediately after 25 full-volume purges of the wells.
Since there may be release of asbestos through colloidal particles it is unclear if the purging freed more asbestos than it cleared.
Alewife Neighbors agrees that the current state of the site poses No Significant Risk to residents and workers. However, Alewife Neighbors feels that the methodology of data collection and analysis may not accurately represent the true risk to residents and workers under a likely situation in which subsurface soils will be excavated.
In light of the findings that the methodology used for the quantification of asbestos contamination may in fact remove asbestos before the analysis, further testing should be conducted with a validated method to ascertain if the methodology under-represents the concentrations of asbestos at the site.
Finally, since there is a large uncertainty in the cause of the asbestos, and therefore the potential locations of high concentrations in the soil, the Phase II Report should indicate that until further testing is done, the whole site should be considered contaminated.
Alewife Neighbors, Inc.