|Alewife Study Group > W. R. Grace site > community feedback > Jan. 22, 2004, on Permit Extension Application||| Search|
Permit Extension Application at W.R. Grace site
January 22, 2004
RTN 3-0277 AND 3-17014
Massachusetts Department of Environmental Protection
Bureau of Waste Site Cleanup
Northeast Regional Office
One Winter Street
Boston, MA 02108
To Whom It May Concern:
It has come to our recent attention that W.R. Grace & Co. has submitted a Permit Extension Application for the above referenced site at 62 Whittemore Avenue, Cambridge, MA. This application proposes to extend the permit for this site to “18 March 2005”.
The rationale for this extension is given as “that additional time may be required to complete and finalize all necessary filings.”
Referenced in this letter is the claim by W.R. Grace that MADEP is currently involved in an “Administrative Completeness Review of the Application”. Although the referenced purpose of this “review” is limited to the application itself, MCP is a structured process with specific milestones and benchmarks that are both interdependent and necessary.
Because of this structure, it is imperative that all previous requirements be met before proceeding to additional permissions and allowances.
The Alewife Study Group and other concerned citizens have consistently pointed out that the site description and history provided by W.R. Grace’s LSP are both materially and literally deficient. Although we are not scientists, we have pointed out in the past that discrepancies have occurred. And we have from time to time provided evidence of such.
Given this history it is once again unfortunate to have to point out that the Phase I requirement of an accurate and forthright description of site history is still as of yet incomplete at best, particularly with respect to asbestos usage.
W.R. Grace has maintained consistently and as recently as November 24, 2003 that site activities involving asbestos were limited to “pilot scale” operations and “small amounts” associated with research and development. On page 35 of the November 24, 2004 Report On Phase II Comprehensive Site Assessment for the Presence of Asbestos, W.R. Grace claims that:
“The demolition of the former buildings, the degradation of the asbestos containing building materials, and releases of fibers from automobile brakes (a friction product) are likely the source of the low levels of asbestos present in the soil”.
The idea that automobile braking residue and SACM’s are likely sources for the unusually high level of asbestos in deeper subsoils is of course inane. But what is more distressing is that apparently W.R. Grace has not fully disclosed the various formulations including fiber additives of major products which are known and have been disclosed. Moreover, there is no evidence that the LSP has bothered to ask about these major products, which even Grace does not deny that it produced at this site in massive quantities over many decades.
On page 4 of the November 24, 2004 Report On Phase II Comprehensive Site Assessment for the Presence of Asbestos it is claimed that:
“The Dewey and Almy facility originally manufactured materials used as can sealing compounds, drum and pail cover gaskets, and bottle cap gaskets.”
In fact a wide range of products were produced at this site including soldering fluxes, thermoplastic coatings, soda lime agents, catalysts, dispersing agents, adhesives and grinding aids for portland cement. Since W.R. Grace did manufacture these products at this facility for worldwide consumption, I would have thought that the LSP might have asked for a complete description of all patented formulations involving these known products.
According to the United State Patent Office, the following patents specifying or suggesting asbestos fiber additives to gasket and similar products were granted to W.R. Grace specifically at this location as opposed to the NY office or the Connecticut or other facility as was the general practice:
This list is by no means comprehensive. It represents only a limited and cursory search. The notion that can and bottle sealants would not contain fiber additive is wholly at variance with established industry practice. Most major gasket producers utilized the same range of filler additives and they most certainly included asbestos.
Given the wide dispersal of loose fiber at significant depth and in the surficial soils as noted by testing conducted by USEPA, this source more fully and credibly explains the presence of asbestos at the site. It is most certainly a part of the larger picture.
At the very least there ought to be some revision of the historical description of site activities with respect to asbestos usage. Such utilization of asbestos fiber with a major product over many decades indicates the need to account for the use of asbestos in other products manufactured at this facility and most importantly how asbestos waste product was disposed. I would assume that some record of such disposal exists and that it can be provided by the Responsible Party (W.R. Grace) through their LSP (Haley & Aldrich).
Our request for a more detailed description of site activities is, therefore, justified and sufficiently limited. We must however express our dismay that once again the neighborhood has had to challenge the Responsible Party even though there is supposedly a Licensed Site Professional retained and presumably engaged. We do not believe that we should be put in the position of enforcers. And we also believe that this sort of deferral does not comport with the spirit or the letter of MCP. It is even less justifiable given the lack of TAG funding.
We would respectfully recommend therefore that any extension of the Phase II or other permits be reserved until all of the foundations of the prior phases are completed with credibility. This would specifically apply to historical accounts of site activities.
Respectfully Submitted on behalf of the Alewife Study Group
Joseph J. Joseph
20 Kassul Park