Grace Site Advisory Committee Final Report (October, 1996)

Note:

This Committee finished its Final Report nearly two years before asbestos was a known and proven contaminant on the W. R. Grace site.

Sections of report:

Site characterization / Environmental recommendations

The W. R. Grace Co. should perform remediation of high concentration contaminant areas before any construction begins.
The Environmental Health and Engineering s report Public Health Evaluation for W. R. Grace Site – Final Draft recommendations #1 and #2 (p.11) are agreeable to the GSAC. In addition, proper rehabilitation and maintenance of existing wells should be continued and these wells should occur at varying depths. Records will be reviewed and should include Russell Field.
A complete comprehensive map designating all known “hot spots” overlaying groundwater, surface water, sediment & soil testing areas should be provided. The ‘testing areas’ well designations should be comprehensive and should not omit the ‘Test Pit Report’ data included in Volume One of the Environmental Data Report of 1988. Test Pit numbers contained in this report should be fully and legibly designated and should include the three digit codes, from the test pit/boring reports. A map of remediation areas overlaid with the map of soil contamination levels should also be included.
The MBTA and the City should perform tests to verify soil and groundwater conditions at Russell Field and secure implementation of any needed improvements.
It must be demonstrated that contaminants will not travel off site through utility and storm drain connections.
All areas where new groundwater and soil sampling occur should include pH testing (acidity & alkalinity). Averaging of pH results from different areas on the site is problematic and should be avoided.
The City should seek to ensure that independent environmental (new soil, sediment, surface & groundwater sampling data) and traffic studies (including air quality) are conducted before permitting of any building construction.
The City should seek to ensure that independent study and sampling for Lehigh Metals Site, Babo’s Site (corner of Rindge Ave. Alewife Brook Parkway) is performed. Also to be included in this is recommendation is the Harvey St. Extension area.
Conduct independent sediment and surface water sampling tests for Parkway Pond, Jerry’s Pond, Yates Pond, and Alewife Brook. Very little data exists for these bodies of water, and virtually no sediment sampling has been conducted. According to Dr. Spengler’s April 1996 report, surface samples which have been collected where done so in the spring although the optimum time to perform these tests may be in the summer or fall. This issue was also referenced in the Spengler Report of February 1987.
Subsurface soil samples should be taken at varying depths by an independent agent or agents.

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Groundwater and hydrology

Groundwater contaminant issues and groundwater flow uncertainties have been well documented. These issues have been referenced in both Spengler Reports of April 1996 & February 1987, the NUS Corporation Superfund Division memo dated July 8, 1985 regarding a preliminary assessment of the W. R. Grace Site for the United States Environmental Protection Agency (EPA) (See Attachment 4), the Final Environmental Impact Report (FEIR) dated November 1987, North Cambridge Stabilization Committee (NCSC) communications to the Massachusetts Executive Office of Environmental Affairs dated February 22, 1987 & January 12, 1988, and etc.. Groundwater contaminant issues and groundwater flow uncertainties should be thoroughly defined by an independent agent or agents before any construction begins.
An independent hydrological study of the site should be undertaken in order to evaluate the impact that any proposed development at the site would have on the floodplain and the watershed system.
With community consultation and independent oversight, the W. R. Grace Co. should provide an improved groundwater model to include recharge rates and the effects of the MBTA tunnel on groundwater movements.
Consider a bypass of water flow from Parkway Pond to any other body of water, or consider a bypass of Parkway Pond, and/or install a decontamination/water quality enhancement system for this body of water.
Research the feasibility of constructing natural berms along site boundaries (especially the Clifton St. and Russell Field edges). This will help prevent surface water runoff to the Field and/or neighborhood basements. A natural berm did exist at one time between the Clifton St. edge and old Russell Field.
The W. R. Grace Co. and any subsequent owner of any part of the site (including the parcels currently to be retained for use by the W. R. Grace Co.) should continue and expand groundwater monitoring. In addition, they should provide indefinite downgradient groundwater monitoring along the site boundaries and install barrier remediation systems when construction takes place so that it can be deployed rapidly if contaminants are observed at the boundary monitoring wells.
Groundwater monitoring and a groundwater model should be provided by an independent agent and by the W. R. Grace Co.
All catch basins to be provided with sediment and oil and grease traps and should be accompanied by an aggressive maintenance schedule.
The City should work with Belmont, Arlington and the Army Corps of Engineers to ensure the ACE swiftly completes a comprehensive hydrologic/hydraulic study. The community believes that no development should take place until the ACE completes the hydrologic study of the Alewife area.
Per the recommendation by the April 1996 report by Environmental & Health and Engineering, more information on groundwater flow patterns in the Russell Field area is needed. Such information should be gathered and assessed independently. The neighborhood should be involved significantly in the design and implementation of this study. The selection of any independent consultant with respect to this concern should be determined in full consultation with the affected neighborhood and should be commenced only with their explicit approval. The related issue of basement testing for both the Clifton/Harvey St. neighborhood and the Whittemore/Seagrave Rd. neighborhood should be similarly addressed.

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Remediation and construction on-site

Use best practices to protect workers, passers-by, and neighbors from airborne particles.
Provide air quality monitoring within the site and on its borders and in the affected neighborhoods during construction with regular reports to the City.
Keep construction vehicles off neighborhood streets.
Site excavation should be timed to minimize risk to public health.
A 10,000 gallon toluene tank is apparently still underground in the northeast section of the site. The extent of its contents should be verified and the surrounding soil should be independently tested and remediated as necessary. All underground storage tanks should be removed from the site unless it can be proven that greater health risks would occur as a result of their removal.
No construction before 8 a.m. and after 5 p.m.
If construction is to occur it is the preference of the neighborhood abutting the site that the site be first capped with clean fill. The Committee would also recommend that buildings be constructed on concrete slab at grade level. The Committee would further recommend that the Cambridge Planning Board be immediately notified of this preference.
Any necessary and/or desirable soil remediation should coincide with site development . If excavation should occur the neighborhood would recommend that the developer first submit an acceptable plan to the neighborhood regarding any and all remediation procedures for approval.

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Public notification of site status

Air quality monitoring during construction should be independently conducted, and regular reports should be prepared for the surrounding neighborhoods as well as the City.
Developer should test and propose to the surrounding neighborhoods and the City a full range of options for addressing hazardous waste issues on the site (cost, etc.) before any construction begins.
In keeping with state regulations neighborhood residents must be notified of any field work before any activity is scheduled to begin.

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Public health and safety

The City should ensure that the Massachusetts Department of Public Health, other appropriate agencies or the City itself conduct an epidemiological study of the Rindge Ave., Clifton St., and Whittemore Ave. neighborhoods with the involvement of the City s public health officers. The study should include but not be limited to cancer and reproductive health risks. (Note: There continue to be persistent anecdotal stories of high cancer rates in these neighborhoods, especially, the Clifton St. neighborhood.)
Rigorous health and safety and contingency planning must be completed prior to the initiation of remediation and/or construction in compliance with state regulations.{SubComFinal,#34}
The risk assessment for the W. R. Grace Site was to some extent developed by averaging site contaminants (hot spots, low level contaminant areas, & “clean” areas). This method is at best problematic, for it doesn’t accurately highlight the dangers of the hot spots. It can not, and should not be relied upon as the basis for conclusions regarding the scope and danger of hazardous waste contamination on the site. Any independent environmental study should avoid using this methodology as the basis for its conclusions.
The bulk of the soil sampling data reviewed for the April 1996 Spengler Report was the same data reviewed for the February 1987 Spengler Report. Chemical analyses for the bulk of these soil samples was performed on composite samples. The Spengler Report of 1987 was highly critical as to the usefulness of chemical analyses on composite samples. This methodology should be avoided in any independent environmental samples. (Note: The Spengler April 1996 Report notes that “the soil samples’ data set contains the results of soil analyses collected mainly in 1986 and 1987 with a few samples from 1984 and 1985.”)

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City official approval

The City should seek to ensure that any development at the W. R. Grace Site (Lehigh Metals, Babo’s) should receive prior written approval from the City’s Commissioner of Public Health (or Acting Commissioner).
The City should seek to ensure that any development at this site should receive prior written approval from the director of the City’s environmental program and the Assistant City Manager for Community Development.
The City should condition approval of any major amendment to the developer’s special permit on Conservation Commission review of the development plan for its effects on the floodplain, as well as wetlands and wildlife. No special permit amendment approval should be effective until the CCC evaluates the plan’s effects on the floodplain, refers any outstanding questions to FEMA and relevant state agencies, issues its recommendations for any improvements that would make the plan acceptable, and the developer redrafts the plan to conform to these recommendations.

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Construction management

Clean and neutralize contaminated soils as necessary. Prevent contaminants from moving off-site, and/or decontaminate contaminants which are moving off-site.
Identify and remediate site contaminant hot spots making use of bioremediation or excavation and removal as needed.
Advocate for a Tier 1 site classification. The W. R. Grace Site is currently classified as a Tier 2 site. As a Tier 2 site, hazardous waste concerns are overseen by a Licensed Site Professional hired by the owners or developers of the site. A Tier 1 site classification would effectuate the direct involvement of the Department of Environmental Protection (DEP). The W. R. Grace Site was initially scored by the LSP, and missed being classified as a Tier 1 site by less than 20 points. In Section 8 of Dr. Spengler’s April 1996 Report, conditions that could raise the site’s scoring enough to require Tier I site classification were discussed. (Note: The W. R. Grace Site’s Tier classification is currently being audited by the DEP.)
Site drainage measures to be installed before construction of structures. All drainage and wetlands protection measures to be in place throughout all phases of construction.
Measures to prevent erosion and sedimentation to be in place before any earthworks (including remediation work).
Flood plain issues should be viewed as to their impact upon site contamination and vice versa. This issue is referenced in the Spengler Report of February 1987 (p.5). “Impacts of construction, excavation, movement of contaminated soils on site, and other aspects of the development project on flooding of the site and the potential for flood water mobilization of contaminants should be addressed.”

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Wetland / Wildlife issues

Developer to provide new wetlands delineation and wildlife habitat survey.
The site should be a limited salt, no pesticide, no herbicide zone.
No fertilizers to be used except sparingly in initial planting.
Research feasibility of creating a direct fish spawning waterway to Jerry’s Pond from Yates Pond or Alewife Brook.
Conduct a study of the habitats of owls, hawks, and osprey.
Habitat areas should be appropriately protected. Consider fencing and shielding from lights and traffic.
Investigate the feasibility and location of a habitat center near Jerry’s Pond.
New wetlands delineation and wildlife habitat survey should be part of a broader focus (whole area), and should be independently reviewed.
A clear and complete presentation of actual plans for compensatory flood storage should be provided by the developer for the entire site.
Any plans for clean up, planting, and wetlands mitigation should be fully developed and fully discussed with abutting neighborhoods and the City prior to the commencement of these activities. When agreed upon and approved, such activities should be commenced and completed prior to the initiation of any other construction. Clean-up, planting, and wetlands mitigation at Jerry s Pond to take place before the start of construction. Any failed vegetation to be replaced within two years of failure.
The project proponent should be responsible for the long term maintenance of any replacement wetlands, flood storage areas, and drainage structures, and this requirement should be included in any eventual or current permits regarding this site. Both the Cambridge Conservation Commission and the community at large should be included in routine review of these and other related matters. Owner of the site to post a maintenance bond as an incentive to assure proper maintenance.
Any schemes for “wetlands replication” should be fully developed and explained in full to the abutting neighborhood, the City ,and all other interested and informed parties. The Committee would express its preference for preservation and protection of existing natural areas including but not limited to wetlands rather than newly constructed replications.

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Overall Alewife traffic

No vehicle entry to the site from any residential neighborhood.
Include a deed restriction in perpetuity (i.e., a restriction binding on successive owners) preventing the extension and opening of Harvey St. into the site as long as the site is non-residential.
For emergency vehicle access, make the right of way at the end of Harvey St. as narrow as the Fire Dept. will accept and use rough pavement (e.g., cobblestones) with removable bollards to indicate that it is not a through street.
No additional lanes to be added to Alewife Brook Parkway to accommodate any additional traffic anticipated as result of development of the site.
If a supermarket is built on the site, provide order and delivery services to encourage less traffic at peak hours.
Implement mitigation measures to decrease the amount of employee commuting by car.
Provide further study of site access and circulation to ensure that traffic moves easily from the site to Route 2 despite commuter traffic from the T garage during peak hours.
Examine the proposed entrance next to Whittemore Ave. to make sure there will be no left turns across Rt. 16 traffic to enter the site.
An independent comprehensive traffic impact study of the proposed development is necessary. The study area must be defined by the affected community and should include not only Route 2/Route 16, but also the inclusive area from Massachusetts Avenue to Concord Avenue. Analysis must be undertaken to determine the traffic bypass routes and volumes that would result from the proposed development and the impact of those routes on area streets including but not limited to Massachusetts Avenue, Concord Avenue, Rindge Avenue, New Street, Walden Street, Sherman Street, Sargent Street, Fayerweather Street, Huron Avenue Whittemore Avenue, Columbus Avenue, Seagrave Road, Madison Avenue, Magoun Street, Harrison Avenue, Harvey Street, Clifton Street, Jackson Street, Clay Street, Reed Street, Montgomery Street, Dudley Street, Cedar Street, and similarly affected streets requested by the Cambridge Highlands and Area 9 neighborhood associations.
Complete and timely disclosure should be made of all raw traffic counts and analysis undertaken in connection with traffic studies of the proposed development.
Any development the site must present a viable traffic management plan. The plan, including the definitive vehicular entry and exit scheme for both customer and commercial traffic, must not be narrowly focused. It must fully address the proposal’s several impacts and in particular, it must protect the residential nature of the immediate neighborhood.
The impact of increased traffic volume (passenger, vehicle and truck) upon affected roadways in East Arlington and Belmont should be included in any independent study of traffic impacts.
In addition to a comprehensive study of automotive traffic a separate study of non-automotive transportation uses at the W. R. Grace Site should also be undertaken.
The Committee recommends that the City seeks to restrict access by commercial vehicles to or from the site via Whittemore Avenue. Any future legal claim to Whittemore Avenue as a truck route should be prohibited prior to the negotiation of any and all commercial leases at this site. It should be understood that any and all truck exclusions which may be imposed in the future on Route 16 shall not affect the restriction proposed for Whittemore Avenue nor shall such potential exclusions affect any vehicular prohibition currently in effect at this site(e. g. Harvey Street).
A serious effort should be made to resolve the technical differences and identify areas of agreement between the Rizzo, Abend, and Kaiser reports regarding the current estimates of traffic levels affecting the site.
A traffic accident and safety analysis should be a significant component of any independent study.
The analysis of the Route 2/Alewife intersection must include capacity calculations which accurately reflect the number of cars getting through the merges and moving on the short lanes.
The developer needs to demonstrate a strategy to ensure that congestion at the driveway does not result in blockage of the ramp.
More extensive and detailed queue counts need to be done to provide a clearer picture of how cars will queue up given increased volume.
Complete and timely disclosure should be made of all raw traffic counts and analysis undertaken in connection with traffic studies of the proposed development.
Any development of the site must present a viable traffic management plan. The plan, including the definitive vehicular entry and exit scheme for both customer and commercial traffic, must not be narrowly focused. It must address the proposal’s several impacts and in particular, it must protect the residential nature of the immediate neighborhood.

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Traffic safety on neighborhood streets

The City Traffic Department must meet with residents of the affected neighborhoods to discuss remedies for the dangerous use of their road systems as bypass routes for Alewife traffic. The City should swiftly implement suggestions arising out of these meetings.

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Parking

Parking by non-residents on nearby neighborhood residential streets should be prohibited .
Parking in W. R. Grace parking lots on Whittemore Street should be restricted to W. R. Grace employees and visitors and to residents.
The Traffic, Transportation and Parking Department should clarify and document the City s position with regard to all current and potential parking capacity at the site, with relevant confirmation from the Interim Parking Control Commission.
Any development plan should be integrated with the current use of Russell Field and the community recreational areas adjacent to the site(for example, overflow parking during the football games and other athletic activities should be provided.)

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Site design

Buildings should be situated as far from the neighborhood and as close to the “T” as possible.
Give preference to proposals that are closer to neighborhood scale than high-rise scale.
Design the site to give as much precedence as possible to pedestrians and cyclists. (The justification for a supermarket in the access study is that it could serve the large number of households in North Cambridge without cars.)
Enhance security at the MBTA Alewife Station entrance with adequate lighting — especially if there is no restaurant and proposed buildings face away from the MBTA stop.
Any parking areas to be shielded from neighborhood view by berms and landscaping.
No blank walls maximum number of windows.
No loading docks or dumpsters facing the neighborhood.
All loading docks to include sound buffering, either by placement near non-residential structures or construction of solid sound barriers.
Use metal-halide lamps (white light) rather than sodium (yellow light). No cobra lamps. Lighting should be adequate for safety but designed to minimize glare and effects on the neighborhood.
Divide the parking lot into small parking fields and provide planting islands throughout the parking lot. 11. All equipment should be acoustically and visually screened.
The City should develop landscape guidelines for the parking lots to mitigate the microclimate effects of the increase in impervious surfaces — heat, winds, air pollution.
Use native plants where possible. Avoid generic suburban landscaping.
A buffer between the development site and the neighborhood should be densely landscaped with both evergreen and deciduous shrubs and ground cover, as well as trees.
Provide pedestrian/bike access from the neighborhood with discreet but attractive gateways.
When the triangular building is demolished – provide landscaping and methods to ensure that there is no vehicle access (only pedestrian/bicycle access) to the development site from the Whittemore parking lots. 17. Employ a site design that discourages auto use.
Consider benches and a walkway around Jerry’s Pond., if recommended by habitat study and Conservation Commission.
To the greatest extent possible, design the site with maximum site-lines to deter crime and enhance safety.
Discontinue snow storage in the Russell Field area, especially in the parking lot adjacent to Comeau Field, just off Rindge Ave.
Ensure the provision of a significant transition and buffer zone between Harvey St. and Whittemore Ave. and the new construction on the W. R. Grace property.
The Community Development Department should apply the guidelines of the Alewife Planning Study to any proposed development of the W. R. Grace site and explore the possibility of integrating the site into the Alewife Planning Study. This includes evaluating any plan in the context of other developments planned in the area, such as the triangle area, the Rte. 2 strip, and the shopping areas near the Concord Ave. rotary.
No super-sized supermarket should be built at the proposed development site under any circumstances.

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Economic benefits

The City should work with any developer to provide answers to the following questions:

What are the likely number and nature of local part-time and full time jobs to be created by the development proposal?
What are the revenue benefits to the City?
What are the likely costs in City services?
What are the best estimates of economic viability given the market and the current condition of comparable developments?

In order to support local employment and youth career development opportunities the developer and tenants should enter into a first source hiring agreement with the City and participate in CRLS school-to-work programs.

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