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IAAC Meeting April 2002

INTER-AGENCY ADVISORY COMMITTEE (IAAC) MEETING
Monday, April 29, 2002, 2:15 PM to 3:15 PM, WHOI Carriage House
DRAFT MINUTES

ATTENDANCE

Members Present: Mike Bothner, USGS; Todd Callaghan, MCZM; Dave Dow, NMFS; Tom
Fredette, USACoE; Russ Isaac, MADEP; and Steve Lipman, MADEP alternate.

Observers: Bruce Berman, Save the Harbor/Save the Bay; Peter Borrelli, Center for Coastal Studies;
Cathy Coniaris, MADEP; Patty Foley, Save the Harbor/Save the Bay; Mike Mickelson, MWRA;
Andrea Rex, MWRA; Larry Schafer, retired; and Steve Tucker, Cape Cod Commission.

SUMMARY OF ACTION ITEMS

  1. IAAC will remain a standing committee. The group decided to not elect a chair at this time.
  2. IAAC recommends that the mussel contaminant monitoring continue for several years.
  3. October 2001 minutes were approved with no amendments.

MINUTES

C. Coniaris noted that Sal Testaverde is no longer the chair of IAAC and thanked him for his work.
She and S. Lipman are co-chairs for this meeting until a chair is elected. The role of IAAC as stated in
the OMSAP charter is “to advise OMSAP on environmental regulations”. IAAC has been discussing
precisely what this means to its members for several years. The group should decide whether it will
continue to meet, and if so, who will be the chair, and how will the group function.

R. Isaac thinks if we follow IAAC’s role as stated in the OMSAP charter, then there does not seem to
be a need for this group, especially since OMSAP has never asked IAAC to convene. Perhaps we can
meet on an ad hoc basis as issues arise. D. Dow thinks that IAAC should continue to meet to discuss
regulatory/management issues.

M. Bothner said that USGS focuses on science, not regulations or management. He hopes USGS will
continue to contribute good science on how the Mass Bay/Boston Harbor system works. He thinks the
agencies should be in communication about what changes are taking place in their programs in Mass
Bay. This could be a useful forum, either as IAAC, or another committee. S. Lipman thinks that is an
excellent idea, but it sounds like a different forum than IAAC.

T. Fredette sees IAAC as a standing subcommittee to OMSAP. The committee is a creation of the
permit and its charter is defined by the permit. He is not sure that IAAC can redefine that without the
support of EPA/MADEP. S. Lipman agreed. R. Isaac thinks the points made in favor of broadening
the role of IAAC are useful, but it is not our role to set that up.

T. Callaghan, a new member, asked if OMSAP asks IAAC members in its audience regulatory
questions. C. Coniaris replied that OMSAP frequently does. P. Borrelli noted that OMSAP reviewed
the mussel study but they did not discuss revising the threshold because no one on IAAC guided them,
even though OMSAP agreed that the threshold did not make sense scientifically. He thinks it is
important that the OMSAP and IAAC members interact. S. Lipman said that at the last OMSAP
meeting, this issue of dissolved oxygen (DO) regulations arose, and EPA/MADEP responded.

A. Rex agreed with P. Borrelli, and it may be interesting for IAAC to have a discussion on the
regulatory implications of the mussel contaminant threshold. MWRA did not request that OMSAP
discuss revising the threshold because we think it is too soon. But the threshold did do its job of
making us look more closely at a change that was significant, although not biologically meaningful. P.
Foley suggested that IAAC meet several weeks before OMSAP so that they can discuss what the role
of the regulators is in the science agenda. R. Isaac said that IAAC was formed to be a responder, and
not an initiator. Prior to OMSAP, there was the Outfall Monitoring Task Force (OMTF) that had
members from the scientific, regulatory, and public interest group communities. There were concerns
about the credibility of such a group and so EPA/MADEP wanted to form a science panel of
independent scientists.

S. Tucker thinks it would be good to have issues such as DO discussed by IAAC, but he does not think
OMSAP would ever call upon them to meet. R. Isaac suggested he write a letter directly to
EPA/MADEP with his concerns. S. Tucker thinks OMSAP should evaluate things like an exceedance
from a scientific perspective, followed by an IAAC review from a regulatory perspective. S. Lipman
said that this is not how the process was set up. T. Fredette thinks that there are a number of IAAC
members who have been involved since the original OMTF that have considerable scientific and
regulatory expertise. There was a desire to continue to have this knowledge available and as OMTF
transitioned into the OMSAP, the IAAC was created. He is not sure why IAAC is needed when EPA
and MADEP, the permit issuers, are present at OMSAP meetings to answer questions. M. Bothner
thinks having IAAC as a standing committee is a good resolution, it shows our willingness to
participate, and does not require a permit modification. ACTION: IAAC will remain a standing
committee. The group decided to not elect a chair at this time.

M. Mickelson asked how IAAC felt about the mussel monitoring. T. Callaghan replied that looking at
just one year and making a decision is irresponsible, especially when that “year” is just a 60-day
deployment. We need to look at variability among several years, at least through the life of this
permit. M. Bothner thinks that the Cape Cod Bay station is very important to maintain because some
contaminants have an atmospheric input as well. He feels that long term data are quite useful. T.
Fredette thinks the mussel monitoring should continue for at least another year. IAAC members
agreed that it was important to continue the mussel contaminant monitoring for several years. C.
Coniaris urged IAAC members to be involved with the upcoming OMSAP discussion on developing a
process for reviewing the Monitoring Plan. ACTION: IAAC recommends that the mussel
contaminant monitoring continue for several years.

ACTION: Minutes from the October 2001 meeting were approved.

ADJOURNED

MEETING HANDOUTS:

  • Agenda
  • April 2002 OMSAP/PIAC/IAAC membership lists
  • October 2001 draft IAAC minutes
  • MWRA information briefings and copies of presentations

Summary prepared by C. Coniaris. 

IAAC Meeting October 2001

Tuesday, October 16, 2001, 9:00-9:45 AM
MADEP
FINAL MINUTES

ATTENDANCE
Members Present: : Salvatore Testaverde, NMFS (chair); Dave Dow, NMFS; Matt Liebman, EPA; Steve Lipman, MADEP alternate; and Jack Schwartz, MADMF.

Observers: Bruce Berman, Save the Harbor/Save the Bay; Mike Borucke, MIT; Cathy Coniaris, MADEP; Mike Delaney, MWRA; Martin Dowgert, FDA; Dave Duest, MWRA; Marianne Farrington, New England Aquarium; Patty Foley, Save the Harbor/Save the Bay; Roger Janson, EPA; Ken Keay, MWRA; Bob Kenney, URI; Mike Mickelson, MWRA; Andrea Rex, MWRA; and Steve Tucker, Cape Cod Commission.

SUMMARY OF ACTION ITEMS

  1. IAAC will continue to meet with its original mission statement "advise OMSAP on environmental regulations" until there is a modification to the OMSAP charter which is attached to MWRA's NPDES permit.
  2. October 1999 minutes were approved with no amendments.


MINUTES

S. Testaverde welcomed everyone. The group then discussed the future role of the IAAC. S. Testaverde explained that he has had a number of meetings with EPA and MADEP and discussions with several IAAC members about IAAC's proposed mission change. EPA and MADEP felt that the mission change was too broad and seemed to conflict with OMSAP's scientific role. As chair, he recommends that the committee continue its work as the permit requires, without a mission statement change. R. Janson assumed that S. Testaverde accepts the charter here as written, that the committee will advise OMSAP on environmental regulations. S. Testaverde agreed. R. Janson added that this is consistent with OMSAP's view of the situation. C. Coniaris pointed out that OMSAP feels that the IAAC mission statement should not be changed. However, they feel that it is important to have people from the agencies in the audience during science panel meetings so that they can be on hand to answer questions. S. Testaverde thinks it is not only important but also part of the permit, under attachment T. Until there is a permit modification, he sees no choice but to continue.

B. Berman asked if there is a way IAAC can be more effective in participating with OMSAP and PIAC without a permit change, so that the concerns that you have expressed could be, at least informally, addressed. S. Testaverde replied that IAAC was trying to have agendas that included other issues that were important to a particular member agency. He will continue to create agendas based upon input from the members. He hopes that IAAC will have the benefit of PIAC and OMSAP members present to hear perhaps agenda items that they may not otherwise hear. S. Lipman thought that IAAC was set-up as a resource to OMSAP, and IAAC's agenda was based on what they were asking us, our role was not to set-up another science panel. S. Testaverde disagreed. He feels the goal is to share information among members. Since the charter was developed in October 1998, OMSAP has never asked us to convene, nor has it asked us any questions. S. Lipman thinks that means either OMSAP did not have questions, or if they did, they were addressed by IAAC members present at OMSAP meetings. He does not think the charter meant for IAAC to convene to discuss our own issues. S. Testaverde asked if IAAC should wait until we are called by OMSAP. S. Lipman said yes, as well as attend OMSAP and PIAC meetings. That is what he thought IAAC was supposed to be doing. R. Janson agreed that that was his reading of the charter as well.

M. Liebman outlined an example of a topic IAAC would be interested in. The marine dissolved oxygen (DO) criteria are about to be reviewed by EPA and IAAC may need an informational session on this complicated issue without waiting for OMSAP to convene them. S. Testaverde pointed out that IAAC's role is very broad: "the committee will advise OMSAP on environmental regulations". He does not see anything in the mission statement that precludes this type of meeting. S. Lipman agreed but he does not see it as being consistent with what IAAC is intended to be. He thinks if OMSAP is concerned about the DO issue, then that would trigger the IAAC to put together information for OMSAP and their discussions. S. Testaverde repeated that IAAC has never been called by OMSAP, yet he considers floatables an issue related to the Endangered Species Act that needs to be addressed.

R. Janson thinks holding an informational session of the IAAC members to discuss proposed, pending, or recently issued DO criteria relative to the regulatory effect on the MWRA permit is probably within the general definition of the mission statement. On the other hand, discussions on floatables regarding the Endangered Species Act can be done individually with S. Testaverde representing NMFS and not IAAC, which is an important distinction. IAAC should not be used to push one agency's position. S. Testaverde said that he was not using the word "push", but rather "informational" to inform other members and also to hear how the other regulatory bodies feel about issues.

S. Tucker thinks that IAAC could have had a large role in what transpired this past year. For example: internal requests for permit modifications and exceedances, exceedance reports and how they are managed, new environmental regulations, and discussions on how OMSAP should respond to exceedances. IAAC could articulate what the agencies' expectations are and convey a message without going into the official process of the permit. D. Dow pointed out that with environmental regulations, it is better to try to deal with them proactively and discuss issues, rather than act reactively and having NMFS doing a section 7 consultation. S. Testaverde agreed and thinks it shows that we are working with our sister agencies in a very positive manner.

S. Testaverde asked if PIAC meets on its own or is it convened by OMSAP. P. Foley replied that PIAC meets on a quarterly basis in partnership with OMSAP and communicates with them, as necessary, in between meetings. PIAC also conducts business on its own via email or telephone calls. So there is a close working relationship that is in partnership with these quarterly meetings and happens as issues or occasions arise outside of the formal meeting setting.

S. Testaverde thinks IAAC should be meeting to discuss upcoming changes proposed by MWRA and share that information with the members. B. Berman pointed out that we heard from all of the agencies on all the exceedances and the proposed changes. He thinks there were spirited discussions and OMSAP made informative decisions.

S. Testaverde asked if everyone agreed with the recommendation that we continue our work as the permit requires with our mission statement, address current issues as they come along, and members can bring up additional topics in informational sessions. J. Schwartz noted that EPA has been unwilling to modify the charter language because they think the change in the charter would overlap the roles of IAAC and OMSAP. He thinks either change the language in the permit or dissolve IAAC. He thinks it is ridiculous to meet and discuss matters without being embodied, or enabled through the permit. He believes that unless EPA decides what to do, IAAC should disband. S. Testaverde disagreed. We are authorized by the permit to meet until the permit is modified, to disband IAAC. J. Schwartz does not see this as a functioning and productive committee.

S. Testaverde is bothered that some IAAC members do not attend OMSAP meetings, because he thinks the outfall is such an important issue to the ecosystem. However, this is the mission statement that we have been provided with. EPA and MADEP have said that they are not going to change the mission statement attached to the permit and so he will continue to call meetings until someone makes the recommendation that the IAAC be disbanded. J. Schwartz moved that we recommend to the permitting agencies to either revise the charter language as discussed in 1999 or eliminate IAAC from the permit. The motion failed. S. Testaverde repeated that IAAC is in the permit. We will continue to meet quarterly on the same day as OMSAP and PIAC to discuss relevant issues.

R. Janson noted that following the strict rules of permitting, EPA and MADEP could not unilaterally make a change in the permit. It would either have to be based on new information, or the MWRA would have to request a modification to the permit. When the permit is up for reissuance, then all parties to that process can entertain what changes they might want to make, if any. They may want to suggest changes to the charter language, they may want to suggest that one or more of these committees be eliminated, or one or more be combined. Going back to OM SAP's view, they want to avoid overlapping roles. He does not see any problem in following the DO example discussed earlier, that when there is some proposed regulatory change that likely would have an impact on this permit, IAAC meet to discuss the issues surrounding it. Perhaps OMSAP needs to be queried as to whether or not they intend to ever engage IAAC based on their own initiative.

Minutes from the October 2001 meeting were approved.

MEETING HANDOUTS

  • Agenda
  • October 2001 OMSAP/PIAC/IAAC membership lists
  • October 1999 draft IAAC minutes
  • OMSAP charter

ADJOURN
Summary prepared by C. Coniaris.

IAAC Meeting October 1999

Thursday, October 14, 1999, 12:30 to 3:00 PM
MADEP Boston
FINAL MINUTES

ATTENDANCE
Members Present: : Salvatore Testaverde, NMFS (chair); Russ Isaac, MADEP, Matt Liebman, EPA; Steve Lipman, MADEP alternate; Jan Smith, MCZM alternate, and Jack Schwartz, MADMF.

Observers: Peter Borrelli, Center for Coastal Studies; Cathy Coniaris, OMSAP/PIAC/IAAC Assistant; Patty Daley, Cape Cod Commission; Gillian Grossman, Save the Harbor/Save the Bay; Mike Mickelson, MWRA; Andrea Rex, MWRA; Larry Schafer, observer; Mark Silver, Center for Coastal Studies; and Grace Vitale, MWRA..

SUMMARY OF ACTION ITEMS

  1. S. Testaverde and J.Schwartz will prepare a letter to EPA/MADEP outlining IAAC's OMSAP charter questions and proposed revisions.
  2. S. Testaverde will present an overview of NMFS' right whale related activities at the next IAAC meeting.


MINUTES

IAAC approved the summary of the May 17, 1999 meeting with no amendments (two members who did not attend abstained).

OMSAP CHARTER DISCUSSION

S. Testaverde recounted the charter discussion from the May 1999 IAAC meeting. The committee had voted and approved the following PROPOSED IAAC MISSION STATEMENT: "The committee will advise the OMSAP, EPA and MADEP on scientific, technical and/or regulatory matters related to discharges from and operations of the MWRA system outfalls that may directly or indirectly affect Boston Harbor, Massachusetts Bay, and Cape Cod Bay. The IAAC may review or evaluate other environmental matters as necessary."

IAAC also discussed several other potential changes to the OMSAP charter but did not vote to approve them. S. Lipman reiterated G. Haas' comments from the May meeting. [Excerpt from May meeting summary: "G. Haas disagreed with this proposed revision (to the IAAC mission) since OMSAP is the group that advises EPA/MADEP on scientific and technical issues. He also pointed out that IAAC includes representation from EPA and MADEP and thus does not have to formally advise those agencies."]

R. Isaac pointed out that the original mission of IAAC was to respond to OMSAP questions on regulatory issues and not to advise EPA and MADEP directly. S. Testaverde stated that at the May meeting, most members felt that the IAAC mission in the OMSAP charter was to narrow. He feels that there should be a broader IAAC mandate so that we can take advantage of the scientific expertise of IAAC members.

J. Schwartz explained that when the Outfall Monitoring Task Force (OMTF) was dissolved and re-structured into OMSAP/IAAC/PIAC, EPA and MADEP were in the process of developing a very unique permit. Everyone knew that they were on untested grounds and a lot of discussion focused on IAAC's role. He feels that if IAAC is to deal only with regulatory questions, then there is no point for the group to meet. He suggested having contact information available for OMSAP and no IAAC meetings, unless the group was given a broader mandate.

M. Liebman clarified that there are two issues regarding the proposed mission: whether to broaden the scope of IAAC's charge to include advising on scientific issues, and whether to report to EPA and MADEP in addition to OMSAP. He thinks that one benefit of IAAC is that it allows for a group of agencies to make a statement instead of individual agencies, but if "who" to advise becomes a sticking point, then IAAC should just advise OMSAP. He agrees that the IAAC mission should be broadened.

S. Testaverde feels that OMSAP will rarely call on IAAC for advice so the group will have to determine its own meaningful issues to discuss. M. Liebman pointed out that the committee can give advice without being asked by OMSAP. S. Testaverde agreed and added that meetings also provide a platform for the committee to discuss issues the group thinks should be explored. R. Isaac thinks IAAC should ask for clarification from EPA/MADEP on the committee's role. He agreed that IAAC should not advise EPA/MADEP. If EPA/MADEP decide to keep the original mission, then he agrees that IAAC should be a standing committee.

J. Schwartz asked whether the OMTF was dissolved because the agency employees were advising agency upper management from an independent group. R. Isaac replied yes, and added that there were also non-scientists on the OMTF from environmental interest groups who had a say in scientific decision-making. Everyone agreed to form a science panel that provided technical recommendations whose membership was composed of well-respected independent experts.

ACTION: S. Testaverde and J. Schwartz will draft a letter to EPA/MADEP. The letter will include the proposed revised IAAC mission, other proposed changes to the OMSAP charter, and three questions - who does IAAC advise, who has authority to make charter changes, and does IAAC advise only on regulatory matters?

NITROGEN REMOVAL TECHNOLOGIES

Grace Vitale (MWRA) gave a brief presentation on current technologies for nitrogen removal (NR). The NPDES permit requires that MWRA maintain a comprehensive technical survey of effective treatment technologies for NR applicable to the Deer Island treatment facility which is updated at least annually for the duration of the permit. This process is designed to facilitate the speedy selection and implementation of NR technology if deemed necessary. In addition, MWRA must implement a monitoring program to characterize the quality of wastewater streams within the treatment plant in order to produce data that would facilitate the selection of NR technology and facility design, if needed. This monitoring plan will be submitted to EPA, MADEP, and OMSAP within 90 days of the effective date of the permit for approval.

The various treatment alternatives are divided into three categories: physical, chemical, and biological. Examples of physical and chemical treatment include ammonia stripping, ion exchange, breakpoint chlorination, and lime addition. Biological treatment involves nitrification and denitrification. Nitrification is the biological conversion of ammonium to nitrate that occurs under oxidative (aerobic) conditions. Denitrification is the reduction of nitrate to nitrite to nitrogen gas by bacterial action (anaerobic). Nitrification technologies can employ suspended growth, attached growth, aerated filters, fluidized bed reactors, or land treatment using wetlands and ponds. Denitrification technologies include submerged packed bed reactors, fluidized bed reactors, or deep bed filters.

Biological nitrogen removal is preferred for municipal treatment plants. Among the things that MWRA must consider when selecting a treatment alternative are: cost effectiveness, land constraints, power availability, year-round or seasonal treatment, form and concentration of nitrogen compounds, effluent limits, compatibility with existing treatment processes, reliability, and flexibility.

G. Vitale described the pros and cons of the alternatives that have been evaluated for Deer Island. At this time, the "candidate" which MWRA recommends is nitrification using biological aerated filters and denitrification using fluidized bed reactors. These two processes would require 3.4 acres, which is available on Deer Island. Effluent treated with these methods would decrease from approximately 10-20 mg/L total nitrogen to about 3-4 mg/L.

G. Vitale then briefly described MWRA's pre-draft of the effluent monitoring program which will measure nutrients in the influent, primary effluent, secondary effluent, and return streams. MWRA will continue to monitor the emergence of new technologies and experience gained on treatment systems, especially those that are used by cold-weather wastewater treatment plants.

J. Schwartz asked what the approval process is once the NR plan is in place. S. Lipman replied that any changes in technology/operations must be approved by MADEP. G. Vitale added that MWRA has to prove that the methods being proposed will decrease nitrogen by a certain amount to MADEP. S. Lipman suggested that the pilot plant be used to test these various methods.

POLYMER USE IN SECONDARY TREATMENT

S. Testaverde gave a primer on polymers and their use in secondary treatment to reduce total suspended solids (TSS) and biological oxygen demand (BOD) during high flow storm events. Several years ago, EPA/MADEP determined that MWRA need not build secondary battery D because both flows and solids were lower than originally projected - this saved ratepayers $200 million. [To assure that the MWRA would not violate TSS or BOD under high flow conditions, EPA/MADEP required MWRA to use polymer if a violation appeared imminent, but MWRA never planned to use polymer on a regular basis (Maury Hall, MWRA, personal communication).] NMFS is concerned about polymer toxicity testing and the possible effects of polymers on the environment.

A polymer, or polyelectrolyte, is a high molecular weight, long-chained substance formed either naturally or synthetically. Polymers are classified by molecular weight, length of polymer chain, type of charge [neutral, anionic (-), and cationic (+)], and charge density. They are used to "polish" effluent by improving the removal of solids. Polymers are also used as "sludge conditioners" and are very expensive to use. [MWRA does not plan on using polymer at all. The conditions under which MWRA could use them, very high flows, occur 8 to 15 days per year (M. Hall, personal communication).]

The use of polymers in secondary treatment involves two processes: coagulation and flocculation. [The following definitions are from http://environment.about.com/culture/environment/library/weekly/blgloss3.htm
Coagulation is the clumping together of very fine particles into larger particles caused by the use of chemicals (coagulants). The chemicals neutralize the electrical charges of the fine particles and cause destabilization of the particles. This clumping together makes it easier to separate the solids from the water by settling, skimming, draining, or filtering. Flocculation is the gathering together of fine particles in water by gentle mixing after the addition of coagulant chemicals to form larger particles.]

Polymer application was required in the MWRA Court Order. MWRA will use polymers when: (1) effluent threatens to violate its NPDES permitted level for average TSS (45 mg/L); (2) at high flows greater than 540 mgd for more than 8 hours; and (3) when solids appear to be flushing into effluent. S. Testaverde believes that the major problem with polymer use is that there is no method to detect polymer in effluent [since polymer is a proprietary mixture of several compounds (M. Hall, personal communication)]. The NPDES permit requires that MWRA minimize the use of polymer in secondary treatment, test new polymers using standard test species, and report the detailed chemical properties of all polymers used [see page 6 of the permit]. The polymer Percol-789 can be dosed at up to 2 mg/L, most of which presumably settles out. S. Testaverde believes that MWRA will have to add more than 2 mg/L to achieve desired results. [MWRA believes that dosing less than 2 mg/L would be sufficient for effective effluent "polishing" (M. Hall, personal communication).] MWRA continues to test new polymers that may be cheaper, better, or less toxic.

MWRA effluent is typically negatively charged and therefore requires a cationic polymer that can be toxic and biologically harmful when used in excess. S. Testaverde quoted from a letter to MWRA from Allied Colloids, dated July 14, 1995 that "cationic (+) polyacrylamides demonstrate appreciable toxicity at moderate doses". Results from toxicity testing using polymer and effluent varied greatly. Older test results found that cationic polymers are acutely toxic at about 2 to 3 ppm in pure water, however, in effluent, there is less toxicity due to the absorption/attachment of polymer and particles. Acute toxicity was reduced by adding solids to adsorb polymers (Biesinger, et al., 1976). However, there are no methods to measure adsorption rates or polymer in effluent.

S. Testaverde showed MWRA toxicity test results for mysid shrimp (acute), lobster larvae (acute), and sea urchin fertilization (chronic). Lobsters larvae were not good test organisms due to high variability in the control survival. Overall, S. Testaverde feels that the polymer toxicity testing results were unclear.

M. Liebman asked what form the polymer is in when it is added. S. Testaverde replied that it is a slippery powder [or liquid (M. Hall, personal communication)]. M. Liebman asked if polymers remove suspended solids using a charge process. S. Testaverde replied that it is a chemical (bonding) and physical (gravity) removal of suspended solids. R. Isaac added that polymers are more efficient at removing very fine particles. Since less is needed compared to other settling compounds, less sludge is created. A. Rex asked if any other wastewater treatment plants have reported environmental problems due to polymer use. S. Testaverde replied that he does not think anyone is looking. He mentioned that he did review some research that showed an impact of positively charged polymers on minnows and sea urchin eggs. He feels that polymers are very effective in reducing TSS and he would be comfortable with their use if more benign types could be developed.

FOOD WEB MODEL SCOPE OF WORK DISCUSSION

P. Daley briefly described Barnstable County Science Advisory Panel's (BCSAP) alternate proposal to MWRA's Food Web Model Scope of Work (FWMSOW). The BCSAP has not finalized the proposal to date. They met to discuss the problems and complexities with food web modeling and attempted to develop a way to address what they see as the potential impacts from the outfall, particularly on right whales. They have developed a food chain concept (not a model) which has three steps and three general hypotheses. The first step is that nutrients from the effluent may affect or change phytoplankton composition and abundance. The second is that a change in phytoplankton may affect zooplankton composition and abundance, and lastly, a change in zooplankton may affect right whales. The BCSAP intends to include several assertions as part of each "step" of the chain referenced from the literature. They believe that the purpose of a food web model scope of work is to look at contingencies and uncertainties. This proposal will be presented in greater detail to OMSAP at their October 26, 1999 meeting. [UPDATE: The BCSAP postponed the presentation of this proposal and the OMSAP meeting was also postponed.]

L. Schafer asked if there are any other species that would be better indicators of the state of the Bays. P. Daley replied that humpback whales may be a better indicator species but since they feed at higher trophic level, developing a food web model for them is much more complex. The focus is on right whales because of their endangered status. L. Schafer believes that measurements of right whale numbers could vary quite a bit due to their scarcity. That is why he feels that a more common species would be a better indicator. S. Testaverde believes that right whales are a better indicator species. Since only about 300 right whales remain, it would be a "red flag" if they did not visit Cape Cod Bay one year. On the other hand, humpback whales are not as good of an indicator species since they number around 10,000-15,000. L. Schafer disagreed and feels that since there are so few right whales, a few fatal ship strikes would throw the monitoring data off. S. Testaverde said that if right whales disappear from a critical habitat [Cape Cod Bay], and if it was determined that the outfall actually caused right whales to leave a critical habitat, MWRA will have violated the Endangered Species Act. L. Schafer agreed but feels that blaming the outfall is a big "if". S. Testaverde believes that NMFS would examine this carefully but thinks that it is up to MWRA to defend themselves from any accusations.

P. Daley pointed out that the BCSAP is examining the food web from the "bottom-up", not the "top-down". In other words, instead of examining the right whale population for changes due to the MWRA outfall, the BCSAP is trying to test the hypothesis that the MWRA outfall could cause changes in the ecosystem that might affect right whales. Though the BCSAP and Cape Cod Commission would like to see additional monitoring in Cape Cod Bay, the FWMSOW is only a paper exercise to help inform the monitoring program on what needs to be looked at more closely.

M. Liebman asked P. Daley what the BCSAP will ask of OMSAP. P. Daley replied that they are not convinced that MWRA's current proposal carefully looks at the dynamics between these different trophic levels. In addition, the scope of work [flowchart] stops moving forward if there is no existing data to prove a connection between the outfall and changes in the environment. She hopes that OMSAP adopts a scope of work that establishes a set of hypotheses showing the interconnections that may be influenced by the outfall and in turn would direct the monitoring program towards looking at those interconnections.

R. Isaac asked S. Testaverde which risks for the right whale population (e.g. drift nets, collision with ships, endocrine disrupters, etc.) are being studied, and what is the biggest risk factor identified to date. S. Testaverde replied that all risks are being studied, with the largest risks to right whales being entanglement and ship strikes. Right whales are monitored every year in Cape Cod Bay by the state of Massachusetts, USCG, and NMFS, and there is a mandatory ship reporting system adopted by the international community for Cape Cod Bay, as well as Georgia and Florida. ACTION: R. Isaac requested an overview of NMFS' right whale-related activities. S. Testaverde agreed to present this at the next IAAC meeting. M. Mickelson suggested that those interested review the report by J. Kelly et al. (1998) which discusses a "bottom-up" approach [Kelly JR, Davis CS, Cibik SJ. 1998. Conceptual food web model for Cape Cod Bay, with associated environmental interactions. Boston: Massachusetts Water Resources Authority. Report ENQUAD 98-04. 9 p. Available at http://www.mwra.state.ma.us/harbor/enquad/pdf/98-04_enquad_report.pdf]. Included at the end of the Kelly et al. report are Robert Kenney's (URI/OMSAP) comments that included a diagram of the factors affecting right whale occurrence in Cape Cod Bay.

P. Borrelli feels that one of the reasons why the right whale does play such an important role in this food web analysis is that there are no more than 350 right whales left. Over the past 12 years, the Center for Coastal Studies (CCS) has seen as many as 100 right whales (one-third of the population) visit Cape Cod Bay each year over a 3-4 month period and of the total population, approximately two-thirds of all animals have been observed in Cape Cod Bay. Thus, relatively speaking, these numbers show that there are relatively many right whales that can be used as indicators. It is also important to realize that the right whales visit Cape Cod Bay because of the dense zooplankton patches which are found almost no where else. The CCS is prepared to hypothesize that the feeding habitat in Cape Cod Bay is unique to the species in the western north Atlantic rivaling the Bay of Fundy and any other known habitat. If this unique environment is disturbed or diminished in any way, it could be catastrophic for the right whales. The CCS is not implying that there is a causal relationship to the MWRA outfall, but certainly, the argument would be to take a cautionary role.

R. Isaac asked how long right whales stay this area. P. Borrelli replied that they are feeding in this area from December to April. M. Mickelson pointed out that Stormy Mayo (CCS) said that there are also zooplankton patches in the Great South Channel and that right whales are able to obtain three times their food requirement in while feeding in Cape Cod Bay. R. Isaac asked if the right whales feed on a very restricted diet. P. Borrelli replied that yes, their diet is very restricted, much more restricted than previously thought. Right whales prefer specific copepods - Calanus finmarchicus. The CCS is about a month away from publishing results on this.

L. Schafer still believes that there is a good chance that MWRA will be blamed for something it is not causing. For example, what if a smaller copepod dominates after the new outfall goes on-line causing right whales to go elsewhere. P. Borrelli replied that that would be an issue NMFS would have to respond to since they administer the Marine Mammal and the Endangered Species Acts. L. Schafer pointed out that it could take ten years or more before enough data is definitively collected which proves that MWRA was to blame. P. Borrelli agreed. S. Testaverde thinks that if there were such a large impact on right whales, the Secretary of Environmental Affairs would have to weigh the issue in a quicker time frame. He feels that there are not enough sampling stations within Cape Cod Bay to determine MWRA liability in that scenario.

P. Borrelli stated that the CCS just completed a project design for a collaboration among scientists from Georgia Tech, Boston University, U. Rhode Island, and the CCS. The project is limited in scope and is based on stable nitrogen isotope tracking in which 20 CCS stations in Cape Cod Bay are sampled (locations coincide with historical right whale/zooplankton stations). Stations will be sampled every month (with two months sampled twice). MWRA data will also be studied. The CCS hopes to determine sampling methodology, locate funding, and begin sampling soon so there can be data from both before and after the outfall goes on-line. M. Mickelson feels that the CCS is well positioned to conduct this study since they have the historical record. They would do a better job of finding patches instead of the MWRA Outfall Monitoring Program since in order to find a patch, it is best to first find whales [the CCS studies whales extensively]. S. Testaverde said that NMFS would like to enter a partnership but that [funding would not be available in time for baseline measurements].

M. Mickelson pointed out that J. Montoya had said that the stable nitrogen isotope method has approximately the same sensitivity as salinity measurements and thus will not be able to track the effluent outside of the nearfield. P. Daley disagreed and thinks that this study would be worth the effort because of the potential risk to the right whales. She believes that the main purpose of the FWMSOW is not to establish blame on the MWRA but rather to help us better understand the system.

S. Testaverde asked what the latest outfall startup date was. M. Mickelson guessed March 2000 though there is no official date due to the ongoing investigation of the accident in the outfall tunnel.

Minutes from the October 1999 meeting were approved.

MEETING HANDOUTS

  • October 1999 OMSAP/PIAC/IAAC membership lists
  • May 17, 1999 draft IAAC meeting summary
  • OMSAP Charter
  • MWRA's Food Web Model Scope of Work
  • Revised IAAC Mission


ADJOURN
Summary prepared by C. Coniaris. Post-meeting comments are included in [brackets].

IAAC Meeting May 1999

Monday, May 17, 1999, 2:30-4:00 PM
New England Aquarium
FINAL MINUTES

ATTENDANCE
Members : Salvatore Testaverde, NMFS (chair); Mike Bothner, USGS; Leigh Bridges, MADMF; David Dow, NMFS alternate; Christian Krahforst, MCZM; Matt Liebman, EPA; Steve Lipman, MADEP alternate; and Anne Smrcina, Stellwagen Bank National Marine Sanctuary. All member agencies were represented at this meeting except the US Army Corps of Engineers.

Observers: Cathy Coniaris, OMSAP/PIAC/IAAC Assistant; Patty Daley, Cape Cod Commission; Mike Delaney, MWRA; Cate Doherty, Save the Harbor/Save the Bay; Glenn Haas, MADEP; Rich Masters, Normandeau; Mike Mickelson, MWRA; and Andrea Rex, MWRA.

Summary prepared by C. Coniaris. Post-meeting comments are included in [brackets].

SUMMARY OF ACTION ITEMS
IAAC members present voted to approve (1 abstain) the proposed revision to the OMSAP charter which describes the IAAC mission (see below). S. Testaverde would like to present an IAAC consensus document regarding the IAAC's OMSAP charter revisions to EPA and MADEP.

SUMMARY OF MEETING
February 24, 1999 meeting summary was approved with no amendments.

DISCUSSION OF IAAC ROLES AND MISSION
M. Liebman distributed a copy of the revisions to the OMSAP charter proposed by the IAAC subcommittee (S. Testaverde, L. Bridges and M. Liebman). The subcommittee took into consideration comments from G. Haas and S. Lipman. [G. Haas and S. Lipman had suggested the following IAAC mission: "(1) At OMSAP's request, IAAC will provide guidance on, and interpretation to, regulatory, procedural issues/questions related to operation of the POTW and Outfall. (2) IAAC will review/discuss OMSAP proposals and if deemed appropriate indicate to OMSAP and EPA/DEP/MWRA how, and if, the proposal complies and interacts with regulatory and resource mandates of the agencies represented on the IAAC. (3) Should the occasion arise, IAAC may independently request to OMSAP specific issues for them to address." They also suggested the following addition to the OMSAP/PIAC/IAAC protocol: "(1) IAAC should meet within a month following the OMSAP meeting if, as a result of the OMSAP meeting, there is something they need to deal with. (2) IAAC membership should be limited to federal and state agencies that have regulatory authority related to the POTW and/or outfall."]

IAAC discussed the proposed revisions to the OMSAP charter. Most IAAC members agreed that in addition to advising OMSAP, IAAC should also advise EPA and MADEP. IAAC agreed that its membership should only include state and federal agencies, though there was no agreement as to whether the Cape Cod Commission should join IAAC or remain on PIAC.

The IAAC reached a consensus, but did not vote on, the following comments regarding the OMSAP charter:

  1. "Membership of the PIAC and IAAC shall rotate among organizations." Comment: clarify or delete this sentence since agencies involved with the Boston Harbor Project should maintain representation on the IAAC.
  2. "OMSAP membership eligibility may include agencies that are not responsible for making direct regulatory decisions." Comment: delete this sentence. OMSAP membership should only be comprised of independent scientists. However, the group decided to only propose changes to sections of the OMSAP charter pertaining to IAAC.
  3. "Members of OMSAP, PIAC, and IAAC who do not attend meetings on a regular basis may be replaced by the EPA Regional Administrator and the Massachusetts Commissioner, if the Chair of the OMSAP recommends such action." Comment: instead of describing method of replacement in the charter, it should be in the protocol, i.e. delete the second half of the sentence.

D. Dow suggested adding a description of how particular agencies represented on IAAC are chosen by EPA/MADEP to the charter. C. Doherty asked how changes to the OMSAP charter can occur if the document will be attached to the permit which will be issued on May 20. She asked that EPA/MADEP provide a time line of how to request changes to attachments to the permit.

ACTION:
In part C of the membership section of the OMSAP charter, IAAC members voted to approve (S. Lipman abstained) the following proposed change: Current charter language: "The committee will advise the OMSAP on environmental regulations." Proposed change: "The committee will advise the OMSAP, EPA and MADEP on scientific, technical and/or regulatory matters related to discharges from and operations of the MWRA system outfalls that may directly or indirectly affect Boston Harbor, Massachusetts Bay, and Cape Cod Bay. The IAAC may review or evaluate other environmental matters as necessary."

G. Haas disagreed with this proposed revision since OMSAP is the group that advises EPA/MADEP on scientific and technical issues. He also pointed out that IAAC includes representation from EPA and MADEP and thus does not have to formally advise those agencies.

OMSAP PUBLIC WORKSHOP
C. Coniaris updated the group on the approach for the OMSAP public workshop. The workshop will be relatively technical in order to describe monitoring results as well as answer questions from the public. The meeting will be open to the public, and a summary paper will be drafted and widely distributed. IAAC agreed with this approach. D. Dow and M. Bothner like the idea of having a poster session during the meeting. There will be a workshop planning meeting on May 18, 1999. A. Smrcina suggested a setting up a web forum in which OMSAP or other local marine scientists are on-line at a specific time to answer questions. Then the questions and answers could be posted on the web. [UPDATE: The planning group recommends that OMSAP host a two-day technical workshop to describe the results of seven years of baseline water quality, benthic, and fish/shellfish monitoring as well as summarize the 10-year Boston Harbor Clean-up Project. This meeting will also address public concerns in preparation for a public workshop. It will be scheduled in late summer and will be open to the public. Since the outfall is scheduled to go on-line by late September, the group also suggests that OMSAP host a public workshop in September to brief citizens on monitoring and address concerns. This would be an evening event geared towards the public.]

REVIEW OF THE DRAFT AGENDA FOR THE JUNE 10 OMSAP MEETING
IAAC reviewed the draft OMSAP agenda. S. Testaverde asked about the proposed MWRA threshold revisions and M. Mickelson replied that MWRA is preparing to brief OMSAP on potential revisions to the chlorophyll, dissolved oxygen decline rate and floatables thresholds. The June 10 presentation will be a briefing and OMSAP will not be asked to deliberate on any revisions. [UPDATE: The June 10 OMSAP meeting has been cancelled due to the postponement of the Cape Cod Commission's Food Web Indicators proposal.]

FOOD WEB MODEL DISCUSSION
P. Daley stated that the Cape Cod Commission is proposing a "Food Web Indicators" approach instead of the MWRA food web model scope of work (FWMSOW). The Commission will present an overview of this approach at the June 10 OMSAP meeting. From the Commission's briefing dated May 17, 1999 to the PIAC and IAAC, "The Cape Cod Commission proposes to establish a set of indicators or thresholds to identify and track changes and trends in the Bays ecosystem with a focus on the food web of the northern right whale. [The] purpose [is] to establish a series of thresholds to identify changes and trends in the right whale food web that may not be detected by the current warning and caution threshold levels….Food Web Indicators should be established to track specific density and particle sizes of Calanus finmarchicus, the right whale's primary food source. Food Web Indicators should also be established for other species that may affect the availability of Calanus finmarchicus, such as Phaeocystis. Particular emphasis should be placed on monitoring in the spring and summer seasons. The current monitoring program establishes some caution and warning levels for phytoplankton and nuisance algae. It also looks at species mix relative to phytoplankton. However, there is no threshold for certain aspects of species diversity that impact the northern right whale…." The Commission disapproves of the FWMSOW flowchart (see MWRA handout) because if there is any uncertainty with questions raised, the flow chart "dead-ends" if no one conducts research to address the questions. The Barnstable Science Advisory Panel will meet to further develop this Food Web Indicators proposal, hopefully by the June 10 OMSAP meeting.

M. Liebman feels that the Commission is on track so far. He described background to the draft permit requirement for a FWMSOW (see handout). S. Testaverde pointed out that NMFS is looking into other research databases for information similar to what the Food Web Indicators proposal would require. M. Mickelson described MWRA's progress towards preparing a FWMSOW (see handout). Since the FWMSOW language appeared in the February 1998 draft permit, MWRA has been working in consultation with the Outfall Monitoring Task Force and the Outfall Monitoring Science Advisory Panel on this draft requirement. If the final NPDES permit includes the same language as the draft permit regarding the FWMSOW, then MWRA will submit its scope of work. M. Mickelson then described the conceptual food web model for Massachusetts and Cape Cod Bays developed by Jack Kelly et al. and the subsequent review of that food web model by OMSAP member Bob Kenney. In his review, B. Kenney pointed out that the Massachusetts Bay and Cape Cod Bay conceptual model is only a small part of the life of a right whale and that there are many other factors which affect its life history.

For a continuation of this discussion, see the May 17, 1999 PIAC meeting summary. [UPDATE: The June 10 OMSAP meeting has been cancelled. The MWRA have posted their food web model scope of work at: http://www.mwra.state.ma.us/harbor/enquad/pdf/99-09_enquad_report.pdf. The NPDES permit (page 9) states that "EPA and the MADEP, in consultation with the OMSAP discussed below, shall provide the MWRA with comments on this scope of work. Within ninety (90) days after receipt of these comments, MWRA shall submit a revised scope of work for review by OMSAP, and for approval by EPA and MADEP. After receipt of the revised scope of work, EPA and MADEP will determine whether implementation of the food web model is warranted." OMSAP will comment on the FWMSOW at its next meeting, sometime in early fall.]

WRAP-UP
S. Testaverde handed out MWRA bottom water dissolved oxygen (DO) baseline data results and a response to emergencies flowchart from the Contingency Plan. He is concerned about what the contingency measures would be in case low dissolved oxygen becomes a problem in the bottom waters around the new outfall. He discussed two suggested pathways for addressing low dissolved oxygen and distributed a handout describing one suggested pathway in which there is a revised response to a low DO event (as opposed to changing the DO threshold value). He would like to discuss this further at a future IAAC meeting.

A. Smrcina then briefly described the Sustainable Seas Expedition that will run during the first two weeks of July. The Stellwagen Bank National Marine Sanctuary will be holding an open house at the New England Aquarium on July 4-5, and will have new one-person submersibles diving in the sanctuary sometime around July 10-14.

The PCB discussion on the agenda was postponed until after the NPDES permit is issued.

ADJOURN

MEETING HANDOUTS:

  • May 1999 OMSAP/PIAC/IAAC membership lists
  • March 2, 1999 draft IAAC meeting summary
  • OMSAP charter
  • Proposed IAAC revisions to the OMSAP charter
  • June 10 draft OMSAP agenda
  • Cape Cod Commission's Food Web Indicators approach briefing
  • Background to EPA's request for a food web model scope of work briefing
  • MWRA's progress toward preparing a food web model scope of work briefing
  • MWRA Boston Harbor Project and monitoring overview packet
  • OMSAP Workshop briefing
  • Dissolved oxygen and contingency flowchart handout (from S. Testaverde)

IAAC Meeting February 1999

Wednesday, February 24, 1999, 1:00-3:30 PM
EPA Boston
FINAL MINUTES

ATTENDANCE
Members Present: Salvatore Testaverde, NMFS (chair); Mike Bothner, USGS; Leigh Bridges, MADMF; David Dow, NMFS alternate; Tom Fredette, USACE; Russell Isaac, MADEP alternate; Matt Liebman, EPA; Steve Lipman, MADEP; and Jack Schwartz, MADMF alternate.

Observers: Cathy Coniaris, OMSAP Assistant; Patty Daley, Cape Cod Commission; Mike Delaney, MWRA; Cate Doherty, Save the Harbor/Save the Bay; Marianne Farrington, New England Aquarium; Glenn Haas, MADEP; Janet Labonte, EPA; Ron Manfredonia, EPA; and Andrea Rex, MWRA.

SUMMARY OF ACTION ITEMS

  1. An ad hoc subcommittee was formed to develop the IAAC mission, discuss potential revisions to the OMSAP charter, and consider the Cape Cod Commission request to leave the Public Interest Advisory Committee to join the IAAC. Recommendations will be forwarded to IAAC. Members of this subcommittee: L. Bridges, M. Liebman, and S. Testaverde.
  2. PCBs will be discussed further at the next IAAC meeting.
  3. IAAC members present elected Sal Testaverde as chair.


SUMMARY OF MEETING
IAAC ROLES AND RESPONSIBILITIES
The draft OMSAP/PIAC/IAAC protocol was distributed. [Comments may be sent directly to C. Coniaris at [email protected] or fax: (617) 292-5696]. R. Manfredonia thanked the members for volunteering their time and then gave background on the formation of OMSAP/PIAC/IAAC. The Outfall Monitoring Task Force was reformatted into the OMSAP mainly to refocus the group so that everyone felt comfortable with the independent science being recommended to EPA/MADEP. The Public Interest Advisory Committee (PIAC) was formed to give citizens the opportunity to participate in terms of bringing forth public concerns to the OMSAP. There was then the dilemma of how to include the agency scientists in this process without introducing conflict of interest. Initially, there were two major roles for the IAAC. The first was to provide information on the responsibilities and the authorities of each agency when asked by the OMSAP (e.g. questions about the permit or the Endangered Species Act). The second involved the input of scientific perspectives. R. Manfredonia recommended the IAAC spend time commenting on the protocol since it will dictate how the three groups function. One benefit of IAAC is that agencies are in the same room in a formal forum discussing issues. G. Haas added that an important role for IAAC is to discuss OMSAP recommendations as a group since some OMSAP advice may mean changes in regulations.

The group then had a discussion about the OMSAP charter. S. Testaverde is concerned that the OMSAP charter implies that the IAAC comes under the authority of OMSAP. R. Manfredonia replied that "[IAAC] will report to the OMSAP" in the OMSAP charter does not mean that the OMSAP has authority over IAAC. S. Testaverde pointed out that within the charter, the mission of IAAC "the committee with advise the OMSAP on environmental regulations" is very narrow. L. Bridges thinks that the IAAC relationship with OMSAP be a two-way street. IAAC should be independent enough to provide information on issues that OMSAP may not be considering. R. Isaac reminded the group that not every issue can go to OMSAP since they are a finite resource. J. Schwartz suggested that the protocol include that IAAC is available on an "as needed basis".

R. Manfredonia stated that the charter may be revised, but not on a whim. J. Labonte added that EPA/MADEP are planning to attach the charter to the NPDES permit as a reference document. R. Manfredonia encouraged IAAC to work with C. Coniaris to try and develop IAAC's roles, responsibilities, protocol, decision making process, amount of involvement and add it to the draft OMSAP/PIAC/IAAC protocol. The group agreed. An ad hoc subcommittee was formed to discuss these aspects as well as discuss revisions to the OMSAP charter, and consider the Cape Cod Commission request to join the IAAC (see below). Recommendations will be forwarded to IAAC. Members of this subcommittee: L. Bridges, M. Liebman, and S. Testaverde.

MEMBERSHIP – CAPE COD COMMISSION'S REQUEST TO JOIN IAAC
P. Daley described the Cape Cod Commission's reasoning for their desire to join the IAAC instead of the PIAC. The CCC was created 10 years ago by a special act of the State legislature and is charged with protecting the resources and economy of Cape Cod by regulating development. The CCC is authorized to coordinate with federal, state, and local governments. Their jurisdiction extends three miles offshore but they do not have regulations pertaining to ocean discharges.

Several points were raised by various members and observers. The OMSAP charter limits IAAC membership to state and federal agencies. By opening membership to the CCC, other commissions would also request membership. There needs to be a limit on membership since large groups can become unproductive. Some felt that the CCC does not belong on IAAC because they do not make any regulatory decisions on the MWRA outfall permit. S. Testaverde believes that the CCC should be a member of the IAAC because they have been very involved with MWRA issues over the years. It was pointed out that the CCC has already been appointed to the PIAC and thus will continue to be involved, even if not allowed to move to the IAAC. S. Testaverde moved to allow membership of CCC. The motion failed. The ad hoc subcommittee will further address this issue.

INTRODUCTION TO ENDOCRINE DISRPUTERS (EDs)
M. Liebman briefly described EDs and how EPA is studying them. In the Food Quality Protection Act of 1996 and amendments to the Safe Drinking Water Act, EPA was mandated to form an advisory committee, the Endocrine Disruptor Screening and Testing Advisory Committee (EDSTAC). Their charge is to set up a process to screen and test the ~87,000 chemicals which may be endocrine disruptors. EDs are "exogenous chemical substances or mixtures that alter the structure or function of the endocrine [hormone] system and cause adverse effects in organisms, progeny, populations or subpopulations". PCBs, many pesticides, tributyltin (an antifoulant for boats) are examples of EDs. Since this program is in its early stages, IAAC agreed that ED monitoring in wastewater is not an issue OMSAP would have to deal with for several years.

POTENTIAL END-OF-PIPE PCB SUBCOMMITTEE
S. Testaverde requested the formation of an "End-of-Pipe PCB Committee" to educate dischargers about PCBs. MWRA stated that since PCBs are banned substances and sources are difficult to track down, they did not think there would be value in having such a group. S. Testaverde pointed out that though PCBs are banned, they are still used under very special circumstances. MWRA agreed to bring their PCB expert to the next IAAC meeting to discuss PCBs further.

ELECTION OF CHAIR
Members present elected Sal Testaverde as chair.

ADJOURN
Summary prepared by C. Coniaris.

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