161 



With regards to 2) above, the following comments recommend specific actions that would 

 strengthen the ESTM and, later, the Biological Impact Assessment The SAP has assumed based 

 on discussions with EPA that the A. D. Little analysis is for the ESTM, and not a complete 

 Biological Impact Assessment 



FINDINGS: Wrincn contributions by individual SAP members are contained in the 

 following addenda. Comments from one panelist. Dr. C. Taylor, are not included as an addenda, 

 because his cruise schedule made him unavailable for meetings and reviews of results. Following 

 is a brief listing of major points consistently raised about the Work Plan. 



• The methodology proposed by the Work Plan ignores the effects on Turtles and 

 Sturgeon. Analogous analysis must be performed for these latter two endangered species. There 

 is an inconsistency between the list of species considered for the Massachusetts Bay Disposal Site 

 and the MWRA outfall. 



• The list of endangered species ignores jxjssible impacts on birtls that feed on marine 

 organisms. Although this issue may not end up as a significant one, it should be addressed 

 formally and reasons provided for not including these species in the ESTM. Possible species to 

 consider include the Piping Plover, the Roseate Tern, and the Least Tern. 



• The hypotheses in the Work Plan are so general and unfocused as to be of litUe use for 

 the ESTM. The generality of the hypotheses makes them untestable using existing data and other 

 scientific information. For instance, a review of the hypotheses shows few if any are testable 

 based on available scientiiic data. 



• The use of threshold effects, as recommended by the Work Plan, is not appropriate for 

 an ecosystem approach. Threshold effects, while applicable perhaps for hydrocarbon analyses on 

 specific organisms (for instance), are inappropriate for polymixtures of organisms, where 

 synergism is important Little-to-no experimental data exist to evaluate threshold effects on 

 ecosystems comparable to Massachusetts Bay. 



• Sublethal effects are not adequately considered in the proposal. In particular, the 

 threshold effects, if used, must include concentrations of materials combined with the time or 

 duration of exposure. The methodology to calculate the dosages to evaluate threshold effects is not 

 provided. 



• Geoaccumulation of toxics in sediments is not discussed, nor is its possible role in the 

 food chain dynamics leading to the endangered species. Sedimentation prtx«sses must be included 

 in the analysis, though the modeling section does not indicate that this will be done. Since the 

 benthic contribution to the food chain is pertinent to at least some of the endangered species, 

 geoaccumulation should be addressed. 



• The role of the benthos in the impact assessment is not clarified. Will the role of benthos 

 as a food chain member and bio-accumulator be considered in the analysis? 



• The Woik Plan should include a discussion of the nutrient speciation as weD as nutrient 

 concentrations, as the impacts are considered. After secondary treatment the nutrients will be in a 

 different chemical form, some of which wUl be more readily available to the phytoplankton. 



• The physical model being applied by the USGS for MWRA is an excellent, state-of-the- 

 art model, applied by competent modelers. However, care must be taken in extrapolating 

 hydrodynamic results to dynamic ecosystem processes, including nutrient cycling, heavy metal 

 accumulation, and similar issues. The dynamics of the ecosystem processes including 



