vvEPA
United States
Environmental Protection
Agency
Office of Water
4303
EPA823-R-01-005
July 2001 .
  DRAFT - NATIONAL BEACH GUIDANCE
    AND PERFORMANCE CRITERIA FOR
          RECREATION WATERS

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                                                                         Table of Contents
                                   Table of Contents

Executive Summary (To be completed)

1.0    Introduction

1.1 Program and Document Overview	1-1
       1.1.1 BEACH Act	1-1
       1.1.2 How This Document Should Be Used 	1-5
       1.1.3 Organization of Document	1-5
1.2    Human Health Concerns	1-6
       1.2.1  Pathogen Groups	; • 1-6
       1.2.2  Health Concerns	 1-7
1.3    Water Quality Standards for Bacteria  ..,	< 1-10
       1.3.1  Organisms that Can Indicate Fecal Contamination	1-10
       1.3.2  EPA's Current Water Quality Criteria for Bacteria: Enterococcus and E. coli 1-10
       1.3.3  EPA's Review of Recent Epidemiological Studies	1-10
1.4    References	1-15

2.0    Grants and Performance Criteria
2.1    BEACH Act Conditions and Requirements Applicable to Section 406 Grants   	2-1
2.2  - Performance Criteria	2-3
     ,  2.2.1  Risk-based Beach Evaluation and Classification (1)	2-4
       2.2.2  Sampling Design and Monitoring Plan (2)  	2-4
       2.2.3  Monitoring Report Submission and Delegation (3)	2-5
       2.2.4  Methods and Assessment Procedures (4)	2-5
       2.2.5  Public Notification and Risk Communication Plan (5)	2-5
       2.2.6  Measures to Notify EPA and Local Governments (6)	2-5
       2.2.7  Measures to Notify the Public (7) 	2-6
       2.2.8  Notification Report Submission and Delegation (8) .	2-6
       2.2.9  Public Evaluation of Program (9)  	2-6
2.3    Additional Grant Information	2-7
       2.3.1  Grant Program Phases	2-7
       2.3.2  Eligibility for Grants			2-7
       2.3.3  Funding	,	2-8
       2.3.4  Selection Process	2-8
       2.3.5  Application Procedure	2-8
2.4    References		2-9

3.0    Risk-based Beach Evaluation and Classification Process
3.1    Performance Criterion	3-1
3.2    Step 1: Identify Recreational Waters	 . . :	3-1
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                National Beach Guidance and Grant Performance Criteria for Recreational Waters	

                       3.2.1  Designated Uses of Waterbodies	3-2
                       3.2.2  Recreational Uses of Waterbodies	3-3
                       3.2.3  Coastal Recreation Waters	.3-4
                3.3     Step 2: Identifying Bathing Beaches	3-4
                3.4     Step 3: Determining Legal Authority for Administering Monitoring and Notification
                       Programs	3-7
                3.5     Step 4: Review of Available Information	3-8
                       3.5.1  Pertinent Reports	3-8
                       3.5.2  Water Quality Monitoring and Modeling Data	 3-13
                       3.5.3  Frequency and Density of Use	3-14
                       3.5.4  Other Factors	  3-14
                3.6     Step 5: Ranking Beaches	3-15
                3.7     References  	3-18

                4.0     Beach Monitoring and Assessment
                4.1     Performance Criteria  	4-1
                4.2     Sampling Design and Monitoring Plan	4-1
                      4.2.1  Tiered Monitoring Design	 4-2
                      4.2.2  Other Elements of a Sampling and Monitoring Plan	4-4
                             4.2.2.1 Ensuring Data Quality	4-4
                             4.2.2.2 Staffing Monitoring Programs	4-5
                             4.2.2.3 Training Monitoring Staff	4-5
                             4.2.2.4 Managing Data	4-5
                             4.2.2.5 Program Implementation and Oversight 	4-7
                4.3    Monitoring Report Submission and Delegation  	4-7
                4.4    Assessment Methods and Procedures  	4-8
                      4.4.1  Laboratory Analysis	 4-8
                      4.4.2  Analytical Procedures		4-10
                      4.4.3  Recommended Sample Collection Techniques	•. .	4-12
                      4.4.4  Data Verification and Validation	4-12
                4.5    Use of Predictive Tools in Beach Monitoring Programs	4-14
                      4.5.1  Criteria for Evaluating Potential Models	4-15
                      4.5.2  Predictive Methods Currently Used		4-18
                             4.5.2.1 Rainfall-based AlertCurve  	4-19
                             4.5.2.2 Other Predictive Tools to Supplement Sampling	4-21
               4.6    References  	4-25

               5.0    Public Notification and Risk Communication
               5.1    Performance Criteria	.5-1
               5.2    Public Notification and Risk Communication Plan	5-1
                      5.2.1   Problem Assessment and Audience Identification	5-2
                      5.2.2  Content and Procedures for Public Notification	 5-3

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                                                                          Table of Contents
             5.2.2.1 Message: Developing the Content of Advisories and Closings	5-3
             5.2.2.2 Types of Notification		5-4
             5.2.2.3 Mechanisms for Disseminating Advisories and Closings	5-5
             5.2.2.4 Procedures for Notifying the Public	5-9
             5.2.2.5 Procedures for Removing Advisories and Reopening Beaches	5-10
       5.2.3  Evaluation of Notification Program's Effectiveness   	5-11
       5.2.4  . Notification Report Submission and Delegation  	5-13
5.3    References ....		5'15

Appendices

Beach Act Fact Sheet	''.	• • A
EPA's Water Quality Criteria for Bacteria	B
State and Local Programs and Nongovernmental Organizations	 C
EPA References: Statutes, Programs, and Activities Related to Recreation Waters	D
EPA Grant Coordinators  	•	 E
Beach Evaluation and Classification List ...	 F
Conducting a Sanitary Survey	-..	G
Monitoring Design Approach	•	H
Data Quality Objectives	I
Training	•*
Sample Collection	•	K
Predictive Tools	 ~
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                                                                                Chapter 1
Chapter 1: Introduction

1.1    Program and Document Overview

Coastal and shoreline development, wastewater collection and treatment facilities, septic tanks,
animal feeding operations, urban runoff, disposal of human waste from boats, and bathers
themselves all contribute to fecal contamination of our nation's recreational waters.  People who
swim and recreate in water contaminated with fecal pollution are at an increased risk of
contracting gastrointestinal disease; respiratory, ear, eye, and skin infections; meningitis; and
hepatitis (Rose et al., 1999).

In response to these concerns, the U.S. Environmental Protection Agency (EPA) announced its
BEACH Program in 1997. The goal of the program is to assist in reducing the risk of disease to
users of U.S. recreation waters by focusing on several key objectives:

1.  Strengthening water quality standards for bathing beaches
2.  Improving state and local government beach programs
3.  Better informing the public
4.  Promoting scientific research to better protect the health of public beach users.

Initial efforts focused on current water quality standards, improving our understanding of current,
state and local programs through national and local conferences, and identifying scientific needs.
EPA also started its annual voluntary survey of state and local agencies that monitor water
quality at beaches. The National Health Protection Survey of Beaches collected information
about which local beaches are monitored and what agencies are responsible for beach programs,
as well as detailed information about advisories and closures at specific beaches. In March 1999
EPA published the Action Plan for Beaches and Recreational Waters (Beach Action Plan), a
multiyear strategy that describes the Agency's programmatic and scientific research efforts to
improve beach programs and research. It was published jointly by EPA's Office of Water and
Office of Research and Development (ORD) and can be accessed at
www.epa.gov/ORDAVebPubs/final/ on the Internet. Printed copies of the document (EPA 600-
R-98-079) can be ordered through the National Service Center for Environmental Publications
(NSCEP), on the Internet at www.epa.gov/ncepi or by telephone at 1-800-490-9198.
1.1.1
BEACH Act
Provisions of the Act

The scope of activities related to managing recreational water quality was changed with the
passage of the Beaches Environmental Assessment and Coastal Health Act (BEACH Act). The
act was passed on October 10, 2000, and amended the Clean Water Act (CWA) to include
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters	

 section 406. The BEACH Act addresses fecal contamination in coastal recreation waters. It
 contains three significant provisions, summarized as follows:

 1.  The BEACH Act amended the CWA to include section 303(i), which requires states that
    have coastal recreation waters to adopt new or revised water quality standards by April 10,
    2004 for pathogens and pathogen indicators for which EPA has published criteria under
    CWA section 304(a). The BEACH Act amendments further direct EPA to promulgate such
    standards for states that fail to do so.

 2.  The BEACH Act amended the CWA to require EPA to study issues associated with
    pathogens and human health and by 2005, to publish new or revised CWA section 304(a)
    criteria for pathogens and pathogen indicators based on that study. Within 3 years after EPA's
    publication of the new or revised section 304(a) criteria, states that have coastal recreation
    waters must then adopt new or revised water quality standards for all pathogens and pathogen
    indicators to which EPA's new or revised section 304(a) criteria apply.
                                                            BEACH Act Time Line
The BEACH Act amended the CWA to include a new section, section 406, which authorizes
EPA to award grants to states for the purpose of developing and implementing a program to
monitor, for pathogens and pathogen indicators, coastal recreation waters adjacent to beaches
that are used by the public and to notify the public if water quality standards for pathogens
and pathogen indicators are exceeded.  To be eligible for the implementation grants, the
states must develop monitoring and notification
programs that are consistent with performance
criteria published by EPA under the act. The
BEACH Act also requires EPA to perform
monitoring and notification activities for waters
in states that do not have a program consistent
with EPA's performance criteria, using grants
funds that would otherwise have been available
to those states. A Fact Sheet about the BEACH
Act is included as Appendix A.  A complete copy
of the BEACH Act can be found at
http://www.epa.gov/OST/beaches/technical.html
Time Line

Figure 1-1 outlines a BEACH Act time line for EPA,
states and local governments.
Section 303(i)(l)(A) of the CWA, as amended by the
BEACH Act, requires states that have coastal
recreation waters to adopt new or revised water
                                                     Development Grants
                                                     announced - Applications
                                                     due July 30, 2001.
                                                     Beach Guidance document .
                                                     finalized (Fall 2000).
                                                     Local governments able
                                                     to apply for implementation
                                                     grants if a state has not   ~
                                                     applied.
                                                 EPA proposes water quality
                                                 standards for states that did
                                                 not adopt 1986 Criteria.
                                                                           . BEACH Act enacted
                                                                            October 2000.
                                                                           Beach Guidance document
                                                                           released for public comment
                                                                           (July 2000).
                                                                          . Implementation Grants
                                                                           available.
                                                                       Deadline for states to adopt
                                                                       1986 criteria or criteria"'as
                                                                       protective as' (April 2004).
                                                                      . EPA publishes new water
                                                                      quality guidance (2005).
                                                 Figure 1-1. BEACH Act time line.
1-2
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                                                                                 Chapter 1
 quality standards for pathogens and pathogen indicators for which EPA has published criteria
 under CWA section 304(a). Under the statute, states must adopt these new or revised standards
 by April 10,2004. If a state fails to adopt water quality criteria and standards in accordance with
 EPA's 1986 criteria or criteria that are as protective of human health as the criteria for pathogens
 and pathogen indicators, EPA will propose regulations for the state setting forth revised or new
 water quality standards for pathogens and pathogen indicators for the coastal recreation waters of
 the state.
   For the purposes of this document, recreation water
   use will be referred to as 'bathing" and "swimming."
1.1.2  How This Document Should Be Used
                                               This document has three functions. First, it
                                               constitutes performance criteria for (a)
                                               monitoring and assessment of coastal
                                               recreation waters adjacent to beaches (or
                                               similar points of access that are used by the
                                               public) for attainment of applicable water
quality standards for pathogens and pathogen indicators; and (b) the prompt public notification of
any exceedance or likelihood of exceedance of applicable water quality standards for pathogens
and pathogen indicators for coastal recreation waters. EPA is required to publish such
performance criteria under section 406(a). Section 406(b) authorizes EPA to award grants to
states and tribes to implement a monitoring and notification program, but only if the program
meets certain requirements (See 406(b)(2)(A)(i)-(v)).  One  of these requirements is that the
monitoring and notification program is consistent with EPA's performance criteria.  Excerpts
from section 406(b)(2)(A) are included in Chapter 2.

Second, this document explains how EPA will evaluate grant applications from states and tribes
when deciding whether to award monitoring and notification program implementation grants
under section 406(b). This document is intended to be used by potential grant recipients to
implement effective programs for monitoring and assessing coastal recreation waters. The next
four chapters  outline the performance criteria by which EPA will evaluate monitoring and
notification programs to determine whether they are consistent with EPAs performance criteria.

Third, this guidance is intended to promote consistency among states, tribes and localities by
recommending standard approaches for recreational water quality programs.  The document will
assist local health departments, water quality managers, beach managers, and other local, state,
and tribal agencies to

•   Improve microbial water quality monitoring programs for more consistent protection of
   coastal recreation waters.
   Assess,  manage, and communicate health risks from waterborne microbial contamination.
•   Notify the public of beach advisories and implement closings to help prevent public exposure
   to potentially harmful pathogens.
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters	    '	

 The document can also serve as a reference guide for how and when to conduct preliminary
 beach assessments, because it includes protocols for water sample collection, sample handling,
 and laboratory analysis. It provides information about the use of predictive models to estimate
 indicator levels and includes procedures for public notification about beach advisories, closings,
 and openings.

 1.1.3   Organization of Document

 The chapters in this document cover the following topics:

 •   Chapter 1 discusses human health concerns and discusses the establishment of water quality
    standards for bacteria.
 •   Chapter 2 addresses the basic requirements that an applicant must meet to receive a program
    implementation grant.  The chapter identifies relevant sections of the BEACH Act, briefly
    describes the corresponding performance criteria that EPA has developed, and provides
    additional grant-related information.
 •   Chapter 3 describes the risk-based evaluation process that EPA recommends for states and
    tribes to classify and prioritize their recreational beaches.  This step-by-step approach allows
    states and tribes to assess the relative human health risks and usage of their beaches and
    assign an appropriate management priority to each of them.
 •   Chapter 4 describes the performance criteria related to monitoring and assessment and
    provides detailed technical guidance.
 •   Chapter 5 describes the performance criteria and technical guidance related to the public
    notification and risk communication portions of a beach program.

 The appendices include detailed technical information associated with the topics discussed in the
 five chapters:

 •   Appendix A: Beach Act Fact Sheet
 •   Appendix B: EPA's Water Quality Criteria for Bacteria
 •   Appendix C: State and Local Programs and Nongovernmental Organizations
 •   Appendix D: EPA References: Statutes, Programs, and Activities Related to Recreation
    Waters
 •   Appendix E: EPA Grant Coordinators
 •   Appendix F: Beach Evaluation and Classification List
 •   Appendix G: Conducting a Sanitary Survey
 •   Appendix H: Monitoring Design Approach
 •   Appendix I: Data Quality Objectives
•   Appendix J: Training
•   Appendix K: Sample Collection
•   Appendix L: Predictive Tools
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                                                                                 Chapter 1
1.2    Human Health Concerns

1.2.1  Pathogen Groups

Pathogens are defined as disease-causing microorganisms. Microorganisms are ever present in
all terrestrial and aquatic ecosystems. Many types are beneficial, functioning as agents for
chemical decomposition, as food sources for larger animals, and as essential components of the
nitrogen cycle and other biogeochemical cycles.  Some microorganisms reside in the bodies of
animals and aid in the digestion of food; others are used for medical purposes such as providing
antibiotics. The small subset of microorganisms that cause human diseases are known as human
pathogens. If taken into the body, pathogens can cause sickness or even death. The source of
these microorganisms is usually the feces of humans and other various warm-blooded animals.
The pathogens most commonly identified and associated with waterborrie diseases can be
grouped into the three general categories: bacteria, protozoans, and viruses.

Bacteria are unicellular organisms that lack an organized nucleus and contain no chlorophyll.
They contain a single strand of DNA and typically reproduce by binary fission, during which a
single cell divides to form two new cells. Waste from warm-blooded animals is a source for
many types of bacteria found in waterbodies, including the coliform group and streptococcus,
lactobacillus, staphylococcus, and clostridia. It is important to note, however, that not all
bacteria are pathogenic.

Protozoans are unicellular organisms that reproduce by fission and occur primarily in the aquatic
environment. Pathogenic protozoans constitute almost 30 percent of the 35,000 known species
of protozoans. Pathogenic protozoans exist in the environment as  cysts that hatch, grow, and
multiply after ingestion, causing associated illness.  Encystation of protozoans facilitates their
survival, protecting them from harsh conditions such as high temperature and salinity. Two
protozoans of major concern as waterborne pathogens are Giardia lamblia and Cryptosporidium
parvum.

Viruses are a group of infectious agents that require a host in which to live. They are composed
of highly organized sequences of nucleic acids—either DNA or RNA, depending on the virus.
The most significant virus group affecting water quality and human health originates in the
gastrointestinal tract of infected animals. These enteric viruses are excreted in feces and include
hepatitis A, rotaviruses, Norwalk-type viruses, adenoviruses, enteroviruses, and reoviruses.

1.2.2  Human Health Concerns

The main route of exposure to disease-causing organisms in recreational beach waters is through
contact with polluted water while swimming, including accidental ingestion of contaminated
water.  In waters containing fecal contamination, potentially all of the waterborne diseases that
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters	.	

 are spread by the fecal-oral route could be contracted by bathers.  These illnesses include diseases
 resulting from the following:

 •   Bacterial infection (such as cholera, salmonellosis, shigellosis, and gastroenteritis).
 •   Viral infection (such as infectious hepatitis, gastroenteritis, and intestinal diseases caused by
    enteroviruses).
 •   Protozoan infections (such as amoebic dysentery and giardiasis).

 Swimming in contaminated water most frequently causes gastroenteritis. Gastroenteritis is a
 term for a variety of diseases that affect the gastrointestinal tract;  symptoms include vomiting,
 diarrhea, stomachache, nausea, headache, and fever.

 Although bathing in contaminated water most often results in contracting diseases that affect the
 gastrointestinal tract, diseases and conditions affecting the eye, ear, skin, and upper respiratory
 tract can be contracted as well.  With these conditions, infection often results when pathogenic
 microorganisms come into contact with small breaks and tears in  the skin or ruptures in delicate
 membranes in the ear or nose resulting from the trauma associated with diving into the water.
 Table 1-1 provides a list of diseases and conditions that can result from contact with water
 contaminated with bacterial, viral, and protozoan pathogens.

 People who contract diseases as a result of bathing in contaminated water do not always  associate
 their illness symptoms with swimming. As a result, disease outbreaks often are inconsistently
 reported. Because the incidence of diseases among bathers is often difficult to determine, several
 studies have been conducted in an attempt to establish a link between the concentration of
 indicators of fecal contamination in bathing waters and the incidence of swimming-associated
 disease symptoms.

 EPA began to study the relationship between the quality of bathing water and the resultant health
 effects in 1972.  Studies in the 1970s and 1980s examined the differences in symptomatic illness
 between swimming and non-swimming beachgoers at marine and freshwater bathing beaches.
 The studies found the following (USEPA,  1999a):

 •  Swimmers that bathe in water contaminated with sewage are at greater risk than non-
   swimmers of contracting gastroenteritis.
 •  The swimming-associated illness rate increases as the quality of the bathing water degrades.
 •  The illness rate in marine swimmers is  greater than that in freshwater swimmers when
   indicator densities are equivalent in marine and fresh waters.

In 1995 researchers launched a, large-scale  study in the Santa Monica Bay area to assess (1) the
effectiveness  of bacterial indicators in predicting health risks to bathers and (2) the relative health
risk associated with bathing near storm drains.  In this study, approximately 15,000 beachgoers
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                                                                                  Chanter 1
 that bathed and immersed their heads were interviewed. Approximately 13,000 of the
 beachgoers were contacted for follow-up interviews designed to assess the occurrence of
 symptoms such as fever, chills, nausea, and diarrhea.  The major findings of the study suggest
 that there is a significant correlation between swimming in water with high densities of indicator
 bacteria and the incidence of adverse health effects. In addition, the study confirmed that people
 who swim in front of flowing storm drains are twice as likely to exhibit adverse health effects
 than people who swim 400 yards away from storm drains (Haile et al., 1996).
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters
 Table 1-1. Waterborne Pathogens
Pathogen
Bacteria
Protozoans
Viruses


Escherichia coli
(enteropathogenic)
Helicobacter pylori
Legionella pneumophila
Leptospira
Pseudomonas
Salmonella typhi
Salmonella
Shigella
Vibrio cholerae
Yersinia enterolitica
Balantidium coli
Cryptosporidium
Entamoeba histolytica
Giardia lambia
Naegleria fowleri
Adenovirus (3 1 types)
Astroviruses
Enterovirus (67 types,
e.g., polio, echo, and
Coxsackie viruses)
Disease
Gastroenteritis
Gastritis
Legionellosis
Leptospirosis
Causes infections in
immunocompomised
individuals
Typhoid fever
Salmonellosis
Shigellosis
Cholera
Yersinosis
Balantidiasis
Crypotosporidiosis
Ameobiasis (amoebic
dysentery)
Giardiasis
Amebic
meningoencephalitis
Respiratory disease
Gastroenteritis
Gastroenteritis
Effects
Vomiting, diarrhea, death in susceptible populations
Peptic ulcers
Acute respiratory illness
Jaundice, fever (Weil's disease)
Urinary tract infections, respiratory system
infections, dermatitis, soft tissue infections,
bacteremia and a variety of systemic infections
High fever, diarrhea, ulceration of the small
intestine
Diarrhea, dehydration
Bacillary dysentery
Extremely heavy diarrhea, dehydration
Diarrhea
Diarrhea, dysentery
Diarrhea
Prolonged diarrhea with bleeding, abscesses of the
liver and small intestine
Mild to severe diarrhea, nausea, indigestion
Fatal disease; inflammation of the brain
Eye infections, diarrhea
Vomiting, diarrhea
Heart anomalies, meningitis
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                                                                                            Chanter 1
Pathogen

Hepatitis A and E
Norwalk- and Sapporo-
like viruses
Reovirus
Rotavirus
Disease
Infectious hepatitis
Gastroenteritis
Gastroenteritis
Gastroenteritis
Effects .
Jaundice, fever
Vomiting, diarrhea
Vomiting, diarrhea
Vomiting, diarrhea
Source: USEPA, 2001.
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A review of studies conducted during the past several decades have provided the following
overall conclusions (Pruss, 1998):

•   A causal dose-response relationship exists between bacterial indicator counts in recreational
    waters and gastrointestinal symptoms in bathers.

•   A strong relationship between bacterial indicator counts and symptoms not related to the
    gastrointestinal tract could not be established.

•   The relative risk of swimming in contaminated versus uncontaminated waters ranged from
    one to three times above the risk associated with swimming in uncontaminated water.

•   Symptom rates were usually higher in individuals with compromised immune systems.

•   The indicators showing the best correlation with adverse health effects were enterococci.
    (marine and fresh water) and Escherichia coli (fresh water).

1.3    Water Quality Standards for Bacteria

Water quality standards define a use(s) for a waterbody-such as primary contact recreation-and
set specific water quality criteria to achieve that use.  They are the foundation of the nation's
water quality management program and are the goals by which success is ultimately measured for
a given waterbody or watershed.

Because it is difficult to directly detect many pathogens or parasites that may be present in
surface waters, the presence of fecal bacteria has long been used as an indicator of the possible
presence of disease causing organisms.  Section 304(a)(l) of the CWA requires the
Administrator of EPA to publish criteria for water quality that accurately reflect the latest
scientific knowledge on the kind and extent of all identifiable effects on health and welfare that
may be expected from the presence of a pollutant in any body of water. Under EPAs regulations
at 40 CFR 131.11 (b), when a state or tribe is adopting water quality criteria as part of its water
quality standards, the state or tribe has three options:

•       adopt EPA's section 304(a) criteria,
•       adopt 304(a) criteria modified to reflect site-specific conditions, or
•       adopt criteria based on other scientifically defensible methods.

In addition, the BEACH Act amended CWA section 303(i) to require states and tribes to adopt
water quality criteria that are "as protective as human health as the criteria for pathogens and
pathogen indicators for coastal recreation waters published by the EPA."
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                                                                                   Chanter 1
1.3.1 Organisms That Can Indicate Fecal Contamination
Because many pathogens are not easily detected, indicator organisms are a fundamental
monitoring tool used to measure both changes in environmental (water) quality or conditions and
the potential presence of hard-to-detect target pathogenic organisms. An indicator organism
provides evidence of the presence or absence of a pathogenic organism surviving under similar
physical, chemical, and nutrient conditions.  For fecal contamination, indicator organisms should

•  Be easily detected using simple laboratory tests.

•  Generally not be present in unpolluted waters.

•  Appear in concentrations that can be correlated with the extent of contamination.

•  Have a die-off rate that is not faster than the die-off rate of the pathogens of concern (Sloat
   and Ziel,  1992; Thomann and Mueller, 1987).

Figure 1-3 provides a summary of the relationships between bacterial indicator organisms for
fecal contamination.
                                    Indicator Organisms
                                                 Fecal S treptococci


F ecal Coliform
B acte ria



E nte rococcl



Streptococcus
bo vis
\
S f re p to coccus
e q u ;n u s


S f re pfo coccus
avium
            Escherichia colt
                     S freptococcus
                        faecalis
S treptococcus
  foecium
          Figure 1-3. Relationship between bacterial indicator organisms for fecal contamination.
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National Beach Guidance and Grant Performance Criteria for Recreational Waters	

1.3.2 EPA's Current Water Quality Criteria for Bacteria: Enterococcus and 'E. coll

In 1986 EPA published Ambient Water Quality Criteria for Bacteria -1986, which
recommended the use of E. coli and enterococci as water quality criteria for bacteria.  In this
document, EPA recommended that the water quality criteria be based on bacterial geometric
mean densities and maximum single-sample bacteria density criteria not to be exceeded in
marine and fresh recreational waters. These criteria are summarized in Table 1-2. Additional
information on EPA's criteria is provided in Appendix B.

Table 1-2. Criteria for Indicators for Bacteriological Densities







State
Geometric
Mean
Indicator
Density
Single Sample Maximum Allowable Density

Designated
Beach Area
(upper 75%
C.L.)
Moderate Full
Body Contact
Recreation
(upper 82%
C.L.)

Lightly Used Full
Body Contact
Recreation (upper
90% C.L.)
Infrequently Used
Full Body
Contact
Recreation (upper
95% C.L.)
Freshwater1
enterococci
E. coli
33
126
61
235
89
298
108
406
151
576
Marine Water2
enterococci
35
104
158
276
500
1 Freshwater densities based on a risk of 8 swimmers per thousand.
1 Marine water densities based on a risk of 19 swimmers per thousand.
Source: USEPA 1986.

Section 303(i)(l)(A) of the CWA, as amended by the BEACH Act, requires states and tribes that
have coastal recreation waters to adopt new or revised water quality standards for pathogens and
pathogen indicators for which EPA has published criteria under CWA section 304(a). As rioted
above, EPA has published 304(a) water quality criteria for enterococcus and E. coli, but not for
fecal coliform. Under the statute, states and tribes must adopt these new or revised standards by
April 10, 2004.

Geometric means
The 304(a) geometric mean values recommended in Ambient Water Quality Criteria for Bacteria
-1986 and summarized in Table 1-2, are based on specific levels of risk of acute gastrointestinal
illness of no more than 8 illnesses per 1,000 swimmers for fresh waters and no more than 19
illnesses per 1,000 swimmers for marine waters (USEPA, 1986). EPA has determined that, when
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                                                                                Chapter 1
these water quality criteria are implemented in a conservative manner, they are protective for
prevention of gastrointestinal illness resulting from primary contact recreation. Appendix B
provides additional information on the equations EPA used to calculate the geometric mean
values.

Single sample maximums
In addition to the geometric mean density values,  Water Quality Criteria for Bacteria —1986 also
recommended single sample bacteria density criteria for enterococci and E. coli not to be
exceeded in marine and fresh waters. Use of a single-sample maximum is important because it is
assumed that environmental conditions (such as rainfall, wind, currents (including tides), and
temperature) will vary temporally and spatially. These single sample maximums, summarized in
Table 1-2, are also based on specific levels of risk of acute gastrointestinal illness of no more
than 8 illnesses per 1,000 swimmers for fresh waters and no more than 19 illnesses per 1,000
swimmers for marine waters.

The single-sample density values were based on four levels of water use: designated beach area,
moderate full body contact recreation, lightly used full body contact recreation, and infrequently
used full body contact recreation.  Confidence intervals were assigned to each of these levels of
use,, which were then used to calculate the density value for that use and indicator. For example,
a smaller confidence level (75 percent) corresponds to a more stringent (lower) single-sample
maximum, whereas a greater confidence level (95 percent) corresponds to less stringent (higher)
maximum values (USEPA, 1986). EPA assigned a more stringent single-sample maximum to
designated bathing beaches because a high degree of caution should be used to evaluate water
quality for heavy-use areas (USEPA,  1986) -while a less stringent single-sample maximum can be
used for less intensively used or more remote swimming areas. Appendix B provides additional
information on the equations EPA used to calculate the single sample maximum values.

1.3.3 EPA's Review of Recent Epidemiological Studies

Since the publication of EPA's 1986 criteria, a number of studies related to bacterial indicators
have been completed. Therefore,  EPA reviewed relevant recent studies to determine whether the
studies continued to support EPA's recommendation to use E. coli and enterococci as bacterial
water quality indicators. EPA's review focused on the epidemiological studies that related
swimming-associated health effects to marine and freshwater bacterial water quality using
studies performed after  1984. The reviewers searched for evidence that  quantitatively proved
that better and more predictive indicator bacteria or more protective water quality levels exist.

EPA's Office of Research and Development (ORD) concluded that

       The epidemiological studies conducted since 1984, which examined the
       relationships between water quality and swimming-associated health effects, have
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters	

        not established any new or unique principles that might significantly affect the
        current guidance EPA recommends for maintaining the microbiological safety of
        marine and freshwater bathing beaches. Many of the studies have, in fact,
        confirmed and validated the findings of the U.S. EPA studies. There would
        appear to be no good reason for modifying the Agency's current guidance for
        recreational waters at this time (Dufour, 1999).

 The new studies added an additional body of evidence that supports EPA's 1986 criteria. As a
 result of this examination, EPA determined that its 1986 water quality criteria for bacteria
 continue to represent the best available science and serve as a defensible foundation for
 protecting public health-in recreational waters. EPA found no reason to undertake a revision of
 the criteria at that time (USEPA, 2000). Additional information on these studies can be found in
 Appendix B.
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                                                                               Chapter 1
1.3    References

Dufour, A.P. 1999. Memo from A. Dufour to Elizabeth Sutherland, Acting Director, Standards
and Applied Science Division, USEPA Office of Science and Technology.

Haile, R. 1996. A Health Effects Study of Swimmers in Santa Monica Bay. Santa Monica Bay
Restoration Project, Monterey Park, CA.

Pruss, A. 1998.  Review of epidemiological studies on health effects from exposure to
recreational water.  InternationalJournal of Epidemiology 27(1): 1-9.

Rose, J.B., R.M. Atlas, C.P. Gerba, M.J.R. Gilchrist, M.W. LeChevallier, M.D. Sobsey, M.V.
Yates, G.H. Cassell, and J.M. Tiedje.  1999. Microbial Pollutants in Our Nation's Water:
Environmental and Public Health Issues. American Society for Microbiology, Washington, DC.

Sloat, S., and C. Ziel. 1992. The Use  of Indicator Organisms to Assess Public Water Safety.
Hach Company, Loveland, CO.

USEPA. 1986. Ambient Water Quality Criteria for Bacteria -1986. U.S. Environmental
Protection Agency, Office of Research and Development, Microbiology and Toxicology Division
and Office of Water Regulations and Standards, Criteria and Standards Division, Washington,
DC.

USEPA. 1999a. Action Plan for Beaches and Recreational  Waters. EPA/600/R-98/079. U. S.
Environmental Protection Agency, Office of Research and Development, and Office of Water,
Washington, DC.

USEPA. 2000. Implementation Guidance for Ambient Water Quality Criteria for Bacteria
-1986. Draft. January 2000. EPA-823-D-00-001. U.S. Environmental Protection Agency, Office
of Water, Washington, DC.

USEPA. 2001. Protocol for Developing Pathogen TMDLs. January 2001.  EPA-84-R-00-002.
U.S. Environmental Protection Agency,  Office of Water, Washington, DC.
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                                                                                  Chapter?
Chapter 2: Grants and Performance Criteria

This chapter addresses the basic requirements that an applicant must meet to receive a program
implementation grant. The chapter identifies relevant sections of the BEACH Act, briefly
describes the corresponding Performance Criteria that EPA has developed, and provides
additional grant-related information.

2.1    BEACH Act Conditions and Requirements Applicable to Section 406 Grants

The BEACH Act establishes a series of conditions and requirements related to grants for
developing and implementing a BEACH monitoring and notification program. Some of these
conditions,and requirements apply to all grants awarded under section 406; others apply only to a
subset of grants (e.g., implementation grants or grants to states and tribes). Section 406(c), which
addresses Content of Local Programs, applies to all grants awarded to states under the authority
of section 406 whether the grant is for development or implementation of a beach monitoring
program.. Section 406 (b)(3)(A), which adresses Reporting, applies to all development and
implementation grants awarded to states and tribes under the authority of section 406.  Section
406(b)(3)(B), which addresses delegation to local governments, applies to development and
implementation grants awarded to states only.  The requirements set forth at 406(b)(2)(A), which
addresses General Requirements, apply only to implementation grants to states, tribes,  and local
governments. Sections 406(a), (b), and (c) have been reproduced below:

•   Section 406 (a) Monitoring and Notification

    (1)...the Administrator shall publish performance criteria for -
       (A) monitoring and assessment (including specifying available methods for monitoring) of coastal
       recreation waters adjacent to beaches or similar points of access that are used by the  public for
       attainment of applicable water quality standards for pathogens and pathogen indicators; and

       (B) the prompt notification of the public, local governments, and the Administrator of any
       exceeding, or likelihood of exceeding, applicable coastal recreation water quality standards
       described in subparagraph (A).

•   Section 406(b) Program Development and  Implementation Grants

    (1) IN GENERAL.—The Administrator may make grants to States and local governments to develop
    and implement programs for monitoring and notification for coastal recreation waters adjacent to
    beaches or similar points of access that are used by the public.
                                                                                 /
    (2)(A) In General- The Administrator may make grants to States and local governments to implement
    a monitoring and notification program if-

       (i) the program is consistent with the performance criteria published by the Administrator under
       subsection (a);
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters	

         (ii) the State or local government prioritizes the use of grant funds for particular coastal recreation
         waters based on the use of the water and the risk to human health presented by pathogens or
         pathogen indicators;

         (iii) the State or local government makes available to the Administrator the factors used to
         prioritize the use of funds under clause (ii);

         (iv) The State or local government provides a list of discrete areas of coastal recreation waters
        that are subject to the program for monitoring and notification for which the grant is provided that
        specifies any coastal recreation waters for which fiscal constraints will prevent consistency with
        the performance criteria under subsection (a); and

        (v) the public is provided an opportunity to review the program through a process that provides for
        public notice and an opportunity for comment.

    (2)(B) Grants to Local Governments - The Administrator may make a grant to a local  government
    under this subsection for implementation of a monitoring and notification program only if, after the 1-
    year beginning on the date of publication of performance criteria under subsection (a)(1), the
    Administrator determines that the State is not implementing a program that meets the requirements of
    this subsection, regardless of whether the State has received a grant under this subsection.

    (3) Other Requirements

        (A) REPORT - A State recipient of a grant under this subsection shall submit to the Administrator,
        in such format and at such intervals as the Administrator determines to be appropriate,  a report
        that describes -

        (i) data collected as part of the program for monitoring and notification as described in
        subsection (c); and

        (ii) actions taken to notify the public when water quality standards are exceeded.

        (B) DELEGATION-A State recipient of a grant under this subsection shall identify each local
        government to which the State has delegated or intends to delegate responsibility for
        implementing a monitoring and notification program consistent with the performance criteria under
       subsection (a).

•   Section 406(c) Content of State and Local Government Programs-

       As a condition of receipt of a grant under subsection (b), a State or local government
       program shall identify:

       1.  lists of coastal recreation waters in the State, including coastal recreation waters
           adjacent to beaches or similar points of access that are used by the public;

       2.  in the case of a State program for monitoring and notification, the process by which
           the State may delegate to local governments responsibility for implementing the
           monitoring and notification program;

       3.  the frequency and location of monitoring  and assessment of coastal recreation waters

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                                                                                     Chanter 2
          based on-
          (A) the periods of recreational use of the waters;
          (B) the nature and extent of use during certain periods;
          (C) the proximity of the waters to known point sources and nonpoint sources of
          pollution; and
          (D) any effect of storm events on the waters;

      4.  (A) the methods to be used for detecting levels of pathogens and pathogen indicators
          that are harmful to human health; and
          (B) the assessment procedures for identifying short-term increases in pathogens and
          pathogen indicators that are harmful to human health in coastal recreation waters
          (including increases in 'relation to storm events);

      5.  measures for prompt communication of the occurrence, nature, location, pollutants
          involved, and extent of any exceeding of, or likelihood of exceeding, applicable water
          quality standards for pathogens and pathogen indicators to-
          (A) the Administrator in such form as the Administrator determines to be appropriate;
          and
          (B) a designated official of the local government having jurisdiction over land adjoining
          the coastal recreation waters for which the failure to meet applicable standards is
          identified;

       6.  measures for the posting of signs at beaches or similar points of access, or
          functionally equivalent communication measures that are sufficient to give notice to
          the public that the coastal recreation waters are not meeting or are not expected to
          meet applicable water quality standards for pathogens and pathogen indicators; and

       7.  measures that inform the public of the potential risks associated with water contact
          activities in the coastal recreation waters that do not meet applicable water quality
          standards.
2.2    Performance Criteria

EPA has developed nine performance criteria for monitoring, assessment, and notification by the
agencies of federal agency, state, tribal, or local government. In order to be eligible for a grant to
implement a monitoring and notification program, the applicant's program must be consistent
with these performance criteria. These performance criteria are based on and incorporate
requirements of the sections of the BEACH Act provided above. The criteria are listed in Table
2-1 and summarized in sections 2.2.1 through 2.2.9. More detailed discussions are provided in
subsequent chapters.
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters
Table 2-1. Summary of BEACH Act Performance Criteria
Category
Evaluation and
Classification
Monitoring
Public
Notification and
Prompt Risk
Communication

Public Evaluation
Performance
Criteria
1
2
.' 3
4
5
6
7
8
9
Requirement
Risk-based Beach Evaluation and
Classification
Sampling Design and Monitoring
Implementation Plan
Monitoring Report Submission and
Delegation
Methods and Assessment
Procedures
Public Notification and Risk
Communication Plan
Measures to Notify EPA and Local
Governments
Measures to Notify the Public
Notification Report Submission and
Delegation
Public Evaluation of Program
BEACH Act
Section
406(b)(2)(A)(ii-iv)
406(c)(l)
406(c)(3)
406(b)(3)(A), (B)
406(c)(2)
406(c)(4)
406(c)(7)
406(c)(5)
406(c)(6)
406(b)(3)(A), (B)
406(c)(2)
406(b)(2)(A)(v)
Chapter
Discussed
3
4
4
4
5
5
5
5
' 2
 2.2.1  Risk-based Beach Evaluation and Classification (Performance Criterion 1)

 The first performance criterion a state or tribe must meet to qualify for an implementation grant
 is to develop a risk-based beach evaluation and classification plan and apply it to state or tribe
 coastal recreation waters. A state or tribal program must describe the factors used in its
 evaluation and classification process and explain how its beaches are ranked as a result of the
 process.  This process must result in the identification of a list of coastal recreation waters in the
 state or tribe, including coastal recreation waters adjacent to beaches or similar points of access
 used by the public.  This performance criterion is discussed in more detail in Chapter 3.

 2.2.2  Sampling Design and Monitoring Plan (Performance Criterion 2)

 The second performance criterion a state or tribe must meet to qualify for an implementation
 grant is to develop a sampling design and monitoring implementation plan.  This plan must
 adequately address the frequency and location of monitoring and assessment of coastal recreation
 waters based on the periods of recreational use of the waters, the nature  and  extent of use during
 certain periods, the proximity of the waters to known point sources and nonpoint sources of
pollution, and any effect of storm events on the waters. This criterion is discussed in more detail
in Chapter 4.
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                                                                                Chapter 2
2.2.3  Monitoring Report Submission and Delegation (Performance Criterion 3)

The third performance criterion a state or tribe must meet to qualify for an implementation grant
is to develop a mechanism to collect relevant information and submit timely reports to EPA and
document any delegation of monitoring responsibilities to local governments.

Report Submission
A state or tribal recipient of a grant must submit to the EPA Administrator timely information
and reports that describes the data collected as part of the monitoring program, and the actions
taken to notify the public when water quality standards are exceeded.

Delegation
If monitoring responsibilities are delegated to local governments, the state grant recipient must
describe the process by which the state may delegate to local governments responsibility for
implementing the monitoring program.  This criterion is discussed in more detail in Chapter 4.

2.2.4  Methods and Assessment Procedures (Performance Criterion 4)

The fourth performance criterion a state or tribe must meet to qualify for an implementation grant
is to develop detailed methods and assessment procedures. These procedures must adequately
address both the methods to be used for detecting levels of pathogens and pathogen indicators
that are harmful to human health and the assessment procedures for identifying short-term
increases in pathogens and pathogen indicators that are harmful to human health. This criterion
is discussed in more detail in Chapter 4.

2.2.5  Public Notification and Risk Communication Plan (Performance Criterion 5)

The fifth performance criterion a state or tribe must meet to qualify for an implementation grant
is to develop an overall public notification and risk communication plan. The plan must describe
the  state's or tribe's public notification efforts and measures to inform the public of the potential
risks associated with water contact activities in'the coastal recreation waters that do not meet
applicable water quality standards.  This criterion is discussed in more detail in Chapter 5.

2.2.6  Measures to Notify EPA and Local Governments (Performance Criterion 6)

The sixth performance criterion a state or tribe must meet to qualify for an implementation grant
is to identify measures for promptly communicating to EPA and local governments of the
occurrence, nature, location, pollutants involved, and extent of any exceeding of, or likelihood of
exceeding, applicable water quality standards for pathogens and pathogen indicators. The state
or tribe must identify how this information will be promptly communicated to EPA and to a
designated official of the local government that has jurisdiction over land adjoining the coastal
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  National Beach Guidance and Grant Performance Criteria for Recreational Waters	

  recreation waters for which the failure to meet applicable standards has been identified. This
  criterion is discussed in more detail in Chapter 5.

  2.2.7  Measures to Notify the Public (Performance Criterion 7)

  The seventh performance criterion a state or tribe must meet to qualify for an implementation
  grant is to develop measures to notify the public through the posting of signs at beaches or
  similar points of access or through functionally equivalent communication measures that are
  sufficient to give notice to the public that the coastal recreation waters are not meeting or are not
  expected to meet applicable water quality standards for pathogens and pathogen indicators. This
  criterion is discussed in more detail in Chapter 5.

  2.2.8  Notification Report Submission and Delegations (Performance Criterion 8)

  The eighth performance criterion a state or tribe must meet to qualify for an implementation
  grant is to develop a mechanism to collect relevant information and submit timely reports to EPA
  and document any delegation of notification responsibilities  to local governments.

 Report Submission
 A state or tribal recipient of a grant must submit to the Administrator timely information and
 reports that describes data collected as part of the notification program and the actions taken to
 notify the public when water quality standards are exceeded.

 Delegation
 If notification responsibilities are delegated to local governments, the state grant recipient must
 describe the process by which the state may delegate to local  governments responsibility for
 implementing the notification program. This criterion is discussed in more detail in Chapter 5.

 2.2.9  Public Evaluation of Program (Performance Criterion 9)

 The ninth performance criterion a state or tribe must meet to qualify for an implementation grant
 is to identify how to provide  the public with an opportunity to review the program through a
 process that provides for public notice, review, and an opportunity to comment. This can be
 accomplished through a record of public comments, meetings, forums, or workshops.

The components of a beach monitoring and notification program that a grant recipients must
provide opportunity for public comment on are:
       Beach Evaluation and Classification Process, including list of waters to be monitored and
       beach ranking (Chapter 3.2);
       Sampling Design and Monitoring Plan, including sampling location and sampling
       frequency (Chapter 4.2);
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                                                                               Chanter 2
       Public Notification and Risk Communication Plan, including methods to notify the public
       of a swimming advisory (Chapter 5.2).

It is beneficial to gather input from the community regarding the recreational waters they would
like to see monitored when classifying and ranking beaches. Annual public or community
meetings, surveys of the users at the beach, local newspaper articles, or other sources can provide
insight into public opinion about the beach, including why the beach is or is not used (e.g., for
sunning, running, swimming, or surfing), perceptions of water quality and health problems, and
whether'beach users desire a monitoring and notification program (if none exists) or how
satisfied they are with the program that has been implemented.

2.3    Additional Grant Information

2.3.1  Grant Program Phases

The BEACH Act authorizes a two-phase grant program -an initial program development phase
followed by a program implementation phase. The initial phase of the grant program focuses on
the development of state or tribal beach monitoring and notification programs. As a condition of
receipt of a Program Development Grant, grant recipients must commit to develop monitoring
and notification programs that will ultimately meet the requirements of the BEACH Act. Each
year, to awared of implementation grant, EPA will assess whether the recipient has made
satisfactory progress in developing a program that is consistent with the BEACH Act and EPA
performance criteria. After the program development phase, implementation grant applicants
must be carrying out beach monitoring and notification programs that are consistent with the
performance criteria outlined in this document.

2.3.2   Eligibility for Grants

State Governments

Coastal and Great Lake states are eligible to apply for grants to develop -and implement
. monitoring and notification programs. For the purposes of the BEACH Act, the term "state"
 applies to 30 coastal and Great Lake states and includes 6 coastal territories defined in CWA
 section 502: the Commonwealth of Puerto Rico, the Virgin Islands, Guam, American Samoa, the
 Commonwealth of the Northern Mariana Islands, and the Trust Territory of the Pacific Islands.
 The Trust Territory of the Pacific Islands, however, no longer exists.  The Marshall Islands, the
 Federated States of Micronesia, and Palau, which were previously entities within the Trust
 Territory of the Pacific Islands, have entered into Compacts of Free Association with the
 Government of the United  States.  As a result, each is now a sovereign, self-governing entity and,
 as such, is no longer eligible to receive grants as a territory or possession of the United States.
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Local Governments

The BEACH Act authorizes EPA to make grants to local governments for development and
implementation of a monitoring and notification program only if, after the 1-year period
beginning on the date of publication of this document, EPA determines that the state is not
implementing a program that meets the requirements of the statute.

Tribal Governments

The BEACH Act amended CWA Section 518(e) to authorize EPA to treat Indian tribes in the
same manner as states for the purpose of CWA section 406, if the tribe meets the treatment as a
state (TAS) requirements in section 518(e). EPA is developing procedures for establishing TAS
for section 406 of the BEACH Act.

2.3.3   Funding

CWA section 406(i) authorizes appropriations of up to $30 million per year through fiscal year
2005 to develop and implement beach programs. The actual amount of funding available to
individual states and tribes will depend on congressional appropriation levels and an allotment
formula for allocating fund among eligible.

2.3.4   Selection Process

The Administrator of EPA has delegated the authority to award BEACH Act program
Development and Implementation Grants to the  Assistant Administrator of the Office of Water
and to the EPA Regional Administrators. The EPA regional offices will award program
Development and Implementation Grants through a noncompetitive process:

EPA expects to award grants to all eligible state, territory, and tribal applicants that meet the
performance criteria specified in this document.

2.3.5   Application Procedure

BEACH Act grants will be awarded and administered according to the regulations at 40 CFR
Part 31 ("Uniform Administrative Requirements for Grants and Cooperative Agreements to State
and Local Governments"). The EPA regional offices have the lead responsibility for providing
grant application packages and advice.  Refer to  Appendix E for a list of the current EPA
Regional  Grant Coordinators or visit the Beach Watch Web site at 
on the Internet.
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                                                                               Chapter 2
2.4    References
USEPA.  2001. NoticeofAvailability of Grants for Development of Coastal Recreation Water
Monitoring and Public Notification under the Beaches Environmental Assessment and Coastal
Health Act. U.S. Environmental Protection Agency, Office of Water, Washington, DC.
Federal Register May 2001, 66(104): 29308-29310.
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2-10
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                                                                                 Chapters
Chapter 3: Risk-based Beach Evaluation and Classification Process

This chapter describes the risk-based beach evaluation and classification process, including the
evaluation steps and recommended information that a state or tribe should consider.

3.1    Performance Criterion

The first performance criterion is to develop a risk-based beach evaluation and classification plan
and apply it to state or tribal coastal recreation waters.  A state or tribal government program
must describe the factors used in its evaluation and classification process and explain how its
beaches are ranked as a result of the process. This process should result in the  identification of a
list of coastal recreation waters, including coastal recreation waters adjacent to beaches or similar
points of access used by the public.

Risk-based beach evaluation and classification is a means to identify potential risk of disease to
swimmers and to protect public health. Although a state or tribe may develop its own approach,
it must address these four core elements:

•  Identification of factors used to evaluate and rank beaches.

•  Identification of coastal recreation waters in the state or tribe.

•  Identification of bathing beaches adjacent to coastal recreational waters

•  Identification of available information including pertinent reports and water quality
   monitoring and modeling data, frequency and density of use, public review, and community
   input.

The  goal of the evaluation process is to use these four elements to classify each beach into a
priority category—High, Medium, or Low.  This classification can then be used to direct
resources toward monitoring and notification programs at the beach (Chapters  4 and 5). A
classification of High priority, for example, indicates a beach is of such a high risk and/or high
usage that significant resources should be devoted to more intensive monitoring and public
notification efforts.

3.2    Step 1: Identify Coastal Recreation Waters

According to the BEACH Act, "coastal recreation waters" are defined as the Great Lakes and
marine coastal waters (including coastal estuaries)  designated under CWA section 303(c) by a
state for use for swimming, bathing, surfing, or similar water contact activities. "Coastal
recreation waters"  do not include either inland waters or waters upstream of the mouth of a river
or stream that has an unimpaired natural connection with the open sea.  The first step in

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 National Beach Guidance and Grant Performance Criteria for Recreational Waters	

 evaluating and classifying your beaches is to make a list of .all coastal recreation waters (Figure
 3-1).
             Step 1      Identify Coastal Recreation Waters
                   oncoastal recreation
                3 .waters(e,g.,-&esliwater
                   exclusive of Great ,
                       Lakes)
        Figure 3-1. Step 1: Identify coastal recreation waters.

3.2.1  Designated Uses of Waterbodies

Proper identification of coastal recreation waters requires an identification of the designated use
of a waterbody. Under CWA section 303(c)(2), states adopt water quality standards that consist
of the "designated uses" for the water to which the standard applies and criteria to protect the
uses. Section 303(c) also authorizes EPA to adopt water quality standards, including designated
uses, for states when EPA disapproves a water quality standards submission or in any case when
the EPA Administrator determines that new or revised water quality standards are necessary to
meet the requirements of the CWA.  Therefore,,for the purpose of the BEACH Act, recreational
uses in coastal waters may be designated by either states, tribes or EPA under 303(c)(4).

Most states and some tribes have established designations for their primary contact waters.
Assigning a designated use to a waterbody is a means of identifying and classifying that
waterbody's intended use (e.g., aquatic life support, fish consumption, shellfish harvesting,
drinking water supply, primary contact recreation, secondary contact recreation). Any change to
the designated use of a waterbody must be submitted to EPA for the Agency's review and
approval or disapproval. Typically, states and tribes review their water quality standards every 3
years and review and revise the standards as appropriate.

In designating a use for a waterbody and setting the appropriate water quality criteria to protect
that use, the state or tribe also takes downstream water quality into consideration and ensures that
3-2
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                                                                                 Chapters
its water quality standards provide for the attainment and maintenance of the water quality
standards for downstream waters.

3.2.2   Recreational Uses of Waterbodies

Recreation occurs in many forms throughout the United States and frequently centers around
waterbodies and activities that take place in and on the water. A primary contact recreation use
should be adopted for any waterbody where people engage in or are likely to engage in activities
that could result in ingestion of the water or immersion. These  activities include swimming,
water skiing, kayaking, and others. Although factors such as the location of a waterbody, high
or low flows, safety concerns, and other physical conditions of the waterbody might make it
unlikely that primary contact recreation would occur, EPA strongly encourages states and tribes
to adopt primary contact recreation use designations whenever people might swim or make other
use of the waterbody such that ingestion could occur.

Often a state or tribe will designate most or all of its surface waters for primary contact
recreation.  Those waters that are adjacent to bathing beaches typically constitute a subset of the
waters designated for primary contact recreation.

Although most recreation waters are designated for year-round primary contact recreation to
protect people engaged in primary contact activities, there are some waters where a primary
contact recreational use is designated only on a seasonal basis.  These uses can include the
designation of intermittent, secondary, or seasonal recreation uses. For example, a state or tribe
might choose to designate a water primary contact recreation only during certain months of the
year if climate precludes such use at other times. Similarly, a state or tribe might designate
waters for non-primary contact recreational use, often known as secondary contact use. Subject to
the provisions  of 40 CFR 131.10, secondary contact recreation uses'might be appropriate on a
year-round basis, for example, where waters have been irreversibly affected by wet weather
events or where protecting a primary contact recreation use at all times would result in
substantial and widespread social and economic impact.
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters
 3.2.3 Coastal Recreation Waters

 Definition of Coastal Recreation Waters
 The requirements of section 303(i) apply only to states and tribes that have "coastal recreation
 waters." As amended by the BEACH Act, the CWA defines "coastal recreation waters" as the
 Great Lakes and marine coastal waters (including coastal estuaries) that are designated under
 section 303(c) by a state or tribe for use for swimming, bathing, surfing, or similar water contact
 activities. Refer to CWA section 502(21).  Coastal recreation waters do not include either inland
 waters or waters upstream of the mouth of a river or stream having an unimpaired natural
 connection with the open sea.  Coastal beaches are intended to exclude areas of tidal influence
                                        beyond the mouth of a river. Figure 3-2 illustrates
                                        what beaches may or may not be considered coastal
                                        recreation waters under the BEACH Act, provided that
                                        all of these waters are designated for swimming.. The
                                        heavy lines indicate areas that would be designated
                                        coastal recreation waters; the smaller lines indicate
                                        areas that would not be designated coastal recreation
                                        waters. The decision to identify and classify waters as
                                        coastal or noncoastal is ultimately up to an individual
                                        state or tribe, taking into consideration site-specific
                                        conditions.
 •..Rive?—
                                  Ocean
                                        3.3     Step 2: Identify Bathing Beaches

                                        The second step in evaluating and classifying your
                                        beach is to identify bathing beaches and similar points
                                        of access (Figure 3-3). This can be done by defining
                                        the term beach and designating the proper legal
                                        authority for your beaches. Defining what constitutes
                                        a beach will help identify the areas that can be
                                        evaluated using the Beach Evaluation and
                                        Classification List (Appendix F). The beach definition
                                        should encompass both the physical nature of the area
and the location of the area adjacent to a waterbody that is designated for recreation. Usually,
state, tribal, and local authorities determine the definition of a beach and similar points of access
used by the public.
Figure 3-2. Examples of coastal and non
coastal recreation waters.
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                                                                                            ChanterS
Beach definitions are commonly found in
state or tribal water quality laws or
regulations. They might take the  form of a
sanitary code set by a department of health
or environmental regulations promulgated
by a department of environmental resources.
State or tribal beach definitions follow a
general pattern and include various
descriptions or unique situations.  Typically,
a bathing beach is defined as a body of water

•   Not contained within a man-made
    structure or building
•   Under the control of a state, tribe or
    local government
•   Used for swimming or other contact
    recreational activity (partial body contact
    with the water).

This definition includes seashores,
oceanfronts, and shorelines associated with
estuaries, and bays.  It also can incluse
shorelines associated with natural lakes,
reservoirs, impoundments," ponds, rivers,
streams, and creeks, but (except for the
Great Lakes), these beaches are not covered
by the BEACH Act. A beach can be located
in a rural or urban area and can be publicly
or privately owned.

 Factors to consider when defining a beach
 include geography,  geology, the type of
 recreational use, and the type of access the
 beach provides.

 •   Geography. A beach may be defined by
     a jurisdictional boundary (e.g., nation,
     state, region, county, township,
     municipality) or by location on an ocean,
     a sound, a bay, an estuary, an inlet, or one
             Examples of Beach Definitions

 Annotated Code of Maryland; Environmental Article: Title
 26: Department of the Environment; Subtitle 08: Water
 Pollution; Chapter 9: Public Bathing Beaches: "Bathing
 Beach" means a beach or bathing place which the owner
 holds open to the public for bathing, swimming, or other
 water recreation and which abuts a pond, lake, quarry, stream,
 bay, or other waterbody. The bathing beach includes the
 buildings and appurtenances, if any, used in connection with
 it.

 Public Swimming Pools: 64E-9 Florida Administrative Code;
 portion quoted is from Florida Statute 514 and is not part of
 the Administrative Code: "Public Bathing Place" means a
 body of water, natural or modified by humans, for swimming,
 diving, and recreational bathing, together with adjacent
 shoreline or land area, buildings, equipment, and
 appurtenances pertaining thereto, used by consent of the
 owner or owners and held out to the public by any person or
 public body, irrespective of whether-a fee is charged for the
 use thereof. The bathing water areas of public bathing places
  include, but are not limited to, lakes, ponds, rivers, streams,
  and artificial  impoundments  (514.011(4) Florida Statute
  514).

  Massachusetts Department of Public Health; 105 CMR
  445.00: Minimum Standards for Bathing Beaches  (State
  Sanitary Code, Chapter VII): "Bathing Beach" shall mean a
  natural or artificial flowing or impounded pond, lake, stream,
  river, or other body of fresh or salt water at the location
  where it is used for bathing and swimming purposes. It shall
  not mean a swimming pool as defined in 105 CMR 435.000.

  New York State Department of Health, Bureau of Community
  Sanitation and Food Protection: Chapter 1, State Sanitary
  Code, Subpart 6-2, Bathing Beaches: "Bathing Beach" shall
  mean a bathing place, together with any buildings and
  appurtenances, and the water and land areas used in
  connection therewith, at a pond, lake, stream, or other body
  of fresh or salt water which is used for bathing or swimming
  with the express or implied permission or consent of the
  owner or lessee of the premises or which is operated for a fee
  or any other consideration or which is openly advertised as a
  place for bathing or swimming.  "Bathing" shall mean to
  become partially or totally immersed in water.
of the Great Lakes.
     Geology. A beach is defined as a gently sloping waterfront area or the shoreline of an ocean,
     a sea, or a lake, covered by sand, gravel, or larger rock fragments, possibly accompanied by
     mud.                                                                                 .
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters	

 •   Access. Access to the waterbody might be from a shoreline structure, or the beach might be
     adjacent to a recreational waterbody.

 •   Designated use. (See Section 3.1.1)
                                  Identify Bathing Beaches

                                    Step 2
       Figure 3-3. Identify bathing beaches.
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                                                                                 Chapter 3
3.4    Step 3: Determine Legal Authority for Administering Monitoring and Notification
       Programs

The third step in evaluating and classifying your beach is to identify who has the legal authority
for administering monitoring and notification programs  (Figure 3-4). You should determine
whether the beach is public or private and whether it is subject to monitoring and
advisories/closings based on regulation. If the beach is not subject to state, tribal, or local
jurisdictional authority (the ability of a local entity to regulate, monitor, and implement
advisories or closings), BEACH Act grant funds should not be used to monitor these beaches.
Where beaches are subject to jurisdictional authority, you should know the roles and
responsibilities of involved agencies and interested parties with respect to beach regulation and
management. The laws and regulations relevant to beach management may derive from diverse
influences, such as public health, social integration and rights of people with disabilities,
navigation for pleasure purposes, aquatic sports, and fishing (Bartram and Rees, 2000).
                              Determine Legal Authority
                                           Step3
               Noncoastal recreation
               waters (e.g., freshwater
                 exclusive of Great
                    Lakes)
      Figure 3-4. Step 3: Determine legal authority.
In most states and some tribes, the health department is responsible for administering a public
health code or other administrative codes to determine requirements for recreational water quality
management. Sometimes the environmental regulatory agency has this responsibility. These
codes should list the agency(ies) responsible for recreational water quality management, which
may or may not include some type of monitoring, sampling, and/or notification program.  The
state level agencies might delegate the legal authority to conduct sanitary surveys, operate
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  National Beach Guidance and Grant Performance Criteria for Recreational Waters	;	

  sampling and monitoring programs, and issue advisories and closings to the local (e.g., city,
  county) health departments. Appropriate responsibilities might be further delegated to'the '
  individual beach managers or operators for each beach within the city's or county's jurisdiction.

  Some states, such as California, have more than 100 federal, state, county, and city agencies with
  some authority for managing coastal resources.  The diversity of regulatory structures throughout
  the nation requires diverse approaches and solutions, but in general managers concerned with
  recreational water use areas should consider both common law, the legal precedents set by a
  judge, and statutory law, the laws passed by the legislature and administrative law (regulations
  and ordinances adopted by appropriate authorities). The large number of interested organizations
  requires coordination and cooperation with the state and local governments that have primary
  responsibility for establishing beach monitoring and notification standards and regulations to
  limit the health hazards to users of recreational waterbodies.

  Local authorities usually contribute to the development and enforcement of beach monitoring,
  notification, and water quality  standards and regulations. In general, public health laws and acts
  provide that a local authority may make bylaws regarding public bathing and beach management
  Municipalities may therefore be responsible for regulating the areas and hours when bathing is
  permitted.  Specific regulations for a beach are frequently determined at the local  level on the
  basis  of the physical, environmental, and social characteristics of the area.  Chapter 5 provides
 guidance on public notification if unacceptable risk is associated with bathing.

 3.5    Step 4: Review Available Information

 The fourth step in evaluating and classifying your beach is to review all available information
 about the beach, including historical knowledge of the beach, its uses, and possible sources of
 fecal contamination (Figure 3-5). This information will help you identify the most important
 issues and data gaps. Source information can be located in state, tribal, or local government
 agency files, literature and records in local libraries, beach management reports, community
 association reports, public health records, papers and journals available at colleges and
 universities, and work performed by local nonprofit organizations.  Appendix F provides a list of
 information that might help in classifying and ranking your beaches.

 3.5.1  Pertinent Reports

 Part of the process of evaluating potential health risks related to exposure to pathogens during
 bathing or swimming activities is to compile available information about each beach, including
 historical knowledge of the beach, designated uses, and possible sources of fecal contamination
 This information can be found in reports that include information on waterbodies that are or are
not in attainment of their designated uses, lists of impaired waterbodies, medical records  past
advisory and closure reports, planning reports, and actual discharge data. The following reports
can be  used to help classify and  rank your beaches.


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                                                                                 Chapter 3
                              Review Available Information
                                                           Step 4
        Figure 3-5. Step 4: Review available information.
State Water Quality Report (CWA Section 305(b) Report)

A state's 305(b) report identifies assessed waterbodies that are in full attainment, partial
attainment, or nonattainment of their designated uses. Every 2 years, each state submits a report
on the quality of its assessed waters to EPA to help determine pollution control and management
priorities at the state, tribal, and national levels.  The report indicates how the state measures
waterbodies against its standards and lists known problems, known or suspected causes, and
proposed corrective actions.  The 305(b) reports are a good source for locating potential problem
areas in recreational waterbodies. EPA also uses the reports to compile the National Water
Quality Inventory (USEPA, 1998a), a national assessment of progress toward national clean
water goals. The National Water Quality Inventory State Reports are available through state
water quality management agencies on the Internet at http://www.epa.gov/OWOW/305b/.

List of Impaired Waters (CWA Section 303(d) List)

A state's 303(d) list is a list of impaired waters that have been identified as not meeting water
quality standards. Each state must develop waterbody- or watershed-based cleanup and
restoration plans, known as Total Maximum Daily Loads (TMDLs) for each waterbody listed.  A
TMDL presents the maximum amount of a pollutant that a waterbody can receive and still meet
water quality standards and includes an allocation of that amount to the pollutant's point and
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National Beach Guidance and Grant Performance Criteria for Recreational Waters
nonpoint sources. The 303(d) lists include a priority ranking of the waters and an identification of
the pollutant(s) causing the impairment. Waterbodies on the 303(d) list must be reexamined
periodically.  The monitoring or sampling performed by the state can sometimes support
monitoring or sampling efforts being conducted for beach programs; however, an advisory or
closing should not be issued for a particular waterbody simply because it has been placed on the
303(d) list. The BEACH Act addresses concerns about the health risks associated with microbial
pathogens. Section 303(d) lists, by contrast, reflect concerns about all types of pollutants that
might impair any type of designated use.  Therefore, it is quite possible that a water might be
listed for a pollutant or stressor that is harmful to aquatic species but does not threaten public
health. The 303(d) list for a state can be obtained from the state's water quality management
agency. Links to these agencies are provided on the Internet at http://www.epa.gov/owow/tmdl.

Swimmer Reports or Hospital Records

Medical records and epidemiological studies can provide information related to the historical risk
of swimming at a particular beach. Swimmer illness reports or complaints to a state or tribal
agency are also valuable sources of information and can answer the following questions: Have
any swimmers complained to the agency about illnesses that they believed were related to the
water quality or debris at a beach? Have any hospitals or other medical facilities documented
such reports of illness? Have any epidemiological studies been conducted at a beach (e.g.,
Calderon et al., 1991; Ferley  et al., 1989; Fleischer et al., 1996; Haile, 1996)? Have other
government agencies described health problems at this beach or adjacent shoreline areas?
Approximately how many reports of illness have occurred? How many have occurred within the
past year? The frequency and severity of reports of swimming-associated illnesses can provide
important insights into the risks of bathing at a particular beach.  In many cases, however, people
who contract diseases as a result of bathing in contaminated water do not always associate their
illness  symptoms with swimming. As a result, disease outbreaks are often inconsistently
reported. On the other hand,  people might associate illnesses caused by other sources with
contaminated water. Caution should therefore be used in determining the significance of such
data.

Advisory Reports and Closings

Previously recorded advisories and closings can provide insight into problems associated with
maintaining beach water quality, links to closings caused by rain events, the frequency of
closings during the swimming season, causes of closings (preemptive, outfalls, increased
sampling, rain), and the number of swimming days affected by an advisory or a closing.

Development Planning Reports

Previous management plans or inspection reports can provide information on sewer lines,
outfalls, trash areas, septic  systems, and other infrastructure and can help to answer questions
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                                                                               Chanter '3
concerning the identification of potential sources of human pathogens at a beach (e.g.,
bathrooms).  The types of bathroom facilities in the area should be known, as well as any threats
of sewage contamination nearby. Potential sources of microbiological contamination of
recreational waters might be associated with system failures in municipal wastewater treatment
facilities, leaking sewer lines, or rainfall and runoff. Other sources include releases from boat
and recreational vehicle holding tanks, pumping stations, portable toilets, and leachate from
poorly maintained or flooding septic systems (CADHS, 1998).  The sources of contamination
listed in the example Beach Evaluation and Classification List (Appendix F) could increase the
human health risk of using recreational waters nearby.

Although these plans and reports are useful, it is important to keep in mind other factors affecting
contamination. For example, a study conducted by the Texas Natural Resource Conservation
Commission found that the density and variability of fecal coliform bacteria appeared to be
strongly influenced by storm water runoff.  Summer sampling over one 30-day period at six
stations (five or six samples were collected) demonstrated that substantial changes in density
were observed within as little as 24 to 48 hours. The range of densities around each station's
geometric mean varied from 765 to 18,840 colony forming units (CFU) per 100 milliliters (mL)
of water. Thus, samples collected on an infrequent basis did not provide an adequate measure of
fecal coliform density and variability, particularly in waters affected by storm events (McGinnis,
1996).    .

Point Source Discharge Data

Facilities authorized to discharge under the National Pollutant Discharge Elimination System
(NPDES) program, including combined sewer overflows (CSOs), concentrated animal feeding
operations (CAFOs), and publically owned treatment works (POTWs) provide information on
the contents of their  point source discharges.

CSOs

CSOs consist of mixtures of domestic  sewage, industrial and commercial wastewaters, and storm
water runoff.  Untreated CSOs often contain high levels of suspended solids, pathogenic
microorganisms, toxic pollutants, organic compounds, oil and grease, and other pollutants that
can cause water quality standards to be exceeded, posing risks to human health (USEPA, 1994b).
 An increased risk of illness was associated with swimming near flowing storm drain outlets in
Santa Monica Bay as compared to swimming more than 400 yards away from the outlets (Haile,
1996; NRDC, 1997).

CAFOs

CAFOs and other animal feeding operations (AFOs) can pose a number of risks to water quality
and public health, mainly because of the amount of animal manure and wastewater they generate
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters	

 (USEPA, 1998a). Manure and wastewater from AFOs and CAFOs have the potential to
 contribute pollutants such as nutrients (e.g., nitrogen, phosphorus), sediment, pathogens, heavy
 metals, hormones, antibiotics, and ammonia to the environment.

 POTWs

 POTWs are waste treatment works owned by a state, unit of local government, or tribe, and they
 are usually designed to treat predominantly domestic wastewaters.
                                                   Microbial Analysis, of Storm Water

                                          Coliforms, pathogenic bacteria, and viruses were detected in
                                          both combined sewer flows and storm sewer flows in
                                          Baltimore, Maryland. The levels of fecal coliforms found in
                                          storm flows ranged from 200 to more than 2,000 most
                                          probable number (MPN) per 100 mL, and 123 of the 136
                                          samples had fecal coliform bacteria counts of greater than
                                          2,000 MPN/100 mL.  Of those 123 samples, 95 percent
                                          were positive for Salmonella. Six storm water flows were
                                          examined for viruses, and all six tested positive (Olivieri et
                                          al., 1977).
 Nonpoint Source (CWA Section 319)
 Reports

 In 1987 Congress passed CWA section
 319, establishing a national program to
 control nonpoint sources of pollution.
 EPA 319 guidance defines nonpoint
 source pollution as pollution "caused by
 rainfall or snowmelt moving over and
 through the ground and carrying natural
 and human-made pollutants into lakes,
 rivers, streams, wetlands, estuaries,
 othercoastal waters, and ground water."
 Hydrological modification can also result in nonpoint source pollution.  Section 319(h)(l 1) of the
 CWA requires states to report annually on their progress in meeting nonpoint source
 management program milestones.  They must also report available information on reductions in
 nonpoint source pollution and on improvements in water quality resulting from program
 implementation.  States may wish to include a list of further actions necessary to achieve CWA
 goals, including any recommendations for future EPA programs to control nonpoint source
 pollution, as well as briefcase studies of any particularly successful nonpoint source control
 efforts.

 Environmental Group Reports

 Many environmental groups conduct studies and publish reports on local beaches and
 recreational waters. These  reports can be helpful in classifying your beach because they might
 evaluate levels of pathogen indicators and  identify potential sources of pollution that could pose
 a health risk to swimmers.  These environmental reports also might include historical
 information and report how water quality conditions have changed over time. Additional
 information on environmental groups that conduct water quality and recreational beach studies is
provided in Appendix C.
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                                                                                Chapter 3
Chamber of Commerce Reports

Chambers of Commerce and other government agencies often publish reports on the economic
value of natural resources or beach recreation.  These reports can assist in the evaluation and
classification of your beach because they might contain information about how your beaches and
recreational waters contribute to your local economy. For example, NRDC (1997) found that
tourists spend billions of dollars annually visiting coastal and Great Lakes counties and their
beaches. California, Florida, and South Carolina estimated the value of coastal tourism to be
more than $37 billion, $23 billion, and $4 billion, respectively (NRDC 1997, 1999). Thus, if
your beaches have a designated use of primary contact recreation, you might want to implement a
"High" level of monitoring and notification to ensure that your beaches are safe and desirable to
the public.

3.5.2  Water Quality Monitoring and Modeling Data

Water Quality Monitoring Reports

State or tribal water quality monitoring reports can provide data to help identify water quality
patterns. Monitoring data can include temperature, flow, and turbidity.  These data can often be
used in evaluating and classifying your beach. For example, Francy and Darner (1998) found a
relationship between turbidity and concentrations of E. coli at three Lake Erie beaches; as
turbidity increased, E. coli concentrations also increased. In that study, other environmental and
water-quality variables were also  shown to be related to E. coli concentrations. It is important to
note that sampling beaches more frequently will detect fluctuations in levels of indicators more
reliably. Therefore, beaches that are sampled only once a month might be a greater health risk to
swimmers than those that are sampled more frequently.

Water Quality Modeling Reports

Water quality models can also assist in the evaluation and classification of your beach.  Models
that predict bacterial contamination during rainfall events can help reduce the risk of swimmer
exposure to contaminants between normal sampling periods (USEPA, 1999b). Chapter 4
provides additional information on these types of models.

Sanitary Surveys

A sanitary survey can be used to evaluate and document sources of contaminants that might
adversely affect public health. The survey should be performed by a Registered
Sanitarian/Registered Environmental Health  Specialist or technicians that have experience,
knowledge, and competence in the design, operation, and maintenance of water supply systems
(USEPA, 1999a). Although sanitary surveys are frequently associated with water supply
systems, they can be used to identify sources of pollution and to provide information on source
controls and identification, persistent problems such as exceeding of water quality standards,
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters	__	

 magnitude of pollution from sources, and management actions and links to controls.  Thus, a
 sanitary survey can be an effective tool for protecting human health at bathing beaches and can
 provide information that helps in designing monitoring programs and selecting sampling
 locations, times, and frequencies.

 Additional information on sanitary surveys is provided in Appendix G.  The sanitary survey list
 can be used to evaluate and identify the potential and existing microbiological hazards that could
 affect the safe use of a particular stretch of recreational water or bathing beach.

 3.5.3  Frequency and Density of Use

 Frequency of Use

 The frequency of use and thus exposure to pathogens can be determined by measuring the level
 of use at a beach and identifying peak periods, including consideration of the percentage of
 people visiting the beach that actually enter the water, beach use during  holidays, the length of
 the swimming season, and a number of other factors.

 Density of Use

 When people who have a compromised immune system or otherwise are at high risk become
 infected with pathogens, severe, life-threatening illness can occur (Ahmed, 1991). Thus,
 children, senior citizens, and people with weakened immune systems (such as persons with AIDS
 or other immune system diseases, cancer patients receiving chemotherapy, and organ transplant
 recipients) are more likely to become ill when they come into contact with contaminated water.
 Fattal et al. (1987) observed a significant association between enteric, disease symptoms and
 recreation waters with high levels of bacterial indicators in children ages birth to 4 years.
 Alexander et al. (1992) found that children between the ages of 6 and  11 that came into contact
 with seawater contaminated with sewage were likely to suffer from vomiting, diarrhea, itchy
 skin, fever, lack of energy, and loss of appetite. These effects can be more significant in areas
 with restricted circulation.

 This increased risk is of particular significance during high-frequency use periods because
 bacterial densities and the potential presence of pathogens are directly related to the number of
 swimmers. Studies have demonstrated an association between high swimmer densities and an
 increase in bacterial densities.  Therefore, swimmers should pay special attention when
 swimming during peak bathing hours, especially if they are immunocompromised or otherwise at
 high risk.

3.5.4   Other Factors

Additional factors such as the importance to local economy, public comments, and community
input are also important considerations in evaluating and classifying your beaches.
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                                                                                Chapters
Importance to Local Economy

A particularly important factor is whether the beach provides substantial support to the local
economy, primarily through residential and tourist income spent at the beach either directly for
fees assessed to use the beach or indirectly for hotels and concessions supplying services to beach
users. Beaches, rivers, and lakes are the number one vacation destination for Americans.
Polluted water puts tourism-dependent economies at risk.  Advisories and closings issued for
popular tourist beaches, such as Myrtle Beach, South Carolina, Southernmost Point Beach, Key
West, Florida,  or Huntington Beach, California, cost local economies thousands of dollars
(Sanchez, 1999). Some communities might prefer to limit water quality monitoring and public
notification because of financial constraints.  However, public confidence hi the local
government might be dramatically affected if an outbreak of diseases was to occur in swimmers
at a particular beach. If beaches designated for primary contact recreation that are highly
important to the local economy, a high level of monitoring and notification should be
implemented.

Public Comments

The BEACH Act requires that a grantee program, and specifically its "List of Waters" be subject
to public review and provide the public an opportunity to review the beach program through a
process that provides for public notice and an opportunity to comment. It is beneficial to gather
input from the community regarding the recreational waters they would like to see monitored
when classifying and ranking your beaches. An annual public or community meeting, surveys of
the users at the beach, local newspaper articles, or other sources can provide insight into public
opinion about the beach, including why the beach is or is not used (e.g.,  for  sunning, running,
swimming, or  surfing), perceptions  of water quality and health problems, and whether beach
users desire a monitoring and notification program (if none exists) or how satisfied they are with
the program that has been implemented.

3.6    Step 5: Ranking Beaches

The final step in evaluating and classifying your beaches is to rank the beaches (Figure 3-6). It is
the discretion of each state or tribe to determine how the beaches in the state or tribe are
classified, however the ranking process and the factors used to classify your beach must be
documented. This ranking should .take into consideration all the factors discussed in  this chapter,
paying particular attention to 1) the amount of rainfall in the area, 2) the frequency of known and
potential pollution sources such as CSOs or SSOs, 3) the density of bathers, 4) the occurrence of
failing or malfunctioning septic systems, and 5) public comment.  For example, significant
rainfall events can frequently cause elevated levels of pathogens and pathogen indicators to
reach the beach. Thus, rainfall might be one of the more important factors.  Beaches where there
are recurring significant rainfall events potentially present a higher risk to public health. Haile et
al. (1999) found that there is an increased risk of adverse health effects associated with
swimming in ocean water that is contaminated with untreated urban runoff. For this reason, it is
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters          	;	

 important to note the frequency of rainfall events and the occurrence of significant flow from
 storm water outfalls, as well as CSOs and SSOs. In addition, exposure is another factor that is
 crucial to consider when evaluating a beach. Beaches that have a high density of bathers have a
 higher risk of exposure to pathogens.

 The public could potentially impact beach evaluation and classification. A beach classified, as
 High priority primarily because of pollution problems might be avoided by the public, and thus  a
 monitoring and notification program might not be warranted. On the other hand, a beach
 classified as Low priority after the preliminary evaluation might be very popular with the public,
 and the public might desire improved monitoring and notification to ensure that water quality
 remains optimal for bathing. If the beach has been  classified as High priority because of actual
 or potential pathogen contamination and it is frequently used by residents and tourists (perhaps
 because it is the only beach available in the area), a more intense level of surveillance and an
 increased effort to locate and address the  source of contamination are warranted.

 Once you have classified your beaches, Chapters 4 and 5 will enable you to design the most
 appropriate monitoring and notification protocols for each classification of beach.  For example,
 "High" priority means frequent sampling  and analysis with weekly posting of advisories or
 closings if necessary. "Medium" priority means less frequent sampling while still meeting water
 quality standards or developing a risk-based model to interpret rainfall events that contribute
 pathogens to the waterbody. "Low" priority indicates that sources of pathogens are rare or that
 few people bathe in the water. Water quality monitoring could therefore be limited to an annual
 survey or conducted only on complaint.

 An agency with  limited resources will need to consider carefully which swimming beaches
 should be targeted for which level of program implementation in the tiered approach or pursue
 sources of funding to provide better coverage of all popular low- to high-risk  beaches.
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                                                                                   Chapter 3
                                     Rank Beaches
StepS
       Figure 3-6. Step 5: Rank beaches.
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National Beach Guidance and Grant Performance Criteria for Recreational Waters

3.7    References

Ahmed, F.E. ed., 1991. Seafood Safety. Committee on Evaluation of the Safety of Fishery
Products, Food and Nutrition Board, Institute of Medicine, National Academy Press,
Washington, DC.

Alexander, L.M., A. Heaven, A. Tennant, and R. Morris. 1992. Symptomatology of children in
contact with sea water contaminated with sewage. Journal of Epidemiology and Community
Health 46:340-344.

Bartram, J., and G. Rees. 2000. Monitoring Bathing Waters: A Practical Guide to the Design
and Implementation of Assessments and Monitoring Programmes. E & FN SPON, London.

CADHS. 1998. Beach Sanitation Guidance for Saltwater Beaches. California Department of
Health Services, .

Calderon, R., and E.W. Mood. 1982. An epidemiological assessment of water quality and
"swimmer's ear." Archives of Environmental Health 37(5):300-305.

California Coastal and Ocean Resources: An Overview.
.

Elder, D., G. Killam, and P. Koberstein. 1999. The Clean Water Act: An Owner's Manual.
River Network, Portland, OR.

Fattal, B., E. Peleg-Olevsky, T. Agursky, and HI Shuval. 1987. The association between
seawater pollution as measured by bacterial indicators and morbidity among bathers
at Mediterranean bathing beaches of Israel. Chemosphere 16:565-570.

Ferley, J.P., D. Zmirou, F. Balducci, B. Baleux, P. Fera, G. Larbaigt, E. Jacq, B. Moissonnier, A.
Blineau, and J. Boudot. 1989. Epidemiological significance of microbiological pollution criteria
for river recreational waters. International Journal of Epidemiology 18(1): 198-205.

Fleisher, J.M., D. Kay, R.L. Salmon, F. Jones, M.D. Wyer, and A.F. Godfree.  1996. Marine
waters contaminated with domestic sewage: Nonenteric illnessess associated with bather
exposure in the United Kingdom. American Journal of Public Health 86(9): 1228-1234.

Francy, D.S., and R.A. Darner. 1998. Factors affecting Escherichia coli concentrations at Lake
Erie public bathing beaches.  Water Resources Investigations Report. 98-4241. U.S. Geological
Survey, Columbus, OH.

Haile, R. 1996. A Health Effects Study of Swimmers in Santa'Monica Bay. October 1996.
Santa Monica Bay Restoration Project, Monterey Park, CA.
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                                                                              Chapter 3
Haile, R, W,, J. S. White, M. Gold, R. Cressey, C. McGee, R.C. Millikan, A. Glasser, N.
Harawa, C. Ervin, P. Harmon, J. Harper, J. Dermand, J. Alamillo, K. Barrett, M.
Nides, and G. Wang. .1999. The health effects of swimming in ocean water
contaminated by storm drain runoff. Epidemiology 10(4): 355-363.

McGinnis, A.E., and J.R. Mummert, 1996, Effect of 'Sampling Frequency on the Assessment of
Fecal Coliform Bacteria Densities in Streams.  Texas Natural Resources Conservation
Commission, Field Operations Division, Region 4, Duncanville, TX.

NRDC. 1997. Testing the Waters Volume VII: How Does Your Vacation Beach Rate?
Natural Resources Defense Council, New York, NY.

NRDC. 1999. Testing the Waters: A Guide to Water Quality at Vacation Beaches. Natural
Resources Defense Council, New York, NY.

Olivieri, V.P., C.W. Kruse, K.  Kawata, and I.E. Smith.  1977.  Microorganisms in Urban
Stormwater.  EPA-600/2-77-087. U.S. Environmental Protection Agency, Municipal
Environmental Research Laboratory, Cincinnati, OH.

Sanchez, R. 1999, September 1. Wipeout at Surf City: Bacteria close ocean  in famed
Huntington Beach, CA; The Washington Post,  p. A3.

USEPA. 1994. Combined sewer overflows control program.  U.S. Environmental
Protection Agency. Federal Register, April. 19, 1994, 59(75).

USEPA.  1998a.  National Water Quality Inventory: 1996 Report to Congress. EPA 841-R-97-
008. U.S. Environmental Protection Agency, Office of Water, Washington, DC.

USEPA. 1999a. Guidance Manual for Conducting Sanitary Surveys of Public Water Systems;
Surface Water and Ground Water Under the Direct Influence (GWUDI) of Surface Water. EPA
815-R-99-016. U.S. Environmental Protection Agency, Office of Water, Washington, DC.

USEPA. 1999b. Review of Potential Modeling  Tools and Approaches to Support the BEACH
Program (Final Draft). March  1999. U.S. Environmental Protection Agency, Office of Science
and Technology, Washington, DC.
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National Beach Guidance and Grant Performance Criteria for Recreational Waters
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                                                                               Chapter 4
Chapter 4: Beach Monitoring and Assessment

This chapter describes the performance criteria related to monitoring and assessment and
provides detailed technical guidance as required by CWA section 406(a)(2).

4.1    Performance Criteria

Three performance criteria related to monitoring and assessment activities must be met to qualify
for BEACH Act Program Implementation Grants: Performance Criteria 2, 3, and 4,

Tiered Sampling Design and Monitoring Plan (Performance Criterion 2). Performance
criterion 2 is to develop a sampling design and monitoring implementation plan. This plan must
adequately address the frequency and location of monitoring and assessment of coastal recreation
waters based on variety of factors, including the periods of recreational use of the waters, the
nature and extent of use during certain periods, the proximity of the waters to known point
sources and nonpoint sources of pollution, and any effect of storm events on the waters.  Refer to
Section 4.2 for more details.

Monitoring Report Submission and Delegation (Performance Criterion 3). Performance
criterion 2 is for states and tribes to compile and report their monitoring data in timely reports
and to describe any delegation of monitoring responsibilities that might have been made to local
governments. See section 4.3 for a more detailed explanation.

Methods and Assessment Procedures (Performance Criterion 4).  Performance criterion 4 is
to develop detailed methods and assessment procedures.  The procedure must adequately address
both the methods to be used for detecting levels of pathogens and pathogen indicators that are
harmful to human health and the assessment procedures for identifying short-term increases in
pathogens and pathogen indicators that are harmful to human health in coastal recreation waters.
Section 4.4 provides,additional information related to this criterion.

4.2    Sampling  Design and Monitoring Plan

Once states and tribes have ranked their beaches and assigned a classification of High, Medium,
or Low, they can use the guidance in this chapter to develop and implement a monitoring
program based on the beach classification. The plan should be composed of two parts: (1) a
tiered sampling design and (2) other recommended elements addressing data quality, staffing,
training, data management, and program oversight.

Note, the BEACH Act requires states and tribes, as a condition for receiving 406 grants,  to
provide the public with an opportunity to review the monitoring and notification program. The
Performance Criterion for public comments is explained in Chapter 2.
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters	

 4.2.1   Tiered Sampling Design

 Your sampling design must identify when basic sampling will be conducted, when additional
 sampling will be conducted, where samples will be collected, arid the depth at which samples
 will be collected. The sampling design must be developed to meet the objective of protecting
 human health and will depend upon the characteristics of the beaches, hi accordance with the
 risk-based approach to evaluating and classifying your beaches, a tiered monitoring approach
 should be used. Table 4-1 presents examples of monitoring options based on the classification of
 your beaches (Chapter 3). It includes suggestions for high-, medium-, and low- priority beaches
 on when to conduct basic sampling, when to conduct additional sampling, where to collect
 samples, and at what depth to sample.  Additional information on a monitoring design can be
 found in Appendix H.

 When to Conduct Basic Sampling           .
 EPA recommends for all beaches that samples be taken at least one month prior to the start of the
 swim season and at least once per week during the swim season. For high and medium priority
 beaches, EPA recommends that water quality samples be taken once per week during the swim
 season. However, at medium and low priority beaches less frequent sampling may be possible
 due to local conditions or as determined by the state, tribal, and local authorities. Point source
 dischargers should be encourages to test their discharge for E. coli or enterococci.

 When to Conduct Additional Sampling
 EPA recommends for all beaches that additional sampling be taken after a pollution event where
 the potential exists that indicator levels may be expected to exceed standards.  In addition, EPA
 recommends that samples be taken as soon as possible after an initial sample shows an
 exceedence of a water quality standard, but where there is reason to doubt the accuracy of the
 sample. (Additional sampling may not be necessary if a preemptive closing already exists.) At
 high and medium priority beaches, EPA recommends that samples be taken after a heavy rainfall,
 particularly if your jurisdiction has a preemptive standard in place.

 Where to Collect Samples
 EPA recommends for all beaches that samples be taken in the middle of a typical bathing area.
 For all high priority short beaches, EPA recommends that samples be taken as a point
 corresponding to each lifeguard chair, or one for every 500 meters of beach. For all high priority
 long beaches (> 5 miles), samples be taken at most highly used areas, and spread out along the
 entire beach. In addition, all high and medium priority beaches should be sampled near known
 and pollution sources, while low priority beaches should be sampled near potential pollution
 sources.

 What Depth to Sample
 EPA recommends that samples be taken at all beaches at knee depth. You are encouraged to
 sample at one depth for all your beaches to ensure consistency and comparability among your

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                                                                                  Chapter 4
 samples.  For example, if the prioritization of your beaches changes over time, the samples
 would remain comparable due to the consistency in sample depth.  At high priority beaches,
 additional samples can be taken as necessary for your particular beach (e.g., surface of water,
 waist depth, sediment).  However, it is important to identify those at most risk and sample
 appropriately to protect those bathers at all priority beaches.
Table 4-1. EPA Recommended Tiered Sampling Design for Beach Managers












Low
Priority












Medium
Priority









High
Priority







When to Conduct
Basic Sampling*
At least 1 month prior to
start of swimming season

Sampling frequency at
low priority beaches
should be determined by
state and local authorities,
taking into account
resource constraints and
evaluation of risk factors
at individual beaches.

Minimum sampling
frequency should be
consistent with other
ambient water quality
sampling programs.
At least 1 month prior to
start of swimming season

Recommended sampling
frequency is once per
week. However, less
frequent sampling may
be possible depending on
proximity to suspected
sources, beach use,
historical water quality
data, and other risk
. factors.
At least 1 month prior to
start of swimming season
At least once per week
during swimming season










When to Conduct Additional
Sampling
After a major pollution event where
potential exists that indicator levels
may be expected to exceed standard
(sewage leak, spill)

For situations not based on
preemptive closings:
Immediate sampling if first sample
exceeds water quality standards and
there is reason to doubt the accuracy
of the sample.






After heavy rainfall (particularly if
you have a preemptive standard)
After a major pollution event where
potential exists that indicator levels
may be expected to exceed standard
(sewage leak, spill)

For situations not based on
preemptive closings:
Immediate sampling if first sample
exceeds water quality standards and
there is reason to doubt the accuracy
of the sample.
After heavy rainfall (if preemptive
standard exists)
After a major pollution event where
potential exists that indicator levels
may be expected to exceed standard
(sewage leak, spill)

For situations not based on
preemptive closings:
Immediate sampling if first sample
exceeds water quality standards and
there is reason to doubt the accuracy
of the sample.

Where to Collect Samples

Depends on characteristics of your
beach:

Middle of typical bathing area

Near potential pollution sources











Depends on characteristics of your
beach:
Middle of typical bathing area

Near known and potential pollution
sources

One sample every half-mile or at most
highly used area (whichever is less)




Depends on characteristics of your
beach:
Middle of typical bathing area

Near known and potential pollution
sources

For short beaches, one sample at a point
corresponding to each lifeguard chair, or
one for every 500 m of beach

For long beaches (> 8 km [5 miles]),
sample at most highly used areas, and
spread out samples along the entire beach
What Depth to
Sample
Knee depth
















Knee, depth












Knee depth

Other as you feel is
necessary for your
beach (e.g., surface of
water, waist depth,
sediment)







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Nntional Beach Guidance and Grant Performance Criteria for Recreational Waters

  * EPA recommends that you lake samples during peak bathing time.
  * When using 24-hour methods, you might want to collect samples at least 24 hours before high-use days (weekends) in case closures might be required,

Current Research

Monitoring program design is an essential part of any sampling program.  EPA's Office of
Research and Development (ORD) is currently undertaking a study at marine, estuarine, and
freshwater beaches to develop a statistically valid monitoring protocol that takes into account
elements that contribute to the uncertainty associated with sampling bathing beach waters, such
as tides,  wind, solar radiation, bather density, temporal and spatial factors, rainfall, and the
proximity of point and nonpoint sources of pollution. New data collected during the summer of
2000 are being evaluated for the purpose of recommending a monitoring protocol that minimizes
uncertainty about the quality of bathing waters while requiring the fewest number of samples
possible. When published, this protocol will provide additional information to assist in
determining when, where, and how many samples should be taken and how the monitoring data
should be analyzed. The data quality objectives of this study are provided at
www.epa.gov/nerlcwww/bch_dqo.pdf.

4.2.2  Other Elements of a Sampling and Monitoring Plan

4.2.2.1 Ensuring Data Quality

To ensure data quality, EPA recommends that your grant application include documentation on
your

•      Quality assurance project plan (QAPP),
•      Data quality objectives (DQOs), and
•      Standard operating procedures (SOPs).

A QAPP is a formal document that describes in detail the technical activities and quality
assurance (QA)  and quality control (QC) procedures that must be implemented to ensure the data
meet the specified standards. A QAPP  details who  is responsible for each task, how it will be
done, when it will be done, what QA and QC activities are necessary to ensure that the data
collected meet the specified standards, and how the data will be analyzed and reported.  EPA
offers detailed guidance on the QAPP planning process in Guidance for the Data Quality
Objectives Process (USEPA, 1994). In addition, general guidance and examples of planning for
monitoring programs are provided in several EPA documents, including Monitoring Guidance
for the National Estuary Program (USEPA, 199 la) and Monitoring Guidance for Determining
the Effectiveness of Nonpoint Source Controls (USEPA, 1997b).

DQOs are qualitative and quantitative statements that clarify study objectives, define the
appropriate types of data, and specify tolerable levels of potential decision errors that will be
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                                                                                Chanter 4
used as the basis for establishing the quality and quantity of data needed to support decisions
(USEPA, 1998c).  EPA requires that any organization receiving funding from the Agency to
collect environmental data used in decision making or compliance determinations  (to select
between two opposing conditions) follow the DQO process during the planning stage of the
study. EPA's DQO guidance and related documents that can help you plan your monitoring
program are available on the Internet at www.epa.gov/qualityl/. Another valuable resource is
Quality Planning for the Life Science Researcher: Meeting Quality Assurance Requirements
(Cross-Smiecinski and Stetzenbach, 1994).  Additional information on DQOs is provided in
Appendix!                                                            •    .

An SOP is a written document that describes in detail the method for a-given operation, analysis,
or action.  It should be used for technical (not administrative) activities that need to be performed
the same way every time, i.e., are standardized. Such activities may include, but are not limited
to, field sampling, laboratory analysis, software development, and database management. The
methods can be presented in sequential steps and can include specific facilities, equipment,
materials and methods, quality assurance (QA) and quality control (QC) procedures, and other
factors required to perform the operation, analysis, or action. The format and content
requirements of an SOP are flexible because the content and level of detail in the SOPs  will  vary
according to the nature of the procedure being performed.

4.2.2.2 Staffing Monitoring Programs

A monitoring plan should also include an EPA-approved staffing plan for the beach monitoring
program. EPA recommends that professional staff from state, tribal, and local agencies monitor
most beaches.

4.2.2.3 Training Monitoring Staff

Once the monitoring program and sampling plan have been developed, the staff that will
implement the program should receive specific training. Whether drawn from the ranks of
professional staff or volunteers, the personnel responsible for sample collection and
environmental measurements at the beach, as well as those performing the bacterial indicator
analyses, should be trained for those activities. The quality of information produced by a
monitoring program depends on the quality of the work undertaken by field and laboratory staff.
Separate training programs should be developed for field staff, laboratory staff, and others
involved in the monitoring program. Training should continue for as long as the monitoring
program is in action. Additional information on training is provided in Appendix  J.

4.2.2 A Managing Data

One of the most important aspects of a monitoring program is the management of the data, from
the collection process through the data analysis. Data management activities include
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters	

 documenting the nature of the data and subsequent analyses in a manner that permits the
 comparison of the data in one set with those in other data sets. Data management also includes
 handling and storing both hard copies and electronic files containing field and laboratory data. A
 data management system that will address the multiple needs of data users should be designed at
 the beginning of the monitoring program. It is important to understand and comply with all
 policies and standards in use at your agency regarding data collection and generation.

 Computers
 The quality of the computer equipment that will be used to store and analyze data should be
 considered first. Your agency may specify procedures for selecting or developing appropriate
 hardware and software for projects involving information management, traditional data and
 geospatial analysis, database management, mathematical modeling, literature search, graphic
 presentation, and document publishing.

 The computer software you use should be recognized by the computer industry and similar users
 as currently suitable and reliable. The software should also be compatible within the agency or
 compatible with other agencies' software, if necessary. For example, if data need to be
 transferred from a county health department to the state health department to meet reporting
 requirements, the database system selected should be the same as the state's or one that permits
 seamless data transfers without corrupting parameter fields or values.

 Related Databases
 Another example of the need to transfer data is providing data to update national ambient water
 quality databases with the results of local beach monitoring.  EPA strongly encourages beach
 managers (and volunteer monitors) to add their data to EPA's storage and retrieval (STORET)
 database. EPA maintains two data management systems containing water quality information for
 the nation's waters: the Legacy Data Center, and STORET. The Legacy Data Center, or LDC,
 contains historical water quality data dating back to the early part of the 20th century and
 collected up to the end of 1998. STORET contains data collected beginning in 1999,  along with
 older data that have been properly documented and migrated from the LDC.  Both systems
 contain raw biological, chemical, and physical data on surface and ground water collected by
 federal, state, and local agencies, Indian tribes, volunteer groups, academics, and others. Each
 sampling result in the LDC and in STORET is accompanied by information on where the sample
 was taken (latitude, longitude, state, county, Hydrologic Unit  Code, and brief site identification),
 when the sample was gathered, the medium sampled (e.g., water, sediment, fish tissue), and the
 name of the organization that sponsored the monitoring. Staff working with the database should
 have expertise and training in the software, as well as in the procedures for data transport, file
 transfer, and system maintenance.  Additional information .on STORET can be found at
 http://www.epa.gov/storet/.

The operation of the data management system should include QA oversight and QC procedures.
If changes in hardware or software become necessary during the course of the project, the data
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                                                                                Chapter4
manager should obtain the most appropriate equipment and test it to verify that the equipment
can perform the necessary jobs. Appropriate user instructions and system documentation should
be available to all staff using the database system.  The development of spreadsheet, database,
and other software applications involves performing QC review's of input data to ensure the
validity of computed data.

4.2.2.5 Program Implementation and Oversight

The monitoring program should be implemented and its effectiveness assessed at regular
intervals. The purpose of assessments such as surveillance, readiness reviews, technical systems
audits, performance evaluations, and audits of data quality is to determine whether the
established QC procedures are being used and how the program is operating. Checklists or
reviews of program documentation and reports can be used to evaluate different aspects of the
program. The types and number of assessments to be performed can be documented in the
monitoring program oversight plan. In addition, the program should clearly provide for the
authority of the assessor (e.g., a QA officer) to stop work and should identify under what
conditions this may occur.

The QA program should include procedures for identifying and defining a problem, assigning
responsibility for investigating the problem, determining the cause of the problem, assigning
responsibility for implementing corrective action, and assigning responsibility for determining
the effectiveness of the corrective action and verifying that the corrective action has eliminated
the problem.  Supervision is important during the program. To provide advice and identify
problems when they occur, personnel providing oversight to technical staff should be well versed
in the procedures they are performing.  This proficiency is needed whether in the field
performing the sampling or in the laboratory performing the microbiological analyses.

Public Comment

The BEACH Act requires states and tribes, as a condition for receiving 406 grants, to provide the
public with an opportunity to review the monitoring and notification program. This need not be
addressed as part of the Public Notification and Risk Communication Plan, if it is elsewhere in a
state's program. Note, providing public comment in addressed in Chapter 2 as Performance
Criterion number 9.

4.3    Monitoring Report Submission and Delegation

The third performance criterion is for states and tribes to compile and report their data in timely
reports and to describe  any delegation of monitoring and notification responsibilities that might
have been made to local governments.
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters                    	

 Delegation
 EPA encourages states to coordinate with local governments and to delegate, as appropriate,
 responsibilities for monitoring programs to local governments. Local governments have
 traditionally played the lead role in administering beach protection programs. There are many
 reasons for the local level to take responsibility in protecting recreational waters. For example,
 local citizens and officials are more familiar with local problems and needs and are in a better
 position to address local issues and formulate solutions. Also, many of the benefits of protecting
 natural resources, in this case coastal recreation waters, accrue at the local level.

 Report Submission
 States and tribes must report their monitoring data to the public, EPA, and other agencies in a
 timely manner. States and tribes must also report the actions they have taken to notify the public
 when water quality standards are exceeded. To meet this criterion, states and tribes should
 coordinate closely with local governments to  acquire information and ensure that it is submitted
 in a consistent fashion. Timely submission of compatible electronic files is a critical component
 of this reporting requiremnt. Comparability with EPA's National Health Protection Survey of
 Beaches is also a very important factor.

 4.4    Assessment Methods and Procedures

 States and tribes also must identify assessment methods and procedures for their coastal
 recreation waters.  Strict adherence to specific procedures for sampling is critically important for
 successful beach monitoring program.  Collection, preservation, and storage of water samples are
 critical to the results of water quality analyses for bacterial indicators at swimming beaches.
 States and tribes should make every effort to adequately develop these procedures and the
 various subparts described below.

 This section and Appendix K discuss the basic equipment and techniques used to obtain water
 samples.  You should determine the most appropriate sampling procedures for your beach
 monitoring program based on your sampling design, the availability of facilities and equipment,
 and how, the samples will be processed. In any case, it is important to develop a written plan or
 SOPs that document the materials  used and the steps performed to obtain the samples and submit
 them to a  laboratory for analysis.

 Appendix K outlines the EPA-recommended SOPs for sample collection, handling, and
 subsequent analysis.

 4.4.1   Laboratory Analysis

 An essential component of the beach monitoring program is the selection of a laboratory
 experienced in performing microbiological techniques that can provide results in conformarice
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                              •	                                  Chapter 4

 with the standards you have established for precision and bias (accuracy).  Your agency might
 already have such a laboratory, or you might decide to contract with a laboratory.  An accredited
 laboratory should be used to obtain data when beach advisory or closing decisions are to be
 made.

 Policies and procedures for obtaining necessary laboratory and analytical services should be
 developed as part of this performance criterion.  Analytical laboratories should have the
 capability to analyze the quantity of samples requested within the required time period, the
 instrumentation/technique expertise to perform the required analyses, and qualified staff to
 perform the analyses (USEPA, 1998b). Not only do microbiological techniques call for strict
 adherence to specified methods, but staff also need to avoid introducing microorganism
 contaminants into media, thereby producing incorrect results. Facilities need to be equipped with
 proper ventilation and equipment; surfaces need to be kept clean and disinfected on a regular
 basis.  Staff need to have received extensive training in a variety of techniques for the detection
 of heterotrophic bacteria and other microorganisms and be able to meet the standards set for
 preparation of sterile media, inoculation procedures, colony counts, and other aspects involved in
 the analysis  of bacterial densities in surface water samples.

 SOPs covering general laboratory operations, as well as specific procedures,  should be approved
 and issued by the laboratory's QA Officer. Copies of all approved laboratory operations SOPs
 should be kept on file. Laboratory operations SOPs usually include discussion of responsibilities
 for performing and overseeing the work; possible interferences that might affect the analyses;
 safety considerations; QC activities, equipment, materials, reagents, and standards needed for the
 analyses; the steps of the procedure in chronological order; an explanation of how data should be
 analyzed and reported; references; and associated documents and forms. The laboratory should
 maintain log books for sample receipt, preparation of standards and media, sample analysis,
 instrument runs, and instrument maintenance. The laboratory should have an established quality
 management plan that specifies the quality policy, staff responsibilities, record management,
 types of assessments performed to evaluate the analyses, and how corrective  actions are
 addressed.

 Further discussions of good laboratory practices, requirements for equipment and supplies,
 training programs for  staff, QA/QC issues, and health  and  safety considerations for
 microbiological laboratories are provided by Cross-Smiecinski and Stetzenbach (1994), Eaton et
 al. (1995), and Csuros and Csuros (1999).  A capable lab should be accredited. Accreditation
 means that the laboratory has been investigated and found  to meet the standards and criteria set
 by an appropriate accrediting agency, including having qualified personnel, appropriate
 instrumentation, SOPs, and demonstrated proficiency in the analysis of samples for particular *
bacterial indicators. Laboratory accreditation is available through EPA's National Environmental
Laboratory Accreditation Program (NELAP), which oversees state accrediting authorities.
Further information on NELAP is available on the Internet at the National Environmental
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters         	;	

 Laboratory Accreditation Conference (NELAC) web site, www.epa.gov/ttn/nelac. NELAC is a
 voluntary association of state and federal agencies that was formed to establish and promote
 mutually acceptable performance standards for the operation of environmental laboratories.

 Your agency's policies and procedures for purchasing analytical services should be reviewed to
 determine their suitability for implementing the beach monitoring program. Of particular
 importance are the specification of method requirements that will be used to identify bacterial
 indicator levels in the water samples, the number of samples that will be submitted for analysis,
 the frequency of submittals, the schedule and turnaround time for results, deliverables and
 reporting format, and contractual requirements, including penalty or damage clauses to reduce
 laboratory default, late data submittals, and improperly performed analyses. Further guidance on
 soliciting and awarding contracts for analytical services is provided in EPA's Guide to
 Laboratory Contracting (USEPA, 1998b).

 4.4.2  Analytical Procedures

 Many methods are available to detect the presence of bacterial indicators. Well-developed
 analytical methods with published standard procedures issued by well recognized standard-
 setting bodies (e.g., American Society for Testing and Materials  [ASTM]) can be used.
 However, documentation supporting the validity of methods other than those currently
 recommended by EPA must be provided.

 Membrane filtration (MF) and most probable number (MPN) are two types of methods that are
 currently used for enumerating E. coli and enterococci in ambient water.  MF is a direct-plating
 method in which sample dilutions/volumes are filtered through membrane filters that  are
 subsequently transferred to petri plates containing selective primary isolation agar or an
 absorbent pad saturated with selective broth.  A second substrate medium is used in the two-step
 MF procedures to confirm or differentiate the target organisms. In MPN tests, the number of
 tubes or wells producing a positive reaction provides an estimate of the original, undiluted
 density (concentration) of target organisms in the sample. This estimate of target organisms,
 based on probability formulas, is termed the most probable number. MPN tests can be conducted
 in multiple-tube fermentation (MTF), multiple-tube enzyme substrate, or multiple-well enzyme
 substrate formats.

 Four membrane filter methods are currently recommended by EPA for making decisions
 concerning the protection of human health at beaches. (EPA is currently reviewing additional
 analytical methods that will be published as proposed regulations under 40 CFR Part 136.)

EPA recommends the following membrane filter techniques for detecting enterococci  in water:

EPA Method 1600 (mEI media): Method 1600 is a single-step MF procedure that provides a
direct count of bacteria in water, based on the development of colonies on the surface  of a filter
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                                                                                Chapter 4
when placed on selective mEI agar (USEPA, 1997a). This medium, a modification of the mE
agar in EPA Method 1106.1, contains a reduced amount of 2-3-5-triphenyltetrazolium chloride,
and an added chromogen, indoxyl-p-D-glucoside. The transfer of the filter to EIA is eliminated,
thereby providing results within 24 hours. In this method, a water sample is filtered, and the
filter is placed on mEI agar and incubated at 41 ± 0.5 °C for 24 hours.  Following incubation, all
colonies with a blue halo, regardless of colony color, are counted as enterococci. Results are
reported as enterococci per 100 mL.

EPA Method 1106.1 (mE media): EPA Method 1106.1 is a two-step MF procedure that provides
a direct count of bacteria in water, based on the development of colonies on the surface of a
membrane filter when placed on a selective nutrient medium (USEPA, 1985b). A water sample
is filtered through a 0.45-um membrane filter, and the filter is placed on a plate containing
selective mE agar. After the plate is incubated at 41 ± 0.5 °C for 48 h, the filter is transferred to
an Esculin iron  agar (EIA) plate and incubated at 41 ±0.5 °C for 20 to30 minutes.  After
incubation, all pink to red colonies on the mE agar that form a black or reddish-brown precipitate
on the underside of the filter when placed on EIA are counted as enterococci. The organism
density is reported as enterococci per 100 mL.

EPA recommends the following membrane filter techniques for detecting E. coli in water:

ModifiedEPA Method 1103.1 (Modified mTEC Media): Modified EPA Method 1103.1 is a
single-step MF  procedure that provides a direct count of E. coli in water based on the
development of colonies on the surface of a filter when placed on a selective modified mTEC
medium (USEPA, 1985a). This is a modification of the standard mTEC media that eliminates
bromcresol purple and bromphenol red from the medium, adds the chromogen
5-bromo-6-chloro-3-indoyl-D-glucuronide (Magenta Glue), and eliminates the transfer of the
filter to a second substrate medium. In this method, a water sample is filtered through a 0.45-um
membrane filter. The filter is placed on modified mTEC agar, incubated at 35 ± 0.5 °C for 2
hours to resuscitate injured or stressed bacteria, and then incubated for 23 ± 1 hours in a 44.5 ±
0.2 °C water bath. Following incubation, all red or magenta colonies are counted as E. coli.

EPA Method 1103.1 (mTEC Agar): EPA Method 1103.1 is a two-step procedure that provides a
direct count of E. coli in water based on the development of colonies on the surface of a
membrane filter when placed on a selective nutrient and substrate medium (USEPA,  1985a).
EPA originally developed to monitor the quality of recreational water. This method was also
used in health studies to develop the bacteriological ambient water quality criteria for E. coli. In
this method/a water sample is filtered through a 0.45-um membrane filter, the filter is placed on
mTEC agar (a selective primary isolation medium), and the plate is incubated first at 35 ± 0.5 °C
for 2 hours to resuscitate injured or stressed bacteria and then at 44.5 ± 0.2 °C for 23 ± 1 hours in
a water bath. Following incubation, the filter is transferred to a filter pad saturated with urea
substrate medium.  After 15 minutes, all yellow or yellow-brown colonies (occasionally
yellow-green) are counted as positive for E. coli using a fluorescent lamp and either a magnifying
lens or a stereoscopic microscope.
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters	

 A new EPA video, "Improved Enumeration Media for E. coli and Enterococci," demonstrates the
 four methods currently recommended by EPA, including the mE and the mEI agar methods for
 enterococci and the modified mTEC and mTEC agar methods for E. coli. The purpose of the
 video is to introduce and demonstrate the improved methods.  Accompanying the video is a
 laboratory manual that explains all four methods in a step-by-step format. The laboratory manual
 also contains color photographs of the target colonies on all media to aid in identification. The
 new video and methods manual are now available to state, tribal, and private laboratories.
 Requests for copies of the manual (Improved Enumeration Methods for the Recreational Water
 Quality Indicators: Enterococci and Escherichia coli, (EPA-821-R-97-004) or videotape (EPA-
 822-V-99-01) (USEPA, 2000) should be directed to EPA's National Service Center for
 Environmental Publications (http://www.epa.gov/ncepihom/).  The manual is also available on
 the Internet at www.epa.gov/OST/beaches or www.epa.gov/microbes.

 4.4.3  Recommended Sample Collection Techniques

 Strict adherence to specific procedures for sampling is criticially important for a successful  beach
 monitoring program. This can be accomplished through an EPA-approved plan or SOP for
 obtaining samples and submitting them for analysis. Proper collection, preservation, and storage
 of water samples are critical to accuracy of the results of water quality analyses for bacterial
 indicators at swimming beaches. This section and Appendix K discuss the basic equipment and
 techniques used to obtain water samples. You should determine the most appropriate sampling
 procedures for your beach monitoring program based on your sampling design, the availability of
 facilities and equipment, and how the samples will be processed. For example, your agency's
 facility might sterilize sample containers before each visit to the beach, the laboratory performing
 the analyses might provide its own sterile containers under contract, or your agency might
 purchase sterile containers from a scientific supply company for the season's sampling effort. In
 any case, it is important to develop a written plan or SOP that documents the materials used and
 the steps performed to obtain the samples and submit them to a laboratory for analysis.
 Appendix I outlines the EPA-recommended SOPs for sample collection, handling, and
 subsequent analysis.

 4.4.4  Data Verification and Validation

 Certain procedures should be used to verify whether the microbiological analyses have correctly
 estimated the densities of indicator bacteria, to ascertain whether particular requirements for a
 specified use of the results have been fulfilled, and to determine how the data should be
 interpreted for decision making.  This section discusses some of the important aspects of these
procedures, which should be included in the monitoring program design to ensure that the data
 obtained are usable and defensible.  Several iterations through these activities might be necessary
to ensure that the data and their interpretation are correct.
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                                                                                          Chapter 4
         Verification Methods

         Verification refers to confirming, by examining and providing objective evidence, that specified
         requirements have been fulfilled. Data verification is a systematic process to determine whether
         the data have been collected in accordance with the specifications of the QAPP (or other plan)
         with respect to compliance, correctness, consistency, and completeness. Data verification
         includes consideration of the data that were obtained, as well as data obtained from QC samples,
         and it assesses whether the measurement DQOs specified in the plan have been met.

         Procedures to verify whether the bacterial indicators were correctly determined should be
         provided for any method used. Verification involves performing additional tests to identify those
         colonies found on the membrane filter that provided information. A false positive rate is
         calculated as the percent of colonies that reacted (were identified as the indicator) but were not
         actually the indicator.  A false negative rate is calculated as the percent of colonies that did not
         react as anticipated (and so were not identified as the indicator) but were in fact that indicator.
         False positive and false negative rates for the media used in EPA Methods 1600 and 1103.1 are
         provided in those methods. Verification procedures should be used in establishing QC limits on
         initial use  of the procedure, when using a new technician to perform the procedure to ensure that
         method requirements can be met, whenever any changes are made in how the procedure is
         performed or in the materials used in the procedure, and always when the results are to be used in
         evidence for legal proceedings.

         Sample records, chain of custody records, and sample tracking records  should be reviewed to
         verify that all the samples collected were analyzed so that the data set will be complete.  Data
         entries and analyses should also be verified. The input of large quantities of data requires spot-
         checking to detect potential data entry errors. Additional checks include graphically displaying
         data to visually inspect for potential errors, using statistical methods to detect invalid data, and
         checking for duplicate data entries. Input data may be reviewed for accuracy, bias, completeness,
         precision,  representativeness, and/or uncertainty. In addition, data reductions and
         transformations should be reviewed (audited) to ensure that they have been correctly performed.
         Review of calculations includes rechecking the computations, reviewing the assumptions used
         and the selection of input data, and checking the input data against the  original sources to be sure
         transcription errors have not occurred. The types of calculations that might be performed on
         bacterial indicator filter counts to estimate bacterial densities per sample are provided in the EPA
         methods.  Further examples are shown in Standard Operating Procedure for Recreational Water
         Collection and Analysis ofE. coli in Streams, Rivers, Lakes and Wastewater (HTF,1999).

         Data verification is always followed by data validation (see below) and data analysis.  The
         reviewer should document the results and report them to the beach monitoring program
         management staff.  Verifying conformance of the data collection effort with the plan requires that
         the data pass the specified numerical QC tests  (precision and bias limits), that the plans were
         followed and calculations performed correctly, that all samples were treated consistently, and that
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters	

 the necessary quantity of data and information relative to the stated DQOs was obtained
 (completeness).  Any components requiring correction should be corrected if possible.  If data
 verification cannot be achieved, the data are not usable.

 Data Validation and Quality Assessment

 Validation refers to the confirmation that particular requirements for a specified intended use
 have been fulfilled. Thus, once the data have been confirmed to meet standards and contract
 requirements, they are systematically examined to determine their technical usability with respect
 to the planned objectives. This activity can also provide a level of overall confidence in the
 reporting of the data based on the methods used. For example, if the wrong medium was used or
 the incubation temperature limit was exceeded, these data would be assigned a qualifier
 indicating their uncertainty would be rejected from further analyses.  A report that provides an
 assessment of the usability of the data, a summary of environmental sample results, and a
 summary of QC and QA results should be prepared.  The report should discuss any discrepancies
 between the DQOs and the data collected and any effects such discrepancies might have on the
 ability to meet the DQOs.

 Finally, an assessment of data quality should be performed to evaluate whether the data are of the
 right type, quality, and quantity to support their intended use. This assessment includes
 reviewing the DQOs and sampling design, conducting a preliminary data review, selecting the
 statistical test, verifying the assumptions of the statistical test, and drawing conclusions from the
 data.

 4.5    Use of Predictive Tools in Beach Monitoring Programs

 A key objective of any beach monitoring program is to minimize beachgoers' health risk
 associated with infectious diseases caused by exposure to microbial organisms. Notifications of
 elevated levels of indicator bacteria are usually based on monitoring of beach waters. Under this
 system, however, users of recreational waters can be exposed to waterborne pathogens because of
 inadequate monitoring or delayed notification  of monitoring results during periods of poor water
 quality. The laboratory  methods commonly used to detect potentially harmful microorganisms
 take 24 to 48 hours. During this period, beachgoers can be exposed to harmful pathogens. To
 reduce exposure to pathogens, government agencies need tools that can provide a quick, reliable
 indication of the water quality conditions. Thus, these tools supplement monitoring and provide
 conservative estimates when there is a lag time between the water quality sampling and obtaining
 results.

 This section inventories  various predictive models or tools that are currently in use or can be
 used by local health agencies to evaluate the need for closing beaches or issuing advisories and
 warnings. Descriptions  of the potential predictive tools and their attributes are provided, as well
 as discussion of the limitations, the input data requirements, and the availability of each of the
predictive tools.
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                                                                                r.hapter4
4.5.1   Criteria for Evaluating Potential Models

A wide range of models are available and could be adapted to support beach advisory decisions.
If beach a manager chooses to use a predictive model, the model chosen for use should be
supported by identified selection criteria. Selection of the appropriate model for helping to
determine beach advisories and closings depends on the site conditions of the waterbody of
concern. Some of the site-specific considerations include the types of sources (point
source/nonpoint source), waterbody types, transport and circulation patterns, severity of
impairment, and frequency of indicator criteria exceedances. Other issues to consider are the
model development and application cost, the accuracy required, the use of the system, training ol
staff  and public outreach and education requirements. In some cases economies of scale can be
identified when related analysis and modeling efforts have been initiated in the waterbody of
concern.

If they are properly developed and applied, simple models for dilution and mixing zone
evaluations can be used in making beach advisory or closing decisions. More complex models
can also be considered in light of their ability to assess dynamic loading and transport processes.
Detailed models can be used in the development of a range of decision rules for categories ot
loading or  environmental conditions.  These decision rules can be used to address day-to-day
operations  in a cost-effective and timely manner.

In some cases objectives can best be met by using one model, whereas in others a combination of
models is needed. Models are often developed for a particular waterbody type, including rivers
and streams  lakes, and offshore  ocean waters. When determining the  type of model to use,
factors such as data needs, application cost, pollutant type, and required accuracy are important to
consider. The selection of the appropriate model can be based on the following screening
factors:

 •  Combined point and nonpoint sources.  An important screening factor is how the model
    handles the loadings from point and nonpoint sources. Models based on water quality data
    implicitly take the point and  nonpoint sources into account, whereas models that use
    continuous simulation of the water quality directly account for the sources. Typically, the
    sources are part of the input parameters.  For example, the rainfall-based alert curves
    discussed later in this chapter are models based on the water quality conditions. Those
    models do not explicitly account for the point and nonpoint sources; instead, the sources
    affect the water quality parameters used in the model.  In the case of the CORMIX and
    PLUME models (described below), point sources are a component of the model input; the
  ,  flow and concentration must also be included.

  •  Pathogen source characterization.  Pathogens found at a beach site of interest might be from
    point sources, including sewage treatment plants, sanitary sewer overflows (SSOs), combined
     sewer overflows (CSOs), and storm water outfalls, or nonpoint sources. Accounting for the
     different sources of pathogens might require the use and integration of a variety of models.
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National Beach Guidance and Grant Performance Criteria for Recreational Waters	              '     	

    Watershed loading models are used to characterize nonpoint sources of pathogens by
    providing concentration and flow rates of pathogens (pollutographs and hydrographs) or unit
    and total loads of pathogens. Because point sources of loadings are not dominated by wet
    weather conditions, loading can be easily estimated from the discharge and concentration.
    Once pathogen loads from point and nonpoint sources are determined, the next step is the
    routing of the pathogen through the system using a representative model of the dominant
    mixing and transport processes to estimate the pathogen concentration at the location of
    interest.

•   Dominant mixing and transport processes. The waterbody type dictates the dominant
    mixing and transport processes of a pollutant. In rivers and streams the dominant processes
    are advection and dispersion.  In estuaries these processes are influenced by tidal cycles and
    flows. Factors such as waterbody size and net freshwater flow are key in determining the
    dominant processes. For discharges in the ocean surf zone, dominant dispersion processes
    include mixture due to breaking waves and transport from nearshore currents.

•   Pathogen concentration prediction.  This factor describes the ability of the model to predict
    the pathogen concentration in the receiving water at the location of interest,  which in this
    case is a beach site.  Transformation processes such as bacterial kinetics also must be
    accounted for in the model to allow for a realistic prediction.

•   Ability to provide time-relevant analysis, decision making, and guideline establishment.
    Timely or time-relevant analysis is needed for an effective  advisory.  Models applied to
    predict water quality conditions can be used as a basis for decision making and as
    management tools. For example, a beach authority can use such tools as a basis for beach
    advisories following a rainfall event or an accidental sewage spill.

•   Time-relevant use. Under this category the input data needed, processing time, and
    postprocessing abilities of the model are evaluated. Potential predictive tools for beach
    advisories must be able to predict pathogen concentration at the site of interest in a relatively
    short amount of time.  This means that the data input requirements and processing time need
    to be minimal. Also crucial to the success of the predictive tool is the postprocessing of the
    output data. Tabular or graphical representation of the output data provides  a quick, easy way
    to interpret results and might serve as a basis for making time-relevant decisions concerning
    beach advisories.

•   Evaluation of unplanned and localized spills.  Spills of a pollutant can be caused
    accidentally by equipment failure or rainfall. In either case, this factor describes how the
    model handles the additional loading. Models based on water quality data do not account for
    this increased loading unless samples  were collected during rainfall or a spill event and
    analyzed, and the data  were then entered into the model database.  On the other hand, models
    that account for point sources can easily account for the increased loading by including the
    spill as an  input parameter.
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                                                                                 Chanter 4
•   Documented application to beach and shellfish closure. This factor describes the ability of
    the model to predict the water quality condition surrounding swimming and shellfish areas.
    Models can be used as water quality predictive tools and as a basis for decision making. For
    example, several communities use rainfall models, and the New York City metropolitan area
    uses the Regional Bypass Model (discussed later in this chapter). These models have proven
    to be effective tools to protect people from exposure to pathogens following rainfall events or
    sewage spills.

•   Ease of use. The level of user experience is an important factor in determining whether a
    model is easy to use.  Some complex models require a great deal of training and experience;
    simple methods require only a conceptual understanding of the processes, and results can be
    readily obtained.

•   Input data requirements.  Input data requirements are a function of a model's complexity. In
    general, complex models require more specific and complex input data than simple models.
    Some of these data might not be readily available, and acquiring such data might require
    expending resources.  Therefore, the objective of the model application can be very important
    in this step.

•   Calibration requirements.  Decision making and management alternatives based on
    modeling results require that the model outcome be acceptable and reliable. Not all models
    can be calibrated.  Models that simulate water quality conditions are calibrated against in-
    stream monitoring stations. Simple models such as the rainfall alert curves are continuously
    updated to provide accurate results. This is done by continually updating the model's
    database.

•   Pollutant routing.  Pollutant routing addresses how a model deals with the fate and
    transformation of pollutants.  Simpler models might not include processes that describe
    pollutant transformation. More complex models vary in their description of the processes.
    The range can be from a gross or a net estimate of the process to a detailed mechanism of the
    process.  The focus is on bacterial processes. In general, most environmental models use the
    first-order decay rate to represent the microbial death rate.

•   Kinetics of pathogen decay. The survival of pathogens (and pathogen indicators) in the
    environment is influenced by many variables, such as age of the fecal deposit, temperature,
    sunlight, pH, soil type, salinity, and moisture conditions. In general, the death rate of
    pathogens can be estimated as a first-order rate, which is incorporated into water quality
    models.

Predictive models are effective tools to supplement actual sampling.  It is important, however, to
consider that models do not provide perfect predictions of actual conditions but instead provide
estimates of current conditions. A public health manager should account for inaccuracies in
models when making decisions related to public health.
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters	

 4.5.2   Predictive Methods Currently Used by Beach Managers

 Two approaches were used to identify the predictive tools currently in use by local agencies.
 First, EPA's National Health Protection Survey of Beaches was used to identify local agencies
 that currently base their beach advisories on water quality model prediction. Those agencies
 were contacted regarding the types of models they use and information about extent of use,
 model developers, and availability.

 The second approach was a review of literature and information from previous EPA programs.
 This approach included reviewing the models and guidelines provided in the CWA section
 301(h) program, identifying tools used in the TMDL program, and reviewing other EPA
 publications that relate to water quality modeling. The beach closure predictive tools identified
 were characterized based on modeling or prediction application techniques and on modeling
 components.

 The tools currently in use by local and state agencies vary in their complexity and approach to
 minimizing exposure to pathogens. The cities of Milwaukee and Stamford and the Delaware
 Department of Natural Resources and Environmental Control (DNREC) .used regression analysis
 to relate rainfall to pathogen concentration. Models developed using this approach are site-
 specific because they are derived from locally observed water quality and rainfall data.

 Simulation of water quality conditions under a variety of scenarios of untreated or partially
 treated sewage can also be used. Comparison of the resulting water quality conditions to the
 established criteria can serve as the basis for the beach closure. The metropolitan Boston area in
 Massachusetts is undertaking such a project.  A predictive model that can predict water quality
 conditions resulting from bypasses of sewage at preselected locations was developed for the New
 York-New Jersey harbor. Beaches surrounding the discharge locations are closed whenever the
 predicted pathogen concentrations exceed the water quality criteria.

 Closure of beaches based on water quality modeling is also practiced in the states of Virginia and
 Washington. Computer models that predict pathogen concentration by simulating the dominant
 mixing and transport processes in the receiving water range from simple to very complex.  The
 Virginia Department of Health uses a simple mixing and transport model to predict water quality
 conditions surrounding wastewater treatment plant outfalls. Washington uses a more complex
 model, CORMIX, to predict water quality conditions surrounding wastewater treatment outfalls.
 Rhode Island is in the early stages of developing predictive models for its beaches. Review of
 Potential Modeling Tools and Approaches to Support the Beach Program (USEPA, 1999c)
 provides a detailed description of these tools and their attributes, limitations, data requirements,
 and availability.  A summary of the capabilities and applicability of these models is included in
 Table 4-4.
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                                                                                    Chapter 4
Table 4-4. Evaluation of model capabilities and applicability



Model
Rainfall-
based
Bypass
SMTM
PLUMES
CORMK
JPEFDC



Combined
PS/NPS"
XXX

x(PS)
x(PS)
x(PS)
x (PS)
XX
(NPS/PS)
Real Time
and
Decision
Making
XXX

XXX
XX
X
X
X




Spills
0

XXX
XX
XX
X
XXX

Application
to Beach or
Shellfish
Closure
XXX

XXX
XX
XX
X
XXX



Ease of
Use
XXX

XXX
XX
XX
XX
X


Input
Data
Required
X

XXX
X
X
X
XXX




Calib.
XX

X
X
X
X
XX




Developing
Guidelines
XX

XX
0
X
X
X




Pollutant
Routing
0

XXX
X
X
X
XXX

 0     Not applicable
 x     Low applicability
 xx    Medium applicability
 xxx    High applicability                                                      ,
 • Point Source/Nonpoint Source

4.5.2.1 Rainfall-based Alert Curves

A rainfall-based alert curve is a statistical relationship between the amount of rainfall at
representative rainfall gauges in the watershed and the observed bacterial indicator concentration
at a specific beach area. This relationship is based on simple regression methods and the
frequency of exceedance of simultaneous and representative observations of bacterial indicator
concentrations and rainfall events. Pathogen data supporting the development of rainfall-based
alert curves are generated from the water column concentrations obtained from ambient or
targeted monitoring programs.  Although these models do not explicitly account for point and
nonpoint sources or fate and transport processes, they rely on a direct statistical relationship and
provide simple, easy-to-use tools with reasonable accuracy.  Rainfall-based alert curves based on
regression analysis have been used for preemptive beach closure in Milwaukee, Wisconsin;
Stamford, Connecticut; Sussex County, Delaware; and the Boston, Massachusetts, area.

In the case of the city of Milwaukee, city of Stamford, and DNREC, the approach taken was
regression analysis to relate rainfall to pathogen concentration. Models developed based on this
approach are site-specific because they are derived from locally observed water quality and
rainfall data as well as beach location/configuration relative to pathogen sources.
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Objectives
The objective of rainfall-based alert curve models is to establish a statistical relationship between
rainfall events and bacterial indicator concentrations. This relationship can then serve as a
management tool for developing operating (advisory and closing) guidelines based on predicted
pathogen concentrations, which suggest the need to restrict or prohibit contact uses of recreation
waters. Several agencies have developed beach operating rules based on analysis of site-specific
relationships between rainfall and water quality monitoring data.  Delaware (DNREC, 1997) and
Connecticut (Kuntz, 1998) have successfully used this approach (USEPA, 1999).

Benefits
The rainfall-based alert curves are highly recommended as a predictive tool to determine the need
for beach advisories or closings because of their simplicity, ease of development and use,
economic feasibility, and virtually instantaneous run time.  A great advantage of rainfall-based
alert curves is that they can be easily translated to decision logic that a beach manager can use
without prior advanced training or a high level of technical skill.

Limitations
It is important to update your model with changes in your watershed or weather pattern.  Weather
patterns typically have cycles, so predictive models must reflect this variance or acknowledge
this limitation.  For example, rainfall based alert curves may not be appropriate for use along the
arid southern California coast because of an "impact lag" effect where discharges from storm
water outfalls can continue for several weeks following substantial rain events.

Overview of Rainfall-Based Alert Curves Technical Approach
Rainfall-based alert curves are developed in three phases: collecting data, analyzing data (linking
the rainfall events to bacterial indicators), and developing operating rules for advisories or
closings of recreational waters. Although EPA is currently supporting continued efforts in
research and development of these techniques, the Agency recommends that state, tribal, and
local beach managers consider developing scientifically based and easy-to-use site-specific
decision rules based on the technical approaches summarized below:

•  Rainfall-based models are site-specific, and their development requires relatively large sets of
   monitoring data for both rainfall and water quality. The overall relationship can be described
   by a statistical regression/estimation model.  Depending on the number of rainfall stations
   considered and the number of rainfall characteristics (amount, duration, lag  time, etc.), the
   relationship might require a more complex multiple-regression model. Because of the
   statistical nature of these types of models, they cannot distinguish  between point sources and
   nonpoint sources of pathogens and do not explicitly incorporate advection, transport, and
   decay processes. Also because their use is limited to assisting in the development of decision
   rules for advisories and closings of recreational waters, they do not attempt to provide the
   spatial and vertical distribution of pathogens.

•  Frequency of exceedance analysis is another rainfall-based method that can  be used to
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                                                                                 Chapter 4
   develop rainfall-based alert curves. An exceedance is defined as any time the observed
   pathogen concentration exceeds the action level, such as the state water quality standard,
   specified by a responsible agency.  The objective of this method is to determine the minimum
   amount of rainfall that causes the pathogen concentration to exceed the action level. This
   amount can be determined by dividing cumulative rainfall amounts over a period of 24 hours
   or more into segments that range from no rainfall to an upper limit that is representative of
   the rainfall record, types of storms, and season. For each rainfall amount category, the
   observed pathogen concentration or the geometric mean of multiple samples is  compared to
   the action level.

•  After establishing a relationship between rainfall amounts and pathogen concentrations,
   developing decision rules for advisories and closings is the next step. An advisory or closing
   threshold is determined based on the least amount of rainfall that would result in a violation
   of the action level.  This method applies to situations where historical rainfall data and water
   quality records exist.  Decision rules should also be developed to include seasonal variation
   in rainfall. EPA is currently developing guidance on a number of linear regression
   techniques that can be used by beach managers to evaluate the need for preemptive advisories
   or closures. When completed, this guidance will be included in National Beach Guidance
   and Grant Performance Criteria for Recreational Waters.

4.5.2.2 Other Predictive Tools to
       Supplement Sampling

The overall objective of beach closure
predictive tools is to minimize the
population's exposure to pathogens. The
tools currently in use by local agencies
vary in their complexity and approach to
minimizing exposure but are generally
simple, reliable tools. Figure 4-1 shows
other predictive tools that can be used to
determine the need for a beach closing.
The listed models are divided into two
categories—watershed pathogen loading
models and pathogen concentration
prediction models  The latter category is        ^ ^.^ ^  applicable to pathogens.
divided into two additional groups to
reflect the waterbody types: rivers and streams, and lakes and estuaries. Currently, there is a lack
of readily available models that address the coastal nearshore environment; therefore, no models
that study the surf zone are included in sections that follow.
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  Pathogen Loading Estimates
  Watershed loading models that can be used to estimate pathogen loadings to receiving waters are
  presented in Table 4-2. Three considerations are taken into account in the table—real-time
  prediction, source type, and land use type.
Table 4-2. Watershed-scale loading models



Watershed-scale
loading












HSPF:
Hydrological
Simulation
Program— Fortran
SWMM: Storm
Water Management
Model
STORM: Storage,
Treatment,
Overflow, Runoff
Mode]
Real- time Prediction
Data
Needs
X



X


X



Processing
Time
X



X


X



Source Type
PS

XX



X


X



NPS

X



X


X



CSO





XX


X



Land Use Type
Urban

X



XX


XX



Rural

XXX



X






  x    Low data requirements/applicability
  XX    Medium data requirements/applicability
  xxx   High data requirements/applicability

 Potential sources of pathogens include point sources (including CSOs) and nonpoint sources.
 Models differ in their ability to account for these various source types. Models that simulate
 nonpoint sources are  capable of describing the pathogen buildup processes during dry weather
 and washoff processes related to rainfall-generated runoff. Accounting for the various land uses
 is very important in estimating the nonpoint source loadings because the processes of buildup
 and washoff are land-use-specific. CSO loading is a function of the hydraulic routing and the
 storage capacity within the publicly owned treatment works (POTW).  Therefore, a model's
 ability to deal with the complex land uses in the watershed is an important factor in model
 selection and applicability. The key loading models suited for real-time prediction summarized
 in Table 4-2 are briefly described in Appendix L.

Pathogen Concentration Prediction
Loading  models, depending on the simulation type, provide estimates of either the total water and
pollutant loading or a time series loading of water and pollutants. Pathogen concentration
prediction is the process of describing the response of the waterbody to pollutant loadings, flows,
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                                                                                Chanter 4
and ambient conditions.  Because the response is specific to the waterbody, different types of
models are required for accurate simulation, as shown in Table 4-3.  The models are divided into
two categories on the table—rivers and streams, and lakes and estuaries.

Rivers and Streams.  Prediction of pathogen concentration in rivers and streams is dominated by
the processes of advection and dispersion and the bacteria indicator degradation. One-, two-, and
three-dimensional models have been developed to describe these processes, as shown in Table 4-
3. Waterbody type and data availability are the two most important factors that determine model
applicability. For most small and shallow rivers, one-dimensional models are sufficient to
simulate the waterbody's response to pathogen loading. For large and deep rivers and streams,
however, the one-dimensional approach falls short of describing the processes of advection and
dispersion. Assumptions that the pathogen concentration is uniform both vertically and laterally
are no longer valid. In such cases two- or three-dimensional models that include a description of
the hydrodynamics are used. The river and stream models summarized in Table 4-3 are briefly
described in Appendix L.

Lakes and Estuaries. Predicting the response of lakes and estuaries to pathogen loading requires
an understanding of the hydrodynamic processes.  Shallow lakes can be simulated as a
simplified, completely mixed system with an inflow stream and outflow stream. However,
simulating deep lakes with multiple inflows and outflows that are affected by tidal cycles is not a
simple task.  Pathogen concentration prediction is dominated by the processes of advection and
dispersion, and these processes are affected by the tidal flow. The size of the lake or the estuary,
the net freshwater flow, and wind conditions are some of the factors that determine the
applicability of the models. The lake and estuary models summarized in Table 4-3  are briefly
described in Appendix L.

Table 4-3. Potential pathogen fate and transport models
Model Name
HSPF: Hydrological Simulation Program — Fortran
CE-QUAL-RIV1 : Hydrodynamic and Water Quality
Model for Streams
CE-QUAL-ICM: A Three-Dimensional, Time-
Variable, Integrated-Compartment Eutrophication
Model
Time-Relevant
Prediction
Data Needs
XX
XX
XXX
Processing
Time
X
XX
XXX
Waterbody Type
Rivers
and
Streams
X
X
X
Lakes &
Estuaries
N/A
N/A
XX
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Rational Beach Guidance and Grant Performance Criteria for Recreational Waters
Model Name
CE-QUAL-W2: A Two-Dimensional, Laterally
Averaged, Hydrodynamic and Water Quality Model
WASPS: Water Quality Analysis Simulation
Program
EFDC: Environmental Fluid Dynamics Computer
Code
QUAL2E: Enhanced Stream Water Quality Model
TPM: Tidal Prism Model
Time-Relevant
Prediction
Data Needs
XXX
XX
XX
X
X
Processing
Time
XX
XX
XX
X
X
Waterbody Type
Rivers
and
Streams
XX
XX
xx
X
N/A
Lakes &
Estuaries
X
XX
XX
N/A
X
 x      Low applicability
 xx     Medium applicability
 xxx    High applicability
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                                                                              Chapter 4
4.4    References

Cross-Smiecinski, A., and L.D. Stetzenbach. 1994. Quality Planning for the Life Science
Researcher: Meeting Quality Assurance Requirements. CRC Press, Boca Raton, FL.

Csuros, M., and S. Csuros.  1999. Microbiological Examination of Water and Wastewater.
Lewis Publishers, Washington, DC.

DNREC. 1997. Swimming (Primary Body Contact) Water Quality Attainability for Priority
Watersheds in Sussex County. Delaware Department of Natural Resources and
Environmental Control, Dover, DE.

Eaton, A.D., L.S. Clesceri, and A.E. Greenberg, eds. 1995. Standard Methods for the
Examination of Water and Wastewater,  19th ed. American Public Health Association, American
Water Works Association, and Water Environment Federation, Washington, DC.

IITF.  1999. Standard Operating Procedure for Recreational Water Collection and Analysis of
E. coli on Streams, Rivers, Lakes and Wastewater. Indiana Interagency Task Force on E. coli.
LaPorte County Health Department, Laporte, IN.

Kuntz, J.E. 1998.  Non-point Sources of Bacteria at Beaches. City of Stamford Health
Department, Stamford, CT.

USEPA. 1985a. "Test Method 1103.1: Escherichia coli in water by the membrane filter
procedure" In Test Methods for Escherichia coli and Enterococci in Water by the Membrane
Filter Procedure. EPA-600-4-85-076. U.S. Environmental Protection Agency, Office of
Research and Development, Environmental Monitoring Support Laboratory, Cincinnati, OH.

USEPA. 1985b. Test Method 1106.1: Enterococci In Water By The Membrane Filter Procedure.
In Test Methods For Escherichia coli and Enterococci In Water By the Membrane Filter
Procedure. EPA-600-4-85-076. U.S. Environmental Protection Agency, Office of Research and
Development, Environmental Monitoring Support Laboratory, Cincinnati, OH.

USEPA. 1991. Monitoring Guidance for the National Estuary Program. EPA 503/8-91-002.
U.S. Environmental Protection Agency, Office of Water, Washington, DC.

USEPA. 1994. Guidance for the Data  Quality Objectives Process. EPA/600/R-96/055. U.S.
Environmental Protection Agency, Office of Research and Development, Washington, DC.

USEPA. 1997a. Method 1600: Membrane Filter Test Method for Enterococci in Water. EPA-
821-R-97-004. U.S. Environmental Protection Agency, Office of Water, Washington, DC.

USEPA. I997b. Monitoring Guidance for Determining the Effectiveness of Nonpoint Source
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                                                                                   4-25-

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  National Beach Guidance and Grant Performance Criteria for Recreational Waters	

  Controls. EPA 841-B-96-004. U.S. Environmental Protection Agency, Office of Water,
  Washington, DC.

  USEPA. 1998b. Guide to Laboratory Contracting U.S. Environmental Protection Agency,
  Office of Water, Washington, .DC.

  USEPA. 1998c. The EPA Quality Manual for Environmental Programs. EPA Manual 5360.
  U.S. Environmental Protection Agency, Office of Research and Development, Washington, DC.

  USEPA. 1999c. Review of Potential Modeling Tools and Approaches to Support the BEACH
  Program. EPA 823-R-99-002. U.S. Environmental Protection Agency, Office of Science and
  Technology, Washington, DC.

  USEPA. 2000. Improved Enumeration Methods for the Recreational Water Quality Indicators:
 Enterococci and Escherichia coli. EPA-821-R-97-004. U.S. Environmental Protection Agency,
 Office of Science and Technology, Washington, DC.
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                                                                                Chapter 5
Chapter 5: Public Notification and Risk Communication

This chapter describes the performance criteria and technical guidance related to the public
notification and risk communication portions of a beach program.

5.1    Performance Criteria

Four primary Performance Criteria are related to public notification and risk communication
(Performance Criteria 5, 6, 7, and 8).

Public Notification and Risk Communication Plan (Performance Criterion 5). The state or
tribe must develop an overall public notification and risk communication plan. The plan must
describe the state's or tribe's public notification efforts and measures to inform the public of the
potential risks associated with water contact activities in the coastal recreation waters that do not
meet applicable water quality standards.

Within this overall plan, the state or tribe should pay special attention to three areas highlighted
by the Beach Act.

Measures to Notify EPA and Local Governments (Performance Criterion 6). The state or
tribe should adequately identify measures for prompt communication of the occurrence, nature,
location, pollutants involved, and extent of any exceeding of, or likelihood of exceeding,
applicable water quality standards for pathogens and pathogen indicators. The state or tribe
should identify how  this information will be promptly communicated to EPA and to a~designated
official of the local government having jurisdiction over land adjoining the coastal recreation
waters for which the failure to meet applicable standards is identified.

Measures to Notify the Public (Performance Criterion 7). A state or tribal program must
adequately address the posting of signs at beaches or similar points of access, or functionally
equivalent communication measures that are sufficient to give notice to the public that the coastal
recreation waters are not meeting or are not expected to meet applicable water quality standards
for pathogens and pathogen indicators.

Notification Report Submission and Delegation (Performance Criterion 8). The eighth
performance criterion is for states and tribes to compile their notification plans in timely reports
and to describe any delegation of notification responsibilities that might have been made to local
governments. See section 5.2.4 for more detail.

5.2    Public Notification and Risk Communication Plan

The required Public  Notification and Risk Communication Plan should adequately address the
following aspects:

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 National Beach Guidance and Grant Performance Criteria for Recreational Waters	'

 •  Problem assessment and audience identification
 •  Content and procedures for public notification
 •  Evaluation of notification program's effectiveness
 •  Report submission and delegation

 Note, the BEACH Act requires states and tribes, as a condition for receiving 406 grants, to
 provide the public with an opportunity to review the monitoring and notification program. The
 Performance Criterion for public comments is explained in Chapter 2.

 5.2.1  Problem Assessment and Audience Identification

 During the problem analysis phase, the state or tribe should identify specific objectives to be
 accomplished by a beach notification and risk communication program. Beach program
 objectives can include general goals, objectives that reflect the agency's mission and mandate, or
 more specific and measurable program goals.

 The audience identification and needs assessment phase includes identifying and characterizing
 the potential target audiences for beach advisories or closings. During this phase,  the beach
 manager or agency determines what types of information and communication styles are
 appropriate for each audience. You need to consider the objectives of the notification and risk
 communication program and the range of behavioral and sociodemographic groups of people that
 might be affected by that program.  Because the different characteristics of beach users might call
 for different methods of communication, you should use care when identifying all potential target
 audiences. For example, a sign posted at the beach entrance could be used for local beach users,
 while a message on an Internet web site or telephone hotline could be used to notify tourists who
 live farther away.

 The public can and should be part of the process of identifying information needs. It is important
 for communicators to understand the linkages between the public's behavior, knowledge, and
 beliefs. It is critical in designing a communication strategy to understand which information
 sources audiences will use to obtain beach information.

 If the population in your area is diverse in its ethnic makeup or your area receives international
 visitors, it might be beneficial to include  advisories in both English and other languages. This
 advice applies particularly to the portion of the advisory that explains health risks to the public.
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                                                                                       Chanter 5
                                  Example of Notice in Spanish

     Coliforms fecales o E.coli son bacterias cuya presencia indica que el agua esta contaminada con
     desechos humanos o de animates. Microbios de esos desechos pueden causar diarrhea, colicos,
     nausea, dolores de cabeza u otros sintomas. Pueden representar un peligro para la salud de infantes,
     ninos y ninas de corta edad y personas con sistemas immunologicos en alto riesgo.
5.2.2   Content and Procedures for
        Public Notification

5.2.2.1 Message: Developing the Content
        of Advisories and Closings

The most important information to include
in a public notification is that swimming is
not advisable because of high microbial
indicator levels detected in the water.
When a sign is posted to notify the public,
the content should be simple and state that
an advisory or closing is being issued
because of high indicator levels.
However, when issuing public notices or
press releases or notifying the public
through a newspaper, it is appropriate to
include additional information because the
writing space is not as limited.

An advisory or closing should include the
following information:

•   General heading: Words to the effect
    of "WARNING," "ADVISORY," or
    "BEACH CLOSED."

•   Reason for the advisory or closing:
    Exceedance of water quality criteria (if
    known) and risk of potential health
    effects (nausea, diarrhea, headaches,
    cramps, or other symptoms).
   AB411 - California Requirement for Signs

Sign information: For public beaches or ocean water
contact sports areas closed because of a release or
spill of untreated or inadequately treated sewage or
for failure to meet microbiological indicator
organism standards, warning signs shall be visible
from each legal primary beach access point, as
identified in the coastal access inventory prepared
and updated...and any additional access points
identified by the health officer.

Example: WARNING! CLOSED TO SWIMMING
AND OTHER WATER CONTACT.
BEACH/SWIMMING AREA IS
CONTAMINATED AND MAY CAUSE ILLNESS.
For a portion of a public beach or ocean water
contact sports area with a storm drain, warning signs
should be placed at the affected area and at other
locations determined by the local health officer (for
example, along walkways to the beach, park
entrances) where they are likely to be read.
Language should be similar to the following:

Example: WARNING! NO SWIMMING OR
OTHER WATER CONTACT. STORM DRAIN
WATER MAY CAUSE ILLNESS.   ..

Signs should be large enough to be clearly visible
and legible.  They should be posted in English and a
second language, as deemed appropriate by the local
health officer, if a large percentage of users of the
public beach or water contact sports area understand
only that language. For example, a variation of the
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters             	        -

 You should explain briefly that you routinely test the water and that the most recent samples
 indicate an exceedance of the water quality criteria.  Appropriate language might be, "We
 routinely monitor for the presence of bacteria in the water.  Our most recent sampling results
 indicated an exceedance of our action level.  Swimming is riot advised until [date/time]." You
 can also explain whether the exceedance is based on an instantaneous criterion or on a rolling
 average criterion. It might be helpful to explain the lag time associated with sample results,
 noting that the sample might have been taken 24 hours before the advisory or closing.  Finally,
 listing the source of the contamination reassures the public that you have investigated the
 problem and are taking steps to address it (USEPA, 1999).

 •   Time and duration of the advisory or closing: When the sampling was performed and the
    results reported and when the advisory or closing is expected to be removed. Identify
    whether the advisory or closing will be in effect until further notice or until the samples
    obtained meet a certain criterion.

 •   Location involved: Beach(es), county, park, or miles affected.

 •   Agency name and contact number.

 Table 5-1 at the end of this chapter provides suggestions for the content of advisories and
 closings.

 5.2.2.2 Types of Notification

 Measures such as beach closings or advisories should be used to inform the public of the
 potential risks associated with water contact activities in waters that do not meet applicable water
 quality standards.  Advisories' or closings as appropriate should be issued when indicator
 bacteria levels exceed the state or tribal water quality criteria for recreational waters.

 Beach Closings

 The term "beach closing" typically means that the beach area is officially closed to the public.
 The closing of a beach is a local decision; EPA  does not set beach closure requirements or
 conditions. EPA recommends, however, that a closing  be issued if there is an imminent public
 health hazard such as a sewage line break or other high-risk source.  During a closing, no one
 should be in the water. Lifeguards may or may not be present at the beach. The beach might be
 closed to the public temporarily or for an extended period (for the remainder of the swimming
 season).

Typical methods of enforcement include placing physical barriers so that the beach is  closed to
public access and issuing fines or citations to any person who uses the beach while it is posted as
closed. For example, in the city of Huntington Beach in California,  a person can be fined for
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                                                                                  Chapter 5
going into the water when there is a closing (USEPA, 2000).  In addition, having staff regularly
patrol the beach can ensure that it has officially been closed and that notification and risk
communication procedures have been followed as required.

Beach Advisories
                                                        Sample Advisory Sign

                                            The water in this lake serves many uses. It is here for
                                            your recreational use* as well as other uses like
                                            irrigation and domestic water supply. Like any natural
                                            water body, the water in this lake contains many
                                            naturally occurring microorganisms, some of which may
                                            cause illness if swallowed. Park staff regularly tests the
                                            water quality at the swim beach. However, if you
                                            believe you became ill from this water, contact the park
                                            office at 690-1166.
                                            -State of Colorado Swimming Pool and Mineral Bath
                                            Regulations, Article 4.6, Natural Swimming Areas,
An advisory does not officially close a
beach to the public, but for human health
reasons it recommends staying away from
the water. There are several types of
advisories.

•  A water quality exceedance advisory
   after indicator bacteria levels have
   been tested and the results show that
   water quality criteria have been
   exceeded.

•  A waterbody might have a constant
   potential human health risk associated
   with its use.  In such a case, you might
   want to issue a permanent advisory, which notifies the public of naturally occurring
   organisms that might be present in the water at your beach every day.

•  A preemptive advisory can be issued when there might be higher levels of microorganisms at
   certain times, such as after significant rainfall, during high temperatures, and in other
   situations. For example, the Portland (Maine) Department of Health and Human Services
   places an advisory sign following any rainy period because rainfall can cause an elevation of
   bacteria levels due to runoff from the land. Another example can be found in Colorado,
   where a permanent interpretive/referral advisory sign is used (see box).

Practical Applications of Closings Versus Advisories

As a beach manager, you might want to make a distinction between voluntary and involuntary
risk. A beach agency or health department does not necessarily have the legal authority to keep
people from swimming. Therefore, you might have to issue advisories and let the public use
their own discretion. The success of this approach lies in making your advisories as effective as
possible.

5.2.2.3 Mechanisms for Disseminating Advisories and Closings

The needs of the target audience(s) determine the most appropriate mechanism(s) to use. The
mechanisms by which potential beach users receive information about beach advisories or
 closings include:
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters
 •   Beach postings and signs
 •   Mass media (newspapers, television, radio)
 •   Internet web sites
 •   Telephone hotlines
 •   Technical reports

 Beach Postings or Functionally Equivalent Measures

 A written posting of an advisory (or closing, if the beach manager chooses) is one of the most
 useful ways to notify beach users of potential health risks associated with using the water. Signs
 should state the type of advisory or closing and the reason it was issued—an exceedance of water
 quality criteria, heavy rainfall and the high levels of bacteria associated with it, or another reason
                                                  you have determined is appropriate.
    Hart-Miller Island Beach Reopened To Swimming
               Effective Immediately
     Hammerman beach at Gunpowder Falls State Park
          remains closed through the weekend

   Chase, MD (August 24, 2000) - After receiving
   consistent good results from bacteria testing, the beach
   at Hart-Miller Island has been reopened to swimming.
   Results from the fecal coliform bacteria tests which
   have been conducted show that the water is now safe
   for swimming.

   The beach at the Hammerman area of Gunpowder
   Falls State Park will remain closed through the
   weekend as a result of continued high levels of fecal
   coliform bacteria.

   Hart-Miller Island is located in the Chesapeake Bay
   near the mouth of the Middle River. It encompasses
   244 acres and is accessible only by boat. The western
   shore of the island offers safe mooring and access to a
   3,000-foot-long sandy beach. The island is part of the
   North Point/Gunpowder Falls State Park management
   area.

   Gunpowder Falls State Park encompasses more than
   15,000 acres along the Gunpowder River Valley. For
   more information, please call the park's headquarters
   at410-592-2897.
   Posted August 25,2000
 It is important to decide where signs are
 most likely to be noticed by users of your
 beach.  Signs or postings should be placed at
 beach entrances, on bulletin boards in the
 office buildings, or in the general vicinity of
 the common swimming areas.  It is
 important to keep the signs simple and
 restrict types of signs to a minimum. The
 signs should be consistent throughout your
 state or tribe to avoid confusion. The  signs
 should also be large enough to be noticed,
 legible, and easily understood. They should
 not contain overly technical language or very
 small print. The signs should be a bright
 color such as red or yellow to attract the
 attention of the public.  Graphics (such as a
 no-swimming symbol) are a good way to  get
 attention and easily convey a risk associated
 with swimming.  The words "WARNING,"
 "ADVISORY," or "BEACH CLOSED"
 should be written in large letters at the top of
the signs to be seen from a distance.
Additional information may be written in
easily read smaller print. The advantage of
posting is that it provides a visual  notice or
personal interaction at the point of access.
The BEACH Act allows states and tribes to
develop functional equivalents when
                                                           July 25, 2001 Draft - Do not cite or quote
5-6

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                                                                                 Chapter 5
notifying recreational water users. A functional equivalent can be a visual notice or personal
interaction such as a flag at a beach or interaction with beach or park personnel.

Mass Media

Newspapers, television, and radio are effective means to communicate that swimming is not
advisable because they enable you to provide more detailed information to the public than a sign
or beach posting.  For example, you can inform the public of the reason an advisory or closing
has been issued, the area affected, and the anticipated duration of the advisory or closing.
Notifying the public through mass media also targets a larger audience than a sign or beach
posting.  Mass media messages are particularly effective because they inform the public of beach
advisories before arrival at the beach. Your Public Notification Plan should include an effective
plan for ensuring sufficient and timely media coverage. You should explain how the mass media
.will be used -through public service announcements, paid media, free media, newspapers, or a
radio or television station.

Press Release

Public notification of a beach advisory or closing can be provided in the form of a press release
issued by the local health officer or beach manager. A press release is more effective if it comes
from the public health authority.  The press release should indicate whether an advisory or
closing is being issued, the reason for the advisory or closing, the area affected, and the
anticipated duration of the advisory or closing.  The press release should include the name of the
agency and a contact number as well. It may be helpful to issue a press release at the beginning
of the swimming season to notify the public that they should not swim 24 hours after a heavy
rain. Any notice or press release you issue for beach advisories and closings should be formatted
to get the reader's attention and communicate the information effectively.  Consider the
following tips (USEPA, 1999):

•   Place the most important information on the top half of the notice in large print because
    people often read only the first half of'the notice.

•   Limit the length of the notice, and use bullets and bold text when appropriate.

•   In a press release given to  a newspaper reporter, provide a list of the required elements and
    tell the press that these must be included.

•   When the notice is sent to TV and radio stations  as well as newspapers, write "PRESS
    RELEASE FOR PUBLIC  SAFETY" at the top of the notice to emphasize its importance.

•   Include your name, title, and telephone and fax numbers or e-mail address so the press can be
    contact you for additional  information or clarification.
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National Beach Guidance and Grant Performance Criteria for Recreational Waters	_—_	—

Internet Web Sites

Internet web sites can be used to report advisories and closings to the public. The message can
and should be updated as the status of the advisory or closing changes.

A web site can be a good way to reach many people in a community where the Internet is highly
accessible. A local web site might already have been established by another agency or
organization. If so, contact the owner of the site so that you and the owner can work together to
provide the most useful links. States, tribes, and local governments are also encouraged to
establish links between their web sites and EPA's BEACH Watch site.  EPA's BEACH Program
coordinates the BEACH Watch site to inform the public of trends in water quality at beaches, as
well as local information for beaches nationwide.  The BEACH Watch site can be found on the
Internet at http://www.epa.gov/OST/beaches/.

The contents of a web site can be as simple as a current update of water quality conditions or a
list of advisories and closings. If desired, a web site can show previous advisories  and closings,
water quality sampling results, maps of the area, photographs of the beach, contact names and
telephone numbers for the public to contact the health department with comments or questions,
and tips for swimming safety to reduce the human health risk of water use.

The style of the web site is more flexible than the style for signs, press releases, and other forms
of communication. Creativity should be used to draw the.reader's attention. Graphics are
helpful, as well as photographs of your beach. You might also choose to include a description of
your monitoring program or other efforts under way by your beach  agency.  People are typically
interested in this type of information, and it will show them that you are trying to protect them
from any health risks from beach use.

Telephone Hotlines

A telephone hotline can be established to inform the public about all beaches in a given area that
are currently closed, posted with an advisory, or otherwise restricted. The hotline message
should state whether there is an advisory or closing, what area is involved (beach, city, county, or
number of miles), the reason for the closing or advisory, and the time frame involved and date of
removal, if known. The name of the responsible agency and a contact telephone number should
be included as well. The hotline should be updated as needed to convey changes in the status of
beach closings and advisories. Hotlines should follow the same general format as written
advisories. The most important information should be stated first, in clear, nontechnical
language because many people will listen to only the beginning of the message.  The message
needs to be updated as the status of the advisory or closing changes.

Technical Reports

To assess the health of the beaches monitored, you might want to compile a monthly or annual
report of the beach advisories and closings after the beach season has ended. This report could
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                                                                                Chapter?
include the number of times criteria were exceeded, the number of days beaches were under an
advisory or closed, the number of beaches affected by an advisory or closing, a compilation of all
the sampling results, or other measures of beach advisories or closings such as "beach mile
days."  This information can assist in completing the annual EPA National Health Protection
Survey of beaches. In addition, EPA recommends that this information also be reported to the
Agency or entered into EPA's STORET database.

5.2.2.4 Procedures for Notifying the Public

On completion of the data reviews and data quality assessment, values for the specified bacterial
indicators should be reported to the beach manager.  A value's exceeding a single-sample or
geometric mean recreational water criterion should result in a state, tribal, or local action.  A
state, tribe, or local government can determine whether public notification (posting) or
resampling is appropriate based on the state's or tribe's water quality standards. The
interpretation of the bacterial indicator densities with respect to posting an advisory or closing
the beach should be clear and based on the decision rules established during the planning
process.

When  indicator levels exceed water quality standards at any state or tribal beach, the public
should be notified either immediately or, if appropriate, when resampling indicates an
exceedance of standards.  EPA recommends that the following two procedures be performed at
all high-, medium-, and low- priority beaches.

•   Notify the owner, manager, or operator and/or the lifeguards of results. When sample results
    indicate an exceedance of either the instantaneous or geometric mean water quality standard,
    the appropriate health agency should notify the beach manager/operator and any staff
    members (lifeguards) immediately.  This approach ensures that the responsible authorities
    know to take action, ensure the safety of the beach employees, and reduce liability.

 •   Prompt public notification. The means of notification could be a sign or functional
    equivalent. For High and Medium priority beaches, notification is at the point of access.

 At some beaches, however, alternative steps should be taken to issue an advisory when a beach
 has  a high level of human health risk or when a sign posted on the beach is not the most effective
 means of communicating human health risk. For example, a beach that is frequented visited by
 tourists or users that do not live in the vicinity of the beach may require notification of advisories
 or closings through news media, telephone hotlines, or an Internet web site.   Some alternative
 methods include:                  •

 •  Discuss situation with other agencies.  You should contact other state, tribal, or local
     agencies, as well as appropriate organizations involved with the beach monitoring and
     notification program.
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National Beach Guidance and Grant Performance Criteria for Recreational Waters	

•   Provide results on a telephone hotline.

•   Issue a press release.

•   Provide information on local beach web site.

5.2.2.5 Procedures for Removing Advisories and Reopening Beaches

It is important to establish a procedure for removing an issued or expired advisory.or reopening a
'closed beach.  The procedure might vary depending on whether the beach was closed or an
advisory was issued.  This is an important step in risk communication. The public should know
when the water meets applicable standards and should be able to recognize the established
procedures for reopening the beach or removing an advisory.

EPA recommends that the following procedure be performed at all high, medium, and low
priority beaches:

•   Resample and compare the bacterial concentrations with the applicable water quality
    standards to determine whether the levels are below the standards. This procedures should be
    performed unless the advisory or closing was due to a rain advisory.

•   Remove advisories or reopen a beach after a set number of hours or days after a rainfall. This
    should be done only if significant testing has previously been conducted to support the
    assumption that bacteria densities are below criteria after a set period of time. Assumptions
    should be based on statistically significant data and not on best professional judgment alone.

The following additional procedures can be used by beach managers for removing advisories
and reopening beaches:

•   Notify the owner/manager/operator and lifeguards of the test results.

•   Provide an announcement to agency staff or local government staff.

•   Remove the advisory or closing sign.

•   Provide the sampling results on a hotline, water quality information/result phone line, or local
    radio or TV station or in a local newspaper.

•   Remove any physical barriers.

•   Assess the number of complaints of sickness. These assessments  can be conducted by using
    bather surveys to determine how many people have become ill because of contact with beach

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                                                                                 Chapter 5
    water. For example, in San Diego, California, surveys conducted by the group Surfers Tired
    of Pollution provide valuable information on illness rates.

5.2.3  Evaluation of Notification Program's Effectiveness

The public notification and risk communication program should be evaluated continuously
throughout the risk communication process. This step is a critical element that helps ensure a
notification program has been designed to meet the needs of the public and the objectives of the
agency. Throughout the risk communication and notification process, it is important to include
activities, benchmarks, and milestones that require formative, process, and summary evaluation
data to be collected and used. An evaluation of program effectiveness should include the
following considerations.

Ensure that the notification program meets the needs of the audiences and the objectives of the
agency.

Evaluations of the notification program are designed to assess the likelihood of attaining program
objectives.  The appropriateness of potential objectives and the strengths and weaknesses of
alternative communication strategies are addressed. An example of this type of assessment is
determining how many people pay attention to communication methods such as beach postings
and physical barriers or assessing how many people actually contact a telephone hotline or
Internet web site to obtain water quality information for a particular beach.  Also, the steps
involved in your communication process should be evaluated.

To conduct informative evaluations, you will need to  use staff members as well as members of
the  target audience.  The time required can range from several hours of staff time spent on
brainstorming and reviewing activities to a considerable amount of time spent interviewing your
target audience (USDHHS, 1993).

Evaluate the notification program.

Process evaluations occur as  the communication strategy is implemented. They are useful in
both new and established risk communication programs. These evaluations are designed to
determine to what extent communication strategies are being implemented as planned and to
assess the adequacy of administrative, personnel, or other resources necessary to keep the
communication program on track. How effective is it to resample the water after the first sample
indicates an exceedance of water quality standards? Is it beneficial or necessary to continue to
contact staff members and other agencies when an advisory is issued or a beach is closed? An-
example is an assessment of whether the appropriate people are always notified when an advisory
is issued, a beach is closed, or a water quality standard is exceeded. Also, you should determine
whether the water quality has been resampled as required by your procedures for issuing
advisories and closing beaches.  Are postings, press releases, and web sites listing appropriate
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters     	_______^_	

 and accurate information? Is the program being conducted on the intended time schedule, with
 the intended information dissemination mechanisms, within budget, and using the intended staff
 and other resources?

 Process evaluations can be conducted during the course of the communication program and used
 to modify the communication strategy during implementation. There is no need to wait until the
 end of the program to evaluate its implementation process. Evaluation activities may include (1)
 regular contacts with communication partners (media personnel, web site owner, target audience)
 to evaluate the timing and adequacy of advisory information and (2) interviews with target
 audience members or focus groups to assess how well the advisory information is reaching the
 target audience and how receptive they are to that information.

 Determine whether the needs of the public and the agency's objectives have been met.

 Summary evaluations are designed to document the short- or long-term results of risk
 communication programs and to evaluate whether objectives were achieved.  These evaluations
 determine whether the beach advisories and closings have been effective in communicating
 health risks to the public. Did people receive enough information to make an informed decision?
 Were people protected from bacterial contamination? Did the public respond positively to the
 advisory and closing program? These questions and others should be considered as part of the
 evaluation process.

 Summary evaluations .should occur at the end of the risk communication program.  They can
 include focus groups, mail surveys, and telephone surveys. A large sample size is often needed
 for the program evaluators to measure statistically significant program outcomes and impacts in
 large regions (e.g., statewide). You might want to develop a focus group of all staff involved in
 the beach risk communication program. Examples of questions to ask include the following:

 •   What agency objectives did the advisory help achieve?
 •   What objectives were not accomplished?
 •   What positive reactions have you heard from or observed in target audiences? What is
    working in the advisory materials?
 •   What negative reactions have you heard from or observed in target audiences? What
    methods of communication need improvement?
 •   What changes do we need to make in our advisory communication program?

 Before development of a risk communication plan, surveys can be mailed or conducted over the
 telephone to gain feedback from a subset of the target audience. These surveys can be used to
 determine the public's knowledge about the following:

 •   Human health risks of swimming in contaminated water
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	'   	;	   Chapter 5

 •   Specific advisory recommendations
 •   The advisory process

 The surveys can also indicate the following:

 •   The public's reaction to advisories and closings
 •   The public's willingness to adhere to advisory and closing recommendations
 •   The public's suggestions for better communication methods

 5.2.4  Notification Report Submission and Delegation

 As discussed in earlier chapters, Performance Criterion 3 is that states and tribes must compile
 and report their notification activities in timely reports and describe any delegation of notification
 responsibilities to local governments that might have been made.

 Report Submission
 States and tribes must provide notification information to the public, EPA, and other agencies in
 a timely manner. States and tribes must also report the actions they have taken to notify the
 public when water quality standards are exceeded. To meet this criterion, states and tribes should
 coordinate closely with local governments to acquire information and ensure that it is submitted
 in a consistent fashion. Timely submission of compatible electronic files is a critical component
 of this reporting requiremnt.  Comparability with EPA's National Health Protection Survey of
 Beaches is also a very  important factor.

 Delegation
 EPA encourages states to coordinate with local governments and to delegate, as appropriate,
 responsibilities for notification programs to local governments. Local governments have
 traditionally played the lead role in administering beach protection programs. There are many
 reasons for the local level to take responsibility in protecting recreational waters.  For example,
 local citizens and officials are more familiar with local problems and needs and are in a better
 position to address local issues and formulate solutions.  Also, many of the benefits of protecting
 natural resources, in this  case coastal recreation waters, accrue at the local level.
 July 25, 2001 Draft - Do note cite or quote
                                                                                       5-13

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National Beach Guidance and Grant Performance Criteria for Recreational Waters

5.3    References

MDDNR. 2001. Press Releases: Hart-Miller Island Beach Reopened to Swimming Effective
Immediately. Maryland Department of Natural Resources.
. Accessed April 2001.

USDHHS, 1993. Recommendations to Improve Health Risk Communication: A Report on Case
Studies in Health Risk Communication.  U.S. Department of Health and Human Services, Public
Health Service Committee to Coordinate Environmental Health and Related Programs,
Washington, DC.

USEPA.  1992. Protecting Coastal and Wetland Resources: A Guide for Local Governments.
EPA 842-R-92-002. U.S. Environmental Protection Agency, Office of Water, Washington, DC.

USEPA.  1999. Public Notification Handbook. Draft for comment. EPA 816-R-99-004. U.S.
Environmental Protection Agency, Office of Water, Washington, DC.

USEPA. 2000. Regional BEACH Program Conferences-1999.  Proceedings. EPA 823-R-OO-
003. U.S. Environmental Protection Agency, Office of Water, Washington, DC.
5-14
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                                                                                              Chapter 5
Table 5-1. Recommended Content for Advisories and Closings
 Exceedance of Water Quality Criteria, Preemptive Advisory or Closing, Permanent Advisory or Closing

 Sign/Posting
 •  Warning," "Advisory," "Beach Closed," or similar language
 •  Reason for advisory or closing
    - For preemptive advisory or closing: "Heavy rainfall has occurred. Beach is closed/under advisory for the
     next 24 hours due to predicted elevated bacteria levels"
 •  Name of beach, city, county, or miles of area affected                                    .
 •  When samples were taken, period of effectiveness, and when advisory will end or beach will reopen
 •  Agency's name and contact number

 Press Release or Public Notice
 •  Attention-getting title
 •  Reason for advisory or closing
    - For preemptive advisory or closing: expected high bacteria levels
 •  What is the health risk and why
 •  Name of beach, city, county, or miles of area affected
 •  When samples were taken, period of effectiveness, and when advisory will end or beach will reopen
 •  Agency's name and contact number, for both the readers and the journalist

 Hotline
 •  "An advisory has been issued for..."
 •  Reason for advisory or closing
    - Preemptive advisory or closing: expected high bacteria levels
 •  What is the health risk and why
 •  Name of beach, city, county, or miles of area affected
 •  When samples were taken, period of effectiveness, and when advisory will end or beach will reopen
 •  Agency's name and contact number

 Internet
 •  A list of beaches, cities, and counties, along with their respective status (open, closed, or under advisory)
 •  Reason for advisory or closing
    - Preemptive advisory or closing: expected high bacteria levels
 •  What is  the health risk and why
 •  Miles or area affected
 •  When samples were taken, period of effectiveness, and when advisory will end or beach will reopen
 •  Agency's name and contact number
 •  Description of monitoring and notification program
 •  Links to beach and environmental agencies and the health department
 •  Maps,'photographs, graphics
 •  Opportunities for volunteer involvement in beach program
 •  Reference list of materials and guides for beach users
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                                                                                                   5-15

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 National Beach Guidance and Grant Performance Criteria for Recreational Waters
5-16
                                                                  July 25, 2001 Draft - Do not cite or quote

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         v>EPA
                           United States
                           Environmental Protection
                           Agency
                                   Office of Water
                                   (4305)
EPA823-F-01-06
January 2001
Beaches  Environmental  Assessment
and  Coastal Health  Act  of 2000
Public Law   106-284
H, Qft October 10, 2000,
5- tfie Beaches Environ-
  mental Assessment and
  Coastal Health Act was
  signed into law. This
  new law authorizes a
  national grant program
  to assist state, tribal,
  and local governments
  in developing and
  implementing monitor-
  ing and public
  notification programs
  for their coastal
  recreation waters. It
  also requires states to
  adopt improved water
  quality standards for
  pathogens and patho-
  gen indicators and
  requires EPA to
  conduct studies and
  develop improved
  microbiological water
  quality criteria guid-
  ance. In addition, the
  law requires EPA to
  develop performance
  criteria for monitoring,
  notification, and public
  information databases
  and requires other
  federal agencies to
  establish certain
  programs.
Purpose and Title
This legislation amends the Federal Water Pollution Control Act (also known as the Clean Water
Act, or CWA) to improve the quality of coastal recreation waters and attain other objectives. The
following summary is provided for>the convenience of the reader. It does not substitute for the
statute. Grant applicants should consult the statute and applicable grant regulations prior to filing
such applications.
Section 1. Short Title
"Beaches Environmental Assessment and Coastal Health Act of 2000"

Water Quality Standards and Criteria
Section 2. Adoption of Coastal Recreation Water Quality Criteria and Standards by States
The provisions of this section amend section 303 of the CWA with respect to the following:
  •  Initial Criteria and Standards: [By April 10, 2004], states having coastal recreation waters
    are required to adopt water quality criteria and standards for pathogens and pathogen
    indicators for which the EPA Administrator has published criteria under the act. [This refers
    to EPA's 1986 Water Quality Criteria for Bacteria.]
  •  New or Revised Criteria and Standards: Requires states to adopt new or revised standards
    for coastal recreation waters not later than 36 months after the EPA Administrator publishes
    new or revised criteria guidance for pathogens and pathogen indicators.
  •  Failure to Adopt: If a state fails to adopt criteria and standards for pathogens and pathogen
    indicators that are "as protective of human health as EPA criteria [by April JO, 2004]" the
    EPA Administrator shall promptly propose regulations setting forth revised criteria and
    standards.
Section 3. Revisions to Water Quality Criteria
This section adds the following to section 104 of the CWA as "Studies Concerning Pathogen
Indicators In Coastal Recreation Waters":
  •  New Studies: [By October 10, 2003], the EPA Administrator shall complete studies for use
    in developing: (1) an assessment of potential health risks from exposure to pathogens in
    coastal recreation waters; (2) appropriate and effective indicators and appropriate, accurate,
    and expeditious methods for detecting or predicting the presence of pathogens in coastal
    recreational waters; and (3) guidance for state
    application of EPA's criteria guidance for
    pathogens to account for the diversity of
    geographic and aquatic conditions.
                               Revised Criteria: Requires the EPA Adminis-
                               trator to publish new or revised water quality
                               criteria guidance for pathogens in such
                               waters not later than October 10, 2005.
                               Criteria is to be reviewed at least once every
                               five years thereafter.
                                             A copy of the Beaches Environmental
                                             Assessment and Coastal Health Act
                                             can be found on the BEACH Watch
                                             website at .

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 Monitoring and Notification
 Section 4. Coastal Recreation Water Quality Monitoring and Notification
 The provisions of this section amend Title IV of the CWA to add section 406, "Coastal Recreation Water Quality Monitoring and
 Notification." This section includes the following provisions:
  •  Monitoring and Notification Performance Criteria: Directs the EPA Administrator, by April 10, 2002, to publish "perfor-
     mance criteria" for a monitoring and notification grants program. The criteria will address the following topics: (1) the      j
     monitoring and assessment of coastal recreation waters adjacent to beaches for attainment of water quality standards for   '
     pathogens, including methods for such monitoring and assessment; and (2) prompt notification of local governments, the
     public, and the EPA Administrator of exceedances, or the likelihood of exceedances, of standards for such waters so that
     public health and safety can be maintained.
  •  Program Development and Implementation Grants: Authorizes the EPA Administrator to make grants to states, tribes, an^l
     local governments to develop and implement monitoring and notification programs. To qualify for an implementation grant,
     a grantee would need to: (1) be consistent with EPA's performance criteria; (2) prioritize use of grant funds based on use of;
     the water and risk to human health, and identify factors considered in setting priorities; (3) develop a list of waters not
     subject to the monitoring and notification program due to .fiscal constraints; and (4) provide an opportunity for public      ;
     comment. States may delegate responsibilities and provide funding to local governments to implement a program. Local
     agencies may also apply for a grant under certain circumstances.                                                    •
  •  Content of State, Tribal, and Local Programs: As a condition of the grant, a state, tribe, or local government shall: (1) list
     coastal recreational waters adjacent to beaches used by the public; (2) identify the delegation process;  (3) identify monitor-,
     ing and assessment methods including frequency and location of monitoring; and (4) identify communication procedures
     and measures.
  •  Federal Agency Programs: Requires Federal agencies to develop programs for certain coastal recreation waters within three
     years. These programs should be designed to: (1) protect public health and safety; (2) meet EPA's performance criteria; and
     (3) address certain other matters required for state and local programs.
  •  EPA Database and Technical Assistance: Directs the EPA Administrator to: (1) establish a national coastal recreation water
     pollution occurrence database; and (2) provide technical assistance for development of assessment and monitoring proce- '
     dures for floatable materials in those waters.                                                                     i
  •  list of Waters'. EPA is required to maintain  a publicly available "list of waters" that are subject to a monitoring and notifica-
     tion program, as well as those not subject to a program because of fiscal constraints.                                  •
  •  EPA Implementation: In states that do not have a program consistent with EPA's performance criteria, EPA is required to  ;
     conduct such a program for listed priority waters using grant funds that otherwise would have been awarded to those
     states. This "backstop" would commence three years after EPA lists waters in such states.
                                                                                                                 i
  *  Authorization of Appropriations: Authorizes annual appropriations of $30 million for fiscal years 2001 through 2005.      ;
     [Actual funding levels depend on specific appropriations enacted annually by  Congress.]

Other Provisions
Section 5. Definitions
  •  Defines "Coastal Recreation Waters": This term includes: "(i) the Great Lakes and (ii) marine coastal waters (including    j
     coastal estuaries) that are designated under section 303(c) by a State for use for swimming, bathing, surfing, or similar water
     contact activities." The term does not include "(i) inland waters or (ii) waters upstream of the mouth of a river or stream     '
     having an unimpaired natural connection with the open sea."                                                       I
                                                   1
Sections. Indian Tribes                                                                                         '-
  •  Tribes Are Treated Like States: Adds language which allows EPA to treat Indian tribes in a manner similar to states for
     purposes of section 406 of the act, which include coastal recreation water quality monitoring and notification programs and
     grants. EPA already had authority to treat tribes in a manner similar to states for purposes of section 303 of the act.  .

Section 7. Report
  •  Reporting Schedule: Requires that EPA report to Congress every four years.                                         \

Section 8. Authorization of Appropriations                                                                       !
  •   Appropriation Authority: Authorizes appropriations to carry out the act.

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                                                                                Appendix B
Appendix B: EPA's Water Quality Criteria for Bacteria

This appendix includes additional information on EPA's methods used in calculating Ambient
Water Quality Criteria for Bacteria - 1986.

B. 1   Organisms that Can Indicate Fecal Contamination

Because many pathogens are not easily detected, indicator organisms are a fundamental
monitoring tool used to measure both changes in environmental (water) quality or conditions and
the potential presence of hard-to-detect target pathogenic organisms.  An indicator organism
provides evidence of the presence or absence of a pathogenic organism surviving under similar
physical, chemical, and nutrient conditions. For fecal contamination, indicator organisms should

1.  Be easily detected using simple laboratory tests.

2.  Generally not be present in unpolluted waters.

3.  Appear in concentrations that can be correlated with the extent of contamination.

4.  Have a die-off rate that is not faster than the die-off rate of the pathogens of concern (Sloat
    and Ziel, 1992; Thomann and Mueller, 1987).

Indicator bacteria are usually harmless, more plentiful, and easier to detect than pathogens
(Wilhelm and Maluk, 1999).  Methods are not currently available to culture or enumerate all of
the disease-causing organisms that might be present in natural waters.  For example, viruses and
protozoans are generally not used as indicators because of difficulties associated with isolating
them and detecting their presence in environmental samples. The bacteria species chosen as
indicators are indigenous to the intestines of warm-blooded animals and indicate the potential
presence of dangerous pathogens that cause human illnesses.

Use and reliability are two aspects that states should consider when selecting an indicator. The
lack of correlation between certain indicators and pathogen-caused diseases in humans, as well as
the uncertain relationship between indicators and different sources of pathogens, are limitations
of bacterial indicators. A positive result for the indicator organism means that the indicator is
present in the waterbody, not necessarily that waterborne pathogens are also present. The
presence of an indicator might not indicate whether those pathogens (if present) are viable or
capable of causing disease and whether the source  of the contamination is humans or other
animals.

Indicators vary in their ability to reliably predict potential risks to human health. Some indicators
have been shown to have a greater statistical relationship to disease than others.  Also,  current
indicators are based on fecal contamination and might not accurately assess the potential for
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B-l

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National Beach Guidance and Grant Performance Criteria for Recreational Waters	

disease from other pathogens that can cause skin, upper respiratory tract, eye, ear, nose, and
throat disease (USEPA, 1999a). More research on the use of other bacteria and viruses as
indicators is being conducted at the federal, state, and local levels. Despite variability in the
ability of indicators to reliably predict potential risks to human health, EPA studies indicate that
enterococci and E. coli are the most effective available primary indicators of fecal contamination.

One area of current scientific debate is whether indicator bacteria react differently under various
climatic and environmental conditions. Preliminary evidence suggests that E. coli and
enterococci can be detected at tropical locales such as Puerto Rico, Hawaii, and Guam for waters
where there is no apparent source of contamination from warm-blooded animals (USEPA,
1999a). EPA and others are evaluating whether the current indicator bacteria are suspected to
grow and persist in natural tropical environments.  If.fi1. coli and enterococci are determined to
propagate naturally in tropical conditions, EPA will conduct additional research to identify
alternative indicators for tropical areas.

B.2    EPA's Current Water Quality Criteria for Bacteria: Enterococcus and E. coli

In 1986, EPA published Ambient Water Quality Criteria for Bacteria - 1986 which
recommended the use of E. Coli and enterococci as water quality criteria for bacteria.  The data
supporting the water quality criteria established in Ambient Water Quality Criteria for Bacteria -
1986 were obtained from a series of research studies  conducted by EPA examining the
relationship between swimming-associated illness and the microbiological quality of the waters
used by recreational bathers.  The results of these studies demonstrated that fecal coliform
bacteria,  the indicator originally recommended hi 1968 by the Federal Water Pollution Control
Admmistration of the Department of the Interior, showed very little correlation to swimming-
associated gastroenteritis.  Two indicator organisms,  E. coli and enterococci, showed a strong
correlation, the former in fresh waters only and the latter in both fresh and marine waters. The
strong correlation could be a result of the similarity in survivability of the indicator organisms
and the pathogens of concern. Consequently, EPA's  Ambient Water Quality Criteria for
Bacteria  - 1986 recommended the use of E. coli and enterococci rather than fecal coliforms as
indicators. Since the publication of Ambient Water Quality Criteria for Bacteria - 1986, many
states have adopted these E.  coli and enterococci criteria.
B-2
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                                                                              Appendix B
Geometric Mean

The current section 304(a) criteria recommendations for indicators of fecal contamination are a
geometric mean of 126 colony forming units (CPU) per 100 milliliters (mL) for E. coli, a
freshwater geometric mean of 33 CPU/100 mL for enterococci, and a marine geometric mean of
35 CFU/100 mL for enterococci (Tables B-l and B-2).  These values are based on specific levels
of risk of acute gastrointestinal illness. EPA used levels of risk correlating to these values of no
more than 8 illnesses per 1,000 swimmers for fresh waters and no more than 19 illnesses per
1,000 swimmers for marine waters (USEPA, 1986). The illness rates are EPA's best estimates of
the accepted illness rates for areas that had previously applied the fecal coliforms criteria.  EPA
has determined that, when these water quality criteria are implemented in a conservative manner,
they are protective for prevention of gastrointestinal illness resulting from primary contact
recreation.

As described in EPA's epidemiological studies from the 1970s to 1980s on marine and
freshwater bathing beaches, the significance of finding enterococci or E. coli in recreational
water samples is the direct relationship between the density of enterococci or E. coli in the water
and swimming-associated gastroenteritis.  EPA recommended that criteria be calculated as the
geometric mean of a statistically sufficient number of samples, at least five samples equally
spaced over a 30-day period (USEPA, 1986). Because of the inherent variability of bacterial
indicators, however, states are encouraged to collect as many samples as possible over a 30-day
period to assess the standard. If a sixth measurement is made during a 30-day period, it should
be included in the calculation of the geometric mean.

EPA calculated the single-sample maximum densities for each confidence level (Table B-l) by
using a control chart analogy (ASTM, 1951) and log standard deviations from EPA studies. All
single-sample maximum levels should be recalculated for individual areas if differences in log
standard deviations occur (Table B-2). A detailed protocol that shows how to determine the
confidence level associated with any illness risk once a maximum has been established for single
samples is available (USEPA, 1986).

EPA recommends that states adopt the criteria in Ambient Water Quality Criteria for Bacteria-
1986, which are based on scientifically defensible methods, to protect recreational waters.  For
those coastal recreational waters where EPA's recommended water quality criteria have been
applied, the recreational beach is determined not to be attaining its designated use if the
geometric mean of bacterial densities measured within a 30-day period exceeds the
recommended criterion.

Single Sample Maximum

Single samples are also used to determine whether beaches meet designated use.  A beach does
not meet its designated use if the bacterial density in a single bacteria density sample exceeds a

July 25, 2001 Draft -Do not cite or quote                                                      B-3

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National Beach Guidance and Grant Performance Criteria for Recreational Waters	

single-sample maximum value. Use of a single-sample maximum is important because it is
assumed that environmental conditions (such as rainfall, wind, and temperature) will vary
temporally and spatially. The confidence intervals in EPA's criteria were based on EPA's
judgment, and a qualitative use intensity was then assigned to each confidence level. A smaller
confidence level (75 percent) corresponds to a more stringent (lower) single-sample maximum,
whereas a greater confidence level (95 percent) corresponds to less stringent (higher) maximum
values (Tables B-l and B-2) (USEPA, 1986).  EPA assigned a more stringent single-sample
maximum to designated bathing beaches because a high degree of caution should be used to
evaluate water quality for heavy-use areas (USEPA, 1986). A less stringent single-sample
maximum can be used for less-intensively used or more remote swimming areas.  Appendix B
provides an explanation to assist in this calculation.

EPA calculated the single-sample maximum densities for each confidence level (Table B-l) by
using a control chart analogy (ASTM, 1951) and. log standard deviations from EPA studies. All
single-sample maximum levels should be recalculated for individual areas if differences in log
standard deviations occur (Table B-2). A detailed protocol is available that shows how to
determine the confidence level associated with any illness risk once a maximum has been
established for single samples (USEPA, 1986).

   Example 1: The geometric mean indicator density for enteroeocci in fresh water is 33 CPU.
   If a segment of fresh water is a designated beach area and is using a 75 percent confidence
   level to provide a more stringent standard, the enteroeocci density would have to meet a
   geometric mean of 33 CFU/100 mL and have no one sample exceeding 61 CFU/100 mL to
   meet the water quality criteria for bacteria. These criteria are more stringent than those for an
   infrequently used beach that might use a 95 percent confidence level.  The infrequently used
   beach would have to meet the  single-sample maximum of 151 CFU/100 mL for enteroeocci
   in addition to the geometric mean. This approach allows for greater fluctuation in sample
   results at the less frequently used beach than at the more frequently use beach (Table B-2).

   Example 2: The geometric mean indicator density for enteroeocci in marine water is 35 CFU.
   If a segment of marine water is a designated beach area and is using a 75 percent confidence
   level to provide a more stringent standard, the  enteroeocci density would have to meet a
   geometric mean of 35 CFU/100 mL and have no one sample exceeding 104 CFU/100 mL to
   meet the water quality criteria  for bacteria. These criteria are more stringent than those for an
   infrequently used beach that might use a 95 percent confidence level.  The infrequently used
  • beach would have to meet the  single-sample maximum of 500 CFU/100 mL for enteroeocci
   in addition to the geometric mean. This approach allows for greater fluctuation in sample
   results at the less frequently used beach than at the more frequently use beach (Table B-2).
B-4
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                                                                                                   Appendix B
 Table B-l. Summary of Environmental Protection Agency Ambient Water Quality Criteria
for Bacteria in Recreational Waters, 1986
                                EPA Criteria for Bathing (Full Body Contact)
                                            Recreational Waters
     Freshwater
     Based on the samples taken over a 30-day period (generally not less than five samples equally spaced over a 30-day
     period'), the geometric mean of the indicated bacterial densities should not exceed one of the following2:
                              E. coli           126 per 100 mL; or
                              Enterococci       33 per 100 mL.

     No sample should exceed a one-sided confidence limit (C.L.) calculated using the following as a guidance:
                              Designated bathing beach   75% C.L.
                              Moderate use for bathing    82% C.L.
                              Light use for bathing       90% C.L.
                              Infrequent use for bathing   95% C.L.
     based on site-specific log standard deviation, or if site data are insufficient to establish a log standard deviation, then
     using 0.4 as the log standard deviation for both indicators.

     Marine Water

     Based on the samples taken over the 30-day period (generally not less than five samples equally spaced over a 30-day
     period'), the geometric mean of the enterococci densities should not exceed 35 per 100 mL.

     No sample should exceed a one-sided confidence limit using the following as a guidance:
                              Designated bathing beach   75% C.L.
                              Moderate use for bathing    82% C.L.
                              Light use for bathing       90% C.L.
                              Infrequent use for bathing   95% C.L.
     based on a site-specific log standard deviation, or if site data are insufficient to establish a log standard deviation, then
 ' States are not limited to only five samples per 30-day period. Due to the inherent variability of bacterial indicators, you are
 encouraged to collect as many samples as possible over a 30 day period to assess the standard.  If a sixth measurement is made
 during a 30-day period, it should be included in the calculation of the geometric mean.
 2 It is only necessary to use one indicator. The regulatory agency should select the appropriate indicator for its conditions.
 Source: USEPA 1986.
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                                                                                                           B-5

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Table R-2. Criteria for Indicators for Bacteriological Densities
Acceptable Swimming-
Associated Gastroenteritis
Rate per 1000 Swimmers
Steady-
State
Geometric
Mean
Indicator
Density
Single Sample Maximum Allowable Density4'5
Designated
Beach Area
(upper
75% C.L.)
Freshwater
enterococci
E. coli
Marine Water
enterococci
8
8
33'
1262
61
235

19
353
104
Moderate
Full Body
Contact
Recreation
(upper
82% C.L.)

89
298

158
Lightly
Used Full
Body
Contact
Recreation
(upper
90% C.L.)

108
406

276
Infrequently
Used Full Body
Contact
Recreation
(upper 95% C.L.)

151 '
576

500
1 Calculated to nearest whole number using equation:
(mean enterococci density) = antilog,0 illness rate/1000 people + 6.28
9.40
2 Calculated to nearest whole number using equation:
. (mean E. coli density) = antilog,0 illness rate/1000 people + 1 1.74
9.40
3 Calculated to nearest whole number using equation:
(mean enterococci density) = antilog,0 illness rate/1000 people - 0.20
12.17
4 Single sample limit = antiloglO |_ (log,0 indicator geometric + (Factor determined X
irean density/ lOOmL) from areas under the
N>rmal probability
crve for the assumed
loglt> standard J
deviation)
Iwel of probability
The appropriate factors for the indicated one-sided confidence levels are:
75%C.L.- 0.675
82%C.L.- 0.935


90% C.L. - 1
95% C.L. - 1
.28
.65




s Based on the observed log standard deviations during the EPA studies: 0.4 for freshwater E. coli and enterococci and 0.7 for
marine water enterococci. Each jurisdiction should establish its own standard deviation for its conditions, which would then
vary the single-sample limit.
Source: USEPA 1986.
B-6
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                                                                            Appendix B
B.3    EPA's Review of Recent Epidemiological Studies

The following table includes the relevant findings of the research EPA reviewed that has been  •
conducted on indicator organisms since 1986.

Table B-3. Summary of Research Conducted Since 1986
Researcher/ Year/
Location
Fattal et al.
(1987)
Israel
Cheung et al.
(1990)
Hong Kong






Balarajan et al.
(1991)
United Kingdom
Von Schirnding et
al.
(1992)
South Africa
(Atlantic Coast)

Corbett et al.
(1993)
Sydney,
Australia



Kay et al.
(1994)
United Kingdom


Type of
Water
Marine


Marine








Marine


Marine





Marine






Marine





Microorganisms Evaluated
Fecal coliforms
Enterococci
Escherichia coli
Fecal coliforms
E. coli
Klebsiella spp.
Enterococci
Fecal streptococci
Staphylococci
Pseudomonas aeruginosa
Candida albicans
Total fungi
Unknown


Enterococci
Fecal coliforms
Coliphages
Staphylococci
F-male-specific
bacteriophages
Fecal coliforms
Fecal steptococci





Total coliforms
Fecal coliforms
Fecal streptococci
Pseudomonas aeruginosa
Total Staphylococci

Relevant Findings
Of the indicators tested, enterococci were the
most predictive indicator for enteric disease
symptoms.
Of the indicators tested, E. coli showed the
highest significant correlation with combined
swimming-associated gastroenteritis and skin
symptom rates.





Risk of illness increased with degree of
exposure.

Uncertainty about the sources of fecal
contamination may explain the lack of
statistically significant relationship rates of
illness between swimmers and non-
swimmers.

Gastrointestinal symptoms in swimmers did
not increase with increasing counts of fecal
bacteria.

Counts of fecal coliforms were better
predictors of swimming-associated illness
than streptococci.
Compared to the other indicators tested,
fecal streptococci were the best indicator of
gastrointestinal symptoms.


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                                                                                   B-7

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National Beach Guidance and Grant Performance Criteria for Recreational Waters
Researcher/ Year/
Location
Kueh et al.
(1995)
Hong Kong
Fleisher et al.
(1996)
United Kingdom
Haile et al.
(1996)
California, USA
McBride et al.
(1998)
New Zealand
Seyfried et al.
(1985)
Canada
Ferley et al.
(1989)
France
Francy et al.
(1993)
Ohio, USA
Type of
Water
Marine
Marine
Marine
Marine
Fresh
Fresh
Fresh
Microorganisms Evaluated
E. coli
Fecal coliforms
Staphylococci
Aeromonas spp.
Clostridium perfringens
Vibrio cholera
Vibrio parahemotylicus
Salmonella spp.
Shigella spp.
Total coliform
Fecal coliform
Fecal streptococci
Total Staphylococci
Pseudomonas aeruginosa
Total coliforms
Fecal coliforms
Enterococci
E. coli
Fecal coliforms
E. coli
Enterococci
Fecal coliforms
Fecal streptococci
Heterotrophic bacteria
Pseudomonas aeroginosa
Total Staphylococci
Fecal coliforms
Fecal streptococci
E. coli
Fecal coliforms
Relevant Findings
No statistical relationship between E. coli
and swimming-associated illness was found
(possibly because only two beaches were
sampled).
Nonenteric illness can be transmitted through
recreational contact with marine waters
contaminated with sewage.
The association of symptoms with both E.
coli and fecal coliforms was very weak
Enterococci were most strongly and
consistently associated with illness risk for
the exposed groups.
If swimmers remained in the water for more
than 30 minutes, the risk differences were
significantly greater between swimmers and
nonswimmers.
A small correlation between fecal
streptococci and gastrointestinal illness was
observed.
The best relationship is between fecal
streptococci and gastrointestinal illness.
In this study, the relationship between E. coli
and fecal coliform bacteria was found to be
statistically significant. This relationship can
differ from one data source to another.
B-8
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                                                                               Appendix B
B.4    Calculating A Geometric Mean

This appendix provides solution steps for calculating the geometric mean of your water quality
samples. The geometric mean of your samples can be calculated using one of two methods; each
one will provide an accurate answer. Taking into consideration that calculators differ and have
different function keys, choose the method that is easier for you to follow.

QUESTION

Calculate the geometric mean for the following five enterococci samples taken within a 30-day
period: 20, 40,  15, 30, and 29.1

SOLUTION STEPS
Method 1: Take the n* root of n samples.

Step 1: Multiply all sample values together.

       20 x 40 x 15 x 30 x 29 = 10,440,000

Step 2: Count the number of samples you are using.
Step 3: Make the value of Step 2 the denominator in a fraction with ' 1' as the numerator.

       = 1/5 ^0.2

Step 4: Take the answer from Step 1 and raise it to the power of the answer from Step 3.

       = ( 10,440,000 )°'2

This calculation can be performed on a scientific calculator in several ways.  For example, enter
10,440,000 into the calculator. Press the "xAy" key and then enter "0.2."  This calculation can
also be performed by entering 10,440,000, pressing the "A" key, and entering 0.2.
Answer:
= 25.336
       'if you have more than five samples collected during a 30-day period, the additional samples should be
included in the calculation of the geometric mean (for both methods).
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National Beach Guidance and Grant Performance Criteria for Recreational Waters             	

Method 2: Take the antilog of the mean of the logarithm of each sample.

Step 1: Take the log of each sample. (This calculation can be performed on a scientific calculator
using the "log" key.  For example, enter "20" into the calculator and then press the "log" key.)
       log(20) = 1.30
       log(40)=1.60
       log(15)=1.17
       log(30)=1.47
       log(29) = 1.46

Step 2: Take the average, or mean, of the log samples.

       1.40  = 1.30 + 1.60 + 1.17 + 1.47 + 1.46
                                  5

Step 3: Take the antilog of the answer from Step 2.

       25.336 = antilog (1.40374)

This calculation can be performed on a scientific calculator in several ways.  For example, enter
"1.40," press the "Inv" key, and then press the "log" key.  This calculation can also be performed
by pressing the "2nd" followed by the "log" key and then typing 1.40.
Answer:
25336
Note: The values received from Method 1 or 2 should be compared to the values in the "Steady
State Geometric Mean Indicator Density" columns of Tables B-2 to determine whether you are
meeting the appropriate water quality criteria.  Although variation around the steady-state
geometric mean indicator density is common, it is important to note that no single sample should
exceed your risk-based single-sample maximum allowable density.
B-10
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                                                                             Appendix C
Appendix C: State and Local Programs and Nongovernmental Organizations

C.I    State and Local Programs

[Under development]

C.2    Nongovernmental Organizations                                       .

Surfrider Foundation
The Surfrider Foundation is a nonprofit environmental organization dedicated to the protection
and enjoyment of the world's oceans, waves, and beaches through conservation, activism,
research, and education. With 27,000 members and 50 national chapters, the Surfrider
Foundation recognizes the biodiversity and ecological integrity of the planet's coasts are
necessary and irreplaceable and is committed to preserving the diversity and ecological integrity
of the coastal environment.  The Surfrider Foundation has established a national beach water
quality testing, monitoring, and notification program called Blue Water Task Force. In 2000 this
program was implemented by 21 local Surfrider chapters located in 9 coastal states (California,
Texas, Florida, North Carolina, Delaware, Rhode Island, New Jersey, New York, and
Massachusetts). More information on the Surfrider Foundation can be found at
.

Heal the Bay
Heal the Bay was founded in 1985. This nonprofit environmental advocacy group, which has
approximately 10,000 members, works to make Santa Montica Bay and Southern California
coastal waters safe and healthy for people and marine life. Heal the Bay uses research,
education, community action, and policy programs to achieve this goal. In 1992 Heal the Bay led
an effort to create a Beach Closure and Health Warning Protocol that mandates beach closures
after every sewage spill and when bacteria exceed certain levels.  Heal the Bay also publishes
regular reports on the water quality of the Santa Monica Bay.

Heal the Bay produces a weekly Beach Report Card that analyzes data from the City and County
of Los Angeles and grades beaches from "A" to "F" based on the bacteria levels in the surf zone.
The Beach Report Card is released weekly to the media and to 18 ocean sports stores and marine
centers. The group's Santa Monica Bay beach grades are also shown on The Weather Channel in
most parts of the county. In addition, from 1990 to 1992 Heal the Bay led a series of studies that
found the presence of human gastrointestinal viruses in storm drain runoff at several locations
throughout Santa Monica Bay. The studies proved that human fecal material was contaminating
certain storm drains, putting the health of beachgoers at risk. The results of this study were used
in developing the local Beach Closure Protocol and performing a ground-breaking health risks
study. More information on Heal the Bay can be found at .
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters	_^___^_	i__	

 Chesapeake Bay Foundation
 The Chesapeake Bay Foundation (CBF) is a nonprofit environmental group of more than 80,000
 members committed to protecting the bay's natural resources from pollution and other harmful
 activities by fighting for strong, effective laws and regulations, hi addition, CBF works
 cooperatively with government, business, and citizens in partnerships to restore the bay's
 essential habitats and filtering mechanisms, such as forests, wetlands, underwater grasses, and
 oysters, through a variety of hands-on projects. The Chesapeake Bay Foundation publishes an
 annual State of the Bay Report that summarizes trends and accomplishments in the Chesapeake
 Bay and its watershed, as well as goals for the coming year. Issues for the annual report include
 habitat, pollution, fisheries, and water quality. More information on the Chesapeake Bay
 Foundation can be found at .

 Natural Resources Defense Council
 The Natural Resources Defense Council (NRDC) uses law, science, and the support of more than
 400,000 members nationwide to protect the planet's wildlife and wild places and to ensure a safe
 and healthy environment for all living things. NRDC is an advocacy group working to safeguard
 drinking water; to protect, preserve, and restore rivers, streams, lakes, wetlands, and coastal
 waters; and to promote conservation and better water management in the arid western states. For
 example, in the past 10 years NRDC has undertaken a study of beach closings and beachwater
 monitoring and public notification programs in coastal and Great Lakes states. This study has
 triggered expansion of beachwater monitoring programs across the United States and new and
 emerging laws that will better protect the health of beachgoers.  More information on NRDC can
 be found at .

 Center for Marine Conservation
 The Center for Marine Conservation (CMC), established in 1972, is a nonprofit organization
 dedicated to protecting marine wildlife and habitats and to conserving coastal and ocean
 resources.  In partnership with an international network of business and industry, other
 conservation groups, government agencies, foundations, associations, and private citizens, CMC
 works to keep the marine environment healthy and safe for future generations. Every year, the
 CMC coordinates an International Coastal Cleanup with the mission to

 •      Remove debris from the shorelines, waterways, and beaches of the world's lakes, rivers,
       and the ocean.
 •      Collect valuable information on the amount and types of debris.
 •      Educate people on the issue of marine debris.
 •      Use the information collected from the cleanup to effect positive change from the
       individual to the international to reduce marine debris and enhance marine conservation.

Additional information on the CMC's International Coastal Cleanup is available at
.
C-2
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                                                                              Appendix C
 CMC also identifies existing and new citizen water quality monitoring programs that improve the
 publics awareness of what is in the water they swim in and the fish they eat. Additional
 information on CMC's water quality workshops can be found at
 .

 American Oceans Campaign
 The mission of American Oceans Campaign (AOC) is to safeguard the vitality of the oceans and
 coastal waters.  AOC produces a "Healthy Beaches Brochure," which is an overview of the
 problems facing coasts and the solutions to ensure safe and healthy beach water. AOC also
 coordinates Healthy Beaches Workshops to provide citizens with information on how beach
 water quality monitoring programs help protect local residents, visitors, and businesses; what is
 being done on the local and national levels to monitor beach water quality:  and what people can
 do to help their communities get the resources they needs to monitor beach water quality
 effectively, protect public health, and keep beach water clean and healthy.  Additional
 information on AOC is provided at .
July 25, 2001 Draft - Do note cite or quote
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters	

 C.3.   References

 AOC. 2001. Beach Water - Latest News. American Oceans Campaign.
 . Accessed April 2001.

 CBF. 2001. Chesapeake Bay Foundation . Accessed January 2001.

 CMC.  200la.  About the International Coastal Cleanup. Center for Marine Conservation.
 . Accessed April, 2001.

 CMC.  2001b.  Water Quality Monitoring and Citizen Outreach. Center for Marine
 Conservation. . Accessed April, 2001.

 Heal the Bay. 2001.  Who Is Heal the Bay? . Accessed January
 2001.

 NRDC. 2001 Natural Resources Defense Council .  Accessed January
 2001.                              •

 Surfiider Foundation. 2001. Surfrider Foundation USA. . Accessed
 January 2001.
C-4
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                                                                               Appendix D
Appendix D: EPA References: Statutes, Programs, and Activities Related to Recreational
Waters

1. Clean Water Act

In 1972 Congress enacted the first comprehensive national clean water legislation in response to
growing public health concerns related to serious and widespread water pollution. The Federal
Water Pollution Control Act, commonly known as the Clean Water Act (CWA), is the primary
federal law that protects the health of our nation's waters, including lakes, rivers, and coastal
areas.

Section 303 of the CWA directs states, with oversight by EPA, to adopt water quality standards
to protect the public health and welfare, enhance the quality of water, and serve the purposes of
the CWA. Under section 303, each state is required to develop water quality standards for waters
of the United States within the state. Section 303(c) provides that water quality standards must
include the designated use or uses to be made of the water and water quality criteria necessary to
protect those uses.  Water quality criteria must be based on sound scientific rationale and must
contain sufficient parameters to protect designated uses.  EPA's implementing regulations at 40
CFR 131.11 require states to adopt water quality criteria based on EPA's recommended 304(a)
water quality criteria or other scientifically defensible methods.

Several sections of the CWA address the protection of coastal marine and fresh waters.  States
and tribes can use these sections of the statute (sections 312 and 403 (c), in particular) to preserve
water quality by limiting or disallowing discharges that might contain high levels of harmful
microorganisms or pollutants.

Section 312 of the CWA (33 U.S.C. Sec. 1322) regulates the discharge of sewage from vessels
and sets standards for the use of marine sanitation devices (MSDs; boat toilets or heads). States
and tribes can use section 312 to protect human health and aquatic  habitats by requiring onboard
treatment or storage of sewage before it is discharged into coastal waters or a pump-out facility
or by designating no-discharge zones. States arid tribes may designate all or portions of their
waters as no-discharge zones to protect (1) aquatic habitats where pump-out facilities are
available, (2) special  aquatic habitats or species (whether or not pump-out facilities are
available), or (3) drinking water supplies (whether or not pump-out facilities are available). The
implementing regulations for section 312 can be found at 40 CFR Part 140.

Section 402 of the CWA requires municipal and industrial dischargers to waters of the United
States to obtain a National Pollutant Discharge Elimination System (NPDES) permit, which
requires compliance with technology- and water quality-based effluent limits. In addition,
because of the complexity and ecological significance of marine ecosystems, dischargers to the
marine environment beyond the baseline (the territorial sea, contiguous zone, and oceans) must
also comply with section 403 of the CWA, which specifically addresses impacts from such point

July 25,2001 Draft - Do note cite or quote             :                                      D^T

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National Beach Guidance and Grant Performance Criteria for Recreational Waters 	_	

sources on marine resources.  The Ocean Discharge Criteria regulations, which are used to
evaluate NPDES permits for dischargers into marine waters, can be fund at 40 CFR Part 140.
These criteria emphasize an assessment of the impact of an ocean discharge on biological
communities, including human health risks.

2. Draft Implementation Guidance for Ambient Water Quality Criteria for Bacteria-1986

EPA released the Draft Implementation Guidance for Ambient Water Quality Criteria for
Bacteria —1986 in January 2000. This draft guidance provides recommendations to help states,
territories, and authorized tribes implement EPA's recommended water quality criteria for
bacteria.  EPA recognizes there has been some uncertainty among states regarding how EPA's
recommended 1986 bacteria water quality criteria should be implemented and how the transition
should be made from fecal coliforms to E. coli and enterococci. This guidance addresses issues
states have identified as impeding their progress toward adopting and implementing EPA's
current recommended water quality criteria for bacteria. Draft Implementation Guidance for
Ambient Water Quality Criteria for Bacteria —1986 is available at
.
D-2
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                                                                              Appendix E
Appendix E: EPA Grant Coordinators

Table E-l provides the names of the Headquarters and Regional Grant Coordinators and
corresponding contact information.
Table E-l. Regional Grant Coordinators 	 , 	 _ 	 	 	 ,
Region
Headquarters
Washington, DC
Region 1
Connecticut, Maine,
Massachusetts, New
Hampshire, Rhode
Island
Region 2
New Jersey, New
York, Puerto Rico,
U.S. Virgin Islands
Region 3
Delaware, Maryland,
Pennsylvania, Virginia
Region 4
Alabama, Florida,
Georgia, Mississippi,
North Carolina, South
Carolina
Region 5
Illinois, Indiana,
Michigan, Minnesota,
Ohio, Wisconsin
Region 6
Louisiana, Texas
Region 9
American Somoa,
California,
Commonwealth of the
Northern Mariana
Islands, Guam, Hawai
Name
Charles
Kovatch
Matt
.iebman
Helen
Grebe
Nancy
Grundahl
Joel
Hansel
Holly
Wirick
Mike
Schaub .
Terry
Fleming
Address
USEPA
200 Pennsylvania Ave., NW
Mail code: 4305
Washington, DC 20460
USEPA Region 1
One Congress Street
Suite 1100-CWQ
Boston, MA 021 14-2023
USEPA Region 2
2890 Woodbridge Ave. (MS220)
Edison, NJ 08837-3679
USEPA Region 3
1650 Arch Street (3ES10)
Philadelphia, PA 191 03-2029
USEPA Region 4
61 Forsyth Street, 15th Floor
Atlanta, GA 30303-341 5
USEPA Region 5
77 West Jackson Blvd.
(WT-16J)
Chicago, IL 60604-3507
USEPA Region 6
1 445 Ross Ave. (6WQ-EW)
Dallas, TX 75202-2733
USEPA Region 9
75 Hawthorne Street (WTR-2)
San Francisco, CA 941 05
Telephone/Fax
202-260-3754
202-260-9830
617-918-1626
617-918-1505
732-321-6797
732-321-6616
215-814-2729
215-814-2782
404-562-9274
404-562-9224
312-353-6704
312-886-0168
214-665-7314
214-665-6689
415-744-1939
415-744-1078
E-mail
kovatch.charles@epa.gov
iebman.matt@epa.gov
grebe.helen@epa.gov
grundahl.nancy@epa.gov
hansel.joel@epa.gov
wirick.holiday@epa.gov
schaub.mike@epa.gov
fleming.terrence@epa.gov
  July 25, 2001 Draft - Do note cite or quote
                                                                                      E-l

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  National Beach Guidance and Grant Performance Criteria for Recreational Waters
Region
Region 10
Alaska, Oregon,
Washington
Name
Pat
Cirone
Address
USEPA Region 10
120 Sixth Ave. (OW-134)
Seattle, WA 98101
Telephone/Fax
206-553-1597
206-553-0165
E-mail
cirone.patricia@epa.gov
E-2
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                                                                                Appendix F
Appendix F: Beach Evaluation and Classification List

This Appendix provides an example of a list of factors that can be used to rank and classify your
beaches. The list includes available information, pollution threats, sanitary surveys, exposure
considerations, and monitoring data.
Category
Available
Information
Pollution
Threats
Sanitary
Survey
Factors
State water quality reports
Swimmers report health effects from this beach
Advisories issued at this beach last year during the bathing season because of exceedance of
water quality standard or preemptive standard
Beach was closed to bathing during the season last year because of health concerns or
exceedance of water quality standard or preemptive standard
Suspected sources of human pathogen contamination of the water at this beach
Industrial point sources
Urban point sources: POTWs
Urban nonpoint sources: Oil, pesticides, other toxics
Urban nonpoint sources: Sewage, pathogens
Urban nonpoint sources: Plastics and other floatables
Agricultural nonpoint sources: Pesticides and other toxics
Agricultural nonpoint sources: Nutrients/animal wastes
Annual rainfall for this area
Number of significant rainfall events during the past year (e.g., more than 1 inch in 24
that were known to contribute to pathogen contamination)
hours)
Type of terrain within 5 miles of the beach
Average high temperature during the swimming season
Average temperature during the past 30 days
Average flow if beach is on a river or estuary with a flow
Flow during past 30 days if beach is on a river or estuary with a flow
Nearshore water movement if beach is on an ocean, lake, or other nonflowing waterbody with
or without a tide
Number of point source dischargers within 1 mile of this area (include outfalls)
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National Beach Guidance and Grant Performance Criteria for Recreational Waters
Category

Exposure
Considerations
Monitoring
Data
Factors
Area is subject to combined sewer overflows (CSOs) or storm sewer overflows (SSOs)
Area is subject to agricultural runoff during storms
Location of nearest POTW is located
Number of POTWs within 5 miles of beach
Approximate number of septic systems within 5 miles of beach "
Water treatment level in the area
Number of animal feeding operations (AFOs, feedlots) or concentrated animal feeding
operations (CAFOs) within 5 miles of beach
Number of aquaculture facilities within 5 miles of beach
Nature of discharges from AFOs, CAFOs, aquaculture facilities to waterbody adjacent to this
beach
Availability of sanitary facilities for the bathing public during bathing season
Number of marina or pleasure craft with toilets
Wild animals present on or near the beach
Domesticated animals present on or near the beach
Approximate number of birds per hour that frequent a typical 50-meter length of this beach or
nearshore waters
Pollution prevention and abatement efforts in this area
Approximate area of beach open to bathers (length x width at high tide)
Average number of days in the bathing season
Percentage of beach visitors that go in the water
Average density of bathers at peak season (include weekends and holidays)
Average density of bathers during off-peak season
Average density of bathers from the susceptible population (children, elderly)
Average time between an observable problem noted during a sanitary survey and public
notification
Water quality standards used in this jurisdiction
Number of indicators analyzed
Enterococci analyzed
F-2
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                                                                                           Appendix F
Category

Other Factors
Factors
If freshwater, E. colt analyzed
Monitoring data have been used to model risks due to rainfall levels at this beach
Turbidity levels at this beach are related to pathogen contamination
Frequency of sampling at this beach
Number of exceedances of averaging period standard per sampling station at a beach per
month
Number of exceedances of instantaneous standard per sampling station at a beach per month
Importance of this beach to the local economy
Results of public comment/concerns about this beach
If a program is not now in place at this beach, resources available for developing a beach
monitoring and notification program 1
If a program is in place or planned, resources available for maintaining a beach monitoring
and notification program
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F-4
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                                                                                           Appendix G
Appendix G: Conducting a Sanitary Survey
Sanitary surveys are frequently associated
with water supply systems.  They are used
to identify sources of pollution and provide
information on source controls and
identification, persistent problems, and
management actions and links to controls.
Thus, a sanitary survey can be an effective
tool for protecting human health at bathing
beaches and can provide information that
helps in designing monitoring programs
and selecting sampling locations, times, and
frequencies.

G.I    When to Conduct a Sanitary
        Survey
             Using Sanitary Surveys

In the past several years, Delaware has become increasingly
concerned about having to close its beaches to swimming for
extended periods because of bacterial contamination. Lake water
quality and designated uses, such as public swimming, are
threatened primarily by high levels of bacteria.

Trap Pond is one of Delaware's most important freshwater
recreational resources. Located in the Nanticoke watershed, a
priority watershed that drains into the Chesapeake Bay, Trap Pond
is the recreational focus for Trap Pond State Park. Although the
watershed has no point source discharges and little developmental
pressure, erosion, pollution transport, and increased nutrient influx
were contributing to the lake's surface and ground water pollution.
Increasing bacteria contamination and symptoms of accelerated
eutrophication such as algal blooms were becoming increasingly
obvious each season. A comparative study found that Saunders
Branch, the major tributary to Trap Pond, had elevated bacteria and
phosphorus levels.

Sanitary surveys revealed the two probable causes —a direct
discharge from an underground septic system and livestock with
direct access to the stream. Property owners were notified of the
leaking septic systems and corrected the problem, and the bacteria
levels decreased immediately in the affected area of Saunders
Branch. Livestock accessibility, the second cause, was addressed
with a 1-year section 319 grant of $84,419. This grant funded a
conservation planner through the Sussex Conservation District and
Soil Conservation Service. The planner provided technical
assistance to implement animal waste management systems and
nutrient management plans on farms throughout the watershed.
Some 98 percent of the producers installed manure storage
facilities, buffer strips, and other best management practices, and all
producers fenced their livestock out of the streams.
A sanitary survey should be conducted in
suspected high-risk situations to identify or
confirm the presence or absence of
contamination sources and to aid in beach
classification.  In addition, sanitary surveys
may be performed periodically during a
swimming season, when a bacterial
exceedance is measured,  or more frequently
depending on the length of the bathing
season (CTDEP, 1992; Figueras et al.,
2000; Great Lakes-Upper Mississippi River
Board of State Sanitary Engineers, 1990).  A sanitary survey should also be conducted as part of
any proposal to expand or develop a recreational beach area or when newly proposed activity
would significantly alter the water quality in an existing recreational beach area.  The findings of
the survey should receive prime consideration in any decision to proceed with development. In
some states, such as Maryland, a permit for operation of a bathing beach may not be issued if a
detailed sanitary survey reveals sources of pollution that affect or might affect the bathing beach
(Maryland Department of Health and Mental Hygiene, 1978). If a significant pollution event
occurs during the bathing season, a source identification should be conducted rather than a
comprehensive sanitary survey.
July 25, 2001 Draft - Do note cite or quote
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National Beach Guidance and Grant Performance Criteria
G.2   Who Conducts a Sanitary Survey

The EPA/State Joint Guidance on Sanitary Surveys recommends that a Registered Sanitarian or a
Registered Environmental Health Specialist conduct and/or supervise the sanitary survey. The
Connecticut Department of Environmental Protection recommends that the local health
department conduct a sanitary survey of any watershed that drains to a public bathing area
(CTDEP, 1992). The Great Lakes-Upper Mississippi River Board of State Sanitary Engineers
suggests that the official agency regulating the bathing beach or a person or persons acceptable to
that agency should conduct the sanitary survey.

G.3   Steps for Performing a Sanitary Survey

The survey should identify new sources of microbiological hazards and evaluate the adequacy of
the existing sampling program and the corrective measures in place to deal with existing hazards.

The Guidance Manual for Conducting Sanitary Surveys of Public Water Systems: Surface Water
and Ground Water Under the Direct Influence (GWUDI) of Surface Water (USEPA, 1999a)
established four steps for conducting a comprehensive sanitary survey:

1. Plan the survey
2. Conduct the survey and site visit
3. Compile the sanitary survey report
4. Review and respond to the report

Examples of how to conduct a sanitary survey are also provided in the Guidance Manual for
Conducting Sanitary Surveys of Public Water System (USEPA, 1999a), the National Shellfish
Sanitation Program Model Ordinance (NSSP, 1997), and California's Guidance for Saltwater
Beaches (draft) and Guidance for Freshwater Beaches (draft) (CADHS, 2000).  A brief
description of the process is provided in the following paragraphs.

G.3.1  Planning the Survey

Before initiating other survey activities you should review the previous sanitary survey report as
well as collect and review any existing data or reports on the area.  These materials will help you
design a thorough and efficient on-site evaluation. You can collect historical data on tides,
currents, prevailing winds, rainfall,  discharges of wastewater treatment plant effluent, storrn
water outfalls, combined sewer overflows, and urban and agricultural effluents.  Compile a
checklist to ensure that all potential sources of pathogen contamination or other hazards that need
to be identified are assessed during  an on-site visit.  The purpose of an on-site visit is to identify
and evaluate all existing and potential sources of microbiological contamination that could affect
the safe use of the area. The checklist in Appendix F can help you target areas to examine as part
of the on-site evaluation.
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                                                                               Appendix G
G.3.2  Conducting the Sanitary Survey

For the purposes of this guidance, the significance of rainfall, climate, terrain, flow, and sources •
of pollution in the watershed and at the beach should be determined to aid in the beach
evaluation process.

•  Rainfall and climate.  Pollution can typically be expected to reach a peak after rainfall when
   storm water runoff washes fecal material into receiving waters (Jagals, 1997). As part of the
   beach evaluation process, therefore, it can be helpful to identify the annual rainfall for the
   area, the pattern of rainfall in the 30 days before the survey (i.e., has it been below normal,
   normal, or above normal?) and the number of significant rainfall events (e.g., more than 1
   inch in 24 hours) in the past year. The type of terrain, the permeability of the soils, and the
   storage characteristics of the watershed can also affect the rate at which runoff reaches the
   beach (Novotny and Olem,  1994). Very hilly or mountainous terrain increases the amount of
   runoff and the rate of which it reaches the beach. The average high temperature during the
   swimming season and the temperature pattern during the last 30 days can affect pathogen
   survival. Microbial growth rates tend to increase as temperatures rise (Auer and Niehaus,
   1993).

•  Water flow.  The average flow and the flow during the last 30 days are important factors to
   consider for beaches on rivers or estuaries.  For nonflpwing waterbodies (lakes, oceans) with
   or without a tide, nearshore water movement is important to consider. Water movement
   affects the concentration of pathogens. Waterbodies with little or no flow or water
   movement usually have higher pathogen concentrations.

•  Sources of pollution in the watershed.  Determining the location and impact of pollution
   sources in the watershed can also aid in the beach evaluation process.  Pollution sources that
   are closer to the beach or that occur more frequently have a greater effect on the beach than
   pollution sources that are farther away and occur less frequently. These sources all have the
   potential to contribute to the bacterial and pathogen load affecting the recreational beach, and
   therefore it is important to identify them during a sanitary survey. Once the sources have
   been identified public health can be protected by enforcing proper discharge levels (Thomann
   and Mueller, 1987; USEPA, 1994b).

•  Water treatment level. The water treatment level and pollution prevention and abatement
   efforts in the area also play  an important role in beach evaluation. Tertiary treatment
   removes more pathogens  than primary, secondary, or no treatment; therefore, areas  where
   tertiary treatment occurs are at lower risk than areas where primary, secondary, or no
   treatment occurs (Thomann and Mueller, 1983).  Pollution prevention and abatement efforts
   can help to minimize health risks to bathers. Areas that have excellent pollution prevention
   and abatement efforts can be of lower risk than areas where few such efforts occur.
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National Beach Guidance and Grant Performance Criteria
•   Sources of pollution at the beach. Human and animal fecal pollution that occurs at the
    beach is an important source of pollution. The adequacy of the sanitary facilities for the
    bathing public should be evaluated. Marinas, pleasure craft with toilets, wild or domestic
    animals and birds, and failing septic drainfileds or tanks can also be direct sources of fecal
    pollution to recreational waters and the beaches adjacent to them (NRDC, 1999; USDHHS,
    1985; Weiskeletal., 1996).

G.3.3  Compiling the Sanitary Survey Report

Final written reports should be prepared.for every sanitary survey in a format that is consistent
statewide (USEPA, 1999a) or that meets the criteria of the particular program for which the
sanitary survey is being conducted. The NSSP (1997) recommends that the following
components be included hi sanitary survey reports for shellfish growing areas:

•   An executive summary that includes a description of the area, a location map, and the history
    of the water quality of the area (if known).

•   A pollution source survey, including a summary of the sources, a map or chart documenting
    the location of the major sources, and an evaluation of the pollution sources and the
    magnitude of the pollutants they produce.

•   Information about physical factors that can affect the distribution and concentration of
    microorganisms and microbial water quality.

•   A description of the hydrographic and meteorological characteristics, including tides, rainfall,
    winds, and river dischargers, and a summary discussion concerning the actual or potential
    effect of transport of pollution to the area.

•   Water quality studies, including a map of the sampling stations; the sampling plan and
    justification; the sample data analysis; and presentation and interpretation of the data,
    including the effects of meteorological and hydrographic conditions on bacterial loading and
    the variability of the data.

•   A conclusion section that includes recommendations for improvement.

The Guidance Manual for Conducting Sanitary Surveys of Public Water Systems (USEPA,
1999a) suggests that the survey report include the date and time of the survey, the names of
survey inspectors, a summary of survey findings with the signatures of survey personnel, a listing
of deficiencies based on a regulatory reference, recommendations for improvement in order of
priority, and a copy of the survey form. For examples of a sanitary survey report, refer to
Bartram and Rees (2000) and NSSP (1997).
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                                                                                       Appendix G
         With a completed sanitary survey report, a more accurate assessment of public health risk at a
         beach can be made. Also, informed decisions on how to improve public health at the beach and
         the implementation of new or unproved sampling locations and frequencies can be discussed.
         Evaluation criteria contained in the sanitary survey checklist in Appendix F include the
         following:

         •  Annual rainfall for the area
         •  Amount of rainfall in the last 30 days
         •  Number of significant rainfall events (e.g., more than 1 inch in 24 hours during the past year)
            that might have contributed to pathogen contamination
         •  Area within 5 miles of the beach
         •  Average high water temperature during the swimming season
         •  Water temperature during the past 30 days
         •  Average flow of beach if the beach is on a river or estuary
         •  Average flow during past 30 days if the beach is on a river or estuary
         •  Water movement if the beach is on an ocean, lake, or other nonflowing waterbody with or
            without a tide
         •  Number of point source dischargers within 1 mile of this area (include outfalls)
         •  Area subject to combined sewer overflows (CSOs) or storm sewer overflows (SSOs)
         •  Area subject to agricultural runoff during storms
         •  Nearest POTW
         •  Number of POTWs within 5 miles of beach
         •  Approximate number of septic systems within 5 miles of beach
         •  Water treatment level in this area
         •  Number of animal feeding operations (AFOs, feedlots) or concentrated animal feeding
            operations (CAFOs) within 5 miles of beach
         •  Number of aquaculture facilities within 5 miles of beach
         •  Nature of discharges from AFOs,  CAFOs, aquaculture facilities to waterbody adjacent to this
            beach
         •  Sanitary facilities during peak season
         •  Presence of a marina or pleasure craft with toilets
         •  Wild animals present on or near the beach
         •  Domesticated animals present on or near the beach
         •  Approximate number of birds per hour that frequent a typical 50-meter length of this beach or
            nearshore waters
         •  Pollution prevention and abatement efforts in this area
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National Beach Guidance and Grant Performance Criteria
G.4    References

Auer, M.T., and S.L. Niehaus. 1993. Modeling fecal coliform bacteria—I. Field and
laboratory determination of loss kinetics. Water Resources 27(4): 693-701.

Bartram, J., and G. Rees. 2000. Monitoring Bathing Waters: A Practical Guide to the Design
and Implementation of Assessments and Monitoring Programmes. E & FN SPON, London.

CADHS. 1998.  Beach Sanitation Guidance for Saltwater Beaches. California Department of
Health Services. December 2, 1998.
http://www.dhs.cahwnet.gov/ps/ddwenvl3eaches/saltwater.htm.

CTDEP. 1992. Guidelines for Monitoring Bathing Waters and Closure Protocol.
Connecticut Department of Environmental Protection.

Great Lakes-Upper Mississippi River Board of State Sanitary Engineers. 1990. Recommended
Standards for Bathing Beaches. Health Education Service, Albany, NY.

Maryland Department of Health and Mental Hygiene. 1978. Public Swimming Pools and Bathing
Beaches, Code of Maryland Regulations 10.17.04, Baltimore, MD.

NRDC. 1999. Testing the Waters: A Guide to Water Quality at Vacation Beaches. Natural
Resources Defense Council, New York, NY.

NSSP. 1997. National Shellfish Sanitation Program Model Ordinance. National Shellfish
Sanitation Program. US  Food and Drug Administration, Washington, DC.

Thomann, R.V., and J.A. Mueller. 1983. Principles of Surface Water Quality Modeling and
Control. Harper & Row, Publishers, New York.

USEPA. 1994b. Combined sewer overflows control program. U.S. Environmental
Protection Agency. Federal Register. Apr. 19, 1994, 59(75).

USEPA. 1999a. Guidance Manual for Conducting Sanitary Surveys of Public Water Systems:
Surface Water and Ground Water Under the Direct Influence (GWUDI) of Surface Water. EPA
815-R-99-016. U.S. Environmental Protection Agency, Office of Water, Washington, D.C.
G-6
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                                                                              Appendix H
Appendix H: Monitoring Design Approach

The National Research Council (NRC, 1990a, 1990b) has evaluated marine monitoring programs
and practices and has made a series of recommendations to improve the usefulness of monitoring
information.  EPA (USEPA, 199la) suggested the following steps based on the NRC's findings
for designing successful monitoring programs.  These steps can be used to develop a beach
monitoring program.

Step 1. Develop monitoring objectives

Clear objectives should be developed for each component of the monitoring program.
Microbiological monitoring of recreational waters, in most cases, is undertaken to establish the
degree of allowable microbiological pollution to protect public health and the environment.  For
beach management programs, recreational waters should attain criteria as protective as those
EPA established in Ambient Water Quality Criteria for Bacteria -1986 (USEPA, 1986). For
example, if the geometric mean of the enterococci densities exceeds 35 per 100 mL in marine
waters and 35 per 100 rnL in freshwater, human health might be affected and an advisory should
be considered. Similarly, if the geometric mean of the E.  coli densities exceeds 126 per 100 mL
in freshwater, human health might be affected and an advisory should be considered. Although
an advisory should be considered when a sample exceeds water quality standards, it is ultimately
a state or local decision to determine when to issue an advisory or closing. Therefore, the
corresponding objective of the monitoring program would be to detect exceedances of the
appropriate water quality standards.

Step 2. Establish testable hypotheses and select statistical methods

Monitoring program objectives should be translated into statistically testable hypotheses.
Establishing testable hypotheses ensures that the results of the monitoring program will be
unambiguous and that the objectives of the program can be met. This approach results in the
creation of a threshold level for determining when to record an exceedance and notify the public.

Step 3. Select analytical methods and alternative sampling designs

Detailed specifications for the analysis of each environmental variable of the monitoring program
should be developed, including field and laboratory protocols and quality assurance/quality
control procedures. In addition, alternative spatial and temporal sampling designs should be
devised.  The sampling designs should specify the number and location of sampling points,
sample frequency, and level of sample replication. This information will then be us'ed in the next
step to evaluate expected monitoring program performance and to select the most efficient
sampling design among the alternatives.
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National Beach Guidance and Grant Performance Criteria for Recreational Waters	_	___

Step 4. Evaluate expected monitoring program performance

The evaluation of monitoring program performance is potentially the most important step in the
design and review process (USEPA, 199la). Before the program begins, an evaluation of
alternative sampling designs assists in the selection of the most appropriate design for cost-
effective sampling that meets the program objectives. During the course of the monitoring effort,
performance evaluations provide a systematic procedure for measuring success in terms of the
ability to continue to meet program goals. The periodic evaluation process also identifies the
need to modify the sampling design and methods.  Without this evaluation, there is a risk of
collecting and analyzing too few or too many samples.  The results of this evaluation are used to
identify the modifications to the initial design necessary to increase monitoring program
effectiveness.

Step 5. Implement data analysis

The development of a data management system is an essential task in the design of monitoring
programs, and sufficient funds should be provided to cover data analysis.  The data management
system should be operational before the monitoring program is implemented. In addition to
specifying data analysis methods, an expeditious timetable for analyzing the data, and the
procedures for reporting and communicating the results, the data management system should be
used to assess implementation progress and monitoring program performance. The results of the
performance assessment can be used to refine the program objectives and to modify individual
study elements to satisfy those objectives.
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                                                                                Appendix I
 Appendix I: Data Quality Objectives

 This appendix provides information about the basic planning elements of the QAPP, SOP, and
 DQO process, as well as some additional information.  It is important to note that the planning
 process is an iterative process. The personnel planning the program should incorporate changes
 as the need for them is identified and should review how those changes affect other elements of
 the program, making revisions to those elements as necessary.

 1.1     Identify the Decision Maker and Program Personnel

 A beach water quality monitoring program requires the efforts of program managers, technical
 staff, and potentially a variety of interested parties or stakeholders.  The team involved in
 planning and implementing the program might include senior government officials from offices
 established to protect health or environmental quality; technical experts familiar with the issues
 and methods to be used; data analysts; data users, including risk assessors and the manager or
 program leader who will make the advisory or closing decision; and quality assurance specialists.
 Individuals or organizations that might be directly affected by the decision should also be
 involved in planning the monitoring program to improve communication and build consensus.
 The members of this group will be able to offer different perspectives and assist in solving
 problems.  They might be involved hi development of the plan at different stages and through
 different types of meetings or other activities.

 It is important to note that some personnel manage or perform the work of the monitoring
 program, while other personnel who do not actually do the work are needed to provide oversight
 and ensure the quality of the work being performed. Quality control (QC) is a system of
 technical procedures and activities developed and implemented to produce measurements of
 requisite quality. Quality assurance (QA) is an integrated system of management procedures and
 activities used to verify that the QC system is operating within acceptable limits.  QA oversight is
 important to maintain the credibility of a beach monitoring program. QA personnel should be
 identified at the planning stage and included during the operation of the program to assess all
 aspects of data collection.

 1.2    Clarify Monitoring Program Goals and Objectives

 A clear statement of the purpose of the monitoring program and the program's objectives is
 necessary to avoid confusion and prevent wasting of resources.  As noted in EPA's monitoring
 guidance (1997b), monitoring programs can be undertaken for different reasons and to answer
 different questions.  The types, quantity, and quality of the data can vary considerably to meet
 different goals. A conceptual model of the potential environmental hazard should be prepared.
This model can be in the form of a diagram illustrating known or suspected sites of
contamination at one Or more beaches, sources of microorganisms, and exposure scenarios (e.g.,
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters

 children playing in sand or shallow water, swimming, or surfing). The problem to be
 investigated needs to be defined.  The following are examples of monitoring program goals:

 •  Determine whether an impairment exists.
 •  Determine the spatial and temporal extent of the impairment.
 •  Determine the causes and sources of the impairment.

 An example of the first type of program goal is routine monitoring to protect human health by
 comparing levels of indicator bacteria to the ambient water quality criteria for bacteria (USEPA,
 1986) during the swimming season. The basic decision to be made is whether the criteria are
 being exceeded so that an advisory can be posted or the beach closed. Based on the initial
 monitoring results, intensive monitoring involving the collection of water samples at different
 times (e.g., daily or only after storm events) and from many locations (e.g., waterbodies
 downstream from the initial location might be indicated).  Intensive monitoring might be
 indicated while  establishing your monitoring program to pinpoint the most appropriate locations
 for the routine sampling effort and the depths, times, and procedures needed to collect the
 samples.  It might be needed during the program to evaluate whether the sampling design in use
 is continuing to effectively protect human health. Intensive monitoring can be used to determine
 the most appropriate sampling frequency needed to assess  standards. Intensive m'onitoring might
 also be desirable or necessary to identify the point and nonpoint sources that could be responsible
 for waterbody impairment or to evaluate the influence of rainfall on the bacterial load at a
 particular beach. Extensive sampling is needed for the development of predictive tools using
 statistical analysis or mathematical models.

 This guidance focuses on routine monitoring for beach advisory or closing decisions. An
• example of a principal study question is

    Could levels of bacteria in the water at Bayside Beach affect swimmers' health?

 Examples of alternative actions that might be considered if the answer to this question is "yes"
 include the following:                                                         .

    Post an advisory at the beach to warn swimmers of the potential hazard.
    Close the beach and do not permit swimming until further notice.
    Conduct a sanitary survey to identify point and nonpoint sources of bacteria.
    Take no action.

 The following is an example of a decision statement for this type of program:

    Determine whether bacterial indicator levels require taking action to protect human
    health.
 1-2
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                                                                               Appendix I
Decision rules developed for this program at a freshwater lake might include the following
examples:

   If the density ofenterococci in any one sample exceeds the EPA instantaneous (single-
   sample) criterion of 61 per 100 mL, the water is sampled again.

   If the density ofenterococci in the second sample exceeds the EPA instantaneous
   criterion, the beach is closed.

   If the running geometric mean of enterococcal densities from 5 sequential samples taken
   during the previous 30 days is greater than the EPA averaging period criterion of 33 per
   100 mL, the beach is  closed.

   If the density of indicator bacteria does not exceed the criteria under the above
   conditions, swimmers are not at risk and the beach remains open.

1.3     Describe the Monitoring Program

The planning team should discuss what information is needed to make the decision. In the above
example, it is obvious that bacterial densities are necessary. Other types of information that
might be useful  are measurements of other environmental factors, such as temperature, nutrients,
dissolved oxygen, salinity, turbidity, or water flow, which might provide supporting evidence for
the existence of the problem or the seriousness of an exceedance.

The regulatory basis for the decision, in this case EPA's ambient water quality criteria for
bacteria, should be documented. In addition, spatial and temporal boundaries for the monitoring
program should be examined. For example, a beach might extend for many miles along the
coastline of a jurisdiction, but swimmers have access to only a few hundred feet of shoreline at
the end of one road. In addition, the presence of a storm sewer outfall on the beach might be the
focus of sampling.

One or more members of the planning team should document these elements of the program in
the monitoring plan. The team should also review available resources, relevant deadlines, the
budget, the availability of personnel, and schedule requirements to determine how they will affect
sampling at the beach(es) in question.  This information should be evaluated along with the
proposed sampling design and the boundaries of the monitoring program (see below) to assess
how well the program objectives can be met within the various technical and cost limitations.

1.4     Identify the Type of Data Needed and the Sampling Design

Various sampling designs have been used for monitoring recreational waters adjacent to bathing
beaches.  The sampling design specifies the number, location, and types of samples to be
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National Beach Guidance and Grant Performance Criteria for Recreational Waters

collected, as well as conditions under which they should be collected, the analyses to be
performed, and the QA and QC procedures required to ensure that sampling design and
measurement errors are controlled to meet the tolerable decision error rates specified in the
DQOs.

Because enterococci and E. coli are commonly found in the feces of humans and other warm-
blooded animals, the presence of enterococci or E. coli in water is an indicator of fecal pollution
and the possible presence of enteric bacteria that pose a risk to human health.  Epidemiological
studies have led to the development of criteria that can be used to promulgate recreational water
standards based on the established relationship between health effects and water quality (Chapter
1). The significance of finding enterococci or E. coli in recreational water samples is the direct
relationship between the density of enterococci or E. coli in the water and the incidence of
swimming-associated gastroenteritis, as found in studies of marine and freshwater bathing
beaches (Cabelli, 1980; Dufour, 1984).

Currently, monitoring the quality of recreational waters should be based on the collection of five
samples during a 30-day period and the calculation of a running geometric mean to determine
whether the estimated bacterial densities exceed the water quality standards (USEPA, 1986).
EPA recognizes, however, that this sampling pattern does not provide timely, accurate
information for risk managers or the public.

Although statistical or probabilistic  sampling designs are highly desirable, not every sampling
problem can be solved with these designs. Local limitations in staff and funding might also
strongly affect the number of samples that can reasonably be analyzed during the swimming
season. Basic sampling design should address the following seven aspects (Bartram and Rees,
2000):

1. Reasons to sample
2. What to sample
3. How to sample
4. When to sample
5. Where to sample
6. How many samples to take
7. Sampling evaluation                               •

A sampling and analysis plan should include the location of sampling sites, frequency of
sampling, duration of the sampling period, and depth of sampling. For each recreational
waterbody, the plan should also include other pertinent information, such as the types of
containers to be used for sampling, how to package samples for transport, references for
analytical methods, how to report data, and requirements for repeat sampling. The plan should
be developed in conjunction with the local laboratory that will conduct the bacteriological
analyses (CADHS, 1999).
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                                                                                 Appendix I
It is difficult to decide the optimum number of samples to take and the most suitable locations to
characterize the water quality in the most meaningful way. Sampling marine and estuarine
waters requires considering tidal cycles, current patterns, bottom currents, countercurrents,
stratification, seasonal fluctuations, dispersion of discharges, multidepth sampling, and many
other factors. Sampling lakes and rivers adjacent to beaches requires considering wind and flow
and whether the beach is upstream or downstream of pollution sources, as well as time of day
(see box at right). Determining the most appropriate, cost-effective use of the resources available
for a monitoring program is also difficult. The following aspects of sampling are presented for
consideration as you develop your monitoring plan:
                                                 A study was conducted at two beaches on Lake
                                                 Erie to evaluate the water sampling design for
                                                 the collection of several microbiological
                                                 indicator organisms in relation to day, time,
                                                 and location of collection. The concentrations
                                                 of these organisms were generally found to
                                                 vary significantly by the specific time of day
                                                 and day of the weekend that collection took
                                                 place. However, the concentrations did not
                                                 vary significantly at various locations in the
                                                 bathing area. Sampling at different locations
                                                 in the bathing area might be considered for
                                                 beaches that have poor dispersion of fecal
                                                 waste sources (Brenniman et al., 1981).
Location. Sampling locations are chosen based
on historical records, usage, current situations,
concentration of bathers, pollution sources,
accessibility, and other factors.  Areas known to
be chronically contaminated, as well as areas that
typically have the highest bather density, should
be included in the sampling plan. An area close
to a storm water outfall might have high counts
of bacteria, but it might not be an area commonly
used for swimming.  Therefore, the priority might
be to sample in the area where more swimmers
are located to obtain a better estimate of risk to
human health. Ultimately, these decisions are
appropriate for the beach manager to make.
Table 4-1  should be consulted for guidance. In
addition, other criteria for sampling might be
defined, such as obtaining the sample at a specified distance from swimmers and animals and not
in the "swash zone" area of low waves near the shore (IITF, 1999), as well as spacing samples at
specified intervals for lengthy stretches of beach.

Frequency. Ideally, when first establishing a recreational water quality monitoring program, the
optimum sampling frequency is daily and samples of estuarine or marine bathing waters should
be obtained at high tide, ebb tide, and low tide to determine the cyclic water quality and
deterioration that should be monitored during the swim season (Bordner et al., 1978;  see box
below). Lakes and rivers might also be sampled at different times; for example, during calm vs.
windy days or during low-flow vs. storm-flow conditions. If a beach monitoring program does
not have the resources to sample this often, a minimum frequency of sampling should be
established locally, based on historical records, usage, current situations, and the potential for .
health hazards and in accordance with the number of samples indicated by the water quality
standards  on which your decision will be based.  In highly populated or high-risk areas, more
frequent sampling is appropriate, as suggested by the tiered approach (Table 4-1). Sampling
might be needed under some circumstances, such as where no sanitary facilities are provided at a
beach or when toilets at the beach are not open or operational.
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters
 Subsequent sampling might also be needed
 to determine when to reopen a recreational
 area after a beach closing.  Sampling
 frequency can be related to the peak bathing
 period, which is generally in the afternoon,
 but preferably samples are collected in both
 the morning and afternoon (Bartram and
 Rees, 2000), at least for beaches classified
 as high-priority. Weekends and holidays
 should be considered in the sampling
 program. If you wish to characterize the
 water quality at the beach before the
 weekend crowd arrives, you might want to
 sample on Thursday so that the results are
 ready by Friday. If you wish to characterize
 the water quality at the beach after the
 weekend crowd has left, sample late Sunday
 or on Monday. The frequency of sampling
 might change according to your beach
 classification.

 Sampling Depth.  The primary factor for
 determining depth of sampling the users at
 risk.  Samples of ankle- and/or knee-depth
 water might be more appropriate for
 children and infants, whereas waist- and/or
 chest-depth samples might be more
 appropriate for adults (Refer to Table 3-1).
 Sampling from boats is usually inadequate
 for beach monitoring because water depths
 would exceed those common to beach-
 related recreational activities, especially for
 young children (CADHS, 1999).  Local
 health agencies, however, might desire to assess water quality away from the shore in additional
 areas where surfing, windsurfing, or other activities occur.

 Sampling Time. The most appropriate time of sampling should be chosen to obtain the best
 estimates of water quality conditions during the highest periods of risk. Wave and tidal actions
 affect bacteria levels, as do the number of bathers at the time of sampling and before and after
sampling; the  water temperature; and the recent, current, and predicted weather conditions (e.g.,
wind, rain). Bacteria levels change frequently, based on these types of environmental conditions.
You should take this factor into account when formulating a sampling design and when
Water quality data for the years 1979 to 1981 were
obtained for a marginally polluted beach in New York
(New York City Department of Health, 1981). A
standard of 2,400 total coliform organisms per 100
mL of sample was used.  On a particular day during
May through September, one sample per hour was
taken for 7 hours. Analysis of the water quality at this
location with respect to infra-day variation showed
significantly higher mean densities during the first 2
hours of sampling than during the last 2 hours of
sampling. During the 3 years studied (1979 -1981),
morning coliform densities tended to be significantly
greater than the standard, whereas afternoon samples
tended to be significantly lower than the standard.
These differences were likely due to environmental
factors such as wind and  local currents.  Because such
environmental factors vary from location to location,
the finding of significant  intra-day variation in
indicator organism density at this location strongly
argued for sampling strategies that ensured numerous
determinations could be made on each sampling date.

Analysis of the inter-year variability of coliform
density at this location showed this variability to be
quite low. Analysis using only one-half of the 3 years
of data compiled by the New York City Health
Department gave a profile of water quality at this
location that showed little difference from the
analysis using the full data set.  This fact, coupled
with the previous findings of the study, indicated that
sanitary surveys should maximize  the number of
replicate determinations made per sampling date
instead of maximizing the number of days on which
samples are taken (Fleisher, 1990).
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                                                                               Appendix I
interpreting sampling results and analyses. If you want to capture the conditions of your beach
when the most people are in the shallow waters, conduct your sampling during high tide when
bacteria levels might be higher near the shore (see Table 4-1). To estimate how water quality is
affected by the number of swimmers in the water, sample the water during the time of day when
there is the highest bather density at your beach.

hi addition, you might want to sample after the weekend to capture the conditions of the water
after the highest bather density.   Or you might want to collect water samples on Thursday so that
you can inform weekend visitors about water quality before they swim on the weekend. (This
type of sampling is recommended for use  only on a temporary basis if resources prevent daily
sampling on a routine basis. It should be done only to obtain a better understanding of indicator
occurrence patterns on which to base the development of a more minimalistic sampling approach
that captures and best represents those patterns.) Ideally, sampling should be done throughout
the day and week to  look for patterns of bacteria levels. However, it is important to remember
that the results of the laboratory test will take approximately 24 hours.

The final sampling design should be carefully documented in a sampling and analysis plan or
incorporated into a QAPP.  (Refer to USEPA, 1998 and 1999a for further information-on QAPP
preparation.)  The plan should include a rationale and listing of the location of all sampling sites
and stations within a site, the frequency of sampling at each station, the depth of water sample
collection, and the duration of the sampling period (e.g., one time only, 2 weeks in July, during
the open swimming  season).  The plan should also include the procedures for obtaining the
samples and analyzing them for bacterial indicators), procedures for collecting other data from
the field, when repeat sampling will be performed, and how and to whom data will be reported.
Standard Operating Procedures (SOPs) should be prepared for all activities that need to be
performed the same  way every time. Each SOP should include details  on the method for a given
operation, analysis, or action in sequential steps, as well as the facilities, equipment, materials
and methods, QA  and QC procedures, and other factors required to perform the operation,
analysis, or action.

1.5 Quality Objectives and Criteria                                   ,

Data quality is defined by a series of statements that set the standards the data must meet.  These
standards cover the way the sample is collected and analyzed, as well as certain performance
criteria which, if met, ensure that the data are acceptable and usable by the decision maker. As
part of the DQO process, the planning team needs to establish program and measurement quality
objectives to enable  the data user to understand any errors or uncertainties associated with the
data. Two categories of errors are commonly recognized, sampling error and measurement error.
Sampling error is the difference between sample values and in situ "true" values, and it results
from unknown biases due to sampling design, including natural variability due to spatial  .
heterogeneity and temporal variability in microorganism abundance and distribution.
Measurement error is the difference between sample values and in situ "true" values associated
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National Beach Guidance and Grant Performance Criteria for Recreational Waters                    	

with the measurement process, including bias and imprecision associated with sampling
methodology, specification of the sampling unit, sample handling, storage, preservation,
identification, instrumentation, and other factors.

The monitoring program should specify methods and procedures to reduce the magnitude of
measurement error sources and frequency of occurrence. For example, using trained staff to
perform the data collection and analyses and following standardized, repeatable procedures for
data and sample collection can help eliminate sloppy, inconclusive work. Uncertainty in the data
because of sampling and measurement errors or errors introduced during data manipulation could
result in identifying a risk to human health when one does not exist (i.e., the true density of
bacteria is not greater than the criterion) or not identifying a risk when one does exist (i.e., the
true density of bacteria exceeds the criterion). Data entry, transfer, calculation, and reporting
mistakes can compound these issues.  Data entries and the procedures for calculating results must
be carefully checked for correctness and completeness.

Measurement performance criteria are qualitative and quantitative statements used to interpret
the degree of acceptability or utility of the data to the user.  These criteria, also known as data
quality indicators (DQIs), include the following:

•   Precision
•   Bias
•   Representativeness
*   Completeness
•   Comparability

Sometimes DQIs for some parameters cannot be expressed in terms of precision and bias
(accuracy) or completeness. In these cases a full description of the method by which the data will
be obtained should be included in the plan.  The various measurement performance criteria that
should be established for beach water quality monitoring parameters are discussed in the
following subsections.

Precision
Precision is defined as the  degree of mutual agreement or consistency between individual
measurements or enumerated values of the same property of a sample.  Obtaining an estimate of
precision provides information on the uncertainty due to natural variation, sampling error, and
analytical error. The precision of sampling methods is estimated by taking two or more samples
at the same sampling site at approximately 10 percent of the sites. The precision of laboratory
analyses is estimated by analyzing two or more aliquots of the same water sample. This data
quality indicator is obtained from two duplicate samples by calculating the relative percent
difference (RPD) as follows:
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                                                                               Appendix I
                                                  -x100
                                        (C1+C2)/2

where C, is the first of the two values and C2 is the second value. Because the absolute value of
the numerator is calculated, the RPD is always a positive number. If it is to be calculated from
three or more replicate samples, the relative standard deviation (RSD) is used and is calculated as

                                   RSD = 4 x 100
                                           x
                     f
where s is the standard deviation and x is the mean of repeated samples. The standard deviation
or the standard error of a sample mean(s) is calculated as
                                  SD =
                                        \
n-1
where Xt is the measured value of the replicate, x is the mean of repeated sample measurements,
and n is the number of replicates. Precision can also be expressed in terms of the range of
measurement values.

Because of the heterogeneity of populations of bacteria in surface waters, an RPD of less than or
equal to 50 percent between field duplicates for microbiological analyses might be considered
acceptable. In laboratory analyses, the precision among laboratories following EPA Method
1600 for detecting enterococci from separate aliquots of the same sample was determined to be
2.2 percent for marine water samples and 18.9 percent for fresh surface water samples (USEPA,
1997a). Analysts should be able to duplicate bacterial colony counts on the same membrane
within 5 percent and the counts of other analysts within 10 percent; otherwise, procedures should
be reviewed and corrective action implemented (IITF, 1999).

Accuracy
Accuracy is the'degree of agreement between an.observed value and an accepted reference or true
value.  Accuracy is a combination of random error (precision) and systematic error (bias), both of
which are due to sampling and analytical operations.  Bias is the systematic distortion of a
measurement process that causes errors in one direction so that the expected sample
measurement is always greater or lesser to the same degree than the sample's true value.
Because accuracy is the measurement of a parameter and comparison to a "truth" and the true
values of environmental physicochemical and biological characteristics cannot be known, use of
a surrogate is required.
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National Beach Guidance and Grant Performance Criteria for Recreational Waters

The accuracy of field measurements is usually evaluated by analyzing samples prepared from
known concentrations of the pollutant(s) of interest or by adding known concentrations of the
pollutant(s) of interest to field-collected samples (known as "spiked" samples). In studies
following Method 1103.1 (USEPA, 1985) to estimate densities of E. coli, use of samples
prepared from known quantities of freeze-dried and cultured E. coli as a surrogate resulted in
97.9 percent recovery of the bacteria from water samples. Based on the mTEC medium, bias was
determined to be -2 percent of the true value. This information is helpful in establishing the most
appropriate methods  to be followed. Accuracy, defined as the similarity of a repeated entity to its
original form, such as information, data entry,  and calculations, can be controlled by double-
checking sources, manual data entries, or electronic data transfers and performing recalculations.
Figure G-l is a graphical representation of the  relationship between bias and precision, and
accuracy.

Representativeness
Data representativeness is defined as the degree to which data accurately and precisely represent
the characteristics of a population, and therefore it addresses the natural variability or the  spatial
and temporal heterogeneity of a population. It is not quantitative but descriptive in nature, and it
can be assessed only by evaluating the sampling design with respect to the particular features of
the water at each beach. It is possible to quantitatively estimate sample sizes using estimates of
variance and selecting acceptable levels of false positive and false negative error.

hi the sampling design, care should be taken to define the area of sample collection and
determine whether it is typical and representative of each area of concern. For swimming
beaches less than 30 m in length, a single sample taken from water at the midpoint of the beach
site might suffice. For lengthy beaches, establishing the number of samples that need to be taken
to ensure that the estimated bacterial densities  provide a reasonable representation of the
potential risk from waterborne pathogens can be problematic.  For example, the monitoring
program might decide to sample from the middle of the area where most swimmers congregate
and then 15 m on either side of that first sampling station to obtain an average value of bacterial
densities for comparison against the standard.  Alternatively, each individual sample result might
be compared to the standard. At beaches where a known point source of pathogens, such  as a
storm water outfall, enters the water, the sample might be drawn from stations within 15m of the
point source or where swimmers might be considered to be at greatest risk from exposure.
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                                                                                            Appendix I
                             (e)
              Figure G-l. Graphical representation of the relationship between bias and precision, and
              accuracy (after Gilbert, 1987). (a): high bias + low precision = low accuracy; (b): low
              bias + low precision = low accuracy; (c): high bias + high precision = low accuracy; and
              (d): low bias + high precision = high accuracy.
          As noted above, an initial intensive sampling study might be necessary to help decide where and
          how often samples need to be routinely collected to address bacterial heterogeneity. If sufficient
          resources are not available to support collecting and analyzing multiple samples along a beach,
          the monitoring program plan should justify the decision and note the extent of the area that might
          be affected by an advisory or closing if bacterial densities at a single station exceed the standards.

          Completeness
          Completeness is defined as the percentage of measurements made that are judged to be valid
          according to specific criteria and entered into the data management system.  Accidental or
          inadvertent loss of samples during transport or lab activities should be avoided because the loss
          of the original samples will result in irreparable loss of data..  Lack of data entry into the database
          will reduce the ability to perform analyses, integrate results, and prepare reports. Thus,
          controlling sample loss by using unbreakable containers, careful sample management (e.g.,


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 National Beach Guidance and Grant Performance Criteria for Recreational Waters	_^____	

 assigning serial laboratory numbers, completing log books), and tracking samples through
 analysis and data entry is important. Percent completeness (%C) for measurement parameters
 can be defined as follows:

                                          %C=-x100
 where v is the number of measurements judged valid and Tis the total number of measurements.
 Most monitoring programs should try to achieve a level of completeness in which no less than 95
 percent of samples are judged to be valid.

 Comparability
 Two data sets are considered to be comparable when there is confidence that the two sets can be
 considered equivalent with respect to the measurement of a specific variable or group of
 variables. Comparability of data is not defined quantitatively; it is ensured by similarity in
 sampling based on geographic, seasonal,  and method characteristics; the uniform training and
 experience of field sampling and laboratory personnel; and the use of standardized, repeatable
 methods for analysis of bacterial indicator densities. The guidance provided in this document is
 intended to improve comparability among beach water quality monitoring programs through the
 use of comparable sampling and analysis procedures so that the meaning of the results can be
 more easily understood by the public nationwide.

 Additional Factors Affecting Sampling Design
 By establishing the "rules" for data quality at the planning stage, the number of samples that need
 to be collected and analyzed is adjusted to obtain data that will be used to judge the quality of the
 data obtained. For example, a duplicate water sample should be collected at least 10 percent of
 the sites included in the study for calculation of precision. Under some conditions, more frequent
 collection of duplicate samples might be advised. Monitoring programs need to carefully balance
 their needs to sample from multiple areas and their resource limitations against considerations of
 data quality. If only one sample is collected from every site for analysis, your agency might be
 covering more territory but it will not be possible to detect that an error occurred during sampling
 that inadvertently reduced the density of bacteria in the sample or that the particular patch of
 water sampled contained an unusually high number of fecal bacteria and was actually not
 representative of the entire area. Thus, inappropriate decisions might be made based on these
 erroneous results.

 For the same cost, the number of sites sampled could be reduced while including some QC
 samples to provide a means to double check your results, both from the field sampling effort and
 from analyses of duplicate aliquots of single samples in the laboratory. This approach can
 increase the level of confidence in the data produced and help detect unusual conditions that
might lead to errors in decision making.
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                                                                               Appendix I
1.6    References

Bartram, J., and G. Rees. 2000. Monitoring Bathing Waters: A Practical Guide to the Design
and Implementation of Assessments and Monitoring Programmes. E & FN SPON, London.

Bordner, R., J.A. Winter, and P.V. Scarpino, eds. 1978. Microbiological Methods for Monitoring
the Environment, Water and Wastes. EPA-600/8-78-017. U.S. Environmental Protection Agency,
Washington, DC.

Brenniman, G.R., S.H. Rosenberg, and R.L. Northrop. 1981. Microbial sampling variables and
recreational water quality standards. American Journal of Public Health 71(3):283-289.

Cabelli, V.J. 1983. Health Effects Criteria for Marine Recreational Waters. EPA 600/1-80-03.
U.S. Environmental Protection Agency, Cincinnati, OH.

CADHS. 1999. Health and Safety Code Section 115875-115915. California Department of
Health Services, Sacramento, CA.

Dufour, A.P. 1984. Health Effects Criteria for Fresh Recreational Waters. EPA 600/1-84-004.
U.S. Environmental Protection Agency, Cincinnati, OH.

Fleisher, J.M. 1990. The effects of measurement error on previously reported mathematical
relationships between indicator organism density and swimming-associated illness: A
quantitative estimate of the resulting bias. InternationalJournal of Epidemiology 19(4):1100-
1106.

Gilbert, R.O. 1987.  Statistical Methods for Environmental Pollution Monitoring.  VanNostrand
Reinhold Company, New York, NY.

IITF. 1999.  Standard Operating Procedure for Recreational Water Collection and Analysis of
E. coli on Streams, Rivers, Lakes and Waste-water. Indiana Interagency Task Force on E. coli.
LaPorte County Health Department, Laporte, IN.

USEPA. 1985. Test Methods for Escherichia coli and Enterococci in Water by the Membrane
Filter Procedure. EPA 600/4-85/076. U.S. Environmental Protection Agency, Washington,
DC.

USEPA. 1986. Ambient Water Quality Criteria for Bacteria -1986. U.S. Environmental
Protection Agency, Office of Research and Development, Microbiology and Toxicology
Division, and Office of Water Regulations and Standards, Criteria and Standards Division,
Washington, DC.             .
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National Beach Guidance and Grant Performance Criteria for Recreational Waters	

USEPA. 1997a. Method 1600: Membrane Filter Test Method for Enterococci in Water. EPA-
821-R-97-004. U.S. Environmental Protection Agency, Office of Water, Washington, DC.

USEPA. 1997b. Monitoring Guidance for Determining the Effectiveness ofNonpoint Source
Controls. EPA 841-B-96-004. U.S. Environmental Protection Agency, Office of Water,
Washington, DC.

USEPA. 1998. EPA Guidance for Quality Assurance Project Plans, EPA QA/G-5.
EPA/600/R-98-018. U.S. Environmental Protection Agency, Office of Research and
Development, Washington, DC.

USEPA. 1999. EPA Requirements for Quality Assurance Project Plans, EPA QA/R-5. Interim
Final.  U.S. Environmental Protection Agency, Quality Staff, Washington, DC.  November 1999.
1-14
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                                                                               Appendix!
Appendix J: Training

Training the volunteers to do their jobs properly is an essential component of a successful
monitoring program. Training is a dynamic process and does not simply begin and end with a
kickoff classroom session. For example, follow-up training must occur to resolve specific
operating problems discovered in an ongoing program. Even experienced staff benefit from
occasional continuing education sessions, which help everyone stay in touch with the program
and foster the ideal of team effort.

According to USEPA (1991), training should be planned from three basic perspectives:

1 .  Training new staff
2.  Training experienced staff (teaching the use of new equipment or improved methods)
3.  Solving specific operating problems

Each of the three training perspectives requires the presentation of unique material. The training
processes involved in presenting this material, however, are similar and consist of the following
components:

•  Creating a job analysis
•  Planning the training
•  Presenting the training
    Evaluating the training
    Providing follow-up coaching, motivation, and feedback.
J.I    Creating a Job Analysis

The job analysis phase can be the hardest but most important part of the training development.
The job analysis is a list of all the tasks volunteers must accomplish when sampling a parameter.
Identifying the tasks to be accomplished when sampling or analyzing for a particular parameter
should be done to ensure that procedures are performed consistently throughout the program.
This list should include a list of sampling tasks, the required quality level for each task, the job
elements that compose each task, and a sampling protocol (standard operating procedure) or job
description handout that will be referred to and followed by staff members each time they collect
water samples or perform laboratory analyses.

J.2    Planning the Training

Once the job analysis has been completed and the job description prepared, the actual training
session should be planned. Training might take place in a group setting or individually. Group
training saves money and time, especially when many staff must be trained simultaneously. For
extensive water sampling efforts throughout a county, however, this approach does have

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drawbacks. Each beach has unique characteristics, and there might be circumstances or problems
that can be addressed only on an individual basis.  In practice, it is often best to structure the
training program so that there are group sessions as well as individual follow-up sessions.

The training should stress the importance of samples being representative of the waterbody from
which they are taken including the theory behind indicator organisms and quality samples,
QA/QC (following the protocols specified in SOPs and the monitoring program plan). Ensuring
that staff understand how to carry out the protocols to meet those requirements is the primary
concern. Training to collect water samples, for example, should also include how to plan
sampling activities, how to make field notes describing the sampling site and station, and how to
perform on-site inspections. The safely aspects of field sampling and laboratory analysis Eire an
important component as well.

J.3    Presenting the Training

A well-organized, well-paced training session is essential to facilitate understanding and
motivate staff. The lesson planning phase provides the trainer with the basic agenda for the
session. The trainer, however, is responsible for adapting the lesson to the expectations,
knowledge, and experience of the audience. The person presenting the training must know the
material and must be organized.  Lectures, activities, and discussions should be planned arid kept
to a timetable. Similarly, demonstration materials, audiovisual equipment, and handouts must be
accessible and easily incorporated into the presentation. The trainer must be able to anticipate
and respond to problems and questions that might occur during an actual training session. A
relaxed presentation that fulfills the education objectives is the basic goal.  Although trainers will
bring their own styles to the training session, they should incorporate basic public speaking
techniques, such as establishing rapport with the audience, enunciating clearly and distinctly,
using effective body language and eye contact, and encouraging questions and comments.

Whether in the classroom or in the field, staff must be allowed to demonstrate what they have
learned. The trainer should observe closely and offer immediate feedback in the form of positive
reinforcement or corrective assistance.  This portion of the session is usually when the real
learning takes place. During the review portion of the training session, the trainer summarizes
what was learned and the staff have an opportunity to ask questions. The session should close
with the reassurance that staff will continue to receive training throughout their tenure with the
monitoring program.

J.4    Evaluating the Training

Training evaluation encompasses the entire training process. It includes .the trainee's perspective,
as well as that of the training program designer and trainer, on how effective the session has
been. To gain immediate feedback about training, staff should fill out evaluation forms at the
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                                                                                            Appendix J
end of the session.  Perhaps more effective, however, is observing staff in action as they collect
or process samples.  If there are problems
or techniques are not performed according
to the desired protocol, trainers might
need to apply new methods in subsequent
training sessions.
J.5     Providing Follow-up Coaching,
        Motivation, and Feedback

As stated previously, training is conducted
throughout the life of the monitoring
program. Follow-up coaching is an
integral part of the training process.
Coaching usually occurs on a one-on-one
basis to maintain communication between
team members, resolve problems, instill
motivation, and implement new or
improved techniques.  The key to  follow-
up coaching is personal contact to increase
staff satisfaction. That personal contact
should be maintained throughout the life
of the program.

J.6     Volunteer Monitoring Programs

EPA acknowledges that citizen volunteers
can often be used to perform some beach
monitoring program functions.  Using
volunteers to collect water samples and
transport them to a laboratory for analysis
is one way to save on program monitoring
costs and, at the same time, establish a
partnership  with local citizens.  Some
citizen monitoring programs also perform
water quality analyses, and a few
determine bacterial indicator levels.
Program planning officials, however, need
to be aware that establishing a volunteer
monitoring program requires a
commitment of time and resources to
ensure that volunteers are  properly trained
   Volunteer Beach Monitoring Programs Across the
                     Nation
Alabama Coastal Foundation volunteers' data are used for
trend research by the Alabama Department of
Environmental Management, Dauphin Island Sea Lab, and
Mobile Bay National Estuary Program.

Alabama Water Watch is a statewide citizen volunteer water
quality monitoring program. More than 50 active groups
monitor about 250 sites on 100 waterbodies in 20 to 30
counties in Alabama and Georgia. Six chemical parameters
are measured, and several groups are beginning to test for
pathogen indicators. The program is coordinated from
Auburn University, where the central database is
maintained.

The Surfrider Foundation is an environmental organization
dedicated to the protection and enhancement of the world's
waves and beaches through conservation, research,
education, and local activism. The Blue Water Task Force,
particularly chapters from Southern California coastal
counties, analyzes water samples collected at beaches for
bacteria and posts results on the Internet.

The Citizen Stewards Program trains volunteers to assist the
Casco BayKeeper in monitoring the water quality of Casco
Bay, Maine. Volunteers gather data at more than 100
selected sites along the 500-mile shoreline, collecting
surface water and performing tests monthly from April
through October. The data are entered into a comprehensive
computer database for management and interpretation.
Water column profile data are also collected from the
BayKeeper's  boat at offshore sites, and water is sampled at
closed clam flats to test for bacteria.

The Environmental Quality Laboratory at Coastal Carolina
University monitors water and sediment quality in the
Waccamaw River and 45 sites from the North Carolina state
line to Bucksports, South Carolina, using EPA-approved
methods. Monthly physical, chemical, and biological
analyses are  performed, and occasional measurements of
nutrients and heavy metals are taken. Results are
interpreted using in situ instantaneous U.S. Geological
Survey data on water stage and flow. The sampling plan is
designed to identify nonpoint pollution sources. Results are
shared with South Carolina's Department of Health and
Environmental Control.

The Salt Pond Watchers currently monitor fecal coliform
bacteria levels in approximately 30 stations in seven coastal
salt  ponds on Rhode Island's Atlantic coast. Data are
provided to the Rhode Island Department of Environmental
Management and local communities to help determine areas
unsuitable for fishing and swimming.
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National Beach Guidance and Grant Performance Criteria for Recreational Waters

and managed and that data quality objectives are met. Officials should never view citizen
volunteers as unpaid adjunct staff. Typically, their motivation to participate in a monitoring
program is not based on a desire to help reduce agency costs. Rather, they donate their time and
energy for the purpose of serving as guardians and stewards of their local waters. This
recognition needs to be considered in every aspect of the volunteer monitoring program
development process.

The EPA document Volunteer Water Monitoring: A Guide for State Managers (USEPA, 1990)
lists seven "basic ingredients" for developing a successful volunteer program:

1.  Develop and articulate a clear purpose for the use of the data
2.  Produce "data of known quality" that meet the stated data quality objectives
3.  Be aware that volunteer monitoring is cost-effective, but not free
4.  Thoroughly train and retrain volunteers
5.  Give the volunteers praise and feedback (the psychological equivalent of a salary)
6.  Use the data volunteers collect
7.  Be flexible, open, and realistic with volunteers
    Most of the volunteer monitoring programs that
    responded to EPA's survey for the 1994 National
    Directory of Volunteer Environmental Programs focus
    on river monitoring (585 programs, 76 percent).
    Monitoring of lakes and reservoirs came in second (34
    percent), followed by wetlands (22 percent) and
    estuaries and marine environments (21 percent).
    Beach monitoring was listed as an activity by 8 percent
    of the responding volunteer monitoring programs.
Including these seven basic ingredients in the
development of a volunteer monitoring
program has produced many success stories
across the United States. The latest edition of
the National Directory of Volunteer
Environmental Programs (RISG and USEPA,
1994) documents a total of 112 programs
currently in operation (see box on left).
A frequent criticism of volunteer monitoring programs is that using the services of volunteers
yields data of less certainty than the data obtained when professionals do the job.  In general,
however, if the seven  "basic ingredients" of a successful program are included, data quality
should be the same for both groups. Putting this theory to the test for any particular program
requires running parallel water sampling tests that compare data collected by professionals versus
those collected by volunteers (Parallel testing, 1997).  Periodic parallel testing serves two
purposes. First, it assures the sponsoring agency that volunteers' data are reliable and can be used
for the program's purposes. Second, it helps identify areas where the volunteer program can be
improved, especially if the results indicate there is a difference in quality between the volunteers'
data and the professionals' data.

Volunteer Water Monitoring: A Guide for State Managers (USEPA, 1990) discusses several
ether ways to maintain volunteers' interest:
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                                                                                  Appendix J
   Sending volunteers regular data reports.

   Keeping volunteers informed about all uses of their data.

   Preparing a regular newsletter.

   Making program officials easily accessible for questions and requests.

   Providing volunteers with educational opportunities.

   Keeping the local media informed of the goals and findings of the monitoring effort.

   Recognizing the efforts of the volunteers through certificates, awards, or other means.

   Providing volunteers with opportunities to grow with the program through additional
   training, learning opportunities, and changing responsibilities.
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 J.7    References

 USEPA, 1991.  Volunteer Lake Monitoring: A Methods Manual.  EPA 440/4-91-002.  U.S.
 Environmental Protection Agency, Office of Water, Washington DC.
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                                                                               Appendix K
Appendix K: Sample Collection

K.1    Sample Containers

The sample bottles used to collect water for bacterial density analyses should be able to
withstand sterilizing conditions and the solvent action of water.  Bordner et al. (1978) suggested
wide-mouth borosilicate glass bottles with screw caps or ground-glass stoppers; however, glass
bottles can break, causing loss of the sample. Heat-resistant polypropylene bottles may be used if
they can be sterilized without producing toxic materials when autoclaved.

Sample bottles should be at least 125-milliliter (mL) volume for adequate sampling and for good
mixing. Bottles of 250-mL, 500-mL, and 1,000-mL volume are often used for multiple analyses,
such as when determining the density of two or more bacterial indicators. Discard bottles that
have chips, cracks, or etched surfaces.  Bottle closures must be watertight.  Before use,
thoroughly cleanse bottles and closures with detergent and hot water, followed by a hot water
rinse to remove all traces of detergent.  Then rinse three times with laboratory-pure water.

Autoclave glass or heat-resistant polypropylene bottles at 121 °C for 15 minutes.  Alternatively,
dry glassware may be sterilized in a hot air oven at 170 °C for not less than 2 hours. Ethylene
oxide gas sterilization is acceptable for plastic containers that are not heat-resistant. Sample
bottles should be stored overnight before they are used to allow the last traces of gas to dissipate.

Commercially available sterile plastic sampling bags (Whirl-pak) are a practical substitute for
polypropylene or glass sample bottles when sampling soil or sediment. The bags are sealed by
the manufacturer and opened only at the time of sampling.

If you are collecting water samples for the determination of other environmental parameters (e.g.,
temperature, salinity, turbidity, dissolved oxygen), you may use nonsterile containers.  Be sure
that the sterile and nonsterile containers are clearly labeled and used for the particular sample for
which they were intended.

K.2    Sampling Method

A grab  sample of water is obtained using a sample bottle that has been prepared as described
above.  The basic steps for this procedure, derived from Bordner et al. (1978) and IITF (1999),
are as follows.

1.  Identify the sampling site on a chain-of-custody tag, if required, or on the bottle label and on
    afield log sheet.

2.  Remove the bottle covering and closure just before obtaining each sample and protect them
    from contamination. Be careful not to touch the inside of the bottle itself or the inside of the
    cover.
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters	

 3. The first sample to be prepared is the trip or field blank (at least one per sampling day for
    routine sampling is recommended). Open one of the sampling bottles and fill it with 100 mL
    of sterile buffered dilution solution (see EPA Method 1103.1) when collecting freshwater,
    estuarine, or marine water samples. Cap the bottle and place it in a cooler.

 4. To collect the surface water samples, carefully move to the first sampling location.  If wading
    in the water, try to avoid kicking up bottom material at the sampling station.  You should be
    positioned downstream of any water current to take the sample from incoming flow.

 5. Open a sampling bottle and grasp it at the base with one hand and plunge  the bottle mouth
    downward into the water to avoid introducing surface scum.  Position the mouth of the bottle
    into the current away from your hand and away from the side of the sampling platform  or
    boat.  The sampling depth should be 15 to 30 centimeters (cm) (6 to 12 inches) below the
    water surface, depending on the depth from which the sample must be taken. If the
    waterbody is static, an artificial current can be created by moving the bottle horizontally with
    the direction of the bottle pointed away from you.  Tip the bottle slightly upward to allow air
    to exit and the bottle to  fill.

 6.  Remove the bottle from the waterbody.

 7.  Pour out a small portion of the sample to allow an air space of 2.5 cm (1 to 2 inches) above
    each sample for proper mixing of the sample before analysis.

 8.  Tightly close the stopper and label the bottle.

 9.  Enter specific details to identify the sample on a permanent label. Take care in transcribing
    sampling information to the label. The label should be clean, waterproof,  nonsmearing, and
    large enough for the necessary information. The label must be securely attached to the
    sample bottle but removable when necessary. Preprinting standard information on the label
    can save time in the field. The marking pen or other device must be nonsmearing and
    maintain a permanent legible mark.

 10. Complete a field record for each sample to record the full details on sampling and other
    pertinent remarks, such  as flooding, rain, or extreme temperature, that are  relevant to
    interpretation of the results.  This record also provides a back-up record of sample
    identification.

 11. Place the samples in a suitable container, and transport them  to the laboratory as soon as
    possible.  Adhering to sample preservation and holding time  limits is critical to the
    production of valid data. Bacteriological samples  should be iced or refrigerated at 1 to  4 °C
    during transit to the laboratory.  Insulated containers, such as plastic or styrofoam coolers, are
    preferable to ensure proper maintenance of storage temperature. Care should be taken to
    ensure that sample bottles are not totally immersed in water during transit  or storage.
K-2
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                                                                               Appendix K
   Samples should be examined as soon as possible after collection. Do not hold samples
   longer than 6 hours between collection and initiation of analysis (USEPA, 2000).  Do not
   analyze samples that exceed holding time limits.

12. Water samples for analyses of other parameters should be collected in separate appropriate
   containers at the same time and analyses performed as specified in the particular methods.

13. After samples have been collected from a station, wash hands and arms with alcohol wipes, a
   disinfectant lotion, or soap and water, and dry to reduce exposure to potentially harmful
   bacteria or other microorganisms.

K.3    Sample Handling

In cases where an agency must demonstrate the reliability of its evidence in legal cases involving
pollution, it is necessary to document the chain of possession and custody of samples that are
offered for evidence or that form the basis of analytical results introduced into evidence (Bordner
et al., 1978).  Although the analytical results of the water samples collected at a swimming beach
are being used to make a decision for the protection of human health, a decision to close the
beach might be unpopular with local businesses and could be contested.  It is thus important that
the agency collecting the samples and the laboratory performing the analysis prepare written
procedures to be followed whenever evidence samples are collected, transferred, stored,
analyzed, or destroyed. These are known as "chain-of-custody" (COC) procedures.

The sampling agency should have procedures to ensure the custody and integrity of the samples
beginning at the time of sampling and continuing through transport and sample receipt. The
laboratory should have procedures for sample receipt, preparation,  analysis and storage, data
generation and reporting, and sample disposal. A sample is defined as being under a person's
custody if any of the following conditions exist: (1) it is in his or her possession; (2) it is in his or
her view, after being in his or her possession; (3) it was in his or her possession and he or she
locked it up; or (4) it is in a designated secure area (AFCEE, 1998). Records concerning the
custody and condition of all field samples are maintained in the field and laboratory files.

A COC form filled out by the person conducting the sampling should provide information such
as the following: sampling location (site ID), tune of collection, date of collection, time of near
or high tide, air temperature, water temperature, rainfall history, collector's name and signature,
agency, and other notes or comments.  A Chain of Custody Review List and a Sample Handling,
Preparation, and Analysis List are provided at the end of this appendix.

Samples are usually transported to the laboratory by the person collecting the sample or picked
up by laboratory personnel. Because of the 8-hour holding time limitation, the laboratory should
be conveniently located near the sampling site and should be notified a few days in advance of
the sampling effort so that it will be ready to process the samples promptly. COC procedures


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 National Beach Guidance and Grant Performance Criteria for Recreational Waters   	;	

 should be followed at the laboratory for all samples. Laboratory personnel receiving samples
 should do the following:

 1.  Check the shipping container for damage and a custody seal. Note whether the custody seal
    is intact and record any anomalies on the sample log-in form.

 2.  Open the container and inspect the sample containers, noting any damage or breakage.
    Immediately take the temperature of the samples. Place a calibrated thermometer or
    temperature probe in the cooler in a representative location (not directly touching any ice or
    cold packs and not inside a sample bottle). Record the temperature on the sample log-in form
    and the COC form enclosed with the sample.

 3.  Remove the individual containers from the shipping container and inspect each one for
    damage, leakage, or any other problem. Note the condition of each container, the date
    received, the project number, the batch number, and the airbill or shipping identification
    number on the sample log-in form and the COC form.

 4.  Compare each sample container to those listed on the COC form to ascertain whether all the
    samples are present and whether all the labels on the sample containers match those on the
    COC form.

 5.  If no COC form accompanies the samples, complete a COC form and confirm all sample
    information with the agency that collected the samples.  Document any contact with the
    agency regarding problems or confirmation on the sample log-in and COC forms.

 6.  Notify the laboratory manager if you note any problems with the samples. Sign and date the
    COC form upon completion of the sample inspection.

 7.  Assign each sample a sample ID code. For example, the sample ID code should include a
    sequential log-in number, a sample type code (e.g., U for upstream, S for site, L for
    laboratory), a code to identify the collecting agency, the sampling date, and the analysis
    required. Replicate samples from the same site receive the same code with a suffix such as -
    A,-B,-C to indicate their replicate status.

 8.  Record each  sample's code on the sample log-in form, the COC form, and the corresponding
    sample container. Indicate on the form where the samples will be held (e.g., which room in
    the laboratory). When samples are removed for final disposition, the removal should be
    documented on the sample log-in form.

 9.  Record additional information on the sample log-in form, including the collecting agency
    contact, sample analyses required, and due dates of analyses.

 10.  Store samples not used immediately at 4 °C.
K.-4
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                                                                                            Appendix K
                                  Chain of Custody Review List
                                                 Task
 Sample custodian designated
 Name of sample custodian
 Sample custodian's procedures and responsibilities documented
 Standard Operating Procedures (SOPs) developed for receipt of samples
 Where are the SOPs documented (laboratory manual, written instructions...)?
 Receipt of chain-of-custody record(s) with samples documented
 Nonreceipt of chain-of-custody record(s) with samples documented
 Integrity of the shipping container(s) documented
 Where is security documented?
 Lack of integrity of the shipping container(s) documented
 Where is nonsecuriry documented?
 Agreement between chain-of-custody records and sample tags verified and documented
 Source of verification and location of documentation
 Sample tag numbers recorded by the sample custodian
 Where are they located?
 Samples stored in a secure area
 Where are they stored?
 Sample identification maintained
 Sample extract (or inorganics concentrate) identification
 Samples maintained. How?
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 National Beach Guidance and Grant Performance Criteria for Recreational Waters
                       Sample Handling, Preparation, and Analysis List
Category
Field Logs
Chain of Custody
Records





Task
Project name/ID and location
Sampling personnel identified
Map
Geological observations
Atmospheric conditions
Field measurements
Sample dates, times, and locations
Sample identifications noted
Sample matrix identified
Sample descriptions (e.g., odors, colors)
Number of samples taken per location
Sampling method/equipment
Description of any QC samples
Deviations from the sampling plan
Difficulties or unusual circumstances
Project name/ID and location
Sample custodian's procedures and responsibilities documented
Sample custodians' signatures verified and on file
Date and time of each transfer
Carrier ID number
Integrity of shipping container and seals verified
Standard Operating Procedures (SOPs) for receipt on file
Samples stored in same area
Holding time protocol verified
K.-0
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                   SOPs for sample preservation on file
                   Identification of proposed analytical method verified
                   Proposed analytical method documentation verified
                   ———^~"~"~"~~~~
                   QA Plan for proposed analytical method on file
                   i^w—^———^—

                   Sample ID
Sample Labels
                    Date and time of collection
                                .
                    Sampler's signature
                    Characteristic or parameter investigated
                    _———————
                    Preservative used
                    Date and time of receipt
 Sample Receipt Log
                    Sample collection date
                    Client sample ID
                    Number of samples
                     Sample matrices
                     Requested analysis, including method number(s)

                     Signature of the sample custodian or designee
                     Sampling kit code (if applicable)
                     Sampling condition
                     Chain-of-custody violations and identities
                     Parameter/analyte of investigation
  Sample Preparation
                      Method number
                      Date and time of preparation
                      Analyst's initials or signature
                      Initial sample volume or weight
                      Final sample volume
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National Beach Guidance and Grant Performance Criteria for Recreational Waters
Category

Sample Analysis
Logs
[nstrument Run
Logs






Task
Concentration and amount of spiking solutions used
QC samples included with the sample batch
ID for reagents, standards, and spiking solutions used
Parameter/analyte of investigation
Method number/reference
Date and time of analysis
Analyst's initials or signature
Laboratory sample ID
Sample aliquot
Dilution factors and final sample volumes (if applicable)
Absorbance values, peak heights, or initial concentrations reading
Final analyte concentration
Calibration data (if applicable)
Correlation coefficient (including parameters)
Calculations of key quantities available
Comments on interferences or unusual observations
QC information, including percent recovery
Name/type of instrument
Instrument manufacturer and model number
Serial number
Date received and date placed in service
Instrument ID assigned by the laboratory (if used)
Service contract information, including service
representative details
Description of each maintenance or repair activity performed
Date and time of each maintenance or repair activity
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                                                                                           Appendix K
Category

Chemical/Standard
Receipt Logs
Standards/Reagent
Preparation Log
Task
Initials of maintenance or repair technicians
Laboratory control number
Date of receipt
Initials or signature of person receiving chemical
Chemical name and catalog number
Vendor name and log number
Concentration or purity of standard
Expiration date
Date of preparation
Initials of analyst preparing the standard solution or reagent
Concentration or purity of standard or reagent
Volume or weight of the stock solution
Final volume of the solution being prepared
Laboratory ID/control number assigned to the new solution
Name of standard reagent
t
Standardization of reagents, titrants, etc. (if applicable)
Expiration date
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                                                                                                  K-9

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K.4   References

AFCEE. 1998. Air Force Center for Environmental Excellence.

Bordner, R., J.A. Winter, andP.V. Scarpino, eds. 1978. Microbiological Methods for Monitoring
the Environment, Water and Wastes. EPA-600/8-78-017. U.S. Environmental Protection Agency,
Washington, DC.

IITF. 1999. Standard Operating Procedure for Recreational Water Collection and Analysis of
E. coli on Streams, Rivers, Lakes and Waste-water. Indiana Interagency Task Force on E. coli.
LaPorte County Health Department, Laporte, IN.

USEPA. 1997. Method 1600: Membrane Filter Test Method for Enterococci in Water. EPA-
821-R-97-004. U.S. Environmental Protection Agency, Office of Water, Washington, DC.

USEPA. 2000. Improved Enumeration Methods for the Recreational Water Quality Indicators:
Enterococci and Escherichia coli. 821-R-97-004. U.S. Environmental Protection Agency,
Office of Science and Technology, Washington, D.C.
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                                                                            Appendix L
Appendix L: Predictive Tools

Appendix L includes brief summaries of the models discussed in Chapter 5.

L.I   Pathogen Loading Estimates

HSPF: Hydrological Simulation Program—Fortran. HSPF is a comprehensive watershed-
scale model developed by EPA.  The model uses continuous simulation of water balance and
pollutant buildup and washoff processes to generate time series of runoff flow rate, as well as
pollutant concentration at any given point in the watershed. Runoff from both urban and rural
areas can be simulated using HSPF; however, simulation of combined.sewer overflows (CSOs) is
not possible. Because of the comprehensive nature of the model, data requirements for HSPF are
extensive and using this  model requires highly trained personnel.

SWMM: Storm Water Management Model.  SWMM is a comprehensive watershed-scale
model developed by EPA. It can be used to model several types of pollutants on either a
continuous or storm event basis. Simulation of mixed land uses is possible using SWMM, but
the model's capabilities  are limited for rural areas. SWMM can simulate loadings from CSOs.
The model requires intensive data input and requires a special effort for validation and
calibration. The output of the model is time series of flow, storage, and contaminant
concentration at any point in the watershed.

STORM: Storage, Treatment, Overflow, Runoff Model.  STORM is a watershed loading
model developed by the  US Army Corps of Engineers for continuous simulation of runoff
quantity and quality. The model was primarily designed for modeling storm water runoff from
urban areas, but it can also simulate combined sewer systems. It requires relatively moderate to
high calibration and input data. The simulation output is hourly hydrographs and pollutographs.

L. 2   Rivers and Streams

HSPF: Hydrological Simulation Program-Fortran. HSPF is a comprehensive watershed-
scale model developed by EPA. The receiving water component allows dynamic simulation of
one-dimensional stream channels, and several hydrodynamic routing options are available.  The
model output is time series of runoff flow rate, as well as pollutant concentration at any given
point in the watershed. Because of the model's comprehensive nature, the data requirements for
HSPF are extensive and running the model requires highly trained personnel.

CE-QUAL-RIV1: Hydrodynamic and Water Quality Model for Streams.  CE-QUAL-RTVl
is a dynamic, one-dimensional model for rivers and estuaries consisting of two codes-—one for
hydraulic routing and another for dynamic water quality simulation.  CE-QUAL-RIV1 allows
simulation of unsteady flow of branched river systems.  The input data requirements include the
river geometry, boundary conditions, initial in-stream and inflow boundary water quality

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 concentrations, and meteorological data.  The model predicts time-varying concentrations of
 water quality constituents.

 L.3    Lake and Estuary Models

 WASPS: Water Quality Analysis Simulation Program. WASP5 is a general-purpose
 modeling system for assessing the fate and transport of pollutants in surface water. The model
 can be applied in one, two, or three dimensions and can be linked to other hydrodynamic models.
 WASPS simulates the time-varying processes of advection and dispersion while considering
 point and nonpoint source loadings and boundary exchange. The waterbody to be simulated is
 divided into a series of completely mixed segments, and the loads, boundary concentrations, and
 initial concentrations must be specified for each state variable.

 CE-QUAL-ICM: A Three-Dimensional Time-Variable Integrated-Compartment
 Eutrophication Model. CE-QUAL-ICM is a dynamic water quality model that can be applied
 to most waterbodies in one, two, or three dimensions.  The model can be coupled with three-
 dimensional hydrodynamic and benthic-sediment model components.  CE-QUAL-ICM predicts
 time-varying concentrations of water quality constituents. The input requirements for the model
 include 140 parameters to specify the kinetic interactions, initial and boundary conditions, and
 geometric data to define the waterbody to be simulated. Model use may require significant
 expertise in aquatic biology and chemistry.

 EFDC: Environmental Fluid Dynamics Computer Code. EFDC is a general three-
 dimensional hydrodynamic model developed by Hamrick (1992).  EFDC is applicable to rivers,
 lakes, reservoirs, estuaries, wetlands, and coastal regions where complex water circulation,
 mixing, and transport conditions are present.  EFDC must be linked  to a water quality model to
 predict the receiving water quality conditions. HEM-3D is a three-dimensional hydrodynamic
 eutrophication model that was developed by integrating EFDC with  a water quality model.
 Considerable technical expertise in hydrodynamics and eutrophication processes is required to
 use the EFDC model.

 CE-QUAL-W2: A Two-Dimensional,  Laterally Averaged Hydrodynamic and Water
 Quality Model. CE-QUAL-W2 is a hydrodynamic water quality model that can be applied to
 most waterbodies in one dimension or laterally averaged in two dimensions. The model is suited
 for simulating long, narrow waterbodies like reservoirs and long estuaries, where stratification
 might occur. The model application is flexible because the constituents are arranged in four
 levels of complexity.  Also, the water quality and hydrodynamic routines are directly coupled,
 which allows for more frequent updating of the water quality routines.  This feature can reduce
 the computational  burden for complex systems.  The input requirements for CE-QUAL-W2
 include geometric  data to define the waterbody, specific initial boundary conditions, and
 specification of approximately 60 coefficients for the simulation of water quality.
L-2
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                                                                              Appendix L
QUAL2E: The Enhanced Stream Water Quality Model. QUAL2E is a steady-state receiving
water model. The basic equation used in QUAL2E is the one-dimensional advective-dispersive
mass transport equation.  Although the model assumes a steady-state flow, it allows simulation of
diurnal variations in meteorological inputs.  The input requirements of QUAL2E include the
stream reach physical representation and the chemical and biological properties for each reach.

TPM: Tidal Prism Model. TPM is a steady-state receiving water quality model applicable only
to small coastal basins. In such locations the mixing and transport of pollutants are dominated by
the tidal cycles. The model assumes that the tide rises and falls simultaneously throughout the
waterbody and that the system is in hydrodynamic equilibrium. Two types of input data are
required to run TPM. The geometric data that define the system being simulated are the
returning ratio, initial concentration, and boundary conditions. The physical data required are the
water temperature, reaction rate, point and nonpoint sources, and initial boundary conditions for
water quality parameters  modeled.
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L-3

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 L.4   References

 DNREC. 1997.  Swimming (Primary Body Contact) Water Quality Attainability for Priority
 Watersheds in Sussex County. Delaware Department of Natural Resources and
 Environmental Control, Dover, DE.

 Kuntz, I.E. 1998. Non-point Sources of Bacteria at Beaches. City of Stamford Health
 Department, Stamford, CT.

 USEPA. 1999. Review of Potential Modeling Tools and Approaches to Support the BEACH
 Program.  EPA 823-R-99-002. U.S. Environmental Protection Agency, Office of Science and
 Technology, Washington, DC.
L-4
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