EPA-823-B-14-001
United States
Environmental Protection
Agency
        NATIONAL BEACH GUIDANCE
        AND REQUIRED PERFORMANCE
        FOR GRANTS, 2014 EDITION
                        RUNOFF/STORMDRAIK WATER MAY CAUSE ILLNESS
                       *OID CONTACT WITH RUNOFF AND AREA OF DISCHARGE
                        ESPECIALLY FOR 72 HOURS FOLLOWING RAINFALL
                         COHRIEMTE DE AGUA/AGUA DEL DRENAJb ~f
                         TORMENTA PUEOE CAUSAR ENFERMEOADL
                        EVITE CONTACTO CON AGUA DE DESAGUE Y EL ^EA
                        DONOE DESEMBOCA ESPECIALMENTE DLRANTf AS
                        SIGUIENTES 72 HORAS, .PESPUF5 DE L« LLI'
                                                     JULY 2014

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National Beach Guidance
and Required Performance Criteria
for Grants, 2014 Edition

July 31, 2014

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    National Beach Guidance
   and Required Performance
Criteria for Grants, 2014 Edition
     United States Environmental Protection Agency
            Office of Water (4305T)
         1200 Pennsylvania Avenue, NW
            Washington, DC 20460


             EPA-823-B-14-001


            July 31, 2014

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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.                  Contents
                                      Contents

Chapter 1:  Introduction	1
    1.1  Program and Document Overview	2
       1.1.1   Implementing the BEACH Act	4
       1.1.2   How to Use This Document	5
       1.1.3   How This Document Is Organized	6
    1.2  Pathogens	6
    1.3  Fecal Indicators	8
    1.4  Health Concerns	10
    1.5  Water Quality Criteria and Standards for Bacteria	11
       1.5.1   State Implementation of the 2012 Recreational Water Quality Criteria
              (RWQC)	11
       1.5.2   Implementation Guidance	13
    1.6  Chapter 1 References	14
Chapter 2:  Grants and Required Performance Criteria	18
    2.1  BEACH Act Conditions and Requirements Applicable to Section 406 Grants	18
    2.2  Performance Criteria	18
       2.2.1   Risk-based Beach Evaluation and Classification Process (Performance
              Criterion 1)	19
       2.2.2   Tiered Monitoring Plan (Performance Criterion 2)	19
       2.2.3   Methods and Assessment Procedures (Performance Criterion 3)	20
       2.2.4   Monitoring Report Submission (Performance Criterion 4)	20
       2.2.5   Delegation of Monitoring  Responsibilities (Performance Criterion 5)	20
       2.2.6   Public Notification and Risk Communication Plan (Performance Criterion 6) ....20
       2.2.7   Actions to Notify the Public (Performance Criterion 7)	21
       2.2.8   Notification Report Submission (Performance Criterion 8)	21
       2.2.9   Delegation of Notification Responsibilities (Performance Criterion 9)	21
       2.2.10  Adoption of New or Revised WQS and Identification and Use of a Beach
              Notification Threshold (Performance Criterion 10)	21
       2.2.11  Public Evaluation of Program (Performance Criterion 11)	21
    2.3  Additional Grant Information	22
       2.3.1   Grant Program Phases	22
       2.3.2   Eligibility for Grants	22
       2.3.3   Selection Process	23
       2.3.4   Grant Award Process	23
Chapter 3:  Risk-based Beach Evaluation and Classification Process	24
    3.1  Performance Criterion	24
    3.2  Step 1:  Identify Coastal Recreation Waters	25
       3.2.1   Coastal Versus Noncoastal Waters	26

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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.                  Contents

       3.2.2  Designated Uses of Water Bodies	27
   3.3   Step 2: Identify "BEACH Act" Beaches	27
   3.4   Step 3: Characterize the Beach to Determine Risk and Use	28
       3.4.1  Assess Potential Sources of Contamination and Risks	29
       3.4.2  Determine Use of the Beach	33
   3.5   Step 4: Rank Beaches by Tiers	34
       3.5.1  Other Factors	34
       3.5.2  Tiered Approach	35
   3.6   Step 5: List of Beaches—Classify Beaches into "Program" Versus "Non-program"
         Beaches and Incorporate Them into a Final State List of Beaches	35
       3.6.1  Initial Submission to EPA	37
       3.6.2  Revising and Updating the List of Beaches	37
   3.7   Federal Beaches	37
   3.8   Chapters References	37
Chapter 4:  Beach Monitoring	39
   4.1   Performance Criteria	40
   4.2   Developing a Tiered Monitoring Plan (Performance Criterion 2)	42
       4.2.1  Goal and Key Considerations	42
       4.2.2  Tiered Monitoring Plan	44
       4.2.3  Quality Management System Requirements for Performance Criterion 2	45
   4.3   Factors to Consider When Developing a Monitoring Plan	47
       4.3.1  Variability of Beach Water Quality	47
       4.3.2  Recommended Monitoring	50
       4.3.3  Administering a Monitoring Program	56
   4.4   Methods and Assessment Procedures (Performance Criterion 3)	59
       4.4.1  EPA-Approved or Validated Analytical Methods	59
       4.4.2  Selection of Analytical Methods: Culture versus qPCR	61
       4.4.3  Using Other Methods or Indicators for Developing Site-specific WQS	64
   4.5   Monitoring Report Submission (Performance Criterion 4)	65
       4.5.1  Data Validation and Verification Recommendations	66
   4.6   Use of Predictive Tools in Beach Monitoring Programs	67
       4.6.1  Statistical Models	68
       4.6.2  Rainfall-based Beach Notification Threshold	70
       4.6.3  Notification Protocols	70
       4.6.4  Deterministic Models	70
       4.6.5  Determining Exceedances Using Predictive Models	71
   4.7   The 2012 RWQC Provide Context for Beach Monitoring Programs	71
       4.7.1  2012 Recreational Water Quality Criteria	71
       4.7.2  Threshold Values for Beach Notification Actions	73
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.                  Contents

       4.7.3   Implementation Requirements for Adopting the 2012 RWQC into State and
              Tribal WQS and Identifying and Using a Beach Notification Threshold
              (Performance Criterion 10)	76
       4.7.4   Use of RWQC  in Identifying CWA Section 303(d) Impaired Waters	77
   4.8   Delegation of Monitoring Responsibilities (Performance Criterion 5)	78
   4.9   Chapter 4 References	78
ChapterS:  Public Notification and Risk Communication	83
   5.1   Performance Criteria	83
   5.2   Public Notification and Risk Communication Plan (Performance Criterion 6)	85
       5.2.1   Creating aRisk Communication Strategy	85
       5.2.2   Addressing Needs and Establishing Trust	87
       5.2.3   Crafting Beach Notifications	88
       5.2.4   Evaluating Public Notification and Risk Communication Plans	91
       5.2.5   When to Notify EPA and Local Governments	92
   5.3   When to Issue and Remove a Notification	92
       5.3.1   When to Issue a Notification	92
       5.3.2   When to Remove a Notification	93
   5.4   Actions to Notify the Public (Performance Criterion 7)	93
       5.4.1   Beach Signs	93
       5.4.2   Traditional  Mass Media	97
       5.4.3   Methods that Allow Stakeholders to Anonymously Seek Out Information	97
       5.4.4   Methods that Rely on Stakeholders to Provide Contact Information to
              Receive Information	98
   5.5   Notification Report Submission (Performance Criterion 8)	100
   5.6   Delegation of Notification Responsibilities (Performance Criterion 9)	100
   5.7   Chapters References	102
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.                   Contents


                                        Tables
Table 1-1. Examples of waterborne pathogens in the three groups: bacteria, viruses, and
          protozoans	9
Table 2-1. Summary of BEACH Act performance criteria	19
Table 2-2. Summary of public evaluation of program performance criterion	22
Table 3-1. Summary of risk-based evaluation and classification process performance
          criterion	25
Table 3-2. Example of a List of Beaches	36
Table 4-1. Summary of monitoring performance criteria	40
Table 4-2. Example of atiered monitoring plan	44
Table 4-3. Percent of exceedances missed for different sampling frequencies	49
Table 4-4. Recommended 2012 RWQC	72
Table 4-5. Beach Action Values (BAVs)	74
Table 4-6. Values for qPCR	76
Table 5-1. Performance criteria details	84
                                        Figures
Figure 3-1. Step 1: Identify coastal recreation waters	26
Figure 3-2. Coastal and noncoastal waters	26
Figure 3-3. Step 2: Identify beaches and similar points of access	27
Figure 3-4. Step 3: Characterize the beach to determine risk and use	28
Figure 3-5. Step 4: Rank beaches by tiers	34
Figure 3-6. Step 5: Complete the List of Beaches	35
Figure 4-1. Relative contributions to temporal variations in FIB density. (Line length
          indicates duration of influence.)	47
Figure 4-2. Relative contributions to spatial variation at coastal beaches	50
Figure 4-3. Relative contributions to spatial variation at inland beaches	50
Figure 5-1. The universal symbol for "No."	94
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.   Acronyms and Abbreviations

                         Acronyms and Abbreviations
AFO            Animal feeding operation
AOAC          Association of Official Analytical Chemists International
APHA          American Public Health Association
ASTM          American Society for Testing and Materials International
ATP            Alternate Test Procedure
AWWA         American Water Works Association
BAV            Beach Action Value
BEACH Act     Beaches Environmental Assessment and Coastal Health Act of 2000
BEACON       Beach Advisory and Closing Online Notification
CAFO          Concentrated animal feeding operation
CCE            Calibrator cell equivalents
CPU            Colony-forming unit(s)
CFR            Code of Federal Regulations
CPD            Chicago Park District
CSO            Combined sewer overflow
CWA           Clean Water Act
DOHMH        [New York City] Department of Health and Mental Hygiene
DQO            Data quality  objective
EMPACT       Environmental Monitoring for Public Access and Community Tracking
EPA            [United States] Environmental Protection Agency
FIB             Fecal indicator bacteria
FR             Federal Register
FY             Fiscal year
GM             Geometric mean
IAC             Internal amplification control
IMS/ATP        Immunomagnetic separation/adenosine triphosphate
mL             Milliliter
MPN            Most probable number
MST            Microbial source tracking
NEEAR         National Epidemiologic and Environmental Assessment of Recreational
                Water
July 31,2014
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.   Acronyms and Abbreviations

NGI            NEEAR gastrointestinal illness
NOAA          National Oceanic and Atmospheric Administration
NPDES         National Pollutant Discharge Elimination System
NRC            National Research Council
OW            Office of Water
POTW          Publicly owned treatment works
QA             Quality assurance
QAPP          Quality assurance project plan
QC             Quality control
QMP            Quality management plan
QMRA          Quantitative microbial risk assessment
qPCR          Quantitative polymerase chain reaction
RSS            Real Simple Syndication
RWQC          Recreational Water Quality Criteria
SCCWRP       Southern California Coastal Water Research Proj ect
SOP            Standard operating procedure
SPC            Sample processing control
SSM            Single sample maximum
STORE!        EPA's national database for STORage and RETrieval (STORE!) of water
                quality data
STV            Statistical Threshold Value
TMDL          Total maximum daily load
USGS          United States Geological Survey
WHO          World Health Organization
WQS            Water quality standard(s)
WQX          Water Quality eXchange
July 31,2014
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.                  Chapter 1
  This document discusses the required performance criteria for beach monitoring and notification
  programs for which the U.S. Environmental Protection Agency (EPA) provides implementation
  grants under Clean Water Act (CWA) section 406(b). It also provides additional guidance
  (recommendations) for grant recipients.
  This document might also be used as nonbinding guidance for states, tribes, and local
  governments that do not have a CWA section 406(b) grant, but want to develop and implement
  beach monitoring and notification programs. This document contains a  wealth of useful
  information and many best management practices that states, tribes, and local governments
  might want to follow.
  The general approach and principles described here are also recommended  for inland beaches,
  although some modifications might be appropriate.
Chapter 1: Introduction

The National Beach Guidance and Required Performance Criteria for Grants outlines the
performance criteria that an eligible coastal or Great Lakes state,l territorial, tribal, or local
government must meet to receive grants to implement coastal recreation water monitoring and
public notification programs under section 406 of the Clean Water Act (CWA), as amended by
the Beaches Environmental Assessment and Coastal Health Act of 2000 (BEACH Act).  Section
3.2.1 defines the coastal recreation waters covered under the grant program. This document also
provides useful guidance for both coastal and inland beach monitoring and notification
programs. The BEACH Act, however, authorizes the award of grant funds to support monitoring
and notification programs for coastal recreation waters only.

In 2002 the U.S. Environmental Protection Agency (EPA) published performance criteria for the
BEACH Act grant program. That document raised the bar for beach monitoring and notification
programs by standardizing required program elements, while still allowing states sufficient
flexibility to accommodate their local conditions. Since then, EPA and the states have created a
strong infrastructure to implement the national and state BEACH Act monitoring and notification
programs. Together, EPA and the states have built a program that has greatly increased
consistency among the states as well as the quality, quantity, and timeliness of beach water
quality data.  This information helps beachgoers to make informed decisions about beach-going
activities and helps beach managers take actions to safeguard the health of their beaches and the
people using them.

Today's beach programs are ready to take the next steps, and following the performance criteria
and recommendations in this guidance will help them to accomplish that.
1 For simplicity, throughout the remainder of this document, unless otherwise noted, we use the general term state to
refer to the 30 coastal and Great Lakes states or local governments and the coastal territories defined in CWA
section 502 as 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. Eligible tribes are recognized
independently and not included in the term state. If certain requirements or recommendations apply in a different
manner to each governmental entity, the text will specify how they apply. This simplified terminology also applies
to those entities using this document as nonbinding guidance, e.g., those not receiving CWA section 406(b) grants.


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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.                  Chapter 1


   •   Consistent with the BEACH Act, the guidance requires states receiving grants under
       CWA section 406 to adopt new or revised recreational water quality standards (WQS).
       State adoption of new or revised standards will put in place the many public health
       protections from the 2012 Recreational Water Quality Criteria (RWQC), including:
       o  Addressing a broader range of illness symptoms.
       o  Better accounting for pollution after heavy rainfall.
       o  Ensuring equal protection for swimmers in coastal and Great Lakes waters.
       o  Encouraging early alerts to beachgoers by identifying a conservative threshold for
          issuing beach notifications (i.e., advisories and closures).
       o  Making available a quantitative molecular method (qPCR) that provides analytical
          results in hours.
       o  Supporting tailored WQS for site-specific public health protection.
   •   The guidance also paves the way for improved beach monitoring and public
       awareness. The performance criteria and recommendations in the guidance will lead
       states into an era characterized by widespread use of sanitary surveys to identify sources
       of fecal pollution; the use of qPCR analysis  and predictive modeling that facilitate same-
       day notification of water quality exceedances; site-specific solutions for protecting public
       health; and timely reporting of water quality results and advisory information for easy
       public access and dissemination.

1.1  Program and Document Overview

EPA initially published National Beach Guidance and Required Performance Criteria for
Grants in June 2002. EPA is revising the guidance to accomplish the following:
   •   Reflect updated science.
   •   Incorporate key considerations deriving from EPA's most recent CWA section 304(a)
       criteria recommendations in the 2012 Recreational Water Quality Criteria (RWQC;
       USEPA2012b).
   •   Emphasize using tools such as sanitary surveys in evaluating and classifying beaches.
   •   Encourage a more comprehensive approach optimizing resources by developing a tiered
       monitoring and notification plan that takes into account new tools, such as modeling and
       rapid methods, and historical information about each beach.
   •   Update the discussion on beach notification and communication to include tools such as
       social media, websites, and email.

Chapters 3, 4, and 5 of this guidance discuss these changes.
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.                   Chapter 1
  Key Changes to This Document from the 2002 Guidance
     •   Updates the science on pathogens, fecal indicator bacteria (FIB), and health concerns
         (sections 1.2, 1.3, and 1.4) and references.
     •   Discusses the beach program and the 2012 RWQC (sections 1.5 and 4.7).
     •   Makes sanitary surveys a central part of the beach classification process (section 3.4).
     •   Provides detailed guidance on developing the List of Beaches (section 3.6).
     •   Strengthens the link between prioritizing beaches and developing a tiered monitoring
         plan (sections 3.5, 3.6, and 4.2).
     •   Adds specific requirements to performance criteria 2, 3, 4, and 6 (sections 4.2, 4.4,
         4.5, and 5.2, respectively).
     •   Updates the science on beach water quality monitoring (section 4.3).
     •   Updates monitoring procedures to include quantitative polymerase chain reaction
         (qPCR) (section 4.4.2).
     •   Expands the discussion on integrating predictive models into monitoring plans (section
         4.6).
     •   Provides guidance on when to issue or remove a notification (section 5.3).
     •   Discusses new beach notification and communication tools, such as social media,
         email, and text messages (section 5.4).
     •   Adds a new performance criterion, Performance Criterion 10 (section 4.7.3).
The BEACH Act addresses the human health risks associated with water quality and swimming
or similar water contact activities in coastal recreation waters. The BEACH Act, an amendment
to the Federal Water Pollution Control Act (commonly known as the Clean Water Act, or CWA),
addresses pathogens and pathogen indicators2 in coastal recreation waters.

The BEACH Act contains four significant provisions:
    1.  The BEACH Act amended the CWA by adding section 303(i), which directs states with
       coastal recreation waters to adopt new or revised WQS for pathogens and pathogen
       indicators for which EPA had published criteria under CWA section 304(a) (i.e., EPA's
       1986 Bacteria Criteria). Section 303(i) also directs EPA to promulgate standards for
       states that fail to establish standards as protective of human health as EPA's 1986 criteria.
       EPA promulgated standards for specific states and territories with the publication of
       Water Quality Standards for Coastal and Great Lakes Recreation Waters Final Rule
       (40 CFR  [Code of Federal Regulations] part 131) in November 2004.
2 The BEACH Act uses the terminology pathogen and. pathogen indicators. The BEACH Act defines pathogen
indicator as "a substance that indicates the potential for human infectious disease" [33 U.S.C. 1362(23)]. Pathogen
indicators is a broad category of entities (which can include chemical and biological parameters) that can be used to
indicate the presence of pathogens in water. In the case of BEACH Act implementation, EPA's current recreational
water quality recommendations and state WQS are for FIB, which are a subset of the pathogen indicators used
globally for management of recreational waters. Where appropriate throughout the remainder of this document, FIB
are referred to specifically when discussing WQS. When a more inclusive discussion of indicators is presented, the
reference is to pathogen indicators.


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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.                  Chapter 1


   2.  The BEACH Act amended the CWA by adding sections 104(v) and 304(a)(9), which
       together require EPA to conduct studies associated with pathogens and human health and
       to publish new or revised CWA section 304(a) criteria for pathogens and pathogen
       indicators on the basis of those studies. EPA completed studies in December 2010 and
       published new or revised criteria for recreation waters in November 2012.

   3.  Under section 303(i)(l)(B), states that have coastal recreation waters are directed to adopt
       new or revised WQS for all pathogens and pathogen indicators to which EPA's new or
       revised section 304(a) criteria are applicable by no later than three years after EPA's
       publication of the new or revised section 304(a) criteria.

   4.  The BEACH Act amended the CWA by adding section 406, which authorizes EPA to
       award grants to states or local governments to develop and implement beach monitoring
       and notification programs. It also requires EPA to maintain state monitoring and
       notification data and make them available to the public. In addition, the BEACH Act
       amended section 518(e) of the CWA to authorize EPA to treat tribes in the same manner
       as states for the purposes of section 406; therefore, EPA is authorized to award grants to
       tribes.

To read the full text of the BEACH Act, go to
http://water.epa.gov/lawsregs/lawsguidance/beachrules/act.cfm.

1.1.1  Implementing the BEACH Act

Since the passage of the BEACH Act in 2000, EPA and states have created a strong
infrastructure to implement national and state BEACH Act monitoring and notification
programs. Significant progress has been made in providing more public health protection at
beaches.
   •   Beach grants. Beginning with development grants in fiscal year (FY) 2001, EPA has
       continued to provide implementation grants to states and tribes to monitor their beaches
       and notify the public of exceedances or likely exceedances of WQS for pathogens and
       pathogen indicators. Since 2001, EPA has made available nearly $130 million in grants to
       38 eligible grantees (30  states, five territories, and three tribes).
   •   State beach program infrastructure. States are the primary implementers of beach
       monitoring and notification programs funded  under the BEACH Act. Since 2000, they
       have significantly refined, improved, and upgraded their beach programs, often through
       the use of innovative approaches. The number of monitored beaches more than doubled
       between 1997 and 2012. Since 2005, monitored beaches have been open for an average
       of 95 percent of the available beach days during each beach season.
       Many states are using innovative tools such as predictive models and rapid analytical
       methods to provide faster, more accurate public notification of exceedances or likely
       exceedances of applicable WQS for pathogen indicators. They have improved beach
       notification signage and outreach and communication with the public. Some states issue
       notifications in English and Spanish or use color-coded systems to indicate differences in
       risk. Many states now provide real-time beach water quality results and beach status
       information through the Internet so the public can be better informed.
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.                  Chapter 1


   •   Sound science and new program tools. In 2008 EPA published the Great Lakes Beach
       Sanitary Survey User Manual (USEPA 2008) and sanitary survey forms to encourage
       using this tool to characterize beach environments and identify likely sources of
       pollution. Through the Great Lakes Restoration Initiative, states conducted more than
       400 sanitary surveys at Great Lakes beaches. On the basis of the findings of the sanitary
       surveys, mitigation measures are currently being implemented at several Great Lakes
       beaches to reduce or eliminate contamination.
       In 2013 EPA published the Marine Beach Sanitary Survey User Manual (USEPA 2013)
       to help beach managers in coastal states synthesize beach and watershed information
       from the survey to improve water quality for swimming and develop models to predict
       daily water quality. The marine survey forms include detailed questions on winds, tides,
       and other characteristics that affect marine beaches; these were not included on the
       survey forms for the Great Lakes.
       EPA also developed and implemented a comprehensive research plan that includes the
       development and validation of rapid molecular methods for quantifying FIB to allow for
       rapid beach notification, the refinement and validation of predictive models for fresh and
       marine waters, and large-scale epidemiological studies in fresh and marine waters to
       determine the relationship between fecal indicator levels and illness.

   •   BEACON. EPA created the Beach Advisory and Closing Online Notification (BEACON)
       system to meet the BEACH Act requirement that EPA establish and maintain a publicly
       available database of pollution occurrences for coastal recreation waters. In January 2012
       EPA launched BEACON 2.0, which provides access to mapped locational data (beaches
       and monitoring stations); monitoring results (pathogen indicators, algae, salinity,  and
       more); and notification data (advisories and closures). For the first time, beachgoers can
       view reports containing both notification and water quality monitoring  data.  To access
       BEACON, go to http://watersgeo.epa.gov/BEACON2/about.html.

1.1.2  How to Use This Document
This document replaces the June 2002 National Beach Guidance and Required Performance
Criteria for Grants and sets forth performance criteria for (1) monitoring and assessing coastal
recreation waters adjacent to beaches (or similar points of access used by the public) to
determine whether there are exceedances of applicable WQS for pathogen indicators and
(2) promptly notifying the public of any exceedance or likely exceedance of applicable WQS for
pathogen indicators for coastal recreation waters. EPA is required to publish performance criteria
under CWA section 406(a). Section 406(b) authorizes EPA to award grants to  states and tribes to
implement  monitoring and notification programs, but  only if the program meets certain
requirements. (See CWA section 406(b) and (c).) One such requirement is that monitoring and
notification programs must be consistent with the performance criteria published under CWA
section 406(a).

EPA will use the performance criteria to determine whether a monitoring and notification
program is  eligible for an implementation grant under CWA section 406(b). This document
includes required performance criteria, general EPA grant rules under 40 CFR part 31, and
nonbinding recommendations. This document can serve as a reference guide on how to develop
and conduct a beach monitoring and notification program that is not funded by a CWA section

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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.                  Chapter 1


406(b) grant. It provides information on classifying recreational waters, performing monitoring
and assessment, and notifying the public about beach advisories. This information is useful to
beach or program managers of all beaches whether they are adjacent to coastal recreation waters
or other waters. For states, tribes, and local governments without CWA 406(b) grants, the
requirements this document describes would not be binding, but they can be used as
recommendations to develop and implement effective beach monitoring and notification
programs.

1.1.3  How This Document Is Organized

   •   Chapter 1 discusses human health concerns associated with exposure to pathogens and
       discusses the establishment of WQS for pathogen indicators, specifically FIB.
   •   Chapter 2 summarizes the basic requirements that an applicant must meet to receive a
       BEACH Act implementation grant. It 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 introduces a tiered, 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 to assess the relative human health risks and usage of their
       beaches and to assign an appropriate management ranking to each beach.
   •   Chapter 4 discusses the performance criteria related to monitoring and assessment and
       provides detailed technical guidance. This chapter provides a step-by-step approach for
       developing a conceptual monitoring framework and applying it to ranked beaches. It also
       includes performance requirements related to recreational water quality criteria and beach
       notification thresholds.
   •   Chapter 5 describes the performance criteria and technical guidance related to a beach
       program's public notification and risk communication. The chapter completes the
       conceptual framework by describing a tiered approach to notification.

1.2  Pathogens

Microorganisms that have the potential to cause disease in a host are called pathogens. The small
subset of infectious microorganisms that are capable of causing human diseases are known as
human pathogens.

Diseases from pathogens occur in a three-stage  process: exposure, infection, and illness.
Exposure to pathogens (e.g., in recreational water) might occur by direct contact, ingestion,
inhalation, or entry into the body through an open wound. Infection occurs in a dynamic
interaction involving the susceptibility of the host and the virulence of the pathogen. Illnesses
that result from these various exposures and host-pathogen interactions can vary in their
symptoms and severity. Commonly documented diseases from  swimming in contaminated
recreational  waters include gastrointestinal illness; respiratory illnesses; skin rashes; and ear, eye,
and wound infections. Sometimes these infections can result in death.
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.                  Chapter 1


Human pathogens in recreational waters can be naturally occurring or of environmental origin,
such as the bacterium Vibrio vulnificus and the amoeba Naegleria fowler7, or they can be
introduced through contamination events with the feces of humans and other warm-blooded
animals (e.g., norovirus, enterohemorrhagic Escherichia coli, and Cryptosporidium sp.). Modern
wastewater treatment is designed to be effective at killing bacteria, such as those that cause
cholera and typhus, but is less effective at reducing human infective enteric viruses and protozoa.
In waters that contain human fecal contamination, potentially all the waterborne diseases spread
by the fecal-oral route could be contracted by bathers. In recreational waters, three groups  of
pathogens—viruses, bacteria, and parasitic protozoa—are of concern.
    •   Viruses are a group of infectious agents that require a host to replicate. The most
       significant virus group affecting water quality and human health grows and reproduces in
       the gastrointestinal tract of people and animals and therefore is called enteric viruses.
       Enteric viruses are excreted in feces, and they can include hepatitis A, rotaviruses,
       caliciviruses, noroviruses, adenoviruses, enteroviruses, and retroviruses. Most
       gastrointestinal illness associated with swimming in water contaminated with wastewater
       effluent and other human fecal sources can be attributed to human enteric viruses (Seller
       et al. 2010). Typical wastewater treatment practices reduce the concentration of
       pathogenic viruses by 10- to 100-fold (Flannery et al. 2012; Lodder and de Roda Husman
       2005), with secondary treated and disinfected effluent still containing human infective
       doses of enteric virus. Viruses are species-specific to their host; that is, human pathogenic
       viruses can cause disease in humans but not in other organisms.
    •   Bacteria are unicellular microorganisms that lack an organized nucleus and other
       membrane-bound organelles. Feces from humans and other warm-blooded animals contain
       large numbers of bacteria, including pathogenic species (such as Campylobacter spp. and
       Salmonella spp.). Some pathogenic bacterial species can be free-living and native to water
       environments, such as Vibrio cholera and Vibrio vulnificus. The pathogenic bacteria that
       are largely of concern for recreational waters  are introduced into waters by fecal
       contamination (e.g., Campylobacter jejuni, Salmonella spp., pathogenic E. coll, Shigella).
    •   Protozoans are unicellular organisms with a defined nucleus. Pathogenic protozoans can
       be found in the feces of humans and other warm-blooded animals or can be part of the
       natural microflora found in the environment. Some species can exist in the environment
       as  spores or cysts that hatch, grow, and multiply after ingestion, causing associated
       illness. Other species, such as Naegleria fowleri and schistosomes, cause disease in a
       free-living life stage (AWWA 2006). Two protozoan species of major concern as
       waterborne pathogens are Giardia lamblia and Cryptosporidium parvum (Academic
       Press 2003).

Waters contaminated by nonhuman fecal material can also pose a risk to swimmers because
some pathogens that infect animals can  also cause illness in humans. These types of pathogens
are called zoonotic pathogens. EPA conducted a review of the scientific literature on zoonotic
pathogens during the development of the 2012 RWQC and found information on key waterborne
zoonotic pathogens and their potential survivability in the environment (USEPA 2009c). A
World Health Organization (WHO) and EPA joint publication (WHO 2004) provides further
detailed information on zoonotic pathogens, including their geographic prevalence, potential
disease prevention measures, good management practices for animal waste disposal, and an
international perspective. Table  1-1 lists some of the  diseases that can result from contact with

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water contaminated by human or animal waste, or naturally occurring bacterial, viral, and
protozoan pathogens.

1.3  Fecal Indicators

A variety of pathogens can be present in waters contaminated by fecal pollution. The types and
numbers of pathogens present will be determined by the source and magnitude of the fecal
contamination reaching a water body. Because of the great diversity of pathogens that can affect
human health (see table 1-1), and the fact that pathogens are often seasonally and geographically
distributed, widespread monitoring of recreational waters directly for all disease-causing
microorganisms from fecal contamination is infeasible. Therefore, protection of public health for
those using recreational waters has been accomplished for more than a century through the use of
FIB such as E. coli and Enterococcus sp. FIB  are bacterial groups or species that are naturally
found in the guts of warm-blooded animals (including humans) and therefore are excreted in
high densities in the feces of such animals (NRC 2004). They provide an estimation of the
amount of feces (or degree of contamination) and, indirectly, the presence and quantity of fecal
pathogens in the water (NRC 2004). Even though public health agencies have long used them to
identify the potential for illness resulting from exposure to contaminated waters, numerous
epidemiology studies have recently corroborated the use of FIB  as predictors of adverse health
outcomes (Colford et al. 2012; Pruss 1998; Wade et al. 2003; Wade et al. 2008; Wiedenmann et
al. 2006; Zmirou et al.  2003).

Since the middle of the last century, EPA and its federal predecessors have recommended levels
of various FIB groups for the protection of the health of those recreating in surface waters
(USEPA 1976, 1986, 2012a). For more information on indicators of fecal contamination, refer to
EPA's literature review of fecal indicator organisms in ambient waters (USEPA 2009a) and a
scientific review of alternative indicators of fecal pollution (Savichtcheva and Okabe 2006).

EPA recommends that states use two different types of FIB to monitor ambient waters,
culturable E. coli and Enterococcus sp. Indicators of fecal contamination are not limited to the
FIB EPA recommends and might include other types of microorganisms, such as viruses
(e.g., coliphage), bacteria (e.g., Bacteroidales), and other enumeration methods for traditional
FIB (e.g., immunomagnetic  separation/adenosine triphosphate [EVIS/ATP], qPCR). Risk
managers might wish to choose indicators that perform effectively given local climatological and
hydrological conditions (e.g., Clostridiumperfringens in tropical waters) or possess
characteristics that help to identify specific fecal contamination  sources (e.g., sterols, brighteners,
microbial genetic markers). Whichever indicators are used for beach notification programs, they
must be reliable predictors of an exceedance or the likelihood of an exceedance of the applicable
WQS.
3 This technical concept was captured and codified into 33 U.S.C. 1362(23) by the BEACH Act amendment to the
CWA. The BEACH Act defines a substance that indicates the potential for human infectious disease to be a
pathogen indicator. Although FIB are not direct indicators of the presence or number of pathogens, their presence
have been shown in epidemiology studies to be predictive of the potential for human infectious disease
(e.g., gastrointestinal illness).

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Chapter 1
             Table 1-1. Examples of waterborne pathogens in the three groups:
                              bacteria, viruses, and protozoans

Bacteria
Protozoa
Viruses
Aeromonas spp.
Campylobacter spp.
Clostridium spp.
Escherichia coli*
Helicobacter pylori
Legionella pneumophila
Leptospira spp.
Pseudomonas
aeruginosa
Salmonella typhi
Salmonella enterica
Shigella sonnei
Vibrio vulnificus
Vibrio cholerae
Yersinia enterolitica
Balantidium coli
Cryptosporidium spp.
Entamoeba histolytica
Giardia lamblia
Naegleria fowleri
Adenovi ruses
Astrovirus
Enterovirus (including
echovirus and Coxsackie
virus)
Hepatitis A and E
Norovirus
Rotavirus
Disease
Wound infections,
gastroenteritis
Gastrointestinal illness
Gastrointestinal illness
Gastrointestinal illness
Gastritis
Legionellosis
Leptospirosis
Urinary tract infection,
respiratory illness, wound
infection
Typhoid fever
Salmonellosis
Shigellosis
Vibriosis
Cholera
Yersinosis
Balantidiasis
Cryptosporidiosis
Amoebiasis (amoebic
dysentery)
Giardiasis
Amoebic
meningoencephalitis
Gastrointestinal illness,
respiratory disease
Gastrointestinal illness
Gastrointestinal illness,
upper respiratory tract
infection, myocarditis
Infectious hepatitis
Gastrointestinal illness
Gastrointestinal illness
Symptoms and Effects
Fever, chills, nausea, abdominal pain,
cellulites
Diarrhea, abdominal pain, gastroenteritis
Diarrhea, fever, nausea, gastroenteritis
Vomiting, diarrhea, gastroenteritis
Diarrhea; peptic ulcers are a long-term
sequela
Acute respiratory illness
Jaundice, fever (Weil's disease)
Dermatitis, soft tissue infections,
bacteremia
High fever, diarrhea, ulceration of the
small intestine
Diarrhea, dehydration
Bacillary dysentery
Wound infection, septicemia, diarrhea
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
Gastroenteritis; vomiting; upper
respiratory tract symptoms such as
coughing, sore throat, fever
Gastroenteritis, vomiting, diarrhea
Diarrhea, gastroenteritis, vomiting, fever,
heart inflammation, cough, sore throat,
bronchitis
Jaundice, fever
Gastroenteritis, vomiting, diarrhea
Gastroenteritis, vomiting, diarrhea
 *Denotes pathogenic E. coli, which differs from the nonpathogenic E. coli used as an FIB.
 Sources: Cloete et al. 2004; Guillot and Loret 2010; USEPA2002, 2009b; and WHO 2004.
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It is important to note that FIB are not exclusively of fecal origin, and they can be part of the
natural microflora in the environment. FIB have also been shown to persist and even grow in
sand, sediments, and soils; on plant surfaces; and within algal mats and biofilms (Byappanahalli
and Ishii 2010; Byappanahalli et al. 2012; Verhougstraete et al. 2010). FIB from these nonfecal
sources have not been demonstrated to be related to the potential for human illness. EPA
recommends that beach managers understand the potential fecal sources in the watershed
affecting their beach to most effectively protect the health of beachgoers. Performing a sanitary
survey4 (section 3.4.1) of the beach watershed is a good step toward this goal, and EPA has made
available surveys for both marine and freshwater beaches.

1.4 Health Concerns

The primary route of exposure to enteric pathogens in recreational waters contaminated with
feces is incidental or accidental ingestion of contaminated water. Swimming in contaminated
waters results in  an elevated potential of contracting gastrointestinal illness. Symptoms include
chills, nausea, diarrhea, and fever and can vary in severity depending on the etiologic agent.
Other health endpoints, such as respiratory illness, ear and eye infections, and skin rashes,  have
been observed from similar exposures, but gastrointestinal illness has been the disease observed
most frequently.  Pathogens from nonfecal sources can have various routes of exposure resulting
in diseases affecting the eye, ear, skin, and upper respiratory tract. Infection can result when
pathogenic microorganisms come into contact with small breaks and tears in the skin or ruptures
in delicate membranes in the ear or nose.

People who acquire an illness from swimming in contaminated water do not always associate
their illness with swimming because of the delay in the onset of the illness. For example, viral
gastrointestinal illness is often mild, short-lived, and self-limiting, but  symptoms usually take up
to 24 hours to appear. Outbreaks of disease are documented when many people seek medical
assistance because of a similar illness or the severity of the illness. However, people with mild
illness  often do not seek medical assistance.  Therefore, disease outbreaks are often inconsistently
recognized and the outbreak information in the literature is likely underestimated.

Pathogens can be difficult to routinely monitor in ambient waters because they often occur at
levels below the  detection limit, can require  samples of large volumes  of water, and often require
concentration before enumeration (Borchardt and Spencer 2002; Girones et al. 2010; Rochelle
and Schwab 2006). In addition, spatial and temporal variability in the occurrence and level of
pathogens should be  considered in any ambient pathogen-monitoring regime. As discussed in
section 1.3, public health agencies have traditionally relied on FIB to measure the magnitude of
fecal contamination in a water body. Since the 1950s,  studies have been conducted to gauge how
the level of fecal contamination translates into potential human health risks through FIB
measurements. Many of these studies, called epidemiology studies, have established a link
between the FIB level in bathing waters and the incidence of swimming-associated disease
symptoms. EPA  conducted a review of the epidemiology studies found in the scientific literature
during the development of the 2012 RWQC  (USEPA 2009b). For many of the epidemiology
studies, the pathogens causing many of the reported illnesses were likely viral in nature
(e.g., norovirus)  (Cabelli  1983; Seller et al. 2010). Additional analyses of the existing
4 http://www2.epa. goWbeach-teclVbeach-sanitarv-survevs
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epidemiological data have shown that the presence of enteroviruses was strongly associated with
the reported gastrointestinal illness (Wade et al. 2003).  Viruses have characteristics, such as their
susceptibility to treatment in a wastewater treatment plant and fate and transport behavior in the
environment, that differ from those of the bacteria used as fecal indicators.

In 1972 EPA began to study the relationship between the quality of bathing water and the
resulting health effects. Studies in the 1970s and 1980s examined the differences in symptomatic
illness between swimming and non-swimming beachgoers at marine and freshwater bathing
beaches affected by treated and nontreated human fecal contamination (Cabelli 1983; Dufour
1984). The studies found that swimmers who recreate in water contaminated with sewage are at
greater risk of contracting gastrointestinal illness than non-swimmers, and that the reported
swimming-associated illness rate increases as the quality of the bathing water (as measured by
FIB) degrades.

A newer study has shown that even at frequently monitored beaches with very low
concentrations of fecal indicators, there is a risk of contracting a swimming-related illness.
Starting in 2003 and continuing through 2010, EPA conducted several epidemiological
investigations as part of the National Epidemiologic and Environmental Assessment of
Recreational Water (NEEAR) study program at freshwater and marine beaches affected
predominantly by secondary treated and disinfected sewage effluent. The purpose of the NEEAR
study program was to determine the relationship between health effects in swimmers and water
quality measured using a quantitative polymerase chain reaction (qPCR) analytical methodology
that produces quantitative results in two to three hours (Wade et al. 2008). Chapter 4 contains
more information on the qPCR methodology.

The NEEAR results found increases in gastrointestinal  illness with increasing FIB levels as
measured through the use of the qPCR analytical methodology as specifically applied to
enumeration of Enterococcus sp. (Wade et al. 2006, 2010). A stronger association was found
with gastrointestinal illness than with other health endpoints (i.e., rash, upper respiratory illness,
eye ailment, earache, and infected cut).  The NEEAR epidemiological studies found the
occurrence of gastrointestinal illness to be positively associated with levels of Enterococcus spp.
as enumerated with EPA's Enterococcus spp. qPCR Method 1611 in marine and fresh waters
and with Bacteroidales enumerated with EPA'sBacteroidales qPCR method in marine waters
(Wade et al. 2008, 2010). The association between gastrointestinal illness and enterococci
enumerated by membrane filtration (EPA Method 1600) in the NEEAR study was positive but
was not statistically significant across the range of water quality observed. However, there was a
similar significant increase of illness noted at 30 and 35 colony-forming units (CFU) enterococci
per 100 milliliters (mL). The results of the NEEAR studies substantially informed the 2012
RWQC.

1.5  Water Quality Criteria  and Standards for Bacteria

1.5.1  State Implementation of the 2012 Recreational Water Quality Criteria (RWQC)
WQS are provisions of state, tribal, or federal law consisting of a designated use or uses for the
waters of the United States and water quality criteria based upon such use (40 CFR 131.3(1)).
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They are the foundation of the nation's water quality management program and define the water
quality goals for a water body.

Section 304(a)(l) of the CWA directs EPA to publish recommended water quality criteria
accurately reflecting the latest scientific knowledge on the effects of the presence of pollutants in
water on health and welfare, including recreation. The criteria EPA published under section
304(a) are intended to provide guidance to states in establishing water quality criteria in their
WQS. Section 304(a)(9) of the CWA, as amended by the BEACH Act, directs EPA to publish
new or revised water quality criteria recommendations for pathogens and pathogen indicators
(including a revised list of testing methods, as appropriate) on the basis of the results of studies
EPA conducted under section 104(v) of the CWA, for the purpose of protecting human health in
coastal recreation waters. EPA's 2012 Recreational Water Quality Criteria (USEPA 2012b)
meet the requirements of section 304(a)(9), but also include section 304(a) recommendations for
noncoastal recreation waters because EPA developed the 2012 RWQC to protect all waters in the
United States designated for primary contact recreation.

CWA section 303(i)(l)(B) directs BEACH Act coastal and Great Lakes states and tribes with
coastal recreation waters designated for primary contact use for which EPA has approved WQS
under the CWA to  submit new or revised WQS for BEACH Act waters to EPA for review by
December 2015 (i.e., "36 months after the date of publication" of the 2012 RWQC). EPA also
encourages states and tribes with non-BEACH Act waters to review and revise their WQS as
appropriate during  their next triennial reviews.

Revised WQS from any state or tribe must include criteria that are scientifically defensible and
protective of the primary contact recreation use. In the 2012 RWQC, EPA recommends that the
state or tribal RWQC consist of a magnitude (the maximum amount of a pollutant that may be
present in a water body that supports the designated use) expressed as a geometric mean (GM)
and statistical threshold value (STV); a duration (the period of time over which the magnitude is
calculated); and frequency of exceedance (the maximum number of times the pollutant may be
present above the magnitude over the specified duration). If a state or tribe were to adopt criteria
based on the 2012 RWQC recommendations, they would be considered scientifically defensible
and protective of the primary contact recreation use.

EPA regulations at 40 CFR part 131 provide that in establishing numeric criteria, states should
establish criteria values based on EPA's section 304(a) recommendations (e.g., the 2012
RWQC), or section 304(a) guidance modified to reflect site-specific conditions, or adopt criteria
based on other scientifically defensible methods (40 CFR 131.11(b)(l)). EPA reviews and
approves state WQS.

The 2012 RWQC, like the 1986 criteria, recommend using culturable E. coti and enterococci as
indicators of fecal contamination for fresh water and enterococci for marine water. However,
there are several differences between the current and previous criteria recommendations. The
2012 RWQC differ as follows. They:
   •  Offer similar public health protection for fresh and marine waters.
   •  Provide two sets of recommended criteria values that protect the designated use of
       primary contact recreation.
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    •   Include a new statistical value, the STV, to be used in conjunction with the recommended
       GM value to evaluate the long-term health of a water body.
    •   Consist of a magnitude, duration, and frequency for both the GM and the STV.

The 1986 Bacteria  Criteria document included four single sample maximum (SSM) values for
different levels of beach usage (use intensities). In the 2012 RWQC, EPA removed those
recommendations and instead provided states and tribes with options for selecting a beach
notification threshold not adopted into WQS. The options differ, depending on whether the state
or tribe receives a grant under CWA section 406.

States and tribes receiving grants under CWA section 406(b) must agree to take a notification
action on an exceedance or likely exceedance of the applicable WQS as a condition of receiving
a grant. The FY 2014 beach grant workplans must include a commitment to develop a schedule
to adopt new or revised WQS pursuant to CWA section 303(i)(l)(B) by FY 2016 and a schedule
to identify and use  an appropriate beach notification threshold by FY 2016. EPA expects that
states and tribes receiving beach grants under CWA section 406 will select as their beach
notification threshold the Beach Action Value (BAV) based on the 75th percentile value that
corresponds to the  indicator and illness rate in their adopted WQS. However, they do have the
option  to submit a written justification to use a different value. The alternative value should be
selected from the same statistical distribution as the illness rate and corresponding values
adopted into state WQS, and the justification should explain why this value is preferable to the
EPA-preferred 75*  percentile value.

Other states and tribes have additional options, as discussed in sections 4.7.2.1 and 4.7.3.

The 2012 RWQC also make available information regarding a qPCR enumeration method
(Method 1611) for  the more rapid detection of Enterococcus spp. in marine and fresh water
compared to the traditional culturable enumeration methods. Method 1611 and an improved
Method 1609 are anticipated to provide increased public health protection by facilitating timely
notification to swimmers  of elevated FIB levels.

Section 4.7 discusses the beach program within the context of the 2012 RWQC
recommendations,  options for selecting a beach notification threshold, and other elements.

1.5.2  Implementation Guidance

It is beyond the scope of this document to provide an in-depth discussion of WQS and associated
technical issues. However, EPA has developed some technical support materials as guidance to
states on how to implement the 2012 Recreational Water Quality Criteria (USEPA 2012b) and
plans to develop more in the near future.

EPA strongly encourages states and tribes to review the technical support materials because they
provide guidance on how to implement tools that states and tribes can use (1) to enhance public
health protection when implementing state and tribal WQS for primary contact recreation and
(2) to develop WQS that differ from EPA's recommended criteria (i.e., alternative criteria).
These tools include sanitary surveys; predictive models;  epidemiological studies; quantitative
microbial risk assessment (QMRA); analytical methods,  including Enterococcus spp. qPCR
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(Method 1611; USEPA 2012a); and approaches for developing criteria using alternative fecal
indicators and methods. The technical support materials are available at
http://water.epa.gov/scitech/swguidance/standards/criteria/health/recreation/index.cfm.
Method 1611 can be found at http://water.epa.gov/scitech/methods/cwa/bioindicators/index.cfm.

1.6  Chapter 1 References

Academic Press. 2003. Handbook of Water and Wastewater Microbiology. Chapter 40, p. 695.
       Elsevier, San Diego, CA.

AWWA (American Water Works Association). 2006. Waterborne pathogens: Manual of Water
       Supply Practices. M48. American Water Works Association, Washington, DC.

Borchardt, M.A., and S.K. Spencer. 2002. Concentration of Cryptosporidium, microsporidia and
       other water-borne pathogens by continuous separation channel centrifugation. Journal of
       Applied Microbiology 92: 649-656.

Byappanahalli, M.N., and S. Ishii. 2010. Environmental Sources of Fecal Bacteria. In The Fecal
       Bacteria, ed. MJ. Sadowsky andR.L. Whitman, pp. 93-110. ASM Press, Washington,
       DC.

Byappanahalli, M.N., B.M. Roll, and R.S. Fujioka. 2012. Evidence for occurrence, persistence,
       and growth potential of Escherichia coli and enterococci in Hawaii's soil environments.
       Microbes and Environments 27(2):  164-170.

Cabelli, V. 1983. Health Effects Criteria for Marine Recreational Waters. EPA-600/1-80-031.
       U.S. Environmental Protection Agency, Cincinnati, OH.

Cloete, E., J. Rose, L.H. Nel, and T. Ford. 2004. Microbial Waterborne Pathogens. IWA
       Publishing, London, UK.

Colford, J.M., K.C. Schiff, J.F. Griffith, V. Yau, B.F. Arnold, C.C. Wright, J.S. Gruber, T.J.
       Wade, S. Burns, J. Hayes, C. McGee, M. Gold, Y. Cao, R.T. Noble, R.  Haugland, and
       S.B. Weisberg. 2012. Using rapid indicators for Enterococcus to assess the risk of illness
       after exposure to urban runoff contaminated marine water. Water Research 46(7): 2176-
       2186.

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

Flannery, J., S. Keaveney, P. Rajko-Nenow, V. O'Flaherty,  and W. Dore. 2012. Concentration of
       norovirus during wastewater treatment and its impact on oyster contamination. Applied
       and Environmental Microbiology 79(13): 3400-3406.

Girones, R, M. A. Ferrus, J. I. Alonso, J. Rodriguez-Manzano, B. Calgua, A. de Abreu Correa,
       A. Hundesa, A. Carratala, and S. Bofil-Mas. 2010. Molecular detection of pathogens in
       water—the pros and cons of molecular techniques. Water Research 44: 4325-4339.
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Guillot, E., and J. Loret. 2010. Waterborne Pathogens: Review for the Drinking Water Industry.
       IWA Publishing, London, UK.

Lodder, W.J., and A.M. de Roda Husman. 2005. Presence of norovirus and other enteric viruses
       in sewage and surface waters in Netherlands. Applied Environmental Microbiology 71(3):
       1453-1461.

NRC (National Research Council). 2004. Indicators for Waterborne Pathogens. The National
       Academies Press, Washington, DC.

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

Rochelle, P. A., and K. J. Schwab. 2006. Molecular Detection of Waterborne Microorganisms.
       Chapter 4 in Waterborne Pathogens: Manual of Water Supply Practices. 2nd ed.
       American Water Works Association, Washington, DC.

Savichtcheva, O., and S. Okabe. 2006. Alternative indicators of fecal pollution: Relations with
       pathogens and conventional indicators, current methodologies for direct pathogen
       monitoring and future application perspectives. Water Resources 40: 2463-2476.

Seller, J.A., T. Bartrand, N.J. Ashbolt, J. Ravenscroft, and T.J. Wade. 2010. Estimating the
       primary etiologic agents in recreational freshwaters impacted by human sources of fecal
       contamination. Water Resources 44: 4736-4747.

USEPA (U.S. Environmental Protection Agency).  1976. Quality Criteria for Water 1976 (The
       Red Book).  EPA 440/9-76-023. U.S. Environmental Protection Agency, Washington,
       DC.

	. 1986.  EPA 's Ambient Water Quality Criteria for Bacteria—1986. EPA 440/5-84-002.
       U.S. Environmental Protection Agency, Washington, DC.
      -. 2002. National Beach Guidance and Required Performance Criteria for Grants. EPA-
       823-B-02-004. U.S. Environmental Protection Agency, Office of Water, Washington,
       DC.

      -. 2008. Great Lakes Beach Sanitary Survey User Manual. EPA-823-B-06-001. U.S.
       Environmental Protection Agency,  Office of Water, Washington, DC.

      -. 2009a. Fecal Indicator Organism  Behavior in Ambient Waters and Alternative
       Indicators for Tropical Regions, U.S. Environmental Protection Agency, Office of
       Science and Technology, Washington, DC.

      -. 2009b. Review of Published Studies to Characterize Relative Risks from Different
       Sources of Fecal Contamination in Recreational Water. EPA 822-R-09-001. U.S.
       Environmental Protection Agency,  Office of Science and Technology, Washington, DC.
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      -. 2009c. Review of Zoonotic Pathogens in Ambient Waters. EPA822-R-09-002.
       U.S. Environmental Protection Agency, Washington, DC.
       http://water.epa.gov/scitech/swguidance/standards/criteri a/heal th/recreation/upload/2009_
       07  16  criteria recreation zoonoticpathogensreview.pdf.
	. 2012a. Method 1611: Enterococci in Water by TaqMan® Quantitative Polymerase
       Chain Reaction (qPCR) Assay. EPA-821-R-12-008. U.S. Environmental Protection
       Agency, Office of Science and Technology, Washington, DC.

	. 2012b. Recreational Water Quality Criteria. EPA 820-F-12-058. U.S. Environmental
       Protection Agency, Office of Water, Washington, DC.

	. 2013. Marine Beach Sanitary Survey User Manual. U.S. Environmental Protection
       Agency, Office of Science and Technology, Washington, DC.

Verhougstraete, M.P., M.N. Byappanahalli, J.B. Rose,  and R.L. Whitman. 2010. Cladophora in
       the Great Lakes: Impacts on beach water quality and human health. Water Science and
       Technology 62(l):68-76.

Wade, T.J., N. Pai, J. N.S. Eisenberg, and J.M. Colford, Jr. 2003. Do U.S. Environmental
       Protection Agency water quality guidelines for  recreational waters prevent
       gastrointestinal illness? A systematic review and meta-analysis. Environmental Health
       Perspectives 111(8): 1102-1109.

Wade, T. J., R.L.  Calderon, E.  Sams, M. Beach, K.P. Brenner, A.H. Williams, and A.P. Dufour.
       2006. Rapidly measured indicators of recreational water quality are predictive of
       swimming-associated gastrointestinal illness. Environmental Health Perspectives 114(1):
       24-28.

Wade, T.J., R.L.  Calderon, K.P. Brenner, E. Sams, M.  Beach, R. Haugland, L. Wymer, and A.P.
       Dufour. 2008. High sensitivity of children to swimming-associated gastrointestinal
       illness—Results using a rapid assay of recreational water quality. Epidemiology 19(3):
       375-383.

Wade, T.J., E. Sams, K.P. Brenner, R. Haugland, E.  Chern, M. Beach, L. Wymer, CC. Rankin,
       D. Love,  Q. Li, R. Noble, and A.P. Dufour. 2010. Rapidly measured indicators or
       recreational water quality and swimming-associated illness at marine  beaches: A
       prospective cohort study. Environmental Health 9:66.

WHO (World Health Organization). 2004. Waterborne zoonoses: identification, causes and
       control, ed. J.A. Cotruvo, A. Dufour, G. Rees, J. Bartram, and R. Carr. IWA Publishing,
       London, UK.

Wiedenmann, A., P. Kriiger, K. Dietz, and J.M. Lopez-Pila.  2006. A randomized  controlled trial
       assessing infectious disease risks from bathing in fresh recreational waters in relation to
       the concentration of Escherichia coli, intestinal enterococci, Clostridium perfringens, and
       somatic coliphages. Environmental Health Perspectives 114(20): 228-236.
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Zmirou, D., L. Pena, M. Ledran, and A. Letertre. 2003. Risks associated with the microbiological
       quality of bodies of fresh and marine water used for recreational purposes: Summary
       estimates based on published epidemiological studies. Archives of Environmental Health
       2003(58): 703-711.
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.                 Chapter 2
Chapter 2: Grants and Required Performance Criteria

This chapter addresses the basic requirements that an applicant must meet to receive a BEACH
Act program implementation grant. It identifies relevant sections of the BEACH Act, briefly
describes the corresponding performance criteria that EPA developed, and provides additional
grant-related information. Beginning with FY 2014 beach grants that are awarded after this
document is final, states5 and tribes must meet the performance criteria in this document to
receive a grant under section 406(b). However, this document contains a wealth of information
and many best management practices that states and tribes might want to follow. The general
approach and principles would also be applicable to inland beaches, although some
modifications might be necessary.
  Key changes to chapter 2 from the 2002 guidance document
     •  Reorganizes the 9 performance criteria and renumbers them to 11.
     •  Introduces new requirements for performance criteria 2, 3, 4, and 6.
     •  Introduces new performance criterion 10.
2.1  BEACH Act Conditions and Requirements Applicable to
      Section 406 Grants

EPA's statutory authority to award grants under section 406(b) of the BEACH Act includes a
series of conditions and requirements for developing and implementing a beach monitoring and
notification program funded by the grant. Section 406(c)  of the CWA, which includes grant
conditions that address the content of state and tribal programs, applies to all grants awarded to
states and tribes under the authority of section 406, regardless of whether the grant is for
development or implementation of a beach monitoring program. Section 406(b)(3)(A), which
addresses 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
(not territories or tribes). The requirements set forth in section 406(b)(2)(A) apply to all
implementation grants.

2.2  Performance Criteria

EPA has 11 performance criteria for implementing monitoring, assessment, and notification
programs based on the  requirements in CWA section 406. To be eligible for a grant to implement
a monitoring and notification program, the state's or tribe's program must be consistent with the
applicable performance criteria. FY 2014 beach grants awarded before this document is final
must be consistent with the performance criteria in the 2002 National Beach Guidance and
Required Performance Criteria for Grants. Beach grants for FY 2014 and beyond that are
awarded after this document is final must be consistent with the performance criteria in this
5 For simplicity, throughout the remainder of this document, unless otherwise noted, we use the general term state to
refer to the grant recipients discussed above (i.e., eligible states, territories, or local governments).


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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.
                                                             Chapter 2
document. The performance criteria also apply to federal agency programs and programs that
EPA implements directly. Table 2-1 lists general requirements of the performance criteria, cross-
referenced to the chapters in which they are discussed. They are also summarized in sections
2.2.1 through 2.2.11. Subsequent chapters provide the specific requirements associated with each
performance criterion, along with more detailed discussions.
                  Table 2-1. Summary of BEACH Act performance criteria
 Evaluation and
 Classification
          Risk-based beach evaluation and classification process
                                                                                    hapter
                                                                                   vvhere
                                                                                 discussed
 Monitoring
                                  Tiered monitoring plan
                                  Methods and assessment procedures
                                  Monitoring report submission
                                  Delegation of monitoring responsibilities
 Public Notification
 and Prompt Risk
 Communication
                                  Public notification and risk communication plan
          Actions to notify the public
          Notification report submission
                                  Delegation of notification responsibilities
 Implementation
 Schedules
10
Adoption of new or revised WQS and identification and
use of a beach notification threshold
 Public Evaluation
11
 Public evaluation of program
2.2.1  Risk-based Beach Evaluation and Classification Process (Performance
       Criterion 1)
Performance criterion 1 requires a state or tribe to develop a risk-based beach evaluation and
classification process and apply the process to its coastal recreation waters. The process must
describe the factors used in the state's or tribe's evaluation and classification process and explain
how the  state's or tribe's coastal recreation waters are ranked as a result of the process. That
process must result in a list of specific coastal recreation waters adjacent to beaches or similar
points of access used by the public. Chapter 3 discusses general and specific requirements for
this performance criterion in more detail.

2.2.2  Tiered Monitoring Plan (Performance Criterion 2)
Performance criterion 2 requires a state or tribe to develop a tiered monitoring plan. The plan
must adequately address the frequency and location of monitoring and the assessment of coastal
recreation waters on the basis of 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 and nonpoint
sources of pollution, and any effect of storm events on the waters. EPA has added three  new
considerations to the basis for developing the tiered monitoring plan. Chapter 4 discusses general
and specific requirements for this criterion in more detail.
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.                  Chapter 2
2.2.3  Methods and Assessment Procedures (Performance Criterion 3)
Performance criterion 3 requires a state or tribe to develop detailed assessment methods and
procedures. States and tribes must adequately address and submit to EPA methods for detecting
levels of pathogens and pathogen indicators that are harmful to human health in coastal
recreation areas. States and tribes must also provide documentation to support the validity of
methods other than those that EPA validated or approved. Finally, states and tribes must identify
and submit to EPA assessment procedures for identifying short-term increases in pathogens and
pathogen indicators that are harmful to human health in coastal recreation areas. Chapter 4
discusses general and specific requirements for this criterion in more detail.

2.2.4  Monitoring Report Submission (Performance Criterion 4)
Performance criterion 4 requires states and tribes to develop a mechanism to collect and report
monitoring data in timely reports. States and tribes must report their monitoring data to the
public in a timely manner, including posting on a website. They must report their monitoring
data to EPA at least annually or at a frequency required by the EPA Administrator. EPA
encourages states to coordinate closely with local governments to ensure that monitoring
information is submitted consistently. Reported data must be consistent with the list of required
data elements (see http://water.epa.gov/grants  funding/beachgrants/datausers index.cfm).
Chapter 4 discusses general and specific requirements for this criterion in more detail.

2.2.5  Delegation of Monitoring Responsibilities (Performance Criterion 5)
Performance criterion 5 requires a state to document any delegation of monitoring
responsibilities that might have been made to local governments. 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. Chapter 4 discusses general and specific requirements for this criterion in more detail.

2.2.6  Public Notification and Risk Communication Plan (Performance Criterion 6)
Performance criterion 6 requires that a state or tribe develop a 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 WQS.

The state or tribe must adequately identify measures to promptly communicate the occurrence,
nature, location, pollutants involved, and extent of any exceedance or likelihood of exceedance
of applicable WQS for pathogens and pathogen indicators. The state or tribe must identify how it
will promptly communicate that information to EPA. States are responsible for identifying how
they will promptly communicate the failure to  meet applicable standards to a designated official
of the local government in the area adjoining the coastal recreation waters with water quality
problems.

A state or tribal government program must describe procedures for posting signs at beaches or
similar points of access,  or taking functionally equivalent communication measures that are
sufficient to give notice to the public that the coastal recreation waters are not meeting or are not
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.                  Chapter 2
expected to meet applicable WQS for pathogens and pathogen indicators. Chapter 5 discusses
general and specific requirements for this criterion in more detail.

2.2.7  Actions to Notify the Public (Performance Criterion 7)
Performance criterion 7 requires that a state or tribe give notice to the public when coastal
recreation waters are not meeting or are not expected to meet applicable WQS for pathogens and
pathogen indicators.

A state or tribe must post signs at beaches or similar points of access, or provide 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 WQS for
pathogens and pathogen indicators. Chapter 5 discusses general and specific requirements for
this criterion in more detail.

2.2.8  Notification Report Submission (Performance Criterion 8)

Performance criterion 8 requires that states and tribes compile their notification data into timely
reports. States and tribes must report to EPA the actions they have taken to notify the public
when WQS are exceeded. Chapter 5 discusses general and specific requirements for this criterion
in more detail.

2.2.9  Delegation of Notification Responsibilities (Performance Criterion 9)
Performance criterion 9 requires that states describe any notification responsibility they have
delegated or intend to delegate to local governments.  The state must describe the process by
which  the state may delegate to local governments responsibility for implementing the
notification program. Chapter 5 discusses general and specific requirements for this criterion in
more detail.

2.2.10 Adoption of New or Revised WQS and Identification and Use of a Beach
       Notification Threshold (Performance Criterion 10)
Performance criterion 10 is a new criterion, intended to focus on adoption of new or revised
WQS as required by CWA section 303(i)(l)(B) and identification and use of an appropriate
beach notification threshold. These requirements apply to states and tribes receiving grants under
CWA section 406(b), and they will be implemented through conditions included in the grants.
Chapter 4 discusses general and specific requirements for this criterion in more detail.

2.2.11 Public Evaluation of Program (Performance Criterion 11)

Performance criterion 11 requires that states and tribes provide the public with an opportunity to
review the program through public notice and provide an opportunity to comment. This is not a
one-time requirement; public input must be sought whenever a state or tribe makes significant
changes to its beach program. If a state or tribe significantly changes its List of Beaches, beach
ranking, or other elements of its monitoring and notification program, the public must have an
opportunity to review the changes before implementation. Further, states and tribes should
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.
                                                       Chapter 2
consult with the applicable EPA Region prior to making significant program changes. Table 2-2
lists the general and specific requirements associated with this criterion.

The public evaluation can be accomplished through notice and public comment, meetings,
forums, or workshops. For example, when classifying and ranking beaches, it is beneficial to
gather input from members of the community regarding the recreational waters they would like
monitored. 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 current program.
        Table 2-2. Summary of public evaluation of program performance criterion
                               Performance criteria
 Public Evaluation of Program
 (Performance Criterion 11):
 This performance criterion
 requires a state, tribe, territory,
 or local government to provide
 the public with an opportunity to
 review the program through
 public notice and an
 opportunity to comment.
                                           Specific requirements
• Provide an opportunity for the public to comment on the following
  components of a beach monitoring and public notification
  program:
   o  Beach evaluation and classification process, including a list
      of waters to be monitored and beach ranking.
   o  Sampling design and monitoring plan, including sampling
      location and sampling frequency.
   o  Public notification and risk communication plan, including
      methods to notify the public of a swimming advisory.
                                                                                 Chapter
                                                                                 section
 3.6.2

4.3.3.5


 5.2.4
2.3  Additional Grant Information

2.3.1  Grant Program Phases

The BEACH Act authorizes EPA to award grants for both developing and implementing
monitoring and notification programs. Accordingly, EPA established 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 developing a state or tribal beach monitoring
and notification program. Currently, only tribes receive development grants. The second phase of
the grant program focuses on implementing a state or tribal beach monitoring and notification
program. All coastal and Great Lakes states and territories are currently receiving
implementation grants.

2.3.2  Eligibility for Grants

    •   State governments. Coastal and Great Lakes states are eligible to apply for grants to
       develop and implement monitoring and notification programs for their coastal recreation
       waters. In the BEACH Act, the term state applies to 30 coastal and Great Lakes states
       and five coastal territories defined in CWA section 502—the Commonwealth of Puerto
       Rico, the U.S. Virgin Islands, Guam, American Samoa, and the Commonwealth of the
       Northern Mariana Islands.
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.                  Chapter 2
   •   Tribal governments. Section 518(e) of the CWA authorizes EPA to treat eligible Indian
       tribes in the same manner as states for the purpose of CWA section 406. To receive
       BEACH Act grant funds, a tribe must have coastal recreation waters designated for
       primary contact use for which EPA has approved WQS under the CWA. Currently, three
       tribes—the Grand Portage Band of Lake Superior Chippewa, the Makah Nation of
       Washington State, and the Bad River Band of the Lake Superior Tribe of Chippewa
       Indians—receive BEACH Act grants.
   •   Local governments. The BEACH Act authorizes EPA to make grants to local
       governments for developing and implementing monitoring and notification programs
       only if EPA determines that the state or tribe is not implementing a program that meets
       the requirements of the statute. Erie County, Pennsylvania, is the only local government
       currently receiving a BEACH Act grant.

As mentioned previously, for the remainder of this document the term state refers to states,
territories, and local governments unless otherwise noted.

2.3.3  Selection Process
The EPA Administrator has delegated the authority to award BEACH Act program development
and implementation grants to the Assistant Administrator of the Office of Water (OW) and to
EPA Regional Administrators. EPA regional offices award program development and
implementation grants through a noncompetitive process.

If funds are available, EPA expects to award grants to all eligible state, territorial, tribal, and
local government applicants that meet the performance criteria specified in this document and
other statutory and regulatory requirements pertaining to grants.

2.3.4  Grant Award Process
EPA will award and administer BEACH Act grants according to the regulations at 40 CFR part
31 (Uniform Administrative Requirements for Grants and Cooperative Agreements to State and
Local Governments). EPA regional offices have the lead responsibility for providing grant
application packages and advice after EPA makes funding available. For information on specific
grants, grant coordinators, or other pertinent information, visit the Beaches website at
http://www2.epa.gov/beaches.
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.                  Chapter 3



Chapter 3: Risk-based Beach Evaluation  and  Classification

               Process

Protecting public health is the primary objective for a beach monitoring and notification
program. To meet this objective, beach program managers should strive to "know your beach"
and understand the potential for exposure to fecal contamination, and thus the adverse public
health risk that might occur at their beaches.

Conducting a risk-based beach evaluation and classification process  is required for BEACH Act
grantees. EPA may award BEACH Act grants to implement a monitoring and notification
program only if (1) the grant recipient prioritizes its grant funds for particular coastal recreation
waters based on the use of the water and the risk to human health presented by pathogens and
pathogen indicators and (2) the grant recipient makes available to EPA the factors used to
prioritize the use of funding (see CWA sections 406(b)(2)(A) (ii) and (iii)).

To meet this requirement, EPA recommends that states and tribes follow a stepwise approach to
conducting a beach evaluation and classification of their beaches. EPA's recommended approach
is discussed throughout this chapter and illustrated in figures 3-1 through 3-6. The term use., as
employed in this context refers to the usage of beach waters by the public; for example, how
many people use a beach and when do periods of peak usage occur. The term risk in this context
refers to the  susceptibility of beach waters to fecal contamination, particularly human, and
therefore the increased risk of adverse public health effects due to pathogens.

Chapters 3, 4, and 5 should be considered together. This chapter (chapter 3) explains how to
classify and rank beaches using risk management decisions based on potential public health
impact. Chapter 4 explains how to translate the beach rankings into detailed tiered monitoring
plans. Chapter 5 discusses the linkage to a state or tribe's notification and risk communication
plans for beaches.
  Key changes to chapter 3 from the 2002 guidance document
     •  Expands and clarifies the process for characterizing beach risk and use (section 3.4).
     •  Strengthens the link between prioritizing beaches and developing a tiered monitoring
        plan (sections 3.5 and 3.6).
     •  Makes sanitary surveys a central part of the beach classification process (section 3.4).
     •  Provides detailed guidance on developing the List of Beaches (section 3.6).
3.1  Performance Criterion

Performance criterion 1 (introduced in chapter 2) addresses the beach evaluation and
classification process that states and tribes must conduct. Table 3-1 includes the general and
specific requirements associated with this criterion, cross-referenced to the chapter sections.
States and tribes may develop their own evaluation and classification approach, but they must
address these requirements.
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.
                                                                         Chapter 3
This approach might also be helpful for assessing beaches in programs not funded by section
406(b) BEACH Act grants. (For example, these could include inland beaches in states that do not
receive beach grants.) For such programs, the requirements described below should be
interpreted as helpful recommendations, not binding requirements.

          Table 3-1. Summary of risk-based evaluation and classification process
                                   performance criterion
E
                    Performance criteria
eneral requirement
Soecific reauirement
  Risk-based Beach Evaluation and
  Classification Process (Performance
  Criterion 1). The state or tribe must develop a
  risk-based beach evaluation and classification
  process and apply it to the state's coastal
  recreation waters. A state or tribal program
  must describe the factors used in its
  evaluation and classification process and
  explain how its coastal recreation waters are
  ranked as a result. The process must result in
  a List of Beaches.
                             • Identify factors used to evaluate and rank
                               beaches.
                             • Identify state or tribal coastal recreation
                               waters.
                             • Notify EPA at least annually if the List of
                               Beaches changes significantly because of
                               revised beach rankings or changes to
                               monitoring and notification requirements and
                               considerations.
                             • Provide for public review of the risk-based rank
                               and classification.
                                                                         ihapter
                                                                         ection
                                                                         3.2-3.6
                                   2.2.10
EPA recommends using the following five steps in an evaluation and classification process to
develop a statewide or tribal List of Beaches:
    •   Step 1: Identify coastal recreation waters.

    •   Step 2: Identify "BEACH Act" beaches.

    •   Step 3: Characterize the beach to determine risk and use.

    •   Step 4: Rank beaches by tiers.
    •   Step 5: Classify beaches into a List of Beaches, identifying program and non-program
        beaches.

Details on each step are provided below.


3.2  Step 1: Identify Coastal Recreation Waters

The first step in the risk-based classification process (figure 3-1) has two parts: identifying
coastal waters and identifying the designated use of the waters.
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.
                                     Chapter 3
      Risk-based Beach Evaluation and Classification Process
Stepl
ID coastal
recreation
waters


^ Step 2
ID BEACH Act
beaches



StepS _
Characterize
beach risk and



Step 4
Rank beaches
by tiers



StepS
• Classify
beaches in
the program
• Create a List
of Beaches






Figure 3-1. Step 1: Identify coastal recreation waters.

The BEACH Act defines coastal recreation waters as the Great Lakes and marine coastal waters
(including coastal estuaries) designated under CWA section 303(c) by a state or tribe for
swimming, bathing, surfing, or similar water contact activities.

3.2.1  Coastal Versus Noncoastal Waters
To identify coastal recreation waters, managers
should first determine which of their waters are
considered coastal waters. The BEACH Act
specifically includes Great Lakes waters and
marine coastal waters, including oceans and
coastal estuaries.

The BEACH Act explicitly excludes from the
definition of coastal recreation waters both
inland waters and waters upstream of the mouth
of a river or stream that has an unimpaired
natural connection with the open sea. Figure 3-2
illustrates this difference. The heavy lines
indicate areas that would be considered coastal
waters; the thin lines indicate areas that would
not be considered coastal waters.
A state or tribe, in consultation with EPA, should
make the classification of coastal versus
noncoastal, taking site-specific conditions into
consideration.
                                                     Coastal Waters
                                                                        Noncoastal Waters
                                              Figure 3-2. Coastal and noncoastal waters.
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.
                                                            Chapter 3
3.2.2  Designated Uses of Water Bodies
States should consult their state WQS to determine the "designated use" for their coastal waters.
Under CWA section 303(c)(2)(A), each WQS adopted by a state or tribe must include a
designated use for the waters to which the standard applies, along with criteria to protect the
use(s).

Recreation occurs in many forms throughout the United States and frequently centers around
water bodies and activities that take place in and on the water. Waters where people could
engage in activities that might result in ingestion of the water or immersion are designated for
use as primary contact recreation waters in state or tribal WQS. Such activities, for example,
typically include swimming, water skiing, and surfing. Often a state will designate most or all of
its surface waters for primary contact recreation. The waters adjacent to bathing beaches
generally constitute a subset of the waters designated for primary contact recreation.

Most recreation waters are designated for year-round primary contact recreation. However, for
some waters,  a primary contact recreation use can be designated as "seasonal," attainable only
for several months of the year such as during warm summer months. Use designations include
seasonal, intermittent, or other recreation uses.

3.3 Step 2: Identify "BEACH Act" Beaches

The next step is to identify "BEACH Act" beaches as illustrated in figure 3-3. After beach
program managers identify which coastal waters are designated as primary contact recreation,
they should then determine which of these are considered "beaches." The BEACH Act grant
program is for "coastal recreation waters adjacent to beaches" or "similar points of access that
are used by the public"—waters where swimming, bathing, and other such activities occur. In
this document, the term beach refers to both beaches and similar points of access adjacent to
coastal recreation waters, not physical characteristics such as substrate and the like.
      Risk-based Beach Evaluation and Classification Process

       Stepl
    ID coastal
    recreation
    waters
   Step 2
ID BEACH Act
beaches
   StepS
Characterize
beach risk and
use
   Step 4
Rank beaches
by tiers
   StepS
• Classify
  beaches in
  the program
• Create a List
  of Beaches
Figure 3-3. Step 2: Identify beaches and similar points of access.
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.                 Chapter 3


A beach does not have to be in the public domain to be covered by a BEACH Act grant-funded
program. Privately owned beaches that are used by the public for swimming, bathing, and other
water contact activities should be included in the identification, evaluation, and classification of
beaches to meet this performance criterion.

As general guidance, beach boundaries can be defined by the following:
   •   Jurisdictional boundaries or designated portions of shoreline within a jurisdictional
       boundary.
   •   Natural or artificial barriers that form an up-coast or down-coast beach boundary.
   •   Access factors, which include proximity to towns, roads, parking lots, visitor centers,
       shops, and other cultural landmarks.
   •   Limits on services such as lifeguards and monitoring programs.

Regardless of the factors involved, however, access and usage of the water body ultimately
should determine whether a beach is included in a BEACH Act monitoring and notification
program.

3.4  Step 3:  Characterize the Beach to Determine Risk and Use

Two factors must be used in the third step (figure 3-4) to rank beaches in a BEACH Act grant-
funded program: (1) factors that indicate the potential risk to human health presented by
pathogens (section 3.4.1) and (2) use of the beach (section 3.4.2). As noted earlier, the term use
refers to the usage of a beach by the public and the term risk refers to the susceptibility of beach
waters to contamination from fecal contamination and, therefore, the increased likelihood of
adverse public health risks due to pathogens.
      Risk-based Beach Evaluation and Classification Process
       Stepl    _^T  Step2 H  »T   Step3   _^    Step4  ~1  ^ f"
                                                    StepS
    ID coastal
    recreation
    waters
ID BEACH Act       Characterize        Rank beaches      • Classify
beaches          beach risk and      by tiers             beaches in
                use                                the program
                                                   Create a List
                                                   of Beaches
Figure 3-4. Step 3: Characterize the beach to determine risk and use.
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.                 Chapter 3
3.4.1  Assess Potential Sources of Contamination and Risks
The first component of step 3 involves reviewing information to help beach managers assess
potential sources of fecal contamination and possible public health risks. The grantee may
consider a wide range of information sources. For example, available information may reside in
many places, including government agency files, literature and records in local libraries, beach
management reports, community association reports, public health records, scientific papers and
journals, and work performed by local nonprofit organizations. The information sources are
listed in order of relative importance.

3.4.1.1  Primary Information Sources
The most useful sources of information are sanitary surveys, reports on beach advisories and
closings, water quality monitoring reports, water quality modeling reports, and microbial source
tracking (MST) information.

3.4.1.1.1 Sanitary Surveys
Sanitary  surveys are one of the most widely accepted tools to assess potential  sources of
pollution that might adversely affect public health. They have been employed extensively in the
Great Lakes to evaluate sources of fecal contamination and help beach managers assess the
magnitude of pollution.

Beach sanitary surveys involve collecting information on factors that can affect water quality,
such as environmental, meteorological,  physical, biological, and land-based parameters.
Examples of information collected at the beach might include the  number of birds at the beach,
slope of the beach, location and type of sewage disposal, condition of bathrooms, recent rainfall
amounts, wind speeds and wave heights, and amount of seaweed on the beach. Information
collected in the watershed  could include land use, location of stormwater outfalls, water quality
tributaries such as rivers and estuaries, and residential septic tank  placement and function.

Even though BEACH Act  funds may not be spent for source mitigation and cleanup efforts,
managers may use grant funds for sanitary surveys to help prioritize beaches for the List of
Beaches. In addition, the survey results  can help prioritize and allocate state or county resources
to projects that can improve beach water quality. The survey results  can also help develop
models to predict beach water quality using readily available data (e.g., FIB levels,  source flow,
turbidity, and rainfall).

A beach sanitary survey also provides a documented historical record of beach and  watershed
water quality. By helping beach or program managers to establish baseline conditions and
understand water quality trends, a sanitary survey enables such managers to perform long-range
water quality and resource planning. A  sanitary survey can support enforcement actions by
recording conditions and operations at specific points in time (e.g., sewage spills). The
information in a survey can benefit stormwater program managers, wastewater facility managers,
local elected  officials, local planning authorities, academic researchers, and  other beach and
water quality professionals.
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.
                                                Chapter 3
For BEACH Act programs, beach managers should use surveys to help characterize health risks
at specific beaches, prioritize beaches for monitoring and notification efforts, and focus the
program to improve beach water quality.

The sanitary survey consists of two types of beach sanitary surveys—the Routine On-site
Sanitary Survey and the Annual Sanitary Survey—to assist with short- and long-term beach
assessments, respectively. The Routine On-site Sanitary Survey is designed to be performed at
the same time that water quality samples are collected. The Annual Sanitary Survey is more
comprehensive and can be used to record detailed information on the beach and the surrounding
watershed that might affect beach water quality. Both surveys include versions tailored for
freshwater and marine beaches. For example, the freshwater survey includes information on
septic tanks in the contributing watershed and land use information. The marine survey forms
include detailed questions on salinity, tides, and other characteristics, which the freshwater
surveys do not include.

All forms are available at http://www2.epa.gov/beach-tech/beach-sanitary-survevs.

The User Manual includes additional detailed information supporting each of these survey
questions, including detail about human and non-human sources. Additional information about
assessing non-human  sources is also available in EPA's RWQC technical support documents for
QMRA.

3.4.1.1.2  Beach Notifications—Advisories and Closings
Previously issued beach notifications (i.e., advisories and closings) can provide insight into water
quality problems. Information might include links to notifications caused by rain events, the
frequency of notifications during the  swimming season, causes of notifications (preemptive,
outfalls, increased sampling, rain),  and the number of swimming days affected by a notification.

3.4.1.1.3  Water Quality Monitoring Reports
Reports with data on bacterial indicator densities might be helpful. State water quality
monitoring reports often contain temperature, flow, turbidity, or other water quality data that
might be helpful in identifying water quality patterns because many factors influence the
temporal and spatial variability of fecal indicators in recreational waters.
3.4.1.1.4  Water Quality
          Modeling Reports
Predictive tools, including water
quality models, provide useful
information. Water quality
reports based on modeled results
can identify or highlight beach
areas that might pose increased
public health risk. Many beach
managers have noticed a
connection between the
A recent special issue of Water Research (Reis and Wuertz
2013) was devoted to a large-scale, collaborative MST project
that was coordinated by the Southern California Coastal
Water Research Project (SCCWRP) (Boehm et al. 2013;
Stewart et al. 2013). The project was called the Source
Identification Pilot Project. Although the project was
conducted only on human and animal fecal sources in
California, it provides a state-of-the-art examination  of MST
methodological approaches and their potential application for
source partitioning. General information on MST can  be found
at the SCCWRP website:
ftp://ftp.sccwrp.org/pub/download/DOCUMENTS/FactSheets/
SourcelDFactSheet web.pdf.
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enumeration of FIB at a beach and the amount of rain received in nearby areas (USEPA 2010).
Models that predict bacterial contamination during rainfall events can help reduce the risk of
swimmer exposure to contaminants between normal sampling periods. Beach managers can
develop a series of questions or a decision tree, considering factors such as rainfall to guide
beach notifications (USEPA 2010). Chapter 4 provides additional information on those types of
models.

3.4.1.1.5 Microbial Source Tracking
MST methods can help managers identify the types (e.g., human versus nonhuman) and sources
of fecal contamination, including those from nonpoint sources. MST is based on the assumption
that, given the appropriate method and source identifier, the source of pollution can be detected
and quantified (USEPA 2005). Several types of analytical methods are employed for MST, and
each has advantages, limitations, and applications. Determining which method is appropriate
depends on the distinctive circumstances associated with the specific study area, the results of
sanitary surveys, and budgetary and time constraints (USEPA 2005).

For more information on MST from EPA Region 10, visit
http://www.epa.gov/regionlO/pdf/tmdl/mst for tmdls guide  04 22 11.pdf Although  this
document addresses using MST in the total maximum daily load (TMDL) program, it also
provides general background information about MST approaches.

3.4.1.2  Other Information Sources

3.4.1.2.1 Point Source Discharge Data
Facilities authorized to discharge wastewater under the National Pollutant Discharge Elimination
System (NPDES) program, including, but not limited to, publicly owned treatment works
(POTWs), combined sewer systems, and concentrated animal feeding operations (CAFOs), can
provide information on the contents, quality, history, and locations of their point source
discharges.

3.4.1.2.1.1  Publicly Owned Treatment Works
POTWs are wastewater treatment works owned by a state or municipality (as defined by CWA
section 502(4)) that include any devices and systems used in the storage, treatment, recycling,
and reclamation of municipal  sewage or industrial wastes of a liquid nature. The term also
includes sewers, pipes, and other conveyances only if they convey wastewater to a POTW.
POTWs can contribute sources of human-derived pathogens that can potentially pose a
significant risk by adversely affecting human health. Therefore, the location, discharge  loadings,
operation, and compliance history of POTWs can be helpful to beach managers. For more
information, visit http://cfpub.epa.gov/npdes/home.cfm?program_id=3.

3.4.1.2.1.2  Combined Sewer Systems
Combined sewer systems are collection systems that convey domestic sewage, industrial and
commercial wastewaters, and stormwater into a POTW for treatment. During a wet-weather
event, a combined sewer overflow (CSO) can occur when the volume of wastewater entering a
combined sewer system exceeds  the POTW's treatment capacity. This results in the discharge of


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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.                 Chapter 3
excess flow directly to surface waters. CSOs contain raw sewage with high levels of floatable
materials, pathogens, conventional and toxic pollutants, and other pollutants. Information about
CSO events can help beach managers because such discharges can cause exceedance of WQS at
beaches, posing risks to human health (USEPA 2001). For more information on CSOs, visit
http://cfpub.epa. gov/npdes/faqs. cfm?program_id=5.

3.4.1.2.1.3  Concentrated Animal Feeding Operations
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.
Manure and wastewater from AFOs and CAFOs have the potential to contribute pollutants such
as pathogens, nutrients (e.g., nitrogen and phosphorus),  sediment, heavy metals, hormones,
antibiotics, and ammonia to the environment. The NPDES permitting program defines and
regulates CAFOs. Information about CAFOs can benefit beach managers because CAFOs might
contribute to water quality concerns if there are discharges near beaches. For more information
on CAFOs, visit http://cfpub.epa.gov/npdes/faqs. cfm?programid=7.

3.4.1.2.2 State Water Quality Assessment Integrated Reporting
A state's integrated report is a biennial state  submittal that includes the state's findings on the
status of all of its assessed waters (as required by CWA section 305(b)), a listing of impaired
waters and the causes of impairment, and the status of actions being taken to restore impaired
waters (as required by CWA section 303(d)). EPA has encouraged states to integrate water
quality assessment  information into one report.

EPA compiles state-submitted integrated report data to develop the National Water Quality
Inventory Report to Congress (CWA section 305(b)), determine states' variable portion of the
section 106 grant allocation formula, inform water quality decisions, and conduct national
analyses with various stakeholders to help restore the nation's waters.

The information in a state's CWA section 305(b) assessment typically identifies assessed water
bodies that are in full attainment, partial attainment, or nonattainment of their designated uses.
The 305(b) assessment is a good source of information for locating potential  problem  areas in
recreational water bodies. The section 305(b) reporting information has been made available
online through EPA's ATTAINS database. ATTAINS includes states' integrated water quality
assessment reporting under both sections 305(b) and 303(d). For more information, see
http://water.epa. gov/lawsregs/guidance/cwa/3 05b/index. cfm.

A state's CWA section 303(d) list of impaired waters includes water bodies that have been
identified as not attaining WQS (that are considered impaired) and, therefore, require TMDLs.
Each state must develop one or more TMDLs for all water body/pollutant combinations on the
state's 303(d) list. The CWA section 303(d) list might provide important water quality
information about the potential for fecal contamination.

For more information, visit http://water.epa.gov/lawsregs/lawsguidance/cwa/tmdl/index.cfm.
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3.4.1.2.3  Nonpoint Source (CWA Section 319) Reports
Nonpoint source pollution can be caused by rainfall or snowmelt moving over and through the
ground and carrying natural and human-made pollutants into lakes, rivers, streams, wetlands,
estuaries,  other coastal waters, and ground water. Since there are many potential nonpoint
sources of fecal contamination, these sources can contribute to contamination at beaches. Thus,
source identification or investigations should be factored into beach ranking decisions. Nonpoint
source pollution also can result from resuspension of bacteria-laden beach sands and
hydrological modification.

For more information on the CWA Section 319 Program, visit
http://water.epa.gov/polwaste/nps/cwact.cfm.

3.4.1.2.4  Illness Reports (Swimmer Reports or Hospital Records)
Medical records and epidemiological studies can provide information related to the historical risk
of swimming at a beach. Swimmer illness reports or complaints to a state agency are also
possible sources of information and can help answer the following questions:
    •   Have any swimmers complained to the state agency about illnesses believed to be related
       to the water quality at the beach?
    •   Have any hospitals or other medical facilities documented such reports of illness? Have
       any epidemiological studies been conducted at the beach?
    •   Have other government agencies described health problems at the beach or adjacent
       shoreline areas?
    •   Approximately how many reports of illness have occurred?  How many have occurred in
       the past year?

The frequency and severity of reports of swimming-associated illnesses can provide important
insight into the risks of bathing at a beach. In many  cases, however, people who contract
illnesses as a result of bathing in contaminated water do not always associate their symptoms
with swimming. They might associate illnesses with sources other than contaminated water. As a
result, illness outbreaks are often inconsistently reported. States should exercise caution when
determining the significance and validity of such data. Because interpretation of medical records
and epidemiological information can be a complex process, professionals trained in data
interpretation should perform this function.

3.4.1.2.5  Environmental Group Reports
Many environmental groups conduct studies and publish reports on local beaches and
recreational waters. The reports can help in classifying beaches because they might evaluate
levels of pathogen indicators and identify potential sources of pollution. The reports also might
include historical information and report how water quality conditions have changed over time.

3.4.2  Determine Use of the Beach
The second component of characterizing a beach is  determining its  use.  As noted at the
beginning of this chapter, the term use refers to the usage of beach waters by the public. The
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.
                                     Chapter 3
frequency of use—and thus potential exposure to pathogens—can be measured by determining
how many people use beach waters and when the peak periods of usage occur. The methods for
determining beach use include counting by hand, counting from photos, counting cars in the
parking lot, and using a laser counter at the beach entrance. Use estimates can be refined by
considering the percentage of people visiting the beach who actually enter the water, beach use
during holidays, the length of the swimming season, and a number of other factors. There is no
national definition of high beach usage. The determination of beach usage and associated
monitoring relies on a state-specific evaluation.

3.5  Step 4: Rank Beaches by Tiers

The fourth step is to rank the beaches and assign them to tiers using the information and data
collected in step 3 (figure 3-5).
Risk-based Beach Evaluation and Classification F
4
Stepl Step 2 Step 3 Step 4
ID coastal ID BEACH Act Characterize Rank beaches
recreation beaches beach risk and by tiers
waters use


'rocess
StepS
• Classify
beaches in
the program
• Create a List
of Beaches

Figure 3-5. Step 4: Rank beaches by tiers.

Once there is a clear understanding of use and potential risk from the previous step, states and
tribes should group beaches into tiers that share a similar risk or use level or both. As noted
earlier, risk and use must be given highest priority when ranking beaches for inclusion in the
monitoring and notification program. However, states and tribes may consider other factors such
as economic issues, tourism, and public opinion.

3.5.1  Other Factors

States may evaluate other factors (e.g., importance to the local economy and community input)
as secondary considerations in evaluating and classifying (i.e., ranking) beaches.  Chambers of
commerce and government agencies occasionally publish reports on the economic value of
natural resources and how they contribute to the local economy.

The state or tribe should identify these other factors and describe how they affect beach rankings.
For example, a state or tribe might determine that it has more beaches than it can monitor with
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.
                                                             Chapter 3
available resources and that beach usage presents equal risk to similar numbers of people. In this
case, the state or tribe might review other factors to decide which beaches to include in its
program, and which ones might either be moved to a lower tier or dropped from the program
entirely. Beaches dropped from the program would still be "BEACH Act beaches," but they
would not be included in the current monitoring and notification program.

3.5.2  Tiered Approach

EPA recommends that states and tribes consider using three tiers, and EPA's approach (here and
in chapters 4 and 5) is linked to such a three-tier organization. Tier 1 beaches, for example,
would include the group of beaches a jurisdiction considers its highest priority because of high
risk, high use, or both. Typically a higher proportion of monitoring and notification efforts would
be devoted to this group. Tier 3 beaches would be considered significantly lower on the risk/use
scale. Risk might be judged lower, for example, because of consistently good water quality as
evidenced by monitoring results. Tier 2 beaches fall somewhere in between.

3.6  Step 5: List of Beaches—Classify Beaches into "Program" Versus
      "Non-program" Beaches and Incorporate Them into a Final State
      List of Beaches

The fifth and final step (figure 3-6) is to use the ranked beaches  from Step 4 to complete the state's or
tribe's List of Beaches. In this document, EPA refers to the resulting list of BEACH Act beaches and
their adjacent waters—showing those which are included in the  monitoring and notification program
and those which are not—as the List of Beaches. States and tribes need to identify their lists and
submit them to EPA consistent with CWA sections 406(b)(2)(A)(iv)6 and 406(c)(l). EPA will rely
on this information to help fulfill its obligations under CWA section 406(g).
      Risk-based Beach Evaluation and Classification Process
      Stepl
   ID coastal
   recreation
   waters
   Step 2
ID BEACH Act
beaches
   Step 3     ^|
Characterize
beach risk and
use
   Step 4
Rank beaches
by tiers
   StepS
• Classify
  beaches in
  the program
• Create a List
  of Beaches
Figure 3-6. Step 5: Complete the List of Beaches.
6 CWA section 406(b)(2)(A)(iv) directs states to provide 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
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.
                                         Chapter 3
Program and non-program beaches are defined as follows:

    •  Program beaches are beaches and their adjacent waters subject to a state's or tribe's
       BEACH Act monitoring and notification program, consistent with the performance
       criteria.

    •  Non-program beaches are BEACH Act beach waters that are not subject to a state's or
       tribe's program, including those beach waters for which fiscal constraints prevent
       consistency with the performance criteria. Non-BEACH Act beaches would not be
       included in the List of Beaches regardless of their monitoring status because they would
       be eliminated during  steps 1 and 2, as discussed earlier in this chapter.

Table 3-2 shows how a state  or tribe might organize its List of Beaches.


                           Table 3-2. Example of a List of Beaches
Beach Rank # Tier Monitoring and Considerations
Beaches ranked individually Beaches grouped by tiers, (Add detail according to
by risk, use, or both) based on risk, use, or both) determinations in chapters 4 and 5*)
Program beaches
Beaches subject to the state's or tribe's BEACH Act monitoring and notification program
Tierl
1
2
3






Tier 2
4
5




TierS
6
7
8






Non-program beaches
Beaches not subject to the state's or tribe's BEACH Act monitoring and notification program
9
10




'Chapter 4 provides in-depth information on the requirements and recommendations for developing a detailed monitoring plan. It
addresses such topics as sources of variability, sampling depth, locations, resampling, analytical methods (e.g., culture versus
qPCR), modeling, analytical approaches, and quality assurance and control. Chapter 5 provides in-depth information on how to
develop a detailed risk communication and notification plan. It addresses such topics as types of notifications, signs, locations,
frequency, risk communication, and other considerations.


EPA recommends that each beach on the list include relevant information such as beach name,
beach ID number, location,  rank, and monitoring frequency.
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.                 Chapter 3
3.6.1  Initial Submission to EPA
The state's or tribe's List of Beaches must be submitted to EPA after the state or tribe has given
the public an opportunity to review it.

The BEACH Act authorizes EPA to award implementation grants only if the public is provided
an opportunity to review the grant-funded monitoring and notification program through a process
that provides for public notice and the opportunity to comment on the program, which would
include ranking of beaches. (See performance criterion 10, section 2.2.10.) A state or tribe
should review and address any public comments before submitting its List of Beaches to EPA.

3.6.2  Revising and Updating the List of Beaches

EPA expects that a state's or tribe's beach program will evolve over time and that its List of
Beaches will be a living document that is updated to reflect changing circumstances, such as
funding levels and evolving priorities. One specific requirement for performance criterion 1 (see
table 3-1) is that a state or tribe must notify EPA at least annually if the List of Beaches changes
significantly. These changes could include revised beach rankings, changes to monitoring and
notification requirements, or other important considerations. Therefore, a state or tribe must
review its program and associated List of Beaches annually to determine whether there are
significant changes and, if so, must provide the public with an opportunity to review these
significant program changes and discuss them with its EPA regional beach coordinators. States
and tribes must submit the information to EPA in the form of a revised state List of Beaches.

3.7  Federal Beaches

The federal government is responsible for BEACH Act beaches on federal property, consistent
with CWA section 406(d). BEACH Act grant funds may not be spent for monitoring or
notification at federal beaches. Moreover, states do not need to report information on those
beaches to EPA or include them in their List of Beaches.

3.8  Chapter 3 References

Boehm, A.B, L.C. Van De Werfhorst, J.F. Griffith, P.A. Holden, J.A. Jay, O.C. Shanks, D.
       Wanga, and S.B. Weisberg. 2013. Performance of forty-one microbial source tracking
       methods: A twenty-seven lab evaluation study. Water Research 47: 6812-6828.

Reis, M., and S. Wuertz, ed. 2013. Microbial  Source Tracking [issue title]. Water Research
       (47)18:6811-6956.

Stewart, J.R., A.B. Boehm, E.A. Dubinsky, T. Fong, K.D. Goodwin,  J.F. Griffith, R.T. Noble,
       O.C. Shanks, K. Vijayavel, and S.B. Weisberg. 2013. Recommendations following a
       multi-laboratory comparison of microbial  source tracking methods. Water Research
       47(18): 6829-6838.

USEPA (U.S. Environmental  Protection Agency). 2001. Guidance: Coordinating CSO Long-
       Term Planning with Water Quality Standards Reviews. EPA-833-R-01-002. U.S.
       Environmental Protection Agency, Office of Water, Washington, DC.

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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.                  Chapter 3
      -. 2005. Microbial Source Tracking Guide. EPA-600/R-05/064. U.S. Environmental
       Protection Agency, Office of Research and Development, Washington, DC.

      -. 2010. Predictive Tools for Beach Notification. Vol. 1, Review and Technical Protocol.
       EPA-823-R-10-003. U.S. Environmental Protection Agency, Office of Science and
       Technology, Washington, DC.
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.                  Chapter 4
Chapter 4: Beach Monitoring
Chapter 3 laid out a step-by-step process by which a state or tribe can conduct an evaluation and
classification of its beaches, resulting in a List of Beaches that is ranked in tiers determined on
the basis of potential risks to public health, beach usage, and other key factors (section 3.6).
  Key changes to chapter 4 from the 2002 guidance document
     •   Strengthens the link between prioritizing beaches and developing a tiered monitoring
         plan (sections 3.5, 3.6, and 4.2).
     •   Adds three specific requirements to performance criterion 2 (section 4.1).
     •   Updates the science on beach water quality monitoring (section 4.3).
     •   Updates monitoring procedures to include qPCR (section 4.4.2).
     •   Adds a specific requirement to report monitoring data to the public on a website
         (section 4.5).
     •   Expands the discussion on integrating predictive models into a monitoring plan (section
         4.6).
     •   Adds discussion of the beach monitoring program within the context of the 2012 RWQC,
         including adoption of new or revised WQS pursuant to CWA section 303(i)(l)(B) and
         identification and use of a beach  notification threshold (section 4.7).
Monitoring has evolved to include a number of support tools, including sampling, sanitary
surveys, and predictive tools. Chapter 4 describes the performance criteria and technical
guidance related to beach monitoring and assessment procedures for identifying short-term
increases in FIB. It also provides information on how to develop a tiered monitoring plan based
on local circumstances using the risk-based classification of beaches discussed in chapter 3. The
contents of the sections of this chapter are as follows:
    •   Section 4.1: A description of the performance criteria that relate to monitoring and
       assessment.
    •   Section 4.2: The concept of a tiered monitoring plan, including goals, considerations, and
       an example plan, along with requirements and recommendations for quality assurance
       (QA).
    •   Section 4.3: Detailed information on how to structure a monitoring program to assess
       beach water quality,  including recommended monitoring and analytical procedures.
    •   Section 4.4: A discussion of methods and procedures, including consideration of rapid
       methods.
    •   Section 4.5: A discussion about monitoring report submission.
    •   Section 4.6: Ways to incorporate predictive tools into a beach monitoring and notification
       program.
    •   Section 4.7: A discussion about the 2012 RWQC and beach monitoring programs.
    •   Section 4.8: A discussion of delegation of monitoring responsibilities.
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.
                                                         Chapter 4
The chapter includes monitoring approaches appropriate for both culture and qPCR methods for
determining FIB densities. Where approaches differ, the specific differences are clearly noted.
Many monitoring procedures are common to both methods of water quality analysis.

Integrating sanitary surveys into beach monitoring planning, using predictive tools in beach
management, and potentially using qPCR methods are valuable approaches that can be used for
beach monitoring, and they are emphasized in this document. EPA encourages beach or program
managers to be flexible when tailoring monitoring plans to their beach settings to optimize public
health protection by using a range of these available tools.
4.1  Performance Criteria

Additions to the monitoring and assessment performance criteria pave the way for states and
tribes receiving beach grants to implement significant improvements to public health protection
by widespread use of sanitary surveys to identify sources of fecal pollution; the use of qPCR
analysis and predictive  modeling, which facilitate same-day notification of water quality
exceedances; timely reporting of water quality results; and tailored WQS for site-specific public
health protection.

Table 4-1 summarizes the general and specific requirements of the five performance criteria
related to monitoring and to the beach assessment activities that go into forming a monitoring
plan (criteria 2 through 5 and 10) and cross-references them to the sections in this chapter that
discuss them.  The term assessment, used in this context, means gathering information to serve as
a basis for a monitoring plan, as distinct from the assessment activities associated with routine
monitoring  of ambient waters under CWA section 305(b).

                  Table 4-1. Summary of monitoring performance criteria
                                  rformance criteria
   General requirement
 Tiered Monitoring Plan
 (Performance Criterion 2).
 Performance criterion 2
 requires development of a
 tiered monitoring plan that
 can adapt to changing
 conditions and adequately
 protect public health.
                Specific requirements
Adequately prioritize, in the tiered monitoring plan, the frequency,
locations, and methods of monitoring and assessment of coastal
waters based on:
 o  A review of existing monitoring data.
 o  Periods of recreational use of the waters.
 o  The nature and extent of use of the waters.
 o  The proximity to known point and nonpoint sources of pollution.
 o  The effect of stormwater runoff on the waters.
 o  The appropriateness of qPCR methods.
 o  The potential use of predictive tools.
Provide for public review of the tiered monitoring plan.
Develop appropriate quality control (QC) policies and procedures and
submit adequate quality management plans (QMPs) and quality
assurance project plans (QAPPs) to EPA for approval.
                                                                                    __
4.2 and
  4.3
                                                                                     2.2.11
                                                                                      4.2.3
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.
                                                              Chapter 4

 Methods and Assessment
 Procedures (Performance
 Criterion 3). Performance
 criterion 3 requires the
 development of detailed
 methods and assessment
 procedures.
                                    rformance criteria
                                              ipecific i
• Submit to EPA methods for characterizing water quality relative to
  human health in coastal recreation areas.
• Provide documentation of the performance of methods other than
  those that EPA recommended or approved or validated.
• Identify and submit to EPA procedures for assessing short-term
  increases in FIB densities that indicate risk to human health in coastal
  recreation waters.
 Monitoring Report
 Submission (Performance
 Criterion 4). Performance
 criterion 4 requires
 development of a
 mechanism to collect and
 report monitoring data in
 timely reports.
  Make monitoring data available to the public, including posting on a
  website.
  Report monitoring data to EPA at least annually or at a frequency that
  the EPA Administrator determines. Reported data must be consistent
  with the reporting requirements specified at
  http://water.epa.gov/qrants fundinq/beachqrants/datausers index.cfm.
 4.5
 Delegation of Monitoring
 Responsibilities
 (Performance Criterion 5)
 States must describe any
 delegation that they have
 made, or intend to make, to
 local governments.
• If a state delegates monitoring responsibilities to local governments,
  the state grant recipient must describe the process that the state
  follows.
                                                                4.8
 Adoption of New or
 Revised WQS and
 Identification and Use of a
 Beach Notification
 Threshold (Performance
 Criterion 10) Performance
 criterion 10 requires states
 and tribes to develop and
 implement schedules
 leading to adoption of new
 or revised WQS and for the
 identification and use of an
 appropriate beach
 notification threshold.
  Develop and implement two separate schedules:
   o  To adopt new or revised WQS by FY 2016.
   o  To identify and use a beach notification threshold by FY 2016.
  Before identification and use of a new beach notification threshold,
  continue to make beach notification decisions using the existing
  threshold based on the currently applicable WQS, e.g., SSM.
4.7.3
Performance criterion 2 now requires states and tribes receiving beach grants to consider the
following elements when developing a tiered monitoring plan:

    •  A review of existing monitoring data. The BEACH Act states have been implementing
       beach monitoring programs since at least 2000, and since that time they have amassed
       large amounts of recreational water quality data.  These data provide a substantial
       characterization of water quality at monitored beaches and are likely to prove useful in
       formulating monitoring plans as well as in supporting model development. States and
       tribes must now consider these historical data when developing a tiered monitoring plan.

    •  The appropriateness ofqPCR. The 2012 RWQC make  available a number of tools to
       assist beach managers in implementing monitoring and notification programs. qPCR is a
       rapid molecular method that facilitates same-day notifications when beach water quality
       presents a risk to public health. It also presents challenges, including method
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       performance. However, given the potential for same-day notifications and the public
       health protection that qPCR could provide, states and tribes must now consider when
       developing tiered monitoring plans whether qPCR might be appropriate at specific sites.
       For states and tribes that know they do not have the resources or expertise to implement
       qPCR, or that practical factors such as proximity to laboratory facilities would preclude
       its use, "consideration" of qPCR could take the form of a brief acknowledgment in the
       grant workplan that, at the present time, the state or tribe has determined that qPCR
       cannot be implemented. For states and tribes that believe there might be beaches where
       qPCR could be implemented, "consideration" could involve developing a plan to perform
       a site-specific analysis.
   •   The potential use of predictive tools. Another tool discussed in  the 2012 RWQC is
       predictive modeling. Like qPCR,  modeling offers the potential for same-day notification,
       but for a considerably smaller resource outlay than qPCR. The 2012 RWQC encourages
       states and tribes to use site-specific models as part of a tiered monitoring plan. Given the
       potential for same-day notifications and the public health protection that modeling could
       provide, states and tribes must now consider when developing tiered monitoring plans
       whether predictive models might be appropriate at specific sites.
       State level of effort in considering the use of predictive models will also  be on a
       continuum, based on a state's or tribe's knowledge of their applicability (e.g., states with
       beaches with very good water quality might already know that models do not work well
       in those environments),  local circumstances, and available resources.

The level of effort a state or tribe puts into considering the use of qPCR or predictive models
may vary depending on the suitability of these tools and the state's or tribe's ability to implement
them, including whether the state or tribe has  sufficient resources.

Performance criterion 4 adds a requirement to post monitoring data on a website, to ensure its
wide public availability.

A new performance criterion 10 requires states and tribes to develop and implement schedules to
adopt new or revised WQS pursuant to CWA section 303(i)(l)(B) and to identify and use an
appropriate beach notification threshold.

4.2  Developing a  Tiered Monitoring Plan (Performance Criterion 2)

This section describes the required elements of a tiered monitoring plan and discusses QA
requirements and recommendations. Developing the tiered monitoring plan starts with the ranked
List of Beaches described in chapter 3.

4.2.1  Goal and Key Considerations
The goal of a tiered monitoring plan is to define combinations of monitoring activities that align
with identified priorities (i.e., tiers), are appropriate for the level of risk and use of a given beach,
effectively allocate available monitoring resources, and address site-specific circumstances. A
BEACH Act grant-funded program must prioritize the use of grant funds for monitoring on the
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basis of the use of the waters and the risk to human health. A beach or program manager should
consider the following factors when developing a detailed tiered monitoring plan:
    •  EPA requirements and policy recommendations for BEACH Act grants.
    •  Existing and historical beach water quality.
    •  Sampling considerations.
    •  Analytical methods.
    •  Available funding and staffing.
    •  Logistical considerations.
    •  Potential use of predictive tools.

The specific elements of monitoring plans will vary according to these factors, local practices
and policies, and the extent and nature of available resources. Regardless of the approach taken,
states and tribes must demonstrate how the plan meets the performance criterion for an adequate
tiered monitoring plan.

The number of tools available to states and tribes has increased in recent years. In 2002, when
the first beach guidance was issued, the primary decisions involved in the development of a
tiered monitoring plan included choosing which beaches to monitor and how often to monitor
them. The number of potential  considerations has increased.  Now states and tribes should factor
in information related to the following additional  questions:
    1.  What does the history of water quality monitoring at  this beach reveal about how often it
       requires monitoring?

    2.  How can sanitary survey findings be used to tailor monitoring approaches?

    3.  What is the most appropriate method of measuring water quality at this beach—culture or
       qPCR methods—relative to sources of contamination, the number and type of people
       visiting the beach (e.g., many families with small children), and available resources?

    4.  If it appears that a beach is a good candidate for qPCR, do practical factors such as
       proximity to laboratory facilities  allow timely notification?

    5.  Is this beach a good candidate for a predictive model or other predictive tool in terms of
       observed effects from sources under varying conditions?

    6.  Are staff members with experience in model development available?

    7.  How can the use of available resources be otherwise  optimized to best protect public
       health?
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4.2.2  Tiered Monitoring Plan
Table 4-2 presents an example of how the various tools available to a beach or program manager
might be incorporated into a tiered monitoring plan to maximize public health protection at a
range of beach settings with varying risk and use characteristics. As chapter 3 described, in
EPA's recommended tiering system, each tier shares a common level of risk (based on sources
and variable water quality) and degree of use by the public. In the example in table 4-2:
   •   Tier 1 = high risk and high beach usage.
   •   Tier 2 = high or moderate use and moderate or low risk.
   •   Tier 3 = low use and low or very low risk.
The tools include:
   •   Sanitary surveys.
   •   Methods and indicators.
   •   Monitoring frequencies.
   •   Predictive models or other predictive tools.
                     Table 4-2. Example of a tiered monitoring plan
Rank # Examples of application of tiered monitoring to a range of beach settings
(risk/ Analytical Monitoring
use) Tier method frequency Model Contributing factors Additional information
Program (P) beaches
1
2
3
4
5
6
7
P-1
P-1
P-1
P-2
P-2
P-2
P-3
qPCR
qPCR
Culture
Culture
Culture
Culture
Culture
5-7
days/week
3 days/week
3 days/week
Weekly
Weekly
Every 2
weeks
None or
infrequent
No
Yes
Yes
Yes
Rainfall
advisory
No
Rainfall
advisory
Nearby lab with qPCR
capability; high use; high
risk
Nearby lab with qPCR
capability; high use; high
risk; modeling experience
Lab with culture capability
only; high use; high risk;
modeling experience
High use; moderate risk
Moderate use; moderate
risk
High-moderate use; low
risk
Low use; low risk
High-use urban beach
Use of model as a
means of reducing
analytical cost through
targeted monitoring
Timely water quality
estimates daily from a
model
Model reduces
analytical cost
Rainfall advisory
supported
Rare exceedances
Rare exceedances or no
history of exceedances
Non-program (NP) beaches
8
9
10
NP
NP
NP
None
None
None
None
None
None
Rainfall
advisory


Low use; very low risk
Low use; very low risk
Low use; very low risk
Remote location
Remote location;
sporadic use
Resource limitation
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Results from sanitary surveys can help a manager classify beaches into tiers and select the most
appropriate tools for the monitoring program. Not every jurisdiction will use every tool in its
monitoring program. The right mix of tools for beach monitoring programs depends on the
setting, the resources available, the capabilities and approaches taken by the local jurisdiction in
meeting the public health protection function, and the tiered List of Beaches.

As mentioned in section 4.2.1, the local beach manager's selection of tools will likely depend in
part on the capabilities and practices specific to the jurisdiction. Resource availability or public
interest might influence a local beach  manager to choose to develop local modeling capability as
a means of stretching resources or to adopt qPCR analysis in response to local demand or the
new availability of qPCR at a local public health laboratory. Section 4.4.2 includes other factors
related to the selection of test methods for the applicable WQS (i.e., culture methods versus
qPCR).

States and tribes must determine which beaches to monitor and which beaches not to monitor
using an analysis of their recreational  waters based on the degree of recreational use of the
adjacent water body and risk to human health posed by known or unknown sources and historical
variable water quality. According to historical data that the states and tribes submitted to EPA,
some open-ocean marine beaches have never had a WQS exceedance. If the same beach has high
rates of beach usage, and is an important beach to a locale or municipality, then that beach would
still be considered important for continued monitoring.  A beach with no exceedances and low
use could be considered for reclassification as a non-program beach (i.e., a beach not subject to
the monitoring and notification program).  Such waters could be included in the state's  or tribe's
routine water quality monitoring program  for CWA  sections 305(b) and 303(d) (attainment and
listing) purposes to confirm continued good water quality in settings where there is no  history of
WQS exceedances.

EPA recommends a tiered monitoring approach that prioritizes the use of funds based on beach
usage and human health risk while taking  into account additional relevant factors. Such a policy
allows  flexibility to states and tribes, recognizing that there might not be uniform monitoring
requirements for all beaches. To best protect public health, the states and tribes must evaluate the
trade-offs  of monitoring more beaches less frequently or fewer beaches more frequently based on
degree of use of the beach, risk to human health, and other considerations. For example, qPCR
sampling could be used on days when a model predicted an exceedance of a WQS, and a
prediction of good water quality could be confirmed after the fact with the results from a less
expensive culture sample. Conversely, a model could replace sampling on some high-use days to
provide timely notification. In addition, beach managers should consider all available
information to reconcile or evaluate conflicting or anomalous analytical results, or results that
seem inconsistent with environmental conditions.  Comparing the outputs of multiple tools (e.g.,
monitoring results, model outputs, daily sanitary survey information), to the extent they are
available,  can help managers make informed assessments concerning their beaches' water
quality.

4.2.3  Quality Management System Requirements for Performance Criterion  2
To meet the quality management portion of performance criterion 2 (development of an adequate
tiered management plan), states and tribes must develop an appropriate QC system that includes
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adequate policies and procedures and submit them to EPA for approval. States and tribes must
submit documentation of the quality system for review and approval by the EPA Grants Officer
and the EPA QA officer, or an approved designee, before environmental measurements (primary
or secondary) are taken. States and tribes should contact the EPA regional QA officer for more
detailed guidance tailored to their grants.

EPA is committed to ensuring the quality of environmental data used in its decision-making
process and in activities supported by the Agency. As a result, EPA has developed an Agency-
wide quality system to ensure that environmental data  are of sufficient quantity and quality to
support the data's intended use. EPA OW has, in turn,  developed a QMP for its activities (the
OW QMP; USEPA 2009c) that is consistent with the Agency-wide quality system. Furthermore,
the tasks performed under BEACH Act grants involve environmentally related measurements
and data  generation, and thus they are covered by 40 CFR part 31 for grants and cooperative
agreements to  states, tribes, and local governments. To comply  with 40 CFR 31.45, grant
recipients must develop and implement QA practices consisting of policies, procedures,
specifications, standards, and documentation necessary to produce data of sufficient quality to
meet project objectives and to minimize loss of data due to out-of-control conditions or
malfunctions.

The grant recipients' consultation with EPA regional officials should determine what
documentation is sufficient to describe the quality system used  for their beach monitoring and
notification programs and should consider a variety of quality management topics, including but
not limited to the following:
   •   Ensuring that QA procedures are consistent with EPA's Policy Directive Number FEM-
       2012-02, Policy to Assure the Competency of Organizations Generating Environmental
       Measurement Data under Agency-Funded Assistance Agreements. A copy of the policy
       is available online at http://www.epa.gov/fem/pdfs/competencv-policy-aaia-new.pdf.
   •   Developing a QAPP or equivalent documentation for their beach monitoring and
       notification programs. A QAPP is a commonly used form of documentation for primary
       data collection. It is a technical planning document that  defines the objectives of a project
       or continuing operation and the methods,  organization, and quality management activities
       necessary to meet the project or operation goals. It serves as the blueprint for
       implementing the data collection activity to ensure that the program's technical and
       quality goals are met. It also provides the necessary link between the required data
       quality constraints and the sampling and analysis activities to be conducted. A QAPP
       typically details the technical activities and QA and QC procedures that should be
       implemented to ensure that the  data meet the specified standards. The QAPP should be
       implemented to ensure that data collected and analytical data generated are complete,
       accurate, and suitable for the intended purpose.
   •   Considering standard operating procedures (SOPs), which can be included as attachments
       to the tiered monitoring plan or QAPP and can  be used to present in detail the method for
       a given technical operation, analysis, or action in sequential steps. An  SOP includes
       specific sites, sampling locations, equipment, materials,  and methods;  QA and QC
       procedures; and other factors necessary to perform sampling, analysis, and notification.
   •   Addressing other tasks identified by EPA regional officials.
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4.3  Factors to Consider When Developing a Monitoring Plan

One of the major issues a beach or program manager must confront is the significant variability
inherent in beach water quality. This section provides information on how beach water quality
can affect the design of a monitoring program, recommended monitoring procedures, logistical
considerations for conducting a monitoring program, and recommendations for securing
laboratory services and choosing appropriate analytical methods. EPA published a thorough
review of scientific studies related to beach monitoring entitled Sampling and Consideration of
Variability (Temporal and Spatial) for Monitoring of Recreational Waters (USEPA 2010c). This
section summarizes the major findings. For more information see
http://water.epa.gov/scitech/swguidance/standards/criteria/health/recreation/upload/P12-
MonRept-fmal 508.pdf.
4.3.1  Variability of Beach Water Quality

4.3.1.1  Temporal Variations in Sources of Fecal Indicators and Pathogens
FIB densities in water samples are highly variable across time (temporal variability) and location
(spatial variability) at a beach. Temporal variability in FIB density—at time scales ranging from
minutes to months—has been observed in time series analyses of FIB density (Taggart et al.
1992). Variations with time scales on the order of minutes are important because such
considerations influence the number of samples needed to accurately characterize microbial
water quality and the confidence with which to ascribe the results of sampling events. Variations
with time scales on the order of tens of minutes are important because they have the same time
scale as that of typical recreational use
episodes. Variations with time scales
on the order of a day are important
because knowledge of them allows
comparison between samples taken  at
different times of the day or between
samples taken on successive days.
Temporal variability can also be
caused by both environmental and
meteorological parameters such as
sunlight intensity and temperature
(USEPA 20 lOc).

Although there can be site-specific
differences, many factors contribute to
temporal variations in FIB density for
both coastal  and inland sites.
Figure 4-1 depicts the relative level  of
effects on FIB densities.
                   Contributors
                   to Temporal
                   Variabilityin
                   Fecal Indicator
                     Bacteria
Figure 4-1. Relative contributions to temporal variations
in FIB density. (Line length indicates duration of
influence.)
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4.3.1.1.1  Event-Scale Variability
Event variability refers to the change in FIB density associated with rain events. Event-scale
variabilities constitute the category of greatest variability (including both temporal and spatial
variabilities) in FIB density for both coastal and inland waters. Rainfall events account for a
large portion of the total FIB loading into receiving water systems. In addition, among the
documented temporal variations, event-scale variability is, by far, the greatest for both inland and
coastal waters. FIB density can increase by several orders of magnitude during a single rainfall
event. FIB loading varies significantly during rain events and  is related to rainfall intensity and
duration, total rainfall amount, and antecedent rainfall patterns. Because event variability is so
great, beach or program managers might use alternatives to FIB densities for assessing water
quality during and after rainfall or storm events. For example, the correlation between historical
rainfall and FIB data might allow the estimation of the total rainfall amount over a 24-hour
period above which beaches are likely to exceed existing WQS.

For inland sites and coastal sites affected by hydrologic features such as streams and drainage
outfalls, FIB densities sometimes correlate poorly with rainfall amounts and stream gauges
because of the dependence  of FIB response on factors such as antecedent rainfall and the input of
FIB from sources such as CSO discharges. In general, indicator density peaks during the rising
limb of the storm hydrograph when loading to the stream is high and streams are turbulent,
promoting re-suspension of sediment-associated indicators. The lag period between the
beginning of rainfall events and sharp rises in indicator density varies among sites, with small,
flashy streams exhibiting shorter lag periods and coastal  sites  exhibiting longer lag periods.
Generally, indicator densities decline faster than the hydrograph because of depletion of
indicators from land surfaces and other reservoirs  as they are washed out. The time it takes for
the indicator density in a stream or lake to recede to pre-storm levels is highly variable among
drainages and even for a given drainage. Similar trends have been observed for coastal sites.
Indicator densities rise quickly during storms because of loading from stormwater runoff,
nearshore sands, and increased wave action and mobilization of indicators from sediments.
Presumably, dilution would cause event-scale variability to be less at coastal sites than in
streams, though poor mixing in the vicinity of stream mouths  and stormwater outfalls appears to
contribute to extreme event-driven changes in indicators.

4.3.1.1.2  Diurnal (Daily) Variability
A limitation of culture methods for the analysis of beach water samples for FIB is that the results
are available a minimum of a day later. By the time the results are received, the water quality at
the location sampled is likely to have changed. Leecaster and Weisberg (2001)  analyzed a large
set of total coliform and fecal coliform data from samples collected at  Southern California
beaches in an attempt to associate sample collection frequency with misidentifying exceedances
of FIB WQS in coastal waters. The lag time between sampling and analysis completion was not
considered. Table 4-3 presents the number of missed exceedances for four sampling frequencies.
One explanation for the poor performance of the schemes considered is the frequency of
exceedances of single-day duration. Approximately 70 percent of exceedances lasted for only a
day. The exceedances were characterized by water quality only slightly exceeding standards.
Given the variabilities and uncertainties associated with sample collection and analysis,  there is a
high probability for misclassification of water quality for samples with FIB  densities near or
within the confidence interval of the existing standard.

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       Table 4-3. Percent of exceedances missed for different sampling frequencies
Sampling frequency
5 days per week (weekdays only)
3 times per week
Once per week
Once per month
% missed exceedances
20%
45%
75%
95%
            Source: Adapted from Leecaster and Weisberg (2001).


4.3.1.1.3  Tidal Variability
Low tides are associated in most cases with higher FIB densities at coastal sites. This association
is typically a result of increased freshwater input to estuarine and coastal locations during low
tide, given the direction of water flow. In a minority of circumstances, such as when rising tides
cause connections with contaminated surface waters during a hurricane or tropical storm,
hydrological connection of sewage and stormwater conveyance systems can occur. In general,
tidal variability is minor compared with diurnal and rainfall variability.

Approaches for accounting for tidal variation of FIB density in developing sampling schemes
include sampling without regard to tidal cycles and sampling at low tide or the portion of the
tidal cycle during which FIB density is highest (all other factors being equal).

4.3.1.1.4  Monthly and Seasonal Variability
Most U.S. inland streams experience higher FIB densities during the spring and summer than
during the winter. That phenomenon arises from generally lower precipitation and runoff during
summer months combined with greater loading from sources such as wildlife and domestic
animals (particularly those with seasonal  access to streams) and bacteria growing in nearshore
soils or sediments. In tropical locales such as Hawaii, Puerto Rico, and south Florida, differences
in seasonal precipitation patterns and other climatic factors can give rise to peak indicator density
in other seasons. For sites where recreational use spans only the summer months, variation in
indicator density with season does not influence the design of monitoring programs.  Similarly,
seasonal and monthly variability of fecal  indicators at coastal sites is difficult to assess and tends
to be linked to the wide range of climates existing along the U.S. shoreline and its indirect
consequences on indicator density (e.g., loading patterns that vary with season). At both inland
and coastal settings, seasonal and monthly variability of fecal indicator organisms is of lesser
significance than event-scale variability.

4.3.1.1.5  Short-Time Variability
Short-time variability describes rapid changes in FIB density occurring even when sample
collection is conducted at intervals as short as 1 to 10 minutes.  Variations in the density of the
Enterococcus spp. greater than the WQS  can occur between adjacent samples taken at those time
scales (Boehm 2007), and certainly variations can occur more quickly than the results of
previous sampling can be obtained using  culture methods.
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4.3.1.2  Relative Magnitude of Spatial Variation
Spatial variability relates to the alignment of
sources at a beach, advection, and the distribution
of mixing on the beach (USEPA 2010c). Although
site variations can alter the relative dependence of
indicator density on sample location, the expected
general dependence of indicator density variability
with location for coastal sites is shown in
figure 4-2. Studies have shown that for coastal
sites, there is a general trend toward decreasing
indicator density with water column depth (USEPA
2010c).
                                                       Site
                                                     Features
 Contributors to
Spatial Variability in
 Fecal Indicator
   Bacteria
                                                                               Sample
                                                                               Depth
                                                  Figure 4-2. Relative contributions to spatial
                                                  variation at coastal beaches.
For inland water sites, the expected variation is
slightly different from that for coastal sites, as
shown in figure 4-3. For inland lakes, however,
there is a general trend toward higher FIB density at the bottom of the water column (USEPA
2010c).

Features that promote or inhibit mixing and point sources of fecal indicator organisms play a
significant role in the distribution of indicators. These features, which can be identified during a
sanitary survey, include:
    •  Jetties, dams, or other features that
       influence mixing at a site or reduce the
       natural flow of water and therefore can
       retain contamination at a beach.
       Point sources, particularly stormwater or
       wastewater treatment discharges, in the
       vicinity of the beach.
       Other diffuse sources of contamination
       such as small ponds and areas where wild
       birds and animals congregate, dog parks,
       and livestock and agriculture operations
       near beaches.
                                                      Depth
                                                      Below
                                                      Surface
                                                               Contributors
                                                                to Spatial
                                                               Variability in
                                                               Fecal Indicator
                                                                Bacteria
                                                                Bad
                                                              V
                Along
               Stream
                                                  Figure 4-3. Relative contributions to spatial
                                                  variation at inland beaches.
4.3.2  Recommended Monitoring
Monitoring programs range from simple to complex, depending on the setting. The range in
beach settings is vast—from pristine settings to heavily used urban beaches. For every beach,
there is an appropriate monitoring plan that addresses the risk and use characteristics chapter 3
described.

The following sections provide recommendations for basic sampling frequency and monitoring
procedures a state should consider in developing its monitoring plan. Not all settings will call for
using the range of options listed in table 4-2. This section includes an example of a basic three-
tiered plan, which is one recommended approach. In addition, careful observation by beach or
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program managers of circumstances under which poor water quality occurs through the use of a
daily sanitary survey or other process could provide the basis for focused sampling or preemptive
advisories.

4.3.2.1  Sampling Considerations
EPA recognizes that variation in indicator bacteria densities is one of the main technical
challenges that beach or program managers face when designing effective monitoring programs
and interpreting sampling results. FIB densities at different sites can substantially vary (spatially
and temporally).  Accordingly, managers should tailor monitoring plans to individual
circumstances. The tiered monitoring plan should address specific monitoring procedures,
including sampling time, location, and depth. Each of these is described in more detail below.

4.3.2.1.1  Sampling Frequency
EPA recommends that samples be taken one or more times per week during the swimming
season at Tier 1 beaches and once per week at Tier 2 beaches, starting a month before the
swimming season. Sample as close as possible to the peak swimming period of the week (usually
the weekend), while still allowing time for retesting and notification on subsequent days.

Sampling frequencies should be consistent with the circumstances at a beach. For example, many
agencies sample  Tier 1 beaches more frequently to minimize the uncertainty in their sampling.
Conversely, less  frequent sampling might be appropriate for Tier 2 or greater beaches, depending
on distance to suspected pollution sources, beach use, historical water quality data, and other risk
factors.

For Tier 3 beaches, EPA recommends a minimum sampling frequency consistent with other
ambient water quality sampling programs. However, these beaches should be reviewed
periodically to determine whether they should be reclassified as Tier 1 or Tier 2 or non-program
beaches. Such an assessment should include a review of beach use, an updated sanitary survey,
and a review of the water quality history and resulting advisories.

When sampling for qPCR analysis, if possible, sample on every day of significant  swimming
activity for same-day notification. If this is not possible, sample on the peak swimming days for
same-day as well as subsequent-day notification and retesting. Rapid methods can also influence
the selection of sampling frequencies. Rapid methods might promote the public expectation of
daily monitoring at heavily used beaches where same-day notification of exceedances has  been
provided on some days.

4.3.2.1.2  Sampling Frequency and Predictive Models
A predictive model can be used to complement analytical test methods for the applicable WQS
(e.g., culture or qPCR methods), reducing the frequency of sampling, depending on the
circumstances and setting of a beach. Data from culture samples can be used as a basis for
models that provide timely results in a cost-effective manner. In addition, historical data are now
available for most monitored beaches.
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The time period covered by the data used to build robust models can vary in length, depending
on the beach setting. According to varying trend analyses conducted by the U.S. Geological
Survey (USGS), the suggested minimum data collection period is roughly two years (Gonzalez et
al. 2012), whereas some EPA modeling trials obtained favorable results from data collected over
45 days (Frick et al. 2008). In addition, using a model should not completely replace monitoring
(USEPA 2010c). If the locally selected threshold for predictive errors is maintained at a lower
monitoring frequency (e.g., twice per week to once per week) after building a model on the basis
of twice per week, the model can save scarce monitoring resources for use at another location
where a model might not be appropriate.

4.3.2.1.3  Timing of Sample Collection
Collecting samples early in the morning for culture analysis appears to offer the best balance
between practicality and generation of data that protect human health (USEPA 201 Ob). If culture
methods are used  for enumerating FIB, morning samples could generate results that would allow
posting of health advisories the next morning.

For culture methods, FIB densities tend to be lower in the afternoon, probably because of the
effects of sunlight. Diurnal (daily) variation in indicator density is observed in both  inland and
coastal waters. In  general, when culture methods are used for FIB enumeration, the highest FIB
densities are observed in the morning. Depending on the insolation on a given day and at a site,
the lowest FIB density might occur between 2:00 p.m. and 3:00 p.m. These patterns suggest that
early sampling might be more protective of public health when using culture methods.

The density of the FIB as determined using qPCR is not as sensitive to time of day as the density
measured using culture methods because the qPCR methods quantify DNA instead of
metabolically active cells (Boehm et al.  2002; Converse et al.  2012). Furthermore, many
epidemiological studies include data collected and pooled from throughout the day (Wade et al.
2008).

When sampling for qPCR quantitation, however, earlier sampling means that public notification
will occur earlier in the day and therefore will inform the public in a timelier manner.
Nevertheless, practical limitations (such as sample transport and other factors) could delay such
notifications.

4.3.2.1.4 Sample Location
There is no standard definition of beach length, or a standard requirement for the distance
between beach monitoring stations. Sampling locations should be selected on the basis of the
ability of a small number of samples to adequately describe water quality at the site. These are
generally locations where FIB are most  likely to be associated with a fecal pollution source.

Sampling locations in the alongshore direction should be chosen on the basis of the mixing
characteristic of the beach and location of sources of fecal contamination as determined by sanitary
surveys. When there are beach features that influence hydrodynamics (mixing), beach regions with
different hydrology cannot be expected to have similar FIB densities, and therefore they should be
sampled separately. The following suggestions can also help in structuring a sampling plan:
    •   Sample within 60 meters of where the greatest beach use occurs (where the people are).

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   •   If the beach is short, take samples at a point corresponding to each lifeguard chair, or one
       point for every 100 to 200 meters of beach, depending on the dimensions of the beach.
   •   If the beach is long (more than 5 miles), take samples at the most highly used areas and
       spread out along the entire beach.
   •   Sampling location should take into account beach features (e.g., channels, streams,
       jetties, groins, stormwater discharge pipes) that might affect FIB density.

Sampling locations should be selected to obtain the greatest amount of information that can be
used for public health protection. The variable effect from a known or potential source would be
an example of such useful information. In contrast, results from sampling at the discharge point
of a source that always exhibits high indicator density would likely be less instructive.

4.3.2.1.5 Sample Depth
Taking a sample in an area parallel to the shore where the water depth is approximately knee
deep or greater appears to offer some advantages. Indicator density tends to vary less in deeper
waters than in shallower zones (USEPA 2005). The indicator density in shallower water is higher
than that in deeper areas because of the re-suspension of indicator organisms growing or
sheltered in sediments. Re-suspended indicators might not indicate fresh fecal pollution, and
therefore samples with a high number of re-suspended organisms might not provide a good
means to assess water quality. Other considerations, such as a steep beach face or safety
concerns, can also play a role in selecting the appropriate sample depth zone.

EPA's general recommendation for all beaches has been that samples be taken at knee depth.
However, local  conditions will dictate the sampling depth selected for a beach. For instance, in
high-energy environments, sampling is often conducted at ankle depth because it is safer and
easier for the sampler. In California marine waters, for example, samples are taken at ankle depth
in part to protect the safety of the sampler from the threat posed by incoming waves. In more
quiescent waters, sampling can be conducted at up to waist depth. The data analysis conducted
for the 2012 RWQC was based on the pooling of data from shin depth to waist depth (0.3-1.0
meter) (Wade et al. 2010), which corresponds to the sampling depth in the NEEAR study, which
was found to have high correlation with risk. The 2012 RWQC STVs and BAVs are based on the
90th and 75th percentile, respectively, in shin- to waist-deep water.

qPCR results in shin-deep water were over 40 percent higher than those in waist-deep water (93
versus 65 qPCR-CCE (calibrator cell equivalents)/100 mL, respectively) among NEEAR Great
Lakes beaches (Wade et al. 2008). Differences were consistent throughout the day at Great Lakes
beaches (unpublished EPA data). Differences between waist and shin depths were greater among
marine beaches (320 versus 190 CCE) and tended to be greatest in the morning (unpublished
EPA data).

The most important aspect of sample depth is consistency from sampling event to sampling event
(Wymer 2007).  Sampling at the same depth ensures the consistent representativeness of the
sample. Therefore, EPA encourages states, tribes, and localities to sample at the same depth at a
given beach to ensure consistency and comparability between sampling events.
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The depth for the sample container (i.e., distance below the water surface) appears to be less
critical than the depth zone (e.g., knee depth) where sampling is conducted (Le Fevre and Lewis
2003). The depth below the water surface, however, should also be consistent. At waist to knee
depth, this should be 0.5 to 1.0 foot below the water surface. At any depth more shallow than knee
depth, mid-water column would be appropriate while avoiding introducing sand or sediment into
the sample. A sampling depth of 0.3 meter below surface represents water to which swimmers
receive maximum exposure with their faces under water. This was also the sampling depth used in
NEEAR and other studies to establish risk relationships. However, variation in qPCR densities
with respect to depth of sample collection has not been studied. An EMPACT (Environmental
Monitoring for Public Access and Community Tracking) study (Wymer 2007) saw no consistent
difference in colony forming units versus depth for culture methods.

4.3.2.2 Sample Collection Techniques
Although EPA has no requirements for sample collection, adherence to specific, state-defined
procedures for sampling is critically important for a successful beach monitoring program. This
can be accomplished by implementing a detailed plan or written SOP for obtaining samples and
submitting them for analysis. Proper collection, preservation, and storage of water samples are
critical to ensuring the accuracy of the results of water quality analyses for FIB at swimming
beaches, and to satisfy the  QA/QC requirements of state certification programs. Section 4.3.3.2
discusses the basic equipment and techniques that can be used to obtain water samples.
Appropriate sampling procedures should be determined for a beach monitoring program on the
basis of the sampling design, the availability of facilities and equipment, and how the samples
will be processed. In addition, it is important to use consistent procedures and take careful notes
in the field when collecting samples. Additional information about EPA-recommended SOPs for
sample collection, handling, and subsequent analysis  can be found in Standard Methods for the
Examination of Water and Wastewater (APHA 1998).

4.3.2.3 Sampling after an Exceedance
When a water quality sample exceeds a beach notification threshold, a state must promptly issue
a beach notification  or resample if there is reason to doubt the accuracy, certainty,  or
representativeness of the first sample. This applies whether the method used to determine the
exceedance was culture-based or qPCR-based.
   •   If a sample result is determined to be accurate and representative and exceeds a beach
       notification threshold, the state agency must issue a beach notification. The notification
       should remain in effect until resampling indicates that the beach notification threshold is
       no longer being exceeded and approved QA/QC requirements are being met. When the
       beach notification threshold is no longer being exceeded, the basic sampling approach
       may be resumed. If in the meantime heavy rainfall or other pollution events have
       occurred as listed below, refer to guidance for that instance.
   •   If there is reason to doubt the accuracy, certainty, or representativeness of the first sample
       collected, based on  QA/QC measures, resampling should be considered. This might be the
       case if sampling results at the beach have shown that, historically, water quality has
       consistently met acceptable beach water quality thresholds and no known or potential
       sources of fecal contamination affect beach water quality. EPA recommends that additional
       samples be taken as soon as possible if the first sample exceeds water quality thresholds.

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If possible, the resampling should be completed immediately after detection of a beach
notification threshold exceedance. If culture methods are used, the results should be obtained as
expeditiously as sample collection and analysis can occur after the routine monitoring results
indicate an exceedance. If qPCR is used, resampling results could be available later the same
day. If the second sample indicates that a water quality threshold has been exceeded, the state or
local government must promptly notify the public.

Chapter 5 discusses notification procedures (beach advisories, postings, and closings) in more
detail. BEACH Act grant QAPPs typically describe state training plans.

4.3.2.3.1  After a Sewage Spill or Pollution Event
For all beaches, EPA recommends sampling immediately after a sewage spill or other significant
pollution event for which FIB densities might be expected to exceed standards. EPA also
strongly recommends that beach managers consider a preemptive beach closure (with or without
confirmatory sampling) when there is suspicion of a sewage spill or major leak. Chapter 5
discusses beach closures in more detail. Beach or program managers should complete additional
sampling of closed beaches to ensure mitigation of the  spill before reopening the beaches.

4.3.2.3.2  After an Advisory or Closing
After an exceedance, additional sampling should be conducted to determine whether a beach
notification can be lifted.  Because an advisory imposed on the basis of sampling results should
not be lifted without subsequent sample results showing that the applicable WQS have been met,
prompt resampling is preferable to waiting until receipt of the next routine sampling results.
Beach advisories issued on the basis of the output of a predictive model can be lifted if the output
from an additional  model run estimates that water quality conditions have improved to within
acceptable parameters or, alternatively, that the results  of a water quality sample indicate that
indicator densities once again meet the applicable standard. Section 5.2.1.2 discusses preemptive
advisories in more  detail.

4.3.2.3.3  After a Heavy Rainfall Event
EPA recommends that managers develop and follow a  protocol for a variety of rain events and
consider such protocols at all recreational beaches. Many states, tribes, and local governments
have protocols in place. At beaches with stream and storm drain discharges, previous sampling
has established that water quality is often poor after a substantial rain, justifying a preemptive
advisory without confirmatory sampling results. A beach or program manager should consider
local circumstances and evaluate whether additional monitoring or a formal protocol for
preemptive beach notification advisories is appropriate.

4.3.2.3.4  Other Circumstances
When routine monitoring at a sample location indicates elevated FIB densities, additional
sampling can be done to determine the extent of the water quality problem. Defining the extent
of the poor water quality more effectively protects public health and might provide valuable
information for source identification and mitigation.
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4.3.3  Administering a Monitoring Program

4.3.3.1 Staffing Monitoring Programs
A monitoring plan should include an adequate staffing plan that accommodates periods of peak
beach use. EPA recommends that professional staff from state and local agencies maintain
primary responsibility for the design and oversight of beach monitoring. Citizen volunteers can
also be used to perform supplemental beach monitoring program functions. For example,
volunteers can be used to provide more intensive monitoring at high-priority beaches or to help
with monitoring at low-priority beach areas where regular staff might not be available.
Additional information on volunteer monitoring programs is available on  EPA's website at
http://water.epa. gov/type/rsl/monitoring/index. cfm.

Once the monitoring plan has been developed, the staff who will implement the program should
receive training. Whether drawn from the ranks of professional staff, other municipal employees,
or volunteers, the personnel responsible for sample collection and environmental measurements
at the beach and 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 done by field and laboratory staff. Separate training programs should be developed
for field staff, laboratory staff, and others involved in the monitoring program. Laboratory
training and analyst qualifications are generally evaluated as part of a laboratory accreditation
program. The training for field staff should include a review of applicable SOPs,  sampling
locations, sampling equipment and containers, field forms and labels to be completed on-site
(e.g., chain-of-custody forms,  sample collection forms, sample labels), sample preservation
information, personal protection equipment, coordination with the analytical laboratory, and
important contact information. Follow-up training should continue for as long as the monitoring
program is active. QAPPs should describe the content of training plans in BEACH Act grant
QAPPs.

Early in each swimming season, it is advisable to conduct procedural reviews with each field
sampling crew.  Such reviews afford program  oversight staff an opportunity to observe the
techniques and procedures being used to collect samples, provide any necessary clarification, and
immediately address any departures from program requirements. Reviews also evaluate whether
program procedures are applicable to potentially changing conditions, and they offer an
opportunity to solicit field staff opinions regarding procedure refinements or enhancements that
could continue to improve the quality of the data.

4.3.3.2 Field Sample Collection Methods
The monitoring plan should also include the following elements on field sample collection
methods:
    •   Selecting sampling locations (e.g., maps, names of sampling locations).  The beach
       manager should survey the site to become familiar with its physical and hydrologic
       features, in addition to or as part of a sanitary survey. The reconnaissance site visits
       should include collecting the following information:
       -  Most convenient and safest point of access to the site.
       -  Potential sampling locations.


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       -  Necessary equipment.
       -  Directions to sampling locations relative to access point.
       -  Justification for the selection of each sampling location.
       -  Other information necessary for preparing for sampling at a site (e.g., health and
          safety requirements).
    •   Chain-of-custody forms, field forms, bottle labels. A sampler should record a detailed
       description of each sample collected and record it on  a chain-of-custody form. The form
       should document the sampling location (site ID), time of collection, date of collection,
       collector's name and signature, agency, laboratory to which the samples were delivered
       or sent, and other notes or comments. Field sampling staff should document on a field
       form basic on-site measurements and observations, such as weather conditions, general
       characteristics about the water, time of sample collection, name of sampler, and number
       of sample bottles filled. A field log (notebook) can also be used to record observations
       and notes not recorded on the field forms.
       A sample identification label (to be placed on the sample container) should be completed
       to accompany each sample throughout the chain of custody. The label should document
       the information for each sample, including sampling trip number, sample number, analyte
       for analysis, and date of sample. All entries should be made in indelible ink and coincide
       with sample information on  the field form and chain-of-custody form.
    •   Equipment, sample container needs. Sampling for recent EPA epidemiological studies
       was conducted consistent with recommendations on microbiological sampling in
       Standard Methods for the Examination of Water and Wastewater (Clesceri et al.  1998).
       Those studies used capped 1,000-mL, pre-sterilized polypropylene bottles for sample
       collection. EPA, in its Microbiological Methods for Monitoring the Environment, Water
       and Wastes (USEPA 1978),  suggests wide-mouth borosilicate glass bottles with screw
       caps or ground-glass  stoppers; however, glass bottles can break, causing loss of the
       sample. Polysulfone (Nalgene) containers of appropriate size are also used. Heat-resistant
       polypropylene bottles may be used if they can be sterilized without producing toxic
       materials when autoclaved, or pre-sterilized disposable containers may be employed.
       Sufficient coolers and ice should be available to place samples promptly on ice for
       transport to the laboratory. Other equipment needs will vary according to local sampling
       practices and/or state protocols.
    •   For qPCR use, pre-sterilized, single-service plastic containers are optimal because of the
       potential for DNA fragments to persist after sterilization. Otherwise, if used, reusable
       containers should be constructed of polysulfone or other similar plastic material, soaked
       in 5 percent bleach solution, and then rinsed with distilled water before each use.
    •   Health and safety concerns. Any field team member who participates in sample
       collection at the beach should know how to swim. Sample collection should be postponed
       if conditions are  dangerous (e.g., bad weather, rough water).
    •   Laboratory availability and scheduling of sample deliveries. Samples are usually
       transported to the laboratory by the person collecting the sample or picked up by
       laboratory personnel. Because of holding time limitations, the laboratory should be
       conveniently near the sampling site and notified a few days before the sampling effort so
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       that it is prepared to process the samples promptly. Chain-of-custody procedures should
       be followed at the laboratory for all samples.
   •   Communication with the lab.  Open communication and collaboration with your
       laboratory service provider will greatly benefit your monitoring program. Laboratories
       work with a variety of clients from various backgrounds and with different levels of
       experience. Laboratories also routinely provide sampling kits (bottleware, labels, and
       custody records), assist in training sampling staff, and provide additional sampling
       instructions or responses to frequently asked questions about their bottleware. When
       selecting a laboratory, if multiple laboratory service providers are available in the vicinity
       of the beach, consider value-added services. In addition to the services above, many
       laboratories offer courier services to drop off supplies and pick up samples, and some
       provide preprinted chain-of-custody forms and bottle labels that require only the
       samplers' initials and the date  and time of sample collection.

4.3.3.3 Managing Data
One of the most important aspects of a monitoring program is data management, from the
collection process through the data analysis. Data management activities include documenting
the nature of the data and subsequent analyses so that the data from different sites are
comparable. Data management also includes handling and storing both hard copies and
electronic files containing field and laboratory data. It is important to understand and comply
with all state agency policies and standards regarding data collection and generation.

The operation of the data management system should include QA oversight and QC procedures.
If changes in hardware or software become necessary, the data 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. Developing spreadsheet, database, and other software applications involves
performing QC reviews of input data to ensure the validity of computed data.

EPA requires beach managers to add their monitoring data to the Agency's STORage and
RETrieval (STORET) database at http://www.epa.gov/storet/wqx/index.html. Each sampling
result in STORET is accompanied by  information describing where the sample was taken
(latitude, longitude, state, county, hydrologic unit code, and brief site identification); when  the
sample was gathered; the medium sampled; and the name of the organization that sponsored the
monitoring. Additional information on STORET is available at http://www.epa.gov/storet.

States, tribes, and local governments can submit their data using a database provided by the
beach program, create a state or local  STORET database, or create an alternative data system.
The beach program's monitoring database can be accessed at
http://water.epa.gov/grants funding/beachgrants/datausers  index.cfm#monitor. These databases
submit monitoring data to EPA's Water Quality eXchange (WQX), which accumulates data that
are copied into the STORET repository on a weekly cycle.  Staff working with the database
should have expertise and training in the software and in the procedures for data transport, file
transfer, and system maintenance.
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4.3.3.4  Program Implementation and Oversight
States and tribes should regularly assess the effectiveness of their monitoring programs. The
purpose of assessments (such as surveillance, readiness reviews, technical system 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 that might 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. Such proficiency is needed whether in the field
performing the sampling or in the laboratory performing the microbiological analyses.

4.3.3.5  Public Comment
Public review of the monitoring plan is part of the overall public review and comment criterion
described in section 2.2.11 (performance criterion 11). States or local governments must submit
documentation of the public review to EPA.

4.4  Methods and Assessment Procedures (Performance Criterion 3)

Performance criterion 3 requires the states and tribes to document methods and assessment
procedures. States and tribes must:
   •   Submit to EPA methods for characterizing water quality relative to human  health in
       coastal recreation areas.
   •   Provide documentation of the performance of methods other than those that EPA
       approved or validated.
   •   Identify and submit to EPA assessment procedures for identifying short-term increases in
       FIB densities that indicate risk to human health in coastal recreation waters.

4.4.1  EPA-Approved or Validated Analytical Methods
EPA recommends a number of analytical methods for use in testing recreational waters. These
are methods that EPA has approved and codified at 40 CFR part 136 or validated in single- or
multi-lab validation studies.  These methods, with their associated indicators, are used to
determine whether the water quality at a beach exceeds or is likely to exceed the applicable
WQS. EPA has established relationships through  epidemiological studies between FIB density in
the water and levels of illness.
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 Sections 4.4.1.1 and 4.4.1.2 discuss EPA's approved culture and validated qPCR methods.
 Section 4.4.2 provides information on selecting the appropriate analytical method—culture
 (4.4.2.1) or qPCR (4.4.2.2). Subsections of 4.4.2.2 discuss the analysis of site-specific
 performance that EPA encourages for qPCR methods.

 4.4.1.1 Culture Methods
 In July 2003 EPA promulgated testing procedures in Guidelines Establishing Test Procedures
for the Analysis of Pollutants; Analytical Methods for Biological Pollutants in Ambient Water;
 Final Rule (Office of the Federal Register 2003). The 2003 rule revises 40 CFR part 136 to add
 analytical methods for Escherichia coli, enterococci, Cryptosporidium, and Giardia in ambient
 waters. It includes methods published in the Official Methods of Analysis of AOAC International
 (AOAC International 1995), the 20th edition of Standard Methods for the Examination of Water
 and Wastewater (APHA 1998), and the 2000 edition of the Annual Book of ASTM Standards
 (volumes  11.01 and 11.02; ASTM 2000). It also includes methods developed by EPA and
 commercial vendors, including Hach Company,  IDEXX Laboratories, and others. This ruling
 was updated in a final ruling in March 2012, which provided updated versions of EPA methods
 (see FR [FederalRegister] 77(97):29758).

 For beach testing, EPA recommends that states and tribes use the EPA-recommended culture
 methods mentioned above. The methods identified at 40 CFR part 136 are also acceptable. States
 and tribes that want to use culture methods other than the currently approved methods at 40 CFR
 part 136 must go through EPA's Alternate Test Procedure (ATP) program, which requires
 submission of their method, along with validation data, to EPA. To meet performance criterion 3,
 documentation supporting the validity of methods other than those EPA has approved must be
 provided.  Detailed descriptions of culture methods are included in
 http://water.epa.gov/scitech/methods/cwa/methods index.cfm.  Vendor method descriptions can
 be obtained from the various vendor websites (see FR 77(97):29758 for details).

 4.4.1.2 qPCR Methods
 EPA Methods 1611 (USEPA 2012a) and 1609 are EPA-validated qPCR Enterococcus spp.
 methods (see http://water.epa.gov/scitech/methods/cwa/bioindicators/upload/Method-1611-
 Enterococci-in-Water-bv-TaqMan-Ouantitative-Polymerase-Chain-Reaction-qPCR-Assav.pdf).
 Method 1609 has internal amplification control (IAC). EPA expects to validate qPCR methods
 for E. coli and Bacteroidales in the near future. Because at present only culture methods are
 included at 40 CFR part 136 as approved methods, the ATP protocol may not be used to qualify
 these qPCR methods for adoption into state or tribal WQS or for use in beach monitoring.
 Consistent with the 2012 RWQC, EPA encourages states and tribes that want to use EPA-
 validated qPCR methods to conduct a site-specific analysis of the method's performance before
 use in a beach notification program or adoption of WQS based on the method. Documentation of
 the site-specific analysis has two parts: method performance (4.4.2.3.1) and site-specific
 acceptability (4.4.2.3.2). In addition, section 4.4.2.3.3 discusses logistical and other practical
 considerations for implementing a qPCR method.
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4.4.2  Selection of Analytical Methods: Culture versus qPCR

4.4.2.1 Culture Methods
Analyzing water samples for the enumeration of FIB by culture methods such as membrane
filtration, multiple-tube fermentation, or defined substrate technology has been the standard for
decades. Although refined, the culture methods in use today still require bacterial growth in
specific selective media for quantification. Culture methods require at least 18 to 48 hours to
produce results, with the densities of the target organism reported in colony-forming units  (CPU)
or most probable number (MPN) per 100 mL. Previous research (e.g., Boehm 2007; Griffith et
al. 2007; Noble et al. 2003; Taggart et al. 1992)  has shown that FIB density exhibits a high
degree of methodological and temporal variability. Culture results, nevertheless, are economical
and reproducible, and they can serve as a source of information for managing waters and
developing predictive models (section 4.5) to provide timely estimates of FIB density.

Culture results are also effective in characterizing long-term water quality and variability at
beaches. If, over the course of a season, weekly  water quality monitoring fails to identify any
occasions when the WQS were exceeded, it can be assumed that water quality is generally good.
That can be expressed numerically by calculating a GM of the results or, more simply, by
reviewing the number of exceedances or viewing data displayed graphically.  Such results might
suggest a reduced monitoring frequency at that location. Conversely, if weekly culture results
produce a range of values including WQS exceedances, the results would indicate that sources of
contamination exist, that the water quality is variable, and that conducting more intensive
monitoring—or using a predictive model or qPCR analytical methods for more timely public
notification—might be appropriate for the site.

4.4.2.2 qPCR Methods
Determining water quality by quantifying the DNA of FIB is a well-established methodology
(e.g., Haugland et al. 2005, Noble et al. 2010). Unlike culture-based methods, qPCR methods
quantify all forms of FIB, whether viable cells, injured cells not capable of growing on selective
culture media, dead  cells, or fragments of free DNA. The premise is that like the viable cells, the
molecular material indicates the presence of fecal material from humans or other vertebrates and
an associated risk of illness, likely from human enteric viruses also found in sewage and
wastewater treatment plant effluent (Colford et al. 2012; Wade et al. 2008). Results of the
epidemiological  studies conducted for the 2012 RWQC demonstrated a significant association
between gastrointestinal illness in swimmers and both culture and qPCR enumeration methods
for Enterococcus; the association observed with qPCR enumeration was the stronger of the two.

The 2012 RWQC discuss using EPA's qPCREnterococcus spp. method (Method 1611) as a tool
for beach management and potential inclusion in WQS. The primary  advantage of qPCR
methods compared to culture methods is that analytical results can be available in as few as three
hours after  receipt of the sample in the lab. This means that the qPCR results are much more
likely to reflect water quality on the day when recreators are exposed to the water that was
sampled. However, using a qPCR method might pose challenges for the beach or program
manager, including method performance, site-specific acceptability, and practical considerations.
Before deciding to use qPCR methods at local beaches, a beach manager should assess the
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acceptability and feasibility of applying qPCR methods in light of these potential challenges.
Section 4.4.2.3 discusses this in more detail.

4.4.2.3  Assessing the Use of qPCR on a Site-specific Basis
A primary message of this document is that beach and program managers should develop tiered
monitoring plans that reflect beach-specific use and risk. The decision whether to use qPCR-
based methods will require weighing the potential advantages of more timely public notification
against the site-specific characteristics of the beach and resource and logistical constraints. This
analysis will help a beach or program manager determine whether using a qPCR-based method is
feasible for local waters before investing in capital equipment and ancillary supplies, repurposing
lab space, and providing the method-specific staff training required to implement qPCR for
beach water quality analyses.

The 2012 RWQC recommend criteria for Enterococcus or E. coll as measured by culture
methods. Although the 2012 RWQC recognize the value of qPCR for beach monitoring, the
RWQC only provided supplementary information on qPCR and did not base EPA's national
RWQC recommendation on it given EPA's limited knowledge regarding the performance of
qPCR methods under varied water body conditions. EPA encourages state and tribal beach
programs that want to use qPCR as a method for beach monitoring to conduct a site-specific
analysis of the method's performance and to assess the method's site-specific acceptability
before using it in a beach notification program or adopting WQS based on the method. These
two assessments are described below.

4.4.2.3.1 Assessing Site-specific Method Performance
States and tribes undertake beach water quality sampling to identify WQS exceedances to issue
beach advisories or closures. As discussed in the 2012 RWQC,  the state of knowledge regarding
the performance of qPCR methods under varied water body conditions is limited. EPA Methods
1611 (USEPA 2012a) and 1609 (USEPA 2013b) are two EPA-validated qPCR enterococci
methods. Method 1611 was released simultaneously with the RWQC.  Method 1609 is an
improved version of Method 1611.  It uses a newer formulation  of PCR reagent (environmental
master mix) that has shown enhanced inhibition control compared to the reagent used in Method
1611 (universal master mix). In addition, Method  1609 includes a competitive IAC assay (i.e., a
control for inhibition) to help specifically identify false  negative reactions (i.e., test results that
wrongly show an effect to be absent) or reduced amplification efficiency due to Taq DNA
polymerase inhibition (Haughland et al. 2012). Although either method is acceptable for use,
EPA recommends using Method 1609 because of these  enhancements.

Both Method 1611 and Method 1609 quantify the number of copies of Enterococcus DNA in
surface water. For states and tribes interested in using either method to make site-specific beach
notification decisions, the 2012 RWQC provide qPCR-based beach notification thresholds. If
local beach managers are considering using EPA Method 1611  or 1609, the method
documentation (USEPA 2012a; USEPA 2013b) provides information on identifying method
limitations in specific waters, such as interference, and procedures for correcting method
problems.
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The performance acceptability criteria of EPA Method 1609 or 1611 are stated in the method
document. The acceptability criteria are based on a nationwide validation of the method (see
section 14 in Methods 1609 and 1611). The method document assumes that the testing laboratory
has been able to perform the method within the acceptance criteria and that the beach or program
manager wants to determine whether the method would be acceptable for use at a particular site.

4.4.2.3.2 Assessing Site-specific Acceptability
The analysis for site-specific acceptability of qPCR analysis should include the following
elements, which are more fully described in Acceptability of the EPA qPCR Test at Your Beach
(USEPA2013a):
    •   At least 10 samples should be taken on different days for site evaluation before using the
       method for beach notification decisions. Sampling for a longer period, however, will
       provide data that are more representative. Among these samples, a maximum of 10
       percent can fail the Salmon DNA sample processing control (SPC) assay criterion (see
       section 9.12 in Method 1611)  or the SPC and IAC assay criteria (see sections 9.12 and
       9.13 in Method 1609). For any samples that fail the initial analysis, one or both of the
       interference mitigation approaches—extract dilution (see section 9.12 in Methods 1609
       and 1611) or higher Salmon DNA (see reference 17.5 in Method 1609)—can be used to
       assess for mitigation of the interference. If mitigation by one of these approaches is
       successful (i.e., samples now pass the control assay criteria specified above), these
       samples can be considered as not having failed in the site evaluation.
    •   Particularly if beach advisories or closures are not mandated by local standards after a
       heavy rain event, site evaluation sampling should include a representative number of
       samples collected after such events.
    •   Sites should be reevaluated every year, preferably before using the method for beach
       action decisions, because water characteristics, including the appearance and
       disappearance  of inhibitors to the method, have been shown to change over time.

Some localities might be inclined to compare the frequency of beach advisories based on the
qPCR test versus the culture test. EPA neither encourages nor discourages such comparisons;
however, if used, the results should be interpreted carefully. Comparisons between exceedances
do not reflect their respective method performance when all the controls in the methods are
performing properly. In addition, a higher rate of exceedances does not necessarily reflect greater
health protection when evaluating qPCR and culture approaches because such comparisons do
not take into account the relative severity of the total health risks on the days of exceedance.  In
all cases, however, the same-day notification potential for qPCR more accurately reflects water
quality for beachgoers compared with methods where results are not available until the following
day.

4.4.2.3.3  Logistical and Other Practical Considerations
Although the results from qPCR sampling can be obtained in a few hours, a number of factors
can affect a state's or tribe's ability to deliver same-day notification. Besides having a laboratory
that is close enough to the beach to allow samples to be quickly transported, prepared, and
analyzed, beach or program managers should consider cost, configuring laboratory facilities for
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                                       Chapter 4
qPCR use, choosing an appropriate
instrument, providing adequate staff
training, selecting reagents and controls,
and documenting QA/QC protocols.

The Southern California Coastal Water
Research Project (SCCWRP) conducted a
pilot study in which the participating
jurisdictions used qPCR to make health
protection decisions at nine beaches in
Orange County (Griffith and Weisberg
2011). The authors determined on the
basis  of the study results that cost and
temporal logistics are the biggest
challenges to initial use of rapid methods,
and that would likely limit qPCR initially
to heavily used beaches or those with
highly variable water quality. They also
found that to post notifications by noon,
they needed to modify every step in the
process, from sample collection to posting
advisories. See the text box for more
details.
Southern California Coastal Water Research
Project (SCCWRP) Pilot Study
During their pilot study, SCCWRP found they had to
modify every step—from sampling to posting
signs—to provide notifications by noon. The
modifications included:
 •  Sample collection routine.
    -  Started sampling earlier in the morning.
    -  Limited sites sampled to high-priority
       beaches (i.e., heavily used or with highly
       variable water quality).
    -  Used a  second crew for qPCR sites.
 •  Laboratory procedures.
    -  Used a  faster method (i.e., one with a
       shorter cycling time).
    -  Did not use a DNA extraction kit with
       multiple pipetting steps.
    -  Completed all preparation steps before
       samples arrived at the lab.
 •  Communication with the beach manager.
    -  Automated the data analysis and QA using
       Excel macros.
    -  Used electronic signs that could be
       controlled remotely.
4.4.3  Using Other Methods or Indicators for Developing Site-specific WQS
Previous sections of this document discuss using EPA-approved culture methods or validated
qPCR methods for assessing water quality at recreational beaches. Relationships have been
established through epidemiological studies between the density of FIB in the water measured by
these methods and levels of illness. There are three scenarios states and tribes might present; they
are discussed briefly below.
    •  The state or tribe wants to use a method that is not EPA-approved or validated but has
       a predictable and consistent relationship with an approved or validated EPA method.
       The state or tribe should consult Site-Specific Alternative Criteria Technical Support
       Materials for Alternative Indicators and Methods (in press-c). In this case, the
       relationship between the alternative method and the EPA method can be correlated with
       the illness rates associated with the EPA method and used to establish site-specific
       alternative water quality criteria to be adopted into site-specific WQS based on the
       alternative method.

    •  The state or tribe wants to use an approved and validated EPA method and wants to
       account for local-scale, non-human sources of fecal contamination. The health studies
       that substantially informed EPA's 2012 RWQC recommendations were conducted at
       beaches contaminated by secondary treated and disinfected wastewater effluent. Beaches
       affected by other fecal sources could pose different, potentially much lower, human
       health risks at the same level of water quality recommended in the  2012 RWQC. In this
       instance, a state or tribe would use QMRA to estimate the human health risks posed by
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       the pathogens coming from the specific sources of fecal contamination affecting a site
       and to calculate site-specific water quality criteria that would provide a level of public
       health protection equivalent to the health goals discussed in the 2012 RWQC. Once
       adopted into site-specific WQS, these criteria would provide a basis for identifying beach
       notification thresholds. States and tribes wishing to establish site-specific water quality
       criteria accounting for nonhuman sources of fecal contamination should  consult Site-
       Specific Alternative Criteria Technical Support Materials for Alternative Fecal Sources
       (USEPA in press-b).
    •   The state or tribe wants to use a method that does not have a predictable and consistent
       relationship with an approved or validated EPA method but is demonstrated to be
       associated with health. In this instance, the state or tribe would establish a site-specific
       health relationship between the indicator and human health effects at the site by
       performing a scientifically defensible epidemiological study and/or QMRA at the site.
       The documented association between the indicator  and health would serve as the basis for
       site-specific criteria to be adopted into site-specific WQS. These WQS would provide a
       basis for identifying beach notification thresholds in the waters where the relationship
       was established. States and tribes wishing to establish a site-specific health/indicator
       relationship should consult Alternative Health Relationships Technical Support Materials
       (USEPA in press-a).

4.5  Monitoring Report Submission (Performance Criterion 4)

The fourth performance criterion requires development of mechanisms to collect relevant
monitoring information, provide timely communication of water quality to the public, and submit
reports to EPA.

States and tribes must report their monitoring data to the public in a timely manner, including
posting the data on a publicly available website. A publicly available website is  one that:
    •   Has its address included on grantee websites and in published materials (e.g., news
       releases, advisories, beach program documents) as a source of additional information
       about the state's or tribe's beach program.
    •   May be a dedicated beach water quality website or  a general state or tribal news website.
    •   Is reliably operational, at least during the beach season.
    •   Does not require access credentials.

Posting all monitoring data to EPA's STORET would also meet the requirement for a publicly
available website. If a state or tribe uses STORET as its "publicly available website," related
state or tribal websites must include a link to STORET and an explanation of the type of data
posted.

In this context, "timely" means posting monitoring data associated with an exceedance
concurrently with or shortly after the issuance of a notification action. States and tribes must
report all other monitoring data to EPA's STORET and to their publicly available website, if not
STORET, at least annually or at a frequency the EPA Administrator requires. Reported
monitoring data must be consistent with section 4.3.3.3.


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4.5.1  Data Validation and Verification Recommendations
EPA recommends that managers use procedures to verify whether the microbiological sample
collection and analyses have correctly estimated the densities of indicator bacteria, to ascertain
whether 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 such procedures. These should be included in the monitoring program design to ensure
that the data obtained are usable and defensible. Several iterations through these procedures
might be necessary to ensure that the data and their interpretation are correct.

4.5.1.1  Data Validation Methods
Single laboratory validation refers to the confirmation that data quality objectives (DQOs) for a
specified intended use have been fulfilled. Thus, once beach or program managers have
confirmed that the data meet standards and contract requirements, they can systematically
examine the data to determine the technical usability with respect to the planned objectives. This
activity can also provide a level of overall confidence in reporting the data on the basis of the
methods used. For example, if the wrong medium was used or  the incubation temperature limit
was exceeded, managers would assign a qualifier to the data indicating their uncertainty and
reject the data from further analyses. The managers should then prepare 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. 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, managers should assess the data to evaluate whether they are of the right type, quality,
and quantity to support their intended use. The assessment could include 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.

4.5.1.2  Data Verification Methods
The laboratory service provider should provide the procedures  for verifying whether the bacterial
indicators were correctly determined 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 (USEPA 2009a) and 1603 (USEPA 2009b)  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.

The laboratory service provider should review the sample records, chain-of-custody records, and
sample tracking records to verify that all the samples collected  were analyzed so that the data set


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will be complete. It should also verify data entries and analyses and, for large quantities of data,
perform spot-checking to detect potential data entry errors. Additional checks could 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 should be reviewed for
accuracy, bias, completeness, precision, representativeness, and uncertainty. In addition, the data
reductions and transformations should be reviewed (audited) to ensure that they have been
correctly performed. The calculation review could include 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 there are no transcription errors. The EPA methods
provide the types of calculations that might be performed on bacterial indicator filter counts to
estimate bacterial densities per sample. Standard Operating Procedure for Recreational Water
Collection and Analysis ofE. coli in Streams, Rivers, Lakes and Wastewater (IITF  1999)
provides more examples.

Beach program managers should obtain a report from the laboratory service provider
documenting the results of the data verification. To verify conformance  of the data collection
effort with the plan, data should pass the specified numerical QC tests (precision and bias limits);
the plans should be followed and calculations should be performed correctly; all samples should
be treated consistently; and the necessary quantity of data and information relative to the stated
DQOs should be obtained (completeness). Staff should address data concerns, if possible, or
managers should reject the data and not use them to make the decision.

4.6 Use of Predictive Tools in Beach Monitoring Programs

EPA encourages states and tribes to use predictive tools to make timely beach notification
decisions and to deliver same-day notifications. Although using qPCR can provide results sooner
than using culture methods, qPCR might not be a viable option for all settings. To reduce
exposure to pathogens, agencies operating beach monitoring and notification programs need
tools that can provide a quick, reliable indication of the water quality conditions. Predictive
models and other predictive tools are another means to provide rapid estimates. These tools are
used to supplement, not replace, monitoring; they provide timely estimates when a lag time
exists between performing sampling and obtaining results.

Predictive tools might also be useful in developing or adapting routine monitoring programs to
focus efforts when conditions favor high FIB  levels. The predictive tools examined in Predictive
Tools for Beach Notification, volume 1 (USEPA  201 Ob) include statistical models,  rain threshold
levels, notification protocols, and deterministic models. Information from that report is briefly
summarized below. The report is available on EPA's website at
http://water.epa.gov/scitech/swguidance/standards/criteria/health/recreation/upload/P26-Report-
Volume-I-Final 508.pdf.
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Significant development and implementation
of statistically based models have occurred
recently, especially in the Great Lakes (Lake
Erie and Lake Michigan), where many
predictive tools were proven reliable and
cost-effective (Francy 2009; Nevers and
Whitman 2005). EPA believes such
predictive tools could be applicable in many
other settings as well, including marine and
inland beaches. These tools develop
statistical relationships or models between
FIB densities (dependent variables) and
various observations that describe the
environmental conditions at the beach
(independent variables). The models use
recent and historical FIB densities and
independent variables that include other
water quality, hydrodynamic, and
meteorological data to predict current FIB
levels and to forecast near-future FIB levels
or the likelihood of exceeding a WQS.
Statistical models and other predictive tools
can be run as frequently as data are available
for measured independent variables and as
long as models are producing reliable
predictions that protect public health.

Rainfall-based beach notifications have been
widely used at marine and freshwater
beaches for decades. Rainfall-based beach
notification thresholds are issued at some
beaches on the basis of an analysis of
historical data. At such beaches, it has been
shown that after a certain amount of rainfall, a beach is likely to have high FIB densities
(USEPA 1999).  Similar notification protocols could be developed in which a certain
combination of conditions has been shown to result in high FIB levels.

Information on these and other types of predictive tools is provided below.

4.6.1  Statistical Models
Statistical model is a general term for any type of statistical modeling approach that predicts or
forecasts beach water quality. Statistical models are also called statistically based models and
include most predictive models currently in use. Linear regression models assume a linear
relationship between factors, or combinations of factors, and FIB densities (Boehm et al. 2007;
Nevers and Whitman 2005; Olyphant and Whitman 2004; USEPA 2007). The most highly
developed and currently used statistical modeling approaches for beach water quality
 Chicago's Modeling Project
 The Chicago Park District (CPD) has developed
 predictive models for water quality to provide
 more current and accurate information to the
 public.
 CPD selected five public beaches in Chicago for
 modeling, from the largest in size (Montrose
 Beach) to one of the city's most popular (Oak
 Street Beach).
 All the beaches are primarily affected by
 nonpoint sources and have a history of between
 8 and 15 percent exceedance rates (percent of
 days when the mean of two samples exceeds
 235 CPU E.  coli per 100 ml of water).
 USGS helped CPD develop empirical models
 using multivariate regression. They modeled
 E. coli levels using results from both the current
 culture-based method and a qPCR-based
 method.
 CPD initially anticipated the need for two years
 of data to have working models developed
 because results depend strongly on the weather.
 The Chicago area has very different beach
 seasons from year to year; therefore, a larger
 data set would help improve the model's
 accuracy.
 CPD began  using the  model in 2012 to make
 management decisions about notification
 actions. They monitor all beaches every
 weekday. CPD runs the models at 9:00 a.m. and
 issues advisories by 9:30 a.m. If the model
 shows no exceedance, CPD posts a green flag;
 however, the public can view both model results
 and sampling values by visiting the beach,
 viewing the website, or calling a hotline.
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management are multivariable linear regression models. These types of models couple
combinations of important independent variables to FIB densities. The most common model
outputs are estimated FIB levels or a probability of exceedance of the adopted state WQS for
FIB. Typical, easy-to-measure environmental and water quality variables that are predictive of
FIB density can include:
   •   Meteorological conditions (e.g., solar radiation, air temperature, precipitation, wind speed
       and direction, dew point).
   •   Water quality (turbidity, pH, conductivity/salinity, ultraviolet/visible spectra).
   •   Hydrodynamic conditions (freshwater discharge, magnitude and direction of water
       currents,  wave height, tidal stage).
   •   Other factors such as presence and number of birds or people.

Statistical models are especially useful at some beaches and less useful at others. According to
Francy (2006), statistically based modeling can effectively predict water quality in situations
where nonpoint or unidentified sources dominate and in settings where discrete sources have
been identified (Nevers and Whitman 2005). If a beach rarely has high bacteria densities or,
conversely, chronically exceeds a bacterial WQS, it is unlikely that a statistical predictive model
would significantly improve timely decision making and notification. If a beach occasionally
exceeds the WQS or if bacteria levels are highly variable, statistical models can help by
providing a timely prediction of whether FIB are likely to exceed the WQS according to
parameters that are easier and faster to measure than FIB densities.

Developing and using a statistical predictive model is a dynamic process based on data collected
from beach monitoring. Statistical modeling uses a retrospective correlation of measured water
quality (FIB levels) with conditions observed at the time of sample collection to produce a timely
estimate of water quality for recreational water management and use by the public. Model
developers can create Internet-based systems that provide model predictions (similar to weather
forecasts) to the public for the current period, as compared to other Internet-based systems that
alert the public to exposure that might have occurred a day or two earlier. However, models
require periodic validation and refinement to improve predictions.

EPA has developed a very effective tool for building freshwater statistical  models—Virtual
Beach. Virtual Beach is a versatile and user-friendly statistical tool that links past water quality
data to observed variables to produce real-time estimates of water quality at freshwater beaches
(USEPA 2010a). EPA is expanding Virtual Beach for marine beaches. Visit
http://www2.epa.gov/exposure-assessment-models/virtual-beach-vb for more information.

Although USGS, the National Oceanic and Atmospheric Administration (NOAA), and other
agencies and Internet sources are available to provide much of the data necessary for developing
multivariable linear regression models, many modeling efforts have been shown to be site-
specific. Therefore, beach water quality managers can expect to need to analyze their own
historical FIB data in relation to mined data from other agencies to develop models specific to
their own locations. To make this process simpler, there is a newly available version of Virtual
Beach, V.3.0.
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Other useful references for information on statistical models include Predictive Modeling at
Beaches, volume 2 (USEPA 2010a), Temporal Synchronization Analysis for Improving
Regression Modeling of Fecal Indicator Bacteria Levels (Cyterski et al. 2012), Partial Least
Squares for Efficient Models of Fecal Indicator Bacteria on Great Lakes Beaches (Brooks et al.
2013), and Application of Empirical Predictive Modeling Using Conventional and Alternative
Fecal Indicator Bacteria in Eastern North Carolina Waters (Gonzalez et al. 2012).

4.6.2  Rainfall-based Beach Notification Threshold
The objective of a rain threshold level is to identify the level of rainfall at which FIB levels are
likely to trigger a beach notification. That is achieved if a statistical relationship—a simple
regression or a frequency of exceedance analysis—between rainfall amount, intensity, and
duration and FIB densities can be observed or if a level of rainfall and rainfall conditions is
consistently shown to be associated with increased FIB densities. With that information, many
beach managers and public health officials commonly issue a preemptive rain threshold advisory
after a rain event of a predefined intensity or duration. Beachgoers are familiar with routine, wet-
weather closures in locations where they are implemented. The beach notification threshold can
then serve as a management tool for developing notification protocols or predicting WQS
exceedances that require a beach notification.

4.6.3  Notification Protocols
Notification protocols are based on a set of decision criteria that trigger beach notifications in
anticipation of poor water quality or other potentially hazardous conditions (e.g., rough waves,
strong rip currents, red tide). The protocol can rely on sampling results, other information, or
beach characteristics either alone or in addition to sampling results. Such evaluations  are
designed to supplement bacteria data with characteristics of the beach that can influence the
related bacteria levels (e.g., proximity to pollution sources,  stormwater runoff, current, or wind
direction).

4.6.4  Deterministic Models
Deterministic models use mathematical representations of the processes that affect FIB densities
to predict exceedances of WQS. They include a range of simple to complex modeling
techniques, such as fate and transport and hydrodynamic models. EPA believes that many
models developed for general purposes might have potential use for understanding beach
processes. However,  at this time, no specific examples of easy-to-implement deterministic
models exist (unlike with predictive statistical models). In contrast to the statistical models
described earlier, deterministic models typically require specialized knowledge and expertise for
successful implementation. It would likely be challenging for local beach managers to set up,
calibrate, and run certain types of deterministic models with sufficient reliability and validity to
protect public health.

In the future, beach managers and modeling practitioners might want to further develop
deterministic modeling tools to support beach monitoring and notification programs. Blending
the performance of multiple types of models, a process known as stacking models, can help to
account for complex  variations in aquatic systems and improve accurate and timely predictions
of WQS exceedances. A complex pattern of WQS exceedances was resolved by combining

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hydrodynamic and statistical modeling at a popular beach in Florida (Zhu 2009). In the Great
Lakes, water current, wind, and water level outputs of deterministic models are generated and
can be used as independent variables in statistical models for predicting water quality at beaches,
as well as for other purposes (NOAA 2012;  Schwab and Bedford 1994). EPA's FRAMES model
combines the functions of multiple process models to estimate water quality. For information on
FRAMES visit http://www.epa.gov/extrmurl/research/3mra.html.

4.6.5  Determining Exceedances Using Predictive Models
Predictive models use past water quality data and current observed hydro-meteorological  data as
a basis for estimating water quality at a given time, as described in section 4.5. Models need a
data set of observations that can vary in length, and ongoing calibration with periodic water
quality determinations that can vary in frequency, to maintain a model's calibration. Beach or
program managers should assess their predictive models by correlating estimates of water quality
with analytical results, the percentages of both Type I (false positive) and Type II (false
negative) errors, or other methods that characterize water quality (e.g., Francy 2009, Gonzalez et
al. 2012).

The water quality estimates should be compared with beach notification thresholds. Beach or
program managers can use beach notification thresholds that provide an adequate basis for public
health protection.  As stated in section 5.3, actions imposed based on the output of a predictive
model can be lifted when the model is run again and new estimates indicate water quality
conditions have improved to within acceptable parameters or, alternatively, when the results of a
water quality sample show that FIB densities once again meet the applicable standard.

Future directions that EPA considers likely for predictive tools for beach notification include
forecasting beach water quality conditions a day or more into the future. Researchers are also
attempting to develop models that would apply to more than one beach or to a region of
shoreline.

4.7  The 2012 RWQC Provide  Context for Beach Monitoring Programs

This section summarizes relevant elements of the 2012 RWQC (section 4.7.1) and describes key
considerations for beach monitoring programs (section 4.7.2). Section 4.7.3 discusses a new
performance criterion—Adoption of New or Revised WQS and Identification and Use of a Beach
Notification Threshold, Performance Criterion 10.

4.7.1  2012 Recreational Water Quality Criteria
On November 26, 2012, EPA released its revised RWQC. It is beyond the scope of this document
to discuss the details of the RWQC. The criteria and associated information are available at
http ://water.epa. gov/scitech/swguidance/standards/criteria/health/recreati on/index, cfm.

The 2012 RWQC, if adopted as recommended into state or tribal WQS, would be the applicable
WQS in CWA programs, including issuing NPDES permits, assessing waters to determine
whether they are attaining WQS, developing TMDLs, and conducting beach monitoring and
notification programs funded under CWA section 406. However, the water quality distribution
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on which a state's or tribe's WQS is based could also be the basis for selecting a beach
notification threshold value to trigger beach notification actions (i.e., advisories and closures).

EPA recommends that WQS based on the 2012 RWQC include the following values:
    •   Magnitude. Magnitude is the numeric expression of the maximum amount of the
       pollutant that might be present in a water body that supports the designated use.
    •   Duration. Duration is the period of time over which the magnitude is calculated.
    •   Frequency.  Frequency of excursion7 describes the maximum number of times the
       pollutant might be present above the magnitude over the specified time period (duration).

Criteria in a WQS should consist of a combination of magnitude, duration, and frequency of
exceedance to protect the designated use (in this case,  primary contact recreation).

As  summarized below and described in greater detail in the 2012 RWQC document (USEPA
2012b), EPA determined that the primary contact recreation designated use would be protected if
the state or tribe adopted one of the sets of criteria values (table 4-4), consisting of a GM and an
STV, into its WQS  and EPA approved it. Note that EPA's criteria recommendations are for a
GM and an STV (rather than just a GM or just an STV) because, used together, they indicate
whether the water quality is protective of the designated use of primary contact recreation. Using
the GM alone would not protect  for spikes in water quality because the GM alone is not sensitive
to them.

The 2012 RWQC provide both GM values and STVs as upper-bound values (table 4-4). EPA
recommends that the criteria magnitude be expressed as  a GM value and an STV. These values
correspond to the 50*  and the 90* percentiles, respectively, of the same water quality
distribution, and thus they are associated with the same level of public health protection.

                          Table 4-4. Recommended  2012 RWQC
Criteria elements
Indicator
Enterococci - marine
and fresh water
OR
£. co// - fresh water
Estimated illness rate (NEEAR Gl):
36 NGI per 1 ,000 recreators
GM
(CFU/100 mL)*
35
STV
(CFU/100 mL)*
130

126
410

OR
Estimated illness rate (NEEAR Gl):
32 NGI per 1,000 recreators
Magnitude
GM
(CFU/100 mL)*
30
STV
(CFU/100 mL)*
110

100
320
Duration: The water body GM and STV should be evaluated over a 30-day interval. Frequency: The selected GM
magnitude should not be exceeded in any 30-day interval, nor should there be greater than a 1 0 percent excursion
frequency of the selected STV magnitude in the same 30-day interval.
*EPA recommends using EPA Method 1600 (USEPA 2009a) to measure culturable enterococci, or another equivalent method that
measures culturable enterococci, and using EPA Method 1603 (USEPA 2009b) to measure culturable £. co//, or any other
equivalent method that measures culturable £. co//.
 The frequency of excursion describes how often water quality sample values may surpass the combined magnitude
and duration components before an exceedance of the WQS occurs and the water body is considered impaired.
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4.7.1.1  Geometric Mean
EPA is recommending that the GM of a water body be calculated in the same way as
recommended in the 1986 criteria by taking the logio of sample values, averaging those values,
and then raising 10 to the power of that average.

4.7.1.2  Statistical Threshold Value
The STV is derived in a similar manner to the 1986 criteria SSM, by estimating the percentile of
the expected water quality distribution around the GM criteria value. EPA recommends an STV
that approximates the 90* percentile of the water quality distribution; it is intended to be a value
that should not be exceeded by more than  10 percent of the samples measured over a 30-day
period used to calculate the GM. EPA selected the estimated 90* percentile as the STV. The 90th
percentile accounts for the expected variability in water quality measurements, while limiting the
number of excursions above the STV. It encourages additional monitoring because using the 90*
percentile reduces the number of samples that could exceed the criteria value (i.e., STV) within
the 30-day duration period. This approach also encourages monitoring because it allows no
excursion of the STV unless at least 10 samples are taken over the 30 days during which the
magnitude component of the criteria is calculated.

In a departure from the 1986 criteria, EPA no longer recommends the concept of multiple use
intensity values of the SSM. EPA's 2012 RWQC include both the GM and STV, used together to
adequately protect the designated use of primary contact recreation. Therefore, EPA
recommends that states and tribes adopt both the GM and STV  into their WQS.

4.7.2   Threshold Values for Beach  Notification Actions

4.7.2.1  Selection of Beach Notification Thresholds for States and Tribes Receiving Grants
        under CWA Section 406
The BEACH Act requires that states and tribes receiving grants under the act notify the public
of any exceedance of or likelihood of exceedance of applicable WQS. When FIB levels at a
beach exceed the applicable threshold, the responsible state or tribal agency issues a beach
notification. Agencies generally issue beach advisories but, in some cases, might issue a beach
closure  notice. The purpose of these public notices  is to inform the public of the potential risks
associated with primary contact recreation in waters that exceed or are likely to exceed the
applicable WQS.

States and tribes must identify a beach notification threshold. This threshold does not need to be
adopted into a state's or tribe's WQS. In the 2012 RWQC EPA suggests use of a specific value,
the Beach Action Value (BAV), which is the 75* percentile value of the water  quality
distributions for the CWA section 304(a) recommended criteria (i.e., the 75th percentile values
for 32 NGI per 1,000 recreators or 36 NGI per 1,000 recreators  for one of the two indicator-
method  combinations (enterococci or E. coli by culture) or qPCR (on a site-specific basis and
with the appropriate analyses (see section 4.4.2.3)) as the threshold value for determining
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                                                                                           th
whether to take a beach notification action.8 EPA selected the 75* percentile value because it
corresponds to the percentile of the SSM values many states currently use as beach notification
thresholds.

In state and tribal programs funded by EPA grants under CWA section 406, it is critical that the
selected beach notification threshold be based on the same water quality distribution as the
state's or tribe's WQS. Any  single sample above the threshold value would trigger a beach
notification until collection of another sample below that value. EPA suggests a BAV at the 75
percentile level in order to trigger an advisory at a lower FIB density than the STV. Because this
BAV is a more conservative point on the same water quality distribution, states and tribes using
this value will satisfy the statutory requirement for a notification action on an exceedance or
likely exceedance of the WQS.

EPA expects that states and tribes receiving beach grants under CWA section 406 will select as
their beach notification threshold the BAV based on the 75* percentile value that corresponds to
the indicator and illness rate in their adopted their WQS. (See table 4-5). However, they do have
the option to submit a written justification to use a different value. The alternative value should
be selected from the same statistical distribution as the illness rate and corresponding values
adopted into state WQS, and the justification should explain why this value is preferable to the
EPA-preferred 75th percentile value.  This is discussed further in section 4.7.3.

                          Table 4-5. Beach Action Values (BAVs)
                                                                      Estimated Illness Rate
                                                                        (NGI): 32 per 1,000
                                                                         primary contact
                                                                            recreators
                                                                      BAV (Units per 100 ml.)
Enterococci - cultivable (fresh and marine)3
£. co// -cultivable (fresh)b
Enterococcus spp. — qPCR (fresh and marine)0
70cfu
235 cfu
1,000 cce
OR
60 cfu
190 cfu
640 cfu
a Enterococci measured using EPA Method 1600 (USEPA 2009a), or another equivalent method that measures culturable
enterococci.
b £. coli measured using EPA Method 1603 (USEPA 2009b), or any other equivalent method that measures culturable E. coli.
0 EPA Enterococcus spp. Method 1611 forqPCR (USEPA 2012a).
Before selecting any new beach notification threshold, states and tribes will continue to make
notification decisions using the existing beach notification thresholds. In most states the existing
beach notification values are SSM values from EPA's 1986 RWQC document. These SSM
                            -th
values corresponded to the 75   percentile values of the 1986 RWQC statistical distribution.
8 All BEACH Act states and tribes that have not revised their WQS as directed in CWA section 303(i)(l)(A) were
required by section 303(i)(l)(A) to have WQS as protective of human health as EPA's 1986 bacteria criteria.
Because EPA's 1986 bacteria criteria recommendations were forthe same fecal indicator bacteria in the 2012
RWQC (enterococci and E. coli), the BAV in the 2012 RWQC have the requisite relationship with the applicable
WQS in states that have not yet revised their WQS under CWA section 303(i)(l)(B).
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4.7.2.2   Alternative Beach Notification Thresholds
For beach programs not funded by EPA grants under CWA section 406(b), there are additional
alternatives for states and tribes to consider. As with the BEACH Act states, neither use of the
BAV nor any of the alternatives requires adoption into a state or tribal WQS.

States and tribes that do not receive funding under CWA section 406 could choose to use any
exceedance of the applicable STV as a threshold for notification for the purposes of their beach
notification program, even without adopting it as a "do not exceed value" into their WQS.
Alternatively, states and tribes that do not receive funding under CWA section 406 could choose
to continue to use their current beach notification value; however, EPA encourages these states
and tribes to use the BAV based on the 75*  percentile value from the water quality distribution
of their WQS.

4.7.2.3   Preemptive Advisories
A state or tribe might have in place a preemptive advisory that automatically takes effect when
conditions in the advisory (e.g., amount of rainfall) are met. The advisory is developed based on
an analysis of monitoring data that shows the conditions under which the applicable WQS will
be exceeded or is likely to be exceeded. The preemptive advisory would take effect and would
end based on those predetermined conditions. Such an advisory might need to be recalibrated if
the state's or tribe's beach notification threshold changes.

4.7.2.4   Exceedances for EPA Enterococcus qPCR Methods
The 2012 RWQC document provides information on a qPCR Enterococcus spp. method (EPA
Enterococcus spp. qPCR Method 1611; USEPA 2012a), discussed in  section 4.4.2.2. EPA
supports state use of qPCR methods for beach notification decisions in lieu of culture methods
because it presents an  opportunity to improve public health protection by enabling beach
managers to take more timely notification actions at recreational beaches.

Because of EPA's limited experience with qPCR performance across  a broad range of
environmental conditions, EPA encourages a site-specific analysis of the method's performance
before using the method in a beach notification program or adopting WQS based on the method.
Section  4.4.2.3 describes a process for assessing the feasibility of using qPCR on a site-specific
basis, including confirming that inhibition does not affect the method's ability to accurately
characterize water quality.

For states considering using qPCR Method 1611 or 1609, the 2012 RWQC provides the
following GM, STV, and  BAV values  (table 4-6) for both the 36/1,000 and 32/1,000 primary
contact recreates' illness rates. Consistent with section 4.7.2.1, states and tribes using qPCR
may also select a beach notification threshold that is other than the 75th percentile value,  with
appropriate justification.
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National Beach Guidance and Required Performance Criteria for Grants, 2014 Ed.
                                     Chapter 4
                               Table 4-6. Values for qPCR
                                                 OR
                                                                  1,000 primary contai
                                                                  recreators
                         (CCE per  (CCE
              100mL)     100mL)    100mL)
                                                          300
                           1,280
640
*EPAEnterococcusspp. Method 1611 forqPCR (USEPA2012a).
4.7.3  Implementation Requirements for Adopting the 2012 RWQC into State and
       Tribal WQS and Identifying and Using a Beach Notification Threshold
       (Performance Criterion 10)
EPA is adding a new performance criterion, Adoption of New or Revised WQS and Identification
and Use of a Beach Notification Threshold, Performance Criterion 10. The purpose of the
criterion is to ensure that BEACH Act states and tribes adopt new or revised WQS as directed in
CWA section 303(i)(l)(B); that is, within three years after EPA issues new or revised RWQC.
The performance criterion also requires selection and use of an appropriate beach notification
threshold. The specifics of performance criterion 10 will change from year to year.

4.7.3.1  FY 2014 Overview
The prerequisite for receiving an FY 2014 BEACH Act grant is to agree to a grant condition
requiring the development of two schedules. BEACH Act states and tribes must include in the
grant workplan for their FY 2014 grants a commitment to develop these schedules within 60
days of grant award:
    •   Adopt new or revised WQS by FY 2016.
    •   Select and use an appropriate beach notification threshold by FY 2016.

Additionally, states and tribes must commit to begin following the schedules by the end of the
grant year. If a state or tribe believes that  it will be unable to develop either or both schedules
within the allotted time frame, the state or tribe may request  from the regional grant project
officer an extension of up to 30 days for submitting the schedule(s).

The schedules  should contain milestones consistent with any relevant aspect of state or tribal law
or custom that could affect the time frame for adopting new or revised WQS and identifying and
using an appropriate beach notification threshold. Milestones might include, for example,
drafting regulations, interagency coordination, public outreach and public comment periods, and
legislative review. Where different state or tribal agencies must collaborate in order to develop
and implement the two schedules, milestones might include creating and convening an
interagency workgroup.

4.7.3.2  FY 2014: Adopting New or Revised Water Quality Standards
The new  or revised WQS anticipated by the schedule must have RWQC expressed as a
magnitude, duration, and frequency for the indicator, and an illness rate consistent with the CWA
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section 304(a) recommendations in the 2012 RWQC or alternative criteria that are scientifically
defensible and protective of the primary contact recreation use.

In 2004, EPA promulgated WQS for 21 states. Since then, only six of those states have revised
their WQS. The other states continue to use the WQS in the federal promulgation to make beach
notification decisions. One purpose of this schedule is to ensure that  such states update their
underlying state regulations.

All BEACH Act states and tribes must develop this schedule except those that have received an
affirmative statement from EPA waiving the requirement. States and tribes that have RWQC that
are consistent with EPA's CWA section 304(a) 2012 RWQC recommendations may be eligible
for such a waiver. EPA will expect the schedule to address specifically those elements that are
not consistent with the 2012 RWQC.

4.7.3.3  FY 2014: Identifying and Using a Beach Notification Threshold
The second schedule is for the state or tribe to identify and use an appropriate beach notification
threshold. The state or tribe must commit to identify the indicator, illness rate, and value the state
or tribe will use as its beach threshold at the completion of the second schedule. EPA expects
that states and tribes will use BAVs as their notification thresholds (i.e., the 75th percentile value
of the water quality illness rate from their new or revised WQS). States and tribes that want to
use an alternative threshold must submit a written justification to EPA based in science, local
water quality data, or monitoring experience.

The 2012 RWQC explicitly did not recommend adoption of a beach threshold as part of the
CWA section 304(a) recommendations for state and tribal WQS. However, some states and
tribes may be required under state or tribal law to  use only the values in their WQS as their beach
notification threshold, and those WQS might not include an appropriate not-to-exceed threshold.
In those situations, the state or tribe would need to change any legal requirement that precludes
the state or tribe from using a value consistent with the requirements of this document.

States and tribes must continue to use their existing beach notification thresholds based on the
currently applicable WQS, e.g., SSM, until the state or tribe adopts new or revised WQS. When
the state or tribe adopts new or revised WQS, it must have a beach notification threshold that can
be used.

4.7.3.4  FY 2015 and Beyond
Grant workplans for FY 2015 and beyond must include a commitment to continue to implement
the schedules for adopting the WQS and identifying and using a beach notification threshold
until the state or tribe has met all the milestones in both schedules. The workplans must also
identify the indicator, illness rate, and value the state or tribe will use as its beach notification
threshold and commit to making beach notification decisions as described.

4.7.4  Use of RWQC in Identifying CWA Section 303(d) Impaired Waters
States that have EPA-approved WQS consistent with EPA's 2012 RWQC recommendations
must use the GM and STV (with corresponding duration and frequency) when identifying CWA
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section 303(d) impaired waters. EPA expects that beach water quality monitoring data from the
beach program, and any other ambient monitoring, would be evaluated as part of a state's or
tribe's data set to calculate the GM and STV for attainment purposes.

States also have the option to consider use of beach notification actions (advisories and closures
in a recreational season) when determining whether the waters demonstrate nonattainment of
their primary recreation use. In general, EPA recommends that states and tribes consider
information about beach notification actions as a supplement to the GM and STV calculations.

4.8  Delegation of Monitoring Responsibilities (Performance
      Criterion 5)

If a state delegates monitoring responsibilities  to local governments, performance criterion 5
requires the state grant recipient to describe the process by which the state may delegate these
responsibilities to local governments and document any specific delegated responsibilities. States
must notify EPA annually if there are any changes in delegated responsibilities.

4.9  Chapter 4 References

AOAC International. 1995. Official Methods of Analysis of AOAC International. 16th ed. Ed.
       P.A. Cunniff AOAC International,  Arlington, VA.

APHA (American Public Health Association).  1998. Standard Methods for the Examination of
       Water and Wastewater. 20th ed. American Public Health Association, Washington, DC.

ASTM (American Society for Testing and Materials International). 2000. Annual Book of ASTM
       Standards, vols. 11.01 and 11.02. American Society for Testing and Materials
       International, West Conshohocken,  PA.

Boehm, A.B. 2007. Enterococci concentrations in diverse coastal environments exhibit extreme
       variability. Environmental Science and Technology 41(24): 8227-8232.

Boehm, A.B., S.B. Grant, J.H. Kim, S.L. Mowbray, C.D. McGee, C.D. Clark, D.M. Foley, and
       D.E. Wellman. 2002. Decadal and shorter period variability and surf zone water quality at
       Huntington Beach, California. Environmental Science and Technology 36(18): 3885-
       3892.

Boehm, A.B., R.L. Whitman, M.B. Nevers, D. Hou, and S.B. Weisberg. 2007. Nowcasting
       recreational water quality. In Statistical Framework for Recreational Water Quality
       Criteria and Monitoring, ed. L. Wymer. Wiley-Interscience, Chichester, West Sussex,
       England.

Brooks, W.R., M.N. Fienen, and S.R. Corsi. 2013. Partial least squares for efficient models of
       fecal indicator bacteria on Great Lakes beaches. Journal of Environmental Management
       114:470-4075.
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Clesceri, L.S., A.E. Greenberg, and A.D. Eaton, eds. 1998. Standard Methods for the
       Examination of Water and Wastewater. 20th ed. American Public Health Association,
       American Water Works Association, and Water Environment Federation, Washington,
       DC.

Colford, J.M., K.C. Schiff, J.F. Griffith, V. Yau, B.F. Arnold, C.C. Wright, J.S. Gruber, T.J. Wade,
       S. Burns, J. Hayes, C. McGee, M. Gold, Y. Cao, R.T. Noble, R. Haughland, and S.B.
       Weisberg . 2012. Using rapid indicators for Enterococcus to assess the risk of illness after
       exposure to urban runoff contaminated marine water. Water Research 46(7): 2176-86.

Converse, R.R., J.L. Kinzelman, E.A.  Sams, E. Hudgens, A.P. Dufour, H. Ryu, J.W. Santo-
       Domingo, C.A. Kelty, O.C. Shanks, S.D. Siefring, R.A. Haugland, and T.J. Wade. 2012.
       Dramatic improvements in beach water quality following gull removal. Environmental
       Science and Technology 46( 18): 10206-10213.

Cyterski, M., S. Zhang, E. White, M. Molina, K. Wolfe, R. Parmar, and R. Zepp. 2012.
       Temporal synchronization analysis for improving regression modeling of fecal indicator
       bacteria levels. Water, Air, & Soil Pollution 223(8): 4841-4851.

Francy, D. 2006. Status and Future of Predictive Modeling at Beaches. U.S. Geological Survey,
       Ohio Water Science Center. Presented at the National Beach Conference, October 11-13,
       2006, Niagara Falls, NY. Accessed March 2009. http://www.tetratech-
       ffx.com/beach_conf06/pdf/sessionVI/francy.pdf

	. 2009. Use of predictive models and rapid methods to nowcast bacteria levels at coastal
       beaches. Aquatic Ecosystem Health and Management 12(2): 177-182.
Frick, W.E., Z. Ge, and R.G. Zepp. 2008. Nowcasting and forecasting concentrations of
       biological contaminants at beaches: A feasibility and case study. Environmental Science
       and Technology 42(13): 4818-4824.

Gonzalez, R.A., K.E. Conn, J.R. Crosswell, and R.T. Noble. 2012. Application of empirical
       predictive modeling using conventional and alternative fecal indicator bacteria in eastern
       North Carolina waters. Water Research 46(2012): 5871-5882.

Griffith, J.F., K.C. Schiff, S.B. Weisberg, C.D. McGee, and C. Clifton. 2007. Efficacy of Shallow
       Water Sampling to Determine Exposure of Surfers to Indicator Bacteria at Marine
       Beaches.  Southern California Coastal Water Research Project, Costa Mesa, CA.

Griffith, J.F., and S.B. Weisberg. 2011. Challenges in implementing new technology for beach
       water quality monitoring: Lessons from a California demonstration project. Marine
       Technology Society Journal 45(2): 65-73.

Haughland, R.A., S.C. Siefring, LJ. Wymer, K.P. Brenner, and A. P. Dufour. 2005. Comparison
       of Enterococcus measurements in freshwater at two recreational beaches by quantitative
       polymerase chain reaction and membrane filter culture analysis.  Water Research
       39(2005): 559-568.
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Haugland, R.A., S. Siefring, J. Lavender, and M. Varma. 2012. Influences of sample interference
       and interference controls on quantification of enterococci fecal indicator bacteria in
       surface water by the qPCR method. Water Research 46(18): 5989-6001.

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

Leecaster, M.K., and S.B. Weisberg. 2001. Effect of sampling frequency on shoreline
       microbiology assessments. Marine Pollution Bulletin 42(11): 1150-1154.

Le Fevre, N.M., and G.D. Lewis. 2003. The role of resuspension in enterococci distribution in
       water at an urban beach.  Water Science and Technology 47(3): 205-210.

Nevers, M.B., and R.L. Whitman. 2005. Nowcast modeling of Escherichia coli concentrations at
       multiple urban  beaches of southern Lake Michigan.  Water Research 39(20): 5250-5260.

NOAA (National Oceanic and Atmospheric Administration). 2012. Great Lakes Coastal
       Forecasting System. National Oceanic and Atmospheric Administration, Great Lakes
       Environmental  Research Laboratory, Ann Arbor, MI. Accessed June 2012.
       http ://www. glerl .noaa. gov/res/glcfs.

Noble, R.T., I.M. Lee,  and K.C.  Schiff. 2003. Inactivation of Indicator Bacteria from Various
       Sources of Fecal Contamination in Seawater and Freshwater. Southern California
       Coastal Water Research Project. 2001-02 Biennial Report, pp. 164-163.

Noble, R.T, A.D. Blackwood, J.F. Griffith, C.D. McGee, and S.B. Weisberg. 2010. Comparison
       of rapid quantitative PCR-based and conventional culture-based methods for enumeration
       of Enterococcus spp. and Escherichia coli in recreational waters. Applied and
       Environmental Microbiology 76(22): 7437-7443.

Office of the Federal Register. 2003. Guidelines Establishing Test Procedures for the Analysis of
       Pollutants; Analytical Methods for Biological Pollutants in Ambient Water; Final Rule.
       Office of the Federal Register,  National Archives and Records Administration,
       Washington, DC. Fed. Regist., Jul. 21, 2003, 68: 43272-43283.

Olyphant, G.A., and R.L. Whitman. 2004. Elements of a predictive model for determining beach
       closures on a real time basis: The case of 63rd Street Beach Chicago. Environmental
       Monitoring and Assessment 98(1-3): 175-190.

Schwab, D.J., and K.W. Bedford. 1994. The Great Lakes Forecasting System. In Coastal and
       Estuarine Studies: Coastal Ocean Prediction, ed. C.N.K. Mooers. American Geophysical
       Union, Washington, DC.

Taggart, J.B., R.A. Hynes, P.A. Prodhol, and A. Ferguson. 1992. A simplified protocol for routine
       total DNA isolation from salmonid fishes. Journal of Fish Biology 40(6): 963-965.
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USEPA (U.S. Environmental Protection Agency). 1978. Microbiological Methods for
      Monitoring the Environment, Water and Wastes. EPA 600/8-78-017. U.S. Environmental
      Protection Agency, Washington, DC.

	. 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.
      -. 2005. The EMPACT Beaches Project: Results from a Study on Microbiological
      Monitoring in Recreational Waters. EPA 600/R-04/023. U.S. Environmental Protection
      Agency, Office of Research and Development, National Exposure Research Laboratory,
      Washington, DC.

      -. 2007. Report of the Experts' Scientific Workshop on Critical Needs for the Development
      of New or Revised Recreational Water Quality Criteria. EPA-823-R-07-006. U.S.
      Environmental Protection Agency, Office of Water and Office of Research and
      Development, Washington, DC.

      -. 2009a. Method 1600: Enterococci in Water by Membrane Filtration Using Membrane-
      Enterococcus Indoxyl-fi-D-Glucoside Agar (mEI). EPA 821/R-09/016.
      U.S. Environmental Protection Agency, Office of Water, Washington, DC.

      -. 2009b. Method 1603: Escherichia coli (E. colij in Water by Membrane Filtration Using
      ModifiedMembrane-ThermotolerantEschenchia coliAgar (ModifiedmTEC).  EPA 821-
      R-09-007. U.S. Environmental Protection Agency, Office of Water, Washington, DC.

      -. 2009c. Office of Water Quality Management Plan, revision 3. EPA-821-R-09-001.
      U.S. Environmental Protection Agency, Office of Water, Washington, DC.

      -. 2010a. Predictive Modeling at Beaches. Vol. 2, Predictive Tools for Beach Notification.
      EPA-600-R-10-176. U.S. Environmental Protection Agency, National Exposure Research
      Laboratory, Athens, GA.

      -. 201 Ob. Predictive Tools for Beach Notification. Vol.  1, Review and Technical Protocol.
      EPA-823-R-10-003. U.S. Environmental Protection Agency, Office of Water,
      Washington, DC.

      -. 2010c. Sampling and Consideration of Variability (Temporal and Spatial) for
      Monitoring of Recreational Waters. EPA-823-R-10-005. U.S. Environmental Protection
      Agency, Office of Water, Washington, DC.

      -. 2012a. Method 1611: Enterococci in Water by TaqMan®  Quantitative Polymerase
      Chain Reaction (qPCR) Assay. EPA-821-R-12-008. U.S. Environmental Protection
      Agency, Office of Water, Washington, DC.
      -. 2012b. Recreational Water Quality Criteria. EPA 820-F-12-058. U.S. Environmental
       Protection Agency, Office of Water, Washington, DC.
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	. 2013a. Acceptability of the EPA qPCR Test at Your Beach. EPA 820-R-13-012.
       U.S. Environmental Protection Agency, Office of Water, Washington, DC.

	. 2013b. Method 1609: Enterococci in Water by TaqMan® Quantitative Polymerase
       Chain Reaction (qPCR) with Internal Amplification Control (IAC) Assay. EPA-820-R-
       13-005. U.S. Environmental Protection Agency, Washington, DC.

	. In press-a. Alternative Health Relationships Technical Support Materials. U.S.
       Environmental Protection Agency, Office of Water, Washington, DC.

	. In press-b. Site-Specific Alternative  Criteria Technical Support Materials for Alternative
       Fecal Sources. U.S. Environmental Protection Agency, Office of Water,  Washington,
       DC.

	. In press-c. Site-Specific Alternative  Criteria Technical Support Materials for Alternative
       Indicators and Methods. U.S. Environmental Protection Agency, Office of Water,
       Washington, DC.

Wade, TJ, R.L. Calderon, K.P. Brenner, E. Sams, M. Beach, R. Haugland, L. Wymer,  and A.P.
       Dufour. 2008. High sensitivity of children to swimming-associated gastrointestinal
       illness: Results using a rapid assay of recreational water quality. Epidemiology  19(3):
       375-383.

Wade, T.J., E. Sams, K.P. Brenner, R. Haugland, E. Chern, M. Beach, L. Wymer, C.C. Rankin,
       D. Love, Q. Li, R. Noble,  and A.P. Dufour. 2010. Rapidly measured indicators  or
       recreational water quality  and swimming-associated illness at marine beaches: A
       prospective cohort study. Environmental Health 9:66.

Wymer, LJ. 2007. The EMPACT Beaches: A Case Study in Recreational Water Sampling.
       Chapter 7 in Statistical Framework for Recreational Water Quality Criteria and
       Monitoring, ed. L. Wymer, pp. 113-134. John Wiley and Sons, Ltd., UK.

Zhu, X. 2009. Modeling Microbial Water Quality at a Non-Point Source Subtropical Beach.
       Master's thesis, University of Miami, Coral Gables, FL.
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Chapter 5: Public Notification and Risk Communication

This chapter describes the performance criteria and technical guidance related to public
notification and risk communication. It includes information on developing and implementing a
plan that describes measures to notify the public of an exceedance or likely exceedance of the
applicable WQS and inform them of the potential risks associated with water contact activities in
recreation waters that do not meet applicable WQS. Assessing the information needs of
stakeholders, developing message content, and selecting communication methods are key
elements of the plan. This chapter discusses a variety of communication options, such as beach
signs, news releases, websites, and social networking. The chapter also  covers BEACH Act
requirements for notifying EPA and  local agencies when WQS are exceeded and reporting
notification activities.

To the extent possible, states and tribes should be moving toward same-day notification of
exceedances and prompt reporting by using tools that provide rapid results (i.e., rapid analytical
methods and predictive models) and tools that facilitate rapid communication of those results
(e.g., electronic notification and real-time reporting).

This guidance reflects those goals in the addition of three new specific requirements under the
performance criteria. These requirements apply to states and tribes that receive grants under
CWA section 406 after this document becomes final:
    • Performance criterion 2, Tiered Monitoring Plan, now requires that states and tribes
      consider the potential use of predictive tools when developing a tiered monitoring plan.
    • Performance criterion 2, Tiered Monitoring Plan, now requires that states and tribes
      consider the appropriateness  of qPCR methods when developing a tiered monitoring plan.
    • Performance criterion 4, Monitoring Report Submission, now requires that states and
      tribes make monitoring data available in a timely manner to the public on a website.

5.1  Performance Criteria

Performance criteria 6 through 9 describe the four requirements for a public notification and risk
communication program:
    • Public Notification and Risk Communication Plan (performance criterion 6).
    • Actions to Notify the Public (performance criterion 7).
    • Notification Report Submission (performance criterion 8).
    • Delegation of Notification Responsibilities (performance criterion 9).
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                                               Chapter 5
    Key changes to chapter 5 from the 2002 guidance document
        •   More clearly ties notification to the tiered monitoring plan (section 5.2).
        •   Adds a specific requirement to identify measures to inform the public of the risks of
            swimming in contaminated water (section 5.2).
        •   Adds information about risk communication objectives, notification content, and
            notification methods (sections 5.2 and 5.4).
        •   Discusses new beach notification and communication tools, such as social media, email,
            and text messages (section 5.4).
        •   Provides guidance on when to issue or remove a notification (section 5.3).
        •   Combines performance criteria 5 through 7 into performance criterion 6 to eliminate
            duplication (section 5.2).
        •   Divides performance criterion 8 into two criteria—performance criteria 8 and 9—to
            separate  disparate activities (sections 5.5 and 5.6).
  Table 5-1 provides details on the general and specific requirements of the performance criteria
  and cross-references them to the sections in this chapter where they are discussed. As explained
  in chapter 2, monitoring and notification programs funded with BEACH Act implementation
  grants must be consistent with the performance criteria.
                               Table 5-1. Performance criteria details
                                               ce criteria
                ral requirements
Public Notification and Risk Communication
Plan (Performance Criterion 6). States and tribes
must develop public notification and risk
communication plans.
             Specific requirem
  Identify measures to notify EPA and local
  governments (if applicable) when indicator bacteria
  levels exceed a beach notification threshold.
  Identify measures to notify the public when a beach
  notification threshold has been exceeded by posting a
  sign or functional equivalent.
  Identify measures that inform the public of the
  potential risks associated with water contact activities
  in the coastal recreation waters that do not meet
  applicable WQS.
  Provide for public review of the public notification and
  risk communication plan.
Actions to Notify the Public (Performance
Criterion 7). States and tribes must give notice to
the public that the coastal recreation waters are not
meeting or are not expected to meet applicable
WQS or the beach  notification threshold for
pathogens and pathogen indicators.
  Promptly issue a public notification for exceedance of
  the beach notification threshold when there is no
  reason to doubt the accuracy of the sample.
  If there is a reason to doubt the accuracy of the first
  sample, the state agency may resample before
  issuing a notification.
                                                      5.4
Notification Report Submission (Performance
Criterion 8). States and tribes must compile their
notification actions in timely reports submitted to
EPA.
  States and tribes must report to EPA at least annually,
  or at a frequency the EPA Administrator determines, on
  the occurrence, nature, location, pollutants involved,
  and extent of any exceedances of any WQS for
  pathogens and pathogen indicators.
5.5
Delegation of Notification Responsibilities
(Performance Criterion 9). States must describe
any delegation of notification responsibilities that
they have made, or intend to make, to local
governments.
• States must identify any local governments to which
  they have delegated responsibility for implementing a
  notification program and describe the process by
  which the state may delegate such authority.
                                                      5.6
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5.2  Public Notification and Risk Communication Plan (Performance
      Criterion 6)

Performance criterion 6 requires states and tribes to develop a public notification and risk
communication plan. The plan must describe the state's or tribe's public notification efforts;
identify measures used to inform the public of an exceedance or likely exceedance of the
applicable WQS; and address a new requirement to identify measures to inform the public about
the potential risks associated with water contact activities in coastal recreation waters that do not
meet the applicable beach notification thresholds. Below are the key steps of creating a public
notification and risk communication plan:
    •   Creating a risk communications strategy.
    •   Assessing needs and establishing trust.
    •   Crafting beach notifications.
    •   Evaluating outcomes.

EPA recognizes that states and tribes usually have such plans in place. States and tribes should
review and evaluate their plans periodically to keep them current with the information needs of
the community, conditions associated with a contamination problem, and resources and
personnel available to the responsible agency. Importantly, careful evaluation will help to
determine to what extent the public notification and risk communication program is achieving its
objectives and what components should be revised and improved.

5.2.1  Creating a Risk Communication Strategy

5.2.1.1  Risk Communication Partners
Public notification and risk communication are primarily information-sharing processes among
three key groups of people:
    •   Stakeholders—the target audiences that receive and respond to beach advisory and
       closing information. They include swimmers and other people (such as  seashore vendors)
       who might be affected by beach actions. Government agencies that have an interest in
       beach actions or must be notified if a beach action is issued are included in this category.
       State agencies should consider the stakeholders' beliefs, attitudes, and backgrounds when
       developing notification content and appropriate ways to distribute it. Stakeholders can
       provide valuable feedback that helps the responsible agency achieve the greatest positive
       impact in the community.
    •   Agency technical experts—the people responsible for beach monitoring and research
       activities; setting policy and procedures in response to violations of WQS; and
       generating, interpreting, and assessing water quality data. They provide the scientific
       foundation for the notification and risk communication program.
    •   Risk communicators—the people responsible for designing and implementing the
       notification and risk communication program. They typically rely on a two-way
       communication process with the other partners to define program objectives, assess
       information needs, and develop communication strategies.
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Those three groups should work toward the common objective of reducing the risk of disease to
users of recreational waters.

5.2.1.2  Types of Public Notifications
When indicator bacteria levels at a beach exceed the beach notification threshold, the responsible
agency issues an advisory or closure to inform the public of an exceedance or likely exceedance
of the applicable WQS and the potential  risks associated with swimming and other water contact
activities.
    •  Beach advisories (orpostings in  California) are recommendations to avoid swimming at
       the beach, or beach  area, because of an increased risk of contracting a water-related
       illness. The action does not, however, officially close a beach to the public. Types of
       advisories include:
       -  Water quality exceedance advisories, which notify the public of an exceedance of
          applicable beach notification  thresholds on the basis of water quality sampling or the
          likelihood of an exceedance on the basis of modeling.
       -  Permanent advisories, which  notify the public of a continuing potential human health
          risk associated with use of the water. These might be issued because of the presence
          of naturally occurring organisms or human influences that cause a continuous or
          reoccurring exceedance of a WQS.
       -  Preemptive advisories, which notify the public of the likelihood of higher FIB levels
          at certain times.  Preemptive advisories are typically based on having done sufficient
          monitoring in the past to support an assumption that water quality will exceed the
          beach notification threshold for a certain period of time after a defined event. An
          event might be significant rainfall that typically results in flushing bacteria from the
          land into the water, high-temperature conditions that stimulate bacterial productivity,
          or prevailing wind conditions that cause the transport of contaminated water from
          known polluted  areas.
    •  Beach closing typically means that the beach, or a beach area, is officially closed to the
       public. Whether to close a beach  is a local decision; EPA does not set beach closure
       requirements  or conditions. States and tribes have the flexibility to close the entire beach
       or just the recreational water adjacent to the beach. For some jurisdictions, closure is a
       recommendation; for others, it might be enforced. EPA recommends, however, that a
       closing be issued if  a clear public health hazard, such as a sewage line break or other
       high-risk contamination source, is present. During such a closing, no one should be in the
       water. Lifeguards might not be present at the beach. The beach could be closed to the
       public temporarily or for an extended period.

A public notification is also issued when a beach action is lifted or suspended.

5.2.1.3  Risk Communication Objectives
A complete set of clear, concise, and measurable objectives helps to guide the development of a
public notification program and serves as a set of measuring tools for program evaluation. In the
case of beach closings, the objective is usually clear-cut—the public is prohibited from
swimming because a public health hazard (such as a sewage line break or other high-risk
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contamination source) or a safety issue (such as dangerous rip tides) is present. The closing
message is usually presented in a commanding tone that leaves no doubt that the message should
be followed. An advisory, on the other hand, sends a different message because it suggests that
the beachgoer consider the information in determining whether to follow the recommendations.

Risk communicators typically take two basic approaches with advisories (USEPA 2011):
   •   Informing the public of the potential risk of swimming in contaminated water so that
       people can make their own judgments and risk management decisions. Communication
       usually has a straightforward, matter-of-fact tone.
   •   Influencing the public by presenting a convincing argument why they should follow
       recommendations that safeguard their health. The message usually has a cajoling tone.

Selecting a communication approach depends on the beliefs and attitudes of the stakeholders.
Beliefs and attitudes, in turn, are shaped by many factors, including the credibility, accessibility,
and adequacy of the information sources. Lifestyle, perceptions, and the opinions of others also
play roles in behavior choices. Gaining an understanding of the beliefs and attitudes of
stakeholders is key when choosing a communication approach.

To keep the program dynamic and relevant, periodically updating objectives is one of the most
important ongoing tasks of the risk communication partnership.

5.2.2  Addressing Needs and Establishing Trust

5.2.2.1  Assessing the Information Needs of Stakeholders
A majority of beach actions issued by states and tribes are beach advisories. Unlike official
beach closings, cooperation is voluntary; people must make up their own minds about following
advisories.

At one extreme, some in the community will accept the advisory recommendations, no questions
asked. Perhaps they deem the issuing agency trustworthy and committed to looking out for their
welfare. Perhaps they experienced sickness after swimming in contaminated water and do not
want to repeat the unpleasant episode. Whatever the motivation, these people need no further
information to convince them to follow an advisory recommendation.

At the other extreme, some will reject the advisory recommendations outright. They might think
the issuing agency is untrustworthy or simply mistaken. They might believe they are immune to
waterborne disease because they have never become sick from swimming. Perhaps they feel the
benefits associated with their water recreation activities are worth the risk of getting sick.
Whatever the reason, these people will likely never change their beach-going behavior because
of an advisory notification.

Most stakeholders fall somewhere between those two extremes. They are open to the
recommendations but need more background information or rationale to convince them to follow
the recommendations. For that reason, it is important to study the target audiences and assess
both their informational needs and the best methods for delivering information to them. Such
assessments are critical for establishing trust.
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5.2.2.2  Establishing Trust
Usually risk communication messages are judged primarily on the basis of whether the source
can be trusted, and only secondarily on the basis of the message itself (USEPA 2011). EPA
developed the Seven Cardinal Rules of Risk Communication (USEPA 1988) to help risk
communicators foster credibility and trust within a community:
    1. Accept and involve the public as a legitimate partner, identifying stakeholder groups
       and incorporating their concerns and perspectives in communication strategies.

    2. Plan carefully and evaluate communication efforts, establishing clear objectives and
       developing two-way communication.

    3. Listen to the public's concerns,  making no assumptions about what people know, think,
       or want done about risks.

    4. Be honest, frank, and open, not minimizing or exaggerating the level of risk and
       discussing data uncertainties, strengths, and weaknesses.

    5.  Coordinate and collaborate with other credible sources, releasing information through
       other credible organizations as appropriate.

    6. Meet the needs of the media, being open  and accessible to reporters.

    7. Speak and write simply and clearly, using nontechnical language.

5.2.3  Crafting Beach Notifications
Performance criterion 1 in chapter 3 addresses the process for evaluating beaches and classifying
them into a tiered ranking system on the basis of potential risks to human health and beach
usage. The tiered ranking system helps grantee agency administrators efficiently allocate
monitoring and public notification resources among the beaches they manage.

This approach, however, does not absolve agencies from their mandated responsibility to
communicate potential health risks in a timely manner at any beach that has exceeded or is likely
to exceed a beach notification threshold. Therefore, at a minimum, states and tribes must post
notification of an advisory or closure (signs or their functional equivalent). Beyond this
minimum requirement, states and tribes  may choose to direct additional resources to beach
notifications.

5.2.3.1  Developing Notification Content
The content of a beach advisory refers to the complete set of information in an  advisory (USEPA
1995). Most advisories include the following:
    •   Core recommendations, which state the specific actions beachgoers should take to
       protect and preserve their health.
    •  Supplemental information, which supports the core recommendations. Depending on the
       approach, the information can be designed to inform or influence stakeholders to follow
      the core recommendations.
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The content of core recommendations is derived from the state, tribal, and EPA risk assessment and
management processes in conjunction with the established policy and procedures of the responsible
agency. A core recommendation should be simple, clear, and authoritative. For example:
    •   For beach closings:
       -  Beach Closed—No Swimming—No Wading.
       -   Stay Out of the Water.
       -  Keep Out—Contaminated Water.
    •   For beach advisories:
       -  Warning—Water Contact Might Cause Illness.
       -  Caution—Water Quality Advisory.
       -  Water Quality Today Is Rated Poor.
Supplemental information, on the other hand, is crafted considering several factors, including the
objectives of the communication program, the informational  needs of the stakeholders, the
communication approach (informing or influencing), and the type and limitations of the
dissemination method. Most supplemental information fits into one of four broad categories:
    •   Information about the current action.
       -  Location or beach length affected by the action.
       -  Reason for the  beach action (e.g., high levels  of fecal bacteria).
       -  Duration of the beach action (e.g., resampling and conditions to be met before the
          action is lifted).
       -  Cause or source of the contamination (e.g., untreated sewage, sewer line break, and
          high runoff).
       -   Scales of risk (e.g., high, medium, and low).
    •   Information about the monitoring program and action policies.
       -  Water quality sampling (e.g., schedule, indicator bacteria, and pathogens).
       -  Monitoring results that trigger an action (e.g., instantaneous criterion and rolling
          average criterion).
       -  Monitoring limitations (e.g., lag between sampling and lab results).
       -  Water quality trends (e.g., past notification actions).
    •   Behavior modification and instructions.
       -  List of unsafe activities (e.g., swimming and wading).
       -  Potential consequences of swimming in contaminated water (e.g., gastritis and ear
          infection).
       -  Reporting a beach-related illness (e.g., hotline).
    •   Agency information.
       -  Contact information.
       -   Sources of additional information (e.g., website and other outreach efforts).
       -  Agency follow-up to  address the problem.

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5.2.3.2  Selecting Notification Methods
State beach program managers typically use a combination of notification methods to reach the
diversity of stakeholders in the community and the nonresidents that might travel to the beach.
Whatever methods are selected, they should be designed so that they complement and reinforce
each other (USEPA 2011). For example, beach signs, which are necessarily limited in size and
scope, should reference a website or source with more detailed information.

The basic  challenges for the risk communicator are to identify the various stakeholder groups
and match them with effective notification methods given the constraints of agency resources.
States and tribes might choose to direct additional resources to higher-priority beaches. For
example, a state or tribe might determine that low-cost tools, such as news releases (discussed in
section 5.4.2) and notices on a website (discussed in section 5.4.3.1) are appropriate for Tier 2
and 3 beaches and that, in addition, social media tools (discussed in section 5.4.4.3) and
electronic signs are appropriate for Tier 1 beaches.

Divergent groupings of stakeholders might be best reached through different methods of
communication:
    •  Older versus younger beachgoers. Younger people are more likely to use social media
       (e.g., Facebook and Twitter) than are older beachgoers, who typically prefer newspapers,
       radio, television, and other traditional media for their news.
    •  Active versus inactive information seekers. Some people are more willing than others to
       actively seek out water quality information before  deciding to go to the beach.
    •  Tourists versus locals. Residents are more familiar with local information outlets,
       whereas nonresidents tend to rely on large-scale public media outlets such as state
       websites.
    •  Differing cultural backgrounds and practices. Often different cultures use completely
       different information outlets, a problem compounded if language barriers also exist. In
       this case, messages should be translated.
    •  People who receive information before visiting the beach versus people at the beach.
       For some beachgoers, the only time to communicate information to them is while they
       are at the beach. They do not seek out information before their trip to the beach.
  Example of Notice in Spanish
  Aviso! Corriente de agua/agua del drenaje de tormenta puede causar enfermedades. Evite
  contacto con agua de desague y con el area donde desemboca al oceano.
  Division de Salud Ambiental del Condado de Orange. Para mas informacion llamar al
  714-667-3752.
  English Translation
  Warning! Runoff or storm drain water may cause illness. Avoid contact with ponded or flowing
  runoff and the area where runoff enters the ocean.
  Orange County Environmental Health Division. For further information, call 714-667-3752.
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5.2.4  Evaluating Public Notification and Risk Communication Plans

Evaluations of both new and established public notification and risk communication plans are
useful to ensure that the plans continue to meet the needs of the public and the objectives of the
state agency. A state or tribe should conduct periodic evaluations to document the short- or long-
term results of its public notification and risk communication plan 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.

States and tribes do not need to wait until the end of a beach season to evaluate plan
implementation.  Evaluation activities can include regular contacts with communication partners
(media personnel, website owner, and stakeholders) to evaluate the timing and adequacy of
advisory information. It can also be useful to interview stakeholders or focus groups or conduct
mail and telephone surveys to assess how well the advisory information is reaching the target
audience and how receptive they are to that information. A large sample size is often needed for
the plan evaluators to measure statistically significant outcomes and effects in large regions
(e.g., statewide).

Before developing a public notification  and risk communication plan, or while evaluating or
updating the plan, a state or tribe can mail surveys or conduct them over the telephone to obtain
feedback from a  subset of the target audience.  The  state or tribe can use the survey to determine
the public's knowledge about the following:
   •  Human health risks of swimming in contaminated water.
   •  Specific advisory recommendations.
   •  The advisory process.

Questions to ask include:
   •  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?
   •  Are signs, press releases, websites, and social media presenting appropriate and accurate
       information?
   •  How many people pay attention  to communication  methods such as beach signs and
       physical barriers?
   •  How many people actually contact a telephone hotline, visit a website, sign up on
       Facebook or Twitter, or choose to receive text messages to obtain water quality
       information for a beach?

A state can design a survey to assess 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.
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5.2.5  When to Notify EPA and Local Governments
As part of performance criterion 6, states and tribes must develop public notification and risk
communication plans that identify measures to notify EPA and local agencies with jurisdiction
over the land adjoining the beach of water quality exceedances. The annual reporting under
performance criterion 8 satisfies this requirement to notify EPA. States must notify local
agencies whenever they issue a notification action.

5.3  When to Issue and  Remove a  Notification

A public notification and risk communication plan should establish clear policies and procedures
for each type of notification the responsible agency uses. As general guidance, EPA recommends
that as soon as the lab analyzes and reviews sampling data, the lab should report them to the
beach or program manager. In addition to how and when to issue a beach advisory or closing, the
plan should include the conditions that must be met to lift the advisory or closing. It should cover
all the methods  the state or tribe might use to issue an advisory, including sampling results,
preemptive advisories, and predictive tools.

5.3.1  When to Issue a Notification

As soon as the data reviews and data quality assessment are completed, based on sampling,
modeling, or preemptive advisories, concentrations for the specified bacterial indicators should
be reported to the beach manager. If a sample indicates that there is an exceedance or a likely
exceedance of a WQS or other notification threshold value, the state or tribe must immediately
issue a public notification according to the policy and procedures established in the public
notification and risk communication plan unless there is a reason to doubt the accuracy of the
first sample. If there is doubt (based on predefined QA measures), the responsible agency should
resample.

If the decision is to resample, the resampling should be done in accordance with the discussion in
section 4.3.2.3.  If the decision is to notify the public, EPA recommends the following actions:
   •  Prompt  notification of the owner, manager, or operator and/or the lifeguards.  When
       sample results indicate an exceedance of a beach notification threshold, the appropriate
       agency must promptly notify the beach manager/operator and appropriate staff members
       (e.g., lifeguards). This approach ensures that the responsible authorities know that action
       should be taken to ensure the safety of the beach employees.
   •  Prompt public notification.  The appropriate agency must promptly notify the public of
       an exceedance of a beach notification threshold—by either a sign or functional equivalent
       (see section 5.4). Notification typically should occur at the point of beach access. States
       and tribes must promptly issue a notification when there is an exceedance of a beach
       notification threshold based on modeling results or a preemptive threshold.
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5.3.2  When to Remove a Notification

EPA recommends that states and tribes follow these procedures at all beaches before lifting an
advisory or closing:
   •   For advisories based on sampling results, sample and compare the bacterial
       concentrations with the applicable WQS or other applicable thresholds to determine
       whether the levels no longer exceed the threshold.
   •   In the case of a preemptive advisory, remove an advisory or reopen a beach after the
       number of hours or days identified in the advisory has elapsed after the event or
       condition. A state or tribe could also sample before lifting a preemptive advisory. Best
       professional judgment could also be used to supplement the decision to reopen a beach. A
       state or tribe should develop protocols for preemptive advisories.
   •   Beach advisories imposed on the basis of a predictive model could be lifted when an
       additional model run estimates that water quality conditions have improved to within
       acceptable parameters or, alternatively, when the results of a water quality sample show
       that indicator densities once again meet the applicable threshold.

5.4 Actions to Notify the Public (Performance Criterion 7)

Programs funded with BEACH Act grants must notify the public (i.e., post signs or use
functionally equivalent communication measures) of an exceedance of a beach notification
threshold. Functionally equivalent communication measures are those that effectively
communicate to the target audience the potential health risk in a manner at least as timely as
posting signs at the beach.

A functionally equivalent measure at the point of access could be a visual notice such as a flag  at
a beach or personal interaction with beach or park personnel. Other functionally equivalent
measures not provided at the point of access include mass media (newspapers, television, and
radio), websites, telephone hotlines, and Internet tools.

Historically, traditional forms of mass media such as newspapers, television, and radio were
commonly used to communicate notification information to stakeholders. Although such
traditional forms of mass media remain important information sources for many segments of the
community, the development of the Internet and electronic media has eroded their importance to
other segments. Consequently, risk communicators should identify the various stakeholder
groups and then match the notification methods to the way each group gets its  news.

A beach or program manager should consider the type of beach and its tier when selecting the
appropriate notification measures.  The measures chosen should be consistent with the  risk and
use of the beach, as described in chapter 3.

5.4.1  Beach Signs
Beach signs are the most direct way to communicate a notification action to people at the beach.
The signs should be where people are most likely to see and read them;  beach entrances, access
points, and lifeguard stations are common choices. It is important that the core message content
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(see section 5.2.3.1) is large enough to be read from a distance, and the sign itself should have
design qualities that attract the eye. Electronic signs can also be used, as they are in Huntington
Beach, California, and other places.

Emphasize and enhance core content by using the following:
    •   Capital letters, boldface fonts, and exclamation points.
    •   Vivid colors for the text or background; red, orange, and yellow
       are the most common.
    •   Images or icons, such as a stop sign or the universal "no" symbol
       (figure 5-1).
    •   Eye-catching sign shape.                                         Figure 5-1. The
                                                                      universal symbol for
    •   Attention-grabbing graphics.                                     "No."

Because signs have limited space, any supplemental content should be brief and to the point.
(See the New York City Department of Health and Mental Hygiene case study in the text box
below.) EPA recommends that signs include a reference to where further information can be
obtained.

In addition to posted beach signs, notification information can often be displayed at other
locations at the beach, such as parking lots, bathhouses, and lifeguard stands. Permanent posters
in those locations that provide more in-depth information about the beach program, water quality
monitoring, and other issues can  also be developed.

The Centers for Disease Control  and Prevention's Healthy Swimming and Recreational Water
website contains excellent health promotion materials such as brochures, fact sheets,  and graphic
(funny and eye-catching) posters about healthy swimming behaviors.  The website is at
http://www.cdc.gov/healthywater/swimming/resources/index.html.
  Tips to Improve the Effectiveness of Signs
     •   Use a standard format for notification signage throughout the state so it is familiar and
         easily recognizable to beachgoers.
     •   Change signage promptly when bacteria levels change.
     •   Provide signage in other languages if non-English-speaking people use the beach.
     •   Use a scale to communicate the severity of the risk. For example, a green, yellow, and red
         scale is often used to indicate low, medium, and high  levels of bacteria.
     •   Make the sign as sturdy and vandal-proof as possible.
     •   Avoid small print and technical jargon.
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                                      Chapter 5
  New York City Department of Health and Mental Hygiene New Texting Program
  In 2013 the New York City Department of Health and Mental Hygiene (DOHMH) conducted focus
  groups and intercept surveys of beach patrons in an effort to improve risk communication to the
  public when beach water quality exceeds acceptable standards. In response to public input on
  several beach signs, DOHMH developed new public notification signs for its beach water quality
  warnings. These signs communicate the core recommendations clearly and directly and provide
  supplemental information on the basis for the advisory or closure.
      WARNING
   BEACH
   CLOSED
        Swimming and wading are
        not recommended.

        Water ts contaminated with sewage or storm runoff, which may cause
        vomiting, diarrhea, respiratory illness or infections. Children, pregnant
        women, the elderly and the chronically ill are at higher risk.
      For beach status update
      Text BEACH to 877-877 or call 311
   For beach status updates
   Text BEACH to 877-877 or call 311
  DOHMH also developed a free texting service for the 2014 beach season so you can "Know
  Before You Go" if your beach is open, under advisory, or closed. Beachgoers can enroll by
  texting the word "beach" to 877-877 to receive on-demand updates on the status of a beach by
  texting the name of the beach.
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                                       Chapter 5
  OPEN:

      *BEACH NAME* is OPEN. To learn more about water quality sampling and the DOH Beach
      Program, go to: http://maps.nyc.gov/beach/.
  ADVISORY;

      WARNING: Swimming and wading at *BEACH  NAME* is NOT recommended at this time.
      Water is contaminated with sewage or storm runoff. For more info, text WHY.
  CLOSED:

      *BEACH NAME* is CLOSED. By Order of the Health Department, swimming and wading
      are not considered safe at this time. For more info, visit: http://maps.nyc.gov/beach/.
  This texting service was accompanied by a media and advertising strategy to promote the
  texting service. Other jurisdictions might wish to consider incorporating texting services into
  their public communication strategies.
                                                Be aware of warnings or closures before you go to the beach.
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5.4.2  Traditional Mass Media
The news release is the key mechanism for providing notification information to newspapers,
radio, television, and other traditional media outlets. Some local jurisdictions include beach
conditions in their weather reports. Risk communicators should treat the news media as another
target audience to assess and cultivate. The objective is to have the notification content promptly
published or announced over the air.  This is more likely to happen if relationships and protocols
are established before a beach action. Communicators should learn the informational needs and
preferences of each media outlet they plan to use, including how it wants the news release
formatted and delivered to it. That groundwork will help to ensure that notifications are
published correctly and in a timely manner.

News releases should be factual, accurate, and carefully proofread. News releases should be
written with short sentences, using no jargon, and in the active voice.  Generally, they should be
no longer than one  page. Where possible, risk communicators should emphasize that a beach
notification news release is an urgent matter involving public safety. Consider, for example,
having the local public health agency issue the release instead of a beach administrative office.
Writing "NEWS RELEASE FOR PUBLIC HEALTH AND SAFETY" and "FOR IMMEDIATE
RELEASE" in large, bold letters at the top of the news release also helps to emphasize its
importance.

Some media outlets will publish or announce the news release  content exactly as written. Others
might use only the first one or two paragraphs. Consequently, it is crucial to have the core
content appear at the beginning of a release, saving the least important information for the end.

As with a beach sign, risk communicators should present the core content in a style that is
authoritative and attention-grabbing;  for example, "(Named Beach) Closed Because of High
Bacteria Levels." The most important secondary content should immediately follow the core
content. The news release should conclude with the name, title, and contact information  of a
person the media outlet can reach for additional  information or clarification.

5.4.3  Methods that Allow Stakeholders to Anonymously Seek Out Information
Motivated stakeholders who want to  learn the current status of a beach should be able to look up
the information themselves.  Websites and hotlines are examples of tools that fulfill this function
while allowing stakeholders to remain anonymous. Passive information sources like these,
however, require the risk communicator to develop a marketing effort to publicize and promote
their use and a plan for continually updating them to keep them current.

Actively marketing the availability of risk communication resources such as websites and
hotlines is critical for their success. Stakeholders will need to know the Web address or
telephone number to use them. That information should  be publicized and promoted in as many
locations as practicable, including the following:
   •   All outreach material, such as brochures  and newsletters,  for the beach program.
   •   Beach signs and posters.
   •   Media outlets, especially those that will receive notification news releases.
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5.4.3.1  Websites
Increased use of the Internet over the past decade has resulted in a corresponding rise in the
importance of using websites to convey information to the public. All the Great Lakes and
coastal states, two tribes, and many local jurisdictions maintain websites with beach advisory and
closing information. The job of the risk communicator is to ensure that a stakeholder seeking
beach status information can navigate to the beach status page quickly and easily. That can be
done in several ways, but perhaps the  simplest is to provide an eye-catching link on the home
page that leads directly to a beach status page.

The beach status page should be designed with the idea that readers want to quickly find the
information they are seeking. Similar to drafting news releases, the core content of any beach
notification should be up front and prominent. Supplemental information should be less
prominent but available to support the core content and inform or influence the reader to follow
the recommendations.

Of all the notification methods, a website provides the best opportunity to present extended
supplemental information about topics related to beach water quality, public notification, and
risk communication. For example, on  the "Where You Live" Web page
(http://www2.epa.gov/beaches/state-and-local-beach-programs), each jurisdiction's name is a
hotlink to its Web page. Another recommended link is to EPA's BEACON website at
http://watersgeo.epa. gov/beacon2/.

5.4.3.2  Hotlines
For stakeholders who do not use or have access to a computer, a toll-free telephone number
(hotline) is a method that allows people to quickly and easily obtain information about a beach's
status. Like a sign, the recorded content should be brief and to the point. In most cases, only the
core message can be relayed to the caller, along with where to find more information.

5.4.3.3  Smartphone Applications
Stakeholders who have smartphones might be able to download an application (app) that will
give them instant access to water quality conditions  at a beach. This technique is being used in
the Great Lakes states, where an app provides real-time information on public beach conditions,
including advisories and closures. Beachgoers can identify the beaches closest to them and save
information on their favorite beaches for future reference. For information about and to
download the BeachCast app, go to http://glin.net/beachcast/.

5.4.4  Methods that Rely on Stakeholders to Provide Contact Information to Receive
       Information
Several methods allow a risk communicator to send beach-related messages directly to a
stakeholder's computer, email,  text inbox, or social networking site. For that to happen, the
stakeholder should become aware of the service and then take an action to link into the system.
In addition to marketing the service, the communicator should develop and maintain a
distribution or subscription list  and implement a plan for continually keeping outreach efforts
current and relevant to stakeholder needs. Emails, text messages, RSS (Real Simple Syndication)
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feeds, Facebook posts, and Twitter feeds are examples of this form of communication. The link
to EPA's BEACON website (http://watersgeo.epa.gov/beacon2/rss.html) is an example of this
form of communication.

5.4.4.1  Email
Email is the most popular method of rapidly sending messages through the Internet to designated
recipients. Recipients can access the message at a time convenient to them and save it if they
desire. A challenge for the risk communicator is developing and maintaining a list of current
email addresses. In general, emails should be sent only when there is an important message to
communicate to stakeholders, such as a beach action. Frequent emails of lower importance might
cause recipients to routinely ignore them or classify them as spam.

The email message itself should be designed similar to a news release, with the core content up
front. Other tips include the following:
   •  Put the core message in the subject line.
   •  Keep supplemental messages concise.
   •  Include the program website address and encourage recipients to visit it for more
      information.
   •  Incorporate eye-catching graphics and photos to further enhance or illustrate the message.

5.4.4.2  Text Messages
The use of mobile phones, especially smartphones, is growing every year. Because people keep
them nearby at almost all times, these devices are becoming popular as an alert system tool.
Beach notifications, because of their health and safety ramifications, can be perceived as
important information worthy of a special alert from the beach program. Creating a text-
messaging list is similar to creating an email list. Thus, a challenge for the risk communicator is
to develop a marketing plan to publicize and promote beach action notification through a text
message alert system.

The text message itself should be concise and focused on core content. Because many phones
have Internet capability, the message can also provide a link to the beach website, where the
recipient can get additional information. See the New York City DOHMH case study.

5.4.4.3  Social Networks
Social networking is an evolving phenomenon that allows people to easily communicate with
others who have similar interests.

Twitter is a free Web application that allows a user to send messages of up to 140 characters
(called tweets) to the email addresses or mobile phone numbers of people who have signed up to
follow the user's feed. Twitter is versatile, and messages can be composed and sent from
computers, mobile phones, and other devices.

Facebook is another social networking tool that lets individuals or organizations  communicate
with one another. Basically, risk communicators can create a beach program  profile page and use
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it to send beach status and other relevant information to a network of Facebook friends. The
messages show up as newsfeeds on the Facebook pages of recipients.

As always, to make social media effective as a communication tool, risk communicators should
undertake a marketing campaign to get stakeholders to sign up for the beach program input.

Chicago uses a multifaceted approach to communicate with beachgoers—flags, signs, phone
hotline, website, and social media. Details are  provided in the text box below.

5.4.4.4 RSS Feeds
RSS is a quick and easy way to alert stakeholders of breaking news at a beach. Basically, when
new information, such as a beach notification,  is added to the beach website, the risk
communicator would also add it to a list on the site's RSS feed page. People who subscribe to
the RSS feed would be alerted that new information has been added on the site. They can then
access it directly by clicking a link that takes them to the appropriate Web page.

5.5  Notification Report Submission (Performance Criterion  8)

Performance criterion 8 requires grant recipients to compile their notification activities and
report them in a timely manner. States and tribes must report their notification data to EPA at
least annually. Reported  data must be consistent with the database schema for PRAWN found at
http://water.epa.gov/grants funding/beachgrants/datausers index.cfm#notify. The data elements
include beach description data, beach program data, station and method identification data, and
beach advisory and closing data.  For more information about data submission,  see EPA's
website at http://water.epa.gov/grants_funding/beachgrants/datausers_index.cfm.

5.6  Delegation of Notification Responsibilities (Performance
      Criterion 9)

Performance criterion 9 requires state grant recipients to describe any delegation of notification
responsibilities to local governments. States must notify EPA, at least annually, of changes in
any delegation of responsibilities. EPA encourages states to coordinate with local governments
and to delegate to local governments, as appropriate, responsibilities for monitoring and
notification programs. Local governments have traditionally  played a lead role in administering
beach protection programs.

People at the local level take responsibility for protecting recreational waters for many reasons.
For example, local citizens and officials often  are more familiar with local problems and needs
and might be 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.
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  Chicago: Using a Multifaceted Approach to Communicate with Beachgoers
  The Chicago Park District (CPD) is responsible for managing 31 beaches in the Chicago area, which
  receive an average of 20 million visitors each summer. CPD launched a multifaceted
  communications campaign for its beach program to better reach a diversity of stakeholders to
  effectively communicate current beach conditions and ways to keep the beach clean.

     Flags and signs
     For beachgoers already at the beach, CPD uses colored flags to notify the public of water
     quality and weather-related beach conditions. Green indicates no issue reported, yellow
     indicates that a swim advisory is in effect (swimming with caution), and red indicates that
     swimming is prohibited because of severe weather or water conditions that might be
     hazardous. A sign at the beach explains the meaning of the flag color.

     Phone hotline and website
     CPD uses other methods to notify beachgoers of beach conditions before they go to the beach,
     including a phone hotline (which might reach older beachgoers) and a website (a good source
     for nonresidents).

     Social media
     Social media were added to CPD's communications campaign in 2009 as a way to reach out to
     younger beachgoers. The CPD Facebook wall (http://www.facebook.com/ChicagoParkDistrict)
     provides daily  beach status updates, posts announcements for events at beaches, and allows
     the public to interact with CPD staff by asking questions or communicating their likes and
     dislikes. The interactive nature of the Facebook site seems to have been well received by the
     public. CPD also sends out announcements using Twitter (http://twitter.com/chicagoparks). In
     2010 CPD launched a new texting service that allows users to receive beach notification
     messages about one or more of the city's beaches.

     Park-and-display service boxes
     To reach beachgoers who might otherwise miss or not have access to the various notification
     methods, CPD  posts the beach status at the entrance to the beach (before paying for parking)
     with park-and-display service boxes.

  CPD has received considerable media attention for its use of novel approaches to reach the public.
  The use of Facebook, Twitter, and the texting service  received wide coverage in Chicago media,
  which might have helped raise awareness of the program. Another  potential factor influencing
  public interest in the social media tools is the combination of information that CPD communicates.
  For example, CPD's continuing to post cultural events of interest to the public on its Facebook page
  during winter months when beaches are closed might encourage people to continue to receive or
  sign up for the updates. As of January 2011, CPD had more than 4,000 Facebook friends and
  nearly 2,000 Twitter followers. Between June 7, 2010, when the service was launched, and the
  end of the swimming season  in September, about 15,000 text messages were delivered to
  beachgoers at their request. About as many people (12,000 to 15,000) visited the CPD website
  weekly.

  In addition to communicating current beach conditions, CPD performs outreach to educate
  beachgoers about  how to keep beaches clean. The park staff performs direct outreach by going
  on-site at Chicago's most popular beaches, encouraging people not to feed gulls and teaching
  them how to properly dispose of litter. The District has also developed a 30-minute cable episode
  to provide similar information.
     Information for this case study was obtained from the report Assessing the Effectiveness of the
     Beaches Environmental Assessment and Coastal Health (BEACH) Act Notification Program
     (USEPA 2011), which can be found on EPA's website at
     http://www.epa.aov/evaluate/pdf/beach-act-evaluation-final-report.pdf.
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5.7 Chapter 5 References

USEPA (U.S. Environmental Protection Agency). 1988. Seven Cardinal Rules of Risk
       Communication. OPA-87-020. U.S. Environmental Protection Agency, Washington, DC.

	. 1995. Guidance for Assessing Chemical Contaminant Data for Use in Fish Advisories.
       Vol. 4, Risk Communication. EPA 823-R-95-001. U.S. Environmental Protection
       Agency. Washington, DC.
      -. 2011. Assessing the Effectiveness of the Beaches Environmental Assessment and
       Coastal Health (BEACH) Act Notification Program. EPA-100-R-11-004. U.S.
       Environmental Protection Agency, Office of Policy, Washington, DC.
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Glossary


B

Beach Action Value (BAV) - The beach notification threshold derived from the 75th percentile
value on the illness risk distribution for the recommended 304(a) criteria: 32 NGI per 1,000
recreators and 36 NGI per 1,000 recreators. It is a conservative value used for making beach
notification decisions (i.e., advisories or closures), and it was introduced in EPA's 2012
Recreational Water Quality Criteria.

Beaches Environmental Assessment and Coastal Health (BEACH) Act - An amendment to
the CWA passed in 2000. The Act authorizes EPA to provide grants to coastal and Great Lakes
states, territories, and eligible tribes to monitor their coastal beaches for bacteria that indicate the
possible presence of disease-causing pathogens and to notify the public when there is a potential
risk to public health.

BEACH Act beaches - Coastal and Great Lakes beaches or similar points of access used by the
public for swimming, bathing, or other such activities.

Beach advisory - Recommendation to avoid swimming at a beach or beach area because of an
increased risk of contracting a waterborne illness.

Beach Advisory and Closing Online Notification (BEACON) - Database of pollution
occurrences and notification actions for coastal recreation waters developed and maintained by
EPA.

Beach closing - Official closure to the public by a state or tribe of a beach or beach area.

Beach use - A factor used to rank beaches in the BEACH Act grant-funded program that refers
to the usage of the beach by the public.

Beach notification - An action, such as an advisory or closing, that an agency issues to notify
the public when a beach has exceeded (or is likely to exceed) an applicable WQS or other beach
notification threshold.

Beach notification threshold - A water quality value selected by a state or tribe that is used to
"trigger" a beach notification.
Clean Water Act (CWA) - Establishes the basic structure for regulating discharges of
pollutants into the waters of the United States and regulating quality standards for surface waters.
The basis of the CWA was enacted in 1948 and was called the Federal Water Pollution Control
Act, but the act was significantly reorganized and expanded in 1972. "Clean Water Act" became
the act's common name with amendments in 1972.
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Coastal recreation waters - Great Lakes and marine coastal waters (including coastal estuaries)
designated under CWA section 303(c) by a state or tribe for use for swimming, bathing, surfing,
or similar water contact activities.

Code of Federal Regulations (CFR) - A codification of the final rules published in the Federal
Register. Title 40 of the CFR contains the environmental regulations.

Colony-forming unit (CFU) - A viable cell grown on or in  a non-liquid medium culture
method, where each distinct colony is assumed to be derived from a single viable cell.

Combined sewer overflow (CSO) - A discharge of untreated wastewater from a combined
sewer system at a point prior to the headworks of a publicly owned treatment works. CSOs
generally occur during wet weather (rainfall or snowmelt). During periods of wet weather, these
systems become overloaded, bypass treatment works, and discharge directly to receiving waters.

Combined sewer systems - A wastewater collection system that conveys sanitary wastewaters
(domestic, commercial, and industrial wastewaters) and stormwater through a single pipe to a
publicly owned treatment works for treatment prior to discharge to surface waters.
D
Data quality objective (DQO) process - A process used to establish performance or acceptance
criteria.
Fecal indicator bacteria (FIB) - Bacterial groups or species that are naturally found in the guts
of warm-blooded animals and excreted in high densities in the feces. They indirectly indicate the
presence and quantity of fecal pathogens in ambient water.
G
Geometric mean (GM) - The mean of the logarithms of recreational water bacterial indicator
densities in modeling risk attributable to swimming in contaminated waters.
N
National Epidemiologic and Environmental Assessment of Recreational (NEEAR) Water
Study - A collaborative research study between two laboratories of EPA and the Centers for
Disease Control and Prevention that investigated human health effects and rapid water quality
methods associated with recreational water use. This study provided real-time water quality
measurements and helped better understand the link between water pollution, swimming at the
beach, and peoples' health. A main goal of the NEEAR study was to determine how new ways of
measuring water pollution can be used effectively to protect swimmers' health.


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National Pollutant Discharge Elimination System (NPDES) - A national program under
CWA section 402 for regulation of discharges of pollutants from point sources to waters of the
United States. Discharges are illegal unless authorized by an NPDES permit.

NEEAR GI - A case of gastrointestinal illness within 10 to 12 days of swimming with any of
the following symptoms: (a) diarrhea (three or more loose stools in a 24-hour period); (b)
vomiting; (c) nausea and stomachache; or (d) nausea or stomachache and impact on daily
activity. NEEAR GI is the definition associated with EPA's 2012 Recreational Water Quality
Criteria.

Non-program beaches - BEACH Act beaches not in a state's or tribe's current monitoring and
notification program, including beaches not monitored because of fiscal constraints.
Pathogen - Microorganisms that have the potential to cause disease in a host.

Pathogen indicator - A substance that indicates the potential for human disease as defined by
the BEACH Act (33 U.S.C. 1362(23). Pathogen indicator is a broad category of entities
(including chemical and biological parameters) that can be used to indicate the presence of
pathogens in water.

Predictive tools - Statistical regression models, rainfall-based notifications, decision trees or
notification protocols, deterministic models, or any combination of these tools used to predict an
exceedance or likely exceedance of a WQS or other notification threshold value.

Primary contact recreation - Recreational activities where immersion and ingestion are likely
and there is a high degree of bodily contact with the water, such as swimming, bathing, surfing,
water skiing, tubing, skin diving, water play by children, or similar water-contact activities.

Program beaches - BEACH Act beaches subject to a state's or tribe's BEACH Act monitoring
and notification program, consistent with the performance criteria.

Publicly owned treatment works (POTWs) - Wastewater treatment works owned by a state or
municipality (as defined by CWA section 502(4)) that include any devices and systems used in
the storage, treatment, recycling, and reclamation of municipal sewage or industrial wastes of a
liquid nature. It also includes sewers, pipes, and other conveyances only if they convey
wastewater to a POTW.
Q
Quantitative microbial risk assessment (QMRA) - A formal process, analogous to chemical
risk assessment, for estimating human health risks due to exposures to selected infectious
pathogens.
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Quantitative polymerase chain reaction (qPCR) - A genetic test used to quantitatively
determine the amount of DNA template in a sample relative to a standard.
R
Recreational Water Quality Criteria - CWA sections 304(a) and 304(a)(9) recommendations
issued by EPA as guidance to states, territories, and authorized tribes in developing WQS to
protect swimmers from exposure to water that contains organisms that indicate the presence of
fecal contamination.

Risk - A factor used to rank beaches in the BEACH Act grant-funded program that refers to the
susceptibility of a beach to fecal contamination.
S
Sanitary sewer overflows - Untreated or partially treated sewage overflows from a sanitary
sewer collection system.

Sanitary survey - Detailed site characterization that compiles information on pollution sources
(such as streams or stormwater outfalls) at a beach, physical features on or near a site, land use in
adjacent areas and in the watershed that drains to the site, and other sources that could regularly
influence water quality.

Statistical Threshold Value - Approximates the 90*  percentile of the water quality distribution
for the 2012 RWQC and is intended to be a value that should not be exceeded by more than 10
percent of the samples taken for assessment and listing purposes.
Tier 1 beaches - Highest priority beaches because of high risk and/or high use.

Tier 2 beaches - Beaches with high or moderate use and moderate or low risk.

Tier 3 beaches - Beaches with low use and low or very low risk.

Tiered monitoring plan - Plan that addresses the frequency and location of monitoring and the
assessment of coastal recreation waters on the basis of the periods of recreational use, the nature
and extent of use during certain periods, the proximity of recreational waters to known point and
nonpoint sources of pollution, and the effect of storm events.
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