Overview of Technical Support Materials: A Guide to the Site-Specific Alternative Recreational Criteria TSM Documents EPA-820-R-14-010 U.S. Environmental Protection Agency Office of Water Office of Science and Technology Health and Ecological Criteria Division December 2014 ------- TSM Guide Table of Contents Table of Contents i Acronyms ii About EPA's Technical Support Materials 1 Alternative Health Relationships 4 Non-Human Fecal Sources 5 Alternative Indicators and Methods 7 Questions and Answers 8 Why would I want to usetheseTSM documents? 8 Who can use these Technical Support Materials? 9 Is my site a candidate for site-specific alternative water quality criteria? 9 How do I decide which TSM to use? 9 Can I use these TSMs to develop site-specific alternative criteria for other designated uses? 10 What kind of information is useful in the sanitary characterization? 11 Conclusion 12 References 13 ------- TSM Guide Acronyms ATP Alternate Test Procedure CPU colony forming units CFR Code of Federal Regulations CWA Clean Water Act E. coli Escherichia coli EPA Environmental Protection Agency FIB fecal indicator bacteria, (e.g. fecal coliforms, E. coli, enterococci, Enterococcus spp.) Gl gastrointestinal CIS geographic information system GM geometric mean ml milliliters MPN most probable number MTF multiple tube fermentation MST microbial source tracking NEEAR National Epidemiological and Environmental Assessment of Recreational Water NGI NEEAR-GI illness NRC National Research Council QMRA quantitative microbial risk assessment qPCR quantitative polymerase chain reaction RWQC recreational water quality criteria TSM technical support materials U.S. United States WQ water quality WQC water quality criteria WQS water quality standard(s) WWTP wastewater treatment plant ------- TSM Guide About EPA's Technical Support Materials This Guide to the Technical Support Materials (TSM) documents is designed to help users evaluate site information and decide which tools would best support the development of site- specific alternative water quality criteria (WQC) that are scientifically defensible and protective of the recreational designated use. The Environmental Protection Agency's (EPA) nationally recommended recreational water quality criteria (RWQC) are broadly applicable for ambient waters designated for primary contact recreation. However, there are waterbodies with conditions that differ from those studied and used to inform EPA's 2012 RWQC. Water quality managers may want to consider WQC reflective of specific conditions or may want to use a different indicator of fecal contamination and/or enumeration method. Text Box 1: Clean Water Act and Establishing WQC EPA's implementing regulations for §303 of the CWA provide that "states must adopt those WQC [water quality criteria] that protect the designated use. Such criteria must be based on sound scientific rationale and must contain sufficient parameters or constituents to protect the designated use." (40 CFR §131.11(a)). EPA's regulations stated in 40 CFR §131.11(b)(l) provide that "In establishing criteria, States should (1) Establish numerical values based on (i) 304(a) Guidance; or (ii) 304(a) Guidance modified to reflect site-specific conditions; or (iii) Other scientifically defensible methods." WQS can be established for waterbodies or a portion of a water body and therefore they could be established for a specific site, such as a waterbody adjacent to a beach or the entire water body that is anticipated to have uniform qualities throughout. When EPA reviews adopted state WQS for approval or disapproval under the CWA, EPA must ensure that the WQC in the standard (regardless of whether they are "site-specific") are scientifically defensible and protective of the designated use. States establish WQC and water quality standards (WQS) under the Clean Water Act (CWA) (see Text Box 1). EPA has previously indicated that States and Territories can use scientific approaches to propose alternative criteria. For example, EPA's 2004 Water Quality Standards for Coastal and Great Lakes Recreation Waters Rule indicates that States and Territories must apply the Escherichia coli (E. coli) and enterococci criteria to all coastal recreation waters. If, however, sanitary surveys and epidemiological studies show the sources of the indicator bacteria to be non-human and the indicator densities do not indicate a human health risk, then it is reasonable for the State or Territory not to consider those sources of fecal contamination in determining whether the standard is being attained (U.S. EPA, 2004). This approach was also included in the 1986 criteria document (U.S. EPA, 1986). EPA also previously indicated that it would be reasonable for a State or Territory to use existing epidemiological studies rather than conduct new or independent epidemiological studies for every waterbody if it is scientifically appropriate to do so (U.S. EPA, 2004). These flexibilities are included in the Code of Federal Regulations (CFR).1 1 Footnote "e" to 40 CFR 131.41(c)(l) and footnote "c" to 40 CFR 131.41(c)(2) state: 'These values apply to [f. coli or enterococci] regardless of origin unless a sanitary survey shows that sources of the indicator bacteria are non- human and an epidemiological study shows that the indicator densities are not indicative of a human health risk." ------- TSM Guide The 2012 RWQC recommends fecal indicator bacteria (FIB) levels (Table 1 in U.S. EPA, 2012a) that appear similar to the 1986 water quality criteria (U.S. EPA, 1986). However, two fundamental differences exist between these criteria that contribute to the scientific foundation of the approaches for derivation of site-specific WQC in Section 6.2 of the 2012 RWQC. These differences were informed by the scientific progress made over the last few decades that contributed to our understanding of microbiology, water quality, risk management, and public health protection. Although states have always had the option of developing WQC tailored to their specific waters, demonstrating the scientific defensibility and protection of the designated use has, until now, been a difficult and potentially burdensome task. First, our understanding of the health effects associated with the historical levels of water quality recommended for public health protection has substantially progressed since 1986. Health studies informing the development of the 2012 RWQC and previous recommendations were conducted at sites predominantly affected by human fecal contamination in the form of secondary treated and disinfected effluent. There is a body of scientific evidence that indicates enteric viruses most likely caused the illnesses reported in those studies (Cabelli, 1983; Dufour, 1984; Seller et al., 2010a). The sources of fecal contamination determine the level and diversity of pathogens, and hence, the potential human health risks, which can be present in water. Similar health studies conducted at sites affected by non-human sources of fecal contamination have not provided a clear linkage between water quality measured by FIB and health effects. Although waters impacted by non-human fecal contamination have long been considered to confer less potential for health risks compared to human impacted waters, the ambiguous results of the health studies did not provide risk managers evidence of the potential health implications of recreational exposure to waters containing animal feces relative to waters containing human feces. Recent advances in human health risk assessment methodologies, source identification techniques, and microbiology have now provided the linkages that allow for the derivation of source- and site-specific WQC (Schoen and Ashbolt, 2010; Seller et al., 2010b; Wuertzetal., 2011). Second, the 2012 RWQC rely on a fundamentally different approach to derive the recommended values. The 1986 criteria recommended values for the culturable fecal indicator bacteria, enterococci and E. coli, were derived based on a proportional translation from the previous fecal coliform recommendations of 200 colony forming units (CFU) per 100 milliliters (ml). The reader is referred to the 2012 RWQC and other references for more discussion on the mathematics of this translation (Dufour and Schaub, 2007; U.S. EPA, 2012a). The values for enterococci and E. coli resulting from this translation were not directly linked to a specific illness rate, nor did they represent a potential risk management target. The 1986 criteria values simply represented an effort to carry forward historically accepted levels of water quality in terms of alternative fecal indicator bacteria (i.e., enterococci and E. coli) that the best available science at the time concluded were more effective at indicating potential fecal contamination. The health studies conducted by Cabelli (1983) and Dufour (1984) informed risk managers ------- TSM Guide about the potential for human illness that might occur following recreational exposure to waters containing levels of enterococci or E. coli at the recommended levels. In contrast, the 2012 RWQC recommendations have an underlying health basis. Using the results of National Epidemiological and Environmental Assessment of Recreational Water (NEEAR) study, EPA derived the current recommendations based on an adjusted odds ratio of gastrointestinal (Gl) illness below which there was no observed statistically significant increase in swimming-associated illness (U.S. EPA, 2012a). This significant increase in illness was first observed to occur at a geometric mean (GM) of 30 CPU enterococci per 100 ml, corresponding to 32 NEEAR-GI illness (NGI) per 1000 recreators. There was no significant difference between the swimming-associated illness rate at a GM of 30 CPU enterococci per 100 ml and a GM of 35 CPU enterococci per 100 ml, corresponding to 36 NGI per 1000 recreators. The 2012 RWQC recommendations for water quality based on an observed increase in illness provides the risk 'anchor' for evaluating the use protection of the alternative WQC. The 2012 RWQC document includes tools that can be used by states to develop site-specific alternative WQC for inclusion into WQS packages to be submitted to and evaluated by EPA. Site-specific alternative WQC need to be scientifically defensible and protective of the designated use. Further, it is incumbent upon the state to substantiate those attributes in their proposed WQS packages. Site-specific alternative WQC should reflect the conditions of the watershed including current land uses and potential sources of fecal contamination and thus, should be revisited no less frequently than triennially to ensure the site-specific alternative WQC remain protective of the designated use. For example, if a substantial source of fecal pollution [e.g., wastewater treatment plant (WWTP)] is added, drainage is altered, or further human growth occurs (e.g., new buildings) the site-specific alternative WQC should be reviewed. This guide will help you decide if your waterbody is a candidate for site-specific alternative criteria and determine which set of tools would be amenable for you to use in deriving site-specific WQC. For over a century, FIB have been used to protect public health (NRC, 2004). FIB have been used as water quality indicators because, among other things, they tend to be more numerous than pathogens in human fecal material, thus are a cheaper, safer, and easier target to enumerate for gauging ambient water quality. However, increasing numbers of scientific studies have demonstrated the existence of non-fecal sources of FIB in environmental matrices (Fujioka and Byappanahalli, 2003; Stewart et al., 2008; Byappanahalli et al., 2011; Van et al., 2011). Notable examples of potential non-fecal sources of FIB include sands and soils (Yamahara et al., 2007; Van et al., 2011), plant and periphyton-associated species (Ksoll et al., 2007; Badgley et al., 2010a,b; Ferguson, 2012), and growth in biofilms (Ferguson, 2006; Skinner et al., 2010). The relationship of the FIB from non-fecal sources to the occurrence and distribution of enteric pathogens and the potential for those microbes to predict human health effects in these examples has not been demonstrated (Halliday and Cast 2011; Viau et al., 2011; Shibata and Solo-Gabriele, 2012). Fecal, but non-human, sources of FIB also exist, but can co-occur with a different enteric pathogen profile relative to secondary treated and disinfected human wastewater effluent (i.e., the predominant source of fecal contamination impacting the ------- TSM Guide epidemiological studies informing EPA's 2012 RWQC). These profile differences can result in differences in potential relative health impacts (Schoen and Ashbolt 2010; Sinigalliano et al., 2010; Seller et al., 2010b; U.S.EPA, 2010a). Traditional culturable FIB have been crucial and successful in protecting public health and as advancements in science and technology occur, additional options become possible. The tools mentioned in this guide and discussed in more detail in the respective TSM documents present scientifically defensible and consistent approaches for understanding your site-specific information in context with water quality and human health risks. The TSM documents also discuss how you can use that information in the development of site-specific alternative water quality criteria. This guide provides an overview of the set of TSM documents that EPA is providing for development of site-specific alternative criteria (as discussed in Section 6.2 of EPA's 2012 RWQC document). This set of TSM documents discusses tools related to the following areas: 1. alternative health relationships (Section 6.2.1 in RWQC "Epidemiological Studies") 2. non-human fecal sources (Section 6.2.2 in RWQC "Quantitative Microbial Risk Assessment") 3. alternative indicators and methods (Section 6.2.3 in RWQC "Alternative Indicators or Methods") EPA plans to publish TSM documents corresponding to each set of these tools. The TSM documents will provide the detailed information that users need to determine which set of tools may be germane for their needs. They will also provide suggestions for gathering information and data to support the approach, conducting analyses, deriving site-specific alternative criteria, and preparing documentation for water quality standards packages. A brief synopsis of each set of tools follows. More detailed information can be found in each TSM document. These TSM documents will allow states to take advantage of the rapid and continuing advancements in the science of microbial water quality for use in their WQS. Alternative Health Relationships Recreational water epidemiological studies describe the probability of illnesses associated with exposure to fecal contamination as measured by FIB. It is important to note that the FIB do not necessarily cause illness themselves. Instead they are used to gauge the magnitude and extent of fecal pollution in a waterbody. Epidemiological studies with or without quantitative microbial risk assessment (QMRA) could be used to develop an alternative health relationship for a water quality metric. This alternative health relationship could inform the basis of site-specific alternative criteria. EPA's NEEAR epidemiological study was conducted in water primarily impacted by human fecal contamination, with the exception of one site that was impacted by urban runoff (U.S. EPA, 2010b; Wade et al., 2006, 2008, 2010). Statistically significant associations between water quality, as determined using EPA's Enterococcus spp. quantitative polymerase chain reaction (qPCR) Method 1611 (U.S. EPA, 2012b), and reported Gl illness were observed in the temperate marine and fresh water beaches impacted by WWTP. In the United States (U.S.) other agencies ------- TSM Guide have also conducted recreational water epidemiological studies. For example, epidemiological studies of recreational water exposures have been conducted in Southern California (Colford et al., 2012), Southern Florida (Fleming et al., 2006, 2008; Sinigalliano et al., 2010), and Ohio (Marion etal., 2010). Several factors can influence the potential epidemiological relationship between indicator density and the potential for human illness. Some of the potentially important factors include the source of fecal contamination, age of the fecal contamination, solar radiation, water salinity, turbidity, dissolved organic matter, water temperature, and nutrient content. Additionally, numerous factors also affect the occurrence and distribution of FIB and pathogens, including but not limited to: predation of bacteria by other organisms; differential interactions between microbes and sediment, including the release and resuspension of bacteria from sediments in the water column; and differential environmental effects on indicator organisms versus pathogens (U.S. EPA, 2010b; WERF, 2009). States or local agencies may choose to conduct epidemiological studies in their waterbodies and use the results from those studies to derive site-specific alternative criteria. To derive scientifically defensible alternative WQC for adoption into state standards, ideally the epidemiological studies should be rigorous, comparable to those used to support the 2012 RWQC, and peer-reviewed. However, smaller scale epidemiological studies may also provide a scientifically defensible foundation for alternative criteria. Additionally, QMRA (see section 6.2.2) can enhance the interpretation and application of new or existing epidemiological data (Boehm et al., 2009; Dorevitch et al., 2011; Seller et al., 2014). QMRA can supplement new or existing epidemiological results by characterizing various exposure scenarios, interpreting potential etiological drivers for the observed epidemiological results, and accounting for differences in risks posed by various types of FIB sources. The additional insights QMRA can provide in these situations may help inform site-specific alternative WQC development. The Site-Specific Alternative Recreational Criteria Technical Support Materials for Alternative Health Relationships document discusses approaches that can be used to document potential human health effects from exposure to feces-contaminated recreational waters. This TSM could be used for documenting the health relationship of new or existing indicators of fecal contamination and their associated enumeration methods to levels of reported illness, or for determining the site-specific health relationship at any site where site-specific epidemiological studies and/or QMRA are conducted. The TSM includes examples of how epidemiological data and QMRA can be used to derive site-specific alternative WQC. Special circumstances related to the waterbody characteristics (i.e., waterbody biology, chemistry, or physics), the demographics of bathers, or the nature of the source may lead to exploration of health relationship based site-specific alternative criteria. Non-Human Fecal Sources EPA believes the 2012 RWQC are protective of the primary contact recreational designated use for waterbodies affected by any source of fecal contamination. The 2012 RWQC was informed by studies conducted in WWTP effluent-impacted waters. Since all pathogens in human feces ------- TSM Guide are potentially infectious to humans, developing criteria recommendations based on these studies represents a prudent and health protective benchmark. However, there are scenarios of contamination from non-human sources and non-fecal sources of FIB that potentially present markedly different probability of illness relative to human sources. QMRA can be used as a basis to develop site-specific alternative criteria, where sources are characterized predominantly as non-human or non-fecal (U.S. EPA, 2009). EPA's research indicates that understanding the predominant source of fecal contamination could help characterize the human health risks associated with recreational water exposure. QMRA studies have demonstrated that the potential human health risks from human and non-human fecal sources could be different due to the nature of the source, the type and number of pathogens from any given source, as well as variations in the co-occurrence of pathogens and fecal indicators associated with different sources (Till and McBride, 2004; Roser and Ashbolt, 2006; Schoen and Ashbolt, 2010; Seller et al., 2010b; Wuertz et al., 2011). Further, research demonstrates that swimming-associated illnesses can be caused by different pathogens, which depend on the source of fecal contamination. For example, in human- impacted recreational waters, human enteric viruses appear to cause a large proportion of illnesses (Seller et al., 2010a). In recreational waters impacted by gulls and agricultural animals such as cattle, pigs, and chickens, pathogenic bacteria and protozoa are the likely etiologic agents of concern (Roser and Ashbolt, 2006; Schoen and Ashbolt, 2010; Seller et al., 2010b). The relative level of predicted human illness in recreational waters contaminated by non- human fecal sources can also vary depending on whether the contamination is direct or via runoff due to a storm event (Seller et al., 2010b; U.S. EPA, 2010a; Seller et al., 2014). To derive site-specific alternative criteria that are considered scientifically defensible and protective of the designated use, QMRA studies should be well documented, transparently presented, follow accepted practices, and rely on scientifically defensible data. A sanitary characterization can provide detailed information on the source(s) of fecal contamination in a waterbody to determine whether the predominant source is human or non-human. EPA developed a QMRA-specific sanitary survey2 application, which could be included in a sanitary characterization, to capture information directly applicable to a QMRA. At sites where non-human sources predominate, QMRA can be used to determine a different enterococci or E. coli criteria value that is equally protective as the recommended 2012 RWQC. Fundamental to this approach is a thorough understanding of the potential sources of fecal contamination impacting your waterbody. The TSM, Site-Specific Alternative Recreational Criteria Technical Support Materials for Predominantly Non-Human Fecal Sources, describes the process that can be used to document likely sources of fecal contamination impacting a waterbody. Fecal source tracking and identification methods can be used to substantiate the findings of the sanitary survey (i.e., human sources do not predominate). As described in the TSM, a sanitary characterization consists of conducting a sanitary survey and substantiating water quality data. The results of monitoring for pathogens and indicators can be used to 2 See: Site-Specific Alternative Criteria Technical Support Materials for Predominantly Non-Human Fecal Sources, Volume A, Appendix A. ------- TSM Guide conduct QMRA. EPA provides QMRA results from several conservative (health protective) scenarios where the predominant sources are from one or more of the following: gulls, pigs, chickens, and non-pathogenic sources. If users document that their site fits one of EPA's conservative scenarios, then EPA provides potential criteria values. Users also have the option of conducting QMRA for other non-human fecal sources and other site-specific parameters documented at a site. Alternative Indicators and Methods EPA anticipates that scientific advancements will provide new technologies for enumerating fecal pathogens or FIB. New technologies may provide alternative ways to address methodological considerations, such as rapidity, sensitivity, specificity, and method performance. As new or alternative indicator and/or enumeration method combinations are developed, states may want to consider using them to develop site-specific alternative criteria for adoption in WQS or as the basis for beach notification when a state does not plan to modify existing WQS. The TSM, Site-Specific Alternative Recreational Criteria Technical Support Materials for Alternative Indicators and Methods, describes a process for comparing enumeration methods that may allow users to take advantage of the rapid and continuing advancements in the science of microbial water quality. Text Box 2 contains examples of potentially useful newer enumeration methods and indicator organisms. Text Box 2: Newer Enumeration Methods and Indicators Some examples of new enumeration methods for FIB include: immunomagnetic separation/adenosine triphosphate, propidium monoazide qPCR, reverse transcriptase qPCR, covalently linked immunomagnetic separation/adenosine triphosphate, and transcription mediated amplification. New methods and additional improvements to currently available methods, platforms, and chemistries may also be developed in the future. Examples of possible alternative indicators include, but are not limited to Bacteroidales, Clostridium perfringens, human enteric viruses, and coliphages. These possible alternative indicator organisms could be used with new methodologies or methodologies similar to those recommended by the 2012 RWQC. For example, in one case, Bacteroidales measured by qPCR were highly correlated with Enterococcus spp. and E. coli when either culture-based methods or qPCR methods were used (Wuertz et al., 2011). The pathogens norovirus Gl and Gil have also been shown to be predictors of the presence of other pathogens such as adenovirus measured by qPCR (Wuertz et al., 2011). The evaluation of multiple FIB and enumeration methods has been used to describe a common level of water quality. For example, the derivation of EPA's 1986 criteria values was fundamentally based on the proportional comparison of multiple FIB: fecal coliform, enterococci, and E. co//. In those specific cases, comparisons were made among membrane filtration methods specific to each target organism. EPA has also approved other culture-based methods for the detection of enterococci and E. coli based on how those methods compare to EPA published methods. In this comparison, results from a membrane-filtration method were compared to another most probable number (MPN) method that relies on substrate-utilization and multiple tube fermentation (MTF). Rapid methods, such as E. coli enumerated by qPCR, ------- TSM Guide have already been evaluated against cultivable methods and have demonstrated utility on a site-specific basis (Lavender and Kinzelman, 2009). If a state adopts WQS using alternative indicator/method combinations, EPA will review those standards, including any technical information submitted to determine whether such standards are scientifically defensible and protective of the primary contact recreation use. To facilitate consideration of such standards, states may gather water quality data over one or more recreational seasons for the indicator/method recommended in the 2012 RWQC and the proposed alternative indicator/method combination. A robust relationship need not be established between EPA's recommendation and alternative indicator(s) for the whole range of indicator densities (U.S. EPA, 2010c). It is, however, important that a consistent and predictable relationship exist between the enumeration methods and an established indicator/health relationship in the range of the recommended criteria. If a state wishes to use an alternative indicator method without modifying existing WQS, then the alternative method should be a reliable predictor of the likelihood of an exceedance of the applicable WQS. As technology advances there may be newer indicators or methods that offer advantages over the EPA published methods. With this approach, a new indicator-method combination can be statistically compared to an EPA method recommended in the RWQC (Methods 1600, 1603, and 1611 or equivalent). This approach uses site-specific water quality data to demonstrate the statistical correlation and may be useful for new methods that will be developed in the future, if that method correlates with EPA's methods at the site under consideration. This TSM approach is different from EPA's Alternate Test Procedure (ATP) program because it is limited to site-specific use, allows different analytes to be compared, and uses actual environmental monitoring for comparing methods. Questions and Answers3 The following questions should help users determine which TSM best fits their needs. For clarity and ease of use, the format of this section is in a question and answer format. Why would I want to use these TSM documents? EPA's recommended RWQC can be applied nationally and are scientifically defensible and protective of the use. These criteria describe a condition that is protective of human health at a given level of water quality. The linkage between WQ and health protection in the RWQC was informed by studies conducted at sites with specific characteristics. EPA recognizes that there are site-specific characteristics and conditions that differ from those used to support the 2012 RWQC. EPA encourages states to improve and update their WQS to reflect the latest science and information. In this format, the question is presumed to be posed by someone who may use the TSMs to develop alternate site-specific alternative criteria and WQS (the use of "I" in many instances). The answer is a response to the user's question (the use of "you" refers back to the person who is interested in developing alternate site-specific criteria). ------- TSM Guide These TSM documents provide states with approaches to fine-tune EPA's recommendations to reflect site-specific characteristics and conditions, while maintaining equivalent public health protection. WQC that reflect site-specific conditions allow states to account for differences in their waterbodies or preferred enumeration method-indicator, while protecting public health. WQS reflective of site-specific conditions are better for determining attainment. Who can use these Technical Support Materials? These TSMs were created for states4 who are interested in deriving site-specific alternative water quality criteria for inclusion in their WQS. The TSM also provide a transparent process that should allow EPA to evaluate and approve these WQS more easily. 7s my site a candidate for site-specific alternative water quality criteria? The nationally recommended RWQC are designed to be scientifically defensible and protective of the designated use for all waters, and were informed by epidemiological data from sites where WWTP effluent impacts the recreational waterbody. You might consider site-specific alternative criteria if your site is not predominantly impacted by WWTP effluent or if you are interested in developing criteria using an alternative indicator or newer method. The national RWQC values are based on the fecal indicator bacteria enterococci and E. coli (Methods 1600, 1603,1611 or equivalent). The TSM approaches can help you develop different enterococci or E. coli values, or derive criteria based on a different indicator or method. How do I decide which TSM to use? A sanitary characterization allow you to gain a better understanding of the potential sources of contamination impacting your waterbody and decide which TSM approach would be most useful for your situation. For more information on watersheds and approaches to watershed management, please see EPA's watershed website (http://water.epa.gov/type/watersheds/). Table 1 summarizes how the sources of fecal contamination and the type of method influence which TSM you should consider. The sanitary characterization is a process that includes 1) compiling information on sources, water quality, and historical trends within your watershed, 2) evaluating this information against this guide and the related TSM documents, 3) identifying and addressing important data gaps relevant for the TSM approach you are considering, 4) collecting information to confirm the conclusions made in the first step. These steps are iterative and should be revisited by risk managers throughout the characterization process. If you do not think that enterococci or E. coli provide the best water quality information and you are interested in developing a health relationship for a different indicator, refer to Site- Specific Alternative Recreational Criteria Technical Support Materials for Alternative Health Relationships. Anyone can prepare WQS and submit to the state. The state submits to EPA for review and approval. ------- TSM Guide Table 1. How do source and indicator method influence which TSM I should choose? TSM Sources of fecal contamination Enumeration methods Alternative Health Relationship Any Any Alternative Fecal Sources Predominantly non- human EPA Methods 1600,1603 or 1611 (or equivalent5) Alternative indicator- method Any New method has predictable consistent relationship with EPA Methods 1600,1603 or 1611 (or equivalent) If the sanitary characterization of your waterbody indicates that there are predominantly non- human fecal sources affecting it, then you may consider using QMRA to determine the potential probability of illness associated with recreating. Please refer to Site-Specific Alternative Recreational Criteria Technical Support Materials for Predominantly Non-Human Fecal Sources for information on what site-specific data is needed, how to conduct QMRA, and how to select alternative criteria values for enterococci or E. coli. If you are interested in using an alternative indicator or method, possibly because of cost, speed, or other methodological advancements, refer to the Site-Specific Alternative Recreational Criteria Technical Support Materials for Alternative Indicators and Methods. The TSM for alternative indicators and methods explains how to demonstrate whether a consistent predictable relationship exists between the new method and one of EPA's methods for enumerating enterococci or E. coli (EPA methods 1600, 1603, 1611 or equivalent). This approach differs from EPA's ATP process in the following ways: 1) ATP is for national or limited use, whereas the TSM is for site-specific use only, 2) ATP is for methods with the same analyte only, whereas the TSM can be used for different indicators, 3) ATP is for new methods for 40 CFR 136 (for CWA uses) or 40 CFR 141 (for drinking water), whereas the TSM is for new methods for ambient water monitoring, and 4) ATP determines correlations by utilizing spiked samples in a laboratory, whereas the TSM determines correlations by environmental monitoring. The TSM approach is for comparing method performance on a site-specific basis and does not include the development of a health relationship with the new method. Can I use these TSMs to develop site-specific alternative criteria for other designated uses? The set of tools discussed in the TSM documents is designed to evaluate potential impacts to human health from exposure to fecal contamination in ambient surface waters designated for primary recreational contact. Any site-specific alternative WQC derived from using these tools In this context, "equivalent" refers to methods that are approved under EPA's ATP. 10 ------- TSM Guide should be scientifically defensible and protective of the recreational designated use. These TSM tools are not designed to be used to characterize potential human health risks associated with other designated uses. If you are interested in assessing human health risks for other stressors/agents or exposure scenarios, refer to other frameworks such as EPA's Framework for Human Health Risk Assessment to Inform Decision Making (U.S. EPA, 2014) and the interagency Microbial Risk Assessment Guideline Pathogenic Microorganisms with Focus on Food and Water (U.S. EPA/USDA, 2012). What kind of information is useful in the sanitary characterization? Once you decide to explore whether site-specific alternative criteria would be desired, the first step is to conduct a sanitary characterization. A sanitary characterization for this purpose includes gathering relevant information about the potential sources of contamination in the waterbody and other information related to source dynamics. As mentioned above, the sanitary characterization is a multistep process for understanding your watershed. Depending on which TSM you choose, the sanitary characterization can include information such as: • Historical information -This includes information from previous FIB or pathogen monitoring. The history of best management practices and other mitigation efforts can be included. • Sanitary survey information -This can be gathered with the marine and Great Lakes sanitary guides6 or the QMRA sanitary survey.7 • Microbial source tracking (MST) - If any information is available from MST monitoring, this information can be very helpful in identifying sources of FIB. • Wildlife survey - The occurrence of wildlife that could be a source of FIB or pathogens (e.g., warm-blooded animals) should be discussed. If there are seasonal differences and other discernible patterns for wildlife, those aspects can be included. • Geographic information system (CIS) mapping - A map should be included in the sanitary characterization. If there are outfalls or other features that could contribute to FIB, those should be included on the map. • Hydrological data - If information on currents and tidal effects is available, it can help characterize how the FIB are moving throughout the waterbody. In some cases, this information may be available in map format. These components can be prioritized based on available resources and the relative usefulness of the information. For more information on how to utilize sanitary characterization for the development of site-specific alternative criteria, see the TSM documents. 6 Visit EPA's Beach Sanitary Surveys website to find FAQs, guides, forms, and examples (http://water.epa.gov/type/oceb/beaches/sanitarvsurvev index.cfm) 7 See Site-Specific Alternative Recreational Criteria Technical Support Materials for Predominantly Non-Human Fecal Sources 11 ------- TSM Guide Conclusion The three TSM documents will help users collect data, derive site-specific alternative criteria, and prepare WQS. EPA considers that the approaches in these documents reflect the state of the science and provide public health protection in a practical and cost effective manner. States can adopt site-specific alternative criteria to reflect local environmental conditions and human exposure patterns. An alternative WQS may involve the adoption of different numerical value(s) that are based on the approaches described in the set of TSM documents. EPA recommends that alternative criteria reflect the same risk management decision regarding illness rate that are the basis of the 2012 RWQC. Such alternative criteria should be scientifically defensible, protective of the use, and reviewed and approved by EPA under CWA §303(c). 12 ------- TSM Guide References Badgley, B.D., Nayak, B.S., Harwood, V.J. 2010a. The Importance of Sediment and Submerged Aquatic Vegetation as Potential Habitats for Persistent Strains of Enterococci in a Subtropical Watershed. Water Research 44: 5857-5866. Badgley, B.D., Thomas, F.I.M., Harwood, V.J. 2010b. The Effects of Submerged Aquatic Vegetation on the Persistence of Environmental Populations of Enterococcus spp. Environmental Microbiology 12(5): 1271-1281. Boehm, A.B., Ashbolt, N.J., Colford, J.M., Dunbar, I.E., Fleming, I.E., Gold, M.A., Hansel, J.A., Hunter, P.R., Ichida, A.M., McGee,C.D., Seller, J.A., Weisberg, S.B. 2009. A Sea Change Ahead for Recreational Water Quality Criteria. Journal of Water and Health 7(1): 9-20. Byappanahalli, M.N., Roll, B.M., Fujioka, R.S. 2011. 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.J. 1983. Health Effects Criteria for Marine Recreational Waters, Technical Report. U.S. Environmental Protection Agency, Health Effects Research Laboratory: Research Triangle Park, NC. EPA-600/1-80-031. Colford, J., Schiff, K.C., Griffith, J.F., Yau, V., Arnold, B.F., Wright, C.C., Gruber, J.S., Wade, T.J., Burns, S., Hayes, J., McGee, C, Gold, M., Cao, Y., Noble, R.T., Haugland, R., Weisberg, S.B. 2012. Using Rapid Indicators for Enterococcus to assess the Risk of Illness after Exposure to Urban Runoff Contaminated Marine Water. Water Research 46: 2176-2186. Dorevitch, S., Doi, M., Hsu, F.C., Lin, K.T., Roberts, J.D., Liu, L.C., Gladding, R., Vannoy, E., Li, H., Javor, M., Scheff, P.A. 2011. A Comparison of Rapid and Conventional Measures of Indicator Bacteria as Predictors of Waterborne Protozoan Pathogen Presence and Density. Journal of Environmental Monitoring 13: 2427-2435. Dufour, A.P. 1984. Health Effects Criteria for Fresh Recreational Waters. EPA-600/1-84-004. Available at EPA's website on microbiological and chemical exposure assessment (http://www.epa.gov/nerlcwww/documents/frc.pdf). Dufour, A.P., Schaub, S. 2007. The Evolution of Water Quality Criteria in the United States 1922- 2003, in Statistical Framework for Recreational Water Quality Criteria and Monitoring (ed L. J. Wymer), John Wiley and Sons, Ltd, Chichester, UK. Ferguson, D. 2006. Growth of E. coli and Enterococcus in Storm Drain Biofilm. Presentation at 2006 U.S. EPA National Beaches Conference. 13 ------- TSM Guide Ferguson, D. 2012. Bacterial Regrowth in Two Storm Drains in San Diego. Presentation available at Texas A&M University (http://naturalresourcestraining.tamu.edU/media/327296/2. ferguson land grant and sea gr ant nwc 5-22-12.pdf). Fleming, I.E., Solo-Gabriele, H.M., Fleisher, J.M., Goodwin, K., Backer, L, Elmir, S., Wang, J. 2006. The Pilot Epidemiologic Assessment of Microbial Indicators for Monitoring Recreational Water Quality in Marine Sub/Tropical Environments. Fleming, I.E., Solo-Gabriele, H., Fleisher, J.M., Elmir, S., Sinigalliano, C., Piano, L., Wang, J. 2008. Final Report on the Pilot Epidemiologic Assessment of Microbial Indicators for Monitoring Recreational Water Quality in Marine Sub/Tropical Environments. The NSF NIEHS Oceans and Human Health Center, University of Miami. Fujioka, R.S., Byappanahalli, M.N. 2003. Tropical Water Quality Indicator Workshop. March 2001. University of Hawaii at Manoa, Special Report SR-2004-01. Halliday, E., Cast, R.J. 2011. Bacteria in Beach Sands: An Emerging Challenge in Protecting Coastal Water Quality and Bather Health. Environmental Science & Technology 45: 370-379. Ksoll, W.B., Ishii, S., Sadowsky, M.J., Hicks, R.E. 2007. Presence and Sources of Fecal Coliform Bacteria in Epilithic Periphyton Communities of Lake Superior. Applied and Environmental Microbiology 73: 3771-3778. Lavender, J. S., Kinzelman, J.L. 2009. A Cross Comparison of qPCR to agar-based or defined Substrate Test Methods for the Determination of Escherichia coli and Enterococci in Municipal Water Quality Monitoring Programs. Water Research 43: 4967-4979. Marion, J.W., Lee, J., Lemeshow, S., Buckley, T.J. 2010. Association of Gastrointestinal Illness and Recreational Water Exposure at an Inland U.S. Beach. Water Research 44(16): 4796-4804. NRC (National Research Council) 2004. Indicators for Waterborne Pathogens. Available for download at the National Academies Press (http://www.nap.edu/catalog/11010.html). Roser, D., Ashbolt, N. 2006. Microbial Exposure Assessment of an Urban Recreational Lake: A Case Study of the Application of New Risk-based Guidelines. Water Science and Technology. 54: 245-252. Schoen, M.E., Ashbolt, N.J. 2010. Assessing Pathogen Risk to Swimmers at Non-sewage Impacted Recreational Beaches. Environmental Science & Technology 44: 2286-2291. Shibata, T., Solo-Gabriele, H.M. 2012. Quantitative Microbial Risk Assessment of Human Illness from Exposure to Marine Beach Sand. Environmental Science & Technology 46: 2799-2805. 14 ------- TSM Guide Sinigalliano, CD., Fleisher, J.M., Gidley, M.L, Solo-Gabriele, H.M., Shibata, T., Piano, L.R., Elmir, S.M., Wanless, D., Bartkowiak, J., Boiteau, R., Withum, K., Abdelzaher, A.M., He, G., Ortega, C., Zhu, X., Wright, M.E., Kish, J., Hollenbeck, J., Scott, T., Backer, L.C., Fleming, I.E. 2010. Traditional and Molecular Analyses for Fecal Indicator Bacteria in Non-Point Source Subtropical Recreational Marine Waters. Water Research 44(13): 3763-3772. Skinner, J. F., Guzman, J., Kappeler, J. 2010. Regrowth of Enterococci and Fecal Coliform in Biofilm. Stormwater. Available for download at Stormwater, the Journal for Surface Water Quality Professionals (http://www.stormh2o.com/SW/Articles/Regrowth of Enterococci Fecal Coliform in Biofilm 11064.aspx). Seller, J.A., Bartrand, T., Ashbolt, N.J., Ravenscroft, J., Wade, T.J. 2010a. Estimating the Primary Etiologic Agents in Recreational Freshwaters Impacted by Human Sources of Faecal Contamination. Water Research 44(16): 4736-4747. Seller, J.A., Schoen, M.E., Bartrand, T., Ravenscroft, J., Wade, T.J. 2010b. Estimated Human Health Risks from Exposure to Recreational Waters Impacted by Human and Non-Human Sources of Faecal Contamination. Water Research 44(16): 4674-4691. Seller, J. et al., 2014. In preparation. Use of Quantitative Microbial Risk Assessment to Improve Interpretation of Recreational Water Epidemiological Study. Stewart, J.R., Cast, R.J., Fujioka, R.S., Solo-Gabriele, H.M., Meshke, J.S., Amaral-Zettler, L.A., del Castillo, E., Polz, M.F., Collier, T.K., Strom, M.S., Sinigalliano, CD., Moeller, P.D.R., Holland, A.F. 2008. The Coastal Environment and Human Health: Microbial Indicators, Pathogens, and Reservoirs. Environmental Health 7(Suppl2):S3. Till, D., McBride, G. 2004. Potential public health risk of Campylobacter and other zoonotic waterborne infections in New Zealand. Chapter 12 in Waterborne Zoonoses: Identification, causes, and control. Cotruvo, J.A., Dufour, A., Rees, G., Bartram, J., Carr, R., Cliver, D.O., Craun, G.F., Fayer, R., Gannon, V.P.J., ed. 2004. World Health Organization (WHO). IWA Publishing: London, UK. U.S. EPA. 1986. EPA's Ambient Water Quality Criteria for Bacteria - 1986. U.S. Environmental Protection Agency: Washington, DC. EPA 440/5-84-002. Available for download at EPA's Science and Technology website on Surface Water Quality Standards and Guidance (http://water.epa.gov/scitech/swguidance/standards/upload/2001 10 12 criteria ambientwq c bacterial986.pdf). U.S. EPA. 2004. Water Quality Standards for Coastal and Great Lakes Recreation Waters Rule (BEACH Act). 69 FR 67217. November 16, 2004. 15 ------- TSM Guide U.S. EPA. 2009. Review of Published Studies to Characterize Relative Risks from Different Sources of Fecal Contamination in Recreational Water, U.S. Environmental Protection Agency, Office of Science and Technology: Washington, DC. EPA 822-R-09-001. U.S. EPA. 2010a. Quantitative Microbial Risk Assessment to Estimate Illness in Fresh water Impacted by Agricultural Animal Sources of Fecal Contamination. EPA 822-R-10-005. Available for download at EPA's Science and Technology website on Surface Water Quality Standards and Guidance (http://water.epa.gov/scitech/swguidance/standards/criteria/health/recreation/upload/P4- QMRA-508.pdf). U.S. EPA. 2010b. Report on 2009 National Epidemiologic and Environmental Assessment of Recreational Water Epidemiology Studies (NEEAR 2010 - Surfside & Boqueron). EPA-600-R-10- 168. Available for download at EPA's website on National Epidemiological and Environmental Assessment of Recreational Water (NEEAR) (http://www.epa.gov/neear/files/Report2009v5 508comp.pdf). U.S. EPA. 2010c. Effects of Holding Time, Storage, and the Preservation of Samples on Sample Integrity for the Detection of Fecal Indicator Bacteria by Quantitative Polymerase Chain Reaction. EPA-600-R-10-150. Available for download at EPA's Science and Technology website on Surface Water Quality Standards and Guidance (http://water.epa.gov/scitech/swguidance/standards/criteria/health/recreation/upload/P16- Final-Report.pdf). U.S. EPA. 2012a. Recreational Water Quality Criteria. EPA-820-F-12-058. Available for download at EPA's Science and Technology website on Surface Water Quality Standards and Guidance (http://water.epa.gov/scitech/swguidance/standards/criteria/health/recreation/upload/RWQC 2012.pdf). U.S. EPA. 2012b. Method 1611: Enterococci in Water byTaqMan® Quantitative Polymerase Chain Reaction (qPCR) Assay. EPA-821-R-12-008. U.S. EPA. 2014. Framework for Human Health Risk Assessment to Inform Decision Making. EPA - 100-R14-001. Available for download at EPA's Risk Assessment Forum website (http://www.epa.gov/raf/files/hhra-framework-final.pdf). U.S. EPA/USDA(U.S. Department of Agriculture). 2012. Microbial Risk Assessment Guideline Pathogenic Microorganisms with Focus on Food and Water. EPA-100-J-12-001 and USDA/FSIS/2012-001. Available for download at EPA's Risk Assessment Forum website (http://www.epa.gov/raf/files/mra-guideline-iuly-final.pdf). Viau, E.J., Lee, D., Boehm, A.B. 2011. Swimmer Risk of Gastrointestinal Illness from Exposure to Tropical Coastal Waters Impacted by Terrestrial Dry-Weather Runoff. Environmental Science & Technology 45: 7158-7165. 16 ------- TSM Guide Wade, T.J., Calderon, R.L, Sams, E., Beach, M., Brenner, K.P., Williams, A.M., Dufour, A.P., 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., Calderon, R.L, Brenner, K.P., Sams, E., Beach, M., Haugland, R., Wymer, L, Dufour, A.P. 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., Sams, E., Brenner, K.P., Haugland, R., Chern, E., Beach, M., Wymer, L., Rankin, C.C., Love, D., Li, Q., Noble, R., Dufour, A.P. 2010. Rapidly Measured Indicators or Recreational Water Quality and Swimming-Associated Illness at Marine Beaches: A Prospective Cohort Study. Environmental Health 9: 66. WERF (Water Environment Research Foundation) 2009. Report on the Expert Scientific Workshop on Critical Research and Science Needs for the Development of Recreational Water Quality Criteria for Inland Waters. PATH4W09. Water Environment Research Foundation, Alexandria, VA. Wuertz, S., Miller, W., Bambic, D., McBride, G. 2011. Final Report: Quantification of Pathogens and Sources of Microbial Indicators for QMRA in Recreational waters. PATH2R08. Water Environment Research Foundation, Alexandria, VA. Van, T., Goto, D.K., Feng, F. 2011. Concentration dynamics of fecal indicators in Hawaii's coastal and inland sand, soil, and water during rainfall events. PATH6R09. Water Environment Research Foundation, Alexandria, VA. Yamahara, K.M., Layton, B.A., Santoro, A.E., Boehm, A.B. 2007. Beach Sands Along the California Coast Are Diffuse Sources of Fecal Bacteria to Coastal Waters. Environmental Science & Technology 41: 4515-4521. 17 ------- |