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13
Recreational Water Quality
            Criteria

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14                                       Disclaimer


15   This information is distributed solely for the purpose of obtaining scientific views on the
16   content of this document. It does not represent and should not be construed to represent
17   any final agency determination or policy.
18
19

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20
21    Disclaimer	i
22    Appendices	iii
23    Acronyms	v
24    1.0 Executive Summary	1
25      1.1 Contents of this Document	1
26      1.2 EPA's Recommended §304(a) Water Quality Criteria	5
27    2.0 Applicability and Scope of the 2012 RWQC	6
28    3.0 Science and Policy Underlying the 2012 RWQC	10
29      3.1 Indicators of Fecal Contamination	10
30        3.1.1 Enumeration Methods in RWQC	11
31      3.2 Linking Water Quality and Health	13
32        3.2.1 Historical Perspectives in Criteria Development	13
33        3.2.2 Human Health Endpoint	14
34        3.2.3 Relationship Between Water Quality and Illness	16
35        3.2.4 Establishing a Comparable Illness Rate for Defining Culture and qPCR
36                Thresholds	22
37      3.3 Scope  of Protected Population	29
38      3.4WaterbodyType	31
39      3.5 Sources of Fecal Contamination	34
40      3.6 Expression of Criteria	38
41        3.6.1 Use of the STV for Beach Notification	40
42        3.6.2 Criteria Magnitude, Duration, and Frequency for other CWA Purposes	40
43        3.6.3 Practical Considerations for Applying the Criteria	42
44    4.0 Recreational Water Quality Criteria	45
45    5.0 Tools to Support States and Tribes in Managing Recreational Waters and for
46        Considering Alternate Water Quality Criteria	47
47      5.1 Tools for Assessing and Managing Recreational Waters	47
48        5.1.1 Sanitary Survey	48
49        5.1.2 Predictive Models	48
50      5.2 Tools for Use in Developing Alternative RWQC	50
51        5.2.1 Epidemiological Studies	51
52        5.2.2 Quantitative Microbial Risk Assessment and Sanitary Characterization	52
53        5.2.3 Developing Alternative Criteria Based on Novel Indicators or New
54                Analytical Methods, without Site-Specific Epidemiological Studies	55
55    References	57
56
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 57
 58                                    Appendices
 59   APPENDIX A. Indicators and Enumeration Methods
 60   Appendix A.I: Results of the Single-Laboratory Validation of EPA Method A for
 61   Enterococci and Method B for Bacteroidales in Waters by TaqMan® Quantitative
 62   Polymerase Chain Reaction (qPCR) Assay, U.S. EPA, 2010.
 63   Appendix A.2: Evaluation of Multiple Indicator Combinations to Develop Quantifiable
 64   Relationships, U.S. EPA 2010, EPA 822-R-10-004.
 65   Appendix A.3: A Study of the Various Parameters that Affect the Performance of the
 66   New Rapid U.S. Environmental Protection Agency Quantitative Polymerase Chain
 67   Reaction (qPCR)  Method for Enterococcus Detection and Comparison with Other
 68   Methods and Pathogens in Treated Wastewater Mixed with Ambient Water, U.S. EPA
 69   2010, EPA 600-R-10-149.
 70   Appendix A.4: Effects of Holding Time, Storage, and the Preservation of Samples on
 71   Sample Integrity for the Detection of Fecal Indicator Bacteria by Quantitative
 72   Polymerase Chain Reaction, U.S.  EPA 2010, EPA 600-R-10-150.
 73   Appendix A.5: Evaluation of the  Suitability of Individual Combinations of Indicators
 74   and Methods for Different Clean Water Act Programs, U.S. EPA 2010, EPA 823-R-10-
 75   004.
 76
 77   APPENDIX B. Linking Water Quality and Health
 78   Appendix B.I: Critical Path  Science Plan: For the Development of New or Revised
 79   Recreational Water Quality Criteria, U.S. EPA, 2007.
 80   Appendix B.2: Comparison and Evaluation of Epidemiological  Study Designs of Health
 81   Effects Associated with Recreational Water Use, U.S. EPA 2010.
 82   Appendix B.3: Report on 2009 National Epidemiologic and Environmental Assessment
 83   of Recreational Water Epidemiology Studies (NEEAR 2010 - Surfside & Boqueron).
 84   U.S. EPA 2010, EPA 600-R-10-168.
 85   Appendix B.4: Translation of 1986  Criteria Risk to Equivalent Risk Levels for Use with
 86   New Health Data Developed  Using Rapid Methods for Measuring Water Quality, U.S.
 87   EPA 2011.
 88   Appendix B.5: Comparison of NEEAR culturable water quality and health effects to
 89   EPA's epidemiology studies from the 1980s : MEMO - NEEAR culture compared to
 90   1980s data.
 91   Appendix B.6: Report on the Expert Scientific Workshop on  Critical Research and
 92   Science Needs for the  Development of Recreational Water Quality Criteria for Inland
 93   Waters, WERF, PATH4W09.
 94   Appendix B.7: MEMO - Analysis of NEEAR culture data: combining marine and fresh
 95   waters.
 96
 97   APPENDIX C. Sources of Fecal Contamination
 98   Appendix C.I: Review of Published Studies to Characterize Relative Risks from
 99   Different Sources of Fecal Contamination in Recreational Water, U.S. EPA 2009, EPA
100   822-R-09-001.
101   Appendix C.2: Review of Zoonotic Pathogens in Ambient Waters, U.S. EPA 2009, EPA
                                            in

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102   822-R-09-002.
103   Appendix C.3: Quantitative Microbial Risk Assessment to Estimate Illness in Fresh
104   water Impacted by Agricultural Animal Sources of Fecal Contamination, U.S. EPA 2010,
105   EPA 822-R-10-005.
106   Appendix C.4: Assessment of the Applicability of Existing Epidemiology Data to Inland
107   Waters. EPA 823-Rl-0002.
108
109   APPENDIX D. Supplemental Tools
110   Appendix D.I: Predictive Tools for Beach Notification Volume I: Review and Technical
111   Protocol, U.S. EPA2010, EPA 823-R-10-003.
112   Appendix D.2: Predictive Modeling at Beaches Volume II:  Predictive Tools for Beach
113   Notification, U.S. EPA 2010, EPA 600-R-10-176.
114
                                            IV

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115                                      Acronyms

      BEACH     Beaches Environmental Assessment and Coastal Health Act of 2000
      BMP        best management practices
      CCE        calibrator cell equivalent
      CDC        U.S. Centers for Disease Control and Prevention
      cfu          colony forming units
      CWA       Clean Water Act
      DNA        deoxyribonucleic acid
      E. coli       Escherichia coll
      EPA        U.S. Environmental Protection Agency
      E.U.         European Union
      FC          fecal coliforms
      FIB         fecal indicator bacteria, which includes total coliforms, fecal
                   coliforms, E. coli or Enterococcus
      FS          fecal streptococci
      GI          gastrointestinal
      GM         geometric mean
      HCGI       highly credible gastrointestinal illness
      MF         membrane filtration
      mL         milliliters
      MPN        most probable number
      NEEAR     National Epidemiological and Environmental Assessment of
                   Recreational Water
      NGI         NEEAR-GI
      NOAEL     no observable adverse effect level
      NFS         non-point source pollution
      NPDES      National Pollutant Discharge Elimination System
      NTAC       National Technical Advisory Committee
      PC          prospective  cohort
      POTW       publicly owned treatment works
      QMRA      quantitative microbial risk assessment
      qPCR       quantitative polymerase chain reaction
      RCT        randomized control trial
      RWQC      recreational  water quality criteria
      SCCWRP    Southern California Coastal Water Research Proj ect
      SPC         sample processing control
      SSM        single sample maximum
      States       states, tribes, and territories
      STV        statistical threshold value
      TC          total coliform
      TMDL       total maximum daily load
      TSM        technical support materials
      U.K.        United Kingdom
      U.S.         United States
      USDA       U.S. Department of Agriculture

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      U.S. EPA    U.S. Environmental Protection Agency
      U.S. PHS    U.S. Public Health Service
      UV         ultraviolet (light)
      WERF      Water Environment Research Foundation
      WHO       World Health Organization (United Nations)
      WQBEL     water quality-based effluent limits
      WQC       water quality criteria
      WQS        water quality standard
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1.0 Executive Summary

The Clean Water Act (CWA), as amended by
the Beaches Environmental Assessment and
Coastal Health (BEACH) Act in 2000, requires
the U.S. Environmental Protection Agency
(EPA) under §104(v) and §304(a)(9) to
conduct studies associated with pathogens
and human health and to publish new or
revised criteria for pathogens and pathogen
indicators based on those studies. This
document was prepared following an extensive
review of the available scientific literature and
evaluation of new information developed in
response to §104(v). This document provides
EPA's recommended CWA §304(a)
Recreational Water Quality Criteria (RWQC)
for States, lays out the science related to the
2012 RWQC, how these scientific findings
were used during the development of the 2012
RWQC, and the water quality methods
associated with the 2012 RWQC.

1.1 Contents of this Document

Section 1 provides an executive summary and
introductory information regarding the history
of water quality criteria (WQC) and the CWA.

Section 2 provides an overview of the most
recent scientific findings used to support the
criteria and explains the scope of the 2012 RWQC. The studies and projects EPA
conducted as part of the 2012 RWQC development are described in the Critical Path
Science Plan and other documents (see Appendix B). The projects align into these major
categories: epidemiological studies,  quantitative microbial risk assessment (QMRA), site
characterization studies, indicators/methods development and validation studies,
modeling, level of public health protection, and literature reviews.  EPA also considered
relevant studies conducted by independent researchers.

Section 3 describes the scientific aspects that were considered during the development of
the 2012 RWQC. These include indicators of fecal contamination and enumeration
methods, linking water quality and health, scope of protected populations, types of
waterbodies, sources of fecal  contamination, and the expression of the 2012 RWQC.

The 2012 RWQC recommendations indicators for fresh water are the bacteria enterococci
and Escherichia coll (E. coll) and for marine water are enterococci. Section 3.1 explains
 What is new in the 2012 RWQC compared
           to the 1986 Criteria?

1. EPA has developed and validated a qPCR
method as a rapid analytical technique for the
detection of enterococci in recreational water.
The method can be used to develop site-
specific criteria for beach monitoring.

2. EPA is introducing a new term, Statistical
Threshold Value (STV), as a clarification and
replacement for the term single sample
maximum (SSM). In addition there are no
longer recommendations for different use
intensities.

3. EPA is providing information on tools for
assessing and managing recreational waters,
such as predictive modeling and sanitary
surveys.

4. EPA is providing information on tools for
developing alternative RWQC on a site-
specific basis. These tools include the
continued use of epidemiological studies in
both fresh and marine waters and the
development of quantitative microbial risk
assessment (QMRA).	

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163    that EPA recommends culture-based methods be used to detect the presence of both
164    indicators and quantitative polymerase chain reaction (qPCR) be used on a site-specific
165    basis for enterococci enumeration for the purposes of beach monitoring. Because of the
166    limited experience with this method, EPA recommends that States evaluate qPCR
167    performance prior to developing new or revised standards based on this qPCR method.
168    EPA will provide separate guidance on how to evaluate qPCR performance.
169
170    Section 3.2.1 provides a historical overview of how WQC have changed throughout the
171    past century. Scientific advancements in microbiological, statistical, and epidemiological
172    methods have demonstrated E. coli and enterococci are better indicators of health than the
173    previous indicators, total coliforms (TC) and fecal coliforms (FC).
174
175    Section 3.2.2 discusses the various human health endpoints that EPA and others have
176    examined in epidemiological studies. Additionally, two illness definitions are discussed.
177    EPA's 1986 criteria correspond to a level of water quality that is associated with an
178    estimated illness rate recommendations expressed in terms of the number of highly
179    credible gastrointestinal illnesses (HCGI) per 1,000 recreators. EPA's National
180    Epidemiological and Environmental  Assessment of Recreational Water (NEEAR) studies
181    used a more encompassing definition of gastrointestinal (GI) illness, referred to as
182    NEEAR-GI (NGI). Because NGI is broader than HCGI (e.g., NGI includes diarrhea
183    without the requirement of fever), more illness cases were reported and associated with
184    aquatic recreation in the NEEAR studies.
185
186    Section 3.2.3 provides an overview of the epidemiological studies conducted by EPA as
187    part of the NEEAR studies. Seven studies were performed at temperate beaches impacted
188    by publicly owned treatment works (POTWs) discharging effluent from treated municipal
189    sewage. Three study beaches were in marine water and four were in fresh water. Studies
190    also were performed at two additional beaches: a temperate beach in Surfside,  South
191    Carolina impacted by urban run-off sources, and a tropical beach in Boqueron, Puerto
192    Rico impacted by a POTW. EPA also considered epidemiological studies from other
193    research efforts.
194
195    Section 3.2.4 describes the process EPA used to establish a comparable illness rate for
196    culture and qPCR thresholds. EPA's recommended indicator density in the 2012 RWC
197    would retain the same level of water quality established by the 1986 criteria (U.S. EPA,
198    1986), as determined by culturable levels of enterococci for both marine waters and fresh
199    waters and E. coli levels for fresh water. The water quality level recommended in the
200    2012 RWQC for marine waters and fresh waters (as measured by enterococci)
201    corresponds to a mean estimate of illness ranging from approximately 6 to 8 cases of
202    HCGI per 1,000 recreators for both fresh and marine waters, based on the results from the
203    NEEAR studies and studies conducted in support of the 1986 criteria. EPA derived a
204    qPCR value for enterococci comparable to the culture-based value based on an illness
205    rate of 8 HCGI per 1,000 recreators for both fresh and marine waters, computed from the
206    combined NEEAR epidemiological regression model. The 2012 RWQC
207    recommendations correspond to the same level of water quality associated with the
208    previous 1986 criteria recommendations.

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209
210    Section 3.3 discusses subpopulations that participated in recreational activities in the
211    NEEAR studies. The sample sizes in the epidemiological data were not large enough to
212    capture potential differences for persons over 55 years of age, pregnant women, and other
213    subpopulations. Children aged 10 years and younger did show a difference from adults in
214    fresh water, but the sample size for marine water exposures was too small to draw
215    statistical conclusions for children. EPA is basing the 2012 RWQC on the general
216    population, which includes children. Because children may be more exposed and more
217    sensitive to pathogens in recreational waters, it is imperative that effective risk
218    communication outreach be done to mitigate their exposure to contaminated waters
219    effectively. Alerting families with children when the water quality does not meet the
220    States' applicable WQS on a given beach day, in real time, will allow for better
221    protection of children.
222
223    Section 3.4 describes EPA's review of the available information comparing coastal
224    (including Great Lakes and marine) and non-coastal (including flowing and non-flowing
225    inland) waters to evaluate whether EPA should recommend that States use the 2012
226    RWQC in developing recreational water quality  standards (WQSs) in all waterbody
227    types. Based on EPA's evaluation of the body of information described in section 3.4,
228    EPA recommends the 2012 RWQC for use in both coastal and non-coastal waterbodies.
229    While some differences may exist between coastal and non-coastal waters, WQS based
230    on the recommended criteria in both waterbody types would constitute a prudent
231    approach to protect public health. Therefore, EPA's §304(a) RWQC recommendations
232    are national recommendations for all surface waters of the United States designated for
233    swimming, bathing, surfing, or similar water contact activities (referred to throughout this
234    document as "primary contact recreational use").
235
236    Section 3.5 describes EPA's evaluation of how different fecal sources may influence
237    risks to human health. EPA's research indicates that the source of contamination is
238    critical for understanding the human health risk associated with recreational  waters and
239    that there is variability in the amount of human health risk in recreational waters from the
240    various fecal sources due to the wide-ranging environmental conditions that occur across
241    the United States. Human pathogens, microorganisms that could cause disease, are
242    present in animal fecal matter. Therefore, there is a level of risk from recreational
243    exposure to human pathogens in  animal-impacted waters. Quantifying that risk is
244    difficult, however, and the methods necessary to distinguish between human and
245    nonhuman sources, with the appropriate level of confidence, are still under development.
246    EPA concluded that States adopting the 2012 RWQC would have WQS protective of
247    public health, regardless of the source of fecal contamination. EPA is not developing
248    separate national criteria for nonhuman sources.  States interested in adopting different
249    standards to address the potential human health risk differences from different sources of
250    fecal contamination on a site-specific basis should refer to section  5 of this document for
251    suggestions on approaches.
252
253    Section 3.6 describes the statistical expression of the RWQC. As part of the 2012
254    RWQC, EPA is recommending that the criteria be expressed using two components: the

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255    geometric mean (GM) and the 75th percentile Statistical Threshold Value (STV). EPA
256    computed the STV based on the water quality variance observed during EPA's
257    epidemiological studies. The STV corresponds to the 75th percentile of an acceptable
258    water-quality distribution. Because fecal indicator bacteria (FIB; which refers to TC, FC,
259    E. coli or Enterococcus) are highly variable in environmental waters, distributional
260    estimates are more robust than single point estimates. EPA is including the STV in the
261    2012 RWQC, rather than the term "single sample maximum," to resolve previous
262    inconsistencies in implementation. In addition, the 2012 RWQC are no longer
263    recommending multiple "use intensity" values, in an effort to increase national
264    consistency across bodies of water and ensure equivalent public health protection in all
265    waters.
266
267    Section 4 presents EPA's recommended magnitude, duration, and frequency for E. coli
268    and enterococci as measured by the culture method.. The designated use of primary
269    contact recreation would be protected if the following criteria are adopted into State
270    WQSs:
271       (a)  For fresh waters, a criterion that measures E. coli using EPA Method 1603, or any
272       other equivalent method that measures culturable E. coli at a GM of 126 colony
273       forming units (cfu) per  100 milliliters (mL) and  an STV of 235 cfu per 100 mL; a
274       criterion for enterococci measured using EPA Method 1600 (U.S. EPA 2002b), or
275       any other equivalent method that measures culturable enterococci at a GM of 33 cfu
276       per 100 mL and an STV of 61 cfu per 100 mL; or both of the  above criteria.
277
278       (b) For marine waters, a criterion that measures  enterococci using EPA Method 1600,
279       or another equivalent method that measures culturable enterococci at  a GM  of 35 cfu
280       per 100 mL and an STV of 104 cfu per 100 mL.
281
282    For the purposes of beach monitoring, EPA is providing information to States for
283    developing a site-specific criterion that measure enterococci using EPA Enterococcus
284    qPCR Method A, at a GM of 475 calibrator cell equivalent (CCE) per 100 mL and an
285    STV of 1,000 CCE per 100 mL.
286
287    Section 5 describes the tools that can be used to assess and manage recreational waters
288    and derive site-specific criteria. The tools listed in section 5 will not only provide States
289    with additional options for revising their WQS for primary contact recreation, but will
290    also help States gain a better understanding of their  surrounding watersheds. Section 5.1
291    describes sanitary surveys and provides an overview of predictive models. Section 5.2
292    provides an overview of how epidemiological studies, QMRA, and alternative fecal
293    indicator/method combinations may be used to support the development of site-specific
294    criteria. The use of alternative fecal indicators and methods may not be scientifically
295    defensible or protective of the use for all CWA purposes. All of the tools described in
296    section 5 will be further explained in technical support materials (TSM) that are being
297    developed by EPA.
298
299    A series of appendices is also included. Appendix A provides additional information on
300    indicators and enumeration methods, Appendix B describes data and information used to

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301    evaluate the linking of water quality and health, Appendix C contains information on
302    sources of fecal contamination, and Appendix D provides additional information on
303    supplemental tools.
304
305    1.2 EPA's Recommended §304(a) Water Quality Criteria
306
307    An important goal of the CWA is to protect and restore waters for swimming. Section
308    304(a) of the CWA directs EPA to publish and, from time to time, to revise the WQC to
309    accurately reflect the latest scientific knowledge on the identifiable  effects on health and
310    welfare that might be expected from the presence of pollutants in any body of water,
311    including groundwater. These recommendations are referred to as §304(a) criteria. Under
312    §304(a)(9) of the CWA, EPA is required to publish WQC for pathogens and pathogen
313    indicators based on the results of the studies conducted under §104(v) for the purpose of
314    protecting human health in coastal recreation waters.
315
316    The 2012 RWQC recommendations are based on data and scientific conclusions on the
317    relationship between FIB density and GI illness and do not reflect the economic impacts
318    or technological feasibility of meeting the criteria. These criteria recommendations may
319    be used by the States to establish WQS, and if adopted in State WQS, will ultimately
320    provide a basis for controlling the discharge or release of pollutants and assessing water
321    bodies. Additionally, the criteria also provide guidance to EPA when promulgating WQS
322    for States under CWA §303(c), when such actions are necessary.  Monitoring and
323    sampling strategies are not included in the 2012 RWQC. The criteria recommendations
324    do not address pollutants in sand, except to the degree that sand may serve as a source of
325    FIB in recreational waters.
326
327    When adopting new or revised WQSs, the States must adopt criteria that are scientifically
328    defensible and protective of the designated uses of the bodies of water. EPA's regulations
329    stated in 40 CFR §131.11(b)(l) provide that "In establishing criteria, States should (1)
330    Establish numerical values based on (i) 304(a) Guidance; or (ii) 304(a) Guidance
331    modified to reflect site-specific conditions; or (iii) Other scientifically defensible
332    methods." EPA's 2012 RWQC recommendations describe the desired ambient water
333    quality conditions to support the designated use of primary contact recreation. WQS are
334    used in various CWA programs to identify and address sources of pollution, with the
335    ultimate goal of attaining standards.  These CWA programs include National Pollutant
336    Discharge Elimination System (NPDES) permitting, waterbody assessments, and the
337    development of total maximum daily loads (TMDLs). In addition, the BEACH Act
338    requires  States with coastal waters to use WQS in beach monitoring and water quality
339    notification programs funded by EPA grants.
340
341    EPA's current recommended criteria for protecting people who use  recreational waters
342    are based on fecal indicators of bacterial contamination. In the 1960s, the U.S. Public
343    Health Service  (U.S. PHS) recommended using fecal coliform as indicator bacteria and
344    EPA revised the recommendation in 1976 (U.S. EPA, 1976). In the  late 1970s and early
345    1980s, EPA conducted epidemiological studies that evaluated the use of several
346    organisms as possible indicators, including FC, E. coli, and enterococci (Cabelli et al.,

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347    1983; Dufour, 1984). These studies showed that enterococci are good predictors of GI
348    illnesses in fresh and marine recreational waters and E. coli is a good predictor of GI
349    illnesses in fresh waters. As a result, EPA published EPA 's Ambient Water Quality
350    Criteria for Bacteria - 1986 (hereafter referred to as "the 1986 criteria") for determining
351    contamination levels in recreational waters. This document recommends the use of E. coli
352    for fresh recreational waters (the criteria recommend a GM of 126 cfu per 100 mL) and
353    enterococci for fresh and marine recreational waters (the criteria recommends a GM of 33
354    cfu per 100 mL in fresh water and 35 cfu per 100 mL in marine water) (U.S. EPA, 1986).
355    The 1986 recommendations replaced the U.S. PHS previously recommended FC criteria
356    of 200 cfu per 100 mL (US EPA, 1976). In 2004, EPA promulgated the!986 criteria as
357    the WQSs for coastal recreational waters in the 21 States that had not yet adopted
358    standards as protective of human health as EPA's 1986 criteria recommendations (U.S.
359    EPA, 2004). Since the promulgation of the BEACH Act Rule, six States have adopted
360    their own standards that are as protective of human health as EPA's 1986 criteria
361    recommendations and therefore, they are no longer covered by the Federal standards.
362
363    Like past EPA recommendations for the protection of people using bodies of water for
364    recreational uses, such as swimming, bathing, surfing, or similar water-contact activities,
365    these criteria are based on an indicator of fecal contamination, which is a pathogen
366    indicator because pathogens frequently occur with fecal contamination. A pathogen
367    indicator, as defined in §502(23) of the CWA and amended by the BEACH Act, is
368    defined as follows: "a substance that indicates the potential for human infectious
369    disease." Most strains of E. coli and enterococci do not cause human illness (that is, they
370    are not human pathogens); rather, they indicate the presence of fecal contamination. The
371    basis for recommending criteria that use bacterial indicators of fecal contamination is that
372    pathogens often co-occur with indicators of fecal contamination.
373
374    2.0 Applicability and Scope of the 2012 RWQC
375
376    EPA's 2012 RWQC recommendations supersede EPA's previous criteria
377    recommendations to protect primary contact recreation, Ambient Water Quality Criteria
378   for Bacteria - 1986 (referred to as the "1986 criteria"). These recommendations are for
379    all waters in the U.S. including coastal, estuarine, Great Lakes, and inland waters that are
380    designed for swimming, bathing, surfing, or similar water-contact activities ("primary
381    contact recreation"). When swimming, bathing, surfing, water skiing, tubing, skin diving,
382    water play by children, or engaging in  similar water-contact activities, immersion and
383    ingestion are likely and there is a high  degree of bodily contact with the water.
384
385    Since EPA last issued recommended RWQC in 1986, scientific advances have been made
386    in the areas of epidemiology, molecular biology, microbiology, QMRA, and methods of
387    analytical assessment. Adding these new scientific and technical advances in the
388    development of the 2012 RWQC strengthens the scientific foundation of EPA's criteria
389    recommendations to protect the designated use of primary  contact recreation.
390
391    In accordance with § 104(v) of the  CWA, as amended by the BEACH Act, EPA
392    developed and implemented a research plan to ensure that state-of-the-art science would

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393    be available to support the development of the 2012 RWQC recommendations. To
394    facilitate the identification of research required to develop the 2012 RWQC, EPA held a
395    5-day scientific workshop in 2007 to obtain a broad range of external scientific input.
396    Forty-three U.S. and international experts provided input on near-term research
397    requirements that would be needed in the next 2-3 years to further develop the scientific
398    foundation of new 2012 RWQC and implementation guidance. The report from this
399    workshop, Report of the Experts Scientific Workshop on Critical Research Needs for the
400    Development of New or Revised Recreational Water Quality Criteria (U.S. EPA, 2007a),
401    included chapters from the seven breakout groups: (1) approaches to criteria
402    development,  (2) pathogens, pathogen indicators, and indicators of fecal contamination,
403    (3) methods development, (4) comparing the risks of different contamination sources to
404    humans, (5) acceptable risk, (6) modeling applications for criteria development and
405    implementation, and (7) implementation realities.
406
407    The report from the Experts Scientific Workshop provided a core part of the information
408    EPA used to develop the Critical Path Science Plan for the Development of New or
409    Revised Recreational Water Quality Criteria (U. S. EPA,  2007b). The Critical Path
410    Science Plan,  which was peer reviewed, includes 32 projects that EPA completed for the
411    development of the 2012 RWQC. All projects included in the Critical Path Science Plan,
412    and any additional projects, were completed and considered during the process of
413    developing the 2012 RWQC. These projects included epidemiological studies to provide
414    data correlating illness with indicators, site-characterization studies to facilitate QMRA,
415    indicator and methods development and validation, water quality modeling, literature
416    reviews, and additional studies to support appropriate levels of public health protection.
417    EPA also supported the Water Environment Research Foundation (WERF) workshop,
418    Experts Scientific Workshop on Critical Research and Science Needs for the
419    Development of Recreational Water Quality Criteria for Inland Waters, to consider the
420    significance of the differences between inland and coastal recreational waters (WERF,
421    2009). As summarized or included in the appendices, these projects included efforts in
422    the following  areas:l
423
424       •   Epidemiological Studies and QMRA
425              °   2003-2004 Temperate Fresh water: four beach sites on the Great Lakes
426              °   2005-2007 Temperate Marine: three beach sites: Alabama, Rhode Island,
427                 Mississippi
428              °   2009 sites: Puerto Rico (tropical), South Carolina (urban runoff)
429              °   QMRA for fresh water impacted by agricultural animals
430              °   Technical support to the Southern California Coastal Water Research
431                 Project (SCCWRP) for epidemiological studies at the beaches of Doheny,
432                 Avalon, and Malibu
433       •   Site Characterization Studies
434              °   Development of site characterization tool for QMRA applications
       1 EPA's RecreationalWater Quality Criteria website:
       http://water.epa.gov/scitech/swguidance/standards/criteria/health/recreation/

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                                                                                 12-9-11
435              °   Expanded data collection at epidemiological study locations to support
436                 modeling and QMRA
437              °   Site selection evaluation for Puerto Rico and South Carolina
438                 epidemiological studies
439              °   Study to better understand spatial and temporal variability
440              °   Pilot sanitary survey in the Great Lakes
441       •  Indicators/Methods Development and Validation Studies
442              °   Evaluate multiple indicator/method combinations to develop quantifiable
443                 relationships
444              °   Study the effects of sample holding time, storage, and preservation
445              °   Performance of qPCR signal in ambient water and wastewater (fate and
446                 transport)
447              °   Develop, refine, validate, and publish new ambient and wastewater
448                 methods
449              °   Publish a rapid test method that has been validated by multiple
450                 laboratories
451              °   Evaluate the suitability of individual combinations of indicators and
452                 methods for different CWA purposes
453              °   Develop new and/or evaluate previously published source-identifying
454                 assays
455              °   Evaluate genetic markers for human, bovine, chickens,  and gulls
456       •  Modeling
457              °   Pilot test Virtual Beach Model Builder
458              °   Refine and validate  existing models for fresh water beaches
459              °   Refine and validate  other existing models for marine beaches
460              °   Develop technical protocol for site-specific application  of predictive
461                 models
462       •  Appropriate Level of Public Health Protect!on
463              °   Evaluate 1986 recommendations for culturable E. coli and enterococci
464                 compared to data collected in EPA studies and non-EPA studies
465              °   Evaluate applicability of EPA Great Lakes epidemiological data to inland
466                 waters
467              °   Evaluate available children's health data
468       •  Literature Reviews
469              °   State-of-the-science reviews of published studies to characterize relative
470                 risk from different fecal  sources
471              °   State-of-the-science review on occurrence and cross-infectivity of specific
472                 pathogens associated with animals
473              °   Comparison and evaluation of epidemiological study designs of health
474                 effects associated with recreational water use
475
476    EPA epidemiological studies were  conducted at U.S. beaches in 2003,  2004, 2005, 2007,
477    and 2009, and as a group are referred to as the NEEAR studies. These  studies enrolled
478    54,250 participants, encompassed 9 locations,  and collected and analyzed numerous

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479    samples from a combination of fresh water, marine, tropical, and temperate beaches
480    (Wade et al., 2008, 2010; U.S. EPA, 2010d).
481
482    In addition to its own studies, EPA considered independent research, based on a
483    comprehensive search of the scientific literature, which was related to the development of
484    the 2012 RWQC. These studies included epidemiological studies, research on the
485    development of new and improved water quality indicators and analytical methods,
486    approaches to QMRA, water quality predictive modeling, and microbial-source tracking.
487    As of the date of the draft RWQC, EPA received data from SCCWRP, which were
488    generally consistent with the NEEAR study findings. However, because results were
489    preliminary in nature, they were not considered quantitatively. These scientific topics are
490    discussed further in section 3 of this  document.
491
492
493

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494    3.0 Science and Policy Underlying the 2012 RWQC
495
496    To develop the 2012 RWQC, EPA considered indicators of fecal contamination, methods
497    for detecting and enumerating such indicators, the relationship between the occurrence of
498    FIB in the water and their human health effects, the populations to be protected by the
499    2012 RWQC, waterbody types, sources of fecal contamination, and how the 2012 RWQC
500    should be expressed in terms of the magnitude, duration, and frequency of any excursions
501    above the criteria values. For each aspect of the 2012 RWQC, the following variables are
502    discussed: background related to the 1986 criteria, new scientific findings and
503    information, and what EPA is  proposing for the 2012 RWQC recommendations.
504
505    Indicators of fecal contamination and RWQC indicator organisms can be detected
506    through different methods, thus information on both the indicator organism and the
507    method of detection are important for RWQC. The important linkage between the
508    organism and the method is captured throughout this document by the use of the term
509    indicator/method to refer to the combination of both. EPA believes that addressing only
510    the organism or only the method is not adequate for  deriving RWQC because the
511    organism and the detection method result in different units (see Section 3.1.1).
512
513    3.1 Indicators of Fecal Contamination
514
515    Public health agencies have long used FIB to identify potential for illness resulting from
516    the engagement in recreational activities in  surface waters contaminated by fecal
517    pollution. EPA based its 1986  criteria for marine and fresh recreational waters on levels
518    of bacterial indicators of fecal  contamination, specifically E. coli and enterococci for
519    fresh water and enterococci for marine water. Although generally not inherently
520    pathogenic, these particular FIB demonstrate characteristics that make them good
521    indicators of fecal contamination, and thus,  indirectly indicate the potential presence of
522    fecal pathogens capable of causing GI illnesses. As such, FIB are "pathogen indicators"
523    as that term is defined by Section 502(23) -"a substance that indicates the potential for
524    human infectious diseases" - even though they are not generally thought of as "pathogen
525    indicators," as that term is typically used by the scientific community as direct indicators
526    of pathogens. EPA cannot publish criteria for "pathogens" at this time because the
527    current state of the science is not sufficient to support this effort.  In addition, there are
528    numerous pathogens that cause the full range of illnesses associated with primary contact
529    recreation. Many pathogen specific methods were not finalized at the time of the fresh
530    and marine water epidemiology studies, and thus a health relationship was not
531    established. For additional information on indicators, see Appendix A.3 and A.5.
532
533    Several microorganisms that are potential indicators of fecal contamination are normally
534    present in fecal material. Not all of these indicators,  however, have a clear relationship to
535    illness levels observed in epidemiological studies.  Two microorganisms that have
536    consistently performed well as indicators of illness in epidemiological studies are
537    enterococci in both fresh and marine water and E.  coli in fresh water (see Section 3.2.3).
538    Although EPA does not have recent epidemiological data on E. coli in fresh water, two
539    independent epidemiological studies support the utility of E. coli as an indicator as


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                                                                                 12-9-11
540    recommended in the 1986 criteria (Marion et al., 2010, Wiedenmann, 2006). A meta-
541    analysis of 27 studies also supports E. coli as an indicator in fresh water (Wade et al.,
542    2003). See section 5.2.3 for discussion of alternative indicators that EPA has not
543    specifically included in 2012 RWQC.
544
545    Some human pathogens, such as various species of Vibrio., Legionella, and the free-living
546    amoeba Naegleria, occur naturally in the environment (Cangelosi et al., 2004; Pond,
547    2005). Other aquatic microbes, such as harmful algae, cyanobacteria, diatoms, and
548    dinoflagellates, produce toxins that can cause human illnesses. These microbes were not
549    the focus of the 2012 RWQC because adverse health effects that occur in humans from
550    these microorganisms have not been associated with FIB.
551
552    3.1.1 Enumeration Methods in RWQC
553
554    FIB can be enumerated using various analytical methods including those in which the
555    organisms are grown (cultured) and those in which their deoxyribonucleic acid (DNA) is
556    amplified and quantified (qPCR).  These different enumeration methods result in method-
557    specific units and values. One culture method, membrane filtration (MF), results in the
558    number of cfu that arise from bacteria captured on the filter per volume of water. One
559    colony  can be produced from one or several cells  (clumped cells in the environmental
560    sample). Another culture method, the defined substrate method, produces a most probable
561    number (MPN) per volume. MPN analyses estimate the number of organisms in a sample
562    using statistical probability tables, hence the "most probable number." Bacterial densities
563    are based on the combination of positive and negative test tube results that  can be read
564    from an MPN table (U.S. EPA,  1978). Culture-based approaches for the enumeration of
565    FIB, such as MPN and MF, do not result in a direct count or concentration  of the bacteria
566    being enumerated but rather rely on probabilities and generate results following culturing
567    of a particular microbe for 18-24 hours. Results from qPCR analysis are reported in CCE
568    units that are calculated based on the target DNA  sequences from test samples relative to
569    those in calibrator samples that contain a known quantity of target organisms (Haugland
570    etal., 2005, Wade etal.,2010).2
571
572    The results from each of these enumeration techniques depend on the method used. Each
573    analytical technique focuses on different attributes of the fecal indicator and results in a
574    "signal" specific to that technique. For example, culture-based methods fundamentally
575    depend on the metabolic state (i.e., viability) of the target organisms for effective
576    enumeration. Only the culturable members of the  target population are detected using
577    culture-based techniques. Alternatively, qPCR-based approaches detect specific
578    sequences of DNA that have been extracted from  a water sample, and results contain
579    sequences from all members of the target population, both viable and nonviable. In the
580    context of the 2012 RWQC, the results for enterococci determined using the culture
       2 Note that in some EPA NEEAR study publications, the term calibrator cell equivalents (CCEs) has been
       shortened to cell equivalents (CEs). EPA considers these terms to be synonymous and in all cases calibrator
       cells were used. EPA used the delta-delta comparative Ct calibration model for estimating CCE or CE in
       all NEEAR studies.
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                                                                                12-9-11
581    methods are not the same as the results for enterococci detected by qPCR methods. These
582    results are not directly interchangeable and require an explanation of each method's
583    results as they relate to the reported health effects (i.e., epidemiological relationships; see
584    section 3.2).
585
586    FIB, such as E. coli, enumerated by culture-based methods have a demonstrated
587    correlation with GI illness from exposure to ambient recreational water previously
588    (Dufour 1984; Wade et al. 2003) and more recently (Marion et al., 2010,Wiedenmann et
589    al., 2006), provide a historical association with previous water-quality data, and are
590    scientifically defensible and protective of the primary contact recreation use when used
591    for multiple CWA programs (beach monitoring and notifications, §303[d] listing,
592    permits, TMDLs). Culture-based methods have a time lag of 24 hours or more between
593    sample collection and results. This lag is less of an issue if monitoring is coupled with a
594    calibrated predictive model (see section 5.1.2).
595
596    EPA is also providing information on how to use a more recently developed qPCR
597    method as a site-specific criterion  for the purposes of beach monitoring. This
598    methodology showed a statistically significant correlation with GI illness among
599    swimmers in both marine and fresh recreational waters impacted by human fecal
600    contamination (Wade et al., 2006,  2008, 2010). The technical literature demonstrates that
601    this enterococci enumeration technique can provide results more rapidly than culture-
602    based methods, with results available the same day (Griffith and Weisberg,  2011). Thus,
603    the strengths of the Enterococcus qPCR compared to the culture method include rapidity
604    and demonstration of stronger and more sensitive health relationships in the NEEAR
605    studies.
606
607    As with other methods, including culture methods, the qPCR methodology may be
608    affected by unpredictable interference from substances in different environmental
609    matrices such as surface waters. Interference is any process that results in lower
610    quantitative estimates than expected or actual values. Unlike culture methods, the EPA
611    Enter ococcus qPCR method (U.S. EPA Method A, 201 Oh) has a sample processing
612    control (SPC) assay that is performed on each sample to identify unacceptable levels of
613    interference (defined as a 3-Ct unit shift compared to corresponding control samples).
614
615    While the fresh water NEEAR studies in the Great Lakes and four temperate marine
616    beaches demonstrated minimal to  no inhibition, EPA's overall testing of qPCR in
617    ambient waters has been limited. EPA anticipates that there may be situations at a given
618    location where the qPCR performance may be inconsistent with  respect to sample
619    interference. Given that there is limited information on the performance of EPA's
620    Enterococcus qPCR method in inland and tropical marine waters, EPA recommends that
621    States evaluate qPCR performance with respect to sample interference prior to
622    developing new or revised standards relying on this method for the purposes of beach
623    monitoring. EPA will provide guidance on how to evaluate performance with  respect to
624    sample interference at a particular site at a later date.
625
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                                                                                12-9-11
626    3.2 Linking Water Quality and Health
627
628    This section discusses the information that EPA considered during the course of
629    evaluating the association between measures of water quality and potential human health
630    effects from exposure to fecal contamination. There are many scenarios where fecal
631    contamination can impact a waterbody, and the relationship between the presence of FIB
632    and of the pathogens that cause illness can be highly variable. The following four
633    subsections—historical perspectives in criteria development,  human health endpoints,
634    water quality and illness, and derivation of recommended numerical criteria values—
635    describe the lines of evidence EPA used to support the association between the 2012
636    RWQC and human health protection. The historical perspectives subsection briefly
637    discusses previous approaches to the development of WQC in the United States. The
638    human health endpoint subsection explains how the definition of illness is important for
639    understanding the meaning of the associated 2012 RWQC illness-rate levels. The water
640    quality and illness subsection presents the results of epidemiological studies that EPA
641    considered when developing the 2012 RWQC. The derivation subsection discusses the
642    mathematical basis of the 2012 RWQC values.
643
644    3.2.1 Historical Perspectives in Criteria Development
645
646    EPA's previously recommended recreational water-quality criteria (the 1986 criteria) and
647    the 2012 RWQC are based on the association between the density of FIB and observation
648    of GI illnesses. FIB levels have long served as the surrogate measure of fecal
649    contamination and thus the presence of pathogens that are commonly associated with
650    fecal material.
651
652    In the 1960s, the U.S. PHS recommended using FC bacteria as the indicator of primary
653    contact with FIB. Studies the U.S. PHS conducted reported a detectable health effect
654    when TC density was about 2,300 per 100 mL (Stevenson, 1953). In 1968, the National
655    Technical Advisory Committee (NTAC) translated the TC level to 400 FC per 100 mL
656    based on a ratio of TC to FC, and then halved that number to  200 FC per 100 mL (U.S.
657    EPA, 1986). The NTAC criteria for recreational waters were  recommended again by EPA
658    in 1976.
659
660    In the late 1970s and early 1980s, EPA conducted a series of epidemiological studies to
661    evaluate several additional organisms as possible indicators of fecal contamination,
662    including E. coli and enterococci. These epidemiological studies showed that enterococci
663    are a good predictor of GI illnesses in fresh and marine recreational waters, and E. coli is
664    a good predictor of GI illnesses in fresh waters (Cabelli et al., 1982; Cabelli,  1983;
665    Dufour, 1984).
666
667    The 1986 criteria values represent the desired ambient condition of the water body
668    necessary to protect the designated use of primary contact recreation. Those values were
669    selected in order to further carry forward the same level of water quality associated with
670    EPA's previous criteria recommendations to protect the primary contact recreation use,
671    which were for FC (US EPA, 1976). For this effort, the enterococci and E. coli criteria


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                                                                               12-9-11
672    values from the existing FC criteria were translated using the GM values for the FIB
673    established in the previous epidemiological studies (see Text Box 1, below) (Dufour and
674    Schaub, 2007). The SSM component of the 1986 criteria was computed using the GM
675    values and corresponding observed variances in the FIB obtained from water quality
676    measurements taken during the epidemiological studies from the 1970s and 1980s. The
677    1986 criteria values resulted in different values and corresponding illness rates for marine
678    and fresh waters because the marine and fresh water epidemiological studies reported
679    different GMs for the FIB associated with the level of water quality corresponding to
680    EPA's FC criteria recommendations.
681
682
683                 Text Box 1. Translation of 1960s criteria to 1986 criteria
                 The 1986 criteria values (A) were derived as follows
                     A = (B*C)/D
                 Where
                 B is the observed GM enterococci (from epidemiological studies)
                 C is the criterion for fecal coliform (200 cfu per 100 mL)
                 D is the observed GM fecal coliform (from epidemiological studies)
684
685
686    For example, using the equation in Text Box 1, the marine enterococci 1986 criterion was
687    calculated as follows:
688
689    B  =  20 cfu per 100 mL (observed GM enterococci)
690    C  =  200 cfu per 100 mL (old FC standard)
691    D  =  115 cfu per 100 mL (observed GM fecal coliforms)
692    Therefore, A = 3 5 cfu per 100 mL.
693
694    Using the observed relationships between the FIB  densities and GI illness, EPA estimated
695    in 1986 that the predicted level of illness associated with the criteria was 8 HCGI per
696    1,000 recreators in fresh water (see section 3.2.2) and 19 HCGI per 1,000 recreators in
697    marine waters (U.S. EPA, 1986).
698
699    3.2.2 Human Health Endpoint
700
701    EPA's 1986 criteria values correspond to a level of water quality associated with an
702    estimated level of illness that is expressed in terms of the number of HCGI. The HCGI
703    case definition is "any one of the following unmistakable or combinations of symptoms
704    [within 8 to 10 days of swimming]: (1) vomiting (2) diarrhea with fever or a disabling
705    condition (remained home, remained in bed or sought medical advice because of
706    symptoms), (3) stomachache or nausea accompanied by a fever."
707
708    EPA's NEEAR epidemiological studies  used a different definition of GI illness, defining
709    a case of GI illness as  "any of the following [within 10 to 12 days after swimming]: (a)
710    diarrhea (3 or more loose stools in a 24 hour period), (b) vomiting, (c) nausea and
711    stomachache, or (d) nausea or stomachache and impact on daily activity." This illness

                                                                                    14

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                                                                                 12-9-11
712    definition is referred to as NGI and is the definition of illness associated with the 2012
713    RWQC. For additional information, see Appendix B.
714
715    The NGI case definition was broadened in that diarrhea, stomachache, or nausea is
716    included without the occurrence of fever. Viral gastroenteritis does not always present
717    with a fever, so including GI illness without fever incorporates more types of viral
718    illnesses in this definition. Viruses are thought to be the etiologic agent responsible for
719    most GI illnesses that are contracted in recreational waters impacted by sources of human
720    fecal contamination (Cabelli,  1983;  Seller et al., 2010a).
721
722    In addition, the NEEAR studies extended the number of days following the swimming
723    event in which illness may have been observed to account for pathogens with longer
724    incubation times. For example, the incubation of Cryptosporidium spp. can be up to 10
725    days, thus participants contacted after 8 days may not have developed symptoms. By
726    calling participants after  10 days, the study design allowed for illness caused by
727    pathogens  associated with longer incubation periods to be included. Similar GI
728    definitions are now widely used nationally and internationally (Colford et al., 2002, 2007;
729    Payment, 1991,  1997; Sinigalliano et al., 2010; Wiedenmann et al., 2006).
730
731    Because the NGI definition is broader than HCGI, more illnesses qualify to be counted as
732    "cases" in the epidemiological studies, than if the older HCGI definition were applied.
733    Therefore, at the same level of water quality, more NGI illnesses will be observed than
734    HCGI illnesses.  The relative differences in rates of GI illness between the studies (i.e.,
735    HCGI versus NGI) are directly attributable to the changes in how illness was defined and
736    not due to an actual increase in the incidence of illness among swimmers at a given level
737    of water quality.
738
739    EPA estimated how the GI illness rate associated with the two GI illness definitions can
740    be compared using the difference between (a)  non-swimmer illness rates from the pre-
741    1986 epidemiological data, and the (b) non-swimmer illness rates from the NEEAR
742    studies (U.S. EPA, 201 la). The non-swimmer HCGI rate from pre-1986 epidemiological
743    studies was 14 illnesses per 1,000 non-swimmer recreators, while the non-swimmer
744    recreators NGI rate from the NEEAR studies was 63 illnesses per 1,000 non-swimmer
745    recreators. Thus an illness level of 8 HCGI per 1,000 recreators is estimated to be
746    equivalent with an illness level of 36 NGI per 1,000 recreators (estimated translation
747    factor of 4.5 NGI per HCGI).   For analyses presented in section 3.2.4, the HCGI illness
748    rate metric was used, through this translation factor, in order to maintain comparability to
749    the 1986 criteria.
750
751    Of all the adverse health  effects considered, the NEEAR epidemiological studies found
752    the strongest association  with GI illnesses (see section 3.2.3). In addition to NGI
753    illnesses, the NEEAR epidemiological studies evaluated other health endpoints that could
754    have been caused by pathogens found in fecal matter. These included the following:
755       1.   "Upper respiratory illness," which was defined as any two of the following: sore
756          throat, cough, runny nose,  cold, or fever;
757       2.  "Rash," which was defined as a rash or itchy skin;


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                                                                                12-9-11
758       3.  "Eye ailments," which were defined as either an eye infection or a watery eye;
759       4.  "Earache," which was defined as ear pain, ear infection, or runny ears;
760       5.  "Infected cut," which was defined as a cut or wound that became infected.
761
762    Results from the NEEAR studies and previous epidemiological studies indicate that
763    criteria based on protecting the public from GI illness correlated with FIB will  prevent
764    most types of recreational waterborne illnesses. In general, these other illnesses occur at a
765    lower rate than GI illness (Fleisher et al., 1998; Haile et al., 1999; McBride et al.  1998;
766    Wade et al.  2008). For example, Wade et al. (2008) reported overall GI illness  incidence
767    of 7.3 percent, upper respiratory infection incidence of 5.7 percent, rash incidence of 2.7
768    percent,  and eye irritations and infections of 2.9 percent. Kay et al. (1994) and  Fleisher et
769    al. (1998) reported 14.8 percent GI illness in swimmers and 9.7 percent in non-
770    swimmers, 4.7 percent incidence of respiratory infection in swimmers and 3 percent in
771    non-swimmers, and 4.2 percent incidence of ear ailments in swimmers and  4.8 percent
772    and non-swimmers.
773
774    Non-EPA studies in waters not impacted by POTWs found correlations between other
775    health endpoints and water quality. Sinigalliano et al. (2010) reported symptoms between
776    one set of human subjects randomly  assigned to marine water exposure with intensive
777    environmental monitoring compared with other subjects who did not have exposure.
778    Their results demonstrated an increase in self-reported GI, respiratory, and  skin illnesses
779    among bathers compared to non-bathers. Among the bathers, a relationship was observed
780    between increasing FIB and skin illness, where skin illness was positively related to
781    enterococci enumeration by culture methods.
782
783
784    3.2.3 Relationship Between Water Quality and Illness
785
786    The protection of the primary contact recreation use has always been the goal of bacterial
787    WQCs in the United States. For decades, epidemiological studies have been used to
788    evaluate how FIB  levels are associated with health effects of primary contact recreation
789    on a quantitative basis. The 1986 criteria recommendations are supported by
790    epidemiological studies conducted by EPA in the 1970s  and 1980s. In those studies, E.
791    coli and enterococci exhibited the strongest correlation to swimming-associated
792    gastroenteritis (specifically HCGI, as discussed in section 3.2.2). Because these indicators
793    correlate with illness, EPA selected E.  coli as the indicator to be measured in fresh water
794    and enterococci as an indicator to be measured in both fresh water and marine water.
795    Both indicators continue to be used in epidemiological studies conducted throughout the
796    world, including in the European Union (E.U.) and Canada (EP/CEU, 2006; MNHW,
797    1992). In addition, the World Health Organization (WHO) recommends the use of these
798    two organisms as water-quality indicators for recreational waters (WHO, 2003).
799
800    EPA NEEAR epidemiological study design and conclusions.
801    EPA conducted the NEEAR epidemiological studies at U.S. beaches in 2003, 2004, 2005,
802    2007, and 2009 and the results of these studies were reported in a series of research
803    articles (Wade et al., 2006, 2008, 2010; U.S. EPA, 2010d). These NEEAR studies were


                                                                                     16

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                                                                                 12-9-11
804    prospective cohort (PC) epidemiological studies that enrolled participants at the beach
805    (the cohort) and followed them for an appropriate period of time to compare incidence of
806    illness (i.e., NGI illness) between the exposed (swimmers) and unexposed groups. This
807    type of study can also include exposure response analyses if varying degrees of exposure
808    (such as water-quality data) are present (see Appendix B). The PC design used in
809    NEEAR studies was a modification of the cohort design previously employed by Cabelli
810    (1983), Dufour (1984), and numerous others (Calderon et al., 1991; Cheung et al., 1990;
811    Colford et al., 2005; Corbett et al., 1993; Haile et al., 1999; McBride et al., 1998; Prieto
812    et al., 2001; Seyfried et al., 1985; von Schirnding et al.,  1992).
813
814    Investigators considered several different study designs, but only the randomized
815    controlled trial (described below) and prospective designs were viewed as potentially
816    viable methods to address the specific goals of the study. The cohort design adopted for
817    these studies modified  and improved the design used for studies in the development of
818    the 1986 criteria (U.S. EPA, 1986). Attributes of the NEEAR studies' design include: (1)
819    the studied population of beach-goers is representative of all beach-goers; (2) the ability
820    to recruit many swimmers and nonswimmers; (3) the studies can be conducted over an
821    entire season, capturing and observing variability in the water quality;  (4) potentially
822    sensitive groups who use the beach,  such as children, the elderly, and the
823    immunocompromised are represented in the sample; and (5) the matrix water-sampling
824    design allows flexibility in determining monitoring options and allows short-term (hours)
825    variability in water quality to be evaluated.
826
827    The criteria used to select the seven beaches studied between 2003 and 20073 include:
828       1.   The beach is an officially designated recreational area near a large population
829           center.
830       2.   The beach has an attendance large enough to support an epidemiological study
831           (e.g., 300-400 attendees/day).
832       3.   The age range of the swimmers is broad (i.e., includes children, teenagers, and
833           adults).
834       4.   The beach generally meets the state or local WQSs with a range of concentrations.
835       5.   The range of indicator concentration is related to occasional contamination by an
836           identified human source of pollution (point-source).
837       6.   The swimming season is at least 90 days long.
838
839    In addition to the above criteria, obtaining agreement and consent from the local
840    community and beach or park management was necessary.
841
842    The enrollment goal was to approach and offer enrollment to all beach-goers between
843    11:00 AM and 5:00 PM. Interviewers approached beach-goers on weekends and holidays
844    during the summer. The health survey was administered in three parts: enrollment, exit
845    interview,  and telephone interview. The beach interview included questions about
846    demographics, swimming and other beach activities, consumption of raw or undercooked
847    meat or runny eggs, chronic illnesses, allergies, acute health symptoms in the past 48
       3 Criteria for selecting urban run-off and tropical beaches included other selection criteria as well (see
       Appendix B.2).

                                                                                      17

-------
                                                                                 12-9-11
848    hours, contact with sick persons in the past 48 hours, other swimming in the past 48
849    hours, and contact with animals in the past 48 hours. The telephone interview was
850    conducted 10-12 days after the beach visit, and consisted of questions about health
851    symptoms experienced since the beach visit and other swimming or water-related
852    activities, contact with animals, and consumption of high-risk foods since the beach visit,
853    among others.
854
855    The goal of the data analysis was to evaluate the relationship between novel and rapid
856    measures of water quality and health  effects and, by doing so, determine whether the new
857    approaches to measuring water quality would be useful in protecting beach-goers health
858    by accurately predicting swimming associated illness.
859
860    Regression models were the primary  method used to determine the strength and the
861    significance of the relationship between the indicator measures and health effects. The
862    types of models used are an improvement over those used in the development of the 1986
863    criteria because they use individual-level data and do not rely on grouping of data points.
864    Grouping of the 1986 data resulted in the loss of the ability to account for individual
865    differences, such as age, sex, and other health conditions. The individual-level analysis
866    results in better control over these and other factors that might differ among individuals
867    (covariates or confounding factors). Nearly all the studies conducted in recent years have
868    used similar models, usually logistic or log-linear models (Fleisher et al., 1993; Haile et
869    al., 1999; Kay et al., 1994; McBride et al., 1998; Prieto et al., 2001; Seyfried et al., 1985).
870    The models used for the NEEAR data analysis are similar, but include several
871    modifications to the usual approach employed by  these studies (Wade et al., 2008 and
872    2010).
873
874    Statistical tests were conducted using several approaches and models to assess whether
875    the odds ratios for the different fresh water and marine beaches were statistically
876    different. The regression models considered many potential covariates, including  age,
877    sex, race, contact with animals, contact with other persons with diarrhea, number of other
878    visits to the beach, any other chronic  illnesses (GI, skin, asthma), digging in sand, and
879    consumption of raw or undercooked meat.
880
881    As a result of the statistical analyses,  EPA concluded that epidemiological data from
882    POTW-impacted temperate fresh waters and marine waters could be combined. A direct
883    comparison of the slope parameters (the change in illness rate per unit change in
884    enterococci CCE) shows no difference (p = 0.44)  between the marine and fresh water
885    beaches. There were no significant differences in  risk estimates from separate models
886    from marine and fresh water beaches  separately or from the combined model. The results
887    indicated that for the maj ority of the range of exposures observed there were no
888    significant differences in the estimated risk levels for marine and fresh waters. Thus,
889    based  on these NEEAR epidemiological study results, the relationship between the
890    Enterococcus qPCR levels and illness did not differ across POTW-impacted temperate
891    fresh water and marine beach sites (U.S. EPA, 201 la). For additional information, see
892    Appendix B.
893
                                                                                      18

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                                                                                 12-9-11
894    As part of the NEEAR epidemiological study design, EPA collected data from seven
895    POTW-influenced temperate fresh water and marine water beaches at intervals
896    throughout the day at different water depths. EPA collected 18 water samples each day
897    for each study. Water samples were  collected three times daily (at 0800 hr, 1100 hr, and
898    1500 hr); two water samples were collected along each of three transects perpendicular to
899    the shoreline, one in waist-high water (1 m deep) and one in shin-high water (0.3 m
900    deep). The association  between the qPCR average of the enterococci sample collected at
901    0800 hr and GI illness was nearly identical to the daily GM of all samples collected.4 The
902    GM of the 18 daily samples provided a single daily value for the health relationship
903    analysis. For the four fresh water beaches and the three marine beaches, enterococci were
904    positively associated with swimming-associated NGI illnesses (Wade et al., 2008, 2010).
905
906    A number of FIB were examined in  the NEEAR studies (see Table  1). The occurrence of
907    GI illness in swimmers was positively associated with exposure to levels of enterococci
908    enumerated with EPA's Enterococcus qPCR method A in fresh waters and marine waters
909    (Wade et al., 2008, 2010). GI illness in swimmers at marine waters  was also associated
910    with exposure to levels of anaerobic bacteria of the order Bacteroidales enumerated with
911    EPA's Bacteroidales qPCR method  (Wade, 2010). The correlation between GI illness
912    and enterococci measured by culture in the NEEAR studies was positive, but not as
913    strong as the qPCR relationship to illness. No associations between adverse health
914    outcomes and any  of the other fecal  indicator organisms were observed in either the fresh
915    water or marine beach  studies. Culturable E. coli was not included in the NEEAR
916    epidemiological studies because EPA had decided at the time to evaluate a single
917    indicator that it could potentially recommend for use by States in both marine and fresh
918    waters. Although cultured E. coli samples were not included in the NEEAR
919    epidemiological studies, other researchers confirm that culturable E. coli remains a useful
920    indicator of contamination in fresh waters (Marion et al., 2010).
921
922    Table 1. Fecal indicator organisms and enumeration methods tested in the NEEAR
923    	epidemiological studies.
EPA Epidemiological
Study
Great Lakes
2007 Marine
Tropical
Urban Runoff
Indicator/Methods Tested in Study
Enterococcus measured by qPCR, enterococci measured by
culture, Bacteroidales measured by qPCR
Enterococcus measured by qPCR, enterococci measured by
culture, E. coli measured by qPCR, Bacteroides
thetaiotamicro (potentially human associated) measured by
qPCR, Bacteroidales, male-specific coliphage measured by
antibody assay, Clostridium spp. measured by qPCR
Same as 2007 marine, but no coliphage
Same as 2007 marine, but no coliphage
924
       4 The association between the 0800-hr sample and health is potentially important from an implementation
       perspective. These results indicate that a sample taken at 0800 hr could be used for beach-management
       decisions on that day.
                                                                                     19

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                                                                                12-9-11
925    In addition to the seven temperate, POTW-influenced beaches, EPA conducted PC
926    epidemiological studies at two other beaches in 2009: a temperate beach in Surfside,
927    South Carolina that is impacted by urban run-off sources but has no POTW sources, and
928    a tropical beach in Boqueron, Puerto Rico that is impacted by a POTW. Boqueron was
929    selected as an epidemiological study site to specifically examine the health relationships
930    of the indicators in a tropical setting. For both studies, the illness levels were found to be
931    low and no correlation between illness and indicator levels was observed (significant
932    inhibition, however, was reported for water samples measured by qPCR in the tropical
933    beach study) (U.S. EPA, 2010d). The very low indicator levels are likely an important
934    reason for the absence of a demonstrated relationship between FIB and health at both
935    sites.
936
937    Other Epidemiological Studies.
938    Findings from epidemiological studies conducted by non-EPA researchers were also
939    reviewed and considered during the development of the RWQC.  Numerous
940    epidemiological investigations have been conducted since the 1950s to evaluate the
941    association between illness risk to recreational water users and the concentration of
942    suitable fecal indicators (Reviewed in U.S. EPA, 2009b). These studies have been
943    conducted in Australia, Canada, Egypt, France, Hong Kong, Israel, the Netherlands, New
944    Zealand, Spain, South Africa, the United States, and the United Kingdom. Most of these
945    studies  investigated waters that were impacted or influenced by wastewater effluent.
946    Several groups of researchers have compiled information and generated broad and wide-
947    ranging inferences from these epidemiological studies (Priiss, 1998; Wade et al., 2003;
948    Zmirou et al., 2003). For example, a systematic review and meta-analysis of 27 published
949    studies  evaluated the evidence linking specific microbial indicators of recreational water
950    quality  to specific health outcomes under non-outbreak (endemic) conditions and
951    concluded that: (1) enterococci andE. coli are indicators of fecal contamination in fresh
952    waters and demonstrated predictors of GI illness in fresh waters,  and enterococci in
953    marine  waters,  but FC are not; and (2) the risk of GI illness is considerably lower in
954    studies  with enterococci and E. coli densities below those established by EPA in 1986
955    (Wade et al., 2003).
956
957    As of the date of the draft RWQC, EPA received data from SCCWRP, which were
958    generally consistent with the NEEAR study findings. However, because results were
959    preliminary in nature, they were not considered quantitatively.
960
961    A PC epidemiological study at an Ohio reservoir (a fresh water inland beach) provided an
962    indicator-illness relationship that agrees with EPA's earlier epidemiological studies
963    conducted at fresh water beaches (Dufour, 1984; Marion et al., 2010).  In this study, E.
964    coli levels (EPA Method 1603; U.S. EPA, 2002a) were associated with HCGI in a
965    statistically similar manner as in EPA's  1970s and 1980s epidemiological studies (U.S.
966    EPA, 201 Of; see Appendix A).
967
968    Several epidemiological studies have been conducted using study designs that differ from
969    the NEEAR design, such as those referred to as randomized control trials (RCT) or
970    randomized exposure  trials (see below). The RCT is an epidemiological experiment in


                                                                                     20

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                                                                                 12-9-11
 971    which the study subjects are randomly allocated to groups to receive an experimental
 972    procedure, manner, or intervention. For recreational water exposures, the groups are
 973    bathers and nonbathers (swimmers vs. nonswimmers). The bathers are instructed as to
 974    their time in the water and activities. Similar to a PC study, bathers and nonbathers must
 975    be followed for an appropriate time to assess illness incidence and the effect of other
 976    biases and potential confounders. Exposure-response analyses may be conducted for this
 977    purpose.
 978
 979    Among the purported merits of RCT study designs are that they (1) better account for the
 980    possibility that those who do not bathe choose not to do so based on factors other than
 981    water quality, (2) associate individuals and the incidence of illness with the water quality
 982    at the time and place of bathing, and (3) account for non-water-related risk factors (Kay,
 983    et al., 1994).  One of the most  significant limitations of RCT is that the exposures in the
 984    study are not necessarily representative of those experienced by the general population.
 985
 986    EPA reviewed and qualitatively considered the results from these studies, to the
 987    maximum extent possible. For example, the  E.U. used epidemiological studies to support
 988    their WQSs (EP/CEU 2006). An RCT was conducted over four bathing seasons
 989    (summers) at a different marine beach each season in the United Kingdom.  Trends in
 990    gastroenteritis (equivalent to GI illness) rate with increasing enterococci exposure were
 991    not significantly different between sites, and data from the four beaches were pooled
 992    (Kay et al., 1994). The source of FIB in this  study was reported as domestic sewage.
 993    Gastroenteritis was defined as "all cases of vomiting or diarrhea or all cases of nausea,
 994    indigestion, diarrhea or vomiting that was accompanied by a fever". Rates of
 995    gastroenteritis were significantly higher in the exposed group than the unexposed group
 996    and adverse health effects were identified when the FIB density exceeded 32 per 100ml
 997    (Kay et al., 1994; Fleisher et al., 1998). Another E.U. randomized control trial at five
 998    fresh water bathing sites in Germany recommended the following guidance values for
 999    water quality: 100 E. coli cfu per 100 mL and 25 enterococci cfu per 100 mL, based on
1000    the no observable adverse effects levels (NOAELs) for gastroenteritis (Wiedenmann et
1001    al., 2006).
1002
1003    Additionally, a randomized exposure epidemiological study at a Florida marine beach not
1004    impacted by a POTW found that those randomized to head immersion were
1005    approximately twice as likely to develop a skin rash when swimming in water with
1006    culturable enterococci levels greater than or  equal to 40 cfu per 100 mL, than swimmers
1007    exposed to enterococci levels  less  than 40 cfu per 100 mL (Fleming et al., 2008;
1008    Sinigalliano et al., 2010).
1009
1010    Not all epidemiological studies show a clear correlation between indicator levels and
1011    health outcomes. For example, in a 1989 PC epidemiological study at marine beaches
1012    impacted by sewage outfalls and stormwater overflows in Sydney, Australia,
1013    gastrointestinal symptoms did not increase with increasing counts of FC or  enterococci
1014    (Corbett et al.,  1993). In a PC epidemiological study at Mission Bay, in California, where
1015    birds were the primary fecal source, only male-specific coliphage had a correlation with
1016    illness (Colford et al., 2005).


                                                                                      21

-------
                                                                                12-9-11
1017
1018   3.2.4 Establishing a Comparable Illness Rate for Defining Culture and qPCR
1019   Thresholds
1020
1021   The 2012 RWQC values for cultureable levels of enterococci for marine and fresh waters
1022   and E. coli for fresh waters, if adopted by a State in its WQSs, would correspond to the
1023   same level of water quality established by the 1986 criteria in terms of indicator density,
1024   if the State had WQS consistent with EPA's 1986 criteria recommendations (U.S. EPA,
1025   1986). They assume this level of water quality would be determined by culturable levels
1026   of enterococci for marine waters and fresh waters and E. coli for fresh waters.
1027
1028   The NEEAR studies provided additional culturable enterococci data that EPA used to
1029   help estimate an illness rate associated with the recommended level of water quality. The
1030   NEEAR culture-based data were analyzed in several ways, some of which differed from
1031   the reported approach with the NEEAR qPCR-based data. EPA conducted these analyses
1032   to provide a comparison with the data analysis underlying the 1986 criteria for
1033   recreational waters. The following details describe EPA analytical approaches to evaluate
1034   the culture-based data. Taken together, these analyses indicate that the illness level
1035   associated with the 2012 RWQC water quality recommendations is approximately 6 to 8
1036   cases of HCGI per 1,000 recreators in both fresh and marine waters. The HCGI illness
1037   rate metric was used in these analyses, rather than the NGI employed in the NEEAR
1038   studies, in order to maintain comparability to the 1986 criteria.
1039
1040   Approach 1.
1041   As reported by Wade et al. (2008, 2010), culture-based measures of enterococci collected
1042   in the NEEAR studies were analyzed using the same rigorous statistical approach applied
1043   to the qPCR data (Wade et al., 2008, 2010). This approach did not result in a statistically
1044   significant illness association over the entire range of observed water quality measured by
1045   culturable enterococci using the fresh water, marine, or combined beach datasets (Wade
1046   et al., 2008, 2010). Therefore, EPA is not relying quantitatively on those exposure-
1047   response relationships because the regression coefficients would have little predictive
1048   value and may be misleading.
1049
1050   EPA's fresh water NEEAR studies, however, did indicate that swimmers exposed above
1051   the guideline value of 33 cfu per 100 mL had higher risks than nonswimmers or
1052   swimmers exposed below this value (Wade et al. 2008). Additionally, during EPA's
1053   marine water NEEAR studies, approximately 16 percent of the marine study days
1054   exceeded the enterococci GM value of 35 cfu enterococci per 100  mL. Similar to the
1055   fresh water NEEAR studies, odds of diarrhea, respiratory illness and earache were
1056   elevated among swimmers compared to non-swimmers on these study days (Wade et al.,
1057   2010).
1058
1059   Approach 2.
1060   EPA also used the NEEAR study statistical approach (Wade et al., 2008, 2010) to
1061   compare the swimmer-associated risk on days when cfu per 100 mL was above and
1062   below 33 cfu per 100 mL and 35 cfu per 100 mL for fresh and marine sites, respectively


                                                                                     22

-------
                                                                                 12-9-11
1063
1064
1065
1066
1067
1068
1069
1070
1071
1072
1073
1074
1075
1076
1077
1078
1079
1080
1081
1082
1083
1084
1085
1086
1087
1088
1089
1090
1091
1092
1093
1094
1095
1096
1097
1098
(Figure la). Those data indicate that (1) on days when the current GM guidelines values
were exceeded, illness rates were similar at marine and fresh water sites, (2) illness rates
at marine sites are likely less than the previously predicted 19 HCGI per 1,000, and (3)
average illness rates in marine and fresh water were on the order of 6 to 8 HCGI per
1,000 recreators.

Approach 3.
EPA then compared the distributions of fresh water and marine swimming-associated
HCGI rates observed in the NEEAR study to that of the corresponding 1986 illness rates.
Results of this analysis indicate that the distribution of NEEAR fresh water swimming-
associated HCGI rates was consistent with that observed in the earlier studies (Figure Ib).
Boxes in Figure Ib  represent the middle 50 percent of the data, which intersect over most
of their range between these two fresh water data sets. (Note that the whiskers describe
the  10th and 90th percentiles, while the lines within the boxes indicate the median values).
In contrast, marine  swimming-associated HCGI rates were considerably higher than fresh
water rates in the 1980s, showing no commonality among the middle 50 percent. This
observation explains the greater level of HCGI risk that was estimated for marine beaches
in the 1986 criteria, at  19 cases per 1,000 in marine waters versus 8 cases per 1,000 in
fresh water. Among the NEEAR beaches, however, the distribution of marine swimming-
associated HCGI rates is similar to that of both the NEEAR and the 1986 fresh water
rates, consistent with the results presented in Figure la.
1 	 1 95% C
• Estima


e

(






                                                 is so
       a)
b)
Figure 1. Swimming-associated HCGI Illness levels observed during EPA's
epidemiological studies, a) risk on days with GM above 35 cfu at marine sites and
above 33 cfu per 100 mL at fresh water sites, b) illness observed during 1986 and
NEEAR studies

Approach 4.
EPA next attempted to compare the behavior of culturable data with respect to GI illness
from the NEEAR studies to the results of the 1986 analyses (Cabelli, 1983; Dufour,
1984). EPA could not reanalyze the 1980s data using the newer and more rigorous
NEEAR analytical approaches because the raw data from those earlier studies are no
longer available. Therefore, EPA used the same analytical approaches employed in the
                                                                                     23

-------
                                                                                 12-9-11
1099    1980s studies to evaluate the comparability of the NEEAR data with the results from the
1100    1980s.
1101
1102    In the 1986 criteria, quantitative relationships between the rates of swimming-associated
1103    illness and FIB densities were determined using regression analysis. Linear relationships
1104    were estimated from data grouped in two ways: (1) pairing the GM indicator density for a
1105    summer bathing season at each beach with the corresponding swimming-associated GI
1106    rate for the same summer (fresh water beaches), and (2) by trial days with similar
1107    indicator densities from each study location (marine beaches). The second approach,
1108    grouping by trial days with similar indicator densities, was not possible with the 1980s
1109    fresh water data because the variation of bacterial indicator densities in fresh water
1110    samples was not large enough to allow such groupings (U.S. EPA, 1986). For the 2012
1111    RWQC, EPA evaluated both approaches with the NEEAR culture-based enterococci data
1112    (seasonal and days of similar water quality) to estimate the illness associated with the
1113    recomm ended 1 evel of water qual ity.
1114
1115    Using the NEEAR culture-based enterococci data, the first analyses summarized each
1116    NEEAR beach as a seasonal GM of water quality and its average seasonal illness rate
1117    estimate, using the entire body of culturable enterococci data from the NEEAR studies.
1118    Illness rates were translated from NGI case definition to the older HCGI case definition
1119    to be able to compare NEEAR epidemiological results to  1986 results (U.S. EPA, 201 la).
1120    These data points generally fell within the predicted range of the published
1121    epidemiological regressions (Cabelli, 1983; Dufour, 1984). However, this analysis
1122    proved to be insufficient to estimate NEEAR study illness estimates, because only seven
1123    data points—one for each of the NEEAR beaches—were  available.
1124
1125    EPA then examined the NEEAR culture-based enterococci data consistent with the
1126    analytical approach utilized for the marine water studies in the 1986 criteria by
1127    aggregating days of similar water quality (bins) for each beach (Cabelli, 1983; U.S. EPA
1128    1986). The NEEAR data were sorted by the observed GM for each beach day and the
1129    data for each beach were grouped according to natural breaks in these data.  Bins of beach
1130    days were established from these data to balance, to the extent feasible, the  existence of
1131    natural breaks of days with similar culturable enterococci GM and the number of study
1132    participants represented in each bin (Table 2). The binned data for all seven NEEAR
1133    beaches resulted in more data points per beach for both fresh water and marine beaches
1134    (Figures 2 and 3), which provided a greater level of resolution to the data compared to the
1135    seasonal-level fresh water analysis described above. Illness rates were also translated into
1136    HCGI equivalents.
1137
1138    EPA compared both fresh water and marine culture-based NEEAR indicator data to the
1139    corresponding 1986 regressions using the binned data. Results of this analysis indicate
1140    the vast majority of these data points fall within the 95th percentile prediction intervals
1141    derived from the 1986 regression models (Figure 2). The prediction intervals can be used
1142    to assess whether the additional data fall within an expected range based on the 1986
1143    data. While, the NEEAR marine culture-based data cluster at the lower end  of the water
1144    quality and illness distribution described by the 1986 marine regression, they occur in a


                                                                                      24

-------
1145
1146
1147
1148
1149
1150
1151
1152
1153
1154
1155
                                                                                  12-9-11
similar range of water quality and illness that was observed in the fresh water studies
(Figure 3). Because this analysis does not take into account the individual and beach-
level factors that may affect the association, EPA is only using this analysis to describe
the potential range of illness associated with the water quality level recommended in the
2012 RWQC for marine and fresh waters, (logio of 35 = 1.54 and logio of 33 = 1.52,
respectively). Based on this analysis, the corresponding mean estimate of illness ranged
approximately from 6 to 8 cases of HCGI per 1,000 recreators for both fresh waters and
marine waters (Figure 3).

Table 2. NEEAR culture-based enterococci and illness rate data for each of the
seven beaches.



Beach


West Beach
(fresh)


Huntington
Beach
(fresh)

Silver Beach
(fresh)



Washington
Park Beach
(fresh)

Edgewater
Beach
(marine)

Fairhope Beach
(marine)


Goddard Beach
(marine)


Daily
geometric
mean
Enterococcus
density
(CFU/100 ml)

1.6
9.2
25.1
110.4
4.7
9.2
15.7
81.1
7.0
14.8
25.8
51.3
106.6
8.4
17.2
27.9
44.6
2.3
10.0
18.9
77.7
5.5
12.7
24.1
81.0
2.6
18.8



Total number
interviewed


1122
726
463
553
731
733
526
850
864
2203
3128
2525
2152
722
789
1368
1465
555
239
441
108
494
541
351
629
2433
535



Number
reporting no
water
contact


360
144
101
117
426
391
251
467
220
603
900
808
843
198
171
364
524
135
66
152
27
261
200
126
266
1322
262



Number
reporting
immersion


556
468
299
344
186
208
167
196
490
1215
1720
1281
945
398
488
764
710
173
77
139
40
120
186
114
225
596
183



Number
NGI cases
no contact


21
2
8
5
43
27
31
46
16
36
54
46
36
15
10
23
31
10
7
13
2
27
19
5
23
58
15



Number
NGI cases
immersion


60
39
28
42
18
33
22
28
37
89
138
98
68
30
45
60
71
13
10
19
5
9
20
11
22
33
15
Excess
HCGI
swimmers
(S/1000),
beach
average
non-
swimmer
illness rate
12.9
7.4
9.7
16.0
0.2
14.0
8.0
10.5
4.4
3.9
5.5
4.6
3.6
2.8
6.5
3.5
8.3
-2.0
10.1
11.7
9.1
-2.6
4.6
2.2
2.4
2.1
8.0
1156
                                                                                      25

-------
                                                                                   12-9-11
1157
1158

1159
1160
1161
1162
1163
40 •

35 •
S 30 •
£
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O
8 20-
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1986 95% prediction interval
D NEEAR freshwater data




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                 0.5   1.0   1.5   2.0   2.5   3.0

                   LoglO Enterococci density/ 100mL
               a)
                      b)
                                                     40-

                                                     35-

                                                     30-

                                                     25-

                                                     20-

                                                     15-

                                                     10-

                                                     5-

                                                     0-

                                                     -5-
•
A
1986 marine data
1986 marine regression
1986 95% Prediction Interval
NEEAR marine data
                                                      0.0  0.5  1.0  1.5  2.0  2.5  3.0  3.5

                                                        LoglO Enterococci density / 100ml_
        Figure 2. NEEAR studies culture data aggregated by similar water quality and 1986
        criteria data for (a) fresh water beaches and (b) marine water beaches.
1 165
1 166
1167
1 168
1 169
1 170
1171
1 172
1 173
            25 -i
           15 -I
         O
         §  10 H
         

-------
                                                                                12-9-11
1174   factor for predicting culturable enterococci levels at NEEAR beaches (see Appendix
1175   B.7).
1176
1177   Conclusion.
1178   Taken together, the set of approaches described above provide lines of evidence to refine
1179   the illness rate estimate associated with the recommended marine criterion for
1180   enterococci (i.e., 19 HCGI per 1,000 recreators was the best mean estimate available at
1181   the time in 1986, but it was accompanied by a wide range of uncertainty) and indicates
1182   that the recommended 2012 RWQC values are similarly protective of public health in
1183   both marine waters and fresh waters.
1184
1185   Derivation of an equivalent qPCR value.
1186   EPA then derived a value for enterococci measured by qPCR value comparable to the
1187   culture-based value based on an illness rate of 8 HCGI per 1,000 recreators for both fresh
1188   waters and marine waters computed from the combined NEEAR epidemiological
1189   regression model (Figure 4) (U.S. EPA, 201 la). This model was used rather than separate
1190   models for marine waters and fresh waters because EPA's analysis indicated that there
1191   was little evidence for differences in illness rate estimates obtained from separate models
1192   from marine and fresh water beaches and because the beach-specific separate models
1193   showed no statistical improvement over a single combined model (U.S. EPA, 201 la).
1194   Furthermore, results from the marine water and fresh water studies are sufficiently
1195   similar to allow combining the NEEAR marine water and fresh water data to give a
1196   single relationship between health effects and water quality measured with a new rapid
1197   method (U.S. EPA, 201 la). The relationship between swimming-associated illness in
1198   terms of NGI per 1,000 recreators and water quality developed from the combined marine
1199   and fresh water data is defined as follows:
1200
1201   Swimming associated NGI illness = -27.3 + 23.64 (mean Logic qPCR CCE/100 mL)
1202
                                                                                     27

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                                                                                 12-9-11
1203
1204
1205
1206
1207
1208
1209
1210
1211
1212

1213
1214
1215
1216
1217
1218
1219
1220
1221
1222
1223
1224
1225
1226
               o
               o
               o
               O
               o:
               !S
               UJ
               03
               Dl
               C
               '£
               £
               s=
                          Swimming-associated illness
                          95% Confidence bound
                     10
                                  100                  1000
                                Enterococcus CCE/100ml (ddCT)
                                    daily geometric mean
Figure 4. Swimming-associated NGI illness and daily average Enterococcus qPCR
CCE. All subjects, marine and fresh water beaches combined (Intercept= -0.0273,
Slope= 0.02364).

The illness level of 8 cases of HCGI per 1,000 recreators corresponds to an estimated 36
cases of NGI per 1,000 recreators based on a translation of the definition of NGI to HCGI
using a factor of 4.5 (U.S. EPA, 201 la). Thus, a qPCR-based GM value of 475 CCE
enterococci per 100 mL corresponds to 36 cases of NGI per 1,000 recreators. Based on
the regression model, the following equation was used to derive the qPCR value:
                        4.S*//CG/+27.3
       qPCR Value  =10
where:
23.64
             qPCR = qPCR value in units of CCE per 100 mL
             HCGI =HCGI illness rate5 in illnesses per 1,000 recreators

This approach to derive a comparable qPCR-based recommended value for enterococci
allows EPA to use all the data collected during the NEEAR studies, demonstrates a
consistent level of protection for enterococci enumerated with culture-based methods,
and provides a qPCR value for States that desire a more rapid enumeration technique for
beach monitoring.

Summary.
EPA's 2012 RWQC recommendations, if adopted into State WQSs, will correspond to
the same level of water quality associated with the previous 1986 criteria
         See U.S. EPA (2011) for translation information of HCGI illness rate into the NEEAR illness rate.
                                                                                     28

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                                                                                 12-9-11
1227    recommendations. The analyses conducted with the NEEAR culture-based enterococci
1228    data allowed for a refined estimate of illness associated with the current level of water
1229    quality described by 35 cfu enterococci per 100 mL in marine waters and 33 cfu
1230    enterococci per 100 mL in fresh waters. Furthermore, the refined illness rate estimate
1231    range of 6 to 8 HCGI per 1,000 recreators applies to both fresh and marine waters. The
1232    illness rate of 8 HCGI per 1,000 recreators was used as the basis for developing a qPCR-
1233    based enterococci value. Visual representations of the separate fresh water and marine
1234    water health relationships can be found in Wade et al.  2008 and Wade et al. 2010.
1235
1236    3.3 Scope of Protected Population
1237
1238    EPA's 1986 criteria recommendations are supported by epidemiological studies that were
1239    conducted in the late 1970s and 1980s. Those studies enrolled participants according to
1240    the following criteria: "Whenever possible, family units were sought because information
1241    on multiple individuals could be obtained from one person, usually an adult member of a
1242    family. During this initial contact, the following information was obtained on each
1243    participant:  sex, age, race and ethnicity" (Dufour, 1984). This enrollment strategy
1244    ensured that children were highly represented in those epidemiological studies. When
1245    EPA published the 1986 recommended criteria values, EPA related the water-quality
1246    level to the  associated illness-rate level derived in the epidemiological studies conducted
1247    in the 1970s and 1980s. Thus, the illness rates corresponding to the 1986 criteria
1248    recommendations are based on the epidemiological relationship for the general
1249    population that includes children. EPA is proposing a similar approach for deriving
1250    illness levels for the 2012 RWQC.
1251
1252    As in the previous EPA epidemiological studies, children were well represented in EPA's
1253    NEEAR studies population. The proportions of individuals in the under 5-year and 5-
1254    to 11-year age categories that were enrolled in the epidemiological  studies  were greater
1255    than those present in the U.S. demographic. For example, at West Beach the proportion
1256    of children aged 10 years and under made up 20 percent of the study sample. A similar
1257    over-representation of children is true for the other beaches, including Huntington (20
1258    percent of the study sample), Washington Park (22 percent), Silver Beach  (22 percent),
1259    Edgewater (17 percent), Fairhope (30 percent), and Goddard (20 percent).  According to
1260    the U.S.  Census data for 2009, children younger than 10 years of age make up
1261    approximately 14 percent of the U.S. population (Census, 2010). Based on national
1262    demographics, the NEEAR epidemiological studies included an over-representation of
1263    children.
1264
1265    EPA conducted statistical analyses of the data from each of EPA's epidemiological
1266    studies at fresh water, marine, and tropical beaches to  evaluate whether children at these
1267    sites were at an increased risk of illness following exposure to recreational waters. The
1268    results for children were compared to adults and other age groups.  The age groups used
1269    for comparison included the following: 10 years and under, 11 to 55 years, and over 55
1270    years of age. Other age groups for children were not separately analyzed due to small
1271    sample sizes. Data for children (i.e., 10 years and under) were specifically analyzed to
                                                                                      29

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                                                                                 12-9-11
1272    evaluate whether their behavior and/or physiology results in different illness rates
1273    compared to the general population.
1274
1275    In the NEEAR fresh water epidemiological studies, the association between GI illness
1276    and water quality, as measured by EPA's Enterococcus qPCR method A, was stronger
1277    among children (age 10 years and under) compared with the NEEAR general population,
1278    which also included children. Relative to body size, children breathe more air and ingest
1279    more food and water than adults (U.S. EPA, 2003). Children also exhibit behaviors that
1280    increase their exposure to environmental  contaminants, including increased head and
1281    body immersion in recreational waters (Wade et al., 2006, 2008; U.S. EPA, 2010d) and
1282    hand-to-mouth contact (Xue et al., 2007). The immature immune systems of children can
1283    also leave them particularly vulnerable to the effects of environmental agents (Pond,
1284    2005). A higher proportion of children immerse their heads in shallow water compared
1285    with adults. Children also stay in the water longer than adults (Wade et al., 2006, 2008)
1286    and ingest more water (Dufour et al., 2006). These characteristics supported the
1287    hypothesis that a significant difference in GI illness in children in comparison to the
1288    general population could have been observed in the epidemiological studies.
1289
1290    In the NEEAR fresh water studies, however, there was considerable overlap in the
1291    confidence intervals associated with the estimated mean illness responses between
1292    children and the general population. The confidence intervals for the children's curve
1293    were wider than the confidence intervals for the general population. When health effects
1294    were compared with water quality, as measured by cultured enterococci, differences
1295    between children (age 10 years and under) and the general population were not observed
1296    (Wade et al., 2008). Swimmers exposed to water qualities above densities of 33 cfu per
1297    100 mL had an elevated risk of developing GI illness compared with non-swimmers and
1298    swimmers exposed to water having densities less than 33 cfu per 100 mL. Both cohorts,
1299    including children (age 10 years and under) and the general population, demonstrated
1300    similar responses to water having more than 33 cfu per 100 mL.
1301
1302    In the NEEAR marine epidemiological studies, there was insufficient evidence of
1303    increased illness among children corresponding to water quality as measured by qPCR.
1304    As with the fresh water sites, a higher proportion of children age 5 to 10 years (75
1305    percent) would immerse their bodies or head in the water compared with adults over age
1306    55  years (26 percent) (Wade et al., 2010). Elevated GI illness levels were observed
1307    among swimmers of all age groups compared with non-swimmers on days that exceeded
1308    the enterococci GM value of 35 cfu per 100 mL (Wade et al., 2010).
1309
1310    The epidemiological studies conducted by EPA in tropical regions (Boqueron Beach,
1311    Puerto Rico) and temperate marine waters that were impacted by urban runoff (Surfside
1312    Beach, South Carolina) showed no evidence of increased illness in children that
1313    corresponded to exposure to FIB in the recreational waters (U.S. EPA, 2010d).
1314
1315    EPA considered children's unique physiological and behavioral characteristics when
1316    developing these criteria. The collective results of the NEEAR epidemiological studies,
1317    however, provide inconclusive evidence that children (age 10 years and under) exhibited


                                                                                     30

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                                                                                 12-9-11
1318    a significantly different illness response given the range of water qualities measured in
1319    these studies.
1320
1321    Another subpopulation of participants, those over the age of 55 years, was also present
1322    but at levels too low to be evaluated separately. For example, in the fresh water studies,
1323    this subgroup represented 7 percent of the study population. This small sample size did
1324    not allow EPA to make any conclusions about risk in the subpopulation over 55 years of
1325    age. EPA's NEEAR studies were also not designed to evaluate the effects on groups with
1326    compromised immune systems or other vulnerable subpopulations.
1327
1328    EPA  considered all the demographic data and results presented above and concluded that
1329    the robustness of the estimates for the general population data provide a significant
1330    advantage over the more uncertain and smaller sample set that consisted only of children.
1331    Importantly, the general population data are weighted to  include children in a robust
1332    manner. Thus, the general population data provide an appropriate basis for deriving
1333    EPA's recommended values for the 2012 RWQC.
1334
1335    The 2012 RWQC document includes information for States on an additional protective
1336    option for children through implementation of qPCR for  site-specifically, which would
1337    allow families to make real-time decisions to protect their children. In contrast to the
1338    "rapid" methods,  such as  qPCR, traditional culture methods provide estimates of water
1339    quality a day or two after the actual exposure. qPCR can  be performed in 2-6 hours and
1340    has been shown to be  successful when implementing same-day health-protective
1341    decisions (Griffith and Weisberg, 2011). Predictive models will also be available for
1342    rapid notification with these new criteria for the measurement of E. coli and enterococci
1343    by culture and qPCR as presented in section 5.1.2. These models have been demonstrated
1344    to be useful tools for implementing beach monitoring programs in the Great Lakes
1345    (Francy, 2009; Frick et al., 2008; Ge and Frick, 2009). Because children may be more
1346    exposed and more sensitive to pathogens in recreational waters, it is imperative that
1347    effective risk communication  and health outreach be done to effectively mitigate
1348    exposure to contaminated waters. Alerting families with children to the level of water
1349    quality on a given beach day,  in real time, will  allow for better protection of children.
1350
1351    3.4 Waterbody Type
1352
1353    EPA's 2012 RWQC national recommendations are for all surface waters of the United
1354    States designated by a State for swimming, bathing, surfing, or similar water contact
1355    activities. Historically, the scientific evidence used to generate criteria recommendations
1356    has been based on data collected mostly from coastal, temperate and Great Lakes
1357    freshwaters. The stakeholder community has asked EPA  to consider whether EPA's
1358    criteria recommendations could be used to develop State WQSs for other types of waters.
1359
1360    In response, EPA conducted a review of the available information comparing coastal
1361    (including Great Lakes and  marine) and non-coastal (including flowing and non-flowing
1362    inland waters, such as streams, rivers, impoundments, and lakes) waters to evaluate
1363    whether EPA should include recommendations in the 2012 RWQC for all waterbody


                                                                                      31

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                                                                                  12-9-11
1364    types (U.S. EPA, 2010g). Additionally, EPA considered the WERF Inland Water
1365    Workshop report (WERF, 2009) and subsequent meeting report publication (Dorevitch et
1366    al., 2010), which concluded that the inclusion of non-coastal waters in the 2012 criteria
1367    will result in public health protection, by preventing illnesses associated with exposure to
1368    non-coastal waters if States adopt WQS based on EPA's 2012 RWQC recommendations.
1369    Additionally, outbreaks from exposure to non-coastal waters indicate a need for public
1370    health protection in such settings. FIB monitoring can be used as a way to reduce the
1371    occurrence of outbreaks of severe illness, as well as the sporadic cases of illness that
1372    occur among swimmers. Overall, the distinction of non-coastal waters versus coastal
1373    waters is of less importance than more fundamental variables such as the source of fecal
1374    contamination, scale of the body of water, and the effects of sediment, which translate
1375    into differences in the densities, transport, and fate of indicators and pathogens
1376    (Dorevitch et al., 2010). The next two subsections describe the scope of the  currently
1377    available data that EPA considered supporting the revision of criteria that include both
1378    coastal and non-coastal waters. For additional information on the EPA report, see
1379    Appendix B.6.
1380
1381    Waterbody type and sources of fecal contamination.
1382    EPA's literature review identified the source of fecal pollution as one of the most
1383    important factors when considering the potential differences between EPA
1384    epidemiological study  sites and non-coastal waters (U.S. EPA 2010g). More information
1385    specifically concerning the source of fecal contamination is found in  section 3.5. Sources
1386    of fecal contamination are discussed in  this section only insofar as they potentially impact
1387    FIB in coastal versus non-coastal settings.
1388
1389    All surface waters receive FIB from point sources, diffuse sources (which may consist of
1390    point source  and non-point source pollution), direct deposition, and resuspension of FIB
1391    contained in  sediments. Loadings and hydrodynamics of FIB in POTW-impacted coastal
1392    and non-coastal waters are generally similar. POTW discharges, which are known
1393    sources of human-derived pathogens and  indicators from fecal pollution, are relatively
1394    steady. Differences exist in FIB loadings between POTW-impacted coastal and non-
1395    coastal waters,  and non-coastal waters impacted by sources other than treated sewage
1396    effluent due to  differences in the physical and biological characteristics that influence
1397    FIB survival  compared to pathogen survival. Some of the characteristics include potential
1398    and extent of shading,  hydrodynamics, potential for sedimentation, and microbial
1399    ecology.
1400
1401    Differences can exist between coastal and non-coastal waters that could affect the
1402    relationship between FIB levels and adverse health effects, including the type of fecal
1403    source impacting the waterbody and the differences in fate and transport of pathogens
1404    and FIB  in the receiving waters. For example, POTW effluents are a continual loading
1405    event, whereas fecal contamination from other  sources, particularly non-point sources,
1406    occurs primarily during precipitation events. Pathogens and FIB in rain event-driven fecal
1407    loadings could  be affected by the different transport characteristics in coastal versus non-
1408    coastal waters.
1409
                                                                                       32

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                                                                                  12-9-11
1410    Epidemiological studies in non-coastal waters.
1411    EPA also evaluated the available epidemiological evidence in non-coastal waters. Only a
1412    handful of studies have been conducted in small lakes and even fewer in inland flowing
1413    waters. Among those, one of the epidemiological sites for earlier EPA studies (Dufour
1414    1984) was a small inland lake in Oklahoma, which helped provide the basis for the 1986
1415    criteria.
1416
1417    Ferley et al. (1989) conducted a retrospective study in the French Ardeche basin to assess
1418    the relationship between swimming-related morbidity and the bacteriological quality of
1419    the recreational water. Tourists (n = 5737) in eight holiday camps were questioned about
1420    the occurrence of illness and their bathing habits during the week preceding the
1421    interviews. GI illness was higher in swimmers than in non-swimmers. Fecal  streptococci
1422    (FS) were best correlated to GI illness. Direct linear regression models and FC did not
1423    predict risk as well. The concentration of FS above which bathers exhibited higher illness
1424    rates than non-bathers was as 20 FS per 100 mL.
1425
1426    A series of RCT epidemiological studies was conducted in Germany to establish the
1427    association of illness with recreational use of designated fresh recreational waters (four
1428    lakes and one river) (Wiedenmann et al., 2006). All study sites were considered to be in
1429    compliance with the European standards for total coliform and FC for at least the three
1430    previous bathing seasons. Sources of fecal contamination at the study sites included
1431    treated and untreated municipal  sewage, non-point source agricultural runoff, and fecal
1432    contamination from water fowl.  Based on the water quality measured as levels of E. coli,
1433    enterococci, somatic coliphages, or Clostridiumperfringens, and observed health effects,
1434    the authors recommended guideline values for each of these fecal indicator organisms.
1435    They noted that these values for E. coll and enterococci were consistent with EPA's 1986
1436    criteria for recreational water recommendations.
1437
1438    Epibathe, a public health project funded under E.U. Framework Programme  6 to produce
1439    "science support for policy" began in December 2005 and ended in March 2009.  The
1440    imperative for this research effort was the relative paucity  of E.U. data describing the
1441    health effects of controlled exposure (head immersion) in E.U. fresh waters and
1442    Mediterranean marine waters. Both aquatic environments provide important recreational
1443    resources throughout the E.U. (European Commission-Epibathe, 2009). Epibathe
1444    comprised a series of marine and fresh recreation water epidemiological studies
1445    conducted in 2006 and 2007 in Spain and Hungary, respectively. Four riverine
1446    recreational sites were assessed in Hungary and four coastal sites were assessed in Spain.
1447    All sites were in compliance with the European standards specified in the E.U. bathing
1448    Water Directive (EP/CEU, 1976). For E.U. marine waters  (Spain and the U.K. RCT
1449    studies), the clearest trend in increasing risk of illness with decreasing water quality was
1450    evident using enterococci as an indicator of water quality. For fresh waters (German and
1451    Hungary RCT studies), the clearest indicator-illness relationship between GI symptoms
1452    and water quality was seen with E. coll. Both analyses (fresh waters and marine waters)
1453    suggest elevations in GI illness in the controlled exposure  (head immersion) cohorts. The
1454    authors concluded that the empirical field studies and combined data analysis suggested
1455    that the WHO or E.U. water quality standard recommendations did not need to be


                                                                                      33

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                                                                                 12-9-11
1456    revised. Additionally, EPA concluded that these results provide further evidence that the
1457    E.U.-recommended E. coll and enterococci guidelines values are consistent with the 1986
1458    criteri a for recreati onal waters.
1459
1460    A PC study was recently conducted at a small inland lake in Ohio (Marion, 2010). The
1461    study was undertaken to examine the illness rates among inland recreational water users.
1462    It also evaluated the effectiveness of E. coli as an effective predictor of GI illness risk
1463    among recreators. Human health data were collected during the 2009 swimming season at
1464    East Fork Lake, Ohio and adverse health outcomes were reported 8-9 days post-
1465    exposure. The authors concluded that E. coli was significantly associated with elevated
1466    GI illness risk among swimmers compared to non-swimmers. The risk of illness
1467    increased among swimmers with increasing densities of E. coli. The results of this study
1468    were consistent with prior fresh water beach studies used by EPA to develop the 1986
1469    criteria for recreational waters.
1470
1471    Based on the best available information, which is summarized above, EPA has
1472    determined that the 2012 RWQC recommendations are applicable to coastal and non-
1473    coastal waterbodies. Although some differences may exist between coastal and non-
1474    coastal waters, application of the recommended criteria in both water types would
1475    constitute a prudent approach to protect public health. States wishing to address site-
1476    specific conditions or local waterbody characteristics in their WQS should refer to section
1477    5 of this document for suggestions on approaches.
1478
1479    3.5 Sources of Fecal Contamination
1480
1481    In the 1986 criteria, EPA recommended:
1482           "the application of these criteria unless sanitary and epidemiological studies show
1483          the sources of the indicator bacteria to be nonhuman and that the indicator
1484          densities are not indicative of a health risk to those swimming in such waters.
1485          EPA is sponsoring research to study the health risk of non-point source pollution
1486          (NPS) from rural areas on the safety of water for swimming. Definitive evidence
1487          from this study was not available at the time of preparation of this criterion, but
1488          will be incorporated into subsequent revisions."
1489
1490    Section 303(i)(2)(A) required EPA to promulgate criteria for States as protective of
1491    human health as EPA's 1986 criteria where States had failed to do so for their coastal and
1492    Great Lakes waters.  When EPA promulgated WQSs for those States based on the 1986
1493    criteria in 2004, EPA evaluated the scientific understanding of the human health risks
1494    associated with nonhuman sources of fecal contamination and concluded that although
1495    "[the] EPA's scientific understanding of pathogens and pathogen indicators has  evolved
1496    since 1986, data characterizing the public health risk associated with nonhuman sources
1497    is still too limited for the [EPA] to promulgate [WQSs for States based on] another
1498    approach." Thus, the federally promulgated criteria values in the Rule were considered
1499    applicable regardless of origin unless a sanitary survey shows that the sources of the
1500    indicator bacteria are nonhuman and an epidemiological study shows that the indicator
1501    densities are not indicative of a human health risk. In addition, in evaluating whether


                                                                                      34

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                                                                                12-9-11
1502    State standards were as protective of human health as EPA's 1986 criteria, EPA
1503    concluded that State WQSs with exemptions for non-human sources were not as
1504    protective of human health as EPA's 1986 criteria (See 69 FR at 67228).
1505
1506    EPA has continued to examine the potential for illness from exposure to nonhuman fecal
1507    contamination compared to the potential for illness from exposure to human fecal
1508    contamination. One of the key topics discussed at the Experts Scientific Workshop on
1509    Critical Research Needs for the Development of New or Revised Recreational Water
1510    Quality Criteria (U.S. EPA, 2007a) was different sources of FIB, including human
1511    sources and a variety of nonhuman sources (such as animals and the environment). EPA
1512    further investigated this topic in Review of Published Studies to Characterize Relative
1513    Risks from Different Sources of Fecal Contamination in Recreational Waters (U.S. EPA,
1514    2009b) and Review ofZoonotic Pathogens in Ambient Waters (U.S. EPA, 2009a). EPA
1515    recognizes the public health importance of waterborne zoonotic pathogens. However, the
1516    state of the science has only recently allowed for the characterization of the potential
1517    health impacts from recreational exposures to zoonotic pathogens relative to the risks
1518    associated with human sources of fecal contamination. Overall, however, the
1519    aforementioned reviews indicate that both human and animal feces in recreational waters
1520    pose potential threats to human health, especially in immunocompromised persons and
1521    subpopulations. For additional information,  see Appendix C.
1522
1523    Humans can become ill from exposure to zoonotic pathogens in fecal contamination
1524    originating from animal sources. Livestock and wildlife carry both human pathogens and
1525    FIB, and can transmit these microbes to surface waters and other bodies of water (CDC,
1526    1993, 1996, 1998, 2000, 2002, 2004, 2006, 2008; USDA, 2000). Additionally, many
1527    documented outbreaks of potential zoonotic pathogens, such as Salmonella, Giardia,
1528    Cryptosporidium, and enterohemorrhagic E. coli O157:H7, could be of either human or
1529    animal origin, although providing proper source attribution for these outbreaks can be
1530    quite difficult. U.S. Centers for Disease Control and Prevention (CDC) reports have
1531    documented instances of E. coli O157:H7 infection resulting from exposure to surface
1532    waters, but the source of the contamination is not specified (CDC 2000, 2002). Other
1533    studies have linked recreational water exposure to outbreaks caused by potentially
1534    zoonotic pathogens, but the sources of fecal contamination in these waters were not
1535    identified (Valderrama, 2009; Roy, 2004; U.S. EPA 2009a). Although formal
1536    surveillance information is not comprehensive, Craun et  al. (2005) estimated that 18
1537    percent of the 259 recreational water outbreaks reported to the CDC from 1970 to 2000
1538    were associated with animals.
1539
1540    One study documenting a 1999 outbreak of E.  coli O157:H7 at a lake in Vancouver,
1541    Washington suggested that duck feces were the source of the pathogen causing the
1542    outbreak (Samadpour, 2002). More than 100 samples of water, soil, sand, sediment, and
1543    animal feces were collected in and around the lake and tested. E. coli O157:H7 was
1544    detected in both water and duck fecal samples. Genetic analyses of the E. coli isolates
1545    demonstrated similar results in the water, duck feces, and patient stool samples. Duck
1546    feces could not be confirmed as the primary source of the zoonotic pathogens, however,
1547    because the ducks could have been infected by the same  source of contamination that was


                                                                                    35

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                                                                                 12-9-11
1548    present in the lake. Other notable outbreaks are discussed in the EPA's Review of
1549    Published Studies to Characterize Relative Risks from Difference Sources of Fecal
1550    Contamination in Recreational Water (Appendix C and U.S. EPA, 2009b).
1551
1552    Fecal contamination from nonhuman sources can transmit pathogens that can cause GI
1553    illnesses, such as those reported in EPA's NEEAR and other epidemiological studies.
1554    The potential human health risks from human versus non-human fecal sources, for a
1555    given level of water quality as measured by FIB, can be different, with certain non-
1556    bovine fecal sources potentially posing less risk (Seller et al. 2010b. and Schoen and
1557    Ashbolt, 2010).
1558
1559    Although EPA's research indicates that the source of contamination is critical for
1560    understanding the human health risk associated with recreational waters, there is
1561    variability in the amount of human health risk in recreational waters from the various
1562    fecal sources due to the wide-ranging environmental conditions that occur across the
1563    United States.  EPA and others have documented human health impacts in numerous
1564    epidemiological studies in fresh waters and marine waters primarily impacted by human
1565    sources of fecal contamination (see sections 3.2 and 3.4 for a discussion of these studies).
1566    The cause of many of the illnesses, particularly those resulting from exposure to POTW
1567    effluent, is thought to be viral (USEPA, 1986, Seller et al., 2010a, Bambic et al., 2011).
1568
1569    While human sources of fecal contamination are fairly consistent in the potential human
1570    health risks posted during recreational exposure, non-human sources of fecal
1571    contamination, and thus the potential human health risks, can vary from site-to-site
1572    depending on factors such as: the nature of the non-human source(s), the fecal load from
1573    the non-human source(s), and the fate and transport characteristics of the fecal
1574    contamination from deposition to the point of exposure. Nonhuman fecal sources can
1575    contaminate recreational bodies of water via direct fecal loading into the body of water,
1576    and indirect contamination can occur via runoff from the land. The fate and transport
1577    characteristics of the zoonotic pathogens and FIB present under these conditions can be
1578    different (e.g., differences in attachment to particulates or differences in susceptibility to
1579    environmental parameters affecting survival) (see  Appendix C.4). For more information
1580    on pathogenic risks from nonhuman sources, see Review of Zoonotic Pathogens in
1581    Ambient Waters (U.S. EPA, 2009a).  EPA did not  develop nationally applicable criteria
1582    values that adjust for the source  of the fecal contamination, for non-human sources.
1583    Rather, EPA recommends that States use these nationally applicable criteria in all waters
1584    designated for primary  contact recreation.
1585
1586    Few epidemiological studies have been conducted in waters impacted by nonhuman
1587    sources of fecal contamination resulting in an ambiguous understanding of the
1588    relationship between swimmer-associated illness and any of the conventionally
1589    enumerated FIB in those types of waters. For example, Calderon (1991) found a lack of a
1590    statistical association between swimmers' illness risk and FIB levels in a rural fresh
1591    waterbody impacted by animal fecal contamination; however, other researchers have
1592    commented that this lack of statistical association was likely due to the small study size
1593    and not a lack of potential human health risks (McBride, 1993). Another epidemiological


                                                                                      36

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                                                                                 12-9-11
1594    study conducted at a nonhuman, nonpoint source impacted beach at Mission Bay,
1595    California documented an increase in diarrhea and skin rash in swimmers versus non-
1596    swimmers, but the incidence of illness was not associated with any of the traditional FIB
1597    levels tested (Colford, 2007). The few studies conducted in non-POTW-impacted waters
1598    that also report significant health effects (McBride et al., 1998; Cheung, 1990; and
1599    Wiedenmann 2006) have (1) been conducted in highly animal-impacted scenarios, and
1600    (2) epidemiological data from beaches with nonhuman fecal source impacts combined
1601    with data from beaches impacted by human fecal contamination sources. McBride et al.
1602    (1998) conducted a separate analysis of the impact on human  sources versus the impact
1603    of animal sources on beach sites in addition to evaluating the effects of both human and
1604    animal sources combined and concluded that illness risks posed by animal versus human
1605    fecal material were not substantially different. Thus, waterbodies with substantial animal
1606    inputs can result in potential human health risks on par with those that result from human
1607    fecal inputs.
1608
1609    Microbial risk assessment approaches are available to assist in characterizing potential
1610    human health risks from nonhuman sources of fecal contamination (Till and McBride,
1611    2004, Roser et al., 2006, Seller et al., 2010b, Schoen and Ashbolt, 2010). For example,
1612    New Zealand, where roughly 80 percent of the total notified illnesses are zoonotic and
1613    potentially waterborne, recently updated its recreational fresh water guidelines based on a
1614    risk analysis of campylobacteriosis (accounting for over half of the reported total
1615    notifiable disease burden in that country) and using E. coli as  a pathogen indicator (Till
1616    and McBride,  2004). Since those waters were highly impacted by fecal contamination, in
1617    this case from agricultural sources, a predictable relationship between the pathogen and
1618    the FIB was able to be developed.  The correlation between the occurrence of
1619    Campylobacter and E. coli may not hold in all waters, but this relationship was
1620    demonstrated in New Zealand, particularly in waters with high levels of Campylobacter
1621    and E. coli. Water quality guidelines based on this work resulted in values for E. coli,
1622    which when compared at similar estimated illness levels, are consistent with the 2012
1623    RWQC recommendations.
1624
1625    EPA determined that the current scientific understanding of the human health risks
1626    associated with the wide variation of exposures to nonhuman fecal contamination is
1627    insufficient to support development of separate nationally applicable 2012 RWQC for
1628    waterbodies impacted by nonhuman sources. The risk presented by fecal contamination
1629    from nonhuman  sources varies and, has been shown in some cases, to be potentially less
1630    significant than the risk presented by fecal contamination from human sources (Seller et
1631    al., 2010a,b; Schoen and Ashbolt, 2010, Bambic et al., 2011). The number of cases where
1632    animals are suspected as being the likely cause of the contamination and resulting illness,
1633    however, present a strong case for not neglecting these sources altogether. EPA's
1634    research indicates that some nonhuman fecal sources (cattle in particular) may pose risks
1635    comparable to those risks from human sources; not all animal fecal material, however,
1636    presents the same level of risk (see Appendix C for additional details; Seller et al.,
1637    2010a,b; U.S.  EPA, 2010a). Human pathogens are present in animal fecal matter, and
1638    there is, therefore, a potential risk from recreational exposure  to human pathogens in
1639    animal-impacted waters. EPA feels that the state of the science is not developed


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                                                                                 12-9-11
1640    sufficiently for quantifying potential human health risks from non-human fecal
1641    contamination on a national basis given the site-to-site variability. For waters
1642    predominated by non-human sources and in the absence of site-specific criteria, EPA
1643    recommends that the national criteria should be used to develop WQS.
1644
1645    For these reasons, EPA has concluded that States adopting the 2012 RWQC, regardless
1646    of the source of fecal contamination, would result in WQSs protective of public health.
1647    EPA is not developing separate national criteria for nonhuman sources.  States interested
1648    in addressing the potential human health risk differences from different sources of fecal
1649    contamination on a site-specific basis should refer to section 5.2.2 of this document for
1650    suggestions on approaches.
1651
1652    3.6 Expression of Criteria
1653
1654    In 1986, EPA recommended criteria for enterococci and E. coli that contain two
1655    components: a GM and an SSM. The 1986 criteria values were derived from separate
1656    beach water quality datasets that were averaged over the entire summer swimming
1657    season, as part of EPA's epidemiological studies  conducted during the 1970s and 1980s.
1658    The GM is calculated as the antilog of the arithmetic mean of the log-transformed
1659    densities (Wymer and Wade, 2007). The SSM densities are based on the upper
1660    percentiles of the water quality distribution around the GM. Together, the GM and SSM
1661    describe a water quality distribution that would be protective of primary contact
1662    recreation, based on the epidemiological studies conducted at that time. Because the GM
1663    and SSM are components of the same water quality distribution, they are anchored to the
1664    same illness rate (e.g., 8 HCGI per 1,000 recreators).
1665
1666    The two components, however, serve different purposes for different CWA programs.
1667    For beach management, the SSM is given as a value that should not be exceeded,
1668    allowing States to determine when to make timely public notifications (i.e., advisories or
1669    closings). The 1986 criteria expression contains four different SSM values, corresponding
1670    to the 75th, 82th, 90th, and 95th percentile confidence levels. EPA recommended using
1671    different SSM percentiles based on a waterbody's use intensity.  For NPDES or  State
1672    permitting programs, water quality-based effluent limitations (WQBELs) for dischargers
1673    are to be calculated in accordance with 40 CFR §122.45, which  requires WQBELS for
1674    continuous dischargers to be expressed as short-term (such as daily or weekly) and long-
1675    term (monthly) limits. These effluent limitations would be derived from the State's WQS
1676    which, if it is consistent with EPA's recommendations would include both a GM and an
1677    SSM value. When identifying those waters for which existing effluent limitations are not
1678    stringent enough to meet recreational WQS (i.e.,  determining attainment status) states,
1679    with standards consistent with EPA's 2012 RWQC  recommendations, would use both the
1680    GM and SSM. Two clarifications to the 1986  criteria expression for determining
1681    attainment status for CWA §303(d) and §305(b) purposes using the GM and SSM are
1682    described below.
1683
1684    First, the 1986 criteria GM was meant to be compared to the calculated  GM of the
1685    waterbody being assessed, using at least five samples taken over a 30-day period. As


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                                                                                 12-9-11
1686    stated in the preamble to EPA's promulgation of WQS for States in 2004 the GM is the
1687    more relevant value for protecting water quality because it is a more reliable measure and
1688    more directly linked to the underlying studies on which the 1986 criteria are based.
1689    However, the 2004 preamble also states that "EPA intends that States and Territories
1690    should retain discretion to use single sample maximum values as they deem appropriate
1691    in the context of Clean Water Act implementation programs other than beach notification
1692    and closure, consistent with the Clean Water Act and its implementing regulations (U.S.
1693    EPA, 2004)."
1694
1695    Secondly, if SSM's values are interpreted to be "never to be exceeded" values for
1696    assessing a waterbody, the resulting water-quality standard is much more stringent than
1697    needed to protect the designated use of primary contact recreation if the GM were  used.
1698    For example, a marine body  of water that is in compliance with the 1986  criteria for
1699    enterococci (i.e., GM = 35 cfu per 100 mL; estimated 75th percentile = 104 cfu per 100
1700    mL) would have a water-quality distribution such that 25 percent of the samples taken
1701    would be higher than 104 cfu per 100 mL. For a body of water to meet  104 cfu per 100
1702    mL as a "never to be exceeded" value, the GM of that body of water would need to be
1703    extremely low.
1704
1705    In the 2012 RWQC, to ensure public health protection and to minimize inconsistencies in
1706    the interpretation or application of the statistical construct, EPA is recommending that the
1707    criteria magnitude be expressed using two components: the GM and the estimated 75th
1708    percentile STV. The recommended GM and STV (essentially the STV represents a
1709    renaming of the previous SSM) values are described below.
1710
1711    The GM for a waterbody should be calculated in the same way it was calculated for the
1712    1986 criteria: 1) take the logic of the samples under consideration,6 2) average those
1713    values, and 3) raise that average to the power of 10. It is important to note that EPA'
1714    recommendations no longer include a recommendation to calculate the GM criterion over
1715    a period  of 30 days. Epidemiological data, from which these criteria are derived, were
1716    evaluated on a seasonally basis. Thus, EPA recommends States to select a duration for
1717    both the  GM and the STV between 30 days and 90 days. The duration for calculating the
1718    GM and  associated STV should not exceed 90 days. The duration should be explicitly
1719    included in the State's WQS, as it is a component of the WQS. Including more  samples in
1720    calculation of the GM and STV improves the accuracy of the characterization of water
1721    quality. If States decide to use a duration that is shorter than 90 days for the purposes of
1722    calculating waterbody GMs, please be aware that smaller number of samples increases
1723    the chance of misclassification and careful  consideration will be needed to properly
1724    interpret multiple GM estimates (see Section 3.6.3).
1725
1726    Identical to the derivation of the SSM in the 1986 criteria document, the STV
1727    corresponds to an upper percentile (e.g., 75th percentile)  of a water-quality distribution
1728    around the 2012 RWQC's GM. EPA is recommending the STV in  the 2012 RWQC,
1729    rather than an SSM, to resolve previous inconsistencies in implementation and  to ensure
        6 For data points reported below detectable limits, the GM calculation should based on the assumption that
        those observations were present at the detection limit.

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                                                                                12-9-11
1730   that both components of the 2012 RWQC (i.e., the GM and STV) are equivalently
1731   stringent. Since FIB are highly variable in environmental waters and generally are well
1732   represented by a logic normal distribution (Bartram and Rees, 2000, Wyer et al., 1999,
1733   Kay et al., 2004), distributional estimates are more robust than single point estimates. In
1734   addition, EPA is no longer recommending multiple "use intensity" values to ensure
1735   equivalent public health protection in all waters. This section clarifies how a WQS that
1736   includes a GM and STV should be used and evaluated for various CWA purposes. EPA
1737   believes that in order to be consistent with EPA's recommended criteria;  the criteria in a
1738   State WQS need to include both the GM and STV.
1739
1740   The STV represents the estimated 75th percentile of a distribution of water quality as
1741   measured by FIB. For the 2012 RWQC, EPA computed the STV based on the observed
1742   pooled variance of the FIB data reported in EPA's epidemiological studies. The
1743   computed pooled variances represent a wide range of weather conditions because the
1744   monitoring was conducted over the full course of the set of epidemiological studies. In
1745   computing  the observed pooled variance, EPA stratified the data from the
1746   epidemiological  studies by beach and water depth, since these are known to differ
1747   systematically in their respective distributions of FIB (Wade et al., 2008), and computed
1748   the variances within each of the resulting strata.  The pooled variances from these 14
1749   subsets of the data in effect represent an overall  mean variance. For the qPCR method,
1750   the pooled variance resulted in a log standard deviation (the standard deviation of the
1751   base 10 logarithms of the  data) of 0.49 and the pooled variance estimates for culturable
1752   FIB that were reported previously (U.S. EPA, 1986). For the STV, EPA selected the
1753   estimated 75* percentile to align the beach notification decision-making process with the
1754   water-quality attainment criteria (i.e., the 1986 SSM was  based on the estimated 75
1755   percentile and beach-management decisions were based on this value).
1756
1757   3.6.1 Use of the STV for Beach Notification
1758
1759   The estimated 75th percentile STV is the recommended value for beach notification
1760   purposes (such as advisories and closings). Any single sample above the estimated 75th
1761   percentile STV should trigger beach notification until another sample that is below the
1762   estimated 75* percentile STV is collected. Additionally, a short-term GM can be useful
1763   in the beach advisory context.
1764
1765   3.6.2 Criteria Magnitude, Duration, and Frequency for other CWA Purposes
1766
1767   o  Magnitude:  GM and the estimated 75th percentile STV regardless of the sample size.
1768   o  Duration: For calculating the GM and associated STV, EPA recommends a duration
1769       between 30 days and 90 days. The duration for calculating the GM and associated
1770       STV should not exceed 90 days. The duration is a component of a water quality
1771       criterion and as such would need to be explicitly included in the State's WQS.
1772       Sampling of waterbodies should be representative of meteorological conditions (e.g.,
1773       wet and dry weather). If a State is not sampling during or immediately after a rain
1774       event, the State should advise the public to the risks of primary contact recreation.
1775   o  Frequency of exceedance:


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                                                                                12-9-11
1776       GM: The GM of a body of water over the duration specified in the standard for
1777       calculating a GM should not be higher than the recommended GM criteria value.
1778       Therefore, EPA recommends a frequency of exceedance of zero - i.e., no
1779       "excursions" - of the GM over the duration specified in the State standard. Like
1780       duration, the frequency of exceedance is a component of a water quality criterion and
1781       as such would need to be explicitly included in a State's WQS.
1782       STV: EPA recommends that no more than 25 percent of the observations  exceed the
1783       STV over the duration specified for calculating the STV. This should be computed by
1784       multiplying the total number of observations by 0.25. The number of observations
1785       above the STV is the whole-number portion of this quotient.
1786
1787   A State's recreational WQS should include a clearly articulated magnitude, duration, and
1788   frequency. States may adopt more stringent criteria into their WQSs. For example, it may
1789   be appropriate for States to establish a lower frequency of exceedances of the  STV based
1790   on regional or site-specific circumstances or studies.
1791
1792   NPDES permitting purposes
1793
1794   The NPDES regulations at 40 CFR 122.44(d) require the development of water quality-
1795   based effluent limitations (WQBELs) as necessary to attain water quality standards.
1796    Under  §122.45(d), permit limits for continuous dischargers must include both short- and
1797   long-term WQBELs unless there is a specific finding of "impracticability." To derive the
1798   required short-term (maximum daily or average weekly) permit limits, EPA recommends
1799   that permitting authorities use the more stringent derivation values between the GM and
1800   STV. To derive the required long-term (average monthly) permit limits, EPA
1801   recommends that permitting authorities use the GM. Once established, pathogen limits
1802   for continuous dischargers are applied and enforced in a manner consistent with all other
1803   water quality parameters.
1804
1805   For non-continuous or episodic discharges, by comparison, 40 CFR 122.45(e) requires
1806   WQBELs to reflect the frequency of discharge; total mass; maximum discharge rate; and
1807   prohibition or limitation of specified pollutants by mass, concentration, or other measure.
1808   Combined sewer overflows (CSOs)  are a key example of these types of discharges.  As
1809   the paragraph below discusses, EPA's longstanding CSO Policy has recommended
1810   various approaches for addressing CSO discharges.  The statistical framework underlying
1811   EPA's revised water quality criteria recommendations recognizes that a certain number
1812   of excursions from the STV criteria value may be permissible. Therefore, in permitting
1813   episodic discharges, such as CSOs, it may be appropriate for a permitting authority to
1814   authorize a limited number of discharge events that could exceed the STV as long as the
1815   permitting authority could demonstrate that the applicable criteria for primary contact
1816   uses (STV and geometric mean values) would be maintained in the stream.  (As
1817   mentioned above, CSOs are episodic discharges that pose particular challenges for water
1818   quality-based permitting due to the extreme variability in the volume and quality of
1819   overflows. For this reason the 1994 CSO Control Policy (also see section 402(q) of the
1820   CWA) provides for expression of WQBELs as performance standards based on average
1821   design conditions (e.g., a maximum number of overflow events per year  or a minimum


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                                                                                12-9-11
1822    percentage capture of combined sewage). The CSO Policy also recommends WQS
1823    review and revision, as appropriate, to reflect the site-specific wet weather impacts of
1824    CSOs. This review should be coordinated with the development, implementation, and
1825    post-construction monitoring associated with an approved long-term CSO control plan.
1826    WQS review could involve a use attainability analysis (40 CFR 131.10(g)) and
1827    subsequent modification of a designated use - for example, adoption of a partial or time-
1828    limited use for a defined period of time when primary contact recreation does not exist.
1829
1830    Detailed approaches for deriving WQBELs to meet WQS based on EPA's final 2012
1831    RWQC will be further explained in the TSM.
1832
1833    Identification of Impaired and Threatened Waters
1834    Under §303(d) of the CWA and EPA's implementing regulations (40 CFR 130.7), states,
1835    territories, and authorized tribes (hereafter referred to as states) are required to develop
1836    lists of impaired and threatened waters that require Total Maximum Daily Loads
1837    (TMDLs). Impaired waters are those that do not meet any applicable WQS. EPA
1838    recommends that states consider as threatened those waters that are currently attaining
1839    WQS, but which are expected not to meet WQS by the next listing cycle (every two
1840    years). Consistent with EPA recommendation, many states consolidate their §303(d) and
1841    §305(b) reporting requirement into one "integrated" report.
1842
1843    For making these water quality attainment determinations, a State that adopts WQSs
1844    consistent with the 2012 RWQC, would evaluate all readily available data and
1845    information to determine whether a waterbody meets the WQS (i.e., whether the
1846    waterbody is in attainment). A WQS that is consistent with EPA's recommended criteria
1847    would include both a GM and an STV, and all three components of a WQS (e.g.,
1848    magnitude, duration,  and frequency) for both the GM and the  STV. Both the GM and the
1849    STV apply independently and would need to be evaluated to determine whether or not
1850    water quality in a given waterbody meets the WQS for primary contact recreation. The
1851    waterbody condition would need to be evaluated based on all existing and readily
1852    available data and information for the specified duration. EPA's regulations define "all
1853    existing and readily available water quality related data and information" at 40 CFR
1854    130.7(b)(5).  EPA expects that water quality attainment determinations would include
1855    water quality monitoring data collected as  part of a beach monitoring program, as well as
1856    information regarding beach closures and advisories.
1857
1858    3.6.3 Practical Considerations for Applying the Criteria
1859
1860    The number of samples is not an approvable element of a WQS, therefore states should
1861    not include a minimum sample size as part of their criteria submission. The
1862    recommendations and information provided in this section can be used when identifying
1863    sampling frequency as part of a state's monitoring plan.
1864
1865    Typically, a larger dataset will more accurately characterize the water quality in a
1866    waterbody, resulting in more meaningful attainment determinations (Table 3 and Figure
1867    5). Therefore, EPA is recommending that states  conduct weekly sampling to calculate a


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                                                                                12-9-11
1868    GM over a 30 to 90 day period. This recommendation is consistent with global
1869    recommendations for recreational water management (WHO, 2003; E.U. 2007; MFE
1870    2003). EPA's analysis indicates increasing the number of samples when calculating a
1871    GM from the typical monthly regime of 4 or 5 samples to the recommended 90 day basis
1872    of 12 to 15 samples will reduce waterbody misclassification from both Type I (false
1873    positive) and Type II (false negative) errors with respect to attainment status based on the
1874    computed GM (Table 3 and Figure 5). For example, compared to GMs based on four
1875    samples (logsd=0.7), the predicted level of waterbody misclassification for 15 samples is
1876    reduced by 50 percent for a simulated waterbody with GM of 30 cfu per 100 mL (from
1877    34 percent to 17 percent) and 98 percent for a simulated waterbody with GM of 60 cfu
1878    per 100 mL (from 10 percent to 0.2 percent). Although waterbody misclassification can
1879    occur even with large datasets (e.g., 60 samples or more), the likelihood of waterbody
1880    misclassification is highest when the GM  is based on a small number of samples (Figure
1881    5).
1882
1883
1884
                                                                                    43

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                                                                                      12-9-11
1885
1886
1887
1888
1889
1890
1891
1892
1893
1894
1895
1896
1897
1898
1899
1900
Table 3. Sample size influences the likelihood of misclassification.1

Number of
Samples
4
5
12
15
Actual Geometric Mean
(cfu enterococci per 100 ml)
25
20.3%
14.0%
5.3%
3.4%
30
34.6%
31.0%
22.0%
17.4%
45
25.0%
21.1%
9.7%
8.6%
60
10.0%
4.0%
0.2%
0.2%
falsely being determined as above or below the limit (35 GM), when in fact the true GM is below
(GM=25 and 30) or above (GM=45 and 60).
2 Actual GM is the GM of a simulated waterbody (with logsd=0.7).
                                                                 Actual GM 25 cfu/lOOmL

                                                                 Actual GM 30 cfu/lOOmL

                                                                 Actual GM 45cfu/100mL

                                                                 Actual GM 60 cfu/lOQmL
                                    20
                                              30        40
                                               Sample size
                                                                                    70
1901
1902
1903
1904
1905
1906
1907
1908
Figure 5. Likelihood of misclassification as a function of sample size.
(Graphical representation of data in Table 3)
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                                                                                12-9-11
1909    4.0 Recreational Water Quality Criteria
1910
1911    EPA evaluated the available data and determined that the designated use of recreation
1912    would be protected if the following criteria were adopted into State WQS:
1913
1914          (a) Fresh water criteria
1915             Magnitude: Culturable E. coli at a GM of 126 cfu per 100 mL and an STV of
1916             235 cfu per 100 mL measured using EPA Method 1603, or any other
1917             equivalent method that measures culturable E. coli; culturable enterococci at a
1918             GM of 33 cfu per 100 mL and an STV of 61 cfu per 100  mL measured using
1919             EPA Method 1600 (U.S. EPA, 2002b), or any other equivalent method that
1920             measures culturable enterococci; or both of the above criteria. EPA believes
1921             that in order to be consistent with EPA's recommended criteria, the criteria in
1922             a State WQS need to include both the GM and STV.
1923
1924             Duration: For calculating the GM and associated STV, EPA recommends a
1925             duration between 30 days and 90 days.  The duration for calculating the GM
1926             and associated STV should not exceed 90 days. The duration  is a component
1927             of a water quality criterion, and as such, would need to be explicitly included
1928             in the State's WQS. Sampling of waterbodies should be representative of
1929             meteorological conditions (e.g., wet and dry weather). If a State is not
1930             sampling during or immediately after a rain event, the State should advise the
1931             public to the risks of primary contact recreation.
1932
1933             Frequency: EPA recommends a frequency of zero exceedances of the GM and
1934             < 25 percent exceedance of the STV, over the duration specified for
1935             calculating the GM and STV. The frequency of exceedance is a component of
1936             a water quality criterion, and as such, would need to be explicitly included in
1937             State's WQS.
1938
1939          (b) Marine criteria
1940             Magnitude: Culturable enterococci at a GM of 35 cfu per 100 mL and an STV
1941             of 104 cfu per 100 mL measured using EPA Method 1600, or any other
1942             equivalent method that measures culturable enterococci. EPA believes that in
1943             order to be consistent with EPA's recommended criteria, the criteria in a State
1944             WQS need to include both the GM and STV.
1945
1946             Duration: For calculating the GM and associated STV, EPA recommends a
1947             duration between 30 days and 90 days. The duration for calculating the GM
1948             and the associated STV should not exceed 90 days. The duration is a
1949             component of a water quality criterion, and as such, would need to be
1950             explicitly included in the State's WQS. Sampling of waterbodies should be
1951             representative of meteorological conditions (e.g., wet and dry weather). If a
1952             State is not sampling  during or immediately after a rain event, the State should
1953             advise the public to the risks of primary contact recreation.
1954
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1955             Frequency: EPA recommends a frequency of zero exceedances of the GM and
1956             < 25 percent exceedance of the STV, over the duration specified for
1957             calculating the GM and STV.  The frequency of exceedance is a component of
1958             a water quality criterion, and as such, would need to be explicitly included in
1959             State's WQS.
1960
1961   EPA has also developed a qPCR method to detect and quantify enterococci more rapidly
1962   than the culture method. Enterococci as measured by EPA Enterococcus qPCR method A
1963   has shown a strong relationship to GI illness in the recent EPA NEEAR epidemiological
1964   studies compared to other methods tested (Wade et al., 2008; U.S. EPA, 2010d).
1965   Introduction of EPA Enterococcus qPCR method A is anticipated also to provide
1966   increased public health protection by permitting timely notification7 to swimmers of
1967   levels of FIB that exceed the site-specific criteria value. While the fresh water Great
1968   Lakes and temperate marine water NEEAR studies resulted in minimal to no inhibition, it
1969   is EPA's goal to publish RWQC recommendations that can be recommended nationally.
1970   Given the current state of knowledge regarding the performance of qPCR methods under
1971   varied waterbody conditions and the limited experience of its use in the field, EPA
1972   encourages a site-specific assessment of the method's performance before it is adopted
1973   into State WQS for implementation in beach monitoring programs.
1974
1975   For the purposes of beach monitoring, alternative site-specific criteria could be adopted
1976   into State standards measured by EPA's Enterococcus qPCR method A based on a site-
1977   specific performance characterization. This method is not recommended for NPDES
1978   permitting. A "site" may be a beach, a waterbody, or a particular watershed that is
1979   anticipated to have uniform qualities throughout.  As  States adopt water-quality standards
1980   for enterococci, as  measured by EP A's Enterococcus qPCR method A, they will gain
1981   experience with the qPCR method and better understand how this method performs in
1982   their waters. Considerations for determining how qPCR could be used to develop site-
1983   specific criteria will be provided in additional  TSM. For States interested in adopting a
1984   value for enterococci using EPA's Enterococcus qPCR method A into their WQS, EPA
1985   recommends a GM criterion of 475  CCE per 100 mL and an  STV criterion of 1,000 CCE
1986   per 100 mL in freshwaters and marine waters based on its epidemiological study data.
1987
1988   Because this document only includes supplementary information about how States may
1989   adopt water-quality standards on a site-specific basis for enterococci as measured by
1990   qPCR, the 2012 RWQC recommendations are not "applicable" to that pathogen indicator
1991   (i.e., enterococci as measured by qPCR). Therefore, the inclusion of qPCR-related
1992   information in this document does not trigger the requirement in CWA §303(i) that States
1993   adopt water-quality standards "for all pathogens and pathogen indicators to which the
1994   new or revised WQC are applicable" for their  coastal recreational waters.
         See section 5.2.1 for a discussion on the use of predictive models as an additional approach for achieving
       timely notification.

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1995    5.0 Tools to Support States and Tribes in Managing Recreational Waters and for
1996    Considering Alternate Water Quality Criteria
1997
1998    EPA's implementing regulations for §303 of the CWA provide that "states must adopt
1999    those WQC that protect the designated use.  Such criteria must be based on sound
2000    scientific rationale and must contain sufficient parameters or constituents to protect the
2001    designated use." (40 CFR §131.11(a)). EPA's regulations  stated in 40 CFR §131.11(b)(l)
2002    provide that "In establishing criteria, States  should (1) Establish numerical values based
2003    on (i) 304(a) Guidance; or (ii) 304(a) Guidance modified to reflect site-specific
2004    conditions; or (iii) Other scientifically defensible methods." WQS can be established for
2005    waterbodies, or a portion of a water body and therefore they could be established for a
2006    specific site, such as a waterbody adjacent to a beach or the entire water body that is
2007    anticipated to have uniform qualities throughout. When EPA reviews State WQSs for
2008    approval or disapproval under the CWA, EPA must ensure that the WQC in the standard
2009    (regardless of whether they are "site-specific") are scientifically defensible and protective
2010    of the designated use.
2011
2012    The tools discussed in this section fall into two main categories: (1) tools that States can
2013    use to enhance public health protection when implementing state WQS for primary
2014    contact recreation; and (2) tools that can be used by States in the development of WQC
2015    that differs from EPA's recommended criteria ("alternate criteria"). Alternate criteria
2016    could be developed to reflect site-specific conditions, or they could be developed using
2017    different indicators and analytical methods.  State WQS that include alternate criteria
2018    would need to be scientifically defensible and protective of the use. These tools reflect
2019    currently available scientific information, can be utilized to assist in the assessment and
2020    management of recreational waters (see section 5.1), and have the potential to be used in
2021    the development of site-specific criteria (see section 5.2). Site-specific criteria are based
2022    in part on assumptions regarding the current state of a watershed such as current land
2023    uses, and should be revisited no less frequently than triennially to ensure the site-specific
2024    criteria remains protective of the primary contact recreation use. This section does not
2025    provide details on how to implement these tools. Additional, detailed information on
2026    these tools will be provided in TSM.
2027
2028    The tools discussed below (and the corresponding subsections) are (1) sanitary surveys
2029    (5.1.1); (2) predictive models (5.1.2); (3) epidemiological  studies (5.2.1); (4) quantitative
2030    microbial risk assessment (QMRA) (5.2.2);  and (5) approaches for developing criteria
2031    using alternative fecal indicators and/or methods (5.2.3).
2032
2033    5.1 Tools for Assessing and Managing Recreational Waters
2034
2035    EPA recognizes that advancements have been made since  the publication of the 1986
2036    criteria in the area of managing recreational waters. This section discusses tools that
2037    States can use to enhance public health protection. These tools can aid in the
2038    identification of days of poor water quality on a  site-specific basis. Specifically, this
2039    section discusses the use of sanitary surveys as a tool for identifying sources of fecal
2040    contamination and identifying and prioritizing clean-up/remediation actions for a specific


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                                                                                  12-9-11
2041    body of water and the use of predictive models for timely beach notification. EPA
2042    encourages the use of sanitary surveys and predictive models, specifically by beach
2043    managers, to better understand and potentially control sources of fecal contamination and
2044    pathogens. EPA also encourages the use of predictive models to supplement a sound
2045    monitoring program that has the potential to prevent human exposure on days of poor
2046    water quality. Together, the tools in this  section have the potential to allow a State or
2047    locality to assess and communicate the risks associated with fecally contaminated
2048    recreational waters. These tools are not a part of the adopted WQSs and do not result in
2049    different numerical criteria value(s).
2050
2051    5.1.1 Sanitary Survey
2052
2053    Beach managers often use sanitary surveys to assess beaches for fecal contamination and
2054    to prioritize clean-up and remediation efforts. Beach sanitary surveys involve collecting
2055    information at the beach, as well as in the surrounding watershed. Information collected
2056    at the beach may include the following: proximity to septic systems, number of birds at
2057    the beach, slope of the beach, location and condition of bathrooms at beach facilities, and
2058    amount of algae on the beach. Information collected in the watershed may include the
2059    following: land use, location of storm water outfalls, surface water quality, and
2060    residential septic tank information.
2061
2062    Sanitary surveys are a "snapshot" of the  conditions at a beach, which can change due to
2063    factors including those listed above. Sanitary surveys help State and local beach program
2064    managers and public health officials identify sources of beach water pollution, assess the
2065    magnitude of pollution, and designate priority locations for water testing. In conjunction
2066    with monitoring to determine whether a waterbody is meeting State WQS for recreation,
2067    they can use sanitary survey data (such as bacteria levels, source flow, turbidity, and
2068    rainfall) to develop models to predict bathing beach water quality using readily available
2069    data. Other information, such as source tracking and watershed information may be
2070    needed to effectively delineate sources within the watershed.
2071
2072    EPA has developed documents on sanitary surveys for the purpose of supplementing the
2073    2012 RWQC recommendations. These documents are available on the website:
2074    http://water.epa.gov/type/oceb/beaches/sanitarysurvey_index.cfm, as well as in Great
2075    Lakes Beach Sanitary Survey User Manual (U. S. EPA, 2008). EPA plans to include
2076    detailed information on developing and using sanitary surveys in its upcoming beach
2077    guidance and other TSM (see Appendix D).
2078
2079    5.1.2 Predictive Models
2080
2081    EPA recognizes that, at some locations and under some conditions, implementation of a
2082    rapid enumeration methodology, such as the qPCR-based method described previously in
2083    this document, is not feasible or is unlikely to provide sufficiently timely information for
2084    making a same-day beach notification decision (for example, in locations where water
2085    samples cannot be transported to the appropriate laboratory facilities for analysis in a
2086    timely manner). EPA is therefore providing an approach that may supplement the current


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                                                                                   12-9-11
2087    culture-based analytical results to facilitate same-day public health decisions. EPA
2088    encourages the use of predictive models in these situations to allow timely notification at
2089    beaches. Typically, States would use these and site-specific predictive models, such as
2090    statistical models, rainfall threshold levels, and notification protocols (U.S. EPA, 2010b,
2091    2010c), to supplement monitoring using culture-based methods. The models would not
2092    themselves be a part of State' WQS.
2093
2094    Predictive models that are currently employed in areas such as the Great Lakes have
2095    proven to be effective. These models draw on existing culture-based monitoring data
2096    bases, are inexpensive to use, and allow for a rapid, proactive beach management
2097    decisions (U.S. EPA, 2010b,c). They provide a means to supplement monitoring and
2098    support rapid notification.
2099
2100    EPA has conducted research and published a two-volume report to advance the use of
2101    predictive models (U.S. EPA, 2010b,c). Volume I summarizes the current uses of these
2102    predictive tools to provide model developers with the basic concepts for developing
2103    predictive tools for same-day beach notifications at coastal marine waters, the Great
2104    Lakes, and inland waters (U.S.  EPA, 2010b). Volume II provides the results of research
2105    conducted by EPA on developing statistical models at research sites. It also presents
2106    Virtual Beach, a software package designed to build statistical multivariate linear
2107    regression predictive models (U.S. EPA, 2010c; see Appendix D). EPA is also expanding
2108    the Virtual Beach tool so that it will include other statistical approaches besides multiple
2109    linear regression. Techniques such as recursive partitioning (especially a technique called
2110    the Gradient Boosting Method  [GBM] that involves usage of multiple decision trees) are
2111    promising. Artificial neural  networks, binary logistic regression, and partial least-squares
2112    techniques also are being added. Beyond these improvements in Virtual Beach, other
2113    efforts such as linking watershed and statistical models, Cyterski's temporal
2114    synchronization approach to incorporate time lags, and process-based transformations are
2115    being pursued to improve predictive modeling efforts.
2116
2117    The types  of predictive tools that can be used to make beach notification decisions fall
2118    into the following categories: statistical  regression models, rainfall-based notifications,
2119    decision trees or notification protocols, deterministic models, and combinations of tools.
2120
2121       •   A statistical regression model is  a general term for any type  of statistical modeling
2122           approach used to predict beach water quality. A statistical correlation (for
2123           example,  one established using multivariate linear regression techniques) is
2124           observed between FIB and environmental and water quality variables that are
2125           easier to measure than FIB. Typical variables include meteorological conditions
2126           (such as solar radiation, air temperature, precipitation, wind speed and direction,
2127           and dew point), water quality (such as turbidity, pH, conductivity/salinity, and
2128           ultraviolet [UV]/visible spectra), and hydrodynamic conditions (such as flows of
2129           nearby tributaries, magnitude and direction of water currents, wave  height, and
2130           tidal stage).
2131       •   Rainfall-based notifications are based on a rain threshold level, which is a
2132           predictive tool that can be used when a connection exists between the

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                                                                                   12-9-11
2133           concentration of FIB at a beach and the amount of rain received in nearby areas.
2134           That relationship can be quantified as the amount or intensity of rainfall (i.e., the
2135           threshold level) that is likely to cause an exceedance of the WQSs at a beach, and
2136           the length of time over which the standards will be exceeded.
2137       •   Decision trees or notification protocols are a series of questions that can also be
2138           used to consider factors such as rainfall to guide beach notifications. Such
2139           evaluations use water quality sampling, rainfall data, and other environmental
2140           factors that could influence FIB levels (such as proximity to pollution sources,
2141           wind direction, visual observations, or other information specific to the region or
2142           beach). This process is referred to as developing a notification protocol.
2143       •   Deterministic models use mathematical representations of the processes that
2144           affect bacteria densities to predict exceedances of WQSs. They include a range of
2145           simple to complex modeling techniques.
2146
2147    There are various considerations for developing each of these model types for beaches
2148    and each has its own  set of challenges (Boehm et al., 2007). To be effective, these
2149    predictive models should be sufficiently calibrated to reflect site-specific conditions and
2150    account for inter-seasonal variations, if applicable. Predictive models are intended for use
2151    as a rapid beach notification tool only. They do not replace the need for a sound
2152    monitoring program,  and the development of predictive models requires monitoring data
2153    both for establishing  and maintaining statistical relevance. A State using a site-specific
2154    predictive model would still need to evaluate the waterbody in order to determine
2155    whether it meets the WQS for purposes of CWA §303(d) listing.
2156
2157    5.2 Tools for Use in  Developing Alternative Criteria
2158
2159    As described  above, EPA's regulations provide that "States must adopt those water
2160    quality criteria that protect the designated use.  Such criteria must be based on sound
2161    scientific rationale and must contain sufficient parameters or constituents to protect the
2162    designated use." 40 CFR 131.1 l(a). EPA's regulations at 40 CFR §131.1 l(b)(l) provide
2163    that in establishing criteria, States should (1) establish numerical criteria based on (i)
2164    EPA's CWA  §304(a) guidance; (ii) §304(a) guidance modified to reflect site-specific
2165    conditions or, (iii) other scientifically defensible  methods. States could adopt  site-specific
2166    modifications of a §304(a) criterion to reflect local environmental conditions and human
2167    exposure patterns.  A "site" may signify beach, a waterbody, or a particular watershed,
2168    that is anticipated to have uniform qualities throughout. Such site-specific criteria may be
2169    adopted into a state WQS as long as the resulting site-specific WQS are scientifically
2170    defensible and protective of the use. For example, alternative WQSs may involve the
2171    adoption of different  numerical value(s) that are based on: (1) the results of an
2172    epidemiological study; (2) the results of a quantitative QMRA to account for different
2173    sources of FIB; or (3) a different FIB-method combination. To be used for CWA
2174    purposes, site-specific criteria would need to be adopted into State WQS and reviewed
2175    and approved under CWA §303(c).
2176
2177    EPA believes that the recommended 2012 RWQC, which are derived from and  informed
2178    by the preponderance of epidemiological evidence in human fecal-impacted waters,

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                                                                                 12-9-11
2179    would be protective of primary contact recreation. EPA recognizes, however, that the
2180    conditions studied in the temperate fresh waters and marine waters by the NEEAR
2181    studies (i.e., waters primarily impacted by secondary-treated and disinfected POTW
2182    effluent) may not be representative of all possible fecal contamination combinations that
2183    could impact recreational bodies of water in the United States. Therefore, this section
2184    describes the tools available to support States considering alternate WQS based on other
2185    data such as: (1) epidemiological studies, (2) QMRA, and (3) novel fecal indicators and
2186    analytical methods.
2187
2188    5.2.1 Epidemiological Studies
2189
2190    EPA's NEEAR epidemiological studies were conducted in water primarily impacted
2191    human fecal contamination, including temperate fresh water, temperate marine water, and
2192    tropical marine water sites, as well as one temperate marine water site that was impacted
2193    by urban runoff (Wade et al., 2006, 2008, 2010; U.S. EPA, 2010d).  Statistically
2194    significant associations between water quality, as determined using Enterococcus
2195    measured by qPCR, and reported illness were observed in the temperate marine water and
2196    fresh water POTW-impacted beaches. No associations between FIB, enumerated with
2197    either culture-based or qPCR-based methods, and reported illness were observed at the
2198    beach impacted by urban runoff in Surfside, SC or at the tropical beach in Boqueron, PR.
2199
2200    Local and/or State agencies have conducted, or are considering conducting,
2201    epidemiological studies of health risks and water quality at recreational beach sites. For
2202    example,  epidemiology studies of recreational water exposures have been conducted
2203    recently in Southern California (SCCWRP,personal communication, 2010), south Florida
2204    (Fleming, 2006; Sinigalliano, 2010), and Ohio (Marion et al., 2010). These studies could
2205    be used to confirm EPA's 2012 criteria or to develop site-specific criteria.
2206
2207    Several factors can influence the potential epidemiological relationship between indicator
2208    density and relative human health risk. Some of the potentially important factors include
2209    the source of fecal contamination, age of the fecal contamination, intensity of solar
2210    radiation that the fecal contamination is exposed to, water salinity, turbidity, dissolved
2211    organic matter, water temperature, and nutrient content. Numerous factors also affect the
2212    occurrence and distribution of FIB and the pathogens from the source of contamination to
2213    the receptor location that include, but are not limited to, the following: predation of
2214    bacteria by other organisms; differential interactions between microbes and sediment,
2215    including the release and resuspension of bacteria from sediments in the water column;
2216    and differential environmental effects on indicator organisms versus pathogens. For
2217    additional information, see Appendix B.
2218
2219    States or local agencies may choose to conduct epidemiological studies in their
2220    waterbodies and use the results from those studies to derive site-specific criteria.  To
2221    derive scientifically defensible site-specific WQC for adoption into  state standards, the
2222    epidemiological studies should be of similar quality and of comparable scientific rigor as
2223    EPA's NEEAR water studies. The epidemiological information underlying the
2224    recommended 2012 RWQC was produced using a study design called "prospective


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                                                                                   12-9-11
2225    cohort." EPA is unsure at the current time how results from alternate epidemiological
2226    study designs can inform  site-specific criteria. Significant differences in the study
2227    designs, data collection, and analysis methods, exposure, and health outcome measures
2228    pose a major challenge to the ability to quantitatively compare the illness rate and water
2229    quality relationships in epidemiological studies with significant design differences to the
2230    NEEAR studies.
2231
2232    Epidemiological studies are resource intensive and logistically difficult, although the
2233    results can provide the data necessary for a scientifically defensible basis to allow the
2234    adoption of WQS based on fecal indicator/methods that are not part of EPA's national
2235    §304(a) recommendations. First, site-specific epidemiological studies can take into
2236    account the characteristics of local waterbodies to support the derivation of a site-specific
2237    criteria value based on the fecal indicator/methods that are part of EPA's national  §304(a)
2238    recommendations.  Second, such studies may support the development and adoption of
2239    alternative criteria based on different health endpoints, such as respiratory illnesses, than
2240    EPA has used in its current recommendations (i.e., GI illnesses). Where the studies
2241    demonstrate a statistically significant correlation between levels of water quality
2242    measured using particular Fffi(s) and adverse health outcomes, they may be scientifically
2243    defensible and as such, could be used to develop and adopt alternate criteria.
2244
2245    If a State wishes to develop alternative criteria using their own epidemiological studies,
2246    EPA recommends that the studies also be of the PC design, to facilitate the evaluation of
2247    the resultant alternative criteria. EPA's TSM will provide additional information on the
2248    use of epidemiological studies in development of site-specific criteria.
2249
2250    5.2.2 Quantitative Microbial Risk Assessment and Sanitary Characterization
2251
2252    If a particular waterbody is believed to be predominantly impacted by nonhuman sources,
2253    a site-specific criterion may be worth investigating. EPA's research indicates that
2254    understanding the predominant source of fecal contamination is critical for
2255    characterization of the human health risks associated with recreational water exposure.
2256    Various epidemiological investigations, including EPA's have documented human health
2257    effects in waters impacted by human fecal contamination. Additionally, QMRA studies
2258    have demonstrated that the potential human health risks from human and non-human
2259    fecal sources can be different due to the nature of the source, the type and number of
2260    pathogens from any given source, as well as, variations in the co-occurrence of pathogens
2261    and fecal indicators associated with different sources (Till and McBride, 2004, Roser et
2262    al, 2006, Schoen and Ashbolt, 2010, Seller et al., 2010b, Bambic et al, 2011). While
2263    human sources of fecal contamination pose similar health risks regardless of location, the
2264    differences in predicted human health risks from recreational water exposure to non-
2265    human fecal contamination are dependent on local characteristics that will vary from site-
2266    to-site.  EPA is not recommending nationally-applicable criteria values for recreational
2267    waters that account for non-human sources of fecal contamination due to this variability.
2268    EPA's nationally applicable criteria values  can be used for such waters. However, EPA is
2269    making available TSMs for QMRA to assist States in developing equivalent site-specific
2270    criteria to account for local scale, non-human sources.


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2271
2272    Any alternative WQSs must be scientifically defensible and protective of the use. QMRA
2273    is one tool that has been identified as potentially useful for developing alternative criteria
2274    by enhancing the interpretation and application of new or existing epidemiological data
2275    (Boehm et al., 2009; Dorevitch et al., 2011). Recreational water epidemiological studies
2276    describe the risks associated with exposure to fecal contamination as measured by FIB.
2277    QMRA can supplement new or existing epidemiological results by characterizing various
2278    exposure scenarios, interpreting potential etiological drivers for the observed
2279    epidemiological results, and accounting for differences in risks posed by various types of
2280    fecal sources. EPA is working to anchor the QMRA framework to existing
2281    epidemiological relationships as part of the TSMs.
2282
2283    QMRA applies risk-assessment principles (NRC, 1983) to approximate the consequences
2284    from exposure to selected infectious pathogens. To the greatest possible extent, the
2285    QMRA process includes the evaluation and consideration of quantitative information;
2286    qualitative information, however, is also used when appropriate (WHO, 1999). QMRA
2287    can be initiated for a variety of reasons, including, but not limited to, the following:
2288
2289        •   to assess the potential for human risk associated with exposure to a known
2290           pathogen;
2291        •   to determine critical points for control, such as watershed protection measures;
2292        •   to determine specific treatment processes to reduce, remove, or inactivate various
2293           pathogens;
2294        •   to predict the consequences of various management options for reducing risk;
2295        •   to determine appropriate criteria (regulatory) levels that will protect individuals
2296           and/or populations to a specified risk level or range
2297        •   to identify and prioritize research needs; and
2298        •   to assist in interpretation of epidemiological investigations.
2299
2300    QMRA methodologies have been applied to evaluate and manage pathogen risks for a
2301    range of scenarios, including from food, sludge/biosolids, drinking water, recycled water,
2302    and recreational waters. Moreover, risk assessment in general has been used extensively
2303    by EPA for decades to establish human health criteria for a wide range of pollutants in
2304    water and other media,  and microbial risk assessment has been used to inform EPA's
2305    policy making for microbiological pollutants in drinking water and biosolids, and by
2306    other U.S. and international governmental agencies (e.g., U.S. Department of Agriculture
2307    [USDA], U.S. Food and Drug Administration, WHO) to protect public health from
2308    exposure to microbiological pollutants in food and water.
2309
2310    For recreational waters, QMRA incorporates a site-specific sanitary characterization and
2311    maybe used to determine if a particular waterbody/watershed is predominantly impacted
2312    by a source other than human fecal contamination and whether lower relative risk is
2313    associated with the contributing source(s) of fecal contamination in that waterbody or
2314    watershed (Seller et al., 2010a,b).  Site  characterization tools (similar to an enhanced
2315    sanitary survey) can provide detailed information on the source(s) of fecal contamination
2316    in a waterbody and whether the sources are human or nonhuman. EPA developed a

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2317    QMRA-specific application of the sanitary survey, hereafter referred to as a site
2318    characterization, to capture information directly applicable for the conduct of a QMRA.
2319    This site-specific sanitary characterization process will be described in detail in the
2320    QMRA TSM.
2321
2322    Where sanitary site characterization work indicates that the predominant source is human,
2323    the 2012 RWQC recommendations are scientifically defensible and protective of primary
2324    contact recreation. Also, when sources are predominately nonhuman, EPA has concluded
2325    the 2012 RWQC would be scientifically defensible and protective of primary contact
2326    recreation. Where the sources of fecal contamination are predominantly nonhuman or
2327    non fecal, QMRA is a tool that is less resource intensive and more broadly applicable
2328    than epidemiological studies. Epidemiological studies have reported ambiguous results
2329    in scenarios impacted by nonhuman sources and are impractical in infrequently used
2330    waterbodies. However, EPA's QMRA framework, anchored with the newer reported
2331    epidemiological relationships, will help facilitate the risk characterization on a site-
2332    specific basis.
2333
2334    EPA's recent QMRA research provides new information on fecal contamination from
2335    nonhuman sources which, under some circumstances, may be less risky to human health
2336    than contamination from human sources (Schoen and Ashbolt, 2010; Seller et al.,
2337    2010a,b; U.S. EPA, 2010a). For additional information and case studies of QMRA for
2338    recreational waters, see Appendix C. This research demonstrates that different pathogens
2339    are expected to cause illness in recreational waters impacted by different sources of fecal
2340    contamination. For example, in human-impacted recreational waters, human enteric
2341    viruses are expected to cause a large proportion of illnesses (Seller et al., 2010a). In
2342    recreational waters impacted by gulls and agricultural animals, such as cattle, pigs, and
2343    chickens, other pathogens (such as bacteria and protozoa) would be expected to be the
2344    etiologic agents that cause human illness (Roser et al., 2006, Seller et al., 2010b; Schoen
2345    and Ashbolt, 2010). Other research also  supports the utility of QMRA, such as QMRA
2346    conducted for a tropical waterbody (Viau et al., 2011) and the use of QMRA to establish
2347    recreational WQC in New Zealand (MFE, 2003).
2348
2349    Moreover, the relative level of predicted human illness in recreational waters impacted by
2350    nonhuman sources can vary depending on whether the contamination is direct or via
2351    runoff due to a storm event (U.S. EPA, 2010a). For example, when considering a direct
2352    contamination scenario in which FIB was assumed to be present at the 1986 criteria
2353    levels, predicted GI illness risks  associated with exposure to recreational waters impacted
2354    by fresh cattle feces were not substantially different from waters impacted by human
2355    sources (Seller et al., 2010b). Predicted illness levels in bodies of water that contain FIB
2356    at the 1986 criteria levels from land-applied fecal material from cattle (with microbial
2357    loading due to runoff from a storm event), however, were approximately 20 times lower
2358    than the risk associated with human-impacted water (U.S. EPA, 2010a). These results
2359    highlight the potential power of QMRA to inform site-specific criteria.
2360
2361    To derive site-specific criteria that are considered scientifically defensible and protective
2362    of the use, QMRA studies should follow accepted practices, rely on scientifically


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2363    defensible data, and be well documented (Haas et al., 1999; Seller et al., 2004; Schoen
2364    and Ashbolt, 2010; MFE, 2003). EPA plans to provide additional guidance on conducting
2365    QMRA for the purpose of assessing differences in risk and for the possible derivation of
2366    site-specific criteria in a TSM.
2367
2368    5.2.3 Developing Alternative Criteria Based on Novel Indicators or New Analytical
2369    Methods, without Site-Specific Epidemiological Studies
2370
2371    EPA anticipates that scientific advancements will provide new technologies for
2372    quantifying fecal pathogens or fecal contamination indicators. These newer technologies
2373    may provide alternative ways to address methodological considerations, such as rapidity,
2374    sensitivity and specificity, and method performance in site-specific situations, but may
2375    not be appropriate for all CWA purposes. As new or alternative indicator and/or
2376    enumeration method combinations are developed,  States may want to consider using
2377    them to develop WQC on a site-specific basis. EPA would approve them if the resulting
2378    criteria are scientifically defensible and protective of the recreational use. One way such
2379    alternate criteria may be demonstrated to be scientifically defensible would be a
2380    consistent and predictable demonstration of the enumeration method performance for a
2381    proposed site-specific criterion.
2382
2383    Previously, EPA has used the relative performance of enumeration methods to describe a
2384    common level of water quality. For example, derivation of the 1986 criteria was
2385    fundamentally based on the comparison of enumeration methods for FC,  enterococci, and
2386    E. coli. In that specific case, those comparisons were made among membrane filtration
2387    methods specific to each target organism. Another example of this occurred when EPA
2388    approved the use of the IDEXX-based methods for the detection of enterococci and
2389    E. coli. In this comparison, results from a membrane-filtration method were compared to
2390    another method that relied on substrate-utilization and MPN enumeration. Use of already
2391    available rapid methods, such as qPCR methods for E. coli, has been demonstrated
2392    (Lavender and Kinzelman, 2009), on a site-specific basis.
2393
2394    Examples of other reported  methodologies for quantifying of FIB include the following:
2395    immunomagnetic separation/adenosine triphosphate (IMS/ATP), propidium monoazide
2396    (PMA) qPCR, reverse transcriptase (RT) PCR, covalently linked immunomagnetic
2397    separation/adenosine triphosphate (COV-EVIS-ATP), and transcription mediated
2398    amplification (TMA-RNA)
2399
2400    Also, additional indicator organisms can be used with existing methodologies similar to
2401    those recommended by the 2012 RWQC. Examples of possible alternative indicators
2402    include but are not limited to, Bacteroidales, Clostridiumperfringens, human enteric
2403    viruses, and coliphages. For example, in one case, Bacteroidales measured by qPCR were
2404    highly correlated with Enterococcus and E.  coli when either traditional, cultivation
2405    dependent, or qPCR methods were used (WERF, 2011). Norovirus GI and Gil have also
2406    shown to be predictors of the presence of other pathogens like Adenovirus, Giardia, and
2407    Cryptosporidium measured  by qPCR (WERF, 2011). E. coli and Enterococcus measured
2408    by qPCR may also be a possible indicator and method in fresh water. For organism and


                                                                                     55

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                                                                                  12-9-11
2409    enumeration methodology combinations that are different from the 2012 RWQC, EPA
2410    would review technical information on incorporating alternative indicator organisms and
2411    enumeration methods provided by the State.
2412
2413    To facilitate consideration, States could gather water quality data over a recreational
2414    season for both an EPA-approved method and the proposed alternative indicator-method
2415    combination. A robust relationship need not necessarily be established between EPA's
2416    recommendation and alternative indicator(s) for the whole range of indicator densities
2417    observed, as EPA's recent research highlights these difficulties and limitations (U.S.
2418    EPA, 2010e). It is, however, important that a consistent and predictable relationship exist
2419    between the enumeration methods and an established indicator-health relationship in the
2420    range of the criteria. A State WQS using a  different indicator or analytical method would
2421    need to be scientifically defensible and protective of the primary contact recreational use.
2422    Information on demonstrating the relationship between two-indicator method
2423    combinations can be found in TSM.
2424
                                                                                       56

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                                                                                 12-9-11
2425    References
2426
2427    Bartram J, Rees G, editors. 2000. Monitoring bathing waters. Lopdon: E & F N Spon.
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2429
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2435    Boehm, A.B., Ashbolt, N., Colford, J.,  Dunbar, L., Fleming, L., Gold, M., Hansel, J.,
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2514
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                                                                                 12-9-11
2515    Corbett, S.J., Rubin, G.L., Curry, G.K., Kleinbaum, D.G. and the Sydney Beach Users
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2530    measures of indicator bacteria as predictors of waterborne protozoan pathogen presence
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2537    swimming activities in a pool: a pilot study. J Water Health 4(4): 425-430.
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2540    States 1922-2003, in Statistical Framework for Recreational Water Quality Criteria and
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2543    EP/CEU (European Parliament/Council of the European Union) 1976. Directive
2544    76/100/EEC of the European Parliament and of the Council of 8 December 1975
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2548    EP/CEU 2006. Directive 2006/7/EC of the European Parliament and of the Council of 15
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2550    Directive 76/160/EEC. Official Journal of the European Union L64: 31-51. Available at:
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2561    Fleisher, J.M., Jones, F., Kay, D., Stanwell-Smith, R., Wyer, M., Morano, R. 1993. Water
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2574    and Wang, J. 2008. Final Report on the Pilot Epidemiologic Assessment of Microbial
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2579    levels at coastal beaches. Aquatic Ecosystem Health and Management 12(2): 177-182.
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2587    Technology 43(4): 1128-1133.
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2592
2593    Haas, C.N., Rose, J., Gerba, C.P. 1999. Quantitative Microbial Risk Assessment. John
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2607    Jacquotte, Z., Shore, R. 1994. Predicting Likelihood of Gastroenteritis from Sea Bathing:
2608    Results from Randomised Exposure. Lancet 344(8927): 905-909.
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2670    States from 1999 to 2001. Journal of Clinical Microbiology 42(7): 2944-51.
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2674    associated with swimming in Battle Ground Lake, Vancouver, Washington. Journal of
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2686    L.R., Elmir, S.M., Wanless, D., Bartkowiak, J., Boiteau, R.,  Withum, K., Abdelzaher,
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2689    Indicator Bacteria in Non-Point Source Subtropical Recreational Marine Waters. Water
2690    Research 44(13): 3763-3772.
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2698    Non-Human Sources of Faecal Contamination. Water Research 44(16): 4674-4691.


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2699
2700    Stevenson, A.H. 1953. Studies of Bathing Water Quality and Health. American Journal
2701    of Public Health 43: 429-538.
2702
2703    Till, D., McBride, G. 2004. Potential public health risk of Campylobacter and other
2704    zoonotic waterborne infections in New Zealand. Chapter 12 in Waterborne Zoonoses:
2705    Identification, causes and control. Cotruvo, J.A., Dufour, A., Rees, G., Bartram, J., Carr,
2706    R., Cliver, D.O., Craun, G.F., Payer, R., Gannon, V.P.J., ed. 2004. World Health
2707    Organization (WHO). IWA Publishing: London, UK.
2708
2709    USDA 2000. Waterborne Pathogens in Agricultural Watersheds. United States
2710    Department of Agriculture, Natural Resources Conservation Service, Watershed Science
2711    Institute.
2712
2713    U.S. EPA 1976. Quality Criteria for Water. U.S. Environmental Protection Agency:
2714    Washington, DC.
2715
2716    U.S. EPA 1978. Microbiological Methods for Monitoring the Environment: Water and
2717    Wastes. U.S. Environmental Protection Agency, Office of Research  and Development:
2718    Cincinnati, OH. EPA 600-8-78-017.
2719
2720    U.S. EPA 1986. EPA's Ambient Water Quality Criteria for Bacteria - 1986. U.S.
2721    Environmental Protection Agency: Washington, DC. EPA440/5-84-002.
2722
2723    U.S. EPA 2002a. Method 1603: Escherichia coli (E. coli) in Water by Membrane
2724    Filtration Using Modified Membrane-Thermotolerant Escherichia coli Agar (Modified
2725    mTEC). Available at: http://www.epa.gov/microbes/1603sp02.pdf
2726
2727    U.S. EPA 2002b. Method 1600: Enterococci in Water by Membrane Filtration Using
2728    membrane-Enterococcus Indoxyl-p-D-Glucoside Agar (mEI). Available at:
2729    http://www.epa.gov/microbes/1600sp02.pdf
2730
2731    U.S. EPA 2003. America's Children and the Environment: Measures of Contaminants,
2732    Body Burdens and Illnesses, 2nd Edition. Available at:
2733    http://vosemitel.epa.gov/ee/epa/eerm.nsf/vwGA/F042C8CE39DE432285256CD7006B8
2734    001
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2736    U.S. EPA 2004. Water Quality Standards for Coastal and Great Lakes Recreation Waters
2737    Rule (BEACH Act). 69 FR 67217. November 16, 2004.
2738
2739    U.S. EPA 2007a. Report of the Expert Scientific Workshop on Critical Research Needs
2740    for the Development of New or Revised Recreational Water Quality Criteria (Airlie
2741    Workshop). EPA-823-R-07-006.
2742
2743    U.S. EPA 2007b. Critical Path Science Plan. EPA-823-R-08-002.
2744
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                                                                                 12-9-11
2745    U.S. EPA 2008. Great Lakes Beach Sanitary Survey User Manual. U.S. Environmental
2746    Protection Agency, Office of Water. EPA-823-B-06-001. Available at:
2747    http://water.epa.gov/type/oceb/beaches/upload/2008_05_29_beaches_sanitarysurvey_use
2748    r-manual.pdf
2749
2750    U.S. EPA 2009a. Review of Zoonotic Pathogens in Ambient Waters. EPA 822-R-09-002.
2751    Available at:
2752    http://water.epa.gov/scitech/swguidance/waterquality/standards/criteria/health/recreation/
2753    upload/2009_07_l 6_criteria_recreation_zoonoticpathogensreview.pdf
2754
2755    U.S. EPA 2009b. Review of Published Studies to Characterize Relative Risks from
2756    Different Sources of Fecal Contamination in Recreational Water, U.S. Environmental
2757    Protection Agency, Office of Science and Technology: Washington, DC. EPA 822-R-09-
2758    001.
2759
2760    U.S. EPA 2010a. Quantitative Microbial Risk Assessment to Estimate Illness in
2761    Freshwater Impacted by Agricultural Animal Sources of Fecal Contamination. EPA 822-
2762    R-10-005. Available at:
2763    http://water.epa.gov/scitech/swguidance/standards/criteria/health/recreation/upload/P4-
2764    QMRA-508.pdf
2765
2766    U.S. EPA 2010b. Predictive Tools for Beach Notification Volume I: Review and
2767    Technical Protocol. EPA-823-R-10-003. Available at:
2768    http://water.epa.gov/scitech/swguidance/standards/criteria/health/recreation/upload/P26-
2769    Report-Volume-I-Final  508.pdf
2770
2771    U.S. EPA 2010c. Predictive Modeling at Beaches Volume II: Predictive Tools for Beach
2772    Notification. EPA-600-R-10-176. Available at:
2773    http://water.epa.gov/scitech/swguidance/standards/criteria/health/recreation/upload/P23-
2774    25-Repoit-Volume-II-Final 508.pdf
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2777    Assessment of Recreational Water Epidemiology Studies (NEEAR 2010 - Surfside &
2778    Boqueron). EPA-600-R-10-168. Available at:
2779    http://www.epa.gov/neear/files/Report2009v5_508comp.pdf
2780
2781    U.S. EPA 2010e. Evaluation of Multiple Indicator Combinations to Develop Quantifiable
2782    Relationships. EPA-822-R-10-004. Available at:
2783    http://water.epa.gov/scitech/swguidance/standards/criteria/health/recreation/upload/P15-
2784    Repoit-to-EPA-12-28-10.pdf
2785
2786    U.S. EPA 201 Of. Effects of Holding Time, Storage, and the Preservation of Samples on
2787    Sample Integrity for the Detection of Fecal  Indicator Bacteria by Quantitative
2788    Polymerase Chain Reaction. EPA/600/R-10/150. Available at:
2789    http://water.epa.gov/scitech/swguidance/standards/criteria/health/recreation/upload/P16-
2790    Final-Report.pdf


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2791
2792    U.S. EPA 2010g. Applicability of Great Lakes NEEAR Dataset to Inland Recreational
2793    Water Criteria; Summary of Key Studies. EPA-823-R1-0002.
2794
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2796    Polymerase Chain Reaction (qPCR) Assay. EPA-821-R-10-004
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2798
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2801    Preparation.
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2805    Associated with a Large Statewide Increase in Cryptosporidiosis. Epidemiological
2806    Infections 137(12):  1781-8.
2807
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2809    Exposure to Tropical Coastal Waters Impacted by Terrestrial Dry-Weather Runoff.
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2816    Protection Agency Water Quality Guidelines for Recreational Waters Prevent
2817    Gastrointestinal Illness? A Systematic Review and Meta-Analysis.  Environmental Health
2818    Perspectives 111(8): 1102-1109.
2819
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2821    A.P., 2006. Rapidly Measured Indicators of Recreational Water Quality Are Predictive of
2822    Swimming-Associated Gastrointestinal Illness. Environmental Health Perspectives
2823    114(1): 24-28.
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2826    L., Dufour, A.P. 2008. High Sensitivity of Children to Swimming-Associated
2827    Gastrointestinal Illness - Results Using a Rapid Assay of Recreational Water Quality.
2828    Epidemiology 19(3): 375-383.
2829
2830    Wade, T.J.,  Sams, E., Brenner, K.P., Haugland, R., Chern, E., Beach, M., Wymer, L.,
2831    Rankin, C.C., Love, D., Li, Q., Noble, R., Dufour, A.P. 2010. Rapidly Measured
2832    Indicators or Recreational Water Quality and Swimming-Associated Illness at Marine
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2834
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2835    WERF 2009. Report on the Expert Scientific Workshop on Critical Research and Science
2836    Needs for the Development of Recreational Water Quality Criteria for Inland Waters.
2837    PATH4W09.
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2840    Indicators for QMRA in Recreational waters. PATH2R08.
2841
2842    WHO 1999. Principles and Guidelines for the Conduct of Microbiological Risk
2843    Assessment, CAC/GL-30. World Health Organization: Geneva, Switzerland. Available
2844    at: http://www.who.int/foodsafety/publications/micro/cacl999/en/
2845
2846    WHO 2003. Guidelines for Safe Recreational Water Environments:  Volume 1 Coastal
2847    and Fresh Waters. Available at:
2848    http://www.who.int/water sanitation  health/bathing/srwe 1 /en/
2849
2850    Wiedenmann, A., Kriiger, P., Dietz, K., Lopez-Pila, J.M., Szewzyk,  R., Botzenhart, K.
2851    2006. A Randomized Controlled Trial Assessing Infectious Disease  Risks from Bathing
2852    in Fresh Recreational Waters in Relation to the Concentration of Escherichia coli,
2853    Intestinal Enterococci, Clostridiumperfringens, and Somatic Coliphages. Environmental
2854    Health Perspectives 114(2): 228-236.
2855
2856    Wyer M.D., Kay, D., Fleisher, J.M.,  Salmon, R.L.,  Jones, F., Godfree, A.F., Jackson, G.,
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2858    Research 33: 715-22.
2859
2860    Wymer, L.J., Wade,  T.J. 2007. The lognormal distribution and use of the geometric mean
2861    and the arithmetic mean in recreational water quality measurement, in Statistical
2862    Framework for Recreational Water Quality Criteria and Monitoring  (ed L. J. Wymer),
2863    John Wiley and Sons, Ltd, Chichester, UK.
2864
2865    Xue, J., Zartarian, V., Moya, J., Freeman, N., Beamer, P., Black, K., Tulve,  N., Shalat,  S.
2866    2007. Meta-Analysis of Children's Hand-to-Mouth Frequency Data  for Estimating
2867    Nondietary Ingestion Exposure.  Risk Analysis 27(2): 411-420.
2868
2869    Zmirou, N., Pena, L., Ledrans, M., Leterte, A. 2003. Risks Associated with the
2870    Microbiological Quality of Bodies of Fresh and Marine Water Used for Recreational
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