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Comments Question Data in Criteria Used for Bacteria Standards Proposal

Questions on the data used to determine safe levels of bacteria in recreational waters and the means of sampling those waters were raised in numerous comments to the Environmental Protection Agency about a proposal establishing standards for coastal and Great Lakes states.
EPA proposed July 9 the water quality criteria for bacteria in recreational waters of coastal and Great Lakes states under the 2000 Beach Environmental Assessment and Coastal Health Act. The comment period closed Aug. 9 (128 DEN A-11, 7/6/04 ; 69 Fed. Reg. 41,720).

The standards would apply in the states that have not yet adopted EPA's criteria reflecting an 1986 EPA document recommending ambient water quality criteria for bacteria. Specifically, the document directs states to use E. coli instead of fecal coliforms as an indicator of unsafe levels of fecal contamination fresh water. Enterococci should be used as the indicator organisms for fresh and marine waters.

The BEACH Act gave coastal and Great Lakes states until April 10 to incorporate water quality criteria limiting bacteria concentrations to levels considered safe enough for swimming based on EPA would have to set the criteria for the four states failing to meet the mandate.

Wastewater treatment officials and representatives from scientific organizations questioned the use of the 1986 criteria document because it relies on data that is more than 20 years old.

The Association of Metropolitan Sewerage Agencies, for example, said the studies used for the 1986 criteria document were flawed.

"AMSA has commented on the flaws in the original studies underlying the criteria and the fact that no studies to confirm the criteria have been conducted since they were first established," the comments said. "The 1986 enterococci criterion, for example, was developed based on very limited and known to be highly polluted U.S. coastal marine environments."

State agencies have raised similar concerns about the 1986 document (138 DEN A-1, 7/20/04 ).


Sources of Contamination

Norm LeBlanc, chief of technical services for the Hampton Roads (Va.) Sanitation District, said the studies done in the 1970s upon which the 1986 criteria are based only looked at areas with fecal contamination known to come from human sources such as combined sewer overflows. The studies did not consider areas contaminated by birds, waterfowl, and other wildlife, LeBlanc said.
"Additionally, there were no control sites or beaches used. There were no sites with natural sources of bacteria. There were clean sites without known point sources of bacterial pollution," LeBlanc said.

Other groups also commented on the fact that the proposed criteria do not consider other sources of contamination nor do they consider human health impacts other than gastrointestinal illness.

The American Society for Microbiology said EPA should consider revising the level of acceptable risk, which may have changed since the 1986 criteria were issued. The risk level in the 1986 criteria is eight cases of gastrointestinal illness per 1,000 swimmers in fresh water and 19 cases in marine waters. ASM said the risk level should consider illnesses other than gastrointestinal problems, such as respiratory sickness that can result from exposure to fecal contamination.

ASM recommended the agency assess the reliability and use of the existing and new indicator species, such as coliphages.

"In addition, the EPA should support detailed assessments of indicator species ecology, particularly with respect to persistence and growth in receiving waters and sediments," ASM said.


Other Criteria Needed

The Natural Resources Defense Council generally supported the proposal but urged EPA to develop criteria for pathogen indicators that correlate with contamination of recreational waters by viruses and other nonbacterial pathogens. The criteria for E. coli and enterococci are superior to those for fecal coliform, NRDC said, but do not serve as indicators for viruses that also may contaminate recreational waters.
NRDC also opposed revising the level of acceptable risk from 0.8 percent to 1.0 percent, saying the proposal would statistically allow a 25-percent increase in illness caused from swimming in contaminated water.

"Such a standard would thus not be 'as protective of human health' as EPA's 1986 304(a) criteria document, and thus would not be consistent with the requirements of Section 303(i) of the Clean Water Act," NRDC said.

The head of the Milwaukee Metropolitan Sewerage District disagreed and said the small increase in risk would have no effect on public health.

"It is doubtful that this increase would be significant in designated swimming areas," Kevin Shafer, executive director of the district, said in comments. "In water bodies with other use designations, this change would be even less significant."

NRDC also said the agency should continue research into other methods of measuring for contaminants.

"NRDC also encourages EPA to accelerate ongoing research into beachwater testing methods for pathogens that can provide immediate results," Stoner said. "Currently available tests usually take 24 hours or longer to provide results."

NRDC also said EPA should specify in the criteria that mixing zones, the areas of initial dilution from a point source, should not be allowed.

"Use of mixing zones would not be as protective as the requirements in the 1986 water quality criteria document," NRDC said.


Geometric Mean, Single Sample Maximum

The 1986 criteria specifies a geometric mean, which EPA said is the best way to assess risk over the course of a recreation season, and a single sample maximum (SSM), which is the best value against which to compare individual measurements.
In the proposal, EPA said the use of SSM values would allow for a quantitative determination based on a single sample of when water quality at a specific site may be degraded.

"This is especially important for beaches that are infrequently monitored or prone to short term spikes in bacteria concentrations," the proposal said.

Four single sample maximums, identical to the 1986 criteria, are proposed based on the different types of recreational use of the water.

A geometric mean, which represents the central tendency of a series of bacteria level measurements without giving too much weight to extreme values that may be considered statistical outliers, is also proposed.

The proposal geometric mean for E. coli in fresh water is 126 colonies of organisms per 100 milliliters.

The agency received significant comments regarding the use of the geometric mean and single sample maximum, with many saying the latter should only be used regarding decisions on whether to close a beach because of excessive bacteria levels. The SSM should not be used for regulatory compliance purposes, such as National Pollutant Discharge Elimination System permit limits, several wastewater treatment officials said.

Erwin Odeal, executive director of the Northeast Ohio Regional Sewer District, said the use of an SSM is more protective than what is mandated in the BEACH Act.

"Adopting the SSM as a value never to be exceeded could, in practical implementation, have the undesired effect of discouraging the collection of sufficient samples to calculate a representative geometric mean--the indicator of human health risk acknowledged by EPA to be much superior to individual values from single samples," Odeal said.

Alton Boozer, chief of the Water Bureau for the South Carolina Department of Health & Environmental Control, was among those who said EPA should include both the geometric mean, which should be used as a chronic number in water quality programs, and the single sample maximum for the acute number in the criteria. However, states should have the flexibility to determine which single sample maximum should be used in which waters, he said.

"We know South Carolina's Grand Strand has extremely high use and the SSM should reflect that," he said. "However, Gulf Coast beaches in Mississippi and Alabama, perhaps the most heavily used in their states, do not receive nearly the use as the Grand Strand. Accordingly, they should have an SSM to reflect that in comparison to the most heavily used beaches in the region or nation."