Page
1
of
3
Note
to
the
record
of
the
Water
Quality
Standards
for
Coastal
and
Great
Lakes
Recreation
Waters
rule
September
29,
2004
On
August
8,
2004,
Denise
Keehner,
Donna
Davis,
and
Jim
Pendergast
of
EPA
met
with
selected
members
of
the
Association
of
State
and
Interstate
Water
Pollution
Control
Administrators
(
ASIWPCA)
at
their
request.
The
meeting
was
at
the
ASIWPCA
annual
meeting
in
Chicago,
IL.

During
the
meeting,
ASIWPCA
members
provided
verbal
commentary
on
the
proposed
Water
Quality
Standards
for
Coastal
and
Great
Lakes
Recreation
Waters
rule
that
EPA
published
for
comment
on
July
9,
2004.
The
public
comment
period
for
this
rule
expired
August
9,
2004.

The
following
are
EPA's
notes
of
what
ASIWPCA
members
said
during
this
meeting.

**************************************************************************

Florida:
Difficult
for
a
state
to
act
not
knowing
what
the
final
rule
will
look
like.
The
state
likes
the
geometric
mean
proposed
and
the
use
of
the
single
sample
maximum
for
issuing
beach
advisories.

N.
Carolina:
Doesn't
think
the
single
sample
maximum
is
appropriate.
The
state
doesn't
know
how
to
move
forward
in
adopting
water
quality
standards
without
knowing
what
the
final
rule
will
look
like.

S.
Carolina:
Using
a
single
sample
maximum
for
making
beach
closures
is
OK,
but
don't
use
it
for
attainment
purposes.
The
state
doesn't
monitor
at
beaches
during
winter,
and
only
looks
at
the
worst
case
situations,
so
the
state
does
not
believe
these
data
are
appropriate
for
determining
impairment.

N.
Carolina:
EPA
needs
to
provide
maximum
flexibility
to
states.
Don't
put
the
single
sample
maximum
into
the
water
quality
standards.
If
the
single
sample
maximum
is
in
the
rule,
states
will
never
be
able
to
propose
anything
less
stringent.
The
single
sample
maximum
issue
is
the
most
important
issue
for
the
state.

Florida:
Florida
cannot
use
the
EPA
data
underlying
the
EPA
criterion
to
support
an
single
sample
maximum
in
Florida
water
quality
standards.
The
state
points
to
the
criticisms
of
the
single
sample
maximum
and
does
not
believe
that
it
can
sustain
defending
the
single
sample
maximum
itself.
The
state
is
OK
with
the
geometric
mean.
The
state
notes
that
the
single
sample
maximum
is
not
tied
to
illness
rates.
The
state
believes
that
an
single
sample
maximum
of
104
for
all
waters
would
cause
a
lot
of
upset,
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3
S.
Carolina:
Expects
many
comments
from
the
regulated
community
with
respect
to
costs
for
meeting
the
criteria.

Florida:
Is
the
cost
of
chlorination
for
the
new
criteria
roughly
the
same
as
for
fecal
coliform?
The
state
does
not
believe
there
will
be
a
large
difference.

Washington:
Issue
is
duplicative
monitoring
and
the
cost
of
that.
The
state
also
questions
whether
there
may
be
additional
treatment
costs.

N.
Carolina:
Questioned
whether
the
original
epidemiological
studies
were
peer
reviews,
and
concerned
that
upper
EPA
management
may
not
know
the
nature
of
the
concern
that
states
have
with
the
scientific
basis
of
the
criterion.

S.
Carolina:
What
did
EPA's
Office
of
Research
and
Development
start
with
redoing
the
fresh
water
studies
instead
of
for
marine
waters.

Kansas:
Concerned
about
reason
why
no
tribes
were
included
in
the
rule;
believes
the
explanation
is
confusing.
Concerned
that
the
rebuttable
presumption
that
all
waters
have
a
primary
contact
recreation
use.

N.
Carolina:
If
the
water
quality
standard
is
too
tightly
tied
down,
states
won't
have
the
flexibility
to
make
risk
management
decisions.

Florida:
Each
state
already
has
implementable
criteria,
and
does
not
see
the
new
criteria
as
an
improvement
to
public
health.

S.
Carolina:
It
is
not
prudent
to
apply
the
criteria
to
all
inland
waters.

N.
Carolina:
WQS
setting
is
a
difficult
process,
and
states
do
not
want
to
go
through
it
multiple
times.
See
the
rule
as
leading
to
this
result.

Mississippi:
What
does
the
rule
say
about
categorizing
beaches.

S.
Carolina:
Should
be
a
national
comparative
scale
for
beaches
rather
than
a
scale
within
a
state.

Washington:
Data
on
how
to
categorize
beaches
won't
likely
be
available.

N.
Carolina:
How
does
a
state
compare
volume
of
use
between
states
from
different
parts
of
the
country?
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S.
Carolina:
If
you
are
doing
things
to
draw
people
to
a
beach
(
parking,
access,
life
guards)
that
should
be
high
use,
but
how
do
you
move
beyond
that
for
the
rest
of
the
categorizations?

Florida:
Deciding
on
what
to
use
for
a
long
coasts
is
a
very
tangled
decision
when
using
Single
sample
maximums,
but
the
geometric
mean
may
resolve
some
of
these
issues.

Washington:
EPA
alternatives
for
non­
human
uses
is
not
comparable
with
the
shellfish
requirements.
Seals
and
sea
lions
may
contribute
to
illness
and
the
state
does
not
think
that
it
is
OK
to
write
off
these
risks.
A
state
should
still
post
the
health
issue
and
recognize
that
it
is
an
animal
issue
in
this
part.

S.
Carolina:
Focus
on
implementation
for
coastal
waters.
See
use
for
single
sample
maximum
in
advisories.
How
do
you
identify
beach
topics
for
discussion
in
later
guidance?
