128 



The ocean stations with 20 percent of samples in excess of the standards were located 

 in Atlantic City in Atlantic County; Long Branch, Loch Arbour, and Spring Lake in 

 Monmouth County; and Seaside Heights and Dover Township in Ocean County. 

 As discussed in III(C) below, DEPE and DOH believe that the exceedances in Seaside 

 Heights are attributable to birds roosting under the pier located it that station. DEPE 

 believes that the number of exceedani es at the other stati ms are attributable 

 primarily to stormwater discharges. I ossible responses to these problems are 

 discussed in III(E) below. 



B. Comparison of Fecal Coliform and Enteroc occi Concentrations 



1. General 



As discussed above, the health agencies base their decisions to close beaches upon 

 fecal coliform concentrations. However, in 1986 the United States Environmental 

 Protection Agency ("USEPA") recommended replacing the fecal coliform primary 

 contact guideline with an enterococci guideline. USEPA epidemiological research 

 indicated that the survivability of enterococci in marine waters more closely 

 simulated the survivability of the viral pathogens that cause gastrointestinal ("GI") 

 disease in recreational bathing populations. USEPA's research also indicated that 

 enterococci concentrations directly correlated with the incidence of GI disease when 

 the enterococci was primarily of human origin; the research did not evaluate 

 whether a correlation exists when the enterococci are predominately of lower 

 (nonhuman) animal or avian origin. 



The DEPE and the DOH believe that they must col'ect background enterococci 

 data for the nearshore coastal waters of the state before adopting the USEPA 

 guideline or developing an alternate primary contact standard. The DEPE and DOH 

 are collecting that data and comparing it with fecal coliform data collected 

 simultaneously from the same monitoring stations. The main purpose of that 

 comparison is to determine whether the guideline that USEPA recommends (35 

 enterococci per 100 mL of sample, which is the same as the SWQS for enterococci) 

 will be at least as effective as the existing fecal coliform primary contact standard. 

 The DEPE's experience with both indicators thus far has shown no material 

 difference in the results they produce. 



Part 2 below sets forth the data that the DEPE has collected. Part 3 sets forth 

 USEPA's data. The DEPE monitoring statior\s are closer than the USEPA stations to 

 the onshore sources of contamination such as stormwater and lake discharges. As a 

 result, the DEPE data for both FC and EC are generally higher than the USEPA data. 



2. DEPE data 



Table 7 lists the geometric mean of FC and EC concentrations at each of 65 ocean 

 and bay stations for 1992. At station 49, the geometric mean of FC concentrations 

 exceeded the federal primary contact guideline, but the geometric mean of EC 



