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state Water Resources Control Board July 15, 1993 



HR31 



Since 1972, the California Ocean Plan has required that waste discharged to the 

 ocean be monitored for total and fecal coliform, the indicator organisms historically 

 used to examine water for its potential to contain pathogenic organisms. However, 

 research conducted over the last 20 years has indicated that total and fecal coliform 

 bacteria may not be adequate indicators of some water-borne pathogens such as 

 viruses. 



In 1986 EPA recommended that states adopt an enterococcus standard for marine 

 waters based on epidemiological studies conducted in east coast waters between 

 1972 and 1978. These studies provide the first and only correlation of the incidence 

 of illness with concentrations of indicator organisms in marine waters. It is our 

 concern that the correlations developed In the EPA studies may not be applicable to 

 the colder, deeper waters of California's coast. The environmental fate of a 

 specified indicator organism may, for example, vary widely between Cape Cod and 

 Santa Monica Bay. 



Because of the controversy surrounding the adoption of the enterococcus standard, 

 an additional provision was added to the California Ocean Plan in 1990 requiring 

 dischargers, upon renewal of their permits, to monitor for enterococcus bacterial at 

 all sites where total and fecal coliform sampling is conducted. The intent of this 

 requirementwas to determine if a correlation exists between levels of various 

 indicator organisms and sources of sewage discharges. 



HR 31 Brings Additional Costs to States 



Although HR 31 does not specify which organism would be used for water quality 

 criteria for pathogens, this discussion assumes that EPA would select enterococcus 

 as the indicator organism of choice and if enterococcus is so designated, California 

 laboratories would then be required to change current procedures. Such changes 

 would result in increased costs to industry and local governments required to 

 provide monitoring data to the state. 



