State of the Beach/State Reports/PR/Water Quality
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- 1 Water Quality Monitoring Program
- 2 Water Quality Contacts
- 3 Beach Closures
- 4 Beach Closure Data
- 5 Storm Drains and Sewage Outfalls
- 6 Water Quality Contact (Runoff and Outfalls)
- 7 Perception of Causes
- 8 Public Education
- 9 General Reference Documents
- 10 Footnotes
Water Quality Monitoring Program
The Beaches Environmental Assessment and Coastal Health Act (BEACH Act) signed into law on October 10, 2000, amends the federal Clean Water Act (CWA), incorporating provisions intended to reduce the risk of illness to users of the Nation's recreational waters. The BEACH Act authorizes the U.S. Environmental Protection Agency (EPA) to award program development and implementation grants to eligible States, Territories, Tribes, and local governments to support microbiological testing and monitoring of coastal recreation waters, including the Great Lakes, that are adjacent to beaches or similar points of access used by the public. BEACH Act grants also provide support for development and implementation of programs to notify the public of the potential exposure to disease-causing microorganisms in coastal recreation waters. EPA encourages coastal States and Territories to apply for BEACH Act Grants for Program Implementation (referred to as Implementation Grants) to implement effective and comprehensive coastal recreation water monitoring and public notification programs. CWA section 406(i) authorizes appropriations of up to $30 million per year to develop and implement beach programs. Unfortunately, only about one-third that amount has been authorized each year since the program's inception. For fiscal year 2014, the total fund available for BEACH Act grants was $9.55 million. Funding beyond 2012 has been in jeopardy, since EPA's budget requests for this program in FY2013 and FY2014 were ZERO (money for testing in 2013 and 2014 was ultimately allocated as part of Continuing Resolutions to resolve the Federal Budget impasse) and there was also no money for beach testing in the FY2015 budget. Again, it was restored at the last minute as part of a Continuing Resolution. It is very discouraging to have to fight for this basic funding to protect the public's health at the beach every year. Thankfully, there is a growing movement to provide stable funding. If available, funds are allocated to the states and territories based on a formula which uses three factors that are readily available and verifiable: (1) Length of beach season, (2) miles of beach and (3) number of people that use the beaches. Puerto Rico was eligible for a $317,000 grant in fiscal year 2014.
Potions of the following discussion are taken from NRDC's report Testing the Waters, A Guide to Water Quality at Vacation Beaches, July 2005 (NRDC has not updated their Puerto Rico report since 2005). The Puerto Rico discussion begins on page 218 of the NRDC report.
In October 2002, Puerto Rico began a monitoring and closing/advisory public notification program. When a beach is closed or an advisory issued, the public is notified through signs posted at the beach and announcements in newspapers. The Puerto Rico Environmental Quality Board (PREQB) has constructed a website to post monitoring and closing/advisory information.
The EQB, in coordination with the EPA, administers the Beaches Environmental Assessment and Coastal Health (BEACH) Program created at the Federal level by the “Beach Act” of 2000. Under this Program, the EQB is responsible for: (1) bacteriological monitoring of all beaches deemed swimmable, (2) notify the results of the monitoring, done every two weeks in the beaches included in the Program and (3) protect the health of users who visit those beaches. Sampling is conducted to monitor fecal coliforms and enterococcus – bacteria used by the EQB as indicators of possible fecal contamination – every two weeks on 23 beaches. The results are notified to the public as required by the CWA. A brief description of the program and a map of the monitored beaches that indicates the current status of each beach can be found at http://www.prtc.net/~jcaagua/monitoria.html.
A table with the actual fecal coliform and enterococcus monitoring results is also available.
More information on the monitoring program and current beach status can be obtained at (787) 767-8181 x3550 and at http://www.prtc.net/~jcaagua/
According to NRDC's report, beaches that are not monitored include:
- Pico de Piedra in Aguada County
- Crash Boat in Aguadilla County∗
- Balneario de Anasco in Anasco County∗
- Moja Casabe in Cabo Rojo County∗
- Balneario Sardinera in Dorado County∗
- Seven Seas in Fajardo County∗
- Balneario de Bogueron in Guanica County∗
- Balneario Playa Santa in Guanica County∗
- Playita Rosada in Lajas County
- Tropical Beach in Naguabo County
- Balneario Patillas in Patillas County∗
- Balneario El Tuque in Ponce County
- El Escambron in San Juan County∗
- Playa Lucia in Yabucoa County
∗ = These beaches are listed as being monitored on the Notificacion Ambiental Website, perhaps indicating an expansion of the monitoring program since 2005.
Surfrider Foundation's Rincon chapter is now monitoring water quality at several beaches in the Rincon area (NW Puerto Rico).
Standards and Testing
Indicator Organisms: Fecal coliform, total coliform, enterococcus.
Standards: According to the Environmental Protection Agency’s (EPA) “Water Quality Standards for Coastal and Great Lakes Recreation Waters: Final Rule,” Puerto Rico did not adopt BEACH Act required standards in 2004: for ocean and bay waters, an enterococcus single sample maximum of 104/100ml and a steady-state geometric mean of 35/100ml.
Puerto Rico’s marine water standards are an enterococcus steady-state geometric mean of 35/100ml and a fecal coliform steady-state geometric mean of 200/100ml, both for five samples.
For freshwater, Puerto Rico uses a geometric mean of 2,000 fecal coliform/100ml for five samples and a geometric mean of 10,000 total coliform/100ml for five samples.
Testing Frequency: For 2004, Puerto Rico reported 36 beaches; 61 percent (22) were monitored every two weeks, and 39 percent (14) were not monitored.
Puerto Rico CZM staff reported to Surfrider Foundation that 27 beaches are monitored and that there have been four new designations of "Blue Flag" beaches (a European quality assurance designation).
Miles of Ocean and Bay Beach Monitored: Of the total 550 miles of coast (includes the principal offshore islands Mona, Vieques, and Culebra), 63 are monitored.
A report Testing Water Quality in Puerto Rico’s Beaches: A Volunteer Experience was prepared by Ana Navarro, Ph.D., University of Puerto Rico Sea Grant College Program. The report concludes:
This project initiated a volunteer monitoring program in several municipalities of Puerto Rico. The local communities were capacitated and made aware of beaches safety. The volunteers obtained baseline water quality data of some beaches that are not tested by the state agencies. As a result of this project, Ciudadanos Aguadeños Pro Conservación del Ambiente (CAPCA), an environmental group of Aguada, be part of an EQB Beach Grant thru the EPA BEACH Program for the year 2001-2002. Achieving a real participation of the local communities in the state (EQB) and federal (EPA) programs that protect the people’s health and the safety of our coastal environments. CAPCA alerted the Puerto Rico Health Department about the relationship between pathogenic bacteria’s in their beaches and an increase of Salmonella sickness in the children of Aguada during the summer. They stated that the Primary Treatment Plant and the septic tanks of the private houses in the maritime zone are the pollution source of these bacteria.
Water Quality Contacts
Puerto Rico Environmental Quality Board
Water Quality Area
P.O. Box 11488
Santurce, PR 00910
TEL: (787) 767-8181 ext. 2539
Calidad de Agua (Water Quality)
431 Ave. Ponce de León
Edif. National Plaza
Hato Rey, P.R. 00917
(787) 767-8181 x2601 (Office of the Director)
(787) 767-8181 x2530 (Division of Plans and Projects)
In 2002, Puerto Rico began a closing/advisory public notification program; when a beach is closed or an advisory issued, the public is notified through signs posted at the beach and announcements in newspapers and on the Internet.
According to NRDC, Puerto Rico reported 460 closing/advisory days in 2006 due to monitoring that revealed elevated bacteria levels from sewage sources.
Beach Closure Data
Source: NRDC, 2007
In June 2013, U.S. EPA released its latest data about beach closings and advisories for the 2012 swimming season. Note that for some states and territories the data is incomplete, making state-to-state or year-to-year comparisons difficult. EPA no longer publishes this report.
In 2009 U.S. EPA conducted epidemiology studies at Surfside Beach in South Carolina and at Boqueron Beach, Puerto Rico. EPA's Report on 2009 National Epidemiologic and Environmental Assessment of Recreational Water Epidemiology Studies (PDF) discusses the results of the studies. In both cases, generally good water quality prevented the researchers from establishing a dose-response relationship between fecal indicator bacteria and gastrointestinal or other illnesses. In Puerto Rico, many quantitative polymerase chain reaction (qPCR) assays could not be completed because of interfering or inhibitory substances in the water samples. Summary.
The Puerto Rico Water and Environmental Research Institute lists several publications on coastal water quality and management in Puerto Rico. http://www.ece.uprm.edu/rumhp/prwrri/
One such publication is Monitoring the Water Quality Parameters of Mayaguez Bay, a project that was scheduled to be completed on May 31, 2004. The Principal Investigators were:
|Nazario D. Ramirez, Ph.D.
Department of Industrial Engineering
Fernando Gilbes, Ph.D
- A Survey of Sediment Discharge and Shelf Reef Conditions
- Fate of Selected Priority Pollutants in Regional Wastewater Treatment Plants in Puerto Rico and Their Impact on the Quality of Coastal Receiving Waters.
The US EPA Office of Water provides access to information about water quality in Puerto Rico. It reports that 99% of the assessed estuarine waters fully support aquatic life use and 95% fully support swimming use. Metals from land disposal and pathogens from unknown sources are responsible for the impaired miles. Industrial and municipal discharges, collection system failures, spills, marinas, urban runoff, and land disposal of wastes also pollute beaches. Puerto Rico also maintains a Permanent Coastal Water Quality Network of 88 stations and the San Juan Beachfront Special Monitoring Network of 22 stations sampled monthly for bacterial contamination. http://www.epa.gov/ow/states/PR/
The United States Geological Survey maintains a Website, USGS Water Resources of the Caribbean. This site is a valuable source of information including current projects, online reports, publications, maps, real-time water conditions, and educational outreach material for teachers and students.
The University of Puerto Rico Sea Grant Program has a Website that provides access to water quality information.
Storm Drains and Sewage Outfalls
No information was found on the location or number of storm drains or sewage outfalls in Puerto Rico.
Excerpts from the 2009 CZM Program document:
The Puerto Rico Aqueducts and Sewers Authority (PRASA) operates 60 water treatment plants which serve approximately 55% of the population located in Puerto Rico’s urban areas. Of these, six plants (Arecibo, Bayamón/Puerto Nuevo, Carolina, Ponce and Aguadilla) provide primary treatment to water and discharge directly to the sea. Primary plants are limited to the separation of solids and chlorine treatment to kill bacteria. Once treated, these waters are discharged to sea, assuming they would be diluted within an area known as the mixing zone. However, these areas are typically close to the coast and bathers areas (i.e. Vacía Talega) and the chlorine used in the treatment processes and the contaminants prevailing in these waters (metals and nutrients) constitute a threat to users, coral communities and marine life.Industries (including plants for generation of energy) are also principal dischargers. In Puerto Rico, 73 industries count with the “National Pollutant Discharge Elimination System” (NPDES) permits. This permit is administered by the EQB as disposed by Section 402 of the CWA, which authorizes point source discharges into coastal waters. The NPDES Program also regulates, through permits, rain water discharges coming from industries and municipalities, better known as run-off or pluvial water. By the same token, discharges of thermal waters coming from Puerto Rico’s thermoelectric complexes (Puerto Nuevo and Palo Seco) in the SJMA, and Guayanilla and Aguirre in the South, are potential polluting sources for coastal waters and marine life."
Primary treatment plants are insufficient in order to effectively purify waters discharged to the sea, even when they comply with water quality standards. This results in the deposit of nutrients, organic matter and metals which affect water quality, thus affecting marine life, including coral reef communities. In order to address this issue, the PRASA will need more funding to allow the expansion of current treatment to possible a secondary or tertiary treatment.
Another 52 plants provide secondary treatment to residual waters. As of 2005, 95% of these complied with requisites established by the EPA and the EQB regarding discharges to the Island’s water bodies. Another three plants in the municipalities of Caguas, Aibonito and Fajardo provide tertiary treatment to residual waters. Nonetheless, in most of Puerto Rico’s rural areas individual, commercial and industrial septic tanks discharge into soil. The EQB’s 2006 “Report on the State and Condition of Puerto Rico’s Environment” estimated there are more than 2,500 structures operating septic tanks to dispose of used waters and/or processed commercial or industrial waste. In Puerto Rico, inadequate septic tank management has the potential to affect the quality of water bodies due to the topography, the proximity of housing to water bodies (which are abundant), as well as the geology and soil composition.
According to Surfrider Foundation's Puerto Rico Chapter, Puerto Rico catches the fresh Trade Wind Currents and is blessed with some of the cleanest natural ocean waters on both the Atlantic (northern) and Caribbean (southern) sides of the island. On the other hand, sewage treatment or septic systems are installed in fewer than half of the homes of Puerto Rico's 4 million residents. Urban waterways and sewage outfalls pump tons of raw sewage and silty runoff out onto coral reef environments at numerous locations.
In July 2011 EPA released a report Keeping Raw Sewage and Contaminated Stormwater Out of the Public’s Water, to answer commonly asked questions about combined sewer overflows. Many of the sewer systems in New York State and New Jersey and some in Puerto Rico are combined systems that carry sewage from homes and businesses as well as rainwater collected from street drains. When they overflow during heavy rains, the rainwater mixes with sewage and results in raw sewage being directly discharged into water bodies. These discharges are called combined sewer overflows and can pose serious environmental and public health risks. EPA's report explains what Combined Sewer Overflows are, the human health and environmental effects of sewer overflows, the prevalence and location of CSOs in New York, New Jersey and Puerto Rico, and actions that are being implemented and can be taken to address the problem.
In February 2003, Region 2 of the United States Environmental Protection Agency (USEPA) issued a final decision in granting the Aguadilla treatment plant a section 301(h) waiver from the requirements of the federal Clean Water Act (CWA). This plant (and others in Puerto Rico) is allowed to discharge wastewater to the ocean after only "advanced primary treatment."
Also in February 2003, the U.S. Justice Department and the USEPA announced a settlement with the Puerto Rico Aqueduct and Sewer Authority (PRASA) regarding alleged releases of untreated sewage from 471 pump stations throughout the island. The agreement requires PRASA and the current operator of its aqueducts and sewers to complete construction and take other remedial actions to eliminate longstanding noncompliance at 185 sewage pump stations. PRASA must develop and implement a comprehensive plan for the operation and maintenance of its entire system of more than 600 pump stations and implement a spill response and cleanup plan.
In September 2005 the USEPA announced that Bacardi's rum plant in Catano, a suburb of San Juan, has been discharging polluted wastewater into the Atlantic Ocean for 2-1/2 years, in violation of the Clean Water Act. The discharge contains unacceptable levels of chemicals, including lead, copper and zinc. The EPA gave Bacardi 180 days to fix the problem.
In June 2006 PRASA entered into an agreement to plead guilty to an indictment charging 15 felony counts of violating the federal CWA through the illegal discharge of pollutants from nine sanitary wastewater treatment plants and five drinking water treatment plants. PRASA will pay $10 million in criminal and civil fines—the largest fine ever paid by a utility for violating the CWA. In addition, a comprehensive civil settlement was reached between PRASA and the USA resolving repeated environmental violations at 61 wastewater treatment plants throughout the Commonwealth. PRASA will spend $1.7 billion for capital improvement projects and other remedial measures at all of its 61 wastewater treatment plants and related collection systems over the next 15 years.
In November 2008 it was announced that Bacardi had paid a $550,000 fine to settle a complaint that its rum distillery in Puerto Rico released excessive pollution into the Atlantic Ocean. The Environmental Protection Agency (EPA) said the company also had agreed to donate and preserve an area of wetlands valued at $1 million. The EPA stated that the plant broke permitted limits over a six-year period for pollutants including lead, copper and oil. In some cases, the plant just outside San Juan was cited for not reporting the results of its own wastewater monitoring.
Nonpoint Source Pollution
Puerto Rico is one of 29 U.S. states and territories with special programs and responsibilities for protecting and managing important coastal resources. To address more specifically the impacts of nonpoint source pollution on coastal water quality, Congress enacted the Coastal Zone Act Reauthorization Amendments of 1990. Section 6217 of the Act requires that each state with an approved coastal zone management program (including Puerto Rico) develop a Coastal Nonpoint Pollution Control Program and submit it to EPA and the National Oceanic and Atmospheric Administration (NOAA) for approval. Each program must provide for the implementation of technical management measures (section 6217(g) measures) that address major categories of nonpoint sources that impair or threaten coastal waters nationally, including agricultural runoff; urban runoff; forestry runoff; marinas and recreational boating; and channelization and channel modification, dams, and streambank and shoreline erosion.
On February 8, 1999, Puerto Rico's governor signed an Executive Order (OE-1999-08) adopting the section 6217(g) management measures as official public policy throughout the Commonwealth of Puerto Rico. The order requires the creation of an Interagency Committee of lead Commonwealth agencies to uphold the mandate for the implementation of the section 6217(g) management measures and to ensure compliance with the measures for the major categories of nonpoint source pollution. The Committee is charged with developing and implementing a plan for the control of nonpoint sources of pollution throughout Puerto Rico, while adopting the section 6217(g) measures as "the official technical guidelines of the Plan."
The Committee is composed of representatives from various agencies in Puerto Rico, such as the Environmental Quality Board, the Department of Natural and Environmental Resources, the Regulations and Permits Administration, the Department of Agriculture, the Soil Conservation Districts, the Planning Board, the Agricultural Experiment Station and the Agricultural Extension Service, the Department of Health, the Department of Transportation and Public Works, the Highway and Transportation Authority, the Aqueduct and Sewer Authority, the Electric Power Authority, the Ports Authority, and any other government institution that the Committee identifies as essential to developing and implementing the plan.
The Executive Order calls for all Committee member agencies to adopt the 6217(g) measures and integrate them into their existing decision-making processes as soon as possible, but not later than 2 years from the effective date of the order. This requirement applies to direct agency activities and authorizations for other public and private activities. The order also lists several specific legal and administrative mechanisms that the Commonwealth agencies must use to demonstrate compliance with the measures. Finally, the order requires the Committee members to jointly develop and implement the "public policies, plans, programs, or organizational structures required" to ensure the effective implementation of the required management measures.
The Committee was deeply involved with the development of Puerto Rico's Coastal Nonpoint Pollution Control Program, which contains detailed 5-year plans and a 15-year strategy to implement the Executive Order. The Executive Order provides for adequate, enforceable policies and mechanisms to ensure implementation of the section 6217(g) management measures. As a result, on October 17, 2000, Puerto Rico received federal approval (from NOAA and EPA) for the Commonwealth's Coastal Nonpoint Pollution Control Program. The program is the first among U.S. island territories to receive full federal approval and the fourth overall after Maryland, Rhode Island, and California. Upon approval of its plan, Puerto Rico immediately began to implement the 6217(g) management measures in all public activities, including the granting of authorizations or permits for public or private actions.
The Committee coordinates implementation of CNP through monthly meetings and through the establishment of issue-specific working groups. The Committee also developed a nonpoint source pollution control plan for Puerto Rico that includes the CNP five-year implementation plan and 15-year program strategy. Puerto Rico’s CNP Interagency Committee is a strong example of many agencies with varied and sometimes overlapping jurisdictions successfully working together to address a complicated issue. Examples of the Committee’s CNP activities include: (1) promoting the adoption of a guidance document that specifies nonpoint source management measures in coastal waters as the CNP’s official technical guidance; and (2) conducting training and workshops on CNP issues such as planning and technical assistance, site selection and permitting, construction and inspection, and project management and monitoring. PRCMP’s CNP efforts included work to:
- Compile a list of nonpoint source pollution control activities throughout the commonwealth;
- Create a septic tank inventory;
- Develop best management practices and management measures; and
- Implement demonstration projects.
Water Quality Contact (Runoff and Outfalls)
| Raul Santini
Puerto Rico Department of Natural and Environmental Resources
Perception of Causes
According to the 2002 305(b) report, Puerto Rico has 5,394 stream/river miles, 3,843 estuary acres, 18 lakes, and 550 shoreline miles. Of 18 lakes/reservoirs assessed, all are impaired due to low dissolved oxygen, sedimentation, and high nutrient concentration, as evidenced by eutrophication. Out of 1,683 total lagoon acres, 554 support and 1,129 acres do not support designated uses. Ten percent of assessed river miles support designated uses (545 miles), while 21% (1,105 miles) are impaired for one or more designated uses. Fifty-eight percent (318 miles) of coastal waters support designated uses, while 4% (24) are impaired, and 38% (208) had insufficient data. All 23 acres of estuaries monitored failed to meet standards, while 25 acres were not monitored.
The 2009 CZM Program document states that 20% of coastal waters meet standards for all designated uses, 35.5% meet standards for some of the uses, 39.2% of the waters could not be evaluated due to lack of data, and 5.5% of the waters where standards are not met and development of a Total Maximum Daily Load (TMDL) will be required to reduce sources of pollution.
Puerto Rico's Adopt-a-Beach program is described in the following document (Spanish):
The issues of nonpoint source pollution, septic tank design and maintenance, providing training to homeowners, farmers, marina operators and local government officials are part of a program jointly conducted by more than 16 federal, commonwealth and local government agencies. Sustainable development and smart growth initiatives are an essential part of protection of environmental and natural resources. This is a complex endeavor that requires the sum of efforts from citizens, governments, NGOs, and academia.
Broader Coastal Education Efforts
Education is a very important component of the efforts to protect Puerto Rico’s coast, which accommodates multiple uses and activities that are critical to the island’s economic vitality. PRCMP’s environmental education efforts are designed to improve the general public’s awareness and understanding of coastal issues. Viewing environmental education as an inclusive and dynamic process, PRCMP has involved DNER’s education personnel, technical staff, members of the Ranger Corps and teachers in developing interactive education activities and distributing education materials.
PRCMP provides key programmatic and technical assistance to DNER’s four regional environmental educators located in San Juan, Mayaguez and Humacao. The regional environmental educators work with department biologists and rangers to identify regional environmental problems and to raise community awareness of the importance of coastal resources. Due to staffing limitations, the environmental educators emphasize interagency collaboration with partners such as the Puerto Rico Department of Education. For example, the two departments worked extensively together to include environmental education in ninth-grade students’ regular science curriculum. PRCMP also participated in a public hearing to support a legislative measure that would include environmental education as a regular course for all students in the first through twelfth grades. Additionally, the regional environmental educators have worked with community-based organizations such as the Young Rangers and Scuba Dogs.
Examples of environmental education activities that PRCMP helped support during the review period include:
- Science Fair and Environmental Coastal Workshop: The regional environmental educators, in coordination with the Puerto Rico Department of Education and private schools, attended school science fairs throughout the commonwealth. The educators gave presentations about the coastal zone, and they also evaluated relevant coastal projects. Students with the twenty best projects were invited to participate in the week-long Environmental Coastal Workshop.
- Coastal Season: The Coastal Season is held each fall and includes a variety of education activities such as beach clean-ups, restoration work and fishing tournaments. The regional environmental educators coordinate and develop activities in their regions, and other educators support and participate in the activities. For example, the regional environmental educators work closely with community and private organizations to participate actively in the International Clean-Up Day each September. Organizations such as Scuba Dogs and Industry and Commerce for Recycling assist by organizing clean-up activities focused on the coastal zone. Prior to and during the clean-up activity, the regional environmental educators offer informational sessions about coastal zone management.
- Marine Turtle Workshop: PRCMP held a Marine Turtle Workshop in the Mayaguez Region for science teachers, university students, environmental organizations and regional environmental educators. The objective of the workshop was to develop educational activities related to marine turtle conservation.
- Teachers’ Workshops: The program also held workshops for science teachers in the Puerto Rico Public Education System. Topics included public policy, coastal zone management and coastal resource conservation. The workshops were held in Mayaguez, Humacao and San Juan.
- Photography Workshops: The regional environmental educators organized photography workshops around specific geographic locations such as Mona Island. Staff used the photos as teaching tools and incorporated them into posters and calendars.
General Reference Documents
EPA has compiled several NPS (Nonpoint Source) Outreach Products that are a selection of television, radio, and print products on nonpoint source pollution that have been developed by various agencies and organizations around the country. They are good examples of outreach in the mass media. Also see What You Can Do.
NOAA, in partnership with the U.S. Environmental Protection Agency, International City/County Management Association and Rhode Island Sea Grant, will be releasing, in August 2009, a first-of-its kind interagency guide that adapts smart growth principles to the unique needs of coastal and waterfront communities. Smart Growth for Coastal and Waterfront Communities builds on existing smart growth principles to offer 10 coastal and waterfront-specific guidelines that help manage development while balancing environmental, economic, and quality of life issues.
USGS' Great Lakes Beach Science website has a nationwide database that contains greater than 1200 citations for publications directly and indirectly pertaining to recreational water quality intended for access by the general public and scientific community. It is a fully searchable, downloadable bibliography that has been categorized into major study topics.
- NRDC. Testing the Waters 2003, A Guide to Water Quality at Vacation Beaches. August 2003.
- NRDC. Testing the Waters 2003, A Guide to Water Quality at Vacation Beaches. August 2003.
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