No Music at the Beach

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TheNRDCNot too Iong after I became Environmental HealthDkector for Monroe County n1995,I received a phone callfrom someone representing the Natural Rsources DefenseCouncil (NRDC) inquiring if there rvas a beach *'atermonitoring progrart in the Keys. My answer was no and Iexplained that Florida had no requirements for beach watermonitoring in its lat'. Accordingly, there was no statefunding to support a testing Program and no regimen forzuch a program described by adminishative code. The phoneconversation u'as obviously relatively brief.After t'e hung up I was thinking about the issue. When

I began public health employment in 1982 with the sanitaryengineering section of the Duval County Health Departmenlour public swimming pool/bathing area inspectorsperiodically sampled Duval County beach water on localinitiative for a while. Within a year or th'o, during a budgetreduction exercise, the beach monibring program rtr'as acasualty since itrvas srrictly elective. Flash forrvard to thefuhrre. After I began to n'ork t'ith the State Health Office Ibecame arvare that Pinellas County had a long-standingbeach monitoring program. Nou', being not too long out ofheadquarters,I thoughtmy an'areness of the statds directionon beach testing !r'as current. Hon'ever, given the potentialfor publicity about the lack of beach monitoring in the Ke1's,I decided to phone program personnel in the State HealthOffice to advise them of the NRDC phone call and to re-affirm my information on state direction.

From the State Health Office, I learned that they havehad dialogue with the NRDC over beach monitoring for awhile and that the state's direction had notchanged. MoruoeCounty u'as not alone in the lack of a beach monitoring

program. My perceptionwas that from the state's (not justDOH, but state govemment from all levels) perspective, beachmonitoring is a local issue arrd if monitoring vt'ere desiredthe initiative rvould have to be local. At the time, other issuest'ere demanding my attention so I filed the beach n'aterquetion arvay in the back of my mind" Later, around the fallof the 1'gn1, NRDC released a report t}rey publish annuallyon the nationrvide stafus of beach monitoring. Florida lvasgenerally criticized for its rvidespread lack of beachmonitoring. The NRDC phone call n'as to become an annualevent and my ansn'er to their question'w'as the same.

In 192 the NRDC decided to spice up their annual reportwith an accompanying press release labeling some of themore prominent tourist destinations that had no beachmonitoring program as "beach bums". The Florida Keys,specifically Key West, had the dubious clistinction ofinclusion on their list Monroe County spends, and hasspent, several million dollars a year to advertise the Keys asa resort destination. As you may imagine, locals are l,erysensitive to any negalive national media that may becounterproductive to promotional efforts. The City of KeyWest decided to conduct bacteriological testing of tenIocations around the island to gain a snapshot of beach rt'atersafety. The tesults of the testing reportedly sholved noviolations for coliform bacEria. Local officials and politiciansn'ere happy to arurounce that the water teas as safe as theyhad aln'ays presumed it rt'as.ADbtantDrumbedt

lVater quality, and the deterioration thereoi inthe FloridaKeys has been a contentious issue for many years. The Stateof Florida declared parts of the ocean, gulf and baysurrounding theIGl,s as Outstanding Florida Waters in 1984.The Florida Deparhrent of Environmenhl Protection (DEP)

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has performed several rvater quality studies over the yearsand documented water quality deterioration. In 199O thefederal government reinforced staE ideals by establishingthe Florida Keys National Marine Sanchrary (NMS) n'hichincorporated previously existing NMS at Key Largo, LooeKey and the Dry Tortugas. Sanctuary status focuses federalexpertise on resource management and one distinct area rvaswater quality protection.

Under the auspices of the Marine Sanctuary, a WaterQuality Protection Steering Committee (WQI5C), consistingof stale agency heads or their delegates, federal agencyrepresenhtives and representatives of special inbrest groupsrvas fonned. The WQISC also had the services of a technicaladvisory committee (tAQ composed of university scientisb/researchers and staff level state and federal agencyrepresentatives. Theiob of the TAC rvas to evaluate technicalinformation and research data on Keys water qualityinformation and make recommendations to the WQPSC fortranslating the information into policy decisions.

In recent years, the United States EnvironmentalProtection Agency (EPA) had annually desoted researchftrnding to the Keys Marine Sanctuary to examine specificissues. Until 1992 virtually all water quality concems hadbeen focused on the effects of nutrients - nitrogen andphosphorous - on Keys u'aters and marine aquaticcommunities. That year, however, the guestion of biologicalcontaminanb emerged One of the research projects fundedthat year r.as to evaluate n'hether servage related pathogensu'ere detectable in canal systems and, if found, qualifyassociated healh risks. The University of South Florida (USF)was awarded the grant to conduct the research and Dr. |oanRose was the principal investigator,

Under the grant, USF had collected samples fromnineteen canal systems throughout the Keys from &e northemmost extremity to the southernnrost point in Key West.Conventional bacteriological rvater quality testing hasfocused on fecal coliform bacteria as the indicator of humansewage contamination. Florida's standard for fecal coliformis sufficientfor detecting moderate or worse contaminationevents. In recent years though, monitoring for fecal co[formhas been questioned as an adequate measure for protectingpublic health. The concern is particularly valid in marineenvironnrenb, which are hostile to the organisms. USF chosea sophisticated suite of biologkal analyses, including viralpathogens sudr as Hepatitis A, whichareconsiderably moreindicative of human waste contamination to fulfill therequiremenb of the canal health assessmenl

DaleGriffen, a doctoral candidate and research associateof Dr. Rose, appeared before the November 1998 meeting ofthe TAC to present the preliminary findings of dreir project"Seventy-seven percentof the samples they collecled shon'edevidence of viruses al,.rd/ or alternative bacterial indicatorssuch as enterococcus. USF's conclusion, greatly simplified,was that st'imming in canals in the Keys represented a

substantial health risk, particularlyfor the very young, elderly orimmuno-compromised individuals.Griffen proclaimed to print anclelectronic media covering the TAC meeting that he wouldnot swim in Keys canals based upon the information fromthe USF study. The presentatiory understandably, causedguite a stir.Seemingly, however, the ability to irrefutably describe

the extmtof health risks from findings such as those of USFremairu elusive. Until recent )ars, for lack of reliable viralanalytical methodology and as a reflection of cost, bacterialindicators have been traditionally used as surrogates toevaluate human health risks in aquatic and marineenvironments. Even with sub-speciation of bacteriologicalresults, room has remained to debate the origin of theorganisru as they apparently have been identified acrossspecies of n arm-blooded animals. In its simplest form, thatdebate can be characterized as, "What about the seagullsand other water fowl. Couldn't they be the source? Whataboutpeople walking their dogs on the beach?" As there area number of rather nasty. avian-borne diseases that humanscan contract from contact with bird rtaste, it's mystifyingthatcomJortwould bederived from theidea thatanimals arethe culprib- A line from lhe recentmoviq "AmericanBeauty'',seems apropos, "Never underestimate the porver of denial."

USF is on the forefront of identifying and institutinganalytical methodologies to overcome the shortfalls oftraditional water quality tests. The method by which theyidentified viral pathogens in the Keys canal study, againgreatly simplified, involves isolating genetic material fromthe specimen. The method will not, hon ever, answer a cmcialquestion - is the virus viable, i.e. capable of infection? Thatansn'er eidrer enhances or diminishes the significance of thefinding. It was also not clear, from the method, if the viruseswere recently deposited or had survived for an extendedperiod. According to USF, after a relatively short period oftinre, on the order of n'eeks, the genetic material cannot bedetected by the analysis they used. However, a different typeof test is able to establish viability and could be performed onisolates from the specimens.

EPA agreed to fund the viability characterization thatwas to be performed at the University of North Carolina.Isolates were sent and the winter of 1V)9 passed rvhile thetests n'ere being performed. Of all the water quality studiesthathavebeen done arguably, USF'smayhavehad the mostimpact on public opinion. It traruforrred the debaE over ttreimpacb of sewage disposal on Keys' waters from esoteric,abstract discussions of marine communities' Iow tolerancefor even the least extra nutrient input to expressions ofimmediate concern for the health of anyone swimming inKeys canals. It was the tip of an iceberg that would emergelater in the year.

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June 1999The WQIISC had a full steering committee meetingscheduled for May 1999 and one of the presenhtions wasthe status of the virus viability testing. Dale Griffm appearedon behalf of USF to present finditgs to date. A little morethan half of the specimens had undergone the viabittyanalysis and none of the viral material in those samplesshor,r'ed viability. Without all the resulb, the questionremained unanswered, at least definitively. USF offered anexplanation for the lack of viability based upon elevaHambient r*,ater temperafure at the time the original sampleswere taken in summer and early fall time frames. Higherwaer &mperahre is hostile to virus survival. USF proposedcollection of a lesser number of new specimens during thern'inter when ambient water temperaturs decline. The EPAagpeed and plans were made to collect more sanples in thewinter of 2000.

The WQPSC meeting occurred coincidental to a nationalmedia awareness initiative on beach rvater quality. A fuwweeks earlier, PresidentBillClinton had issued a presidentialdirective torvard enhancing national monitoring of beachrvater. The CBS affiliate in Miami was developing a storyand attended the WQPSC to obtain interviews. Almostalllocal print media were present The looming debate lvasactually a public policy issue. What should or shouldn't bedone with the research information from the USF study? Onone extreme, the suggestion of posting no swimmingwarninp ontheedges of everycanalsysbm in theKeys wasposed. The other extreme was simply disregard theinfornration altogether since no viable vinrses were identified.The departmenfs position, at the state level as rvell asMCHD, was that no reaction was indicated before all thedata was reported.

The controversy hadn't simmered very long before it rvaspushed aside by a clear cut, beach wahr contaminationepisode which was b begin a very long sum.urer for the Keys.The City of Key l{est had continued its beach watermonitoring progranr after the initial sampling event from flrcsurrmer of 1997. Initially, the planned sampling inbrvalwas quarterly. Their program was not long in place beforeHurricane Georges intemrpted it in September of 1998. Itwas resumed by late spring 1999 and the sampling intervalswere increased from quarterly to monthly on the secondTuesday of the month. Their fune monitoring event shon'edviolations of Florida's Class Itr marine recreational water,single day, fecal coliform standard of eight hundred coloniesper one hundred milliliters atmore than one public swimmingbeach. The City notified MCHD and we issued healthadvisories for the affecEd beadres. We also collrEd samplesfrom those beaches and otherlocations onKey Westto confirmtheir findingp. Our sample resulb reflected the City's and, inaddition, showed water quality violations at other locationsthey had not tested.

The summer of 7999 emergedwith seemingly more rainfall thanother recent summers. The daybefore MCHD collected its samplesto verify the City's findings there had been a deluge lastingfor a couple of hours. Through monitoring of its stormwateroudalls, DEP and the City were already aware there washeavy bacteriologicalcontamination finding is way into thestormrvater collection system. Until the contaminated beachsamples of |une 1999, the contamination of the storm \A'atercollection system had seemingly not affected publicswimming areas. The City was moving ahead withincremental rehabilitation of its sewer collection system inhopes of eliminating ediltration that could be at least onesource of the stormwater contamination. Because Key Westis an island with vigorous tidal exchange trvice per day,some assumptions *'ere made that if bacteriologicalcontamination was emitbd from sbrmwaEr ou$alls it lvouldbeprompdy dilubd, Mudrwas b beleamed over the zummerandfall of 1999.

When the beach water quality problems persisted in KeyWest over lhe sucrmer, the City Utilities Depa*ment initiahdextensive "tightness" evaluations of its storm andrvastewater collection systems to locate and abate majorconkibutions. As previously mmtioned, they were alreadyaware thatsome areas of the server collection system were indisrepair. After this exercise, it became apparent that loss ofpiping integrity was r,r,idespread. Much of the servagecollection systm was installed in the 193Us and 4ffs andquih a bit of it has never been replaced. The materials wereclay and iron pipe and have deteriorated.

When stormwatet and sewage collection systemsintersect, knownas conflicts, bday's construction standardsrequire measures to protect the sewage pipe so it doesn'tdischarge into the stormwater system. The City found thatin many of its conflicts, the sewage collecEon piping wasdamaged or destroyed. Key West was faced with a need toacceleraE widespread rehabilitation of its sewage collectionsystem. A successful refermdu.m was held in November1999 to secure bonding to finance the accelerated rmovationand projected time frams for completion are compressedfrom fiveto twoyeanr.

Even exteruive rehabilitation of the publicly ownedinfrastructure may not solve all the problems. Many of tJrestructures on Key West are very old and their private servagelaterals areof tlre same vintage as thecitr's collection system.The privab Iateral concem extends across tfte spectnrm fromcommercial operatioru to private residences. In the oldestareas of bwn, the location of laErals is not apparent at groundsurface. The lots are small, heavily vegetated and thesEucture covers mostof tlre properly. Evaluating the inbgdtyof private laterals will be an expensive and difficultundertaking but is a necessity for addeving a comprehensivesolution. Key West is moving toward a mandatory lateraltesting program but it is a politically difficult process.

Flot-ida lou:-nai of Envrrcnrnentai Health, t.larah 2O0O


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By November of 1999, rain was becoming scarce as isnormal for Fall in the Keys. The drier weather was reflectedin the sample results from the beaches. By Christmas, thelast health advisory for all beaches in Key West had beenlifted v/hen the state stardard was met. However, theunderlying problem, the state of disrepair of the Key Wesf ssewage infrastructure, was and is still there. By early Jaluary2000, even without rain, a fecal coliform violation wasdetected at the most prominent public beach on Key West.Once again, a thirty-day sampling regimen was begun. ByFebruary 2000, another beach had shown a violation. Thehealth advisory reprieve was short-lived.Fecal Coliform us. Enterococcrs

As mentioned earter, in a curious dichotomy, while DOHhas no regulatory requirements to monitor saltwater beaches,Dtr has regulatory standards for marine recreational watels.Those standards are found in Chapter 62-302.530 of theFlorida Administrative Code (F.A.C.). The standard isexpressed in levels of Fecal Coliform and Total Coliformcolonies per 100 milliliters of sample. Irt this instance, therewas no need to look at Total Coliform because the FecalCoMorm levels were clearly violatioru of the standard. DEPclassifies the wabrs of Florida dependant upon their intendeduse. Under this rule, waters intended for recreational usessuch as fishing and swimming are categorized as Class Itrand there is further distinction between marine and fresh. Inmarine waters, fecal cotform counts shall not exceed amonthly average of 200, nor exceed 400 in 10% of the samples,nor exceed 800 in any one day. Monthly averages shall beexpressed as geometric means based on a minimum of 10samples taken over a30-day period.

Using 62-302.530, F.A.C. as our guide, MCHD began theprocess of collecting the minimum ten samples per monthafter the ]une event. After the fust elevated levels weredeEcEd, we observed ftem diminish after a few days withoutheavy rainfall. Hov/ever, it seemed we could go no Iongerthan three or four days without rain and the bacterial levelsappeared to escalate within twenty-four hours of the rainfallevent. During each successive thirty-day period over thesummer and falf no beach could meet aII tfuee provisiors ofDEP's rule. Geometric means is a sthtistical analysismethodology that hims outlying data points so, frequenfly,the beaches met the averaging requirement of no more thantwo hundred colonies. However, none could comply withthe "no more than ten percent exceeding four hundred andno single day exceeding eight hundred" requirements.

In 1986, the EPA concluded that biological indicatorsother than fecal coliform ryere more representative of humanhealth risks from exposure to sewage contamination inswimming waters than fecal coliform. Particularly so inmarine waters whiclL as previously mentioned, are hostileto their survival. When the fecal coMorm problem persisted,the DOH Division of Environmental Health suggestedMCHD also include testing for Enterococcus, a fecalsheptococcus organism that EPA recommends for marine

rvaters to aid in distinguishinghuman waste contarrrination fromother sources. However, there wereobstacles. Driving out of the Keys =Tnto Miani is a three.hour prospect if all goes \l/elL Invariablytraffic will be tied up because of accidents or normalcongestion. The presendy approved laboratory methodologyfor fecal streptococcus in Florida requires forty-eight hoursto complete and the samples only have a six-hour holdingtime. There were no laboratories in the Keys that held statecertification for an Enterococcus method. The closest wasthe Miami branch DOH lab. To meet the holding time, ouronly option was to collect the samples arrd fly them bycommercial air carrier to Miarni and even that skategy ranholding times to the edge. Had the sampling sites been'upthe Keys', as we say, it wou-ld have been tactically impossibleto get the samples to the Miami lab.

Under EPA guidelines, based on a minimum of fivesamples over a monthly period, Enterococcus levels are ratedas GOOD = 0-34 colonies per 100 rrilliliters of marine water,MODERATE = 3!103 colonies per 100 milliliters of marinewater, or POOR: 104 or greater colonies per 100 milliliters.Enbrococcus Bt results for Key West beaches did not alwayscorrespond with fecal coliform levels. Sometimes there wouldbe correlation and other times there would be a fecal coliformviolation and only "GOOD" ranges of Enterococcus. Onother occasions, there would be very high levels ofEnterococcus yet no unacceptable levels of fecal coliform.For lack of corsisbnt correspondence between the indicators,MCHD chose to continue to base its public health advisoryactivities on the established Florida standard.

Even that choice led to conhoversy. The one Key Westbeach that had consistently shown no fecal coliformviolatiors was at Fort Zachary Taylor State Park. By August1999, there were two separate occasions y/hen theEnterococcus levels were greater than three hundred. AsMCHD had declared its health advisory program to be basedonly upon state standards, it seemed inappropriate to issuea health advisory based upon those sample resu1ts. StatePark Service management personnel were concerned overthe findings and made a very corscientious decision to posta notice for swimmers. DOH/MCHD collaborated with themto develop signage to explain the risks and the distinctionbetween the advisories in place at other Key West beaches.Testing at the Fort Zachaty Taylor beach was continued.There were no more poor Enterococcus results in thesucceeding two months and the notice signs were eventuallyremoved

Under a limited beach monitoring initiative in othercounties, the departnoent is attempting to advance the use ofEnterococcus as a beach monitoring tool. DOH maintains aweb site devoted to the project that you may access throughthe intranet or from the DOH home page atwww.doh.state.fl.us to visitto learn more about the Florida

fi*y' Floiida Jouinaioi Envirc|]meniel Heaitir, i"larch 2000


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proiect To leam more about the national program visit theEPA rveb site at http: / / www.epa. gov / 05T/ beaches.Up The Kqs

As the beach n ater problems in Key West lingered andnedia attention *'as given to the USF report, residenb inother parE of the Keys naturally began torvonder aboutwaterquality at their local sr,r'imming areas. Clearly, though therewere no categorical resources to support the expectation,MCHD had to respond to public concern. In collaborationwith DEP, Monroe County govemment shff, and affectedmunicipal govemmmt representatives, a listof fifteen beachsihs tuoughout the Keys were identified to be hsted. Becauseof the logistical difficulty in meeting the six-hour holdingtime with thewidely disbibuted sites, thesamples were onlyanalyzed for fecal coliform.

Tfuee of the sites showed single day violations of thestate standard. Health advisories n'ere issued for thoselocations and a thirty-day, ten sanple, regimen at the threesites was initiated to evaluate compliance *'ith the three foldcriteria from 62-302, f.A.C. One of the sites, a popular publicpark in the upper Keys, cleared within the first thirty-daycycle. The two other sites required tnro thirty-day cycles tomeet all three provisiors of the rule. The most persistentlycontaminated site is a relatively pristine natural area andthe source of the fecal contamination was not readilyapparent

The extensive need for beach monitoring tfuoughout theKeys was becoming very apparent However, the drain onstaff time and fiscal resources was becoming enormous.Especially rvhen beach sites shorved violations of the statestandard and had to be re'visited over the ensuing thirtyday,s to achieve compliance.

TheEPAGrantCongressman Peter Deubch's office prevailed uponEPA's Region IV Office for funding assistance to addressbeach lraher quality monitoring in the Keys. ffA respondedaffirmatively by identifying twenty thousand dollars to bemade available by grant to support the activity. As RegionIV had already established liaison rvith the DOH Bureau ofFacilities Programs on the Florida proi'ct, they had a nahrralconduit for developing the terns of the grant The amount offunding would allorv MCHD to sample fifteen beaches everyother rveek for about six months. The deparknent anticipatedsubmitting a legislative budget request (LBR) for state*'idebeach testing for the 2000 legislative session and this grantrvould support Keys beach testing while the fate of the LBRwas determined. By early fall otl999, the grantwas writbn;horvever, once again there were obstacles to immediateimplementation"

One of the primary conditions of the grant was that onlyEnterococcus analysis could be used. As mentioned earlier.because of drive times in the Keys, it would be logisticallyimpossible to collect all fifteen samples, transport them to

the Ivliami DOH branch laboratoryand meet the holding time, IEnterococcus certification had to bedeveloped locally for the program toadvance. A private laboratory in the lower Keys decided toobtain the necessary certification. They began the process inthe fall of 1999 and only recently successfuIlycompleted it.

The fifteen sites to be monitored under the grant had tobe formally established and that rvould again require acollaborative effort similar to that of the summer of 1999. Bythe end of February 2000, those sites were determined andthe testing program began in early lvfarch. Nothing everseems to be simple in the Keys.A hedicmte Beach Aosure Mo del

As mentioned earlier, Key West beaches are evidentlyvulnerable to contamination on any given day until thesewage and stormwater collection system issues are solved.Atthe sametime, the sampling programhas been extensiveenough to document that there may be stretches of days orrveeks when thebeachwater dos meetstahestandards butahealth advisory is in effect based upon a single day violation.In addition, there is an inherentweakness in using laboratoryanalysis to monitor beach rvater quality since the results arenot available for, at minimum, tn'enty-four hours aftersampling. Water quality will have fikely changed before theresults are available and anyone sn'imming the day theunsatisfactory sample was collected has been exposed.

The City of Key West has proposed developing a modelfor predictive beach closure urilizing factors that have beenassociad withbeach rrabr contamination episodes. Clearlyrainfall has played a maior role in the summer of 1999 but itseems there wereother mitigating factors as there was not aperfect correlation betn'een rainfall and every beach waterviolation Factors such as rvind direction, tidal phase, sewagecollection system &'et $'ell levels that reflect surcharge state,and, perhaps, water temperahrre appear to have influenceas n'ell Data for some of these elements are readily available.Key Westproposes to have correlations betw'een the differertfactors statistically analyzed with the objective of arriving atan acceptable predictive beach closure model that rvoulddisplace sampling as the beach water monitoring tool.

After an occurrence of anv higger deemed significant,signage already in place would be activated to warnsn"immers of the danger. The warning rt'ould remain in placefor as long as seventy-ht'o horus to ensure that the conditionhad subsided. It would be extended if any of the triggersoccurred during the seventy-trr-o hours. When the model isfirst implemmted, Enterococcus sampling would be initiatedforty-eight hours before the expiration of any seventy-hvohour waming period to affirm u'ater quality safety. At thispoint, the proposal is in development If the model can bedeveloped, it may offer a more protective public healthmeasure than sampling. Only time q'ill tell.

FL:rida ]curnal of Envir-onrnentai Health, March 2000


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Conchsion and AcknowledgemensThe MCHD beach water testing program has been a whirlwind experience. We have receivedoutstanding laboratory support from the DEP branch office laboratory in Marathon and from DOHlaboratories - both the main lab inJacksonville and the branch lab in Miami. On three separah occasions,DOH main lab employees analyzed samples in the Keys with portable Iab equipment they shipped down. The DOH Bureau ofIacilities Prograrns and Division of Environmental Health has always been available for corsu.ltation on tough decisions.MCHD staff has risen to the occasion by adding the beach sampling to an already tight schedule.

Florida stands at an important crossroads with regards to beach water safety as we move into the year 2000. DOH hasursuccessfully submitted LBRs to support statewide beach warcr testing for the past two consecutive legislative sessions. At$600,000, the budget request is monetarily small and is spread over three years. The amount is only adequate for minimalmonitoring. Hopefully, the third try will be the charm.

Florida's ocean and beaches are a large part of the attraction for visitors and residents. In a state with tens of millions ofresidents and whose economy is as heavily tourist dependant as Florida's, it would seem imperative that resident and visitorsafety would be a premiere concem. AII the people who enjoy a dip in the surf do so presuming that it will not endanger theirhealth. They might be surprised to Ieam that the larger majority of beach water is not monitored.

About the Author:Jack Teague hasbeen the Environmenral Admini$rator for the Monroe Count-y- Health Department since 1995. He

began his car eer in Environmental Health in 1982 i,,ith the Duval Countv Health Departnent Environmental Engineeringsection. ln 1986, he moved to Tallahasee to w'ork in Env'ironmentalHealth Programs r,vithin the State Health Office. Hecompleted the Pre-Veterinary Medicine Program at Aubum University leading to a B.A. Jack has previously authoredarticles for the FEHA Joumal and feature magazines. hesently he is u",orking on a non-fiction book about his erperiencesas Environmental Administrator for dre health department in the Keys. The Ke)E beach w?ter experience of 1 999 r','iil beone chapter.

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Florida lournal of Environmental Health, lvlarch 2000

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