UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF THE
REGIONAL ADMINISTRATOR
REGION 5
230 S. DEARBORN STREET
CHICAGO, ILLINOIS 60604
EPA-905/2-77-003
JUNE 1977
Do not WEED. This document
should be retained in the EPA
Region 5 Library Collection.
DETERGENT PHOSPHATE BAN
POSITION PAPER PREPARED BY
THE REGION V PHOSPHORUS COMMITTEE
-------
Document is available to the public through
the National Technical Information Service,
Springfield, Virginia 22151.
-------
CORRECTION
Paragraph 5. on page 55 is misplaced, it should be inserted on
page 56 right above TABLE A-2.
DETERGENT PHOSPHATE BAN
U.S. EPA, Region V, Position Paper Prepared by the
Region V Phosphorus Committee
George R. Alexander, Jr., Regional Administrator
Donald A. Wallgren, Committee Chairman
JUNE 1977
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CONTENTS
PAGE
Introduction 1
Chapter I Summary and Recommendations 4
Chapter II Background of Phosphorus Control Policy 6
Chapter III Advantages and Disadvantages of a Phosphorus Ban 29
Chapter IV Feasibility of a Detergent Phosphate Ban 57
Acknowledgements 62
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INTRODUCTION
Region V of the U.S. Environmental Protection Agency now advocates
that States in the Great Lakes Basin that have not already done so, give
urgent consideration to the adoption of a ban on phosphorus in detergents.
This position is a departure from the EPA policy on phosphorus con-
trol from 1971 to the present. The policy was to rely on chemical treatment
to reduce phosphorus levels in municipal sewage and industrial wastes dis-
charged into waterways. Because this policy has failed to achieve the water
quality goal of sufficiently decreasing and stabilizing rates of eutrophication
in both inland lakes and the Great Lakes, not only Region V of EPA, but State
governments and other regional and international agencies have recently been
reconsidering the need and means of reducing phosphorus loadings. No other
single factor is so important for the future water quality of the Great Lakes
Region.
Through the 1960s both scientists and the general public became increas-
ingly concerned about eutrophication in many waterways, especially lakes. The
evidence of rapid eutrophication was the heavy growths of algae that appeared
in most small lakes, in the western basin of Lake Erie, and in harbors and
inshore waters of Lakes Michigan and Ontario. There were more and more frequent
algae "blooms" that made water murky and smelly, piled slimy masses of decaying
vegetation on beaches, and even caused massive fish kills due to oxygen de-
pletion as the water plants decomposed.
While the public protested the immediate and unpleasant consequences of
the acceleration of eutrophication that interfered with recreation and drinking
water supplies, the scientists were most concerned about the impact on future
water quality. They warned that fundamental, probably irreversible, changes
in the natural biological systems were being caused by man's contributions
to the nutrient levels in fresh water lakes.
Though there was no doubt that the rising levels of nutrients essential
for algae growth were due to concentrations of man-made wastes, limnologists
still debated for a time which nutrient was the limiting factor whose control
could prevent the overloading of the natural ability of the lakes to renew
and maintain themselves. By 1971, phosphorus was established as the limiting
nutrient for all of the Great Lakes and most of the inland lakes of the
region. It was clear, therefore, that decreasing and stabilizing rates
of eutrophication depended on limiting phosphorus loadings to the waterways.
Although it is recognized that land runoff is a source of phosphorus
from both chemical fertilizers and natural organic matter, attention centered
on the fact that phosphorus loading from point sources had greatly increased
with the use of phosphate detergents for both industrial and domestic purposes.
The debate about how to keep phosphorus out of the lakes focused on setting and
achieving low enough effluent limits for this element.
-1-
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Under the Great Lakes Water Quality Agreement of 1972, Canada and
the United States, agreed on the necessity for a 1 mg/1 limit for phos-
phorus for all municipal treatment plants which discharge more than one
million gallons a day. This limit was the basis for loading requirements
for the lower Great Lakes. But the two countries took different routes
toward achieving the effluent limit. The Canadian government chose to
reduce phosphorus discharges both by treatment and by limiting the phos-
phate content of detergents.
Because of doubts about possible threats to human health of nitri-
lotracetic acid (NTA), the chemical which detergent manufacturers had been
developing as a potential substitute for phosphorus, the Federal government
of the United States elected in 1971 to depend on removal of phosphorus in .
the treatment of sewage. Experience in Canada, which continued to allow use
of NTA, has not confirmed its danger as a carcinogen when used in household
detergents. Meanwhile, other substitutes have been successfully used where
phosphate bans have been adopted in this country. Several other factors have
also caused Region V EPA, which is responsible for the administration of the
United States Great Lakes programs, to conclude that it is now necessary to
seek removal of phosphates from detergents as well as removal by chemical
treatment of sewage and control of nonpoint sources such as land runoff. The
following chapters explain why Region V now concludes that banning of phos-
phates from detergents is not only feasible but essential for both environ-
mental and economic reasons.
The International Joint Commission held its annual meeting in Windsor,
Ontario, in July 1976. There the Water Quality Board of the IJC, which had
been established under the Agreement, submitted its 1975 annual report on pro-
gress toward achieving the objectives. The report, with its four appendices,
stressed that, while eutrophication may have slowed somewhat in some places,
overall its acceleration beyond natural rates remains a threat to the Great
Lakes. The urgency of reducing eutrophication is certain to be a central
issue as the required fifth year review of the Agreement continues in 1977.
The extent of extreme eutrophication in inland lakes had already been con-
firmed by EPA's National Eutrophication Survey begun in 1972.
The Water Quality Board report emphasized several factors that had not
been appreciated at the time of the original agreement when EPA adopted its
policy of dependence on removal of phosphorus by treatment. One factor is
that it has now been established that a significant percent of the phosphorus
loadings of the lakes is input from the atmosphere. Another is that the tri-
butary loads appear to have been underestimated. Still another is that less
has been achieved with the 1 mg/1 effluent limit than was hoped for. This is
due not only to the delay in completion of some major treatment facilities,
Detroit being a prime example, but to the unreliability of phosphorus removal
in some facilities which have been brought on line.
-2-
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The report makes the point that not only is there better understanding
now of the present sources of phosphorus loadings, but also a better ability
to forcast long term consequences. Several mathematical models have been
developed which purport to show that, even if the 1 mg/1 effluent limit is
achieved consistently at all possible places, the phosphorus loadings to the
lakes will still remain so high that eutrophication rates will not be stabi-
lized.
For all these reasons the IJC is now considering whether the effluent
limit will have to be lowered to perhaps as little as 0.1 mg/1 and should be
extended to all municipal plants. As an immediate measure, the report urged
adoption of uniform 0.5 percent limit for phosphorus by weight for all
detergents manufactured for use in the Great Lakes basin.
In considering what to do in the face of these long term predictions on
eutrophication, the Water Quality Board report considered not only the
experience with treatment but also the experience with phosphorus bans. Not-
withstanding, the national policy, the State of Indiana had adopted a
phosphorus ban in 1971 with dramatic and fast improvement for both inland
lakes and rivers. The City of Chicago had adopted a ban which the Metropolitan
Sanitary District of Greater Chicago estimates that it would cost several mil-
lion dollars a year in treatment to effect an equivalent reduction in phos-
phorus. In these locations as well as in the State of New York and in the City
of Akron in Ohio, initial consumer resistance to nonphosphate detergents has
faded away almost completely. Finally, the rising share of the total detergent
market for nonphosphate products throughout the region is evidence of consumer
acceptance, though it cannot be known how much the choice of nonphosphate
products is related to concern about environmental problems associated with
phosphate detergents. For all these reasons, the Water Quality Board
recommended that the IJC consider supporting a ban on phosphates in detergents.
Since the Windsor meeting, the IJC has endorsed and submitted the Water
Quality Board report to both governments. Recently the phosphorus ban was
unanimously endorsed by the Great Lakes Basin Commission. Minnesota has
adopted a ban presently being challenged in court which was to go into effect
on January 1, 1977. The issue is before the Michigan legislature and the Natural
Resources Commission. The issue is being raised in Wisconsin and will soon be
raised in Ohio.
-3-
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Chapter I. Summary and Recommendations
A. Executive Summary
It is essential that resolute and prudent steps be taken immediately
to reduce the rate of euhophication of lake waters and streams in the Great
Lakes Basin. Some accelerated irreparable changes take place each day where
phosphorus loadings exceed the levels that trigger more rapid eutrophication.
EPA and its predecessors have worked for more than a decade to reduce effuent
levels of phosphorus from municipal point sources in the Great Lakes Basin,
but with limited success. The United States has been unable to meet the
target loadings set in the 1972 Water Quality Agreement with Canada. Recent
studies question whether even these levels will be sufficient to achieve and
maintain desired water quality in the Great Lakes.
Reducing the nutrient input is the soundest preventative and resto-
rative measure toward reducing rates of eutrophication. Every nutrient source
must eventually be examined for control possibilities, but first attention must
be directed to sources that can be controlled now. The urgency of controlling
at least some sources of the limiting nutrient phosphorus is the basis for the
present intense concern with detergent phosphate bans in the Great Lakes basin.
With present technology, the only readily controllable source of phos-
phorus input to the environment is sewage effuent. It has not been possible to
depend on sewage treatment alone in the Great Lakes Basin for two reasons.
Some plants have not attained consistently reliable phosphorus removal. In
other cases, phophorus removal equipment cannot be installed where it is needed
because of lack of funds or the lack of a municipal sewerage system.
Other sources that cannot be as readily controlled are (1) agricultural
runoff, (2) atmospheric deposition, (3) urban runoff through stormwater and other
bypass situations, (4) nonpoint sources like shoreline erosion, mining, con-
struction, and silviculture, and (5) and anoxic regeneration from sediments.
While greater curtailment of input of phosphorus from sewage effluent is being
sought, other sources must be investigated if the water quality desired for lakes
and streams in the Great Lakes Basin is to be obtained.
B. Region V Recommendations
Region V, EPA, supports the recommendations of the Great Lakes Water
Quality Board of the International Joint Commission and the IJC's confirming
recommendations to the governments of the United States and Canada. The ap-
pendix at the end of this chapter will briefly describe the mechanisms estab-
lished under the Water Quality Agreement by which these recommendations are
developed. The.IJC findings and recommendations are as"follows:
1) The present U.S. policy of treatment for phosphorus has not been
effective in reducing phosphorus input to Lake Erie and Lake
Ontario.
2) Detroit and Cleveland as well as other major metropolitan cities
must act quickly to reduce their discharges of phosphorus.
-4-
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3) The Upper Great Lakes, including Lake Superior, Lake Huron and
Lake Michigan must be protected from potential water quality
degradation due to accelerated eutrophication associated with
high phosphorus levels.
It is hoped that all of the Great Lakes States will consider adoption
of a ban on phosphates in detergents. Region V, EPA, will provide technical
assistance and expertise on this issue to all regulatory and legislative
agencies in the States. Region V will also assist in informing the general
public about the reasons for this proposal, including its costs to consumers
as well as benefits to the environment. These matters are discussed in
detail in the following chapters.
Appendix Mechanisms Established Under the Great Lakes Water Quality
Agreement Through Which the IJC Develops its Recommendations
The U.S./Canada Agreement on Great Lakes Water Quality of 1972 was
signed by both governments on the basis of the premise that the governments
adopt common water quality objectives. The best means of meeting this com-
mitment was identified as the implementation of cooperative programs toward
the goal of achieving improved water quality in the Great Lakes.
Eutrophication was one of the key problems identified by earlier IJC
studies on the Great Lakes. This problem resulted in the identification of
phosphorus as one of the specific water quality objectives of the Agreement,
although no specific number was set. The Agreement, did however, go on to
highlight phosphorus in Annex 2, which includes an effluent limitation and a
load allocation for phosphorus to the Great Lakes.
It is important to understand the mechanisms by which the IJC, through
its investigative and recommendatory functions, places Great Lakes' water
quality issues before the governments.
The Agreement assigned specific responsibilities, functions and powers
to the IJC and provided for joint institutions to support it. The principal
institution is the Water Quality Board, although a Research Advisory Board,
an Upper Lakes Reference Group and a Pollution from Land Use Activities Refer-
ence Group were established as well.
The Agreement calls for the Water Quality Board to focus its own
investigative and recommendatory functions, through an intense and con-
tinuing assessment, on the strength and quality of the U.S. and Canada pro-
grams being implemented to meet the Agreement. Thus, the Water Quality Board
provides an overview to the IJC of all of the pollution related activities
on the Great Lakes.
The Water Quality Board consists of one federal member from U.S. EPA
as Co-Chairman, and includes membership from all eight Great Lakes States.
U.S. membership is matched by an equal number of Canadians from federal and
provincial levels. The principal subordinate units of the Water Quality
Board are the Implementation Committee and the four subcommittees on
Surveillance, Remedial Programs, Water Quality Objectives and Radioactivity.
The Board is required to prepare an annual report to the IJC on water quality
in the Great Lakes, utilizing the broad range of expertise available from
the joint governments who hold membership on the committees. The IJC then
prepares its own report to the respective governments, reflecting the sub-
stance if not the letter of the Board's report. The governments can then
implement (or ignore) these recommendations. If the recommendations are be-
yond the scope of existing legislation, the governments can seek legislation
to carry the recommendations out.
-5-
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Chapter II. Background of Phosphorus Control Policy
A. LIMITING NUTRIENT CONCEPT
Control of eutrophication depends on the limiting nutrient concept.
This concept is based on Leibig's Law of the Minimum that "growth is limited
by the substance that is present in minimal quantity in respect to the needs
of the organism." While physical factors such as light penetration and
temperature and chemical factors such as toxicity may limit growth in surface
waters unaffected by human activity, phosphorus is normally the nutrient that
limits algae production.
B. REDUCTION OF PHOSPHORUS LOADINGS
Phosphorus as phosphate is essential for plant nutrition. In excess of
a critical concentration, phosphates stimulate plant growths. During the
past 30 years, standing crops of aquatic plants have increased enough to inter-
fere with water uses and become nuisances to man. Such phenomena are associated
with accelerated eutrophication, or aging of waters. It is recognized that phos-
phorus is not the sole cause of eutrophication but there is substantial evidence
tfhat generally it is naturally present in the least amount relative to need.
Therefore, an increase in phosphorus allows use of other nutrients already present
for plant growth. If other elements such as silicon are depleted, a shift in algal
species will occur. Often blooms of nuisance bluegreen algae will develop. Of all
of the elements required for plant growth in the water environment, phosphorus is
the most easily controlled by man.
Table 2-1 From Vallentyne, illustrates this point:
Table 2-1 Comparison of Various Plants Nutrients in Respect to (A)
Whether They are Ever Growth-Controlling in Lakes and (B)
Whether They are Controllable by Man. Elements Listed in
Order of Increasing Atomic Weight. Note that Phosphorus
is the Only Element Meeting Both Requirements.
Nutrient
Nutrient
Hydrogen
Boron
Carbon
Nitrogen
Oxygen
Sodium
Magnesium
Aluminum
Silicon
Phosphorus
Sulphur
no
no
rarely
yes
no
no
no
no
yes**
yes
rarely
no
no
no
partly
no
no
no
no
no
yes
no
Chlorine
Potassium
Calcium
Manganese
Iron
Cobalt
Copper
Zinc
Molybdenuitf
Iodine
no
no
no
sometimes
sometimes
rarely
no
no
sometimes
no
no
no
no
no
no
no
no
no
no
no
*Vallentyne J.R. 1970, Phosphorus and the control of eutrophication.
Res. & Development 3: 36-43, 49.
**Diatoms only
Canadian
-6-
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Evidence indicates that: (1) high phosphorus concentrations are associated
with accelerated eutrophication of waters, when other growth promoting facts are
present; (2) aquatic plant problems develop in reservoirs and other standing
waters at phosphorus values lower than those critical in flowing streams; (3)
reservoirs and lakes collect phosphates from influent streams and store a portion
of them within consolidated sediments, thus serving as a phosphate sink; and, (4)
phosphorus concentrations critical to noxious plant growth vary, and nuisance
growths may result from a particular concentration of phosphate in one geographical
area but not in another. The amount or percentage of inflowing nutrients that may
be retained by a lake or reservoir varies with: (1) the detention time within the
lake basin or the time available for biological activities; (2) the extent of bio-
logical activities; (3) the volume of the euphotic zone; (4) the nutrient loading
to the lake or reservoir; and (5) the rate of discharge from the lake or from the
reservoir.*
Phosphates enter waterways from several different sources. The human body
excretes about one pound per year of phosphorus expressed as "P". Current use of
phosphate detergents and other domestic phosphates increases the per capita con-
tribution to about 2 1/2-3 pounds per year of phosphorus as P. The major
phosphorus ingredient from detergents is soluble tripolyphosphate which is readily
available for biological activities. This increases its significance relative to
its percentage of total phosphorus. Some industries have wastewaters high in
phosphates. Crop, forest, idle, and urban land contribute varying amounts of
phosphorus from diffuse sources by drainage into watercourses. This drainage may
be surface runoff of rainfall, or effluent from tile lines. Shoreline erosion,
anoxic regeneration from sediments, tree leaves, and fallout from the atmosphere all
are contributing sources.
Once nutrients are available within the aquatic ecosystem, their removal is
tedious and expensive. Phosphates used by algae and higher aquatic plants may be
stored in excess of use within the plant cell. With decomposition of the plant
cell, some phosphorus may be released immediately through bacterial action for
recycling within the biotic community, while the remainder may be deposited with
sediments. Much of the phosphorus that becomes combined with the consolidated
sediments within the lake bottom is bound permanently and will not be recycled
into the system. However, sediments can act as a reservoir of phosphorus should
widespread anoxic conditions develop.
LAKE ENRICHMENT
The response of lake systems to nutrient loadings or different rates of
enrichment depends on the depth, flushing time, surface area, and bottom sediment
type of the lake. The response of aquatic plants to enrichment determines the
trophic nature of the lake which is the basis for lake classification as
oligotrophic, mesotrophic, or eutrophic. Figure 2-1** shows in general terms the
relationship between trophic state and water quality conditions. Figures 2-2**
and 2-3** show the chlorophyll oi and the total phosphorus concentrations, respec-
tively, of selected areas of the Great Lakes System.
* 1976 Quality Criteria for Water -- U.S. EPA — Washington, D.C. 20460, Pre-
publication Copy, p353-359; Substantial material for this and following two
paragraphs was drawn from this source.
** 1976 IJC Upper Lakes Reference Group. The waters of Lake Huron and Lake
Superior, Volume I, Summary and Recommendations, pg 128, 112, & 129.
-7-
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10
15 20
Phosphorus ugljf,
25 30
40
10
Chlorophyll a
15 20
25
30
024 68 10
Yearly Primary Production g Carbon/m2-a
A 2 3 A .5 .6
Optical Transparency %/m
I
I
i
K
\
UJ
10
20 40
Secchi Depth ?o/m
Water Supply Problems Taste and Odor-Filter Clogging
Phytoplankton Species Change
Zooplankton Species Change
&&&&&8£S^&£&£8£^
SSSSo8£S5H5JiSS8B5BoSiSfil3cBC3SoSoo
-------
15
!
0
Eutrophic
Mesotrophic
2.0
36
WJJJ88
O/igotmphicB,
17
12
Level after
Planned Programs
1.4
Duluth Open Lake North Georgian Northern Saginaw Southern Western Central Eastern Lake
Area Lake Michigan Channel Bay Lake Bay Lake Lake Lake Lake Ontario
Superior ' "
Huron
Huron Erie
Erie
Erie
FIGURE: 2-2, TROPHIC STATUS OF THE GREAT LAKES BASED ON CHLOROPHYLL a
-------
o
50
45
40
^ 35
S 30
3 25
o *.o
a
8 20
£
1 15
H 10
5
0
Winter
Summer =
Superior Michigan Georgian
Bay
Huron
Erie
(West)
Erie
(Central
Erie
(East)
FIGURE 2-3 TOTAL PHOSPHORUS CONCENTRATIONS
IN THE OPEN WATERS OF THE GREAT LAKES
Ontario
-------
Since enrichment takes place at specific shore locations - either cultural
point sources (and regions) or tributary mouths - and since there is a dilution
effect as one moves further from the source, the impact varies with location in
a lake. It is most severe in embayments or harbors. Time scales of reaction to
changes in enrichment rates also vary. Nearshore or embayment areas in the Great
Lakes already show impact from the increased enrichment (inflow concentrations of
total phosphorus exceeding 30 to 40 mg/1) of recent years. Only subtle changes
can be detected in the open waters of the lakes where changes are both smaller and
longer in developing, though equally significant. A key factor influencing 'the
trophic state of a lake is the rate of supply of phosphorus to that lake. All
phosphorus sources are implicated in the nutrient supply of a well-mixed system.
The nearshore-offshore exchange processes are inadequately understood and
in-depth study is required if man is to manage the Great Lakes. Without thorough
understanding of these exchange phenomena, very careful conservative management
which would not lead to degradation of this high quality water resource is essen-
tial.
GREAT LAKES SITUATIONS AND CURRENT TARGET LOADINGS
LAKE SUPERIOR *
Lake Superior is oligotrophic (Figure 2-4) with chlorophyll levels of
1 ug/1 levels (Figure 2-2) and total phosphorus concentrations of 3-5 ug/1
(Figure 2-3). In order to maintain present water quality and taking into account
that the lake is not in equilibrium with present loadings, the calculated loading
must not exceed 3900 t/a to prevent accelerated eutrophication. Table 2-2
summarizes the present and projected loadings of phosphorus to Lake Superior.
Present loading from point sources is only 15% of the total.
The planned reductions of 200 t/a will come close to maintaining the present
water quality of Lake Superior. In order to achieve the objective of 3900 t/a
and with future development, it will be necessary to install maximum phosphorus
controls at all municipal and industrial sources. Additional control can be
achieved through reductions of phosphorus in detergents (P-Ban) and by reducing
nonpoint source inputs. The maximum estimate of possible reductions with a P-Ban
is 60 t/a (see table 2-3).
The Duluth-Superior Harbor exhibits definite signs of enrichment. In
addition, there is nutrient buildup in local areas at Munising, Marquette, and
Thunder Bay. Adequate treatment and phosphorus removal will alleviate this
water quality degradation; facilities are being installed for the three U.S.
areas.
Op. Cit. - The Waters of Lake Huron and Lake Superior, p 137
-11-
-------
I,,. 11.1, tj
-I—1_
.. ll
>*
a.
s
o
5
a:
z
UL)
CJ
g
O
u.
z
UJ
3
or
UJ
^
lOO-
tO-
MICHIGAN
NORTH CHANNEL
•
,-
• HURON « WHOLE*
HURON >MAIN LAKt *
suf'l
GEORGlAN 8AY
•f PROJECTION TO 2020 (BASE SCENARIOS
— . AFIER SCHEDULED REDUCTIONS
-1 1 1 r—r-
"'''"!
100
rr-r-
I 10
WATER RENEWAL TIME (YEARS)
FIGURE 2-4 TROPHIC STATUS OF THE GREAT LAKES
-------
Table 2-2 PHOSPHORUS LOADINGS [METRIC TONS/ANNUM]
Source
Superior^
1974 Scheduled
Huron^
1974 Scheduled
Erie-*
1974 Recommended
Ontario7 Michigan
1974 Scheduled- 1974 Recommende
Outflow From
Other Lakes
Atmospheric
Shoreline
Erosion
Municipal
^Direct
coj
Indirect
Industrial
Direct
Indirect
^onpoint Source
(land run off in
basin)
(\noxic Regeneration
— — — -. — —
800 800
280 280
480 280
132
348
120 120
99
21
2460 2460
/11/in in/in
863 863
450 450
_-
1014 314
70
944
70 70
67
3
1323 1323
__
2334 2334 6680 6680
5604 5604 3504 3504 10009 10009
--
8442 -J3638
6529 / 1908
1913/
120
0
8711 6553 3711 -
- 291610
„ 2276 1088
182812
4511
4511
31 3912
2100$ 21005
-------
Table 2-2
1. 1976 IJC Upper Lakes Reference Group Volume I - The Waters of Lake Huron and Lake Superior -
Summary and Recommendations, pp. 54 and 138
2. 1976 IJC Upper Lakes Reference Group Volume I - The Waters of Lake Huron and Lake Superior -
Summary and Recommendations, pp. 52 and 133
3. . Lake Erie Wastewater Management Study - Preliminary Feasibility Report Volume 1 Main
Report pp. 57 and 157
4. 1975 IJC Great Lakes Water Quality Board Appendix B - Surveillance Subcommittee Report p. 107
5. 1975 IJC Great Lakes Water Quality Board Appendix B - Surveillance Subcommittee Report p. 69
6. Does not include atmospheric and anoxic regeneration
7. 1975 UC Great Lakes Water Quality Board Appendix B - Surveillance Subcommittee Report p. 209
8. Does not include atmospheric
9- !976 Murphy T.J., and Doskey P.V. 'Inputs of Phosphorus from Precipitation to Lake Michigan1
International Association for Great Lakes Research Journal of Great Lakes Research Vol 2 No 1 p 60
10. 1974 IJC Great Lakes Water Quality Board Appendix C - Remedial Program Subcommittee - Table 18 p72
11. 1974 IJC Great Lakes Water Quality Board Appendix C - Remedial Program Subcommittee Report-Table 6 p60
12. By computation - See references in 10 and 11.
13. 1973 IJC Great Lakes Water Quality Board Annual Report - Table 13 p89 (does not include atmospheric)
-------
Superior
Huron
Eric
Ontario
I.
Phos
I
12
90
Michigan
1
a.
).
4.
5.
6.
UC, Uppc
UC , Uppe
1972 Grea
Corps of
Plan S. V
1972 Crea
UC, Wate
Lai..
Lai
Uk.
n9ln,
1. 1
Laki
Qua
». Hi );55
-------
LAKE HURON (MAIN LAKE) *
The Lake Huron Basin contains three distinct water bodies: the North Channel,
Georgian Bay, and Lake Huron proper. These different bodies act semi-independently
and are therefore discussed separately. ,
The trophic state of Lake Huron can be expressed in terms of total phosphorus
loading and the volume and water renewal time for that lake. For Lake Huron proper,
exclusive of Georgian Bay and the North Channel, this can be represented as a point
on the Vollenweider chart relating average inflow concentration to the water renewal
time (Figure 2-4). On this basis, Lake Huron proper is classed as oligotrophic;
this is confirmed from examination of several other criteria. Principal among these
criteria are the low chlorophyll <=t concentrations (1 to 2 ug/1, Figure 2-2), low
phosphorus concentrations (3.5 to 5.5 ug/1, Figure 2-3), the domination of phy-
toplankton assemblages by diatoms and microflagellates throughout the year, minimal
oxygen depletion in the hypolimnion'in summer stratification, and in secchi disc
readings of 8 m. However, there is summer nutrient depletion in the epilimnion,
indicating approaching mesotrophy.
In order to maintain present water quality as indicated by a chlorophyll °*
concentration of 1.4 ug/1, the calculated loading as predicted by eutrophication
models must not exceed 3600 t/a. Table 2-2 summarizes the present and projected
loadings of phosphorus to the main body of Lake Huron. The present total loading
is 3720 t/a, of which 29% is due to cultural point sources. These sources are being
subjected to additional control (particularly for inputs to Saginaw Bay), which
will reduce phosphorus loading from its present 3720 t/a to 3020 t/a. This level
of loading is adequate to protect the present trophic state of the lake. However,
the potential for future cultural enrichment is large, as indicated by projections
to the year 2020, even with maximum phosphorus controls of all municipal and indus-
trial sources. Therefore increased controls on other sources, which account for
71% of the present phosphorus inputs, will be necessary. These include contri-
butions from land use activities, atmospheric inputs, Lake Superior, Lake Michigan,
the North Channel, and Georgian Bay. Table 2-3 indicates the anticipated load
reduction from P-Ban.
Of the total phosphorus loading to Lake Huron proper, '-»-' 70% is retained
within the lake, primarily in the sediments. Only one fourth is effectively
passed on to the Lower Lakes.
Very few nearshore areas of Lake Huron proper can be considered eutrophic.
The one exception is Saginaw Bay, which receives wastes from about 1,200,000
persons, as well as from industry and from rural drainage from intensively
farmed land. The Saginaw River contributes 30% of the total phosphorus which
enters the main body of Lake Huron. This elevated loading has resulted in ex-
tremely enriched conditions in Saginaw Bay compared with other areas of the
Great Lakes system. Total phosphorus concentrations of up to 0.058 mg/1 have
been measured from 1965 to 1974 (compare with Figure 2-3) .
*0p. Cit. - The Waters of Lake Huron and Lake Superior, p 133.
-16-
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The average chlorophyll concentration in Saginaw Bay is 15.7 ug/1 (Figure
2-2). Taste and odor problems within the Saginaw - Midland, Bay City,
and Pinconning Michigan water supply systems and filter cloggings at two of the
three municipal intake sites on Saginaw Bay haye been a problem for a number of
years. Forty-two percent of the threshold odor measurements taken at the public
watet supply intake at Whitestone Point equalled or exceeded the U.S. drinking
water standard of three. Reductions in loading of essential algal nutrients
should indirectly assist in bacteria population regulation which are involved in
taste and odor problems in the Great Lakes. The substantial nutrient inputs to
Saginaw Bay require effective control if enrichment in Saginaw Bay is to be
reversed.
A high portion of the phosphorus input to, and the algae produced in Saginaw
Bay, escape to the open lake; thus, reduction of phosphorus loading to Saginaw
Bay will improve water quality in both Saginaw Bay and the open lake. Model
projections for Saginaw Bay indicate reductions in blue-green algae and phos-
phorus concentrations proportional to reductions in phosphorus loading. Cur-
rently planned programs will reduce phosphorus loading from 1300 t/a to 700 t/a.
This is expected to reduce the phytoplankton standing crop by 33% (Figure 2-2).
Goedrich, Cheboygan, Alpena, and Harbor Beach are four small areas impacted
by nutrient inputs; phosphorus removal would alleviate enrichment problems, and
is being implemented at the last three locations.
GEORGIAN BAY
The criteria for trophic state indicate that Georgian Bay, as a whole, is
oligotrophic (Figure 2-4). The chlorophyll <^ concentration averages 1.2 ug/1
(Figure 2-2) and the total phosphorus concentation is •-^-'8.0 ug/1 (Figure 2-3).
The present phosphorus loading is 928 t/a of which more than 90% is from atmo-
spheric and nonpoint sources. Georgian Bay acts as an effective sedimentation
basin for phosphorus with 90% of that entering the bay eventually being lost to
the sediments. This 90% effective removal benefits the main body of Lake Huron
substantially. Future trophic control in Georgian Bay will be difficult since
phosphorus removal is already in place at municipal treatment plants around the
bay. Canada has reduced the phosphorus content of laundry detergent to a
maximum of 2.2% phosphorus. Maintenance of water quality in Georgian Bay will
require nonpoint source controls.
There is localized enrichment at Midland Bay, Penetang Bay, and Collingwood
Harbor. Phosphorus removal is not operational at municipal treatment plants
in these locations and should lead to improvements in water quality. The ex-
pected improvements in these bays should be the subject of surveillance.
NORTH CHANNEL
Phosphorus loadings to the North Channel are well up .into the mesotrophic
range (Figure 2-4). Chlorophyll cX concentrations average 1.7 ug/1 (Figure 2-2)
The principal cause is loading from the St. Marys River and from local tribu-
taries. The phosphorus loading to the North Channel is expected to increased
from its present level of 1220 t/a. Maintenance or improvement of the water
quality in the North Channel can only be accomplished through nonpoint source
controls.
LAKE MICHIGAN
The loading rate of phosphorus into Lake Michigan and concentrations of
this nutrient confirms that certain areas of the Lake are exhibiting cultural
-17-
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eutrophication. Lake Michigan's nearshore, embayments, and southern parts,
would be classified as mesotrophic or eutrophic while the open waters,
especially, in the northern parts of the Lake, are oligotrophic with a
tendancy towards mesotrophic. Indicators of trophic status for the entire
lake suggest that Lake Michigan is a mesotrophic body of water. The phos-
phorus loadings to Lake Michigan are well up into the mesotrophic range
(Figure 2.4). Total phosphorus concentrations in the open waters during
winter are in the mesotrophic range (Figure 2-3). Chlorophyll cX levels of
1.3 ug/1 levels (Figure 2-2) are close to the lower boundary of the mesotrophic
range.
It is predicted by Tarapchak and Stoermer in Environmental Status of the
Lake Michigan Region, Vol. 4, Phytoplankton of Lake Michigan (in press), that
if Lake Michigan's phosphorus load continually increases, the rate of eutrophi-
cation will accelerate, and nitrogen and light will eventually become factors
limiting phytoplankton growth. Such conditions presently occur in Green Bay,
a body of water characterized by nuisance blooms of blue-green algae. In-
creased nutrient loadings generally affect the shallow, inshore regions first.
Gradually, offshore water is altered and exhibits symptoms of cultural
eutrophication induced by sustained nutrient inputs into the nearshore en-
vironment. Data on concentrations and loading rates of phosphorus, nitrogen,
and silica suggest that the present pattern of cultural eutrophication in Lake
Michigan is similar to that proposed for large lakes by Beeton and Edmondson
(1972), as cited by Tarpchak and Stoermer, op. cite.
In order to meet the target phosphorus load, the present total load of
7100 t/a of which 42% is due to cultural point sources must be reduced.
These sources are being subjected to additional control which should reduce
phosphorus loading by 1145 t/a from its 1974 level. These reductions alone
will not be sufficient to meet the recommended loading.
Estimated residual loads after P-Ban and 1 mg/1 treatment apppear to be
sufficient to achieve the total lake target load based on present loading
estimates (see Table 2-3). These reductions in phosphorus loading to the
lake should result in significant improvements in nearshore, and eventually,
offshore water quality. Local improvements in Lake County Illinois and north
Chicago have occurred as the result of abatement programs. However, inshore
regions in the southern basin, near Milwaukee, and in southern Green Bay
presently exhibit clear signs of advanced eutrophication resulting from
large supplies of phosphorus received from polluted tributaries.
LAKE ERIE
Lake Erie, because it is the most eutrophic of the Great Lakes, is of
particular public interest. Its classification as eutrophic is indicated,
by its position on a Vollenweider-type diagram (Figure 2-4), where influent
phosphorus is related to water renewal time for the lake'. Figure 2-2 con-
firms this classification for the Western Basin of Lake Erie where the average
chlorophyll a* concentration of 11.1 ug/1 places it in the eutrophic range.
In the Central and Eastern Basins, average chlorophyll <^ concentrations are
5.5 and 4.3 ug/1, in the mesotrophic range. Another factor which enter into
the classification is the lack of dissolved oxygen in the hypolimnion of the
Central Basin.
In view of the wide public interest in the condition of Lake Erie, a re-
view of progress in controlling pollution of the Lake is presented. According
to a 1974 report of the Surveillance Subcommittee of the Water Quality Board,
-18-
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Figure 2-5
TOTAL PHOSPHORUS CONCENTRATIONS IN LAKE ERIE 1970-1975
O.07
O.O6
Cfl
°
mo
* O 0.04
%
I
I—
vO
O
o.oj
0.02
0.01
DATA SOURCES
1970-72 Canada Center tor Inland Waters
1973-75 Center for Lake Erie Area Research,
Ohio State University
Central
'j'jVs^
1070
1971
1972
1973
DATE OF OBSERVATION
1974
1975
-------
Figure 2-6 VOLUME WEIGHTED CONCENTRATION (juG/L) OF CORRECTED CHLOROPHYLL a
IN LAKE ERIE 1973-1975
20T
15- -
5
ID-
DATA SOURCE
Center for Lake Erie Area ^Research.
Ohio Slate University
JFMAMJ JASON O'j FMAMJ JASON D* J FMAMJ JASON D*
1973
1974
1975
-------
"Lake Erie appears, on the whole, to be no longer deteriorating, having stabi-
lized at a still undesirable condition."
Though phosphorus loadings are still far from the target levels scheduled
under the 1972 Agreement, there has been considerable progress in reducing
loadings. For example, loadings from the Detroit River have declined from 33
thousand t/a in 1968 to 12 thousand t/a in 1975, though most of this reduction
occurred before the Agreement went into effect. In the period covered by the
Agreement, overall loadings to the Lake have declined 30% from about 28,304 t/a
in 1971 to 19,607 t/a in 1974-75. Though the latter is still considerably higher
than the target loads for 1975 and 1976 (15,240 t/a and 14,606 t/a, respectively),
two-thirds of the reduction targeted by 1975 had been achieved.
The minimum summer phosphorus mass appears to have increased over the past
six years (Figure 2-5).* Trends have not been found in chlorophyll <^ concentra-
trations for the past three years (Figure 2-6).*
Two other aspects of Lake Erie's are of interest. First, the Surveillance
Subcommittee has observed some shifts over time in zooplankton and macroin-
vertebrates toward warm-water and pollution-tolerant forms.**
Secondly, with regard to an aspect of Lake Erie's condition which has re-
ceived wide attention, the area of the Central Basin hypolimnion which become
anoxic - a state of no dissolved oxygen - reached a peak in 1973 at 94% and de-
clined dramatically in 1975 to 6%. However, this does not indicate a definite
improvement in the Lake since the 1975 result is due to the spring weather
conditions which prevailed and its effect on the thermal structure of the Lake.
The anoxic area has an effect on biota, and can cause phosphorus in the sediment
to go back into solution. In 1976, the area of anoxic was 63%.
In a study authorized under P.L. 92-500, the U.S. Corps of Engineers con-
centrated on analyzing present sources and quantities of phosphorus loadings to
the Lake. For 1974-75, the total phosphorus loading rate is estimated to be
19,607 t/a. Table 2-2 summarizes the phosphorus loadings from various sources.
In the Corps' study, a mathematical model was used to predict equilibrium phos-
phorus concentrations in each basin under various loading scenarios. This model
which assumes the Lakes' three major basins to be "completed-mixed reactors"
in series and assumes various physical, chemical and biological transformations
of phosphorus within each reactor, was used to predict equilibrium phosphorus
concentrations in each basin under various loading scenarios.
The Corps considers that, in order to return Lake Erie to a mesotrophic state,
the phosphorus concentration in the Western Basin must be reduced from the
present 0.037 mg P/l to 0.020 mg P/l, the Central Basin from 0.018 mg P/l to
0.015 mg P/l and the Eastern Basin from 0.022 mg P/l to 0.015 mg P/l. To
achieve these in-lake concentrations, the study concluded that loadings to the
lake must be reduced to 12,525 t/a. The study concluded that these conditions
could be achieved in 1-6 years after an adequate reduction in applied phosphorus
loadings. However, scheduled elimination of municipal and industrial point
dischargers of phosphorus will not be sufficient to achieve this (see Table 2-3)
since a 44% of the present loadings is estimated to come from diffuse sources
such as land runoff.
* 1975 IJC Water Quality Board Report - Appendix B Surveillance Subcommittee
Report, p 73 and 74.
** 1974 IJC Water Quality Board Report - Appendix B Surveillance Subcommittee
Report, p 103.
-21-
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The Corps is continuing its study in order to develop an economically and
technically feasible program to achieve the desired reductions in phosphorus
loading to Lake Erie and, in cooperation with EPA, is attempting to model
phosphorus loadings and lake conditions as they change over time.
While much is yet to be learned about the lake, it is worth noting that a
P-ban would have a significant effect on loadings. As mentioned, present P-loads
are 19,607 t/a in contrast to the WQ Agreement target of 14,606 t/a, a difference
of 5,000 t/a. A P-ban in Michigan would approximately halve the gap, a reduction
of about 2,500 t/a.
LAKE ONTARIO
Lake Ontario is classified as a mesotrophic lake (Figure 2-4). Figure 2-2
confirms this evaluation with average chlorophyll <=^ concentration at 4.8 ug/1 in
the mesotrophic range. In order to maintain present water quality and taking
into account that the lake is not in equilibrium with present loadings, it is
calculated that loading must not exceed 7450 t/a,* a lower target load than
previously. Table 2-2 summarizes the estimated phosphorus loading. The present
loading from point sources is about 16% of the total. The planned reductions
(Table 2-3) from 1 mg/1 effluent requirements of 2,486 t/a in the Lake Ontario
basin and 3751 t/a, if the Lake Erie reductions can be anticipated, will not be
sufficient, based on current P-loads and lowered target load. Estimated residual
loads after P-ban in the Lake Erie Basin and 1 mg/1 treatment are still insuf-
ficient to achieve the lowered target load. The additional reductions with
treatment to achieve a 0.1 mg/1 effluent limit could be sufficient based on
current estimates (see Table 2-3). However, as technology becomes available,
phosphorus inputs from presently uncontrolled sources, the atmospheric sources,
land drainage, lake sediments and shore erosion will all need to be reduced.
CONCLUSIONS
With the long flushing times and effective mixing of the Upper Lakes, the
general trophic states of Lake Superior and the main body of Lake Huron
are the result of loading from all sources. In contrast to the Lower Lakes
(and with the exception of Saginaw Bay), cultural inputs of phosphorus do
not dominate the present loading, though their significance could increase
in the future.
Embayments and harbors are the isolated cases of presently identified
enrichment impact, with the exception of Saginaw Bay which has a measurable
and distinct impact on southern Lake Huron. However, these embayments and
harbors are the focus of local efforts to clean up pollution.
In the face of projected development, to maintain the present or the
reduced levels of loading (see Table 2-3), the reduction of atmospheric or
land use inputs will be required to prevent degradation of these fresh
water bodies.
For the Lower Lakes, the United States is behind schedule in reducing
loadings under the 1972 Water Quality Agreement with Canada. The reductions
in phosphorus loadings to Lake Ontario and Lake Erie anticipated in the
Agreement are not likely to be met. New estimates of the response of these
*0p. Cit. 1975 IJC Water Quality Board Report - Appendix B, Figure 3:55, p 221
-22-
-------
lakes indicate the likelihood of delayed recovery in response to current
scheduled phosphorus reductions and the growing recognition of the importance
of nonpoint sources of phosphorus. Although further reductions in phosphorus
loadings from municipal and industrial sources are possible after achieving
1 mg/1 P, significant amounts are entering the lakes from the atmosphere,
lake sediments and land drainage.
REQUIREMENTS ON PHOSPHORUS CONTROL
The 1972 Agreement set target loadings for municipal treatment plants
for the Lower Lakes which called for effluent limitations of 1 mg/1 for
plants discharging over 1 MGD. All of the States in the Great Lakes Basin
have established phosphorus effluent limitations.
A brief list of the current effluent requirements on municipal plants
to protect downstream water uses is:
Illinois
Indiana
Michigan
Minnesota
New York
Ohio
Penna
Wisconsin
1 mg/1 in the Lake Michigan Basin and in the Fox River
Basin for plants over 1500 population. Illinois
municipalities no longer discharge to Lake Michigan
Basin.
removal or 1 mg/1 whichever is more stringent if
the discharge is in the Great Lakes Basin or within
forty miles of a lake or reservoir and discharges
ten or more pounds of phosphorus per day.
removal or 1 mg/1
1 mg/1 if discharge is directly to or affects a lake or
a reservoir.
1 mg/1
1 mg/1 or stricter requirements set by OEPA-NPDES permits
in Lake Erie Basin, and in all waters tributary to the
Ohio River and its basin where nuisance growths exist.
1 mg/1
85% removal for plants over 2500 population in the Great
Lakes Basin.
A recent summary of the current status for removal of phosphates from
detergents in the Great Lakes is shown in Table 2-4.
-23-
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TABLE 2-4
STATUS OF LEGISLATION TO LIMIT THE PHOSPHORUS CONTENT OF DETERGENTS USED IN THE GREAT LAKES BASIN
JlT?vTfmCTlON POPULATION (1970)
(in Great Lakes Basin) Date Effective
DETERGENTS PHOSPHORUS LEGISLATION
Allowable P (%) Detergents Included
w York
(Eric County)
3,517,992
(1,103,414)
01/72 to 07/73
07/73
05/71 to 01/72
01/72
8.7%
0.5%
8.7%
0.5%
-household use, laundry use,
other personal uses,
industrial uses except those
for machine dishwasher, dairy
equipment, beverage equipment,
food processing equipment and
industrial cleaning equipment.
References
1
2
MJc.aif.aa
(Der.roit)
i
ro
Indiana
8,780,119
(4,199,931)
1,291,125
07/72
(07/72)
01/72 to 01/73
01/73
8.7%
(0.5%)
8.7%
0.5%
-all cleaners
-(City ordinance enacted but
pre-empted by Act 226 - State
of Michigan above).
-does not include detergents
for cleaning in-place food
processing and dairy equipment;
phosphoric acid products includ-
ing sanitizerSj brighteners, acid
cleaners and metal conditioners,
detergents for use in dish
washing machine equipment,
including household and commercial
machine, dishwashers, detergents
for use in hospitals and health
care facilities; industrial
laundry detergents, detergents
for use in dairy, beverage, food
processing and other industrial
cleaning equipment.
-------
TABLE 2-4 (continued)
STATUS OF LEGISLATION TO LIMIT THE PHOSPHORUS CONTENT OF DETERGENTS USED IN THE GREAT LAKES BASIN
Minnesota
POPULATION (1970)_
(la Great Lakes Basin) Date Effective
235,805
01/77
01/77
DETERGENTS PHOSPHORUS LEGISLATION
Allowable P
0.5%
11%
Determents "Included
References
-all household cleaning agents
intended to be uncc' In tha homo,
laundry determents and built
soaps for machine laundry except
chemical water conditioners
and household and commercial
detergents for machine dishwashing,
-household and commercial
detergents for machine diohwashing.
en
i
Ohio
Akron
Pennsylvania
Ilr ie
Wisconsin
Illinois
Chicago
4,259,247
(679,239)
235,998
232,074
2,456,351
4,618,598
(4,618,598)
None
01/73
None
None
None
None
07/72 to 03/73
0.5%
0.5%
-total ban
-household laundry detergents
7
7
7
8
Canada
6,376,955 (1971) 07/70 to 01/73
01/73
8.7%
2.2%
-laundry detergents
9
9
-------
TABLE 2-4
REFERENCES
.. Eberly, W.R., "History of the Phosphate Detergent Ban in Indiana,"
Proceedings of the Indiana Academy of Science for 1974, Vol. 84,
1975, pg. 410.
I. Hopson, N.E., "Phosphorus Removal by Legislation," Water Resources
Bulletin, American Water Resources Association, Volume 11, No. 2,
April 1975, pg. 358.
3. Michigan Cleaning Agents and Water Conditioners Act, (Act 226, Public
Acts of 1971; Effective July 1, 1972) 811:0161.
'4. Porcella, Donald B., and A. Bruce Bishop, Comprehensive Management of
Phosphorus Water Pollution, Ann Arbor Science, Ann Arbor, Michigan,
1975, pg. 186
5. Indiana Phosphate Detergent Law (Indiana Code 1971, 13-1-5.5; Public
Law 174, Laws of 1971, Amended by Public Law 97, Laws of 1072, and
Public Law 117, Laws of 1973) 471:0141.
6. State of Minnesota, Pollution Control Agency, Chapter Thirty Seven:
WPC 37, Standards for the Limitation of the Amount of Phosphorus in
Various Cleaning Agents and Chemical Water Conditioners.
Section 116 24 (d) Nutrient Limitation.
7. Great Lakes Water Quality Board, International Joint Commission,
Great Lakes Water Quality 1975, Appendix C, Remedial Programs
Subcommittee Report, pg. 105.
8. Porcella, Donald B., and A. Bruce Bishop, Comprehensive Management of
Phosphorus Water Pollution, Ann Arbor Science, Ann Arbor, Michigan,
1975, pg. 186.
9 The Canada Water Act; Sections 18 and 19.
-26-
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STATUS OF PHOSPHORUS REMOVAL FACILITIES IN THE GREAT LAKES
Table 2-5 provides two measures of progress in phosphorus control. The numbers
in column A give the proportion of capacity which employed phosphorus removal in
1974. The Agreement pertains to the Lower Lakes (Erie and Ontario): note that most
Lake Erie treatment plant capacity has phosphorus removal. The statistics in column
B reflects overall phosphorus removal operating efficiencies of these facilities.
These percents are based on 1975 data and cannot be compared precisely with the capacity
based on 1974 data. However, one would expect in this comparison that the column B
percents should exceed or equal column A if phosphorus removal operating efficiency were
100% effective.
Table 2-5+ PERCENT OF DAILY SEWAGE FLOW* FOR WHICH PHOSPHORUS REMOVAL FACILITIES
HAVE BEEN PROVIDED AND PERCENT TREATED (SEWAGE FLOW WITH PHOSPHORUS
CONCENTRATIONS £ 1.0 mg/1)
United States
Canada
Total
% of Facilities
with P Removal
Lake Superior
Lake Huron
Lake Michigan
Lake-trie
Lake Ontario &
St. Lawrence
4
30
89
83
20
Overall
Facility
Operating
Efficiency
B
( 5)++
(36)
(42)
(12)
( 5)
A B
0 ( 0)++
60 (33)
100 (67)
84 (22)
4
39
89
84
B
(3)++
(35)
(42)
(17)
54 (15)
+ Modified from Table 10 p. 96 1975 Appendix C Great Lakes Water Quality Board Rem-
dial Programs Subcommittee Report. International Joint Commission.
* Includes all direct dischargers and those indirect dischargers with flow greater
than on million gallons a day.
•H- Percents computed from Table 5.3 p43, 1976, Appendix C; Great Lakes Water Quality
Board Remedial Programs Subcommittee Report; International Joint Commission (Final
Draft, May 10, 1977).
-27-
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The following conclusions are appropriate in light of present knowledge of eutro-
phication, its causes and prospects for control:**
1. Limiting phosphorus availability in lakes is the single
most important and necessary step to be taken now in
eutrophication control.
2. The most effective way to do this is to reduce phosphorus
inputs.
3. Municipal sewage is the major point source. All such dis-
charges to lakes and other susceptible waters should be
treated to reduce phosphorus content to realistic target
levels.
4. Phosphorus contributions to sewage should be reduced in
every feasible way.
5. Because all inputs are additive, and therefore potentially
significant, all should be considered for control.
6. Means must be developed to curtail phosphorus inputs from
all significant point and diffuse sources.
**Bartsch A.F., August 1972 "Role of Phosphorus in Eutrophication" EPA-R3-72-001
Ecological Research Series - National Environmental Research Center U.S. EPA,
Corvallis, Oregon 97330
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Chapter III. Advantages and Disadvantages of a Phosphorus Ban
There are three choices for phosphorus control:
L. Phosphorus can be removed at the treatment plants by
chemical precipitation;
2. It can be controlled by limiting its use and subsequent
introduction to natural systems; or
3. It can be controlled by the combination of in-plant
removal with specific source reductions.
Although in-plant removal is ultimately necessary to achieve the 1.0 mg/1
effluent total phosphorus goal, the delay in construction of most treatment
facilities makes the third alternative the most appropriate choice now to reduce
the phosphorus loading discharged into the receiving waters in a timely fashion.
Control of phosphorus in laundry detergents will reduce the influent phosphorus
loading to all wastewater treatment facilities by about 40% and effluent phosphorus
concentrations by about 50% as discussed in the Appendix to this chapter. The pros
and cons of a P-ban in the State of Michigan, Ohio, and Wisconsin and the Great
Lakes Basin area are summarized in Tables 3-1, 3-2, 3-3, and 3-4.
Cost and environmental benefits resulting from a P-ban can be estimated based
on populations residing in hard water areas and municipal wastewater flows.
The Great Lakes Basin Framework Study showed a total of 6,868,000 Michigan resi-
dents served by public water supplies in 1970. The study reported 5,330,900 (78%)
were served from Great Lakes sources, 173,200 (2%) served from inland lakes and
streams, and 1,364,700 (20%) served from ground water sources. An additional
2,006,300 persons obtained drinking water from private sources.
The State of Ohio Water Plan of Public Water Systems 1969 published by the
Ohio Department of Health Division of Engineering Water Supply Unit showed a total
of 8,455,178 Ohio residents served by public water supplies in 1969. This report
indicated that 6,036,000 persons (71%) were served by surface water supplies and
2,419,178 (29%) were served by ground water supplies. An additional 2,196,839
residents obtained drinking water from private sources. In Ohio's portion of the
Great Lakes Drainage Basin, a total of 3,703,600 residents were served.by public
water supplies in 1970 as reported in the Great Lakes Basin Framework Study Appendix
6. This study reported 2,655,300 persons (72%) were served from Great Lakes sources,
770,400 persons (21%) were served from inland lakes and streams, and 277,900 persons
(08%) were served from ground water sources. An additional 676,000 persons obtain
drinking water from private sources. In Ohio, the city of Akron's water supply
serves 354,900 persons. The city has a P-Ban. The subsequent economic consid-
erations in Ohio from a P-Ban does not include Akron's population.
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The State of Wisconsin Public Water Supply Data - 1970 published by Wis-
consin Department of Natural Resources' Division of Environmental Protection
showed a total of 2,823,000 Wisconsin residents served'by public water sup-
plies in 1970. This report indicated that 1,593,000 persons (56%) were served
by surface water sources and 1,230,000 persons (44%) were served by ground
water sources. An additional 1,594,731 persons obtained drinking water from
private sources. In Wisconsin's portion of the Great Lakes Drainage Basin, a
total of 1,864,330 residents were served by public water supplies in 1970 as
reported in the Great Lak'es Basin Framework Study Appendix 6. This study re-
ported 1,325,250 persons (71%) were served from Great Lakes sources, 130,960
persons (07%) were served from inland lakes and stream sources, and 408,120
persons (22%) were served from ground water sources. An additional 752,870
persons obtain drinking water from private sources.
The Great Lakes Basin Framework Study showed a total of 23,693,300 Great
Lakes Basin residents served by public water systems. Of these, 17,277,600
persons (73%) receive drinking water from Great Lakes sources, 2,337,600
persons (10%) from inland lakes and streams, and 4,078,100 (17%) from wells.
An additional 5,639,000 people receive drinking water from private sources.
Most of the private sources of water are obtained from ground water supplies.
The area included in the Great Lakes Basin Framework Study is shown in Figure
3-1.
Table 16 of the Great Lakes Water Quality Board 1974 Great Lakes Water
Quality Report* indicated that the actual flow of all direct and indirect
dischargers with over 1.0 MGD is 3,465 MGD. The total treatment plant flow
for plants over 1.0 MGD which discharge into the Great Lakes Drainage Basin
are 1,472 MGD for Michigan, 560 MGD for Ohio, and 317 MGD for Wisconsin.
Since Akron, Ohio already has a P-Ban, the Lake Erie Basin flow is reduced
by 90 MGD to approximate the wastewater flow from Akron. The municipal flow
in all of Ohio and Wisconsin for plants over 1 MGD is estimated at 1340 and
520 MGD respectively for 1974.
*1974 IJC Great Lakes Water Quality Annual Report, Appendix C "Remedial
Program Subcommittee Report", pages 66-74.
-30-
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TABLE 3-1
Summary of Advantages and Disadvantages
of a Phosphate Ban
In the State of Michigan
(Metric Tons)
A. Environmental Benefits
1. Immediate reduction of eutrophication rate of receiving waters.
2. Immediate reduction of sludge generated by 42,700 to 55,100
tons/year.
3. Immediate reduction of total dissolved solids added to receiving
waters by 56,900 tons SO a year or 42,100 tons Cl a year
4. Immediate reduction of energy consumption by 2,360,000 to 3,000,000
gallons Number 2 fuel oil a year.
B. Economic Benefits
1. Cost savings for chemicals and sludge disposal of $17,500,000
or more a year>' depending on the size of the facilities.
2. Conserve 6,100 tons of phosphorus a year for food production.
3. Conserve 116,000 tons of alum or 63,500 tons of ferric chloride
for other industrial uses.
4. Reduce the need for treatment at small plants by reducing influent
phosphorous loadings.
C. "Disadvantages" - Alleged Cost to Consumers
a) Procter and Gamble Study in 1975:
Cost to Michigan residents $5,300,000 in 1975.
D. Region V Evaluation
b) Minimum savings from the P-Ban is $12,200,000 a year
($17,500,000 - $5,300,000).
-31-
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TABLE 3-2
Summary of Advantages and Disadvantages of a Phosphate Ban
in the State of Ohio Drainage Basin to Lake Erie
Figures for the entire State within parenthesis
(Metric Tons)
A. Environmental Benefits
1. Immediate reduction of eutrophication rate of receiving waters.
2. Immediate reduction of sludge generated by 12,700 to 17,200
(35,400 to 46,300) tons/year.
3. Immediate reduction of total dissolved solids added to receiving
waters by 17,400 (47,500) tons S(^= a year or 12,900 (35,100)
tons Cl a year.
4. Immediate reduction of energy consumption by 720,000 (1,968,000)
to 929,000 (2,540,000) gallons number 2 fuel oil a year.
B. Economic Benefits
1. Cost savings for chemicals and sludge disposal of $5,400,000
($14,800,000) or more a year, depending on the size of the
facilities.
2. Conserve 1,870 (5,100) tons of phosphorus a year for food pro-
duction.
3. Conserve 35,400 (98,000) tons of alum or 19,400 (52,600) tons
of ferric chloride for other industrial uses.
4. Reduce the need for treatment at small plants by reducing in-
fluent phosphorus loadings.
C. "Disadvantages" - Alleged Cost to Consumers
a) Proctor and Gamble Study in 1975 Cost to Ohio residents
of $1,500,000 ($7,200,000).
D. Region V Evaluation
b) Minimum savings from the P-Ban is $3,900,000 ($7,600,000)
$5,400,000 - $1,500,000 ($14,800,000 - $7,200,000).
-32-
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TABLE 3-3
Summary of Advantages and Disadvantages of a Phosphate Ban in the
State of Wisconsin Drainage Basins to Lakes Superior and Michigan
Figures for the entire State within parenthesis
(Metric Tons)
A. Environmental Benefits
1. Immediate reduction of eutrophication rate of receiving waters.
2. Immediate reduction of sludge generated by 9,000 to 12,000
tons/year (15,000 to 20,000 tons/year).
3. Immediate reduction of total dissolved solids added to receiving
waters by 12,200 (20,100) tons S0l;= a year or 9,000 (14,900)
tons Cl a year.
4. Immediate reduction of energy consumption by 507,000 (834,000)
to 655,000 (1,076,000) gallons Number 2 fuel oil a year,
B. Economic Benefits
1. Cost savings for chemicals and sludge disposal of $3,800,000
($6,300,000) or more a year depending on the size of the faci-
lities.
2. Conserve 1,320 (2,160) tons of phosphorus a year for food pro-
duction.
3. Conserve 9,000 (15,000) tons of alum or 12,000 (20,000) tons of
ferric chloride for other industrial uses.
4. Reduce the need for treatment at small plants by reducing influent
phsophorus loadings.
C. "Disadvantages" - Alleged Cost to Consumers
a) Proctor and Gamble Study in 1975
Cost to Wisconsin residents of $1,800,000 ($4,400,000)
D. Region V - Evaluation
1. Minimum savings from the P-Ban is $2,000,000 ($1,900,000)
$3,800,000 - $1,800,000 ($6,300,000 - $4,400,000)
-33-
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TABLE 3-4
Summary of Advantages and Disadvantages
of a Phosphate Ban
In the Great Lakes Basin Area
(Metric Tons)
A. Environmental Benefits
1. Immediate reduction of eutrophication rate of receiving waters.
2. Immediate reducion of sludge generated by 101,000 to 130,000 tons
a year.
3. Immediate reduction of total dissolved solids added to receiving
waters by 134,000 ton S0^= a year or 99,000 ton Cl~ a year.
4. Immediate reduction of energy consumption by 5,540,000 to
7,160,000 gallon Number 2 fuel oil a year.
B. Economic Benefits
1. Cost savings for chemicals and sludge disposal of $41,500,000
or more a year, depending on the size of the facilities.
2. Conserve 14,400 tons of phosphorus a year for food production.
3. Conserve 275,000 tons alum or 150,000 tons ferric chloride a year
for other industrial uses.
4. Reduce the need for treatment at small plants by reducing
influent phosphorus loadings.
C. "Disadvantages" - Alleged Cost to Consumers
a) Procter and Gamble Study in 1975.
Cost to the Great Lakes Basin Area residents of $15,200,000 in
1975.
D. Region V Evaluation
b) Minimum savings from the P-ban is $26,300,000 a year
($41,500,000 - $15,200,000).
-34-
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The environmental benefits, economic benefits, and disadvantages are
discussed based on figures presented in Table 3-1 thru 3-4.
A. Environmental Benefit
A P-Ban would result in an immediate reduction of the eutrophication rate
of receiving waters, a reduction of sludge generated and resultant air and land
pollution, a reduction of total dissolved solids added to the receiving waters
and a reduction of energy consumption.
1. Immediate Reduction of Eutrophication Rate of Receiving Waters
Experience in Indiana and New York indicates that the ambient level of
phosphorus in lakes and streams has decreased since the P-Ban went into effect.
Also water quality improvements have been recorded. It is, therefore, antici-
pated that the water quality of both the Great Lakes and inland lakes will be
improved through a P-Ban.
a. Great Lakes
Most of the larger wastewater treatment plants in the Great Lakes Basin
Area are not achieving the 1 mg/1 total phosphorus effluent concentration goal.
In some instances it will be five years or more before plants have adequate faci-
lities to precipitate the phosphorus and handle the increased amount of sludge.
A P-Ban will complement efforts to remove phosphorus at wastewater treatment
plants, although implementation of the P-Ban alone can not meet the 1 mg/1 total
phosphorus effluent limitation limitation goal. For example, Detroit's current
influent and effluent phosphorus loadings are 6,300 tons a year and 4,500 tons a
year respectively a removal efficiency of only about 29%. Based on the experience
of the Metropolitan Sanitary District of Greater Chicago, it is conservative to
estimate that the effluent loading from Detroit would decrease by another 2,000
tons as a result of the P-Ban.
Appendix C of the 1975 Great Lakes Water Quality Annual Report contains
a list of plants with their effluent phosphorus concentrations. In the case of
Lake Erie, the P-Ban will bring about a reduction of 280 t/a for plants other
than Detroit not achieving 1 mg/1. On a Lake Erie wide basis, a 17% reduction
could be achieved with the P-Ban with treatment plants remaining at their pre-
sent levels of removal.
b. Inland Lakes
Potential removal of phosphorus from the P-Ban and estimated phosphorus
loadings from detergent in unserviced areas of the Great Lakes area are
summarized in Table 3-5 and Table 3-6.
-36-
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Table 3-5
POTENTIAL REMOVAL OF PHOSPHORUS FROM PHOSPHORUS DETERGENT BAN
Phosphorus Loads Metric Tons
Detroit STP
With Present
Treatment
Lake (T/Yr)
Superior
Huron
Erie 20001
Ontario
Michigan
Other City Unsewered
STP's Not STP's At Population
Achieving 1 mg/1 1 mg/1 (T/Yr)
(T/Yr) (T/Yr) Min. Max.
? 7 60
? 36 322
2802 ? 98 886
PHOSPHORUS DETERGENT BAN
4002 ? 125 1129
STP's Under4
1 MGD
(T/Yr)
-
-
278
IN EFFECT
?
Total
Sewage5 Load
Bypasses (T/Yr)
(T/Yr) Min. Max.
7 60
36 322
330 2986 3774
3506 875 1879
References :
1. P. Pan, EPA, Region V
2. IJC, Water Quality Board 1975 Report, Appendix C . .
3. Table 3-6
4. Schuette in Procter and Gamble Letter of 11/10/76
5. EPA, Region V, MODO, R. Buckley Memo
6. Lee, G.F. Phosphorus Water Quality and Eutrophication in Lake Michigan 1972 Conference - Pollution of Lake
Michigan and its Tributary Basin, Illinois, Indiana, Wisconsin, Michigan Volume 1 Fourth Session September 19 -
21, 1972 Chicago Illinois.
WWTT whose effluent yields greater than 1 mg/P/1 (loading
times .35) lower reduction used in that some of the plants
have partial chemical removal.
Prepared by:
EPA, Large Lakes Research
Station Grosse He, Michigan
December 1976
-------
Table 3-6
ESTIMATED PHOSPHORUS LOADINGS FROM DETERGENTS IN UNSEWERED AREAS OF THE GREAT LAKES
Lake
Superior
Huron
Erie
Ontario
Michigan
Un sewered
Population
118,1001
627.8002
1,727,000s
657, OOO1*
2,200,0007
Minimum5
Per Capita
Load Potential
Kg P.Capital/Yr
.057
.057
.057
.057
Minimum
Total
Load
(Metric T/Yr)
7
36
98
PHOSPHORUS DETERGENT
125
Maximum5
Per Capita
Load Potential
Kq P/Capita/Yr
.513
.513
.513
BAN IN EFFECT
.513
Maximum6
Total
Load
(Metric T/Yr)
60
322
885
1129
00
References:
1. IJC, Upper Lakes Reference Report, Vol. 1
2. IJC, Upper Lakes Reference Report, Vol. 1
3. Schuette in Proctor and Gamble Letter of 11/10/76
4. Schuette in Proctor and Gamble Letter of 11/10/76
5. Schuette in Proctor and Gamble Letter of 11/10/76 (.57 Kg P/Cap/Yr)
Dillon and. Viraraghavan (10% retention of Phosphorus by drain fields)
6, By computation
7. Great Lakes Basin Framework Study - Report'Table 8 p. 32
and Appendix 19 Economic and Demographic Studies Table 19-2 p.3
-------
Studies conducted by the State of Indiana have demonstrated positive effects by
reducing phosphorus concentration in Indiana lakes and reservoirs. Two lakes and one
reservoir were chosen for a comparison of before-and-after studies. These include
the Mississinewa Reservoir which drains a large area containing many sewage treatment
plants; Long Lake which receives the effluent from the Angola Sewage Treatment Plant,
as well as septic tank effluent from the Town of Pleasant Lake and a few shoreside
cottages; and Olin Lake which is largely undeveloped and receives only a small amount
of agricultural runoff. Table 3-7 is a summary of the results for the comparative
studies.
TABLE 3-7
SUMMARY OF INDIANA COMPARATIVE STUDIES
TOTAL PHOSPHORUS (mg/1)
Olin Lake
Station
Center
State Survey
July 26, 1972
.01 mg/1
N.E.S. Survey
August 6, 1973
.011 mg/1
Percent Change
Station
Just east
of S.R. 13
Just east
of Red Bridge
Near Dam
State Survey
August 2, 1972
.217 mg/1
,108 mg/1
.075 mg/1
Mississinewa Reservoir
N.E.S. Survey State Survey Percent Change
August 7, 1975
August 3, 1973
.161 mg/1
.093 mg/1
.046 mg/1
.02
-26%
-14%
-73%
Station
Center of
Main Basin
Long Lake
State Survey N.E.S. Survey State Survey Percent Change
August 27, 1970 August 6, 1973 July 30, 1975
1.2 mg/1
0.38 mg/1
.12
-90%
-39-
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Surveys conducted as part of the State's Lake Studies Program indicate that
significant phosphorus reductions have occurred in a number of other lakes and
reservoirs.
In the State of Michigan over 90% of its more than 2,000 lakes are not
sewered. Approximately 40% of these lakes show enrichment problems due in part
to shoreline development. A P-Ban will reduce the amount of phosphorus entering
the lakes from septic tank drain fields by about 33%.
In addition, many small communities use stabilization lagoons to treat the
wastewater. While these lagoons achieve minimal phosphorus removal, it is
difficult to reduce this further by addition of phosphorus removal facilities to
a pond. A P-Ban will provide a benefit similar to that for septic tank drain
fields.
2. Immediate Reduction of Sludge Generated and Resultant Air and Land Pollution
Removing phosphorus by chemical precipitation generates excess sludge from
20% (using alum or ferric chloride) up to 200% (using lime) of the total sludge
produced in conventional secondary treatment plants. The amount of sludge
generated depends mainly on the phosphorus content, the chemicals used, the
alkalinity and the pH of the wastewater to be treated. Based on a 3.0 mg/1 re-
duction of influent phosphorus concentration, a P-Ban will reduce the sludge
generated as folows in the State of Michigan ranging from 42,700 tons/year
(using alum) to 55,100 tons/year (using ferric chloride), in the Great Lakes
Basin of Ohio ranging from 12,700 tons/year (using alum) to 17,200 tons/year
(using ferric chloride), and in the Great Lakes Basin of Wisconsin ranging from
9,000 tons/year (using alum) to 12,000 tons/year (using ferric chloride). For
the Great Lakes Basin Area production of sludge will be reduced 101,000 tons/year
(using alum) to 130,000 tons/year (using ferric chloride).
National air pollution standards for emissions from municipal sludge
incinerators limit emissions for particulates from incinerators used to burn
wastewater sludge to "No more than 0.65 g/kg dry sludge input (1.30 Ib./ton
dry sludge input)". Assuming that 10%* of the treatment facilities use
incineration and that all are meeting the "New Source Standards", a 3.0 mg/1
reduction of influent phosphorus means a reduction of approximately 7,000 Ibs.
of particulate emissions a year in the State of Michigan, approximately
2,100 Ibs. of particulate emissions a year in the Great Lakes Basin of Ohio,
approximately 1,500 Ibs. of particulate emissions a year in the Great Lakes
Basin of Wisconsin and approximately 16,500 Ibs. of particulate emissions a
year in the entire Great Lakes Basin.
The Metropolitan Sanitary District of Greater Chicago (MSDGC) has been
shipping its wet sludge to Fulton County, Illinois (180 miles away from Cook
County) for the reclamation of strip-mined land. There does not appear to
be a saturation period after eleven years of application. Problems with
PCB's and heavy metals have not occurred in crops grown on the land.**
* Association of Metropolitan Sewage Agencies (AMSA), "Field Report on
Current Practices and Problems of Sludge Management"
** Dr. David Zenz, Coordinator of Research, Research & Development - Metro-
politan Sanitary District of Greater Chicago, Personal Communication
(April 1977)
-40-
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Based on MSDGC's estimation, in the first year 75 dry tons/acre can be applied
safely, with the amount tapering down to 20 dry tons/year/acre in five years.
Application rates are lower on undisturbed soils. The application rate of 20 to
30 dry tons/acre/year can be maintained. The reduction in land requirement for
wet sludge disposal resulting from a P-ban (90% of the total sludge generated)
would then be approximately 2000 acres for Michigan, 600 acres for Ohio, and 400
acres for Wisconsin when restricted to the Great Lakes Drainage Basin with a total
of 4600 acres for the entire basin.
3. Immediate Reduction of Total Dissolved Solids Added to Receiving Waters
The total dissolved solids content in drinking water should preferably not ex-
ceed 250 parts per million (ppm).* The allowable total dissolved solids content for
modern ultrahigh pressure steam power plants is less than 1.0 ppm. The specific
objective of the International Joint Commission Agreement, Annex 1, Specific Water
Quality Objectives, requires that the level of total dissolved solids should not
exceed 200 mg/1 or the present (1972) levels.
Chemical precipitation for phosphorus removal adds extraneous ions to the treated
effluent, which in turn adds total dissolved solids to the receiving waters. Each
pound of alum used as aluminium will generate 5.35 pounds sulfate ion (SO ) and each
pound of ferric chloride used as iron will generate 1.91 pounds chloride ion,(Cl ).
Based on a 3.0 mg/1 reduction of influent phosphorus, an immediate reduction of total
dissolved solids added to the receiving waters would be 56,900 tons sulfate ion per
year or 42,100 tons chloride ion per year for the State of Michigan and 17,400 tons
sulfate ion per year or 12,900 tons chloride ion per year for the Great Lakes Basin
portion of Ohio, 12,200 tons sulfate ion per year or 9,000 tons chloride ion per year
for the Great Lakes Basin portion of Wisconsin, and 134,000 tons sulfate ion per year
or 99,000 tons chloride ion per year for the entire Great Lakes Basin.
4. Immediate Reduction of Energy Consumption
Sludge incineration is an energy consuming process. Fifty gallons of number two
fuel oil are required to burn a ton of sludge.** Based on a 3.0 mg/1 reduction of
influent phosphorus concentration, a reduction of energy consumption for burning
chemical sludge alone would range from 2,360,000 to 3.. 040,000 gallons of number two
fuel oil a year for the State of Michigan, from 720,000 to 929,000 gallons of number
two fuel oil for the Great Lakes Basin drainage area of Ohio, from 507,000 to 655,000
gallons of number two fuel oil a year for the Great Lakes Basin drainage area of Wis-
consin or a total of 5,540,00 to 7,160,000 gallons of number two fuel oil for the
entire Great Lakes Basin.
* Op Git. 1976 Quality Criteria For Water, p394,
**Glexsey, R. and J.B. Farrell. "Sludge Incineration and Fuel Conservation,"
"News of Environmental Research in Cincinnati,," U.S. EPA, May 3, 1974.
-41-
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B. Economic Benefits of a Phosphorus Ban
'Another beneficial effect of a P-Ban is the cost saving due to the reduction of
chemicals needed for phosphorus removal, equipment to handle the chemical sludge
generated, and its ultimate disposal. In addition to this cost saving, a P-Ban also
conserves phosphorus for food production, conserves chemicals for other industrial
use, and reduces the required treatment at small plants.
1. Cost Saving for Chemicals and Sludge Disposal
Dr. Edwin Earth, of the Environmental Protection Agency, Cincinnati Laboratory,
estimates that with a one-third reduction in phosphorus concentration, excluding
the cost reduction for sludge handling, chemical and operating costs might be re-
duced about 20 percent.
The Michigan Department of Natural Resources (MD.NR) staff reported that the
average chemical and sludge handling costs, excluding"-the cost for ultimate sludge
disposal, is $3.45 per capita per year for six municipal wastewater treatment
facilities in Michigan. The current flows of these facilities range from 0.87 MGD
to 17.5 MGD, with an average flow of 6.2 M6D.
The Region V staff estimates that a cost saving of $1.20 per capita per year
will result from a P-Ban for treatment facilities with a flow greater than 100 MGD.
This estimate is based on (1) a water consumption rate of 100 gallons per capita
per day; (2) a 3.0 mg/1 influent phosphorus concentration reduction resulting from
a P-Ban; (3) October 1976 chemical costs; and (4) MSDGC cost analysis for sludge
handling and ultimate disposal.
Based on our earlier discussion, the reductions in cost resulting from a P-Ban
within the Great Lakes Drainage Basin are $17.5 million per year for the State of
Michigan, $5,400,000 million per year for Ohio, (excluding Akron, Ohio) $3,800,000
million per year for Wisconsin and a total of $41.5 million per year for the entire
Great Lakes Basin. For smaller facilities, which have not been included, we would
expect greater cost reductions.'
2. Conserving Phosphorus for Food Production
Based on a 3.0 mg/1 total phosphorus reduction in wastewater influent due to
a P-Ban, we calculated that 6,100 tons/year of phosphorus in Michigan, 1,870 tons/
year of phosphorus in OtffLo, 1,320 tons/year of phosphorus in Wisconsin, and a total
of 14,400 tons/year of phosphorus in the entire Great Lakes Basin can be conserved
for food production.
3• Conserving Chemicals for Other Industrial Use
Based on a 3.0 mg/1 total phsophorus reduction in wastewater influent, it can
be calculated that 116,000 tons of alum or 63,500 tons of ferric chloride in the
State of Michigan, 35,400 tons of alum or 19,400 tons of ferric chloride in Ohio's
Great Lakes Drainage Basin, 9,000 tons of alum or 12,000 tons of ferric chloride
in Wisconsin Great Lakes Drainage Basin or 275,000 tons of alum or 150,000 tons
of ferric chloride can be conserved in the entire Great Lakes Basin.
-42-
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4. Reduction of Required Treatment at Small Plants
In the many small communities using septic tanks and wastewater treatment
lagoons, where phosphorus removal efficiency is minimal, a P-Ban will reduce their
phosphorus loading by approximately 33%. Although the P-Ban alone may not allow
them to achieve the 1 mg/1 total phosphorus effluent level, the P-Ban will at least
reduce their receiving waters' rate of eutrophication.
C. "Disadvantages" - Alleged Cost to Consumers
Two studies financed by detergent and related industries which were made avail-
able to Region V have reported that a P-Ban may result in "cost penalties" to
consumers. These "penalties" are claimed to be $23.27 per family per year by Home-
maker Testing Corporation (HTC) in 1974 and $5.17 by the Procter and Gamble Company
(P&GC) in 1975. Region V considers the HTC report to be invalid and misleading, as
discussed in Section lll-C-3. The $5.17 "cost penalty" claimed by the P&GC report
is used for discussion, though this study is also biased in our opinion.
Both reports made invalid comparisons by selecting the "banned area" with poorer
water quality than the "un-banned area(s)" under study. Despite the fact that this
cost differential may have resulted from the difference in water quality, the "cost
penalties" of $23.27 in 1974 and $5.17 in 1975 seems to indicate that this cost
differential is rapidly diminishing and may even favor non-phosphorus detergent in
the future. When all influential factors are taken into consideration, the cost
differential favors the non-phosphate detergents.
As will be discussed in Chapter IV, adverse effects of non-phosphorus detergents,
to the extent they exist, are associated with hard water. Water containing more than
150 mg/1 is assumed to be hard for our cost estimates. The majority of Michigan and
Great Lakes Basin Area residents are served from the Great Lakes and inland surface
waters. The water supplied from these sources has a total hardness of less than 150
mg/1. Only 38% and 33% of the residents in Michigan and the Great Lakes Basin Area,
respectively obtain drinking water from ground water sources and/or private sources
that may have a total hardness higher than 150 mg/1. In Ohio (43%) and Wisconsin
(64%) of the residents in these States obtain their drinking water from ground water
sources and/or private sources that may have a total hardness higher than 150 mg/1.
In the Great Lakes Drainage Basins' of Ohio and Wisconsin respectively, 22% and 44%
of the residents obtain their drinking water from sources which may have a total
hardness higher than 150 mg/1. Assuming the $5.17 per household (3.3 persons) per
year additional cost to be fact, only residents using "hard water" would probably be
affected by the full $5.17 in 1975. Based on these figufes, the costs for the entire
States of Michigan, Ohio, and Wisconsin would be estimated at $5.3, $7.2, and $4.4
million respectively, according to P & G Company. Within the entire Great Lakes
Drainage Basin and the portions of each State within this hydrologic boundary, the
costs would be estimated at $15.2 (Great Lakes Basin), $5.3 (Michigan), $1.5 (Wis-
consin), and $1.8 (Ohio) millions.
-43-
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1. The Homemaker Testing Corporation (HTC) Report of 1974
The HTC prepared a report for the FMC Corporation in 1974 to compare non-
phosphate detergent use in Indianapolis, Indiana, where there is a ban, and
phosphate detergent use in Kansas City, Kansas. This study selected 200 families
in each city. None of the families had a home water softener. The report concluded
that a "cost penalty" of $23.27 per family per year has resulted from the use of
non-phosphate made detergent. These costs resulted from the use of additional
detergent, more laundry additives, rewashing and rerinsing clothes.
2. The Procter and Gamble Company Study of 1975
A letter from Mr. J.W. Schuette of P&GC to Mr. S. T. Davis of the U.S. Environ-
mental Protection Agency, Washington, B.C., made the following statement:
"During 1975, P&GC developed additional
information based on market sales data
comparing Indianapolis (zero phosphate
area) with the demographically similar
cities of Cincinnati, Dayton, and
Columbus (phosphate areas). These
studies indicated an added annual cost
per household of $4.17 in the zero
phosphate area due to increased use of
detergents, laundry aids and performance
boosters. The $4.17 figure is averaged
over all Indiana households, and is
probably very conservative. This is
because it is based on actual sales
figures, even though we know that some
Indiana consumers have either purchased
permanent home water softeners or have
purchased their detergent outside of
Indiana to relieve some of the performance
negatives of the non-phosphate granular
detergents."
"Other areas where the current carbonate-
base, non-phosphate detergents can cause
additional consumer costs are increased
machine repairs, increased garment wear-out
due to poor cleaning and carbonate deposition,
and installation and operation of permanent
home water softeners. At this point, we
would estimate the cost of increased
machines repair to be approximately $1.00
per household per year, based on service
call records of a major applicance manu-
facturer. Garment wear-out and home water
softener costs have been difficult to
quantify accurately. To be conservative,
we therefore estimate that a ban will cost
the average household a minimum of $5.17
per year, based on available data."
-44-
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3. Region V's Evaluation
Both of the above-mentioned studies ignored the most important factors —
water supply characteristics — which would affect the dosage of detergent and
chemical additives needed per wash load, which in turn affect the cost per wash
load.
The HTC Report compares Indianapolis, Indiana, with Kansas City, Kansas.
The P&GC study compares the State of Indiana, based on market sales data, with
three cities: Cincinnati, Columbus and Dayton in Ohio.
The water supply characteristics for the study year of the key cities under
study are tabulated in Tables 3-8 and 3-9. Specific quantitative information
regarding the water supply characteristics for the State of Indiana are not
available to Region V at this time. In general, the total hardness of the water
supplies for the State of Indiana is in the range of 300 - 400 mg/1. Only 14 or
15 of the 455 water supply utilities in the State of Indiana treat their water
with a lime-soda softening process. For the purpose of comparison, the water
supply of Indianapolis is chosen as representative of the water supply of the
State.
TABLE 3-8
Water Supply Characteristics
of
Indianapolis, Indiana and Kansas City, Kansas
Annual Average 1974
Indianapolis, Indiana
Kansas City, Kansas
Total Hardness in mg/1
Iron in ppb as Fe
Manganese in ppb as Mn
pH ranges
Color
261
30
10
6.70 - 8.11
10
219
4
less than detectable limit
7.5 - 8.4
1
-45-
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TABLE 3-9
Water Supply Characteristics
of
Indianapolis, Indiana,
Cincinnati, Ohio, Dayton, Ohio and Columbus, Ohio
Annual Average, 1975
Indianapolis Cincinnati Columbus Dayton
Total Hardness in mg/1 251 146 126 154
Iron in ppb as Fe 30 0.02 0 0
Manganese in ppb as Mn 0 0 00
pH range 6.9 - 8.0 8.4 8.6 - 8.7 9.6 - 10.0
Color 10 1 or 2 0 0
a. Total Hardness of Water Supplies.
As illustrated in Tables 3-10 through 3-12 Washability Performance for both "Low
Phosphate" and "No Phosphate" detergents are strongly dependent upon the total hard-
ness of the water used. The total hardness of water supplies for Indianapolis, Indiana,
and Kansas City, Kansas, during the study in September and October 1974 happened to be
very similar. However, the 1974 annual average data for Indianapolis' total hardness
was 42 mg/1 higher than Kansas City, Kansas. The maximum total hardness for the State
of Indiana in 1974 was as high as 344 mg/1. Those "hard" days may have caused the
needed additional detergent, more laundry additives, rewashing and rerinsing as reported
by HTC.
The annual average total hardness of Indianapolis in 1975 was 251 mg/1, whereas all
the water utilities for Cincinnati, Columbus, and Dayton in Ohio supply relatively soft
water (average total hardness for the study year ranges from 126 to 154 mg/1).
Based on the above, it can be concluded that a substantial fraction of HTC's $23.27
in 1974 and P&GC's $5.17 in 1975 cost differentials are attributable to the differential
in total hardness of the water supplied to these cities under study.
-46-
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TABLE 3-10
WASHABILITY PERFORMANCE*
RELATIVE SOIL REMOVAL OF LOW AND NONPHOSPHATE DETERGENT
WATER HARDNESS EFFECTS/0.20% CONCENTRATION
Water Cotton Polyester
Hardness Low P Non P Low P Non P
150 ppm 90.0% 77.2% 92.4% 66.5%
300 ppm 75.3% 77.8% 72.4% 66.6%
MRC - Manufacturer's recommended concentraiton, average is 0.13%
Water Hardness — As CaCo, 150 ppm = 8.8 gpg
300 ppm = 17.5 gpg
Data — Average soil removal data for top selling major brand
detergents (60% of retail market).
b. Suyrvey Population
(i) The HTC report completely omitted from the survey population
households with home water softeners. In Indianapolis, this
amounted to the elimination of 1 of every 3 households from
the survey.
(ii) The HTC report failed to compare the age groups of children,
particularly the age groups under 3 and around 6. For children
under 3, a lot of bleach and softener would be needed for
cleaning diapers. Children at around the age of 6 always have
dirtier clothes to be cleaned.
(iii) The HTC report failed to compare the professions of the adults.
For example, an auto machanic may be in the same income bracket
as a college professor, but an auto mechanic needs a lot more
spotter to clean his clothes than a office worker.
(iv) The P & GC study compares urban residence (three big cities of
Ohio) and a general population, including both urban and rural
residents.
*Rutkowski, B.J. "Performance Characteristics of Non-Phosphate Detergents"
Science Research Department Whirlpool Corporation Benton Harbor, Michigan,
presented at Michigan Natural Resources Commission meeting December 8, 1976.
-47-
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TABLE 3-11
RELATIVE PERFORMANCE OF 8.7Z PHOSPHORUS DETERGENTS
COMPARED TO SEARS NON-PHOSPHATE DETERGENT 2
ALL PRODUCTS TESTED AT EQUAL CONCENTRATION
. Relative Performance
(120* F)
Relative Perfornunce
(120'F)
Brand — Cloth — Hardneu
Soil
Removal
Whiteness
Retention
Brightener
Piciup
Overall
Rating
SEARS NON-PHOSPHATE
Cotton
Polyester
Average
BOLD
Cotton
Polyester
Average
CHEER
Cotton
Polyester
Average
CAIN
Cotton
Polyester
Average
TIDE
Cotton
Polyester
Avenge
140 ppm
300 ppra
140 ppm
300 ppm
140 ppm
300 ppm
140 ppm
300 ppm
140 ppm
300 ppm
140 ppm
300 ppm
140 ppm
300 ppm
140 ppm
300 ppm
140 ppm
300 ppm
140 ppm
300 ppm
100.0
100.0
100.0
100.0
100.0
97.7
77.5
92.2
50.8
79.6
92.9
73.5
99.8
69.1
.83.8
86.5
74.3
88.6
56.0
76.4
88.4
764
95.1
53.4
78.9
100.0
100.0
100.0
igoo_
100.0
95.6
94.0
851
71.2
86.5
86.9
91.3
90.6
91.5
90.1
80.1
84.5
78.6
82.6
81.5
86.1
89.9
90.4
85.6
68.0
100.0
100.0
100.0
100.0
100.0
101.8
100.4
100.6
99.2
100.5
98.0
101.7
100.5
101.0
100.3
95.2
97.9
100.3
99.8
98.3
96.2
99.4
100.6
100.3
99.6
100.0
100.0
100.0
100.0
100.0
98.4
90.6
92.6
73.7
88.8
92.6
88.8
97.0
87.2
91.4
873
85.6
89.2
79.5
85.4
90.9
88.6
95.4
80.4
88.8
Brand— Goth — Hardness
AIL
Cotton
Polyester
Average
DRIVE
Cotton
Polyester
Average
AJAX
Cotton
Polyester
Average
COLD" POWER
Cotton
Polyester
Average
FAB
Cotton
Polyester
Average
PUNCH
Cotton
Polyester
Avenge
140 ppm
300 ppm
140 ppm
300 ppm
140 ppm
300 ppm
140 ppm
300 ppm
140 ppm
300 ppm
140 ppm
300 ppm
140 ppm
300 ppm
140 ppm
300 ppro
140 ppm
300 ppo
140 ppm
300 ppm
140 ppm
300 ppm
140 ppm
300 ppm
Soil
Removal
92.2
75.0
92.8
56.9
79.2
9S.4
81.4
89.2
66.0
83.0
92.5
76.4
89.4
51.9
77.7
9S.7
74.0
99.7
49.2
79.7
92.7
75.7
98.5
62.4
82-3
96.2
86.5
90-3
_3LL
81-5
Whiteness
Retention
99.4
99.2
94.5
69.9
90.8
93.9
92.0
79.6
75.4
83.2
99.1
102.6
82.0
81.0
• 91.2
94.8
98.9
79.0
73.3
86.5
90.4
92.4
88.6
89.0
90.1
99.2
104.6
81.6
73.7
89.8
Bnghtener
Pickup
94.7
92.8
101.7
99.5
97 2
90.6
89.3
101.0
100.0
95.2
103.8
104.0
103.5
102.6
103.5
102.8
103.2
104.0
103.9
103.5
100.9
101.6
102.6
102.6
102.0
102.9
105.1
100.5
99.7
102.1
Overall
Rating
95.4
89.0
96J
7S.4
89.0
93.3
87.6
89.9
805
87.8
98.5
94.3
91.8
78.S
90.8
97.8
92.0
94 2
75.5
89.9
94.7
89.9
96.6
84.7
91.5
99.4
98.7
90.8
75.5
91.1
*Howe, R. S., Morris, J. G. and Poston, H. W. "Laundry Detergents and Environmental
Quality" School of Public and Environmental Affairs, Indiana University. Occasional
Papers No. 2, May 1973
-48-
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TABLE 3-12
DETERGENCY OF VARIOUS DETERGENTS AT DIFFERENT WATER HARDNESS*
Percent Soil Removal
Water
Hardness (ppm)
0
0
0
20
20
20
50
50
50
150
150
150
300
300
300
Detergent
Nonionic Carbonate
Anionic Phosphate
Nonionic Phosphate
Nonionic Carbonate
Anionic Phosphate
Nonionic Phosphate
Nonionic Carbonate
Anionic Phosphate
Nonionic Phosphate
Nonionic Carbonate
Anionic Phosphate
Nonionic Phosphate
Nonionic Carbonate
Anionic Phosphate
Nonionic Phosphate
Em pa
101
61.6
59.0
51.2
57.1
58.4
50.1
63.6
54.6
49.4
61.1
51.3
43.3
56.8
41.2
25.6
U.S.
Testing
24.2
19.8
17.7
19.4
19.2
17.4
21.4
18.1
16.8
20.3
17.0
11.9
17.7
19.3
11.4
TFI 65/35
PE/C P.P.
39.6
38.2
27.1
32.0
35.6
25.6
38.5
"34.7
23.5
35.6
34.6
20.6
33.5
37.1
19.6
TFI
Cotton
30.0
38.8
27.8
30.2
36.8
19.2
32.7
36.4
24.4
29.7
34.5
16.7
29.5
28.8
16.7
4 Test
Cloth Avg.
38.9
39.0
31.0
34.7
37.5
28.1
39.0
36.0
28.5
36.7
34.4
23.1
34.4
31.6
17.3
" cv J> G* 3nd P°St0n' H< W' l>Laun
-------
c. Bleach
The amount o'f bleach needed depends mainly on the iron and manganese
content and color of the water supply. Iron and manganese causes stain, "red
water" scale, and black spot. As illustrated in Tables 3-8 through 3-9, re-
spectively, the iron concentration in Indianapolis is approximately 10 to 20
times as high as all the other cities under study. The maximum manganese
concentrations in Indianapolis are as high as 30 ppb whereas in the other
cities, the manganese is at the less than detectable limit. As to color units,
in Indianapolis on the average it is ten times that of the other cities. All
the above would result in using substantially more bleach in Indianapolis than
in the other cities. In addition fabric strength loss increases when excess
amounts of bleach are used. A large excess of bleaching may also result in bad
soil removal efficiency, which in turn results in more detergent consumption.
d. pH
A pH below 8.0 in relatively soft water will cause corrosion of the water
pipe. A pH below 7.0 may impair the effectiveness of a sequestering agent, which
forms soluble complexes with calcium and magnesium, instead of insoluble preci-
pitants. As illustrated in Tables 3-8 and 3-9 from 1974 through 1975, the
minimum pH-in Indianapolis dropped below 7.0, whereas in all the other cities,
the pH is always above 7.0. In addition, fabric strength loss decreases when
the pH of the bleach bath is increased.
e. Size of Washload
The HTC report failed to consider the size of the washload. For example,
top loading automatic washers require twice as much detergent as front loading
automatic washers per wash,
f. Hardness
The property of hardness in water is due principally to the presence of
carbonates, bicarbonates, sulfate or other compounds of calcium and magnesium.
Water hardness diminishes the ability of soap or detergents to form suds and the
carbonate hardness forms a scale deposited on the inside surfaces of boilers and
water .heaters, making them less efficient and necessarily requiring frequent
cleaning or replacement. The standard for permissible hardness varies from less
than 50 mg/1 to 150 mg/1. Experience has shown that hardness in excess of 200 mg/1
may cause some problems in the household. Even without adding any precipitant,
calcium and/or magnesium scale tend to form and to cause more frequent washer re-
pair services in hard water areas.
g. Summary
It is significant to note that the largest share of the estimated increase
in cost was due to the use of laundry aids and additives which would be expected
to do little or no good in improving performance. The occasional double wash or
rinse in the cities may have resulted from abnormally high total hardness of the
water from the tap during the washing period. Thus, consumer education on correct
laundry practices and use of water softeners in those areas which have excessive
hard wa.ter, would seem appropriate.
-50-
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It is our estimation that, to remove- each grain (17.14 mg) of hardness
in raw water using home water softeners, the cost saving on detergent is $2.60
per family per year. The annual amortized cost for softeners is about $30 per
year. Based on these estimations, the break even point for installing water
softeners is about 200 mg/1 total hardness. In addition to the cost saving
in detergent, water softening would prevent scale formation in the water supply
pipes and in the hot water heater. It would prolong the life of the water pipe
and hot water heater, and improve the efficiency of the hot water heater, which
in turn conserves energy.
Excluding all the other influential factors, the minimum cost benefits
resulting from a P-Ban can be obtained by subtracting the cost to consumers due
to the cost differential claimed by P&GC ($5.17/per capital/ year) from the cost
savings on chemicals and sludge disposal which results from a P-ban. These min-
imum net cost benefits per year are estimated for the residents of the following
areas at $12.2 million (State of Michigan), $3.9 million (within the Great Lakes
Drainage Basin of Ohio (excluding Akron), $2.0 million (within the Great Lakes
Drainage Basin of Wisconsin), and $26.3 million savings (entire Great Lakes Basin
Area). The minimum net cost benefits per year for the entire states of Ohio and
Wisconsin are estimated at $7.6 and $1.9 million respectively.
Appendix Impact of P-Ban Phosphorus in Wastewater
In areas where a ban on phosphates has been implemented, measurable
decreases in the concentrations of phosphorus in sewage have been reported
within months of implementation. Measurable decreases in total and the phosphate
in receiving streams were observed within a year. Thus, dual benefits of conser-
vation of resources while also reducing expenditures of both energy and capital
for wastewater treatment facilities are achieved.
The following studies* show that the reduction of phosphorus content in
detergent has resulted in a significantly lower phosphorus influent as well
as effluent phosphorus concentration in sewage.
1. During an evaluation of a demonstration pressure sewer system in
New York State serving a small group of single family homes, the
phosphorus concentration in the domestic wastewater was determined
during separate 3-week time periods when phosphorus detergents and
non-phosphate, heavy duty soap were used. A phosphorus reduction
of 48 percent was observed during this study. Monthly data col-
lected pre- and post-ban from one Monroe County New York facility
indicated a 55 percent phosphorus reduction from 1973 to 1975.
2. A review of available phosphorus data from municipal discharges in
the New York portion of the Great Lakes Basin has been undertaken
to evaluate the effectiveness of the phosphorus-in-detergent ban.
The majority of these dischargers are in Erie County where a county-
wide ban preceded the statewide ban by 1-1/2 years. The statewide
ban, which became effective on June 1, 1973, limited phosphorus to
0.5 percent by weight of the product content. Influent and effluent
samples have been collected at most municipal facilities at least
once a year in connection with New York's operation and maintenance
inspection program. This annual data was evaluated for discrete
*1975 IJC Great Lakes Water Quality Board, Great Lakes Water Quality Appendix C.
Remedial Program Subcommittee Report pp. 104-107.
-51-
-------
time periods in order to determine the trend in municipal phos-
phorus concentrations. Figure A-l shows a reduction in influent
phosphorus concentrations of 53 percent from 1972 to 1975.
From 1971 through 1975 Indiana Stream Pollution Control Board's
staff conducted a large number of 29 hour surveys of municipal
wastewater treatment plants. As illustrated in Figure A-2*, the
influent concentration of total phosphorus has dropped from about
12 mg/1 prior to the P-Ban down to about 4.5 mg/1 after the P-Ban.
The Metropolitan Sanitary District of Greater Chicago (MSDGC)'s
report examined the phosphorus concentrations and other data for
the raw sewage and the effluents from the three major treatment
works of the Metropolitan Sanitary District of Greater Chicago
prior to and after the ordinance banned phosphorus-containing
detergents went into effect, on June 30, 1972.
The Metropolitan Sanitary District serves an area of approximately
860 square miles including the City of Chicago and over 110 sur-
rounding communities. The District maintains and operates three
major treatment works, North Side, West-Southwest and Calument, all
of which receive a part of the wastewaters treated from the City of
Chicago.
The annual average concentrations of phosphorus found in the in-
fluent sewages have shown a decrease in 1972 as compared to pre-
vious years are summarized in Table A-l. The raw sewage phosphorus
concentration at the North Side STW has decreased from an annual
average of 10 mg/1 P for the 1969-1971 period to an annual average
of 4.9 mg/1 P in 1972. The degree of reduction was not as great at
the Calumet STW where the annual average phosphorus concentration
was 9.2 mg/1 P for 1969-1971 and 7.9 mg/1 P in 1972.
A more noticeable decline in phosphorus levels has been observed
in the final effluents from the three major treatment works. The
reduction in the raw sewage phosphorus levels at Calumet and North
Side appears to be directly related to the reduction in phosphorus
containing detergents in those segments of the two service areas in
which the phosphorus ban is effective; i.e., those segments which
lie within the corporate limits of the city of Chicago. Dr. Cecil
Lue-Hing** did not know of any other factors which may have occurred
which would effect such a reduction. Factors, such as storm flows,
which would affect the phosphorus concentrations, while variable
did not appear to be appreciably different in those years. The
final effluent concentrations of phosphorus at North Side STW were
lower in 1972 (yearly average of 3.1 mg/1 P) than in the period of
1969-1970 (yearly averages of 5.2 and 6.1 mg/1 P). At the Calumet
STW, the final effluent concentrations decreased from a level of
4.9 mg/1 P during the 1969 - 1971 period to 2.8 mg/1 P in 1972.
The final effluent concentrations for the West-Southwest STW averaged
2.5 mg/1 for the 1969-1971 period as compared to 1.3 mg/1 P in 1972.
However, in the case of the Southwest raw sewage, the complexity
*1975 305(b) Report, Indiana Pollution Control Board pp 342-35.
** Dr. Cecil Lue-Hing, Director, Research & Development, The
Metropolitan Sanitary District of Greater Chicago, Personal Com-
munication, March 29, 1977
-52-
-------
X
CL
cn
o
a.
24-
23-
22-
21-
2O-
19-
)8-
17-
16-
15-
14-
13-
12-
II-
10-
9-
8-
7-
6-
S-
4-
3-
2-
I •
O-
* PHOSPHORUS CONCENTRATIONS (mg/1)
ERIE COUNTY. NEW YORK. DATA
•^Average phosphorus concentration
computed for approximately
30 municipal discharges,
one sample per year
I97I
I972
I973
1974
I075
Fig, A-l
-53-
-------
FIGURE **
SUMMARY OF PHOSPHORUS DATA
24-HOUR SURVEYS
RAW SEWAGE AT MUNICIPAL TREATMENT PLANTS
1971
1972
1973
1974
1975
5
14
13
12
11
10
9
8
7
6
5
4
3
2
1
Q AYE. LBS./CAP./DAY X 103
— • — O AVE. MG./L
37
43
50
POUNDS/CAPITA/DAY • NO. OF SURVEYS
IN AVE.
51
55
51 42
NO. OF SURVEYS IN AVE.
92
-54-
-------
of the West-Southwest Sewage Treatment Works does not allow us to
accurately estimate what portion of the phosphorus reduction is
attributable to the phosphorus ban and what portion could be
attributed to other causes.
The phosphorus loads in terms of metric tons per day discharged from
each of the three treatment works were determined for various time
periods before and after the phosphorus detergent ban. The total
average daily phosphorus load from all three plants was 14.2 tons
per day for the first six months of 1972. The phosphorus loading
decreased to 6.5 tons per day in the last six months of 1972 or a
reduction of 53.8 percent.
The total volume of effluent discharged was slightly higher in the
second half of 1972 (1411 MGD) as compared to the first half of
1972 (1357 MGD).
In Michigan, the average influent phosphorus loading from four
municipal sewage treatment plants, decreased from 15.0 lbs/1000
people/year in 1970 to 8.8 lbs/1000 people/year in 1975 which re-
sulted from the reduction of the average phosphorus content in
detergent from 11.4% in 1970 to 7.07% in 1976.
TABLE A-l*
THE METROPOLITAN SANITARY DISTRICT OF GREATER CHICAGO
CONCENTRATION OF PHOSPHORUS IN MG/L FOUND AT THE
MSDGC TREATMENT PLANTS
ANNUAL AVERAGES 1969-1972
Year Calumet
Raw Final
1969 9.8 5.1
1970 8.6 4.7
1971 9.3 4.3
1972 7.9 2.8
Southwest
Raw Raw Final
SW WS
20.1 2.7
17.3 6.2 2.3
37.4 2.7
12.5 5.1 1.3
North Side
Raw Final
9.7 5.2
10.6 6.1 •
10.3 6.4
4.9 3.1
*Cecil Lue-Hing, David T. Lordi, "Report on City of Chicago's Phosphorus
Ban and Its Effect Upon Effluent Quality, the Metropolitan Sanitary
District of Greater Chicago. Department of Research and Development,
February 1973. -55-
-------
A comparison was made between a period when there was no limitation on
phosphorus detergents, the year 1970, and a period, November 1972, after
the phosphorus ban went into effect. The phosphorus loads for the com-
bined effluents decreased from 18.3 tons per day to 5.9 tons per day or by
67.6 percent.
Table A-2 shows numerically the continuing effects of the phosphorus
ban. The North Side Plant receives a high percentage of domestic sewage.
The West Southwest Plant receives over 50% of its sewage from industrial
wastes. It can be observed that without any additional phosphorus removal
capability, effluent phosphorus concentration decreased to below the Illinois
1 mg/1 standard for the Southwest Plant which has a flow close to a billion
gallons per day.
It is difficult to completely assess the effects of the phosphorus ban
because of the precentage of flow from outside of the city of Chicago which
is treated in the District plants. However, there has been a definite re-
duction in the phosphorus concentrations in both the raw sewage and the
resultant treatment plant effluents. These reductions appear to be in the
range of 40 to 60 percent. Improvements in the effluent concentrations
reflect the reduced influent phosphorus levels and possibly may be partially
a reflection of improved treatment performance.
TABLE A-2*
THE METROPOLITAN SANITARY DISTRICT OF GREATER CHICAGO
CONCENTRATION OF PHOSPHORUS IN MG/L FOUND AT THE
MSDGC TREATMENT PLANTS
ANNUAL AVERAGES 1969-1975
Year
Southwest
Raw
Final
North Side
Raw
Final
1969
1970
1971
1972
1973
1974
1975 (1/2 year)
20.1
34.0
37.4
14.0
7.8
5.8
6.3
2.7
2.3
2.7
1.3
0.4
1.0
0.8
9.7
10.6
10.3
4.9
4.2
5.8
3.9
5.2
6.1
6.4
3.1
1.8
3.2
2.2
*H.W. foston, John G. Morris, Cecil Lue-Hing, Richard S. Howe, "Meeting
Phosphorus Effluent Standards Without Increasing Capital Expenditures
or Operation and Maintenance Cost," September 1975
-56-
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Chapter IV. Feasibility of a Detergent Phosphate Ban
The original barriers to detergent reformulation in 1971 related to the
performance and safety of the substitutes then available. Progress in the
development of non-phosphate detergents and their wide use in areas where bans
exist have resulted in a group of commercially available non-phosphorus deter-
gents which are safe, perform adequately, and are a feasible substitute for
phosphate based detergents.
Performance and Safety of Non-Phosphate Detergents
Most modern laundry detergents use "builders-" to tie up calcium ions
in the wash water so that the "surfactants" or cleaning ingredients can remove
dirt from the clothes. The presently available buiMers for detergents are
phosphates (usually in the form of sodium tripolyphosphate); sodium carbonate
and sodium silicate (in varying combinations); citric acid (citrate); nitri-
lotriacetic acid (NTA) and a number of other builders in various states of
testing and experiment. Detergent builders work in one of two ways. They
either "sequester" the hardness ions by chemical reaction, maintaining them in
solution (phosphates, NTA, citrate), or they precipitate them out of solution
(sodium carbonate/silicate).
Results regarding the performance of phosphate and non-phosphate builders
are mixed. Builders of the sequestering variety are considered by most detergent
industry experts to be superior in cleaning performance to the precipitating
variety. Of the presently available builders, phosphates are considered to be
superior by the same industry experts. However, a number of studies done by
agencies and non-phosphate detergent manufacturers* have drawn the conclusion
that non-phosphate detergents are as effective as phosphate detergents in
cleaning ability. While NTA equals phosphates in its performance, cost, and
degradability, questions have been raised about its safety and, at present, it
is not available to detergent makers in this country. It is, however, used in
Canada. Other builders of the sequestering and precipitating variety have been
developed and are being tested by manufacturers.
In areas where phosphate detergents cannot be sold, substitutes used (in
the U.S.) are sodium carbonate and sodium silicate separately or in varying combi-
nations, citrate, and unbuilt liquid detergents, with the latter of growing popu-
larity. There is evidence that hard water can cause an undesirable build-up of
calcium carbonate precipitate to form on clothes and washing machine parts. For
practical purposes, only soap and the carbonate containing detergents cause
troublesome deposits to build-up on the fiber; and for these the rate and extent
of deposition increase in proportion to the water hardness and carbonate content.**
* Richard S. Howe, et al Laundry Detergents and Environmental Quality, (May 1973)
Also see Table 3-10, 3-11, and 3-12.
** Schwartz, A.M., Transcript of Testimony, Minnesota Pollution Control Agency
Hearings on Proposed Regulation WPC 37, (Feb. 11, 1975).
-57-
-------
It is this calcium buildup that causes most of the problems that have
occurred with carbonate-built detergents. Since the amount of build-up that
occurs can be linked directly to the washwater hardness, and carbonate content
detergent users in hard water areas without water conditioning equipment have
experienced more problems than have users in areas of soft to medium hardness.
The types of problems that have been reported range from lowered cleaning effi-
ciency for man-made fibers (resulting in "grayness") to, in cases of extreme
hardness, shortened clothing life and interference with washing machine op-
eration.
It also should be noted that where carbonate detergents cause problems,
there are other alternatives for the consumer. Users can purchase unbuilt
phosphate-free liquids, at least one citrate-built liquid (Wisk), and silicate
built detergent; none of which cause a calcium build-up. Water conditioning
equipment will also solve the problem. The heavy-duty liquid detergents,
primarily Wisk, Era, and Dynamo, made up a rapidly growing share of tlv. laundry
detergent market—19.3% in 1975. These are widely used as spotters (they are
effective in removing stains on synthetic fabrics, e.g., ring-around-the-
collar). They also can be used as regular detergents. Increasing sales and
manufacturer's advertising indicates liquid products are now widely accepted
for doing the entire wash. In the area of oily or greasy soils, liquid
detergents are clearly superior to other detergents.
Several studies have tested and compared the performance of phosphate
and carbonate builders. As Michigan Department of National Resources staff
pointed out in a review of available studies prior to their August hearing,
it is difficult to interpret the results of the studies since both the meth-
odologies and the xesults varied from study to study. As might be expected,
the studias sponsored by companies with ties to the phosphate detergent
industry do not reach the same conclusions as those sponsored fay the makers
of non-phosphate detergents.
It is probably safe to conclude that the presently available non-
phosphate detergents (carbonate/silicate built combinations, citrate-built
and unbuilt) have comparable performance to phosphate detergents at lower
hardness levels but do not perform quite as well at higher hardness levels as
do phosphate detergents. In areas of extreme hardness, users of any detergent
may experience laundering problems. Users of carbonate detergents are apt to
experience the poorest performance and precipitate build-up may result in
damage to clothing and to the washing machine. However, as already indicated,
water softeners, citrate-built detergents*, and unbuilt liquid detergents, are
available to alleviate impacts.
The contention was made in 1971 that non-phosphate, carbonate/silicate,
detergents are a more dangerous irritant than phosphate products. However,
this does not appear to apply to the brands now marketed by the major manu-
facturers .**
* Citrate is used as a builder in only one major brand of detergent, non-
phosphate Wisk, a liquid. It is marketed primarily in areas where regular
phosphate Wisk cannot be sold.
**The non-phosphate formulations presently marketed by the major manufacturers
contain far less Carbonates than did the non-phosphate products first intro-
duced in the early 1970"s. Whereas the carbonate content of some early
products was in the 50-70% range, most major brands now average in the 20-50%
range.
-58-
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Tests performed by the U.S. Food and Drug Administration concluded that
generalizations could not be made with respect to the safety characteristics
of phosphate detergents versus non-phosphate detergents (see Howe, et al. op.
cit:-' pp. 1-4).
Another concern raised in 1971 was that of maintaining flame retar-
dancy in children's sleepwear. The use of non-phosphate, carbonate containing
detergents can create a carbonate film which reduces the flame retardency of
cotton flannel and some synthetic fabric. The problem can be avoided by
switching to liquid detergents, or corrected by hand rinsing with vinegar.
Most important is that 90% of the fiber now used in children's sleepwear
is inherently more flame resistant. Recent tests* show that these synthetic
fabrics can be washed in carbonate detergents without harming flame retardency.
The same tests show that phosphate free liquids are even more effective at
maintaining flame retardency than are phosphate free detergents. Many major
brands of detergents, both low phosphate and non-phosphate, now warn users to
read labels on these garments before washing them in anything. Whether bans
are enacted or not, it is important that consumers be educated in the proper
care of flame resistant garments or whether to use flame resistant garments
at all.**
Rising Consumer Acceptance
The most prominent example of the acceptance of non-phosphate deter-
gents is the large number of states and municipalities (table 2-4) that have
adopted bans and kept them despite determined detergent industry opposition.
Currently over 32 million persons live in areas where phosphorus in detergents
has been banned. A second example of acceptance is the rapid growth in both
ban and non-ban areas of the use of heavy-duty liquid detergents which are
primarily non-phosphate, and constituted 19.3% of the market in 1975. A recent
Michigan DNR survey in Lansing, Michigan where no ban exists showed that ap-
proximately 20% of detergents sold were non-phosphate. Complaint levels in
regard to non-phosphate detergents are fairly low. Howe, et al, report a
relative absence of complaints in Erie County, New York; Dade County, Florida,
and in Chicago. Information obtained from cooperative extension agents in
Chicago and Dade County confirms the absence of complaints in these areas.
However, agents in Indiana and New York have reported laundering problems in
hard water areas apparently due to carbonate detergents. Conversations by
Region V staff with officials of non-phosphte detergent manufacturers, and with
citizens in various areas of the midwest with phosphorus bans all indicate a
very low level of consumer dissatisfaction. Region V staff feel that public
sentiment, as evidenced in these conversations, public hearings, and the
various studies and contacts that are referenced elsewhere in this report,
indicate general public support for a phosphate ban. Members of the
phosphorus committee of the regional office who authored this report are
affected by the Chicago phosphorus ban. On the basis of our experience and
the studies cited, we consider presently available non-phosphate detergents
to be a feasible substitute in both hard and soft water.
* Proposed Guidelines For Evaluating The Effects Of Laundering vs The
Flammability of Sleepwear And Fabrics, Committee RR 38, American
Association Of Textile Chemists And Colorists, July 22, 1974.
** April 1977 Consumer Products Safety Commission banned production of
TRIS (2,3, Dibromopropyl phosphate) a flame retardant chemical used on
children's sleepware.
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Only a few formal studies are available which have surveyed consumer
acceptance. One such study entitled "Detergent Substitution Studies at
C.F.S. Gloucester" was done in 1973 by Environment Canada and involved
a detergent substitution program conducted at a Canadian Forces Station.
Carbonates, NTA, citrate, and high phosphate'detergents were substituted
for normal laundry detergents and a number of studies, including user
acceptance were performed. Results of the opinion poll showed "a general
acceptance of the NTA, citrate and high-phosphate products, with a
general dislike for the carbonate product,"
A second study, done in 1974 by Homemaker Testing Corporation for
a phosphate manufacturer, the FMC Corporation, included as an appendix,
verbatum remarks made by non-phosphate detergent users in Indianapolis,
Indiana (a hard water area). Almost all of the respondents had negative
statements to make in reference to problems they had with non-phosphate
detergents.
A third study, cited in a Michigan Department of Natural Resources
staff paper was H. Hammerman's "The Erie County Phosphate Ban—Final Report"
done at Cornell University in 1973. New York residents were questioned as
to their laundry habits before and after a county-wide phosphate detergent
ban went into effect. It was the opinion of 80% of the people surveyed
(out of a total of 397) that they spent equal time on their laundry
after the ban as before and 59% stated their laundry costs were unchanged
(4% said it cost them less) after the ban. The Michigan Staff paper points
out that these numbers are based on each of the respondents' knowledge
of their laundry habits. It is, however, not likely that all respondents
kept detailed records.
Results of a similar study for Indiana were reported by Dr. William
Eberly at the Michigan hearings. Of 231 women interviewed, 70% were
satisfied with their detergents and of the remainder 40% still supported
the Ban.
In summary, the foregoing information indicates that consumer accep-
tance for non-phosphate detergents is growing, particularly in soft water
areas, but that some users of non-phosphate detergents in very hard water
areas are still experiencing problems. Such problems however, can be
reduced by the use of water softeners, heavy duty nonphosphate liquids
or ordinary soap.
Water Softeners
Any discussion of family laundering costs should acknowledge the fact
that approximately 6.5 million households out of a total of 67 million have
home water softeners (1970 data), approximately 10 percent. The 6.5 million
households are primarily in hard-water areas. According to the Water Quality
Association (water softener trade association), the "prime market" for home
softeners is 14.8 million to medium and high-income families who reside in
single family dwellings in hard-water areas. About 40% of such families have
water softener appliances. In hard-water areas, the presence of a home water
softener or a city wide service can significantly reduce laundering problems
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as well as laundering costs through savings in detergent, additives, and
energy. The softener can reduce home water heating costs as well. Where
non-phosphate, carbonate-built detergents are used, a home softener can
eliminate most of the precipitate and its associated problems. While the
prevalence of home softeners in hard water areas can decrease the total
cost of a ban, it also implies that a relatively greater cost burden rests
on lower income families who cannot afford water softeners, unless such
families commonly use laundromats with water softeners. Given the advantages
of water softeners in energy savings, laundering, etc. more municipal water
systems may find it advantageous to add water softening to the water treat-
ment process.
Availability of Non-Phosphate Product
Because of the large number of jurisdictions now enforcing phosphate
bans (see table 2-4), a large variety of non-phosphate products are now
available for use and new products are constantly under development. The
availability of non-phosphate products to serve a particular ban would, of
course, depend on the particulars of the deadline and the distribution net-
work in the area involved. There appears to be no particular supply problem
so long as a reasonable time is provided for changeover.
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ACKNOWLEDGEMENTS
Many people assisted the Committee in its work. A draft version of
this report was circulated for review to members of the academic and
professional community, and to concerned governmental and industrial
representatives. Numerous individuals contributed to the report and
the Committee is indebted to them. Although it is not possible to
reference each contribution, the Committee is extremely grateful to
the reviewers for the significant data and information incorporated
due to their efforts. In particular, I want to acknowledge the con-
tinued assistance of Mr. Nelson Thomas, Chief, Large Lakes Research
Branch, and the staff of the Large Lakes Research station for their
research work and valued advise; and Dr. Joseph V. Yance, Economist,
Office of Water Planning and Standards, EPA Headquarters for his
incisive critique. The Committee, of course, undertakes full respon-
sibility for the substance of the report, the conclusions, and the
recommendations contained in it.
I am especially grateful to the members of the Committee for their
technical and editorial support; Lee Botts, Deputy Director, Office
of Public and Inter-Governmental Affairs, Steven L. Dudas, Sanitary
Engineer, Water Division, Dr. Paul Pan, Sanitary Engineer, Municipal
Construction Division, Office of Program Operations, EPA Headquarters;
David C. Rockwell, Physical Scientist, Surveillance and Analysis
Division, Joseph R. Tynsky, Sanitary Engineer, Office of Great Lakes
Coordinator, and Howard B. Zar, Physical Scientist, Enforcement
Division.
I want to thank Judith Hays, Delores Jackson, Theressa Jones, and
Doris Longo for their dedicated secretarial efforts in typing and
modifications of the report.
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-905/2-77-003
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
DETERGENT PHOSPHATE BAN
5. REPORT DATE
June, 1977
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
Region V Phosphate Committee
Donald A. Wallgren, Chairman
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Office of Regional Administrator
Analysis Division
US EPA, Region V
Chicago, Illinois 60620
The Surveillance
10. PROGRAM ELEMENT NO.
2BA644
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Region V
230 South Dearborn Street
Chicago, Illinois 60604
13. TYPE OF REPORT AND PFRIOD COVERED
Final
14. SPONSORING AGENCY CODE
EPA 905/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT ~~ ~
It is essential that steps be taken immediately to reduce the rate of eutrophication
of lake waters and streams in the Great Lakes Basin. Reducing the limiting nutrient
phosphorus input is the soundest measure toward reducing this rate and with present
technology, the only readily controllable source of phosphorus input is sewage
effluent. While treatment plants will remove phosphorus, they have not met design
expectations consistently and in many cases, construction has lagged because of
lack of funds. An immediate phosphorus reduction would be realized if phosphorus
were banned in detergents. This is now economically and technically feasible
and practical based on actual experience in areas where bans have been in effect.
Substitutes for phosphorus are available that are safe and environmentally more
acceptable. Therefore, U.S. Environmental Protection Agency, Region V, is now
recommending that detergent phosphorus bans be adopted in all of the States in the
Great Lakes Basin.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
c. COS AT I Field/Group
phosphorus
eutrophication
phosphorus removal
sewage effluent
phosphate
18. DISTRIBUTION STATEMENT
Document is available to the public throug
the National Technical Information Service
Springfield. Virginia 22151
19. SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
66
,20 SECURITY CLASS (This page)
Unclassified
22. PRICE
EPA Form 2220-1 (Rev. 4-77)
PREVIOUS EDITION IS OBSOLETE
U.S. GOVERNMENT PRINTING OFFICE. 1977 — 750-O64/I4O2
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