&EPA
United States
Environmental Protection
Agency
   Res National
5rogram Office
536 South Clark Street
Chicago, Illinois 60605
                                        905R85110
             The Environmental and Economic
             Impacts of Detergent Phosphorus
             Bans on Great Lakes Municipal
             Wastewater Treatment Systems
                   Volume  I

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                                                      EPA-68-04-5017
                                                      March,  1985
                                                               PEER REVj£yy

                        Draft Report
           The Environmental and Economic Impacts
                             of
          Detergent Phosphorus Bans on Great Lakes
           Municipal Wastewater Treatment Systems
Project Managers:    King K. Moy, P.E. ESEI/EcolSciences,  Inc.
                     John E. Racek, P.E. Williams and Works


Technical Advisors:  Charles LaFrance, Ph.D., ESEI/EcolSciences, Inc.
                     Albert Posthuma, P.E., Williams and Works
EPA Project Monitor: Paul Horvatin
             Great Lakes National Program Office
                         ^Region V -
            U.S.  Environmental Protection Agency
                   536 South Clark StrSet
                  Chicago,  Illinois  60605

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                                   Volume 1

                               Table of Contents

Section                                                                   Page

1.0  SUMMARY AND CONCLUSIONS	      1

2.0  INTRODUCTION  	      2

     2.1  Background	      2
     2.2  Purpose of Study	      2

3.0  SELECTION OF REPRESENTATIVE MUNICIPAL WWTPs 	      5

     3.1  Preliminary Screening  	      5
     3.2  Final Screening  	      7

4.0  EVALUATION METHOD 	      8

     4.1  Quality Control Protocol  	      8
     4.2  Data Request Checklist 	      8
     4.3  Technical  Assumptions  	      9

5.0  ASSESSMENT OF ENVIRONMENTAL AND ECONOMIC IMPACTS OF 	    11
       DETERGENT PHOSPHORUS BAN

     5.1  Validity of the Selected  Sample Plants 	    11
     5.2  Flow Evaluation	    15
     5.3  Influent Pho'sphorus Loading Evaluation	    15
     5.4  Effluent Phosphorus Evaluation 	    18
     5.5  Cost per Pound  of Phosphorus Removal	    18
     5.6  Cost per Capita per Year  Evaluation	    22

6.0  TEST CASE	    24

     6.1  Phosphorus Loading Evaluation  	    24
     6.2  Cost Evaluation	    26
     6.3  Conclusion	    26

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                                List of Tables
Table
1
2
3
4

5
6
7
8
9

Data Summary of Selected WWTPs 	
Validity of the Selected Sample Plants 	
Comparison of Flow (mgd) Between P-Ban and 	
Non P-Ban States
Comparison of Influent Total-P (ppm) Between 	
P-Ban and Non P-Ban States
Comparison of Influent Total-P (Ib/capita/year) . . .
Between P-Ban and Non P-Ban States
Comparison of Effluent Total-P (concentration in ppm).
Between P-Ban and Non P-Ban States
Cost Comparison ($/lb P Removal) Between P-Ban and . .
Non P-Ban States
Cost Comparison (Cost of P Removal $/capita/yr) . . . .
Between P-Ban and Non P-Ban States
Comparison of Influent Phosphorus Between Pre and . .
Page
12
14
16
17

19
20
21
23
25
Figure
  1
Appendix
  A

  B
  C
  D
               Post Bans at Midland WWTP, Michigan
                                List of Figures
Great Lakes Basin
                 List of Appendices

Status of Detergent Phosphorus Legislation in the
  Great Lakes Basin
Data Quality Assurance Protocol
Data Request Checklist
Statistical Evaluation
Page
  3

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 1.0   SUMMARY  AND  CONCLUSIONS
      A  total  of 24 representative WWTPs were selected  in  the  Great Lakes Basin

 to  determine  the  environmental  and economic  impacts  resulting  from detergent

 phosphorus  bans.    The sampled  WWTPs  were  selected  on the  basis  of  effluent
 compliance,  laboratory quality control, record  keeping and limited industrial

 waste contribution.   The WWTPs  were also  visited  and data were statistically

 analyzed  to  ensure  the  validity of  the  results  which   included  considerable

 inputs  from individual  plant personnel.
               ^.                     .
      The analysis included comparisons of influent phosphorus loading, effluent

 phosphorus  loading,  and  costs between  WWTPs  in  both  states with  and without

 detergent phosphorus bans.  The findings of this study are as follows:


      •  Detergent phosphorus  bans have  produced  a  23  percent  reduction
         (from 5.6  ppm  to 4.3  ppm)  in  total  influent  phosphorus  concen- \
         tration  and  a 32  percent  reduction (from  3.10  to  2.10 lb/capita/  \
         year)   in  influent   phosphorus  loading  per  capital  per  year.  c   f  v^. I'
         Therefore,  it can be  extrapolated  that  phosphorus loading  to the    ' • L^V-^
         Great  Lakes due  to combined sewer  overflows  (CSO)  will  be  reduced   • oA^'v.j <-^
 r        as  a  result  of detergent  phosphorus bans.                            , / , ,.  -y^
                             s                                               yufcl V\ K ^
      t  There  is no  reduction in effluent phosphorus  concentration  from         2 ///<
/        WWTPs  with  detergent  phosohorus  bans comoared  to  WWTPs  without ^^
  '/     detergent phosphorus  bans  (0.71 ppm  vs. 0.70 ppm).
      •  There  is a  47 percent reduction  in  average  cost  per capita per
         year  for phosphorus removal  attributable  to  detergent  phosphorus
  '       ban (from 2.44 to 1.29 $/capita/yr) . ' However,  the cost  per Ib of
       ^tiosphorus  removed is  approximately the  same J,$0.88/lb  P-removal)
         regardless  of detergent phsophorus  bairs.       &&-> j    ._ /  /. (I
              ,                      O  t''T    • > .      . / j.'l -^.M' X"Si_^ c*r~ 7X i*-*~ t~
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 2.0   INTRODUCTION
      2.1  Background
      Pursuant to the Great Lakes Water Quality Agreements of  1972  and  1978, the
 United States and Canadian Governments agreed to develop and  implement programs
 to reduce phosphorus  loading  in  order to control accelerated eutrophication of
 the  Great  Lakes.    Measures  undertaken  by  the  two  governments  include the
 following:

      •  Construction and operation of municipal wastewater treatment
        plants (WWTPs) with phosphorus removal;
      •  Implementation of industrial pretreatment program;
      •  Control of nonpoint sources;
      •  Limitation of phosphorus in detergents sold for use within
        the Great Lakes Basin.

      The  United States did not enact legislation to limit phosphorus content of
 detergents  on  a  national  basis.    Each state  was  allowed  to  pass   its own
 legislation on the basis of  costs and benefits  in  limiting  phosphorus content
 in detergents.   The eight states  which  border  the  Great  Lakes  are Illinois,
 Indiana,  Michigan, Minnesota, New  York,  Ohio,  Pennsylvania,  and Wisconsin (see
 Figure  1).   Currently,  all  Great  Lakes  States  except  Ohio,   Illinois  and
 Pennsylvania have  legislation  limiting  laundry detergents  to  0.5  percent.
 Cities of Chicago  and Arkon  which have  local  bans  are  the exception  in the
 States of Illinois  and Ohio.   The status  of  past  and current  legislation  to
 limit  the phosphorus  content of  detergents  in  the  Great   Lakes  States  are
 summarized in Appendix A.

     2.2 Purpose of Study
     The  purpose of  this  study  is to  quantify the environmental  and  economic
 benefits  of  phosphorus ban  (P-Ban)   in  detergents  by  analyzing  the  influent
phosphorus loadings  and  operation and maintenance  (O&M)  costs of representa-
tive  sample  municipal  WWTPs   in  the Great  Lakes  Basin.   The  selected  sample
  \
      \\\^ \ 'VV ~^*-s          \
      I  \             J
                                      -2-

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                                                                          ui;
                                                                           III
                                                                                                       
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                                                                                                              O
                                                                                                      CO

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                                                 -3-

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WWTPs  will  be evenly distributed  between P-Ban and  Non  P-Ban  states  so that
comparisons  could  be made  to determine  the  following impacts  (if  any)  as  a
result of detergent P-Ban:

     •  Impaction of WWTP influent phosphorus loadings in ppm and Ib/capita/yr;
     0  Impact on WWTP effluent phosphorus loadings in ppm;
     •  Impact on cost per Ib of phosphorus removed;
     •  Impact on cost per capita per year for phosphorus removal at  WWTPs.

     Statistical  analyses will  be  employed  to  ensure  the  validity  of  the
results.  Results derived from this  study in  conjunction  with previous studies
would enable USEPA as well as other State and local  government agencies to make
sound legislative decisions concerning phosphorus ban in detergents.
                                   -4-

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             f
            I
 3. Ql SELECTION  OF  REPRESENTATIVE  MUNICIPAL  WWTPs
-. •/? - *•
 *-'-*   A total, of 287  U.S.  Municipal  WWTPs  were identified  in  the Great  Lakes
 Basin by the Water Quality  Board  of  the International Joint Commission (IJC).
 Information. for each  facility  was compiled  in an  inventory  of the  November,
 1983  IJC Study  (Appendix  A of a  Review of  the Municipal Pollution  Abatement
 Programs in the Great  Lakes Basin).    This document  formed the basis  for  the
 selection of  the representative municipal WWTPs for this  study.

      The selection process  consisted  of  two  phases:    preliminary   and  final
 screenings.   The goal  of  the preliminary screening was to reduce the  number of
 facilities  to a manageable  number (i.e. under  75  plants) where more detailed
 analysis could  be  conducted as part  of the final  screening.   The  goal of  the
 final   screening  process  was  to  further  reduce  the  number  of  plants   to
 approximately '25 so that  an  analysis  (including a field trip to  each  facility)
 could  be  performed   on   the  environmental   and   cost  impacts  of   detergent
 phosphorus  ban.  \  ^ ,        ^ ,V';U^  v^u^  b'T
                  ^
                                                                    "'
      3.1  Preliminary Screening     "^
      The  first step of  the preliminary  screening  process  was  to  review  the
 followingxfocuments to derive certain  information  for  screening:
         A  Review of Municipal Pollution Abatement Program  in the Great
         Lakes  Basin (November,  1983), Municipal Abatement  Task Force  of
         Water  Quality Program Committee.
      •   Results of Round Robin  on-Total Phosphorus  in Municipal WWTP
         effluents.    -. _  "7 -•-       '
      •   Detailed Review of Thirty Municipal Wastewater Treatment
         Facilities in the Great Lakes Basin; Canviro Consultants LTD.
      •   CSO loadings inventory  for Great Lakes Basin; GCA  Corporation.
      •   Evaluation of High-Performance Phosphorus Control  POTWs in the
         Great  Lakes Basin; Illinois  Institute of Technology.     ^
      t   Municipal October, 1981 -.September, 1982 Total Phosphorus--
         Control.         5 "   '
      •   1983 U.S. Great Lakes Point  Source Discharge Inventory  f  ,-
         (October, 1983), Great  Lakes National Program Office.^ - '
                                      -5-

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       Information  derived  from the  above  documents  included:   percentage  of
  industrial   flows,   general   performance  of  facilities,   laboratory  quality
^.control,  and type of  sewerage facilities  (combined  or  sanitary system).   The
  above  information was  then incorporated into  Appendix  A of the  November,  1983
 fIJC  Report.   As a supplement, field trips  and telephone contacts were  made  to
  EPA  Region  II (NYC  and  Edison,  NJ)  and Region V,  Michigan DNR, Wisconsin  DNR
  and  New  York  DEC  to-collect  the  following  information:
      t
      t
        DMR-QA\fo^ 1981, 1982 and 1983. MJith the exception of a few
        planish most of the 1981 DMR-QA were not available. )
        Discharge Monitoring Report Results (Files of EPA region II and V,
        Michigan DNR and Wisconsin DNR).

        User Charge System Summary Sheets (EPA, Region V).

        1984 Needs Survey for New York State WWTPs (EPA, Region II) and
        copies of New York State permit applications.
                                                                      t   *•. *
     t  EPA Field Inspection Forms and Handwritten Comments
        (£PA Region II and V).
         V.^
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      Application of the  above rules resulted  in the elimination of 220 WWTPs:
Total
WWTPs
18
97
6
63
65
3
35
287
WWTPS
Eliminated
12
83
3
48
48
2
24
220
WWTPs Survived First
High Rating
1
6
0
2
8
0
7
24
Screening
Marginal
5
8
3
13
9
1
4
43
      Indiana
      Michigan
      Minnesota
      New York
      Ohio
      Pennsylvania
      Wisconsin
           Total

      It  should be noted that the DMR-QA  and Round  Robin  Laboratory  results  were
 not  used to  eliminate  any facilities.  They were used  in conjunction  with other
 criteria to  support the selection  or  elimination  process.   Those  plants  that
 survived the preliminary screening  process were then yanked  as  "High  Rating"  or
 "Marginal" for final screening.        ,        fti^^'
                                     ,  'M • v '•'•
                                    "AA/  f
                                 c-r   /"                       -      • '  *     i '
      3.2 Final  Screening          '  /-                           _.,'••
      Once the  preliminary  screening  process  was  completed,  DSE^A  requested
 inputs from  individual  State^ concerning the suitability  of the "High Rating"
 plants  and requested  recommendations  for  alternative  (backup)  plants.   As  a
 result of their  inputs, one "High Rating"  plant  was  deleted and six  "Marginal"
 plants were  added resulting in a total  of 30 final  plants.

      Following  the  selection of the final  plants,  notifications were forwarded
 to  the  municipal  WWTPs  detailing   the  intent  of the  study  and   requesting
 additional data (i.e. monthly operation reports, cost records, chemical useage,
 etc.) for further evaluation.   As  a supplement,  telephone contacts were made  to
 provide the  chief operators or superintendents with more details  on the study.
 Subsequent to  the telephone conversations, three  more  plants  were eliminated
because  of their'nutrient deficient  wastes,  resulting  in a  total of  27 plants
for further field investigation.
                                      -7-

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4.0  EVALUATION METHOD
     Upon  completion  of the screening process,  field  investigations were  made
to individual plants to collect operation/cost data for the  analyses.   Prior  to
initiation  of the  field  investigations, three  major  tasks  were  developed  to
ensure the  effectiveness  of the trips and  the  validity of  the  analyses, to  be
performed  later.  These three tasks were:

     •  Determination of the adequacy of the plant quality control program
        (formal or  informal)
     •  Preparation of  a Data Request Checklist
     •  Outlining the technical assumptions which might affect the data
        collection  procedures and results of the analyses.

     4 . 1  Quality Control Protocol               /v « -*•" ? ' ''
     A protocol was developed to evaluate the quality control/assurance of  each
selected  WWTP.    A  copy  of the  protocol   is  provided in  Appendix  B  of  this
report.   During each  plant field  investigation,  the  protocol  was  used  as   a
guide  for  inspecting  lab  equipment,  standard  lab  analytical   procedures,
sampling  procedures,  chemical  feed  rate  meteri-ng,   sludge metering, record
keeping procedures  and other features which might affect the study.
     The  infection  staff  consisted of  either  one licensed  engineer with one
licensed  operator  or chemist.   One person  addressed  data collection  and the
other for  quality  control  inspection.    All  inspection teams  realized  that no
plant would  achieve  a perfect score. •  In
                                          •     -.-:  -        .^0.
fojrmaljQiiaJ-i±y~-A&sur>ance ^Programs.  The  adequacy  or  suitability of a plant was
a subjective assessment  of  the team members after consulting  with the Project
Management Team.  The quality control  assurance inspections in conjunction with
the  availability  of operation  and  cost  data  resulted  in  the  elimination  of
three more plants, leaving 24 plants remaining for cost analyses.

     4.2  Data Request Checklist
     A Data Request Checklist  was developed  to help  reduce the  time  needed  to
collect the data  during  the field investigation.  A copy of  the  Data Request
Checklist is provided in Appendix C.  Copies of the checklist were forwarded to
                                      -8-

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individual plants  so  that  available data could  be  gathered by plant  personnel
prior to  the  arrival  of  the inspection team.  Once  again,  no plant would  have
all the data  outlined  in the checklist.  Many  items  were optional which would
help  the  analyses  but  not  essential  to the  study.   Major  items  which  were
requested during the field trips included:

     0  Process flow diagram including  actual operating modes  versus
        designed modes
     t  Operation records  including flow rates, TP/TSS/BOD5
        concentrations,  and  sludge quantities
     •  Cost records including chemical, labor, fuel oil, natural  gas,
        electricity, maintenance and contract costs  (i.e. sludge
        hauling and/or landfill ing)
     t  Population of service area
     •  Quantity of industrial flow.

     When available,  data  requested  were for  both  fiscal year  1982  and 1983.
However, only single plant year data were considered suitable  in many  plants as
a result of operational  problems,  change  of  operation  modes,  and expiration of
phosphorus ban  (Wisconsin).   Fiscal year  1984  data were not  available during
the field investigation period (June to October, 1984).

     4.3  Technical Assumptions
     In order  to  perform  the analyses,  many  assumptions   were  made.   These
assumptions were made  prior to the  field trips and  then modified  to reflect
inputs from the plant personnel  at  the end of  the field  investigation task.
These major technical  assumptions  are:
     a. Sludge/ generated by  phosphorus removal were  calculated using
        stoichiometric equations between  phosphorus and  iron  or alum.
        Plant  operation  records were  used  to  determine the  overall
        percentage of chemical or P sludge to total sludge.
                  •Z* L,"^'"
     b. Labor''associated with phosphorus  laboratory testing  and  O&M of
        chemical  feed systems were  derived  from estimates  provided by
        plant personnel.
                                      -9-

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i?;
-<-<•-                    .'. -r  '•//•"  s ' \    ^'•?*£
 d.  All  energy  costs  for  chemical   pumping  were  considered   for
    phosphorus  removal.    Energy costs  associated  with  the  sludge
    handling   operation   were    calculated   using   chemical    sludge
    percentages derived under Item a.

,e.  No  capital  costs  for phosphorus  removal equipment were considered.

 f.  Sludge hauling  costs  were  considered  in cases  where hauling  was
    contracted  to  private contractors  (payment  on  basis  of  sludge
    quantity).   In  cases where sludge  hauling  was performed by  plant
    personnel,  labor  and  or energy costs were  considered  based  on
    inputs from plant staff.

 g.  Costs  for phosphorus  removal   were  determined  on  a per capita  per
    year  and  on a per pound  (Ib)  of  P removal basis.   Fiscal year  1982
  :  costs  were  indexed to  1983 dollars.

    Uniform   unit  costs  J5or  chemical,  energy   and   labor  were   not
  ' considered  because-- they  would  not  reflect  the   actual  plant
'T—,experiences in  the Great Lakes Basin.

""ir  During the  study period, two  plants  in the Non  P-ban states  did
    hot have  to pay  for  all of  their  chemicals  used for phosphorus
 /  removal.  This  may have produced a slightly lower cost difference
/   for phosphorus  removal between P-Ban and Non P-Ban states.  Sf^"-"V •?
     .
                                                                                    > n
                                    -10-

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 5.0  ASSESSMENT OF ENVIRONMENTAL AND ECONOMIC IMPACTS OF DETERGENT
     PHOSPHOROUS BAN
     Once  the cost  and  environmental  data  were  developed for  the  individual
 plants  (see  Volume  2),  analyses  were performed  to evaluate  the  impacts of
 detergent  phosphorous  ban  and the validity  of  the data using  the  analysis of
 variance (ANOVA).  Items evaluated in this study include:   ,           .
                                                  f  • /   -- •',...-  U   "* -
      /          ^
     *  Validity of the selected sample plants
     •"BlaT'due to plant flow (mgd) for selected P-Ban and Non P-Ban WWTPs
     •  Impacts on municipal WWTP influent loadings (ppm and Ib per capita/yr)
     t  Impacts on municipal WWTP effluent loadings (ppm)
     •  Impacts on cost of phosphorus removal ($/lb P Removal and $/capita/
        year)

     Prior to the evaluation and statistical analyses, operation data of the 24
selected  municipal   WWTPS  were  tabulated  (Table  1)  for  comparison.    Data
provided  in  Table  1  represents  the  average  of  Fiscal  Years  1982 and  1983*
although  onTy^single7 ph&qt ,year  da^a was'  used  for  some of  the  'selected
facilities.            °"""' *  *"  ''\                                        I
                                                                            ft -'<
     The  following  sections address the  results  of the  above-subjected  items
individually.

     5.1 Validity of the Selected Sample Plants
     The  validity of  the selected  sample  plants was  tested by comparing  the
flow (mgd) data for the 24  sample  plants  and  the flow data  for  all  WWTPs  with
flows of 1 mgd or higher in the entire Great Lakes Basin.  The statistical  test
demonstrates that the selected  sample of 24  WWTPs  is a  valid,  representative
sample of  Great Lakes Basin WWTPs.
                      --                                 - ,., ,,
     The data  are  summarized in Table  2.   There  are 275 - WWTPs  in  the  Great
Lakes Basin  with  flows of  1 mgd  or higher.   Of  these,  24  are the  "sample
population"  for this  study.   To insure  independence of the  data the  sample
population  was  removed  from the  "statistical  universe"  for the  test of  the
validity of the sample,  leaving 251  WWTPs  in  the  statistical  universe.   The
                                     -11-

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                                    Table 2
                     Validity of the Selected Sample Plants

Sample Population

     n= 24     Iy=400.67         2^=14511.54

                y= 16.69          S2=  340.11


Statistical Universe (excluding sample population)

     n=251     Ey=2907.69        Iy2=612799.74

                y=  11.58         S2=  2316.46


Total

    in=275    ZEy=3308.36       Z£y2=627311.28

                y=  12.03         S2=  2144.20


o  Test for Homogeneity of Variance

     Fs = 6.8109 *(therefore, ANOVA cannot be used)


o  Cochran and Cox  t   = 1.056  n.s.
                  t05   = 2.034
                                   -14-

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 statistical  test  was  set up to determine (shether/or not the  sample  population
 of  24 WWTPs  are  taken  from the  same  popuratton  as  the statistical  universe.
 Since the test for homogeneity of  variances detected heterogeneity,  the  ANOVA
 could not be  used.   Instead,  Cochran and  Cox's  procedure for  a t-test  with
 unpaired  observations and  unequal variances  was  used.   This  test  result  was not
                                                                      ~X      f.
 significant;  t=1.0564 is well  below the critical value,  tg5=2.0339.      '<• ,• <..,/,

      5.2  Flow Evaluation
      There  is no  reason to  believe that detergent  phosphorus bans will have any
 causal relationship to flow.   Statistical comparison confirms that there  is  no
 difference  in flow (mgd) between  the two  groups  of WWTPs.  Flow was tested as  a
 means  discovering any inadvertent biases  introduced by  the sampling design.

      Although  the mean  flow  at  WWTPs  with  phosphorus  bans  of 21.2  mgd  seems
 intuitively to be different from  the mean flow at  WWTPs  without phosphorus bans
 of  12.0 mgd,  the  underlying WWTP  flows are  not different.   The F ratio  of 2.96
 for the analysis of variance  (Table 3) is less than  the critical  value  of 4.08
 associated with the 95 percent confidence level.-,  Therefore, there is  no reason
 to  reject the hypothesis  that the flow of  WWTPs with  phosphorus bans  and the
 flow  of WWTP's without phosphorous bans are  the  same.                        ,
     5 . 3 Influent Phosphorus Loading Evaluation      W l
     Detergent  phosphorus  bans  have  produced  a 23  percent reduction  in the
total  phosphorus^entering  the  WWTPs  of  the  Great  Lakes  Basin.    The average
loadings on WWTPs/ in states with detergent phosphorus bans are 4.3 ppm compared
to  5.6  ppm in  states  without  detergent  phosophate  bans.    This  difference is
significant  (probability greater than 95 percent),  with  an F ratio  of   10.68
(Table 4).  The, assumptions of the analysis of variance (ANOVA) are met because
the test of homogeneity of  variances,  yielded an Fs^ratio of 1.13 which is well
below the critical  value of 2.12 at the 95 percent!  confident level.   The other
ANOVA  assumptions  are  discussed in the  section entitled  "Statistical  Evalua-
tion" (Appendix
                                     -15-

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               Comparison of Flow (mgd)

                          P-Ban
 Table 3
Between P-Ban and Non P-Ban States

                            Non P-Ban
WWTP
Indiana
Ft. Wayne
South Bend
Michigan
Ann Arbor
Benton Harbor-
St. Joseph
E. Lansing
Gr. Rapids
Midland
New York
Monroe NWQ
N. Tonawanda
Tonawanda
Monroe GCO
1982
y

34.1
43.6
18.3
7.5

11.1
56.9
6.8

11.1
-
17.2
12.2
1983
y

35.1
38.0
-
8.2

11.3
56.1
6.5

12.3
6.9
17.8
12.8
n=20    Iy=423.8 Ey2=14169.84                 n=19

         y=21.2    S2=273.13

                   IN=39   ZZy=650.8 Z£y2=22098.90

                              y=16.7      S2=295.76

                             o  Test  for Homogeneity
WWTP
Ohio
French Cr.
Lima
Lorain
Maumee River
Oregon
Painesville
Willoughby-
E. Lake
Wisconsin
De Pere
Fond Du Lac
Manitowoc
Milwaukee-
S. Shore
Oshkosh
Sheboygan
ly=227.00
y=12.0
1982 1983
y y
1.8 1.9
16.0 12.7
18.4 16.4
6.7
2.6 4.0
3.9 3.3
8.5 7.5
3.9
7.5
9.9
79.0
11.2
11.8
Ey2=7929.06
S2=289.83
                             Fs  =  1.0611  n.s.  variances  are  equal


                             o   ANOVA  Table

                             Source      df       ss
                            B/T          1    832.36
                            W/I         37   10406.52
                            Total       38   11238.88
               ms

              832.36
              281.26
2.9594 n.s.
means are
different
                                         -16-

-------
                                          Table  4
          Comparison of  Influent Total-P  (ppm) Between  P-Ban  and Non  P-Ban  States
                         P-Ban
n=20
                             Non P-Ban

WWTP
Indiana
Ft . Wayne
South Bend
Michigan
Ann Arbor

1982 1983
y y

5.7 7.7
2.1 1.9

5.0

1982
WWTP y
Ohio
French Cr. 7.1
Lima 4.2
Lorain 6.7

Maumee River
1983
y

6.5
4.1
6.2

4.4
Benton Harbor- 5.1 4.3
St. Joseph
E. Lansing
Gr. Rapids

Midland

New York
Monroe NWQ

N. Tonawanda

Tonawanda

Monroe GCO


Zy=85.40
y=4.3

5.2 5.3
3.8 3.5

4.1 3.9


4.7 4.3

2.4

3.9 3.0

5.0 4.5


Zy2=398.94
S2=1.80
Oregon 4.8
Painesville 5.2
Willoughby- 6.1
E. Lake

Wisconsin
De Pere

Fond Du Lac

Manitowoc

Milwaukee-
S. Shore
Oshkosh
Sheboygan
n=19 !y=107.10
y=5.6
4.0
5.3
6.2



6.7

8.3

7.2

5.4

4.0
4.7
Iy2=632.49
S2=1.60
                     ZN=39   EZy=192.50   E£y2=1031.43

                               y=4.9         S2=2.14

                      o   Test  for  Homogeneity

                      Fs  =  1.1250  n.s.

                      o   ANOVA Table

                      Source          df       ss       ms
                      B/T
                      W/I
                      Total
 1     18.20   18.20
37     63.07    1.70
38     81.27
 F

10.68 *
                                       -17-

-------
     The test for homogeneity of variances yielded an Fs ratio of 1.43 which is
well within the critical value of 2.12, so the  analysis  of  variance is a valid
test.
                                     -18-
      When   influent   phosphorus  is  expressed  in  pounds  per   capita   (3.10
 Ib/capita/yr  in Non P-Ban  States  and 2.10 Ib/capita/yr  in P-Ban States),  the   ^ w
 reduction  attributable  to  detergent phosphorus  bans  is  32  percent.    This ^^
 difference  is  also  significant (probability greater than 95 percent), with  at   f
 ratio of 3.336  (Table  5).   The test for homogeneity of variances  yielded  an  Fs
                                                                             ^-«—-•*'
 ratio of  5.59  which  is  not  below  the critical  value  of 2.12  (95 percent
 confident  level), so  Cochran and Cox's  t-test was used to  test significance  of
 the  means.

      5.4 Effluent Phosphorous  Evaluation
      There  is  no reduction in  effluent  phosphorous  concentration  from  WWTPs
 with detergent  phosphorus bans  compared  to WWTPs  without  detergent  phosphorus
 bans.   The  average  discharge  of  0.71  ppm with  detergent  phosphorus  bans  is
 indistinguishable from the  0.70  ppm discharged without the  detergent  phosphorus
 bans.  The analysis of variance  (Table 6) yields  an F ratio of only  0.03  which
 is an order  of  magnitude less than the critical value of 4.08 associated with
 the  95 percent  confidence  level.  The Fs  ratio test of homogeneity of variances
 produces a value of 1.68 which  is well  below  the  critical value of 2.12 at the
 95 percent confidence  level.   Therefore,  the  ANOVA  test  is valid.  There  is  no
 evidence to reject the hypothesis that  all  WWTPs  in the Great Lakes  Basin form
 a  single population  with respect to  effluent  phosphorus  concentration,  with a
 sample mean of  0.70 ppm, and a sample variance of 0.04.
     5.5 Costs per Pound of Phosphorus Removal
     Although  the WWTPs  with detergent  phosphorus bans  have  sligteiy- lower
costs  per  pound  of  phosphorus  removal  than  do the  WWTPs  without  detergent
                                     5Ml-<^J-^jc- **j
phosphorus bans, the difference  is not .significant.  The F ratio of 1.86 (Table
7)  is   less than  the  critical  value  of  4.08  associated  with  the  95 percent
confidence level.  Thus there  is  00" evidens^-to-H^e^eet— tte- hypothesis 4&at the \ F'V
                                                                                  /
average cost per  pound  of phosphorus removed  ($0.88/lb) is  imtep-endent  of- they I1*-"
phosphorus ban.                                              Kcf/ '^^^ ^^/ ** L

-------
                                         Table 5
   Comparison of  Influent Total-P (Ib/capita/year) between P-Ban and Non P-Ban States
                         P-Ban
WWTP
Indiana
Ft. Wayne
South Bend
Michigan
Ann Arbor
Benton Harbor-
St. Joseph
E. Lansing
Gr. Rapids
Midland
New York
Monroe NWQ
N. Tonawanda
Tonawanda
Monroe GCO
1982
y
2.33
2.49
2.66
1.81
2.06
2.53
2.17
1.66
-
1.57
2.72
1983
y
3.29
1.90
_
1.67
2.02
2.29
1.96
1.69
1.40
1.25
2.97
Non P- Ban
1982
WWTP y
Ohio
French Cr. 2.48
Lima 3.44
Lorain 4.76
Maumee River
Oregon 1.72
Painesville 3.30
Willoughby- 3.52
E. Lake
Wisconsin
De Pere
Fond Du Lac
Manitowoc
Milwaukee-
S. Shore
Oshkosh
Sheboygan
1983
y
2.49
2.71
3.90
1.40
1.96
2.99
3.10
2.78
4.06
6.70
1.99
2.60
2.94
n=20    Zy=42.02 Zy2=93.23                   n=19    Zy=58.84  Zy2=208.45

         y=2.10   S2=0.26 (variance)                    y=3.10     S2=l .46  (variance)

                          ZN=39  ZZ y=100.86 ZZ y2=310.05

                                   y=2.59      S2=1.30

                           o   Test  for  Homogeneity

                           Fs  = 5.59*

                           o   Cochran and Cox     t =  3.336  *
                              critical  value,   tgs =  2.100
                                        -19-

-------
                                          Table 6
Comparison of Effluent Total-P (concentration in ppm)  between P-Ban and Non P-Ban States
                          P-Ban
                                     Non P-Ban
 n=20

WWTP
Indiana
Ft . Wayne
South Bend
Michigan
Ann Arbor

1982
y

0.71
0.36

' 0.80

Benton Harbor- 0.80
St. Joseph
E. Lansing
Gr. Rapids

Midland

New York
Monroe NWQ

N. Tonawanda

Tonawanda

Monroe 6CO


Zy=14.19
y=o.7i

0.93
0.91

0.30


0.97

0.62

0.60

0.91


Zy2=11.14
S2=0.06
1983
y

0.91
0.30

-

0.60

0.88
0.93

0.26


0.88

-

0.66

0.86




1982
WWTP y
Ohio
French Cr. 0.80
Lima 0.56
Lorain 0.82

Maumee River

Oregon 0.90
Painesville 0.47
Willoughby- 0.80
E. Lake

Wisconsin
De Pere

Fond Du Lac

Manitowoc

Milwaukee-
S. Shore
Oshkosh •
Sheboygan
n=19 Zy=13.27 zy2=9.87
y=0.70 S2=0.03
1983
y

0.90
0.52
0.84

0.50

0.90
0.47
0.90



0.50

0.64

0.74

0.65

0.41
0.95


                ZN=39   ZZy=27.46  zzy2=21.02

                          y=0.70     S2=0.04

                 o  Test for Homogeneity
                 Fs = 1.6834 n.s.

                 o  ANOVA Table

                 Source          df      ss
                 B/T
                 W/I
                 Total
 1
37
38
0.0012
1.6829
1.6841

  -20-
 ms      F

0.0012  0.0263 n.s.
0.0455

-------
                                         Table 7
            Cost  Comparison  ($/lb P Removal) between  P-Ban  and  Non P-Ban  States
                         P-Ban
                                               Non P-Ban

WWTP
Indiana
Ft. Wayne
South Bend
Michigan
Ann Arbor

Benton Harbor-
St. Joseph
E. Lansing
Gr. Rapids

Midland

New York
Monroe NWQ

N. Tonawanda

Tonawanda

Monroe GCO


1982
y

0.26
0.74

1.16

0.45

0.50
0.50

1.02


1.27

-

0.45

1.02


1983
y

0.15
0.46

-

0.54

0.49
0.38

1.31


0.99

2.29

0.57

0.81


1982
WWTP y
Ohio
French Cr. 1.43
Lima 0.64
Lorain 0.52

Maumee River

Oregon 1.70
Painesville 0.88
Willoughby- 0.91
E. Lake

Wisconsin
De Pere

Fond Du Lac

Manitowoc

Milwaukee-
S. Shore
Oshkosh
Sheboygan
1983
y

1.25
0.23
0.57

2.41

2.12
0.92
0.88



1.19

1.25

0.74

0.36

0.71
0.37
n=20    zy=15.36    zy2=16.3910             n=19

         y=0.79      S2=0.2418

                    ZN=39   ZZy=34.44   zzy2=41.7688

                               y=0.91      S2=  0.2988

                      o   Test for  Homogeneity  of Variance
                      Fs  = 1.4284  n.s.

                      o   ANOVA Table

                      Source          df       ss
                               Zy=19.08    Zy2=25.3778

                                y=1.03      S2= 0.3454
B/T
W/I
Total
 1   0.5436
37  10.8120
38~  11.3556
  ms

0.5436
0.2922
                                                             1.8604 n.s.
                                        -21-

-------
     5.6 Cost per Capita per Year Evaluation
     There is a 47 percent  reduction  in  average costs per capita  per  year for
phosphorus removal attributable to detergent phosphorus ban.   The average costs
in  P-Ban  states  was  $1.29/capita/year  compared  to  $2.44/capita/year.    This
difference is statistically significant, with a Cochran  and  Cox's  t  test value
of  3.84  (Table 8)  compared to  a critical  value of  2.10  at  the 95  percent
confidence level.

     The test of homogeneity of variances yielded an Fs  ratio of 2.34  which is
not  within  the critical  value of  2.12 at  the 95  percent  confidence  level.
Therefore, the Cochran and Cox's  t test has to be used to  test  the significant
difference between the  mean  costs per capita per year in  P-Ban and Non P-Ban
states.
                                    -22-

-------
                                         Table 8
   Cost Comparison (Cost of P Removal $/capita/yr)  between P-Ban  and Non  P-Ban  States
                         P-Ban
                                                Non P-Ban
WWTP
Indiana
Ft. Wayne
South Bend
Michigan
Ann Arbor
Benton Harbor-
St. Joseph
E. Lansing
Gr. Rapids
Midland
New York
Monroe NWQ
N. Tonawanda
Tonawanda
Monroe GCO
1982
y

0.52
1.53
2.63
0.68

0.84
0.94
2.04

1.64
-
0.56
2.22
1983
y

0.45
1.53
-
0.77

0.81
0.62
2.37

1.29
2,27
0,54
1.63
n=20    zy=25.88

         y= 1.29
1982
WWTP y
Ohio
French Cr. 3.14
Lima 1.88
Lorain 2.13
Maumee River
Oregon 2.41
Painesville 2.63
Willoughby- 2.78
E. Lake
Wisconsin
De Pere
Fond Ou Lac
Manitowoc
Milwaukee-
S. Shore
Oshkosh
Sheboygan
1983
y
2.70
0.54
1.90
2.97
3.04
2.53
2.33
3.06
4.69
4.45
0.62
1.67
0.85
Zy2=43.2322            n=19     Zy=46.32

 S2= 0.5128                      y= 2.44

 ZN=39   IZy=72.20  Zly2=177.7584

           y= 1.85    S2=  1.1604

  o  Test for Homogeneity of Variance

  Fs = 2.3403 *

  o  Cochran and Cox  t = 3.8385 *
                      tos - 2.101
  £y2=134.5262

   S2=   1.2002

'1,30   '
                                        -23-

-------
      6.0  TEST CASE
           The  previous  sections  have  demonstrated  a  significant  reduction   in
      influent phosphorus loadings (ppm; Ib/capita/yr) and a significant cost  savings
      ($/capit a/year)  as a result of detergent  phosphorus  bans.   Based on the design
      of the present study, these conclusions  are valid for  regional  studies within
      the Great Lakes  Basin,  or for the entire Great Lakes Basin.

           It  is  tempting to  generalize  the  conclusions as  a  prediction  of  the
      effects of detergent phosphorus  policy on  individual  WWTPs.   To do  so would
      require extrapolation from the study data from  the pooled  regional  data to the
      individual  WWTP  operating  experience.    On the  other  hand,  if  it  could   be
      demonstrated  that such  extrapolations  are valid,  it would;  (1)  strengthen the
      conclusions,  and (2) provide  potentially  useful guidance  in  setting detergent
      phosphorus  policy;  i.e.,  instituting   a  ban  when   one  is  not  in  place,   or
      suspending  the ban when  it is in  place.
1  ,;•
   '''
     A r
."  /l<     To  achieve the verification that  the study conclusions can  be applied to
  .7  individual  WWTPs,  a representative  WWTP was selected.   The selected  WWTP was
. / '
u     the Midland,  Michigan facility,  for which  data  were  readily  available.   Only
      influent  phosphorus  loading  (ppm)  and costs/capita were analyzed to confirm the
      results.   The  data  used for  this  test  case study were  drawn from  different
     years than  those included in the  basin-wide study.                  •    ^^ ~1
          :•}•   '     i  -r '-''•• ' " ;             ;  :    .        .    ,   ' f,    .,  J  ,-'•"'
               '                                    /,     — — /,  -,  ,*•''••  */  ,
           6.1  Phosphorus  Loading Evaluation    / J'f ~t'l^t'1 '    ('• "'      j,£_,  '  -^ ••" ' >"''  ' «<
           There  was  a 31  percent  reduction in  the influent  phosphorus  loading (ppm)   ,^,
      at  Midland  as  a  result  of the detergent  phosphorus  ban  (Table  9).   Monthly S '"•-'•
      average  concentrations of phosphorus in  the  influent  wastewater  dropped  from
     6.4  ppm  in  July,  1976 -  June,   1977  (pre  ban) to  4.4 ppm in July,  1978  - June,
      1979  (post  ban).

           The  observed  reduction   in  phosphorus loading  is  significant,  with  a
     Cochran  and Cox,  t=6.068 compared  to  a critical value  of 2.^201  at  the  95
     percent confidence  level .  The Cochran and  Cox t-test  was  used as the test  of
     significance  because  the test for  homogeneity  of variance  was  significant,
     Fs=4.21 compared to  a  critical  value of 2.12.
                                          -24-

-------
                            Table 9
  Comparison of Influent Phosphorus between Pre and Post Bans
                   at Midland WWTP, Michigan
Pre-Ban (1976-1977)
Post-Ban (1978-1979)
Month
July
August
September
October
November
December
January
February
March
April
May
June
n=12 zy=76.2
y= 6.4
y
5.4
5.8
6.3
6.5
6.5
6.4
6.3
6.7
6.2
6.0
7.4
6.7
Zy2=486.62
S2= 0.25
Month
July
August
September
October
November
December
January
February
March
April
May
June
n=12 Zy=52.2
y= 4.4
y
5.0
4.6
4.7
5.2
4.1
4.8
5.3
5.4
2.1
2.7
3.9
4.4
Zy2=238.66
S2= 1.05
         Zn=24    ZZy=128.4    ZZy2=725.28
                    y=  5.4      S2=  1.67
          o  Test for Homogeneity of Varience
             Fs = 4.2144 *
          o  Cochran and Cox t  = 6.068 *
                            t05 = 2.201
                             -25-

-------

-------
      6.2  Cost  Evaluation
      Fiscal  year 1976-1977  (pre  ban)  and  1978-1979  (post ban)  data from  the
 Midland   WWTP  were  compared  to  determine  the  impact  caused  by  detergent
 phosphorus  ban imposed  in October,  1977.   The  1976-1977 costs were  updated  by
 indexing  the unit costs to  1978-1979 level.   The  indexed pre  ban  total cost  was
 $77,156  for phosphorus removal  of  $2.06/capita/year.   The  post  ban cost  was
 $57,514 for phosphorus removal or $1.53/capita/year.  This  comparison indicates
 a j:ost  reduction of  approximately 25.5 percent.   Further,  the costs per  pound
 of  phosphorus  removed between  pre ban  and post  ban were  approximately the same
 ($0.73/lb vs.   $0.75/lb,   respectively)   which   concurs  with the   statistical
 conclusion discussed in a previous section.

      6.3  Conclusions
      The  results and conclusions presented  in Section 5  were  based on a statis-
 tically valid  sample  of  basin-wide  conditions.   As  a  result,  the  conclusions
 can be used to describe the effects  of detergent phosphorus  policies generally
 in  the Great Lakes Basin. •  It  is  clear that regional  detergent phosphorus bans
 will  result in significant reductions  in the following parameters:
      •  Influent phosphorus  loading (ppm and  Ibs/capita/year)
      •  Costs  ($/capita/year)

      Section 6  presented a test case to confirm that these same conclusions can
 be  generalized to  predict what  would  happen on  an  individual  WWTP  case  if a
 phosphorus ban were  adopted.   It was  confirmed  that  there  was  a significant
 reduction  in   influent  phosphorus loading  (ppm)  and that  cost  savings  were
 consistent with  basin-wide  results  when  a  post  ban  fiscal  year  was compared
 with  a pre ban  fiscal  year for the Midland,  Michigan,  WWTP.

     Therefore, the conclusions  of the study are  valid  equally  for   individual
WWTPs in the Great Lakes  Basin and for  basin-wide studies.
                                     -26-

-------
APPENDIX A

-------
             DETERGENT   PHOSPHORUS   LEGISLATION
JURISDICTION
DATE
EFFECTIVE
ALLOWABLE
PU)
DETERGENTS INCLUDED
REFER-
ENCES
 Michigan - cont'd.
               01/81 to present
  Detroit
 (07/72)
Minnesota
New York
             01/72 to 05/73 '
             06/73 to present
Erie County  05/71  to 12/71
             01/72
Syrr.;.use     07/71
Ohio
  Akron
             02/71 to 06/72
              None*
07/72 to 12/72
01/73 to present
                     28.0
                                 (0.5)
01/77 to present     0.5

01/77 to present    11.0
                     8.7
                     0.5
                     8.7
                     0.5
                     8.7
                     8.7
                                   8.7
                                   0.5
 - metal  brighteners, cleansers & 19
 treatment compounds, corrosion
 or paint removers,  conversion
 coating  agent,rust inhibitors,
 etchant, phosphatizer,
 degreasing compound, industrial
 or commercial  cleansers used
 primarily in  industrial and
 manufacturing  projects.
 - (City  ordinance enacted        10
 but pre-empted  by Act
 226 -  State of  Michigan-
 above).
 -  total  ban

 -  detergents  used  for house-
 hold  and commercial
 machine  dishwashing.

 -  household use, laundry use,
 other personal use,  indus-
 trial uses except  those for
 machine  dishwashers,  dairy
 equipment, beverage  equip-
 ment, food processing and
 industrial cleaning  equip-
 ment.
- excluded detergents used
for machine dishwashers;
dairy, beverage, food
processing and industrial
cleaning equipment.
- all cleansers
- excludes machine dish-
washers; dairy, beverage,
food processing and indus-
trial cleaning equipment.
                                                                             1-6,
                                                                              11
                                                                             12
2,3,16
1-5,16
6
13
6
1,3,4
2,14
                                                                            14
                                                                            2,4,5,
                                                                             14

-------
         STATUS OF LEGISLATION TO LIMIT THE  PHOSPHORUS CONTENT  OF  DETERGENTS
                              IN THE GREAT LAKES BASIN


             DETERGENT   PHOSPHORUS   LEGISLATION
JURISDICTION
DATE
EFFECTIVE
ALLOWABLE
Pii)
DETERGENTS INCLUDED
REFER-
ENCES
 Illinois
  Chicago


 Indiana
              None
/71 to 06/72
07/72 to present

01/72 to 12/72
01/73 to present
Michigan
07/72 to 09/77
10/77 to present
 8.7
 0.5

 8.7
 0.5
8.7
0.5
               01/81  to  present    14.0
 -  all  cleansers
 -  detergents.

 -  all  cleansers
 -  excludes  detergents used
 for  cleaning  in-place
 food processing and dairy
 equipment;  phosphorus acid
 products  including  san-
 itizers,  brightners,
 acid cleansers  and  metal
 conditioners; detergents
 used in household and
 commercial  machine
 dishwashers; detergents
 used in hospitals and
 health care facilities;
 industrial  laundry
 detergents; detergents
 used in dairy,  beverage,
 food processing and other
 industrial  cleaning
 equipment.

 - all cleansers
 - household laundry
 detergents
 - commercial machine  dish-
washers, dairy and farm opera-
 tion cleansers;  cleansers used
 in the manufacturing, prepara-
tion and processing of foods
and food products including
dairy,  beverage, egg, fish,
brewery, poultry, meat, fruit
and vegetable processing.
 1
 2
 1-5

 2,20
 1-7,
 20
2,8,17
1-4,
 9,18
19

-------
             DETERGENT   PHOSPHORUS   LEGISLATION
 JURISDICTION
      DATE
    EFFECTIVE
ALLOWABLE
   Ptt)
     DETERGENTS  INCLUDED
REFER-
ENCES
 Ohio
  Akron
              None*
02/71 to 06/72       8.7
               07/72 to 12/72       8.7
               01/73 to present     0.5
Pennsylvania                 None

Wisconsin      07/79 to 06/82**     0.5

                                    8.7
Canada
03/70 to 12/72
01/73 to present
  20.0

  8.7
  2.2
             - excluded detergents used
             for machine dishwashers;
             dairy, beverage, food
             processing and industrial
             cleaning equipment.
             - all cleansers
             - excludes machine dish-
             washers; dairy, beverage,
             food processing and indus-
             trial cleaning equipment.
- laundry detergents

- machine dishwashing
detergents and medical and
surgical equipment cleansers
- chemical water conditioners,

- laundry detergents.
                                  1,3,4
                                  2,14
                                                                 14
                                                                 2,4,5
                                                                  14
                                                                1,3

                                                                1,2,
                                                                 21
                                                                21
21

15,23
1,3,4
 6,23
  m/  !'   '  '
  ft' proposed 2.2% ban is  under  consideration.   Sadewicz,  John J.   July 11,  1983:
  Personal  Communication^.   Ohio Environmental  Protection  Agency.
**An reinstatement; of the  bans  ts  undor--conGidGrat'ion>  poscib-ly -comfnoncing
  January 1, 198^.  Schuettpelz, Duane  H.   July 12,  1983:   Personal  Communication
  Wisconsin Department of  Natural  Resources.

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APPENDIX B

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DATA QUALITY ASSURANCE PROTOCOL





              FOR





        MUNICIPAL POTWS
     PHOSPHORUS  BAN  STUDY
    EPA DELIVERY ORDER #16

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This  report  provides   protocols   for  evaluating  the  data  quality  control/
assurance of  each  POTW  selected  for this  study.   In  order  to  determine  the
validity of the data from the POTW for the purpose of this study, the following
areas will  be evaluated.

     I.    General  Laboratory Quality Assurance/Control

     II.  Quality  Control for Analytical  Performance  -
          a.   Phosphorus
          b.   Biochemical  Oxygen  Demand
          c.   Total  and Suspended Solids

     III.  Sampling  Procedures

     IV.  Flow Measurement  and Recording
          a.   Raw  Wastewater
          b.   Sludge Handling
     '7    c.   Chemical  Feed System

     v.    Recordkeeping  and Reporting

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                                        Name of POTW: _fe4.OcVr%
                                        Date:
                                        Reviewer:
I.   GENERAL LABORATORY QUALITY ASSURANCE/CONTROL

Quality control is an on-going  laboratory  responsibility  to assure the genera-
tion of data that is accurate.  Quality  assurance  is  the  result of a series of
checks and  balances monitoring  all  phases  of  the  measurement  process.   The
components of the quality control  program are described below.

                                              T
                                     -i-

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                                        Name of POTW:
                                        Date:  	
                                        Reviewer:
                                                                      Yes   No

     Laboratory Staff Responsibilities and Operational  Procedures

     a.   An individual  is responsible to implement and monitor
          laboratory quality assurance and control                      /
          Whom? _                       /

     b.   The analytical  procedures used are acceptable to USEPA       .
          Type: _        ^f

     c.   Laboratory bench sheets  and written procedures are used

     d.   Quality assurance check  samples are performed
          Frequency:
     e.   All  pertinent data  is  recorded in  laboratory  records         \/   _

     f.   Instrument or procedure malfunctions  or variances
          from acceptable  limits are  reported                          \/   _

     g.   Comments: _
2.   Distilled Water

     a.    Distilled  water  is  produced  in  laboratory  still
          Type : — ^" _                                     _

     b.    Distilled  water  is  of acceptable quality for  phosphorus,
          BOD  and suspended solids  analyses:             •              /.
          -  The distilled  water is  phosphorus  free                     J
          -  BOD dilution water oxygen  depletion  is equal to or
            less than 0.20 mg/1 after  5 days incubation of 20°C
          -  Conductivity is greater than  0.2 megohm  as  resis-            /
            tivity or less than 2.0 micromhos/cmat 25°C               j/
          -  Maximum  total  matter of 1.0 mg/1
     c.    Still  is  in good working condition                            / /

     d.    Preventive maintenance is performed on the still regularly   tx

     e.    Storage of distilled water is acceptable                     \s

     f.    Comments-: — "t(*0..   \   naw^-in
                             C          i
                                     -2-

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                                        Name of POTW:
                                        Date: 	
                                        Reviewer:
                                                                      Yes   No
3.   Laboratory Services
     The following laboratory services are provided in good
     working condition?
     a.   Compressed air                                              , /   	
     b.   Vacuum system                                               [/   	
     c.   Hood system                                                 \/'   	
     d.   Electrical services
     e.   Comments:
     Analytical  Balance  Type:
     a.   The balance is operated according to manufacturer's            *
          instructions                                                \/    _
     b.   Balance is mounted on heavy shock proof table
     c.   Balance location is appropriate
     d.   Balance is stored properly when not in  use.
     e.   Balance is checked and calibrated by manufacturer
          Frequency:
          Standard weights are used to  check  accuracy
          Frequency: _         '                 _    \s
          Comments:
5.   pH/Specific  Ion  Meters   Type:
     a.    Instrument is  in  good  working condition                      \/
     b..   Instrument is  calibrated with two  buffers at a
          minimum of two points  that bracket the expected                   /v
          pH  of  the  sample  and are three  pH  units apart               _ V _ .
     c.    pH/ion probes  are properly stored  and in good condition
     d.    Comments:  "TV\£.  n\-\  m?      *s rr>.^rA,r  ^r^i
                            »         .                          i
                        -j   o^(?  -Vo
                                     -3-

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                                        Name of POTW:
                                        Date: 	
                                        Reviewer:
                                                                      Yes    No
6..   Spectrophotometer  Type:  pyaaScV
                                        V
     a.   Instrument is  in  good working  condition
     b.   Instrument is  used according to  manufacturer's
          recommendations
     c.   Instrument  is checked and  calibrated  by manufacturer
          Frequency: 	
     d.   Instrument checked for wave length  alignment
          Frequency: ^ •*   npo  ypaT
     e.   Proper cells (cuvetts)  or sample holders are  used
     f»   Instrument has ultraviolet  range
     g.   Instrument has infrared range
     h.   Absorption cells  are  kept clean
     i.   Matched absorption cells are used for  check
     j.   Comments:
7.    Glassware
     a.    The following volumetric glassware is used:
          -  volumetric flasks
          -  pipettes                                                   i/   	
          -  burets                                     •                \/   	
     b.    Volumetric glassware  is Class A designation
     c.    Cleaning and storage  of glassware is proper, including
          warm detergent wash and three distilled water rinses
     d.    Cleaning and handling of glassware for biochemical oxygen
          demand  is acceptable
     e.    Cleaning and handling of glassware for phosphorus
          analysis is acceptable
         Comments:
W^T    or,\
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                                        Name 01  rui«:
                                        Date:  	
                                        Reviewer:
                                                                      Yes   No
8.   Reagent Quality
     a.   Reagents used are of analytical  reagent grade
     b.   Reagents are prepared and standardized with care and           ,
          proper technique                                            \s    	
     c.   Reagents are restandardized or prepared fresh as required      /
          by their stability                                          i/    	
     d.   Stocks and standards checked regularity for deterioration
     e.   Reagents are prepared in  volumetric  glassware
     f.   Reagents are stored  in proper glassware
     g.   Borosilicate glass bottles  with  ground glass stoppers  used
     h.   Reagents properly labeled with proper identification
     i.   Comments:
9.   Ovens and Furnaces
     a.    Ovens,  incubators,  and  temperature control  instrumentation
          are checked  against NBS certified  thermometers
          Frequency:
                          xw
     b.    Servicing/recalibration  is  initiated when problems arise
     c.    Comments:
                                     -5-

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                                        roame or
                                        Date:
                                        Reviewer:  	
II.  QUALITY CONTROL FOR ANALYTICAL PERFORMANCE

Quality assurance  control  for  analytical  performance is  used  to  insure  that
valid precision and  accuracy is generated  for each determination  and  by  each
analyst.

                                                                      Yes   _No
1.   Standard Acceptance Criteria
     a.    Acceptance criteria is established for each  parameter  and      ,
          procedure                                                    \/   	
     b.    Quality  control  charts are used for establishing  deviations 	
     c.    Mean or  central  lines  are established for upper or lower
          limits                                                      	
     d.    Comments:
2.   Standard Curves
     a.    Standard  curves  constructed for all  spectrometer
          determinations                                              	 .
     b.    Curve  consists of  reagent  blank and  three  to  five  standards  ^/
     c.    Standards fall on  linear portion of  curve                    \/
     d.    Sample data  falls  on  curves within range of standards        \/
     e.    Curve  constructed  by  plotting  instrument response  versus
          concentration
     f.    Curve  contains proper title and analytical protocol
          -  dates of analyses
          -  analysts initials                                          ^/  _
          -  operating  condition of instrument                          \/  _
     g.    Curves constructed when  new reagents are made or                  .
          standards exceed deviation  limits                           	\/
     h.    Reagent blank and at  least  two standards used with each
          determination
i .
         Comments : 5Aa.vvln> v-i4
                                     -6-

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                                        name u i  i \j i i« .
                                        Date: 	
                                        Reviewer:
                                                                      Yes   No
3.   Quality Control Check Samples
     a.   USEPA known value samples are used for quality control
          check samples
     b.   Frequency:
c. Analyses: �<- n\e4&l<


9 "
55
t • k
^ L

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                                        Date:  	
                                        Reviewer:
                                                                      Yes    N£
          Proper sample dilutions are used
     g.   Incubation bottles as  water sealed                          ^/    	
     h.   Dissolved oxygen analyses performed by acceptable
          method:      /\*      probe	winkler         i/    	
     i.   Samples  show residual  DO of 1 mg/1  and a  depletion  of
          at least 2 mg/1  after  incubation                            S    	
     j.   Depletion of dilution  water no more than  0.2 mg/1 after
          incubation                                                  y/    	
     k.   Calculations are correct               •                    	   	
     1.   Comments:
6.   Solids  Analyses
     a.    Procedure as  outlined in 15th  edition  of  Standard Methods      y   _
     b.    Gooch  Crucibles  Size #4 are used
     c.'   Reeve Angel,  934AH,  2.4  cm   or  equivalent glass filter
          filter paper  are  used                                        [/
     d.    Analytical  balance  is  used  properly                          (/
     e.    Muffle furnace  operated  at  550°C                     .        //
     f.    Drying oven operated at  103°C ± 1°C                         _^X
     g.    Desiccator and desiccant are used properly                     tX
     h.    Gooch crucibles are  prepared properly                        tx
     i.    Two  samples are analyzed for each determination             _
     j.    Sample volumes  greater or equal to 50 ml are used for all      ..
          determinations                                               is
     k.    Calculations  are  correct                                   _
     1.    Comments:   O^lvj   ov\o.  sawU \S   uiSgrV
                                     -8-

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                                             ui ruin;
                                        Date:
                                        Reviewer:
III. SAMPLING PROCEDURES
                                                                       Yes   No
     a.   Sampling points are representative of waste stream
          - Influent
     b.
     c.
     d.
     e.
     f.
          - Final effluent
          - Pimary sludge
          Composite sampling is used
          - based on time    *r
          - proportion to flow   ^/
          Samples are properly refrigerated and preserved
          Automatic samplers are clean and properly maintained
          Sample vessels are properly cleaned
          Comments:  Py^VA-p y\v"-.  ,o>"\\\  ^ \OLO
                      \\'i<
          ^
               A
                  *  TI
i 0 \ >"V\CA
                                          D«>\
IV.  FLOW MEASUREMENT AND RECORDING
1.    Raw Wastewater
     a.    Raw wastewater flows metered
          Type:  U>ev\\u-v* i	 Location:
          Meters properly maintained
          Calibration periodically checked
          Frequency:	 Method:  	
     b.
     c.
          Regular service/recalibration by service representative
          Frequency: 	
          Comments:  y\r>    •cPovA    en.\ \ \\fT*j\~\o ir\  5cK'gr\ u^l-ff^
          IS   -Sollon')   or  Oer^nrmppi1. vY\e^
2.   Sludge Handling
     a.   Sludge handling flow metered
          Type:	^
     b.   Meters properly maintained
                                      -9-

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c.
d.
e.
                                   Name  of  POTW:
                                   Date: 	
                                   Reviewer:
     Calibration periodically checked
     Frequency: 	Method:
     Regular service/recalibration by service representative
     Frequency:  	
     Comments:
                                                                  Yes    No
Chemical  Feed System
a.   Chemical feed rates metered
     Type:   (jjJa 11 <\ cv_  r  Ti *v A^ **•
b.   Metering pumps  are calibrated properly
c.   Calibration chambers are used to calibrate pumps
d.   Jar testing is  used for chemical feed rate determination
e.   Comments:  r^Sdv   v ^  \r-.oS   We-^   IA^PC/	
                ~T  v,  «    °
                 .frV  b<
                                                                 w-^
                                                                 I/
                                                                 ~7
           k
RECORDKEEP.IMG AND REPORTING
a.   Data handling in laboratory accomplished with bench sheets
b.   Laboratory bench sheets containing information as to
     analytical methodology, date of analysis, analyst,
     standards and corresponding resposnes, sample identi-
     fication, calculation, and quality control measures
c.   Raw flow records adequate
d.   Sludge quantities record adequate
e.   Chemical feed rates properly recorded
f.   Chemical feed rates accurate
g.   All records stored properly for future reference
h.   Comments:
                                 -10-

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                                        Date:
                                        Reviewer:

SUMMARY
a.   Quality Control and Assurance is Adequate
     Laboratory Staff Responsibilities and Operational Procedures:
          Impact on Data Quality   fl>>  r,r\ucr<^
                                                                       Yes
     Distilled Water:                                    (
          Impact on Data Quality   /A7r>  nA\f?,r
     pH/Specific Ion Meters:
          Impact on Data Quality   !{}&    add
     Glassware:
          Impact on Data Quality _ A/o
                tmfiac-f-
     Reagent  Quality:
          Impact  on Data Quality Wr>  g d Perse.
     Standard  Acceptance  Criteria:
          Impact  on  Data  Quality
                                                   >W
     Spectrophotometer:                                     -
          Impact on Data Quality  j    arli/f'sfr   ir-^C'r
     Ovens  and  Furnaces:                                       /
          Impact  on  Data  Quality  /l/p    *,efiscr?e.   imacT
     Standard  Curves:
          Impact  on  Data  Quality  rv/^tx^r  «?hr>t*,(d
                                TTrtr'l   r hPc.kecf'
                            l\.t
                            /
                                      -11-

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                                         Date: 	
                                         Reviewer:
                                                                        Yes   No

     Quality Control  Check Samples:
                                                            ,
           Impact  on  Data  Quality   A/7  //y.*f-A<'/\   o c'c-fQio
                                    "'..--   i
      Phosphorus Analyses:
           Impact on  Data  Quality
                       run   C{y\fi
                                         (/       /
     Biochemical Oxygen  Demand:                 /
         % Impact on  Data Quality
     Solids Analyses:
           Impact on Data  Quality
     Sludge Handling:
          Impact on Data Quality  /\Q
     Chemical Feed System:
          Impact on Data Quality  ftnnrf  harrf/e
b.   Comments:
                                    'T   ,'.<;
                                 _

                           y  ' J.   htive.   vteihrf
        p/o rs*-4()r\!   J^'lS A-  r fit*  fe-
                                              /nino/~
                         .
Signature A  ^-/IAI   A ,'

Date:
                                    '
                                       -12-
     Raw Wastewater:                                        /
           Impact on Data  Quality nn    nd(/e/-\z  i^f&C'
             trta,'  fioer   or\   et^  r/a< l    kaSK   I H&.
                               A   -       r-aa     -ea
                     /? /. era. //    A- rt r{


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APPENDIX C

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                         Environmental Protection Agency
                Evaluation of Impact of Detergent Phosphorus Bans
              on Great Lakes Municipal Wastewater Treatment Systems
                             REQUEST FOR INFORMATION
                                                                 INFORMATION
                                                                  FURNISHED
A.   DESCRIPTION OF TREATMENT PLANT
     1.   Process Schematics                                     	
          - Wastewater Treatment                                 	
          - Solids Handling and Disposal                          	
          - Recycle Streams                                      	
     2.   Design Data                                            	
     3.   Effluent Limits                                        	
     4.   Site Plan                                              	
     5.   Influent Flow                                          	
          - Domestic, MGD, BOD, SS                               	
          - Industrial, MGD, BOD, SS                             	;_
          - Infiltration & Inflow, Average & Peak MGD            	
          - Major Industrial Flows - Identify and
            describe impact on influent flow and quality         	
          - Population Served                                    	
          - Overflows, Bypassing in sewer system-describe        	
     6.   Phosphorus Removal - Describe
          - Chemical  Used                                        	
          - Addition Point                                       	
          - Method of Controlling                                	
     Possible  Sources:
     1.   Facility Plan or Design Report                          	
     2.   NPDES  Permit
                                                                      4/84

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                         Environmental Protection Agency

               Evaluation of Impact of Detergent Phosphorous Bans
              On Great Lakes Municipal Wastewater Treatment Systems

              PROCEDURES FOR DATA COLLECTION AND TECHNICAL ANALYSIS

 1.   Telephone - State Regulatory Agency
     - Review each WWTP
     - Obtain name of Superintendent or contact person

 2.   Telephone Each WWTP
     - Review purpose of Study
     - Confirm willingness to participate
     - Discuss Information Request form to be mailed and availability of data
     - Tentative dates for site visit

 3.   Mail Information Request Form to each WWTP

 4.   Review data returned with request form
     - Make list of incomplete or missing information
     - Make list of questions on plant and operation

 5.   Telephone Each WWTP
     - Review list of information still needed and ways to get information
     - Confirm date for plant visit

 6.   Plant Visit
     - Evaluate quality of data per protocol
     - Collect remaining data from files or from in-plant investigation if not
       available in files
     - Complete checklist of information needed

 7.   Review Quality of Plant Data
     - Quality of Data per protocol  and impact on study conclusions
     - Completeness of Information per checklist and impact on study conclus-
       ions
     - Screen out any plants whose data would adversely affect the validity of
       the study conclusions

8.   Technical  Analysis of Data
     - Summarize Data from remaining plants
     - Calculate average BOD, Solids and phosphorus  removal  versus chemical and
       energy use
     - Estimate solids production and costs associated with phosphorus removal
     - Develop list of questions and additional  information needed

9.   Follow-up Plant Visit
     - Telephone WWTP and review questions
     - Visit plant and obtain additional  information

10.  Complete Technical  Analysis of  Data
     - Develop Summary of Data
     - Develop matrix to compare plants in  different/states.
                                                                      4/84

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B.   OPERATING DATA - 1982 & 1983
     1.   Influent Flow - BOD, SS, Phosphorus
     2.   Primary Effluent - BOD, SS, Phosphorus
     3.   Secondary Effluent - BOD, SS, Phosphorus
     4.   Final  Effluent - BOD, SS, Phosphorus
     5.   Sludge Production - Primary, Secondary, Other
     6.   Sludge Thickening - Flow, % Solids, Phosphorus
     7.   Sludge Dewatering - Flow, % Solids, Phosphorus
     8.   Sludge Disposal  - Total, % Solids,  Phosphorus
     9.   Recycle Streams  - Flows, % Solids,  Phosphorus
     10.   Operating Parameters - Biological Treatment
     11.   Chemical  Use for Phosphorus Removal
          - Chemical, concentration, where added, total Ibs,
            or gallons used
     12.   Chemical  Use for Sludge
          - Chemical(s),  concentration, where added,  total
            Ibs.  or gallons used
     Possible  Sources:
     1.   Monthly Operating Reports
     2.   Annual  Summary
     3.   Operating Logs
                                                                      4/84

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C.   ENERGY USE - 1982 & 1983
     1.   Electricity - Total Plant
          - By process if available (Sludge Only)
     2.   Natural Gas - Total Plant
          - By process if available (Sludge Only)
     3.   Other Energy - Describe
     4.   Energy Reuse - Describe
     Possible Sources:
     1.   Operating Reports
     2.   Billing Records
     3. ,  Annual  Report

D.   COSTS - 1982 & 1983
     1.   Chemicals - Total  Cost of chemical  per year
                    - Cost per unit as delivered
     2.   Electricity - Total Cost per month
                      - Cost per KW hr.  (average including
                                         all  charges)
     3.   Natural  Gas - Total Cost per month
                      - Cost per 100 cu.  ft.  (average
                                              including  all
                                              charges)
     4.   Other Energy - Total  Cost per month
     5.   Sludge  Disposal  -  Total  Cost per  year
     6.   Overall  Operation  & Maintenance if  available
     Possible Sources:
     1.   Billing  Records
     2.   Annual  Report
                                                                      4/84

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E.   Comments  on plant and  information  furnished.   (Attach  additional  sheets  if
     more space is  needed).
                                                                     4/84'

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APPENDIX D

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 APPENDIX  D.
 Statistical Evaluations
      Formal  hypothesis  testing, or  statistical  procedures  have been  employed
 here  to  determine whether or  not  there is  a difference in  the means of  each
 parameter  between states with  detergent  phosphorus bans  ("P-Ban"  states)  and
 states without  detergent  phosphous bans ("non-P-Ban" states).   The two primary
 options  for  statistically testing  a  difference between  two means  are (1) to
 compare  an  estimate of  the   difference  to  an  estimate   of   dispersion   (or
 variability) of  the  individual  values used to estimate  the  mean, by  a t-test,
 the most  familiar of which  is  Student's  t;  or  (2) to  compare  an  estimate of
 variance based on the individual values,  by an F-ratio (cf.., Steele  & Torrie,
 1960, p. 72).  In either case,  the usual null  hyptohesis, for testing  purposes,
 is that there is  no different between the means.

      Although each test criterion,  a  t-test  on an  F-ratio,  is employed to  test
 the same  null  hypothesis, they differ  in the  implicit  alternative hypothesis
 suppported.  The  underlying model for t-tests  is usually that each observation,
 Yj, consists of
                                 YI = y + Eis
 where y  is the true, parametric population  mean and E-j is  a random  variable,
 which is normally distributed with  a  mean  of zero  and  which describes sampling
 error.  Therefore, the most valid  alternative hypothesis is that the  two means
 being tested are  not equal.

      On the other hand,  the  usual  underlying  model  for F-ratios is  that  each
 observation, Y2j> consists of
                                 Y2j = y + Tj + E,
 where Tj  is  a  "treatment" component  attributable  to treatment  j.   Therefore,
the F-ratio as  a test criterion supports  the alternative  hypothesis  that the
treatments  (in  the  present  case,  whether  or not  there  is a  P-Ban) have  a
 significant effect on the results.   Since  the present study is  concerned  with
the alternative  hypothesis  that P-Ban  versus non  P-Ban has  an   effect on the
results,   the  F-ratio is  a  more  appropriate  test  criterion  as  long as  the
assumptions of  the test  are  met.

-------
     The  primary  assumptions  of the  F-ratio  test  criteria  include  normally
distributed sampling  error,  additive  treatment effects,  independence,  and  uni-
form or  homogeneous  variance.   Each  of  these will be discussed  below to  show
how these  assumptions  are  met for the F-ratio  or  analysis of variance  (ANOVA)
test.

     Normal distribution.   The  raw  data for  all  of  the  statistical  tests in
this  study are  annual  average  values.   By  the  Central   Limit  Theorem, these
averages  are  normally  distributed  although  the  individual  values  (e.g.,  365
values for flow  in mgd) are not  (Sokal &. Rohlf, 1969, p 130).

     Additive treatment effects.  Conversely, this assumption can be worded as
"no interaction  anong treatments."  In the special case of single treatment (as
is  the  case for  this study),  this  assumption  reduces  to  a tautology  so is
necessarily true.

     Independence.   This  assumption  is the  equivalent   of  the  previous  one
applied to residual variance  (sampling error);  that  is,  no interaction  between
sampling  error  and treatments.   There  is  no  reason  to   suspect  a systematic
error associated  with  P-Ban  on  non P-Ban.   Therefore  it   is  assumped  that  the
residual variance  (W/I in the ANOVA tables) is  independent.

     Homogeneous  variance.    This  assumption  must be  tested  individually  for
each ANOVA.  For a comparison of two means, this assumption is tested by taking
the ratio of the variance about one sample mean to the variance about the other
sample mean.   For each statistical test employed in this study, the homogeneity
of  variances   test  is  reported as  an  Fs  ratio.    Whenever  heterogeneous
variances are encountered,  a t-test has been used as the test criterion for the
effects of P-Ban.   However,  the  familiar  Student's  t required  homogeneity of
variance.  The  appropriate t  for heterogeneous variances  is  Cochran  and Cox's
(Steele & Torrie, 1960, p 81).

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 Procedures.
     For  each statistical  test  (in  the present  study),   it  is  necessary to
 accumulate the sum  of  the observations,  ZY (P-Ban),  ZY (non  P-Ban)  and   ZZ Y
 (pooled),  and the  sum  of the  observations  squared, xzY^  (P-Ban),   Z Y^  (non
 P-Ban),   ZZ y2 (pooled).   We  then calculate the  means  Y (and  pooled on total
 mean, Y)  and  variances, 82-
             /                   !
             /                    1
     The  test of omogeneity  of jvariance,  Fs,  is  calculated  by  dividing  the
 larger of the\J;wo variances X^-Ban or non P-Ban) by the smaller of the two.

     The  following  formulas  are  used  for  the  ANOVA  (if  Fs  was  less  than  the
 critical value):
                    TT-
     ssw/I  =       ssTOT - ssB/T

and any MS = SS/df.  The F-ratio of interest here is MSg/j/MSw/j.

     The  Cochran  & Cox t-test  differs  from Student's t  only in  the  critical
value  of  t05,  which   for  Cochran  &  Cox's  t  is  calculated  as  the  weighted
mean of the appropriate Student's t valves.

-------