ILLINOIS POLLUTION CONTROL BOARD
April
28, 1971
inre
#R70—6
PHOSPHORUS WATER STANDARDS
Opinion of
the Board
(by
Mr.
Dumelle):
1.
Introduction
We
like to believe
that there is
a
time and place
for
everything.
The
time
to be serious about saving our place called
Lake Michigan i~very quickly passing.
It has been demonstrated
to the Pollution Control Board
that we must enact measures which
will restrict the input of phosphates
into
the Lake now so that it
will not suffer the
fate of Lake Erie,
so that Lake Michigan will
not have, its quality impaired beyond the present state,
so that
Lake Michigan will not be lost
as
a “great”
lake.
To preserve
Lake Michigan as
a source of public water supply,
as
a commer~±al
and sport fishing center,
as
an invaluable recreation area
and as
a natural public possession of inestimable worth we must act now.
The first annual report of the President~sCouncil on Environ-
mental Quality recommends that
a concerted
and comprehensive
attack be made on eutrophication.
The report stresses three necessary
actions:
i)phase phosphates
out of detergents
as soon as feasible,
2)find better methods to control agricultural
runoff,
and
3)
remove
from lakes more of the nutrients generated by towns and cities
particularly
in urban centers and critical areas such as the
Great Lakes
CR,
489).
With
the enactment of
the Environmental Protection Act,
the
Illinois Legislature charged the Illinois Pollution Control Board
to “determine, define and implement
the
environmental control
standards” necessary
to accomplish
the purpose of
the Act
—-
“to
restore, protect,
and enhance the quality of the environment.
..“
ISec.
5(b),
2(b).
The enactment of a water quality and effluent
standard to restrict phosphorus discharges
into Lake Michigan
is
a
measure backed by that purpose.
Possibly
the single most urgent concern we must have with
Lake Michigan is
the question of accelerated eutrophication
--
that
is,
concern with the speed-up of the natural aging of
the
Lake due
to manes introduction of an abundance
of nutrients in a
quantity fantastically beyond nature~s input.
As
a rough but
dramatic analogy we
can view nature’s input of nutrients into Lake
Michigan as being enough to feed
a suckling piglet while man’s
activities,
including agriculture,
are pouring in
a sufficient
1
—
515
amount
to sate
a 500 pound hog.
With final adoption of the phosphate
water quality and water effluent standard on January
6,
1971,
the
Illinois Pollution Control Board has
in effect declared that
“We
must save Lake Michigan
—
no
ifs, ands or buts
-
starting right now”.
The section of this opinion headed Eutrophication has been
further subdivided to consider the following questions:
a.
What
is the present lake quality?
b.
Why limit phosphorus?
c.
At what level should phosphorus be limited?
d.
What is the contribution of land-runoff?
e.
Should phosphate detergents be banned?
2.
Effluent and Water Quality Standard
The phosphorus standard adopted by the Board on January
6,
1971
originally proposed on August 19,
1970
in
a somewhat different form.
As finally enacted this standard reads as follows:
PREAMBLE
Phosphorus
is an el~ementwhich is
a nutrient for algae.
Present Federal and State policies
for Lake Michigan include the
control and reduction of phosphorus in order
to limit the production
of algae.
Algae causes tastes and odors
in water supplies
and may
reduce dissolved oxygen in water.
Algae
is
a nuisance to swimmers
and can reduce the enjoyment
and ~roperty
values
of shore line
property
The
present
standards
for
phosphorus
in
the
waLer
of
Lake
Michigan
are
at
levels
which
are
thought
to
be
those
at
which
algae
blooms
will
occur and greater than mresent hulk
water
levels.
The
new
standard
is
2,’3
of
the
former
standard.
An
effluent
standard
is
added
to
provide
a
control
on
phosphorus
discharges
to
Lake
Michiqan
1.
Water
Quality
Standard.
Existing
Board
Regulations
specifying
water
quality
standards
for
Lake
Michigan,
wolf
Lake
and
the
Calumet
River
(lakeward
of
the
O’Brien
Locks)
are
hereby
amended
to
provide
that
the
concentration
of
total
phosphorus
measured
on
unfiltered
samples
in
these
waters
shall
not
exceed
0.02
:ng,”l
as
:p~iosphate’(POt)
Ot
0.007
mg/I
as
phosphorus
(P)
2.
Effluent
Standard.
Except
for
unavoidable
combined
sewer
overflows
during
the
interim
period
before
their
complete
elimination,
no
effluent
to the
waters
of
Illinois
listed
in
Section
1
above,
shall
include
phsophorus
in excess of
3.0
mg/I
as
phosphate
(P04)
or
1.0
mg/i
as
phosphorus
(P)
after December
31,
1971.
Dilution
of
effluents
shall
not
be
acceptable
alternatives
to
treatment.
Where
water
is
added
to
streams
of:
waste
water
and
cannot
he
reasonably
separated,
then
its
quantity
shall
be
measured
and
effluent
concentrations
recomputed
to exclude
its diluting effect.
I
—
516
3.
Testing.
All testing pursuant to the Regulations herein
provided
shall be made using methods
as listed in the publi-
cation
tI~.1ethods of Chemical Analysis of Water and Wastes”,
November,
1969 as issued by the U.S. Federal Water Quality
Administration.
4.
Effective date.
Except as specifically provided in Section
2 of these Regulations,
the requirements of these Regulations
shall
be met within ten days after filing with the Secretary
of
State.
3.
Eutrophication
The pollution problem or hazard presented by the introduction
of phosphates
into water bodies,
and
in this
case Lake Michigan,
is the enhancement or increased rate of eutrophecation.
Leading
authorities,
including
Dr. A.F.
Bartsch have stated that the
problem of eutrophication is one
of the
chief concerns about
Lake Michigan.
utrophication
is
the
aging
process
of
the
Lake
in
which
the
waters
become
more
fertile
and
acquire
a
greater
ability
to
grow
algae
and
other
forms
of
unwanted
living
matter.
Eutrophication
becomes
a
severe
oroblem
when
the
algae
become
so
preponderant
that
they
color
the
water
green
and
interfere
in
many
ways
with
the
continued
usefulness
of
the
water.
Considering
the
undesirable
effects
of
eutrophication,
it
may
be
regarded
as
a
severe
form
of
nollution.
Human
sewage
anC
~ndustrnai
waste
are
segnifacant
sources
of
nutrients
that
contribute
to
the
eutrophication
of
Lake
Michigan.
Drainape from fara:
land is also
as
important
source,
a
substantial
c;uant~ty of
the
nutrients
come
from manure
that
is
spread
on
frozen
grounds
which
is
subsequently
flushed.
into
streams
during
sPring
thaws
and
rains.
Runoff
from
urban
areas
is
rich
in
phosphate
and
nitrare,
(ix,
3,
p.
4)
The
abundance-
and
species
comuosition
of
pianktonic,
bacterial,
benthic
and fish
ocoulatnons
change
as
eutroohi
cation
progresses
and
changes
0::
this
nature
may
be
used
to
detect.
and
measure
the
degree
and
rate
of
eutroehication.
inriched
lakes
develop
dense
nopulatlons
of
piankt.onic
cigue,
commonly
combated
by
a
few
species
of
blue—green
algae.
Lake
Erie
1’~as
already
experienced
the
elimination
of
benthic
invertebrates
and
massive
blue—green
alcrae
blooms.
(Ex,
3,
p.
4)
~)r.
Bartsch
nas
staten
tha-c
some
0±
one
changes
to
iOc)~:
.tor
are:
decrease
in transparency
of
t:~e’~a
ter;
increase
of
total
dissolved
solids;
loss of dissolved oxygen in the deeper layers;
and changes
in
bottom
dwellcnq
animals
and mic.roscopac olants.
Wnen eutrophaca--
tion
has
not
proceeded
to
an
obvious
and
objectionable
stage,
it
becomes
necessary
to
examine
the
combination
of
these
more
subtle
clues
in
order
to
sense
the
existing
state
of
affairs.
In
many
cases,
such
scrutiny
may
reveal
a
forecast
of
things
to
come.
Changes
such
as
the
above
are
now
appearing
in Lake
Michigan
(R.
69)
a.
What is the present lake quality?
The testimony of Dr. Bartsch showed that extensive inshore
areas of pollut4on were found along the entire southern perimete~-
of Lake Michigan.
At various times swimming beaches have been closed
in Chicago
and other areas when large mats of
foul smelling algae
have been deposited on the beaches.
The aesthetic character of Lake
Michigan has been impared by algae on many occasions.
On
a
far more
practical level drinking water treatment plants have had their oper-
ation and efficiency impaired by short filter runs
and tastes and
odors resulting from high phytoplankton.
Such impediments
to the
operation of these plants have lead
to increased cost of water
treatment in Chicago and other cities
(R,
24).
High concentrations of phosphorus favor the blue—green algae
which are capable of using nitrogen from the atmosphere
as
a source
of nutrition,
These algae are particularly obnoxious because they
are more buoyant than other forms thus tending to form windrows
and
produce especially obnoxious
“pig pen odors” because of chemical
compounds peculiar to them,
The seemingly inexhaustible
supply of
algae that has washed ashpre in recent years
has defied maintenance
attempts
to keep some beaches usable during the entire recreational
period.
Bathers and sunbathers must travel further to enjoy
their sport
CR.
27).
Bottom animals serve as
a vital link in the aquatic food web
by converting plant food into animal food
for predatory fishes.
Changes in numbers and species of bottom animals consisting pre-
dominately of burrowing worms favors
a community of fishes such as
carp and suckers that root for their food,
An increase in worms
is
a product of an increased food supply from sedimentation or organic
waste materials or dead algae.
Changes in
the kinds and numbers
of bottom animals are effects that are frequently
a product of
pollutants;
these changes result in damages to desirable aquatic
organisms,
and may produce increased numbers of undesirable aquatic
organisms that interfere with the use
that can be made of the water
(R..29)
Mid—Lake Area
Deep water areas
of Lake Michigan
are as yet unaffected by
the more intensive pollution observed
in many in—shore areas.
The
soluble phosphate content has been determined to be 0.02 mg/I
(P04)
in deep water areas
as an average with
some concentrations going up
as high as 0.14 mg/i.
Areas close to shore averaged 0.04 mg/l with
some concentrations a~high
as 5.00 mg/l.
In-Shore Area
Inshore areas are primarily the shoreline areas which are used
for recreation, which extend out as far as one goes
for water supply.
This may be out to
a depth of approximately
10 meters or approximately
40 feet
CR.
93).
I
—
5Th
Massive areas along the
perimeter
of
the
southern
half
of
Lake Michigan are polluted to such an extent that large populations
of
pollution
tolerant
sludgeworms
occur
CR.
36).
For
several
years
the
Gaicago Park District has reported that beaches became fouled
with algae washed in from the Lake,
The windrows of algae that
completely lined the beaches became
foul smelling after
a few
days exposure to the summer heat.
Flies and other insects covered
the decaying mass
(R.
46),
These biological
findings reflect the
deteriorated water quality of Lake Michigan and represent the gross
pollution resulting from the domestic and industrial waste dis-
charged into the Lake
arid the result of urban and rural land runoff
of nutrients
CR,
50).
The facts revealed by these studies make up the story of
what has been happening to Lake Michigan in recent times.
Many aspects
of the story are
far from clear but what is clear
is that excessive
amounts of nutrients
are present
CR,
67)
In the words of Dr. Bartsch the condition
of Lake Michigan
can be summarized
as follows:
The
tremendous
mass
of
data
gathered
on the
physical,
chemical,
and
biological
status of Lake
Michigan
indicate
that the
Lake,
as
a whole,
is
beginning to show some early symptoms of accelerated
eutrophication.
The offshore,
deep water areas of Lake Michigan do
not show substantial effects of pollution or the onset
of eutrophication forces,
They do, however, exhibit
a
combination of minor and subtle changes that
suggest that the real beginnings
of eutrophication
are
just around the corner.
In contrast
to the offshore waters,
the inshore areas
have
changed drastically
,,.
In
recent
years both
attached
and
free
floating
algae,
,..
frequently
have
appeared
in
nuisance
proportions
at
various
harbour
and waterfront areas around the Lake.
The
growth
of such masses of algae is
a direct response
to concentrated levels of nutrients brought into the
Lake by way of municipal
sewage,
land runoff, urban
drainage,
industrial waste
and other sources,
In Lake
Erie growths of
algae
seem to havebeenaforerunner
of
the more widely dispersed free floating or plankton
growths that now exist there,
In
the southern end of the Lake there
is ample
evidence of deterioration of chemical water quality
in areas adjacent to population centers.
Total
inorganic nitrogen and soluble phosphate were found
to
be
highest
here
CR.
79-83).
1
—
519
Dr.
Bartsch concluded as follows:
While
the deep water areas
of Lake Michigan give only
a suggestion of creeping eutrophication,
the Lake’s
response
to increasing nutrients in the inshore waters~
is obvious and shows that the Lake
can respond when
nutrients
for plant growth
are abundant.
Lake Michigan,
as
a whole,
is now at an early stage
in the eutrophication
process that was passed through by Lake Erie at some point
in the past.
With increasing time, nutrient levels will
increase until finally the entire Lak~becomes involved.
With certain reservations, Lake Erie can be viewed
as
a prototype
and
a preview of what can happen in Lake
Michigan if nutrient bearing wastes input continues
unabated
CR,
87).
b.
Why
limit Phosphorus?
Many nutrients
are required for the growing of algae and
among these are carbon and phosphorus, nitrogen and others.
The
easiest one to
limit
is phosphorus.
The activities of people
account for a high propottion of the phosphorus input into troubled
lakes.
This
is
a good reason to focus control on phosphorus.
Dr.
Bartsch commented on carbon as
a limiting
factor.
He
stated that briefly,
the carbon theory is that
if bacteria in the
Lake which have the capability of decomposing organic matter, in
doing so liberate carbon
as carbon dioxide, then
the supply of
carbon dioxide in the
water
is increased and
is available to
algae for growth.
Obviously this accelerates the eutrophication
process.
The carbon theory implicates carbon as the culprit and
attaches
little
significance
to
phosphorus
input.
An
important
tenet of
the theory that carbon is the critical factor
in the
process
of eutrophication is the symbiotic relationship between
bacteria
and
algae;
the relationship is the main thesis of the
Lange-Kuentzel-Kerr proposition.
Dr. Bartsch stated that he
disagrees with this thesis and feels that the principal scientific
and limnological community is also in disagreement with the
thesis.
The fundamental biology relating to algae, an abundance of which
signifies the most onerous characteristic of eutrophication,
requires that a number of nutrient elements are necessary to support
their growth.
Algae use
up carbon
in a ratio
of 100 to 16 nitrogen
to
1 phosphorus atom.
Also
to be considered is the fact that carbon and nitrogen
are very nearly ubiquitous while the
same cannot be said for
phosphorus.
That is, phosphorus can be kept out of the water more
easily than can either carbon or nitrogen.
Lakes that have been
studied and seem to indicate that carbon may become the limiting
factor are not typical lakes,
the kind generally thought of with
eutrophication problems.
A more in—depth look at the question leads
one
to
the conclusion that
for all practical purposes
the controllin
element to consider is phosphorus
CR.
278).
1
—
520
Some lakes with high phosphorus content are not algae
bloomers because other elements, sometimes
trace metals,
are not
present.
In Lake Tahoe nitrogen may
be
the
limiting
factor
(R.
314).
To ascertain
the limiting factors
one must look
at all the
nutrients that are needed,
If one of the nutrients, phosphorus,
can
be limited, then it becomes the critical limiting
factor,.
We do
not know with complete certainty what the limiting factor in Lake
Michigan is
(R.
286),
But it is manifestly evident that phosphate
has
an effect on
the algae population in Lake Michigan.
c.
At what level should phosphorus be limited?
The generally accepted rule of phosphate in excess of
0,01 mg/l
as
P as causing algae blooms appears
to have been derived
from a paper published in
1947, by Clair
N.
Sawyer
CEx.
2).
Before
undertaking
any discussion of eutrophication and phosphate input
into water it should be noted that considerable confusion inevitably
arises
as to whether one
is expressing concentrations and inputs in
terms of phosphate
(P04)
or phosphorus
(P).
Fortuitously
the
conversion factor from phosphorus to phosphate is simply
3.
Conversely to change basis from phosphate to phosphorus
is simply
a
matter of dividing by
3.
In this opinion the convention of expressing
concentration on the phosphorus basis
is used unless otherwise noted,
If the availability of phosphorus
is increased,
algal growth
increases.
Sawyer
(Ex.
2)
has demonstrated this although his data
has been misused.
Sawyer stated that if the studied lakes were
to
have
a concentration of inorganic phosphorus
at the level of
.015 mg/i at the time of the spring overturn and an accompanying
concentration of 0,3 mg/i of nitrogen objectionable blooms of~algae
would result,
Some observers have ignored the spring overturn
and others have interpreted these numbers
to be somehow magic below
which there would be no algae and above which there would be
an
abundance.
Mr. John Morris of the City of Chicago, Department of Environmental
Control recommended
the setting of
a water quality standard lower than
.02 mg/l
(POA).
He stated that the proposed effluent standard of
1 mg/i
(P) d~es not appear to be adequate
to protect Lake Michigan
from the threat of accelerated eutrophication due
to the
presence
of excessive amounts of phosphorus.
It does not appear to reflect
the more stringent standards being considered elsewhere nor the
potential
of current technology.
He urged the Board to adopt an
effluent standard which recognizes and requires utilization of the
best available technology
CR.
492),
The Lake Michigan and Adjoining Land Study Commission has stated
that the Lake should not be allowed to deteriorate beyond its present
phosphate
level
(R,
349).
The Commission asserted that if the proposed
effluent standard,
1.0 mg/i as
P, were adopted and
if current sources
of phosphate input were allowed
to continue discharging
at their present
rates water quality would deteriorate,
The Commission urged
the Board
to arrive
at
a standard
which would
I
—
521
not further degrade
the Lake,
Phosphorus removal technology
is
available
for
use
today
the
Commission
asserted,
and
an
effluent
standard
of
I mg/l will still degrade the Lake,
It must be stated that the effluent standard of
1 mg/i
(as
P)
was not designed to meet the 0.007 mg/i water quality standard
because,
as was stated in the original proposal,
there was
no way
of
ascertaining
that
figure
CR.
359),
The
figure
of
1
mg/i
was
proposed as representing
the application of
the maximum feasible
technology for phosphorus removal,
Phosphorus removal technology
is both well known and
readily available,
Phosphorus removal can be effected by either
straight biological
removal, straight chemical precipitation or
combined biological—chemical removal,
Other, less common processes
such as ion exchange,
and electrodialysis are
less
feasible, but
available.
Removal efficiencies in the range
of 80-05 per cent
can
be
expected
from
the ordinary treatment methods.
(H.
185-186).
The treatment method which
can most easily be designed,
constructed and operated today
is
chemical removal by precipita-
tion and coagulation.
The chemical removal process can be closely
controlled and efficiencies
in excess
of
90 per cent are readily
effected,
(R,
190-192)
.
An additional benefit accrues in the
removal process inasmuch as other pollutants are substantially re-
duced.
Lime,
alum, polyelectrolytes
and waste pickle liquor are
the most common chemical additives in use
today,
All
four treat-
ment methods are straight-forward,
reliable
and easily controlled
to produce
a predictable effluent quality,
The choice of which
chemical agent to use is principally dictated by local considerations
such as availability of pickle
liquor and sludge disposal requirements.
Mr.
Raymond E. Anderson,
General Manager of
the North
Shore Sanitary District discussed
the District’s experience
in
using waste pickle liquor
(spent hydrochloric and sulfuric acid)
which is trucked from a steel works
in Waukegan to the Waukegan
treatment plant.
The chemical
is available at no cost, other than
freight costs,
to the District;
the steel mill is happy
to
be
rid
of
it
as
it
alleviates
a
waste
disposal
problem
for
the
mill,
Eighty percent removal of
the 12-15 ppm of phosphate,in
the plant
influent
is accomplished by addition to the sedimentation
tanks
(R,
122—127)
Costs of phosphorus removal have been variously estimated.
At one end of the spectrum istheminimal
capital and chemical use
and
operating
costs
associated
with the use of spent pickle
liquor.
Dr.
John
Pfeffer,
Professor
of
Sanitary
Engineering
at
the
University
of
Illinois,
testified
that
technology
is
available
for
removal
of
phosphorus
at the
90 percent level at the cost of less than 5~per
1,000 gallons
CR,
164—165).
He further testified that treatment
with poiyelectroiytes
or
lime are probably at the
same
cost level
~(R.
182)
,
As
processes
improve,
the
record
of
experience
.is length-
ened,
and economies of scale are realized,
it
is anticipated
that
1
—
522
treatment costs will be much improved
CR.
194-196)
.
On another
basis
it was estimated that removal of
50
of the phosphorus
in sewage
could be
accomplished at a cost in the range of
$.22
to
$1.40
per
person
per
year
(R.
405,
419-422)
The
analytical
method
of
determining
the
phosphate
content
of
waste
water
and
Lake
Michigan
water
was
another
subject
of
consideration
for
the
Board.
To
facilitate
the comparison of data
from
an
historical
prospective,
it is
important
that
reports
from
various years
can easily be correlated.
The Illinois Sanitary
Water Board’s report of May 1970 indicated a change in analytical
technique
as follows:
During 1968,. .the, tests were performed on
unfiltered
samples.
It was decided prior
to
the
1969 season that only soluble phosphates
should be measured.
Therefore the 1969 sam-
ples were all filtered prior to analysis.
Such
a change in laboratory methods can,
and indeed has, resulted
in data which’cannot be easily compared.
The Board therefore felt
that the method or a choice of methods should be specified in the
standard.
Other testimony indicated that the ratio of total phosphorus
to that form of phosphorus available
for plant growth varies widely
and it is therefore desirable
to establish limits on the total
phosphorus rather than on that part of the element that may be
available for immediate plant use.
The appropriate phosphorus deter-
mination for water in which there is
a substantial amount of suspended
soil particles
is currently receiving further study.
For Lake Michigan
the record shows that the standard should apply to total phosphorus
and
rn t
simply a portion of the phosphorus such as soluble or filterable phos-
phorus.
d,
What
is the contribution of land runoff?
One of the principal
factors that affects the rate of
eutrophication
is
the extent to which nutrients needed by algae
enter
the body of water.
Under natural conditions unaffected by
man,
the input of nutrients from the watershed runoff,
and
in
deposition
from rain and snow is low,
The aging process thus
proceeds at
a low rate,
Cultural developments
on the watershed
such as the establishment of cities and various agricultural
activities accelerate the nutrient input leading to accelerated
aging
(R.
71).
The Lake
is brought more rapidly to
a high
level
of fertility,
and greater crops of algae and other plants
are
produced than under natural influences alone
(R.
73)
Drainage
areas that are primarily rural with intensive
agricultural activities can be expected
to have runoff as the major
phosphorus
input; as the land use changes from agricultural
to
urban,
the contribution of phosphorus from land drainage decreases
(R.
155-157)
.
In heavily urbanized drainage basins
a major portion
of the phosphorus originates from waste water from municipalities
and industry.
The FWQA study of Lake Erie indicated that approxi-
mately
2/3 of the phosphorus input into Lake Erie was attributable
1
—
523
to urban sources.
Clearly,
control of municipal and industrial
discharges
to Lake Erie would markedly reduce
the eutrophication
effects.
It must
be noted that
the Lake Erie basin
is very small
and highly urbanized and in this regard contrasts strikingly with
the Lake Michigan basin
(R.
157).
Dr.
Bartsch estimated that the annual input of phosphate
to
the Lake from the soils of the Lake
Michigan basin amount to
approximately
5,000,000 pounds per year.
Another 10,000,000 pounds
comes from municipal
and industrial waste
CR.
74).
Expressed
as
phosphorus
this would be
a total annual input
of.
5 million pounds.
Although this estimate of phosphorus input is frequently heard,
it
is open to question and
is currently undergoing re—evaluation,
The
sources of
the
phosphate can be readily identified but quantification
of
the phosphate input from each source is not easily made.
Mr.
R.
H.
Harmeson reported that the annual phosphorus
input
to Lake Michigan
in
1963—1964 totaled 4,790,000 pounds while
the outflow was 262,000 pounds.
The total input was estimated to
be about 1/3
(1,640,000 pounds)
from soil in runoff and
2/3
(3,150,000
pounds)
from municipal
and industrial wastes,
The population
for 1960
in
the Lake Michigan drai?xage basin was 4,2 million.
This excludes
the large numbers of people living
in the Chicago metropolitan area
complex since they are outside the Lake drainage
area.
The reported
phosphorus input calculates to
a phosphorus input rate of about
0.7
pounds per person per year from the domestic—industrial
source,
Using Harmeson’s 1963-64 ihput data the extrapolated
estimate
for 1970
is 5,650,000 pounds
of phosphorus input into
Lake Michigan.
Of this total 1.6 million pounds
is ebtimated
as
soil runoff and
3.9 million pounds
as contained in waste effluents
and
a comparatively miniscule 150,000 pounds as direct precipitation
contained in rain and snow.
These figures are the result of using
an estimated annual usage rate per person of
0,7 pounds
as
phosphorus.
Harmeson stated that
the 1964 estimate
for the input
rate from land runoff was
36
lbs,/mi.2/year which he characterized
as
a highly conservative rate,
Sawyer’s average for the Madison
Wisconsin area was
255 lbs./rni.2/year
CR.
331-332),
The accuracy of these estimates
of input rates
is not
nearly so significant
as the relative magnitude of the contributions
from various sources,
the phosphorus input from waste effluent
compared
to that from land runoff
is
a ratio of
2:1.
Mr. Harmeson also reported estimated phosphorus loading
using
a more realistic input estimate of
4.0 pounds/person/year,
With
this latter rate the 1970 input estimate totals 23.75 million
pounds with the soil runoff remaining
the same
at 1.6 million
pounds and the amount attributable
to waste effluents being 22.0
million pounds
(R.
335).
I
—
524
It is interesting to note that using Sawyer’s estimate
of
255 lbs./mi.2/year
for the
land runoff figure
results in
a total
loading from this source of ii,
68
million pounds per
year.
When
juxtaposed with Harmeson’s estimate of
22.0
million pounds of
phosphorus
from industrial—domestic sources the ratio of 2:1
is
maintained.
A
very
recent
analysis
by
Mr.
Michael
J.
Schmitt
(Phosphorus and Phosphorus Input
to
Lake Michigan,
unpublished
manuscript,
1971) reports.a 1969 total input level of 15,282,222
pounds/year
as phosphorus.
This
is more than
300
greater than the
input figure usually heard.
No attempt
is made
to estimate the
important ratio of waste effluents
to land runoff.
The great
disparity in the various estimates
of
phosphorus
inputs
is
a
lustily waving warning flag
to all investigators pointing
to the
fact that more definitive investigation
is needed to more pre-
cisely ascertain both the actual amount of input and the relative
contributions of waste discharges
and
land runoff.
The disparity in the estimates also suggests that the
contribution attributed
to land runoff may be grossly understated
and that indeed runoff may be the greatest contribution.
This has
been suggested to the Lake Michigan Enforcement Conference with
the further suggestion that the Conference undertake an immediate
comprehensive
survey of the question.
hate detergents be
banned
The amount of phosphates discharged to Lake Michigan
are
partly controllable and partly uncontrollable,
If phosphates
in
treated waste water are to be controlled,
two methods are available;
(1)
elimination at the source or
(2)removai in the treatment plant
process.
Waste detergents
are
a principal source of phosphates
in
sewage.
Steps have been taken locally and are being considered
nationally
to ban
the sale of detergents containing phosphates
(H,
120)
Mr. John Morris
of the City of Chicago Department of
Environmental Control requested that
the Board consider regulations
prohibiting
the sale of detergents containing phosphates.
He~
introduced
as
an exhibit
a copy of
the Chicago ordinance banning
the sale of detergents containing greater than
8,7
(wt,
expressed
as
F)
of phosphates after February
1,
1971
CR,
492),
Mr. Theodore Brenner testified as
a witness
for the Soap
and Detergent Industry Association and Dr.
Paul Derr testified for
FMC Corporation
as
a major producer of phosphates
for detergents.
The
Soap and Detergent Industry Association
is an industry trade
organization representing well over
90
of the
soap and
detergent
production in the country.
Mr.
Brenner stated that the Association
is
fully in support of any effort to control nutrient inputs into
lakes
and other surface waters which may be endangered by accelerated
I
—
525
cultural eutrophication.
He stated that, where feasible
all
wastes should be diverted from lakes and where diversion of
waste water is not possible improved waste technology should
be
applied.
Mr.
Brenner reported that the detergent industry has
accelerated its research efforts in the search for
a phosphate
replacement.
The program has
first priority in several company
laboratories.
He further stated that the most widely discussed
phosphate replacement material, NTA
(nitrilotriacetate)
,
has
a
primary value
in combination with phosphate in detergents.
There
are
other
problems
with
NTA
at
the
present
time.
NTA
has
not
been
thoroughly tested as
to
its
ultimate environmental safety and there
are
indications
that
widespread
use
of
NTA
may
have
a
more
adverse
effect on our environment then use
of phosphates. CR.
406).
Polycarboxylates were noted as another class of materials attracting
attention for detergent
use although
these materials may not have
the
proper
performance
characteristics
and
they
may
not
meet
the
necessary biodegradability standards
CR.
407).
Still other materials
which are
talked about as
a replacement for phosphates
in detergents
are various forms
of silicates,
Sodium carbonates are also being
considered
CR.
416).
Why
not
a
return
to
soap?
It
was
stated
that
this appears
to be impractical because
(l)the supply of
fats
and oils is inade-
quate to furnish the needed raw materials,
and
(2)the performance
of soap in modern automatic washing machines
is not on
the same
level as detergents.
The first synthetic detergent was marketed
in 1934,
it contained no phosphate
and was
a failure..
Following
World War II phosphates and detergents were combined and from that
point they enjoyed
a dramatic growth
to the point that by
the
early
‘50’s,
soap was virtually off the market place
(B.
412),
Phosphates are unique
in that they perform several functions
in
detergent products and there
is no single replacement material,
They soften water,
they
are anti-redeposition
agents,
they emulsify
oils,
and they adjust alkalinity.
The phosphate portion of the
detergent is an extremely important part of
the product
(B,
431),
Although in considering the phosphate problem,
the Board
initially proposed only
a water quality and effluent standard,
the
Board made clear during the hearing that matters such
as
a ban on
phosphate containing detergents was another avenue which could
and.
should be considered.
The fact that the State of Illinois has
a
very limited number of phosphate dischargers
into Lake Michigan was
an important consideration in considering
a
phosphate
detergent
ban.
The phosphate discharges
to Lake Michigan from Illinois
are
limited, being confined almost exclusively
to the discharges
from
the North Shore Sanitary District.
The Sanitary District is
presently experimenting with
the use of waste pickle liquor from
a
steel
company
for
phosphate
removal in its waste
water
CR.
122)
P~esultsof full plant scale application indicates phosphate reduc-
tions on the order of
80
to be readily attainable,
It appears
I
—
526
that the use of pickle liquor may be the answer to the North
Shore Sanitary District meeting the phosphate removal requirements.
Further,
the North Shore Sanitary
District has plans to divert
away from Lake Michigan by
early 1973.
At
that
time most of the
phosphate into Lake Michigan will be coming from Indiana,
Wisconsin
and
Michigan
(B.
360)
Dr.
Bartsch stated that consideration should be given
to
banning phosphates
in detergents.
Curtailing the input from all
sources
and. not only of all of the sources of waste which are
treated should be
the rationale.
Inputs
of phosphorus
are additive
in
terms of
the various sources that are involved.
As regards
qualifications
to the banning of phosphates
from detergents,
Dr.
Bartsch
said
that
we
would.
not
want
‘to
replace
it
with
an
element or
a compound or
a substance which has
a substantial
deleterious
effect. on the environment like phosphates.
There
is no question
that
the Board has
the power
to
outlaw
the
sale
or use of phosphate detergents under Section
13
of the Environmental Protection Act.
Because the Board has decided
not
to
iiopose
a
ban
on phosphate detergents with
‘this regulation
does
oct moan
that
it
will
not do
so
at
another
time.
The
Board
presently
has
before
it
a
citizen’s
oetition
pursuant
to
section 28
of
the
Environmental
Protection
Act
which
seeks
to ban
the
sale
of
all
detergents
or
other
cleaning
products
containing
phosphorus
tbroucthout the entire state after
Curie
1,
1972,
4.
Summary ano
Conclusion
Perhaps
the
most
succinct
and.
cogent
statement
of
‘the
rationaie
underly~ng
the
adoption
of
the
water
qusiaty
and
effluent
standard
for
phosphate
is
the
exolanatory
statement
which
accompanied
the
origtnal
pronosal:
Phospnorus
is
an
element
which
has
been
implicated
in
the
excossive
growth
of
algae
in
fresh
water
Lakes.
The
alqaa
grows,
dies
and
in
decomposing
robs
the
water
of
necesuary
dissolved
oxyqen,
In
addition,
algae
is
a
nuisance
on
beaches
to
swimmers
and
to
water
treatment
plants.
The
proposed.
water
ruality
standard
for
phosphorus
i,s
2/3
of
the
present
standard.
and.
is
at
the
same
level
as
the
bulk
waters
of
Lake
riichigan,
Since
the
existing
phosphorus
water
cuality
standard.
is
not
at
the
danger
level
for alcae blooms,
it Is prudent
to tighten this
standard.,
The
consideration
of
a
phosphoru
s
limitation
ci
inout
into
Lake
Michigan
was
one
of
the
first
matters
considered
by
this
new
governmental
agency,
the
Illinois
Pollution
Control
Board.
The
urgency
attached
to
this
matter
was
not
misplaced.
To
prevent
1
—
527
Lake Michigan from becoming another Lake
Erie,
to preserve our
beautiful Lake,
we must take
this action now by restoring
the
inshore areas of Lake Michigan
to an acceptable
state and
preserving the offshore waters in their present state of purity.
We must keep all nutrient input from all sources at the lowest
possible level consistent with feasibility and reasonableness.
The offshore waters
of Lake Michigan are now of high
quality.
They are just beginning to show slight, subtle changes in
the direction of eutrophication.
Localized inshore waters are now
eutrophic
and have lost their usefulness
for many desirable purposes.
If forecast of future chemical input materializes,
eutrophication
processes will be accelerated.
Problems in inshore areas will
then become even more distasteful and costly and they will gradually
involve
the offshore waters.
Accelerated eutrophication
can he
prevented. if actions
to slow down nutrients
input are taken
soon enough.
The Lake Michigan campaign can be largely
a preven-
tive one.
Therefore, more effective
and economical than
a totally
restorative program.
All controllable nutrient input should be
stopped
CR.
91).
To save our
lake,
to preserve its present quality from
further deterioration we miust rein—in the present galloping eutrophic-
ation
in the near-shore areas. Ample testimony has been presented
before
the Board which emphasized that
‘the most feasible way
of
doing this at this
time
is
to limit
the input to the Lake of the
essential nutrient, phosphorus.
Dr.
Bartsch in stressing the importance of keeping
nutrients out of the lake
put it this way:
If
you like this Lake
the way
it is,
then you ought
to quit insulting it with all this
junk you are putting
in;
and
if you keep the
level down to the lowest you
can, maybe you can even turn it back in time
CR.
305).
I
dissent:
I, Regina
B.
Ryan, Clerk of the Illinois Pollution Control
Board.,
certif
that the
Board. adopted the above opinion this
28
day of April, 1971.
/
Illinbis Pollution Control
Board.
1
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528
