PWS Ref (c) COMUSFJ Memo_29May2020.pdf

This memorandum provides supplementary guidance for the disposal of waste containing Perfluorooctane Sulfonate (PFOS) or Perfluorooctanoic Acid (PFOA) at U.S. military installations in Japan, issued by the Commander, U.S. Forces Japan (COMUSFJ) on May 29, 2020.

The memorandum updates previous disposal guidance issued November 15, 2019, in response to Japan's establishment of a 50 nanograms per liter (ng/L) target level for PFOS/PFOA in drinking water and ongoing clarification of disposal requirements. Disposal procedures are tiered based on combined PFOS/PFOA concentration levels: wastewater exceeding 50 parts per trillion (ppt) must be treated to below 50 ppt before disposal; wastewater below 50 ppt may be discharged to sanitary or storm water systems consistent with original destination if no other Japanese Environmental Governing Standards (JEGS) restrictions apply; wastewater unable to meet the 50 ppt guideline must be disposed of as hazardous waste using high-temperature incineration per JEGS Chapter 6. Additional requirements include: disposal of undiluted AFFF product, filtration/adsorption media, and PFOS/PFOA-impacted soil as hazardous waste; storage of impacted materials in accordance with JEGS Chapter 5 hazardous material requirements; wastewater sampling and analysis through DoD Environmental Laboratory Accreditation Program (DoD ELAP) accredited laboratories; and reporting of accidental releases as spills to USFJ through required component channels. Questions should be directed to COL J. Jon Nufable, USFJ/J9, Command Engineer.