PWS Ref (d) COMUSFJ Memo_18Nov2020.pdf

This is a Navy instruction document (CNFJINST/CNRJINST 5090.3) dated November 18, 2020, issued by Commander U.S. Naval Forces Japan/Navy Region Japan regarding the handling of oily wastewater (OWW) containing per- and polyfluoroalkyl substances (PFAS).

The instruction applies to Commander Fleet Activities Yokosuka, Sasebo, and Okinawa and establishes requirements for sampling, treatment, discharge, and disposal of PFAS-contaminated oily wastewater. PFAS are man-made compounds known as "forever chemicals" due to their environmental persistence; they are found in aqueous film-forming foam (AFFF), food wrappers, stain/water repellants, and electronics. The Government of Japan designated PFOS as a Class I Specified Chemical Substance in 2010, and in April 2020, established a target level of 50 nanograms per liter (ng/L) or parts per trillion (ppt) for combined PFOS and PFOA in drinking water and ground/surface water. Treatment of OWW containing PFAS is approximately 30 times more costly than treatment without PFAS; CNRJ incurred costs of ~$1M in fiscal years 2018-2019 to treat and dispose of PFOS-contaminated oily waste.

Key requirements include: shore activities and ship personnel must collect initial shipboard OWW samples for PFOS and PFOA upon entering port; if combined concentrations are below 50 ppt, the OWW transfers to a treatment barge or Bilge and Oily Wastewater Treatment System (BOWTS) for traditional treatment; if concentrations exceed 50 ppt, treatment and disposal follow Section 5 requirements. Contracts supporting shore activities for OWW treatment or disposal must include all specified requirements and references. Treatment processes cannot include dilution with seawater; barge treatment systems must operate in batch discharge mode with sample collection from final treated water tanks prior to discharge. Installation and tenant environmental offices must review treatment and disposal contracts for compliance; Contracting Officers should assign a Contracting Officer's Representative (COR) or Technical Representative (COTR) to each treatment and disposal contract. Shore activities must retain laboratory reports, certifications, waste manifests, inventories, contractor certifications/licenses, and final treatment/disposal documentation for a minimum of five years. All records created must be managed per Secretary of Navy Manual 5210.1 of January 2012.