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Regulatory - Alert (RA 99-7)

Member Pipeline - Regulatory - Alert (RA 99-7)

To:

Members, Affiliates & Pretreatment & Hazardous Waste Committee

From:

National Office

Date:

April 15, 1999

Subject:

AMSA-U.S. Navy Sign Joint Guidance on Shipboard Dicharges to POTWs

Reference:

RA 99-7

AMSA and the U.S. Navy recently signed joint guidance regarding the regulation of wastewater discharges from U.S. Navy ship Collection, Holding, and Transfer (CHT) systems. Data collected by the U.S. Navy, in cooperation with AMSA member agencies in Norfolk, Virginia and San Diego, California, demonstrated that Navy CHT wastewater is domestic in nature. The same data also concludes that concentrations of metals, such as copper, nickel, and zinc, in Navy CHT wastewater can be attributed to the corrosion of ship plumbing systems exposed to seawater. Guy Aydlett, Chair, AMSA Pretreatment & Hazardous Waste Committee and Elsie Munsell, Deputy Assistant Secretary of the Navy (Environment and Safety) represented the two organizations at the signing ceremony held at the Pentagon in March.

An investigation of metals in CHT system wastewater onboard Navy ships was conducted by the U.S. Navy, Hampton Roads Sanitation District, and the City of San Diego to classify CHT discharges. The investigation was designed to determine whether elevated metals concentrations in CHT effluent are a result of industrial discharges to the CHT system or from corrosion of metal components of the ships' plumbing systems. The study concluded that elevated metals concentrations in CHT effluent is a result of corrosion of ships' plumbing systems, and that ships' CHT discharges are domestic in nature.

Subsequent to the CHT study, a partnering effort was initiated with AMSA to apply the results nationwide. AMSA's Pretreatment & Hazardous Waste Committee reviewed the data submitted by the Navy and agreed with those conclusions and recommends that whenever possible, member agencies:

  • Regulate Navy CHT wastewater as domestic wastewater (uncommingled);
  • Implement this guidance on a site-specific basis utilizing existing analytical data;
  • Maintain POTW plant performance and comply with approved pretreatment program guidelines; and
  • Make appropriate allowance, within approved pretreatment program guidelines, or metal concentrations in Navy effluent, which contains a mixture of CHT wastewater and industrial wastewater (uncommingled).

A number of AMSA member agencies situated near U.S. Navy installations and Coast Guard operations such as Seattle, Portland, San Francisco, Anchorage, Honolulu, Houston, Philadelphia, Boston, Providence, Newark and some 20 other agencies will benefit from this guidance to regulate CHT wastewater as a domestic source. EPA will be advised of the guidance and supporting study. Copies of the U.S. Navy study can be obtained by contacting Ron Tickle, Chief of Naval Operations, Arlington, VA; 703/602-2787. Implementation questions should be directed to Sam Hadeed, c/o AMSA at 202/833-4655.