[ RadSafe ] RadSafe Digest, Vol 723, Issue 1

Fredrick L. Miller millerfl at tricity.wsu.edu
Tue Aug 23 13:38:36 CDT 2011

My explanation may not be reasonable but it is the law.  As a private
citizen, you are largely exempt from environmental laws but commercial
entities such as pharmacies, hospitals, and government agencies are
bound by them.  Sewer disposal of certain pharmaceuticals regulated at
40 CFR 261 (http://www.epa.gov/epawaste/laws-regs/regs-haz.htm) is
prohibited without a permit from the agency having jurisdiction.
Typically, this is the individual states' environmental agency and/or
USEPA in the case of states which don't have counterpart agencies.  RCRA
(Resource Conservation and Recovery Act) prohibits disposal of regulated
chemicals to the surface waters of the United States except via
treatment works permitted under the Clean Water Act as codified at 40
CFR (http://cfpub.epa.gov/npdes/npdesreg.cfm?program_id=45)

Local POTWs have permits they have to comply with.  They normally take
the precaution of restricting individual commercial discharges to the
same limits their permit requires of them for discharge to the receiving
body of water, be it a river, lake, or ocean.   This gives them the
headroom they need, taking dilution into account, to comply with their
permit while accepting much more concentrated slugs from unregulated
households on the system. 

 Similarly, 40 CFR 268 restricts certain untreated pharmaceuticals from
"land disposal" which impacts POTWs that land apply their biosolids.
Wastewater treatment technology does not degrade or "treat"
pharmaceutical waste to the standards required by RCRA so the POTWs must
test their biosolids prior to shipping them off-site to determine if
they can be land applied, disposed at a sanitary landfill (common
garbage) or sent for disposal at a RCRA permitted TSDF
(treatment/disposal facility, includes haz waste landfills).

As you can see from a very brief bit of reading, the regs are full of
little "gotcha" conditions which force jurisdictions to ban sewer
disposal.  I'm not joking about this being a brief bit of reading.  I've
been involved in the wonderful world of RCRA and CWA compliance for over
20 years and I'm still learning.  Those poor souls at cities and sewage
treatment districts around the country don't have a prayer of sorting
through the maze so they have to take a very conservative approach to
the problem.  While it may seem nonsense to us and a pain to deal with,
I can assure you they are doing the best they can with the resources
they have.

Fred Miller

P.s. For my next trick I'll try to explain why radioactive waste
disposal to the sewer is allowable in nearly every jurisdiction in
America except the ones serving the national laboratories.  Then I'll
explain simple things like time, gravity, and the opposite
sex......well, perhaps not the opposite sex.  I'm only human.

Message: 1
Date: Mon, 22 Aug 2011 14:05:06 -0700 (PDT)
From: Jerry Cohen <jjc105 at yahoo.com>
Subject: Re: [ RadSafe ] The solution to pollution
To: "The International Radiation Protection \(Health Physics\) Mailing
	List"	<radsafe at health.phys.iit.edu>
Message-ID: <1314047106.59432.YahooMailRC at web82701.mail.mud.yahoo.com>
Content-Type: text/plain; charset=iso-8859-1

??? Many years ago, when I began to work in the environmental health
field, there existed a guideline to the effect, "The solution
to?pollution is dilution". In other words, if it could be assured that
disposal of any harmful agent could not result in environmental
concentrations?above designated standards,?the disposal method could be
considered acceptable.?Over time, this approach had apparently been
superceded by the "Any is too much" philosophy where the detectible
presence of anything harmful is not acceptable. The ALARA principle in
radiation safety is a manifestation of this type of thinking.
??? Now, it seems that we have evolved to the next level. I recently
noted a warning from our?state Health Dept. to the effect that any
disposal of outdated medications into the sewage system is forbidden.
I've tried to imagine a set of conditions where this practice might
conceivably result in some harmful effect, but I am stumped. When?I
inquired about the rational, I learned the reason for this prohibition
is because the practice is illegal. OK, ---I give? up! Maybe someone on
radsafe has a reasonable explanation.
Jerry Cohen

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