[ RadSafe ] Hospital emergency response and RDD waste management

[LNMolino at aol.com]

In a message dated 3/2/2005 5:19:28 P.M. Central Standard Time,  
alstonchris at netscape.net writes:

Put it  down the sanitary sewer *please*, not the storm drains, unless it's 
some kind  of ultimate extremity.  For one thing, it's not legal to dispose of  
hazmat (I'm using the term loosely) in the storm sewers (one can imagine your 
 finding yourself with an EPA citation, on top of everything else).   
Sanitary sewerage is pretty well controlled and monitored.  It shouldn't  be 
difficult to figure out how much is there, even at the treatment  plant.  The storm 
drains can potentially overflow anywhere upstream of  the final discharge point.

The NUKE issues aside (most of you are much more well versed in that arena  
than I will ever be) the legal ability of an Incident Commander to "create" a  
run off situation where he or she is in the process of saving life and limb is 
 well documented and goes all the way back to the days of the "Old Domestic  
Preparedness Program" (AKA the 120 Cities Program).
 
At that time (1996 or 97 time frame) the leader of the US Army Chemical  Team 
for the DPP asked for a formal interpretation from EPA on the topic related  
to chemical waste run off, more specifically that run off that may well be  
generated in a mass DECON scenario post a chemical release (remember this is a  
few years out from the Tokyo Subway Sarin Incident in 1995) and the EPA in a  
letter that has not ever been rescinded or really challenged said at that time 
 in a nutshell that the IC of HAZMAT incident could create a run off 
situation  with no fear of federal liability per SARA and CERCLA as long as they were 
due  diligent in their reporting of the run off situation via normal HAZMAT 
spill  reporting channels. While it was aimed at chemical incidents at the time 
most  everyone I have spoken to regarding this in the past 10 years has felt 
that the  letter was broad based enough to cover all CBRNE type events.
 
Of course they (EPA) could change their minds seemingly on a whim at any  
moment?
 
Louis N.  Molino, Sr., CET
FF/NREMT-B/FSI/EMSI
LNMolino at aol.com
979-690-3607  (Home Office)
979-412-0890 (Cell Phone)
979-458-0795 (TEEX  Office)

"A Texan with a Jersey Attitude"

The comments contained in  this E-mail are the opinions of the author and the 
author alone. I in no way  ever intend to speak for any person or 
organization that I am in any way  whatsoever involved or associated with unless I 
specifically state that I am  doing so. Further this E-mail is intended only for its 
stated recipient and may  contain private and or confidential materials 
retransmission is strictly  prohibited unless placed in the public domain by the 
original  author.