Sewer Disposal Restrictions

["David Scherer" <DAVID@speedy.ehs.uiuc.edu>]

>We too are not allowed to discharge radioactive materials to the 
sanitary 
> sewer. However, we did reach an agreement with the sanitation district to 
> allow us to discharge human waste containing radionuclides (as allowed under 
> federal and state regs) as it would create more of a hazard if we had to 
> collect the wastes from all patients who have had nuclear medicine scans or 
> are undergoing treatment with 131-Iodine.
> 
Someone correct me if I'm wrong, but doesn't the federal Atomic 
Energy Act of 1954, as amended, preempt state and/or local regulation 
of radioactive materials.  The only exceptions I know of are (1) 
Agreement States (and only when the NRC has made a finding of 
compatability), (2) under the Clean Air Act (hence NESHAPS), and (3) 
DOT hazardous materials rules.  Otherwise the EPA doesn't regulate 
radioactivity (except NORM, e.g. Ra) - that's why mixed waste is under 
dual redgualtion.

Unless your local sewer district has been accepted as an Agreement 
State organization, they cannot impose this restriction.  And it could 
not be accepted as an Agreement State organization with this kind of 
restriction.

Dave Scherer
(scherer@uiuc.edu)