Storm Drain Disposal

[mikeg@SLAC.Stanford.EDU (Michael P. Grissom)]

There is an item called an NPDES permit for those facilities
that routinely discharge detectable materials (including
radionuclides) in storm drains.  The EPA is not fond of any
such discharges but recognizes that anyone with a parking
lot is going to have some oil and lead going into outfalls
with detectable materials in it.  Nonetheless, potential
contaminants are susceptible to maximum permitted limits
(and hence the "generator" must routinely conduct environ-
mental sampling and analysis to verify that permitted amounts
are not exceeded).  If you don't have a permit, you have not
been approved (in the US) to discharge anything via the storms,
but rainwater!

The quantities permitted rarely exceed ppb for organics and a 
very few pCi/l for radionuclides levels.  Certainly, in the 
case of tritium, the levels would be expected to be well below 
the MCL for drinking water applied to POTWs (20,000 pCi/l).  
Permits may specify specific rain/discharge events/levels in 
addition to annual total amounts.  Penalties for exceeding 
permitted levels tend to depend on where (and who) you are!
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>> Someone proposed disposing of radioactive material via storm 
>> sewers.  I thought that the NRC/DOE/Agreement States 
>> prohibited required transfer of radioactve materials to 
>> licensed recipients only.  The sanitary sewer disposal is an 
>> exception to this principle, but I know of no such exception 
>> for storm sewers (or throwing it over the fence, either).
>> 
>How about using effluent concentration limits in Appendix B Table 
>2 of -10CFR 20?(or equivalent agreement state regulations). These
>concentrations are for release to unrestricted areas . 
>  
>BTW, I dont believe that "Disposal of RAM" in concentrations 
>below the regulatory limits is the same as "transfer of licensed 
>quantities of RAM".
>
>Ninni Jacob
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Michael P. Grissom
mikeg@slac.stanford.edu
Phone:  (415) 926-2346
Fax:    (415) 926-3030