Re: Storm Drain Disposal

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

Licensees are prohibitted from releasing materials to unrestricted 
above specified concentrations, but that does not mean we are free to 
do whatever we want below these concentrations.  Would it be 
permissible to bury waste on site (or off site) if the concentrations 
are below the DACs?  Not in Illinois.  Any exceptions to the disposal 
procedures specified in the regulations must be listed in the 
license.

And the sewer provisions are more liberal, not more restrictive, than 
other releases.  Sewer discharge concentrations can be up to ten 
times the DAC for public areas.

Dave Scherer
scherer@uiuc.edu

Having reviewed many licenses, and license applications, I find that
most licensees box themselves into corners and invite citations via
unnecessarily restrictive statements in their license applications. Face
it, if you include waste disposal procedures in excruciating detail,
you're stuck with them with little flexibility. However, if you say
something like, "We will dispose of our radioactive waste through a
qualified waste broker, or other method in accordance with the
regulations" this allows a lot of options. Remember, the regulations
authorize release of radioactive material to the environment, to air and
water, at certain concentrations, with additional limitations on
sanitary sewer releases. If they say you can do it, why not?