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HPPOS-158 PDR-9111220137

10 CFR 20.303 (d) – Disposal by Release Into Sanitary Sewerage Systems

See the excerpt from IE Manual entitled as above and dated February 26, 1973. Under 10 CFR 20.303 (d), a licensee may release up to one curie per year into any one sewerage system. If a licensee maintains facilities in several cities, each facility could release up to one curie per year provided that separate sewerage systems are involved. This health physics position also applies to “new” 10 CFR 20.2003 (a) (4).

A literal interpretation of 10 CFR 20.303 (d) appears to indicate that the maximum quantity of radioactive material that a licensee may release to a sanitary sewer is one curie per year. While this is essentially true, this also implies that the sum total for all geographical sites under one license may not exceed the above limit, even if a licensee has 10 or 100 facilities spread throughout the country. OGC advised that the words in the regulation, “… radioactive material released into the sewerage system may not exceed …” could be construed to mean that no more than one curie may be released into any one sewerage system by a licensee. [Note: 10 CFR 20.2003 (a) (4) states similarly: “The total quantity of licensed and other radioactive material that the licensee releases in the sanitary sewage system in a year does not exceed 5 curies (185 GBq) of hydrogen-3, 1 curie (37GBq) of carbon-14, and 1 curie (37 GBq) of all other radioactive materials combined.”]

“Sewerage systems” are generally local (e.g., city) so that if a licensee maintains facilities in several cities, each facility could release up to one curie per year, provided separate sewerage systems are involved. OGC also advised that this interpretation is consistent with the intent of the regulations, i.e., to maintain releases at a minimum to a sewerage system in the interest of precluding any significant health problems. By contrast, a much worse situation could be conceived where a thousand licensees use the same sewerage system, which is perfectly legal under the present regulations, but would appear to be of greater significance than the above considerations.

Regulatory references: 10 CFR 20.303, 10 CFR 20.2003

Subject codes: 9.2, 9.7

Applicability: All