U.S. Nuclear Regulatory Commission

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

HPPOS-158 PDR-9111220137

Title: 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