Economic impact of 10CFR61 a utility point of view

No one who is generating radioactive waste needs to be told what has happened to disposal costs over the past five years. The implementation of 10CFR61 has given disposal site operators another reason to increase site-related disposal costs. This, however, is only a part of our increased cost and not the part for discussion now. The real impact to utilities of Part 61 comes in the reporting and documentation requirements of waste classification and waste form. Part 61 requires the reporting of the concentrations of certain isotopes. Some industries that utilize only a known number of isotopes can state with certainty those isotopes not present and usually know, within a reasonable range, the concentrations of others to be expected in their waste streams. Reactor operations, on the other hand, produces a broad spectrum of fission and activation product whose distribution and concentration may vary with time within a reactor system. The fact that nearly all of the isotopes listed in Part 61 might (or could) be present in reactor wastes means that measurements must be made for them down to the physical lower limits of detection. The problem is compounded when one must measure low concentrations of low energy beta and alpha emitters in the presence of higher concentrations of gamma emitters. Part 61 mandates a waste classification system based upon isotopic concentrations. Wastes exceeding the limits for Class A have additional requirements on waste form that must be documented. The paper discusses actual cost associated with implementation of a Part 61 program, as well as annual costs for program maintenance. In addition, a range of costs is discussed that should define the limits of an acceptable program