U.S. Nuclear Regulatory Commission

Transfer and/or Disposal of Spent Generators

HPPOS-127 PDR-9111210299

Title: Transfer and/or Disposal of Spent Generators

See IE Information Notice No. 81-32 entitled as above and

dated October 23, 1981. This notice states that spent

radiopharmaceutical generators may be stored for decay to

background and, after surveys, disposed of in any manner.

Spent generators with residual activity may be transferred

only to a person licensed to receive the material. The

health physics position was written in the context of 10

CFR 20.201 and 20.207, but it also applies to the "new" 10

CFR Part 20, Sections 20.1301, 20.1801, and 20.1902.

HPPOS-045 contains a related topic.

It was reported to NRC that drivers of transporting

companies with contracts from suppliers to deliver new

generators and to pick up spent generators from medical

institutions were storing the generators at their residence

and/or removing the generator lead shielding for resale.

In one incidence, police found eleven used Mo-99 / Tc-99m

generators from a major radiopharmaceutical supplier inside

a box labeled radioactive materials in the driveway of a

driver. The average exposure rates measured from these

generators were approximately 25 mR/hr at contact and 2

mR/hr at 3 feet; sufficient to deliver a dose of 25 mrem to

the hands during dismantling.

NRC licenses contain specific procedures for the disposal

of spent generators (e.g., return to supplier, etc.). In a

letter dated June 4, 1981, the NRC Material Licensing

Branch stated the conditions for authorizing

decay-in-storage of certain radioactive materials,

including generators. (A copy is enclosed with this

document.) These conditions would be automatically added

to new licenses or to existing licenses upon request. The

proper way to store spent generators for decay and

subsequent disposal is to segregate the generator columns

and monitor them separately prior to disposal. There are

no special requirements on disposal except for appropriate

surveys to verify total decay, records of the surveys, and

defacing or removal of labels on the devices. Any surveys

should include the lead shielding. The generators may be

disposed in non-radioactive trash when the activity has

decayed to background levels. When spent generators are

stored for decay, the requirements of 10 CFR 20.105

(permissible levels of radiation in unrestricted areas), 10

CFR 20.207 (storage and control of licensed materials in

unrestricted areas), and 10 CFR 20.203 (posting and

labeling requirements) must be complied with. [Note: The

equivalent requirements are now found in 10 CFR 20.1301

(dose limits for individuals members of the public), 10 CFR

20.1801 (security of stored material), and 10 CFR 20.1902

(posting of areas or rooms in which licensed material is

used or stored).]

Until surveys indicate that no radioactivity remains, the

generators must be treated as licensed material. None of

the exemptions of Part 30 apply. Any person possessing

these items (e.g., for lead recovery or waste disposal) is

required to have an NRC license. The only exception would

be the delivery of properly packaged and labeled items to a

common or contract carrier for transport to an authorized

recipient.

10 CFR 30.41 (b) (5) requires that licensed material be

transferred only to a person who is licensed by NRC or one

of the Agreement States. Therefore, when transferring

spent generators back to the supplier, the common or

contract carrier transporting the generators should be made

fully aware that any operations with or use of the

material, other than the actual transport or storage, is

not authorized. Following delivery of the generators to

the carrier, licensees are urged to provide specific

instructions on the shipping papers indicating that the

generators are to be delivered to the consignee without any

unnecessary delay or unauthorized storage, and that the

generators are not to be disassembled. It would be

judicious to establish a routine point-of-contact with the

supplier to inform him of the carriers being used, and to

ask for the supplier's cooperation in reporting any

instances of improper actions.

The generator supplier may have provided instructions in

package inserts regarding proper, safe and legal packaging

and transport of generators. If licensees do not have

these instructions or are unfamiliar with them, they are

urged to contact the supplier.

Regulatory references: 10 CFR 20.201, 10 CFR 20.207, 10

CFR 20.1301, 10 CFR 20.1801, 10 CFR 20.1902, 10 CFR 30.41

Subject codes: 3.4, 3.5, 9.7

Applicability: Byproduct Material