Licensing of Depleted Uranium Shielding for Use in Possessing of Mo-99 / Tc-9 9m Generator
See the letter from V. L. Miller to All Medical Licensees and Commercial Nuclear Pharmacies dated January 9, 1986.
This letter states that depleted uranium associated with Mo-99 / Tc-99m generators is exempt from licensing requirements under 10 CFR 40.13 only when it is used as a shipping container.
A specific license from NRC is needed to possess and use the depleted uranium as a shield. Many of the addressees of this letter were authorized to possess and use Mo-99 / Tc-99m generators ranging in activity from 200 millicuries to 16 curies of Mo-99. Although most generators are surrounded by lead shielding, some with Mo-99 activity greater than 4 curies are surrounded by depleted uranium first used as a shipping container and then, upon receipt, as shielding.
The NRC regulations covering depleted uranium are found in 10 CFR Part 40 and include revised provisions that became effective December 24, 1981. The view of NRC is that depleted uranium associated with Mo-99 / Tc-99m generators is exempted from licensing requirements [10 CFR 40.13 (c) (6)] only when it is used as a shipping container (e.g., when the generator is in transit from the manufacturer).
A specific license or authorization from NRC is needed to possess and use the depleted uranium as a shield (e.g., during the time the Mo-99 / Tc-99m generators are stored or used by medical licensees or commercial nuclear pharmacies).
Many licensee facilities using high activity Mo-99 / Tc-99m generators do not have specific authorization from NRC to possess and use the depleted uranium as a shield.
The following license condition must be contained in or added to the license:
"Pursuant to Title 10, Chapter 1, Code of Federal Regulations, Part 40, 'Domestic Licensing of Source Material,' the licensee is authorized to possess, use, transfer, and import up to 999 kilograms of depleted uranium contained as shielding material in the molybdenum-99 / technetium-99m generators authorized by this license."
The absence of this condition on the licensees current license is not a health and safety problem and will not be considered an item of noncompliance. The next time the license is amended, NRC will formally add this condition to licenses authorizing possession and use of 4 curies or more of Mo-99 / Tc-99m generators. Amendments to increase generator possession limits to 4 curies or more will also include this license condition.
Regulatory references: 10 CFR 40.13
Subject codes: 11.1, 11.6
Applicability: Source Material