However, the NRC noted that Mo-99 producers have not been swift to adopt LEU production processes developed by the DOE. Crowley explained this is likely due to business concerns, as there would be little revenue benefit or cost savings from conversion. The NRC did not find any large-scale producers engaging in the research and development to convert to LEU production. Nonetheless, the cost of conversion would be less than 10 percent for those large-scale producers, "given a sufficiently long amortization period."

Crowley identified additional steps the NRC recommended for the DOE and others to improve the development of conversion. These steps include: producers committing to conversion and a schedule for eliminating HEU production; DOE making the technical expertise of the national laboratory system available to assist producers with conversion-related research and development; the Department of State intensifying diplomatic pressure on countries still using HEU to convert; the FDA working with industry and technical experts for a common understanding of FDA requirements in obtaining regulatory approvals for medical use of LEU for Mo-99; Congress providing clear policy directions concerning conversion to LEU-based molybdenum 99 production; incentives to motivate conversion and the development of domestic sources of molybdenum 99 production.


Crowley concluded with the NRC's judgment that 7-10 years would be sufficient for producers to make an orderly conversion to LEU-based production.

The final witness was Federal Affairs Senior Director Roy Brown from the Council on Radionuclides and Radiopharmaceuticals (CORAR). CORAR is an organization of companies producing products utilizing many different radionuclides, including the major manufacturers and distributors of the radiological materials used in U.S. medical applications. Several members are primary processors of Mo-99.

Brown stated his support for H.R. 3276, and emphasized a few issues on behalf of CORAR regarding the legislative goals of serving medical needs of domestic patients. Brown said CORAR is urging that the DOE should accept radioactive waste resulting from medical isotope production at reasonable prices; develop a regulatory framework for funding from the legislation without unnecessary duplicative regulatory reviews; that the Nuclear Regulatory Commission allow for the licensing of new medical isotope production reactors that do not have to be licensed as power reactors, and that the DOE has a fair process for administration of funds that is technology-neutral and has appropriate input from industry.

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