NRC License for Depleted Uranium in Davy Crockett...
Transcript of NRC License for Depleted Uranium in Davy Crockett...
NRC License for Depleted Uranium
in Davy Crockett Cartridge, 20mm Spotting M101
Robert Cherry, PhD, CHP
President-elect (2015-2016), Health Physics Society
Radiation Safety Staff Officer
US Army Installation Management Command
M28 Davy Crockett Weapon System
All information herein is in Public Domain
Sources
Wikipedia
YouTube
US Army Corps of Engineers, St Louis District, Archive Search
Report: Use of Cartridge, 20mm Spotting M101, Davy Crockett
Light Weapon M28
Army application and amendment application to Nuclear Regulation
Commission (NRC) for source material license number SUC-1593
The licensing process for the M101 depleted uranium (DU) spotting
round is new and unique to both the Army and the NRC and has been
troublesome to both. Nothing herein is intended as a criticism of the
NRC.
Tactical nuclear recoilless spigot gun
M388 Projectile, Atomic Supercaliber 279mm
M390 Projectile, Atomic Supercaliber 279mm Practice
Deployed 1962-1968
Developed in late 1950s for use against Soviet armor and
troops if war broke out in Europe
Davy Crockett M28 sections assigned to mechanized and
non-mechanized Infantry battalions
M388 round used version of W54 warhead
Mk-54 weighed about 51 pounds (23 kg)
Yield between 10 and 20 tons of TNT equivalent (near
minimum practical size and yield for fission warhead)
Only selectable feature was height-of-burst dial
M28 Davy Crockett Weapon System
M28 Davy Crockett Weapon System
Complete M388 round
76 pounds (34.5 kg)
31 inches (78.7 cm) long
11 inches (28 cm) diameter at its widest point
Subcaliber spigot at back of shell inserted into launcher's
barrel
M388 mounted on barrel-inserted spigot via bayonet slots
Spigot became launching piston after propellant discharged
Maximum range = about 1.25 miles (2 km)
Operated by a three-man crew
Vehicle-mounted M29s eventually replaced M28s
M28 Davy Crockett Weapon System
More than 2,100 M388 projectiles produced
Poor accuracy
Nuclear weapon effects: heat, blast, and radiation
Greatest effect of M388 due to radiation
More than 10,000 rad within 500 feet (150 m)
About 600 rad at quarter mile (400 m)
About 24 rad at max range 1.25 miles (2000 m)
Warhead tested on July 7, 1962 (Little Feller II)
M29 system tested from a distance of 1.7 miles (2.7 km) on
July 17, 1962 (Little Feller I)
Last atmospheric test detonation at Nevada Test Site
Videos on YouTube
M28 Davy Crockett Weapon System
The following museums have a Davy Crockett casing in their
collection:
Air Force Space & Missile Museum, Cape Canaveral Air Force
Station, Florida
National Atomic Museum, Albuquerque, New Mexico
National Infantry Museum, Fort Benning, Georgia
Army Ordnance Museum, Aberdeen Proving Ground, Maryland
(moving to Fort Lee, Virginia)
Watervliet Arsenal Museum, Watervliet, New York
West Point Museum, United States Military Academy, New York
Atomic Testing Museum, Las Vegas, Nevada
Don F. Pratt Museum, Fort Campbell, Clarksville, Tennessee
Low velocity cartridge used to determine the impact point
for the 279mm projectile (M28 system only)
Upon impact, M101 projectile emitted puff of white smoke
Two to three meters in diameter, two to five meters in
height
Visible for several seconds
“Insured a high probability of a first round hit for the
major caliber projectile”
Cartridge, 20mm Spotting M101
Highly dense material required for the 20mm shell body to
mimic trajectories of M388 and M390
Tungsten alloy initially selected
Met military requirements
Costly and difficult to machine
1959 study indicated depleted uranium (DU) alloy as
alternative
8 percent molybdenum (D-38 uranium alloy)
Uranium density (18.8 g/cm3) comparable to tungsten
density (19.6 g/cm3)
DU cost less than 50 percent of tungsten cost
DU easier to machine than tungsten
About 7½ inches long, weighed about a pound
Cartridge, 20mm Spotting M101
DU projectile body spec
= (3,180 ± 25) grains
D-38 alloy/round: 3180 grains
= 206 g
DU/round = 92% × 206 g
= 190 g
Manufactured, assembled, loaded,
and packed at Lake City Ordnance
Plant (LCAAP) MO except fuze
Total production = 75,318 rounds
On Army ranges under NRC
jurisdiction < 30,000 rounds
Cartridge, 20mm Spotting M101
License application to Atomic Energy Commission, May 1, 1961
Letter with two-page enclosure
Machine barstock at Lake City Arsenal
Distribute product to Army Field Forces
“We request … guidance on controls required for the proposed
end use of the item.”
216,157 pounds (98,000 kg) of DU
License # SUB-459 issued November 1, 1961
Lake City Arsenal MO and Frankford Arsenal PA
Included products in addition to M101 spotting round
Allowed distribution to Army Field Forces
Silent on “controls required for the end use of the item”
Original Licensing of the M101 Spotting Round
Renewal, April 21, 1965
Lake City Arsenal no longer on license
Frankford Arsenal remains on license
Amendment, October 17, 1973
Limits Army to fabrication and testing
Distribution to Army Field Forces prohibited
License #SUB-459 expired April 30, 1978; does not address
decommissioning of LCAAP, Frankford Arsenal, or Army ranges
License #SUB-1339 supersedes SUB-459 for Frankford Arsenal in
1978
Army asked for “storage and decontamination”
Remediation activities in 1980-1981
License expired in 1983
Documentation of license termination not found
Did not address residual M101 DU on Army ranges
Original Licensing of the M101 Spotting Round
Remediation of LCAAP
Addresses demilitarization of 40,000 M101 rounds
Does not address residual M101 DU on Army ranges
NRC reexamination of license terminations
GAO-directed in 1989
NRC looked at Frankford Arsenal and residual M101 DU on
Army ranges
NRC determines Frankford Arsenal required additional review
(i.e., data)
NRC does not determine that residual M101 DU on Army ranges
required additional review
NRC confirms Frankford Arsenal acceptable for release on August
18, 2003 after additional surveys and remediation
Original Licensing of the M101 Spotting Round
Physical Properties of Uranium (U) Metal or Alloy
Density = 18.8 g/cm3 (comparison: water, 1.0 g/cm3; lead,
11.3 g/cm3; tungsten and gold, 19.3 g/cm3)
Pyrophoric
Naturally occurring
Found in low levels within all rock, soil, and water
51st most abundant element in Earth’s crust (2-4 ppm)
Less common than tin (#49)
More common than germanium (#53), arsenic (#55), silver
(#65), and gold (#72)
Typical daily intake from food is 0.1 – 1.1 g
Typical body content is about 0.1 mg
Highest atomic number (92) in nature
Radioactive (emits α, , and γ)
Decay series ends at lead-206 (206Pb) or 207Pb
Source (along with thorium) of all helium and radon in
atmosphere
Uranium Isotopes
Isotope Neutrons Half-life (years)
234U 142 245.5 thousand
235U 143 704 million
238U 146 4.468 billion
Typical Isotopic Mass Abundances
Isotope Natural Enriched Depleted
234U 0.0055% 0.03% 0.0007%
235U 0.72% 2.96% 0.20%
238U 99.28% 97.01% 99.80%
Typical Isotopic Activity Abundances
Isotope Natural Enriched Depleted
234U 48.9% 81.8% 14.2%
235U 2.2% 3.4% 1.1%
238U 48.9% 14.7% 84.7%
Primary Biological Effects
EffectKidney Burden
(μg U/g kidney)
Total Kidney
Burden (mg U)
Intake
(mg)
No effect 1.1 0.337 6.5
Maximum nonlethal 2.2 0.71 13
LD50 54.8 16.79 322
Heavy Metal Chemical Toxicity Due to Intake
Likelihood of lung cancer induction due to inhalation is
presumed to be proportional to the radiation dose.
Uranium Overexposure Dominant Effect
Natural Approximately even
Enriched Lung cancer induction
Depleted Chemical toxicity
Potential Health Risks
Models, developed by National Laboratories,
using environmental radiological monitoring
data, show no significant potential health
risks for residual DU on Army ranges
Monitoring to date indicates minimal DU
migration
Uranium Oxides
M101 DU oxidizes when left in the environment. The most common
forms of uranium oxide are U3O8 and UO2. Both:
Are solids
Have low solubility in water
Are relatively stable over a wide range of environmental conditions
Triuranium octaoxide (U3O8)
Most stable form of uranium oxide
Form of uranium oxide most commonly found in nature
Uranium dioxide (UO2)
Form of uranium most commonly used as a nuclear reactor fuel
At ambient temperatures, UO2 gradually converts to U3O8
“Discovery” of M101 DU at Schofield Barracks
In 2005, the Army discovered M101 rounds during unexploded ordnance
(UXO) clearance for a new Battle Area Complex on Schofield Barracks
ranges.
The Army reported this to the NRC in 2006.
The NRC then required the Army to apply for a new license to possess
legacy M101 DU on all its ranges.
USACE St Louis began project to conduct archive searches and to collect
and analyze information concerning M101 use at Army installations.
Commanding General (CG), US Army Installation Management
Command (IMCOM) applied for this license in 2008 on behalf the Army
for all known M101 impact areas under NRC jurisdiction.
Army hired a qualified health physicist to be the license radiation safety
officer (RSO) in 2009.
The license RSO became the manager of licensing activities almost
immediately after hire by default.
USACE St Louis Archive Search Project
Installation Estimated number of M101 rounds
Donnelly Training Area, Fort Wainwright AK 93
Fort Benning GA 9700
Fort Bragg NC 4212
Fort Campbell KY 681
Fort Carson CO 1404
Fort Gordon GA 135
Fort Hood TX 4038
Fort Hunter Liggett CA 135
Fort Jackson SC 135
Fort Knox KY 3956
Fort Polk LA 1923
Fort Riley KS 105
Fort Sill OK 585
Joint Base Lewis-McChord/Yakima Training Center WA 1756
Joint Base McGuire-Dix-Lakehurst NJ 50
Schofield Barracks/Pohakuloa Training Area HI 714
Total 29622 (5628 kg)
Licensing Correspondence, 2009-2010
July 8, 2009: Army provided generic Physical Security Plan (PSP), generic
Environmental Radiation Monitoring Plan (ERMP) and site-specific ERMPs for
Schofield Barracks and Pohakuloa Training Area.
March 11, 2010: NRC requested Army submit license applications for the
remaining DU facilities, including site specific ERMPs, within 6 months.
September 9, 2010: Army responded to March 11, 2010 NRC letter and
requested a two week extension.
September 13, 2010: Army provided the site-specific ERMP for Fort Benning.
November 24, 2010: NRC orders Army to allow:
No entry into any M101 impact area unless NRC-approved RSP is in place
No use of high explosive munitions in any M101 impact area
November 30, 2010: NRC comments on previous correspondence:
Provide site-specific Radiation Safety Programs (RSPs), PSPs, and Training
Programs for each installation where DU is identified
Provide a revised generic ERMP
Develop revised ERMPs for the Schofield Barracks, Pohakuloa, and Fort
Benning sites
Licensing Correspondence, 2011-
February 9, 2011: Army asks for relief at Schofield Barracks from “no
entry” and provided RSP for NRC consideration
February 17, 2011: Army responds to November 30, 2010 NRC letter
May 17, 2011: NRC provides comments on proposed RSP
July 23, 2012: NRC proposes license conditions
August 1, 2011: In response to a petition, NRC issues NOV to Army for
not possessing a license for DU on its ranges, but assesses no penalties
September 10, 2012: Army responds to proposed license conditions (one
of which required constant air monitoring around M101 impact areas)
October 13, 2013: NRC issues SML #1593 to CG IMCOM for Hawaii
ranges
June 1, 2015: CG IMCOM applies for amendment to add remaining 15
installations to license
Current Status
License amendment application includes:
Radiation Safety Plan
Physical Security Plan
Programmatic approach for preparing site-specific
environmental radiation monitoring plan
Decommissioning funding plan (estimated cost for
decommissioning ALL sites = $350,000,000
NRC accepted license amendment application for review and
requested additional information on September 1
NRC published draft license conditions in Federal Register on January 4
Expecting license amendment near end of February