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



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


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


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


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


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


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


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%

Uranium-238 Decay Series

Uranium-235 Decay Series

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

Uranium Chemistry

UO2(NO3)2∙6H2O = uranium nitrate hexahydrate (UNH)

“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)

Typical M101 Impact Area

M101 Rounds

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

Davy Crockett (1786-1836)

Upon losing re-election to Congress:

“You may all go to hell, and I will go to Texas.”

nrc license for depleted uranium in davy crockett...

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