ML19161A199

Meeting Summary Document and a Memo

ML19161A199
Person / Time
Issue date:	07/03/2019
From:	Richard Chang Division of Decommissioning, Uranium Recovery and Waste Programs
To:	Stephen Koenick Division of Decommissioning, Uranium Recovery and Waste Programs
Chang R
References
Download: ML19161A199 (6)

Text

July 3, 2019 MEMORANDUM TO: Stephen Koenick, Chief Low-Level Waste and Projects Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards FROM: Richard Chang, Project Manager //RA//

Low-Level Waste and Projects Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards

SUBJECT:

PUBLIC MEETING

SUMMARY

On May 31, 2019, a Category 2 public meeting webinar was held at U.S. Nuclear Regulatory Commission (NRC) headquarters. The purpose of the meeting was to make the public aware that NRC staff is working to confirm that Depleted Uranium (DU) on Department of Defense firing ranges is under regulatory oversight (and if any sites are identified with unregulated DU, NRC staff will work to put that site under appropriate regulatory oversight). The associated meeting was noticed on NRCs public website and the notice is available at NRCs Agencywide Documents Access and Management System (ADAMS) Accession No.

ML19144A200. The meeting agenda was included as part of the meeting notice. A summary of the meeting is enclosed.

Enclosure:

Meeting Report CONTACT: Richard Chang, LLPB/DUWP (301) 415-5888

ML19161A199

• via email OFFICE NMSS/DUWP NMSS/DUWP NMSS/DUWP NAME R. Chang S.Dembek A. Ridge DATE 6/6/19 6/6/19 6/7/19 OFFICE NMSS/DUWP NMSS/DUWP NMSS/DUWP NAME S. Achten S. Koenick R.Chang DATE 6/10/2019 7/2/19 7/3/19

MEETING REPORT DATE: Friday, May 31, 2019 TIME: 2:00 p.m. - 3:15 p.m.

PLACE: U.S. Nuclear Regulatory Commission (NRC) 11545 Rockville Pike, Room T5D30 Rockville, MD 20852 PURPOSE: For the NRC staff to discuss the NRCs Depleted Uranium (DU)

Implementation Plan with the public.

ATTENDEES: See List Below PURPOSE:

The NRC staff developed the DU Implementation Plan to identify DU on military ranges and determine its licensing status. The implementation plan is focused on DU (e.g., spent munitions, armor, other items) that remains on active or inactive military ranges and provides a strategy for confirming that the possession of all DU on active and inactive military ranges is currently either: 1) authorized by an NRC license or 2) being addressed through the Memorandum of Understanding (MOU) between the NRC and U.S. Department of Defense (DoD) for Coordination on Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Response Actions at DoD Sites with Radioactive Materials (available in the Agencywide Documents Access and Management System (ADAMS) at ML16092A294).

This webinar is to make interested members of the public aware of NRCs efforts to confirm the oversight of DU.

BACKGROUND:

In 2007, the Army discovered unlicensed DU in the Davy Crockett M101 Spotting Rounds that were present on one range on the Island of Oahu and four ranges on the Island of Hawaii.

The manufacture, storage, testing, and distribution of these rounds was conducted under Atomic Energy Commission regulatory oversight from the 1940s through the 1970s and NRC regulatory oversight in the late 1970s. Historically, these munitions were not accounted for after they had been used on ranges. The Army did not remove or clean up these spent rounds on the range.

As a result of further evaluation of its ranges, the Army identified additional ranges containing spent DU rounds. Based on the Armys possession of spent DU munitions at these ranges, the NRC requested that the Army apply for a source material license for possession of the DU material. Source Materials License SUC-1593 was issued to the Department of the Army in 2013 for the initial ranges identified. The NRC used a programmatic approach and added the additional sites to the license in 2015.

During the licensing of the Davy Crockett munitions, the NRC staff realized that similar spent DU munitions from other weapon systems could be present on military ranges and not under NRC regulatory oversight. The NRC staff determined that, after completion of the licensing of all the Davy Crockett DU, the NRC would assess if DU munitions from other Enclosure

weapon systems were present on military ranges. Based on these findings, the NRC would determine if further actions were necessary. During a public meeting with stakeholders in 2013 (ADAMS Accession No. ML13352A214), the NRC committed to evaluate the potential for the presence of other (non-Davy Crockett) spent DU munitions on the Hawaiian military installations. This plan will address this commitment and help ensure that DU is under appropriate regulatory oversight nationwide.

DISCUSSION:

NRC staff presented background information and its planned path forward. NRC staffs presentation material (ADAMS Accession No. ML19144A134) was also posted on the webinar for download.

Highlights of the discussion from the Question and Answer portion of the meeting are presented below:

- Questions from the public centered mainly around the: 1) adequacy of environmental monitoring at the Davy Crockett Weapons Systems DU sites in Hawaii; 2) potential health risks associated with DU in the body, especially to the lungs and especially from the oxide chemical form; and 3) potential for DU to transport in the environment, given the potential for DU on firing ranges to be impacted by bombs.

- NRC staff responded to these questions by discussing that: 1) the Davy Crockett Weapons Systems DU sites in Hawaii are adequately monitored consistent with their NRC license; 2) NRC staff accounts for health risks of DU in the body as part of our conservative dose modeling; and 3) Licensed DU munition training ranges have formal security, radiation protection, and environmental monitoring programs in place at the licensed sites. These programs help ensure that soldiers in training and members of the public are protected from radiation and radioactivity as required by license and regulatory requirements.

After the webinar, NRC staff received a number of public comments. As appropriate, NRC staff will be responding to these comments. These are the summaries of the comments that have been received to date:

1. Issues with the Webinar (e.g., the availability of a more detailed preliminary outline (agenda) would have been helpful; some problems with the on-line webinar question panel as it kept disappearing).

2. While the NRC need not enforce the Armys regulations for the Army, it must not ignore its existence and at the very least minimally require the same standards for the license as those regulations.

3. Military use of depleted uranium in weapons and armor should be explored in U.S.

Territories as well.

4. Sampling at installations is an important part of determining if DU is present and in what quantity and form, and what the risk from its presence might be.

5. In the webinar it seemed that NRC was accepting a common bottom line that although DU is present, the yearly dose one might receive, including the mythical resident farmer, is so low as to be a negligible risk factor. That would change, of course, with a different mode. Forget whole body dose but use a more realistic model that considers the most organ-specific and probable risk through inhalation.

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6. Another issue that was approached during the webinar was clean up of DU. It would be proper for the NRC to require remediation to be part of the license.

7. Has anyone studied the feral sheep, mouflon, goat and even cattle populations for the presence of DU near these sites.

8. Hot DU and Cold DU should be examined for their impacts on people (Hot DU and Cold DU are isotopically different).

The staff plans to respond to the Pohakuloa Training Area-specific comments as part of correspondence back to Dr. Reimer. The response will be publicly available to be included under the Docket Number 040-09083.

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WEBINAR ATTENDEES:

First Last Name Name 1 Myranda Spear 2 Robert Atwell 3 Robert Cherry 4 Craig Adams 5 Bryan Frey 6 David Shaffer 7 Robert Cherry 8 Mary Svoboda 9 Gregory Fleming 10 Sarah Lopas 11 Mike Kurth Masnyk 12 Orysia Bailey 13 Christine Lipa 14 Patty Pelke 15 Wendy Steinhoff 16 David Pelton 17 Terri Spicher 18 Joan Heller 19 Christina Peace 20 Mike Kunowski 21 Blair Spitzberg 22 Shawn Seeley 23 Kevin Huhn 24 Myranda Spear 25 Donna Janda 26 Luwella Leonardi 27 Jim Albertini 28 Michael Reimer 29 Michael LaFranzo 30 Priya Yadav 31 Lino Fragoso 32 Betsy Ullrich 33 Alan Hale 34 Steve Acker 35 Katherine Warner 36 Julie Clements 37 Shirley Xu 38 Christianne Ridge 39 Richard Chang 4