[CPEO-MEF] Depleted Uranium at Jefferson Proving Ground

[Lenny Siegel <lsiegel@cpeo.org>]

[The following is from Richard Hill <phill@venus.net>.]


October 5, 2001


Army's Depleted Uranium (DU) decommissioning plan (DP) for Jefferson
Proving Ground (JPG) rejected by Nuclear Regulatory Commission (NRC)

NRC's acceptance review of the DP found seven deficiencies in the Army's
plan.  Of these seven deficiencies, six were the same ones pointed out
by Save the Valley's written responses to the DP.  In their report on
the review the NRC still fails to address the non-radiological, toxic
heavy-metal properties of DU. The Army will be allowed to correct the
deficiencies and submit them to the NRC.  No time limit has been set for
these corrections.

Following is a verbatim relation of the deficiencies as included in the
NRC's September 27 letter to the Army:

1. To support license termination, the licensee has evaluated two main
scenarios using RESRAD version 6.0 in the dose assessment of the
depleted uranium (DU) impact area.  The dose assessment scenarios
presented in the DP do not account for possible off-site transport of DU
and subsequent exposure to receptors.  Therefore, the DP should be
revised to include an additional dose assessment for surface water and
groundwater users off-site.  This scenario should include the potential
DU transport pathways:  (1) drinking ground/surface water contaminated
with DU; (2) ingesting vegetables that have been irrigated with DU
contaminated ground/surface water; and (3) ingesting milk and meat from
livestock that have ingested DU contaminated ground/surface water and DU
contaminated ground/surface water irrigated crops and forage.  This
additional dose assessment scenario is required to adequately assess the
impact soluble or particulate DU from stream flow or groundwater would
have on potential receptors.

2. The licensee needs to include an assessment of the potential for
ingestion of DU in meat from deer, turkeys, fish, and other wildlife
that have been exposed to DU. Data used for this assessment should
represent current conditions of DU concentrations in wildlife tissue and
human consumption rates.  The assessment is needed in order to calculate
the potential amount of DU ingested by off-site receptors.

3. The licensee needs to evaluate the potential for the DU penetrators
to be carried by Big Creek flood waters down stream from the DU impact
area.  This information is needed to understand the possible transport
mechanisms of the DU from the impact area to off-site areas.  The
potential impact of other natural events, such as tornado or earthquake,
on off-site transport needs to be evaluated.

4. The dose assessment scenarios rely heavily on model default
parameters.  Licensees may use default values for behavioral and
metabolic parameters (primarily those describe for D and D) as long as
the values are consistent with the definition of the average member of
the critical group.  Physical parameters should be justified.  Site
specific data are an important part of an EIS evaluation and should be
provided if they are reasonable to measure.

5. Section 3.4.3 identifies heavy fog as potentially resulting in ground
deposition of airborne radionuclides.  However, this information should
either be included or justified for elimination from the dose estimates
provided as either an on-facility or off-facility transport pathway.

6. Water control structures such as beaver dams are briefly discussed in
Section 3.6.5.  The licensee should identify what impact ponds or marsh
areas would have on the DU. This information is needed to determine if
additional water in the DU impact area would affect the degradation of
the DU or enhance off-site transport.

7. The composition of the DU should be completely characterized.  There
are recent reports that DU may contain impurities such as plutonium,
americium, technetium, neptunium, and uranium-236.  The composition of
the DU is needed to determine the effect of the DU on human health and
the environment.

Richard Hill
President, Save the Valley
<phill@venus.net>
visit our website at:  http://www.oldmadison.com/stv/

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