[CPEO-MEF] Fwd: JPG DU Environmental Report and Decommissioning Plan

[Lenny Siegel <lsiegel@cpeo.org>]

Begin forwarded message:

> From: Richard Hill <rhill@cinergymetro.net>
> Date: September 13, 2013 5:55:35 PM PDT
>
>
> FYI,
>
> On August 28, 2013 the U.S. Army submitted to the Nuclear  
> Regulatory Commission (NRC) the final Environmental Report (ER) and  
> Decommissioning Plan (DP) for the Depleted Uranium (DU) impact area  
> at the former Jefferson Proving Ground (JPG) near Madison,  
> Indiana.  Between 1984 and 1994 armor-piercing DU rounds were  
> tested for accuracy by being fired into soft targets (tarps  
> stretched between tall poles).  This testing left approximately  
> 175,000 pounds of DU on and in the ground in the DU testing area at  
> JPG.  The area also contains a significant amount of unexploded  
> conventional ordnance (UXO) as a result of prior testing of those  
> types of weapons.
>
> The Environmental Report was prepared in support of the Army's  
> Proposed Action to terminate its U.S. Nuclear Regulatory Commission  
> (NRC) Materials License for the Jefferson Proving Ground (JPG)  
> Materials License SUB-1435, Docket Number 40-08838, Amendment No.  
> 17 allows for the possession only of up to 176,370 pounds (Ib)  
> (80,000 [kilograms] kg) of depleted uranium (DU) metal, alloy, and/ 
> or other forms in the DU Impact Area.  This Environmental Report  
> fulfills requirements specified in Title 10, Code of Federal  
> Regulations (CFR) Parts 51.45 (Environmental Report) and 51.60  
> (Environmental Report-Materials Licenses). The Decommissioning Plan  
> (U.S. Army 2013a) includes additional information related to the  
> Army's Proposed Action to terminate NRC Materials License SUB-1435.
>
> This Decommissioning Plan was prepared in support of the Army's  
> request to terminate its U.S.
> Nuclear Regulatory Commission (NRC) Materials License for Jefferson  
> Proving Ground (JPG) located in Madison, Indiana, under restricted  
> conditions. The U.S. Army is the organization responsible for this  
> license. Colonel Elmer Speights, Jr., Garrison Commander, U.S. Army  
> Garrison, Rock Island Arsenal (USAG-RIA). I Rock Island Arsenal,  
> Rock Island, Illinois 61299-5000 is the representative from the  
> Army responsible for ensuring the completion of the license  
> responsibilities. This Decommissioning Plan presents background  
> information, assessments, and commitments to support this license  
> termination request.
>
> The selected decommissioning objective is license termination with  
> restrictions in compliance with the requirements of Title 10, Code  
> of Federal Regulations (CFR) Part 20 Section 1403 (10 CFR  
> 20.1403).  The selection of this objective for decommissioning and  
> license termination was made after considering decontamination and  
> license termination without restrictions (10 CFR 20.1402). The Army  
> maintains that the license termination with restrictions was  
> selected for the following reasons:
>
> * It is compatible with current and future use plans for the JPG  
> property, specifically the
> maintenance of the Big Oaks NWR and the use of portions of the JPG  
> property for bombing
> practice by Indiana Air National Guard.
> * The Army has proposed institutional controls that involve  
> continued perpetual Army ownership and access and land use  
> restrictions for the area north of the firing line, in general,  
> because of the potential unexploded conventional ordnance hazards.
> * The Army has committed to request the necessary annual funding  
> for the maintenance and
> implementation of institutional controls necessary to support  
> license termination under
> restricted conditions.
> * The proposed institutional controls are legally enforceable and  
> provide reasonable assurance
> that the total effective dose equivalent (TEDE) from residual DU  
> radioactivity distinguishable
> from background to the average member of the critical group will  
> not exceed 25 millirems per
> year (mrem/y) if the institutional controls remain in place.
> * Residual radioactivity at the site is such that if institutional  
> controls were no longer in effect,
> there is reasonable assurance that the TEDE from residual  
> radioactivity distinguishable from
> background to the average member of the critical group is as low as  
> reasonably achievable
> (ALARA) and would not exceed 100 mrem/y.
> * The residual DU activity is consistent with ALARA because of the  
> high costs of UXO and DU
> detection, removal, and disposal and the small benefit that would  
> result from the cleanup of
> portions or all of the approximately 2,080-ac (8.4-kin 2) DU Impact  
> Area inside the 50,950-ac
> (206-km2) portion of JPG where UXO is present and 1,038 ac are  
> currently used for bombing
> practice. The ALARA analysis also indicates that decontamination of  
> the DU Impact Area
> under lowest cost remediation scenario to meet the criteria for  
> unrestricted use was determined to be prohibitively expensive.
>
> The NRC will have 90 days to evaluate the ER and DP.  If the NRC  
> finds issues with the ER or DP they will send those issues back to  
> the Army for resolution.  Barring any issues the NRC will decide  
> whether to grant or deny the license termination.
>
> License Termination will mean no remediation, no monitoring, and  
> use of institutional controls to secure the area.
>
>
>
> Richard Hill

--

Lenny Siegel
Executive Director, Center for Public Environmental Oversight
a project of the Pacific Studies Center
278-A Hope St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/961-8918
<lsiegel@cpeo.org>
http://www.cpeo.org

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