This chapter considers general applications for DU and specific military applications in particular. It describes the regulations, policies and procedures that the Army follows in acquiring, ensuring system safety, producing, storing, transporting, demilitarizing and disposing of DU weapon systems. In addition, this chapter briefly describes the Armyís radiation protection program for all phases of the DU life cycle.

3.1 Applications

During the early years (1945 to 1960) of weapons production and reactor fuel manufacturing, DU was collected and stored. Scientists and engineers later found additional military and civilian uses for DU because of its density. The material has been used in military ordnance and in medical, space, aviation, heavy equipment, and petroleum exploration applications. The U.S. military uses DU in kinetic energy penetrators, armor plate and anti-personnel mines. Other nations also use DU in civilian and military applications. Typical non-military systems that use DU include:

• Neutron detectors.
• Radiation detection and shielding for medicine and industry.
• Shielding in shipping containers for radiopharma- ceuticals, other radioisotopes, and spent nuclear reactor fuel rods.
• Components of aircraft ailerons, elevators, landing gear, and rotor blades.
• Damping weights, mounting brackets, and boring bars to suppress vibration chatter during petroleum exploration.
• Counterbalance weights in radar antennae and ballast in satellites, missiles, and other craft.

The Army uses alloyed DU in the 25, 105, and 120 millimeter (mm) kinetic energy cartridges. The Bradley Fighting Vehicle will use the 25 mm cartridge (not released for use as of May 1995) in its chain gun. The M1 and M60 series tanks use the 105 mm cartridge; the Army also plans to use the 105 mm in the main gun of the XM8 Armored Gun System. The M1A1 and M1A2 Abrams Tank main guns use the 120 mm cartridge. A cross section of a typical 120 mm DU round is shown in Figure 3-1. DU is used as an armor component on the M1 series heavy armor (HA) tanks. Small amounts of DU are used as an epoxy catalyst for the M86 Pursuit Deterrent Munition (PDM) and the Area Denial Artillery Munition (ADAM).

More than 50 current and former sites have been involved in the production, manufacture, development, testing and storage of DU for various DoD uses (see charts in Appendix B). As of February 1994, contractors had produced more than 1.6 million DU penetrators for tank ammunition and more than 55 million DU penetrators for small caliber (20, 25 and 30 mm) applications. More than 99 percent of the small-caliber production has been for the U.S. Air Force (30 mm GAU-8)

3.3ÝÝÝ Acquisition

Three documents describe the policies and procedures of the Defense Systems Acquisition Process that the Army follows for major weapon systems:

• DoD Directive (DODD) 5000.1, Defense Acquisition
• DoD Instruction (DODI) 5000.2, Defense Acquisition Management Policies and Procedures
• DoD Manual (DODM) 5000.2-M, Defense Acquisition Management Documentation and Reports

Figure 3-1ÝÝ 120 mm DU Round

Figure 3-2ÝÝ Defense Systems Acquisition Process

The Army essentially follows the life cycle evaluation process described in the National Environmental Policy Act (NEPA). These findings are documented in Annex E of the Integrated Program Summary for a proposed system at each milestone. The NEPA process, as incorporated into the Defense Systems Acquisition Process, also requires a complete system life cycle analysis of the environmental consequences of a proposed system and the actions the PM or system user can take to mitigate any environmental impacts. This process starts with the inception of the system and is carried through to the systemís disposal from inventory. The NEPA requires the PM to use a systematic interdisciplinary approach to determine the environmental consequences of using a proposed system. Similar evaluations are made under Military Standard-882C (MIL-STD-882C), System Safety Program Requirements, for personnel and equipment safety during system use, as well as under individual service regulations.
As Figure 3-2 shows, the Defense Systems Acquisition Process begins with determining mission needs and continues through system operations and support. It includes field testing to ensure compliance with requirements. However, except for system effectiveness, it does not address the results of a systemís use. For example, it may not address test range cleanup after a system is used.

Army Regulation 70-1 (AR 70-1), Army Acquisition Policy?Research, Development, and Acquisition, implements DODI 5000.2 and assigns responsibilities to DA commands to support environmental quality and system safety activities. When DoD is acquiring a new system, the Program Executive Officer (PEO), Program Manager (PM), or major command (MACOM) designee is responsible for the required environmental analyses, system safety evaluations, and health hazards evaluations. DA Pamphlet 70-1 (DA Pam 70-1), Materiel Acquisition Handbook (revised February 1994), provides procedural guidance. Other regulations detail subordinate command procedures for safety, health and environmental analyses of weapon systems. AR 200-2, Environmental Effects of Army Actions, governs NEPA implementation; it establishes policy, procedures and responsibilities for assessing the environmental effects of Army actions. The following sections of AR 200-2 relate to AR 70-1 and the DoD documents previously described:

1-5, b. Environmental considerations will be integrated into the decisionmaking process to ensure tható
Ý
(1) Major decision points are designated for principal programs and proposals likely to have a significant effect on the quality of the human environment, while providing for the NEPA process to coincide with these decision points.

(2) Relevant environmental documents, comments, and responses accompany the proposal through the existing Army review and the decisionmaking process. The Army will integrate NEPA requirements with other planning and environmental review procedures required by law or Army practice so that review of environmental considerations is concurrent rather than consecutive.
Ý

2-1, b. The NEPA process includes the systematic examination of possible and probable environmental consequences of implementing a proposed action. To be effective, integration of the NEPA process with other Army project planning will occur at the earliest possible time to ensureó
(1) Planning and decisionmaking reflect environmental valuesÖ.
2-1, c. To achieve these actions, all Army decisionmaking that may have an impact on the human environment will use a systematic, interdisciplinary approach that ensures the integrated use of the natural and social sciences, planning, and the environmental design arts. (PL 91-190; Sec. 102 (2) (A)). This approach allows timely identification of environmental effects and values in sufficient detail for evaluation concurrently with economic, technical, and mission-related analyses at the earliest possible step in the decision processÖ.

2-2, a. The types of projects or actions to evaluate for environmental impact includeÖ.

(2) New management and operational concepts and programs in areas such as logistics, research, development, test and evaluation, procurement, and personnel assignment.

(5) Requests for a Nuclear Regulatory Commission license (new, renewal, or amendment) or an Army radiation authorizationÖ.

2-2, b. In addition to the above, certain activities supported by the Army... require proper environmental documentation: Ö
Ý
(3) Request for approval to use or store materials, radiation sources, hazardous and toxic material, or wastes on Army landÖ.
2-6, c(2). An example would be the assessment of a proposed major weapon system program. Development of an overall programmatic EIS [Environmental Impact Statement] or EA [Environmental Assessment] for the life cycle of the system is recommended. Tiered EAs and EISs, as appropriate, would evaluate specific subphases such as testing, production, development, use, and ultimate disposal.

3-1, f. Life cycle environmental document (LCED). The LCED is intended to be a programmatic assessment that addresses the known and reasonably foreseeable environmental impacts of a proposed item/system during all phases of development, production, use, and ultimate disposal of the item/system. The LCED may be in the form of an EA or an EIS, and must be supplemented to address additional significant environmental impacts as conditions change. The LCED will be prepared by the DA proponent/developer (or program manager) and is most frequently used within the materiel research, development, and acquisition community.

Table 3-1 lists the environmental documentation for Army systems involving DU.

3.4 System Safety

The DODD 5000.1, Defense Acquisition and MIL-STD-882C, System Safety Program Requirements, provide requirements for developing and implementing a system safety program to identify hazards and improve design requirements and management controls. They are intended to eliminate hazards or to reduce risk to an acceptable level. The MIL-STD-882C applies to all DoD systems and facilities and to every activity in the system life cycle.

The AR 385-16, System Safety Engineering and Management, implements the DoD system safety policy. It prescribes policies and procedures and identifies responsibilities to ensure that the Army identifies hazards in its systems and facilities and properly manages their risks. Army policy requires commands to implement system safety engineering and management responsibilities throughout the life cycle of each Army system and to document each systemís safety. This documentation is reviewed at all Materiel Decision Reviews. Army policy under AR 385-16 is that the health hazard assessment required by AR 40-10, Health Hazard Assessment Program (HHA) in Support of the Army Materiel Acquisition Decision Process must be considered. Safety analyses and safety and health verifications are key to the Armyís system safety effort.

Table 3-1.ÝÝ Environmental Documentation for Army Systems With DU

Note: The Project Managerís OfficeÝ for the M1A2 heavy armor tank is updating environmental documentation for the tank and will complete it before fielding the weapon (Hyder, 1993; Cannon, 1993). The authors did not find any plans to generate environmental documentation for the ADAM mine.

The HHA Program is designed to identify, evaluate, and eliminate or control health hazards associated with weapon system management. AR-40-10 states that the Army cannot compromise health protection criteria and standards without formally documenting the risks. For each system, the PM must submit health hazard data to the Armyís Office of the Surgeon General (OTSG) for assessment. In addition, the U.S. Army Test and Evaluation Command (TECOM) confirms the safety of each fielded munition system. TECOM is an Army Materiel Command (AMC) subordinate command chartered as the independent safety evaluator for weapon systems.

The MIL-STD-882C, AR 385-16, and AR 40-10 normally require TECOM to do substantial testing of components and systems of a new design. Since World War I, the Army has developed a series of standard tests for tanks and ammunition; new tests are created as needed. Where appropriate, a program manager may initiate tests on weapons at extreme and ambient temperatures (-25^o to 120^o F). Health and safety testing includes tests for toxic fumes, blast overpressure, radiation, rough handling, vibration, metal fatigue (where component failure could hurt personnel), excess charge, and human factors. Before the Army uses any weapon, TECOM reviews data from tests involving personnel and, if satisfied, issues a safety release. Various reports document the results and conclusions of safety and environmental testing. The reports include the safety confirmation issued by TECOM, the HHA issued by the U.S. Army Center for Health Promotion and Preventive Medicine (USACHPPM) and reviewed by the AMC Command Surgeon, and the Safety and Health Data Sheet issued by the developer. The reports identify all known residual hazards and categorize them according to severity and frequency. The developer then must either eliminate the hazards or reduce the risks to an acceptable level.

A program manager must request approval of each residual hazard in a weapon system being proposed for acceptance. The PM is required to write a formal System Safety Risk Assessment (SSRA) to document the acceptance of any risk that exceeds the criteria for low risk.

Radiological hazards are a particular concern during the development of DU munitions and armor. The Army measures radiation from a cartridge, a cartridge in its shipping container, a pallet of rounds, and a vehicle fully loaded with DU munitions.Ý It then performs hazard classification tests, including burn tests of a pallet, to determine exclusion zones and appropriate cleanup procedures for a fire or explosion (Fliszar, 1993b). Other tests include tank burn tests and hard impact tests of a penetrator on an armored target. If a new DU weapon is similar to an existing DU weapon, some of the tests are not repeated.

After testing the developmental item and measuring radiation, the developers, including the Armament, Munitions and Chemical Command (AMCCOM), compare the data with established radiation system safety protocols, that include current NRC standards. The developers then prepare a request for a license amendment that AMCCOM submits to the NRC. The NRC passes judgment on the proposed license amendment. The Army does not release items to the soldier in the field in peacetime without an approved NRC amendment.

The AMCCOM assumes responsibility for monitoring the weapon system in the field and serves as the central point of contact on DU questions and issues from the field. It conducts periodic wipe tests on ammunition to detect the formation of uranium oxides (Buckrop, 1993). The Army Materiel Systems Analysis Activity (AMSAA) also periodically tests ammunition and armor.

3.5 Production

3.5.1ÝÝ General Controls

Except for exploration and mining, NRC has primary responsibility for regulating the use and disposal of uranium. Additional groups that oversee various aspects of the uranium life cycle include DoD, DOE, EPA, the Department of Transportation (DOT), BLM, USFS and 28 ìagreement states.î
Section 274 of the Atomic Energy Act of 1954 allows a state to assume regulatory authority over nuclear sources and byproducts if its governor signs a formal agreement with NRC. For a state to assume this authority and become an ìagreement state,î its governor must certify that the stateís regulatory program can protect the public health and safety. Furthermore, NRC is required to ìperform an independent evaluation and to make a finding that the Stateís program is adequate from a health and safety standpoint and is compatible with the Commissionís regulatory programî
(57 Federal Register 22495-01). The NRC reviews the licensing and regulatory actions of ìagreement statesî to ensure continuing compatibility with NRC regulations (56 FR 66457-02). Federal facilities in ìagreement states,î however, are regulated by NRCís regional licensing program and not by the states [10 CFR 40.5(b)(2)].

The NRC has issued a general license authorizing limited transfer and use of DU by commercial and industrial firms; research, educational and medical institutions; and federal, state and local government agencies. These entities are allowed to use and transfer no more than 15 pounds of DU at a time.Ý The yearly limit is 150 pounds (10 CFR 40.22). Fifteen pounds of DU is about the size of a 12-ounce soft drink can. The license does not authorize metallurgical processing or machining of uranium. The NRC requires anyone possessing more than 15 pounds of DU, except DOE or DOE prime contractors, to have an individual license (10 CFR 40.22). Therefore, DA contractors must obtain an NRC or ìagreement stateî license to machine DU into munitions.

When DU is used solely because of its high density, the user only needs to register with NRC and dispose of the DU by returning it to a licensed disposal site. For example, when DU is used as a counterweight in an airplane, missile or helicopter, the user is exempt from source material licensing regulations (10 CFR 40.13).

NEPA provides the means to ensure protection of the environment (40 CFR 1500-1508). Federal agencies are required to comply with the act and use it as a decision tool in actions that will protect, restore or enhance the environment. The AR 200-2, Environmental Effects of Army Actions, implements NEPA. AR 200-2, paragraphs 2-2a(5) and 2-2b(3),Ýrequires the Army custodian who manages the use or storage of radioactive materials on Army property to assess environmental impacts for new NRC licenses, renewals or amendments.

3.5.2ÝÝÝ Procurement Procedures

An AMC subordinate command, such as AMCCOM or the Tank Automotive Command (TACOM), uses a Material and Services Order to procure DUF₆ from DOE for a specific weapons program. DOE ships cylinders of DUF₆ to a designated, licensed commercial company. The company converts the DUF₆ to DUF₄, an intermediate product, and then converts DUF₄ into depleted uranium metal (CMI, undated; DOE, 1993). Army contractors, licensed by NRC or an ìagreement state,î process, alloy, form, and machine the metal. The NRC, EPA, ìagreement statesî and Army regulations control health and environmental management in this phase of the Army DU life cycle.

3.5.3ÝÝÝ Manufacture of DU Components

Army contractors manufacture penetrators from DU metal at contractor-owned, contractor-operated (COCO) facilities. The NRC and ìagreement statesî license these contractors to possess and store DU and to produce munitions components from it. A typical contractor license would permit a company to receive DUF₆ from DOE; transport it to a manufacturing facility; process it into DUF₄ and DU metal products; and sell material containing DU to an authorized buyer (DOE, 1993).

Licensees must ensure that workersí internal and external exposure to DU is consistent with standards in 10 CFR 20. Procedures vary with each license. License representatives from NRC and ìagreement statesî periodically inspect workplaces and records to ensure compliance with license provisions and appropriate state and federal regulations. To prevent environmental contamination outside a facility, 10 CFR 20 also requires
compliance for releases into the air and water. Some licensees design an ERM plan to document compliance.

Aerojet Ordnance Tennessee, Inc., (AOT) of Jonesborough, Tenn., and Nuclear Metals, Inc., (NMI) of Concord, Mass., are licensed to produce DU penetrators (Hickman, 1993; Vumbaco, 1993a). The Manufacturing Sciences Corporation (MSC) of Oak Ridge, Tenn., produces DU castings, bar stock, sheet and plate (Liby, 1993).

The M919 25 mm DU round is produced exclusively by Olin Ordnance in Marion, Il.; the rounds were originally produced by Aerojet Manufacturing of Chino, Calif., while the M774, M833 and M900 (105 mm) penetrators and the M829, M829A1 and M829A2 (120 mm) penetrators have been made by both AOT and NMI (Hickman, 1993). Figure 3-3 shows 105, 120 and 25 mm cartridges that contain DU penetrators. The penetrators are produced under subcontract to a government prime ammunition production contractor (usually Alliant Tech Systems of Edina, Minn., or Olin Ordnance of St. Petersburg, Fla.). The prime contractor then contracts for the metal parts manufacturing and projectile assembly with Olin Ordnance of Red Lion, Pa.; Chamberlain Manufacturing of Waterloo, Iowa; or National Manufacturing Corporation of St. Louis, Mo. Two government owned, contractor-operated (GOCO) plants load, assemble and pack (LAP) the complete tank rounds: the Milan Army Ammunition Plant (MAAP) of Milan, Tenn., operated by Martin Marietta Ordnance Systems, Inc. and the Iowa Army Ammunition Plant (IAAP) of Middletown, Iowa, operated by Mason & Hanger - Silas Mason Company, Inc. (Van Dorn, 1993; Vumbaco, 1993a; Crumpler, 1993; Hickman, 1993). Aerojet performs LAP for the 25 mm DU rounds. Each facility operates under its own license.

Figure 3-3.Ý Cartridges that Contain DU Penetrators
Ý
The NMI and AOT are involved with all DU processes (conversion, reduction, casting, metal forming, machining, etc.) (NMI, undated a, undated b). Their licenses require radiation safety programs, including a thorough annual medical workup for all employees exposed to radiation on the job. The companies also periodically perform bioassay monitoring (whole body counting and analysis of uranium in the urine) to measure the amount of radioactive material deposited in the lungs and kidneys of workers. Each of these monitoring practices helps assure compliance with regulatory requirements and with the philosophy to keep risk As Low As Reasonably Achievable (ALARA).

When NMI and AOT work for the Army using DU, they submit employee radiation exposure information to the Army in a quarterly report as a contract deliverable.

NMI also produces cast billets that are used to make armor for the M1A1 Heavy Armor tank. During development of the M1A1 armor system, MSC also produced cast billets. The DOE fabricates them into DU armor at its Special Manufacturing Capability Site at Idaho Falls, which is operated by Babcock and Wilcox Idaho, Inc. The Lima Tank Plant in Lima, Ohio, operated by the Land Systems Division of the General Dynamics Corporation, installs the DU armor on the tanks and covers it with homogeneous rolled steel armor (McGuire, 1993a, 1993b, 1993c, 1993d; Liby, 1993).
Alliant Tech Systems, Inc., manufactures the M86 PDM and ADAM at the Twin Cities Army Ammunition Plant in New Brighton, Minn. Very small quantities of DU serve as a catalyst in an epoxy molding compound that forms the body of these two mines. Each 206-gram mine contains approximately 0.101 g of DU. Based on the weight percent of DU within the molding compound, the mines are exempt from NRC licensing (10 CFR 40.13). In a survey of radioactivity that Alliant Tech Systems, Inc., conducted in 1983, observed readings were well below NRC requirements for an unrestricted work area (DA, 1991).

In an effort to minimize DU waste generated in the manufacturing process, the Army has funded several processes that reduce DU waste generated during DU penetrator production. AOT has a program that uses magnesium as a reducing agent to convert DUF₄ to DU metal. This process generates a magnesium fluoride (MgF₂) waste stream contaminated with DU. Historically, the MgF₂ waste stream has been classified as a radioactive waste requiring disposal as such. AOT has developed a process to recover DU contamination from the waste stream so that MgF₂ is no longer considered an NRC- regulated waste. The Army has procured the license rights for DoD, DOE and their contractors to use this process (NMI, 1991; AOT, 1993).

3.6 Army Licenses

The Army has 14 NRC licenses to possess DU.Ý Twelve of these are for developing, testing and deploying munitions and armor containing DU. Several contractors are also licensed to use DU at Army ammunition plants, firing ranges and other locations. No license is held at the DA or MACOM level for using DU in munitions or armor. Instead, NRC issues Army licenses to the individual user or manager of a system containing DU. The licenses are site- and mission-specific. In accordance with AR 200-2, all sites must document the environmental impact of using or storing DU. Some of the AMC subordinate commands or activities that are licensed to use or store DU munitions or armor hold more than one license. A discussion of each Army licensee follows.

3.6.1ÝÝ Test and Evaluation Command

TECOM is responsible for testing all Army materiel, including DU munitions and armor. It has four test centers individually licensed to use DU: U.S. Army Combat Systems Test Activity, Jefferson Proving Ground, Yuma Proving Ground and White Sands Missile Range (WSMR). The WSMR does not test DU munitions or armor and is not discussed further in this report. Each TECOM test center has an environmental monitoring program and has a document addressing the environmental impacts as required by AR 200-2. TECOM has contracted Los Alamos National Laboratory (LANL) to study the long-term fate of DU at Aberdeen Proving Ground (APG) and YPG. This investigation is designed to determine if DU migrates within or out of impact areas and, if so, what effect it has on the environment and affected populations. LANL can use information from the study to infer the health and environmental effects of DU on these ranges. LANL published a draft report from the study in late May 1995.

3.6.2ÝÝÝÝ U.S. Army Combat Systems Test Activity

USACSTA, formerly the Material Test Directorate of APG, is licensed to test DU munitions and armor at APG. Systems tested there include the Bradley Fighting Vehicle, the Abrams Tank and the Tank Main Armament Systems (TMAS). In munitions testing, various sizes of rounds are fired against soft targets (plywood, plastic mesh, cloth) and hard targets (armor, steel). USACSTA conducted all testing on outdoor ranges until 1979, when NRC prohibited destructive testing that released airborne radioactive material to unrestricted areas. To accommodate this ruling, USACSTA moved hard target testing indoors so it could contain the DU particles this testing produces. In soft-target testing, DU penetrators remain intact or break into large fragments (see Figure 3-4). Soft-target testing creates relatively few aerosol particles and is conducted on open test ranges at APG and YPG.

As of December 1992, USACSTA had used about 92,554 kilograms (kg) of DU in soft-target testing. Before 1989, personnel recovered 21 percent of the DU fired at soft targets during periodic downrange sweeps. However, these sweeps exposed personnel to hazardous unexploded ordnance (UXO). In 1989, USACSTA installed catch boxes to limit the spread of DU contamination and to reduce personnel exposure to UXO (see Figure 3-5). These sand-filled three-sided enclosures capture about 85 percent of the DU munitions fired (Oxenberg and Davis, 1993).

USACSTA has two enclosed hard target test ranges for DU: the Bomb Throwing Device (BTD) Range (Figure 3-6) and the Superbox at Fordís Farm (Figure 3-7). In the Superbox, USACSTA can fire DU munitions against a fully loaded tank equipped with DU armor.

Figure 3-4.Ý Intact and Broken DU Penetrators

Figure 3-5.Ý Catch Box at USACSTAÝ

Figure 3-6.Ý Bomb Throwing Device Range

Figure 3-7.Ý Superbox at Fordís Farm

DU-contaminated targets are disassembled in an enclosure at Fordís Farm. This structure was built in 1980 for hard-target testing and used for test firing until 1985. Disassembly must be done in an enclosure because cutting targets can release DU fragments and aerosols. The enclosure has air ventilation and filtration systems to ensure that the quality of exhaust air meets NRC standards (10 CFR 20). Real-time aerosol monitors sample respirable particles and display aerosol concentrations in aerosol mass per unit volume of air ( g/m3). Measurements are conservative because the monitors measure all airborne substances (including dust, water, etc.) as DU. In accordance with 10 CFR 20, employees must wear respirators and protective clothing to minimize exposure when airborne particulates are detected.

USACSTA has a facility at BTD Range to decontaminate armor plate for recycling (Figure 3-8). USACSTA and ARL-Aberdeen have minimized radioactive waste production by recycling decon- taminated and contaminated armor plate. USACSTA transferred 3,000 tons of contaminated armor plate to LANL in 1986 and 1987 for use as radiation shielding. However, holes and uneven surfaces in the plates reduced the shielding efficiency by about 25 percent compared with new armor plate. Therefore, in 1991, USACSTA contracted Scientific Ecology Group (SEG) to process 1,400 tons of contaminated plate into uniform blocks for DOE to use as radiation shielding (Figure 3-9). AMCCOM has since contracted SEG to process APGís stockpile of plate (produced by USACSTA and ARL-Aberdeen) into additional shielding blocks for DOE.

Since 1979, USACSTA has had an active ERM plan to detect possible DU migration to the environment. USACSTA continues to improve and enhance this ERM plan. USACSTA has an EA and a Finding of No Significant Impact (FNSI) addressing all DU operations at APG.
APG has contracted LANL to design a single ERM plan to address all radioisotope use by tenant activities, such as USACSTA and ARL-Aberdeen. APG expects to implement the new ERM plan in FY96 (Ebinger, 1992a).

Figure 3-8.Ý Decontamination Facility at BTD Range

Figure 3-9.Ý Uniform Shielding Block
Ý
3.6.3ÝÝÝÝ Jefferson Proving Ground

JPG conducted production acceptance testing of DU munitions against soft targets from March 1984 to May 1994 (NRC, 1991b). Figure 3-10 shows the location of JPG near Madison, Ind. From March 1984 to December 1992, JPG tested 90,832 kg of DU. It recovered 21,872 kg or 24 percent of the amount fired (Oxenberg and Davis, 1993). JPG shipped recovered penetrators to the manufacturer for recycling. The Army plans to close JPG in FY95 as part of Base Realignment and Closure (BRAC) and to transfer its DU test mission to YPG. JPG did not install catch boxes, because base closure procedures prevent the construction of new facilities.

Before firing DU on the range, JPG conducted an environmental baseline study as part of an environmental assessment. JPG has also taken samples from the test range twice yearly since 1983. As a result of the EA, JPG filed a FNSI for the DU activities.

Figure 3-10.Ý Jefferson Proving Ground

To safely remediate the DU-contaminated areas of the JPG ranges, the Army will have to strip several feet of soil to ensure the simultaneous removal of UXO. This action will facilitate soil erosion, thereby increasing the potential for DU-contaminated soil to migrate to previously clean areas. Range remediation must consider the safety issue of UXO on the range from unrelated testing of high explosive rounds.

LANL has been contracted to develop a risk assessment to evaluate alternative decommissioning strategies that will comply with current NRC requirements. TECOM is preparing a proposal to have the impact area characterized for radiation exposure and radioactivity levels. JPG will use the risk assessment, site characterization and decommissioning plan in developing remediation plans for the site (10 CFR 40.36).

The range at JPG, under existing NRC guidance, can not be released for unrestricted use unless it meets an NRC 35 picocurie (pCi) DU per gram (DU/g) of soil standard. However, the Army and NRC, using information from the LANL risk assessment (Ebinger, 1991a and Ebinger, 1993b) and elsewhere, are negotiating to develop an approach that minimizes the overall environmental impact of both the radioactive and UXO contaminants on the JPG range. JPG requested that NRC terminate its license without decommissioning the impact area to unrestricted use criteria. All buildings and firing sites were surveyed and decontaminated as required.Ý These buildings and sites are awaiting NRCís confirming survey. The NRC is writing an EIS that considers in-place closure of the impact area as a wildlife refuge managed by the U.S. Fish and Wildlife Service.

3.6.4ÝÝÝÝ Yuma Proving Ground

YPG in Arizona, shown in Figure 3-11, began testing DU research and development (R&D) munitions against soft targets at gun positions 17A and 20 in 1982 (NRC, 1992e). YPG fired 38,590 kg and recovered 18,852 kg of DU during the first 10 years of operation. Catch boxes have not been built at Yuma because approximately 50 percent of the DU is already recovered. Initial estimates did not suggest that catch boxes would offer a significant improvement. However, USACSTA data have shown that catch boxes typically retain more than 85 percent of DU munitions fired at APG. Given these new data, YPG has scheduled construction of a catch box at gun position 17 to support the transfer of JPGís mission. If the workload requires continued operations at gun position 20, YPG plans to build a catch box at that position, also.
YPG has an EA addressing the environmental impact of testing at gun positions 17 and 20. YPG also has an ERM plan and collects soil samples twice a year and sediment samples after major rainstorms. Sample data do not indicate migration out of the impact areas. YPG has contracted LANL to develop a new ERM plan that would better assess the potential for DU migration (Ebinger, 1992b).

Figure 3-11.Ý Yuma Proving Ground
Ý
3.6.5ÝÝÝÝ Army Research Laboratory

The Army Research Laboratory is licensed for DU at Watertown, Mass., and at APG.

ARL-Watertown

ARL-Watertown was formerly the Materiels Technology Laboratory (MTL) and the Materiel and Mechanics Research Center. The NRC licensed MTL to research and develop alloys and to explore military applications of DU. It was authorized to smelt, machine, cut and cast DU when developing alloys and shapes. MTLís mission ended in the late 1980s. ARL-Watertown is scheduled to be closed as part of BRAC and is presently licensed only to decontaminate and decommission its facilities and to store radioactive material until disposal. The cost for decontaminating and decommissioning ARL-Watertown is 72 million dollars. ARL-Watertown has asked USACHPPM to verify decontamination before NRC, the Commonwealth of Massachusetts and EPA will conduct the final survey. ARL-Watertown must assure these regulators of decontamination before NRC will terminate the license.

ARL-Aberdeen

The NRC has licensed ARL-Aberdeen, formerly the Ballistic Research Laboratory (BRL), to research and develop DU penetrators and armor for the Project Managers of the Bradley, Abrams, and TMAS.Ý The ARL-Aberdeen has conducted DU experiments since the Armyís early use of DU in the 1950s. It is authorized to fire various sizes of munitions against hard targets in enclosed facilities at APG and at other temporary U.S. sites. (ARL-Aberdeen stopped open-air firing at APG in 1979.) It is also licensed to machine and cut targets containing DU and to decontaminate armor plate by liquid abrasive blasting (high pressure water mixed with an abrasive).

ARL-Aberdeen decontaminated the Aberdeen Transonic Range (an outdoor test range used before 1979). It packaged the principal waste, DU-contaminated sand, as radioactive waste and stored it at APG. The APG radioactive waste manager plans to dispose of the sand at a burial site operated by Envirocare of Utah, Inc., of Clive, Utah but is awaiting approval from AMCCOM, the Armyís radioactive waste manager. The Aberdeen Transonic Range has not yet been surveyed, certified and released.

ARL-Aberdeen operates three enclosed hard target facilities at Ranges 9, 14 and 110 (Figure 3-12). ARL- Aberdeen monitors personnel exposure and environ- mental releases from the ventilation systems at these facilities and uses the highest measurements of DU-contaminated particles to calculate the time that personnel can safely remain in a range without exceeding personal exposure limits.

Hard target testing generates much low-level radioactive waste (LLRW) as contaminated filters, armor plate, and debris from target assembly. ARL-Aberdeen has aggressively worked to reduce this waste by compacting and shredding filters and by decontaminating armor plate. It removes contaminated areas around penetration points in these plates using liquid abrasive blasting. This process is more effective and produces fewer incidental waste products (such as acid) than the electropolishing process, which ARL-Aberdeen used before 1989.

Figure 3-12.Ý Aberdeen Proving Ground
Ý

ARL-Aberdeen has an EA that addresses its various DU operations at APG and an ERM plan that evaluates the potential migration of DU to soil, surface water, air and vegetation (ARL, 1989, 1990). As confirmed by the ERM and area surveys, the enclosures contain the airborne contaminants and contaminated water from washing targets. Based on the EA and on sampling data from the ERM plan, ARL-Aberdeen published an FNSI that addressed three alternatives: no testing, testing at another location, and continued use of the existing enclosed firing ranges. ARL-Aberdeen considered the last option acceptable because the use of DU at APG had no significant environmental effects.

3.6.6ÝÝÝÝ Watervliet Arsenal

Watervliet Arsenal, N.Y., has also studied various uses of DU in munitions. The arsenal no longer conducts DU research or uses DU. The site still contains contaminated equipment, therefore, maintains its NRC license. This site will be decommissioned when the Army has met all cleanup criteria (NRC, 1993a).

3.6.7ÝÝÝÝ Armament Research, Development and Engineering Center (ARDEC)

The NRC has licensed the ARDEC at Picatinny Arsenal, N.J., to use DU to research and develop munitions and armor for the Project Managers of the TMAS, Bradley and Abrams. The license authorizes ARDEC to machine, cut and fabricate DU.Ý ARDEC is also authorized for indoor hard impact testing of small caliber DU munitions, but it has not tested any since 1985. DU is only used in indoor areas that are routinely surveyed for contamination. ARDEC stopped firing DU munitions outdoors in the early 1960s. ARDEC did not develop an ERM plan for this facility because it considered pathways to the environment to be insignificant. Because the DU operations at ARDEC predate AR 200-2, no environmental documents accompany the NRC license that specifically address the use of DU. ARDEC has a contractor preparing these documents to bring it into compliance with AR 200-2 (Fliszar, 1993a, 1994c).

3.6.8ÝÝÝÝ AMCCOM

The AMCCOM has two NRC licenses:Ý one authorizing it to use standardized DU sources for instrument calibration and one authorizing fielding of DU munitions (NRC, 1991a, 1992d). The second license authorizes AMCCOM to ship, store and receive DU munitions at Sierra Army Depot in Herlong, Calif.; Seneca Army Depot in Romulus, N.Y.; Hawthorne Army Depot in Hawthorne, Nev.; Letterkenny Army Depot in Chambersburg, Pa.; and temporary locations at Army installations and Marine Corps bases anywhere in the U.S. This license is limited to type-classified munitions that have NRC approval, such as the 105 mm M774, M833 and M900; the 120 mm M829 and M829A1; the 25 mm PGU-20/U series; and the Air Forceís 30 mm GAU-8. In the past, the Navy used the 25 mm PGU-20 round but has phased it out of use. The license does not cover storing, shipping, receiving or firing R&D munitions. Licenses granted to contractors and to Army Research, Development, Testing and Evaluation (RDT&E) activities must cover these R&D munitions.

AMCCOM is responsible for decontaminating the Lake City Army Ammunition Plant in Independence, Mo., which tested DU in the 1960s. The NRC licensed the Remington Arms Company to operate this plant. When the operating contractor changed from Remington Arms to Olin Ordnance, AMCCOM was required to assume licensing responsibility because Olin was not prepared to assume license responsibility for past operations not affiliated with its contract requirements.

3.6.9ÝÝÝÝ Depots and Depot Activities Licensed for DU

Savanna, Sierra and Tooele Army Depots and the Seneca Army Depot Activity are individually licensed to store, transport, inspect and perform minor maintenance on DU munitions. Savanna, Sierra and Tooele are licensed to demilitarize 30 mm GAU-8 DU munitions, although only Savanna has performed these operations. As of February 1994, Seneca was awaiting approval to conduct the same operations. Environmental documentation required in AR 200-2 to specifically address the impact of DU at these locations had not been prepared by the depots as of June 1994 (Davis, K., 1993; NRC, 1990a; Scott, 1993).

3.6.10ÝÝÝÝ Tank Automotive Command

TACOM is licensed to transport, store and receive DU-armored tanks at Army installations anywhere in the U.S. and to assemble DU armor onto tanks at the Lima Army Tank Plant in Lima, Ohio. TACOM is not licensed to maintain or repair the tanksí DU armor. Chem-Nuclear Systems is licensed to do this maintenance and repair and to decontaminate tanks at the Defense Consolidation Facility (DCF) in Snelling, S.C. (McGuire, 1993e). As discussed further in Chapter 4, DCF is processing the DU-contaminated tanks and Bradleys from Operation Desert Shield and Desert Storm (McGuire, 1993f).

3.6.11ÝÝÝÝ Army Contractors

Several contractors are licensed to load, to assemble and pack and to fabricate and test DU ammunition at Army or non-government sites. Alliant Tech Systems, Inc., and Olin Ordnance test DU munitions at the Energetic Material Research and Technology Center in Socorro, N.M. (formerly the Terminal Effects Research and Analysis (TERA) Facility). Alliant Tech Systems conducted open air testing of DU munitions for the Army at the Naval Weapons Center (NWC) in China Lake, Calif., from 1979 to 1989. The Army has completed remediation at NWC that meets NRC and California criteria. Alliant Tech Systems is also authorized to fabricate DU munitions at the Twin Cities Army Ammunition Plant in Minnesota (NRC, 1992a). The General Electric Company is licensed to test DU munitions at the Ethan Allen Firing Range in Burlington, Vt. The Army has stopped using the Twin Cities Army Ammunition Plant and the Ethan Allen Firing Range for DU operations; the contractors are decommissioning these sites according to the terms of their contracts.

3.7ÝÝÝÝ DU Ammo Storage

The Army stores DU ammunition at depots and installations. Figure 3-13 outlines the policies and procedures that pertain to the handling, storage and use of DU.

Large caliber (120 mm) M829 series rounds are factory-packed in individual, waterproof metal containers that interlock into pallets holding either 25 or 30 rounds (Figure 3-14) (Hooker and Hadlock, 1986). The 105 mm rounds are packaged in either metal or fiber con tainers. Metal containers are interlocked into 30-container pallets. Fiber containers are packed with two rounds per wooden box, either 15 or 20 boxes per pallet (Bratlett et al., 1979). Medium caliber rounds (25 mm), such as M919 ammunition, are stored belted, 15 rounds per belt, two belts per can, with 27 cans per pallet (Hadlock and Parkhurst, 1990).

Figure 3-13.Ý Policies and Procedures Pertaining to DU Handling, Storage and Use

Figure 3-14.Ý 30-Container Pallet of DU Ammunition Rounds

Storage capacity at depots, field ammunition supply points and basic load holding areas is restricted by NRC license possession limits and the amounts of explosives (TM 9-1300-206, 1973). The typical above-ground structure can hold 100,000 to 600,000 pounds of DU; however, some storage configurations may hold up to 1,700,000 pounds. The explosive hazards of the propellant exceed the DU radiation hazards and thus determine storage requirements. NRC regulations require the Army to identify DU storage areas as radioactive materials areas (10 CFR 20.1902(e)).

3.8ÝÝÝÝ Ammunition Management

DODD 5160.65 assigned the mission of Single Manager for Conventional Ammunition (SMCA) to the Secretary of the Army. This made the Army responsible for depot and ammunition plant storage inventory of all conventional ammunition (including DU) and explosives for all the military services. AMCCOM is the field operating agency responsible for executing this mission (DA, 1983). The Executive Director SMCA is located at AMC in Alexandria, Va.

The SMCA mission includes managing the production, storage and transportation of munitions. The mission excludes a few service-specific items, such as torpedoes, large rockets, smart bombs and missiles. The SMCA does not manage DU munitions inventories after they are issued for use overseas or to other services.

The Army National Inventory Control Point (NICP) manages the Armyís worldwide stockpile of conventional ammunition and explosives. AMCCOMís Ammunition Directorate in Rock Island, Ill., serves as the NICP. It issues combat ammunition on demand. DU ammunition is used only in combat and is not issued for training.

3.9 Transportation

Two separate legal regimesódomestic and internationalógovern the transportation of low-level radioactive materials and waste. DOT and NRC regulations contain the domestic regime. Several United Nations (U.N.) conventions and agreements make up the international regime.

3.9.1ÝÝÝÝ Domestic Transportation

DOT regulates the transportation of hazardous materials and hazardous waste in the U.S. (49 USC 1804 et seq). DOT regulations apply to DU both as a hazardous material and as a hazardous waste. NRC requires that shipments in government-owned aircraft conform to DOT regulations (10 CFR 71.5(b)). NRC or ìagreement statesî license the Army and its contractors to ship and receive DU. The shipper is responsible for ensuring that the shipment complies with the requirements for shipping radioactive material and that the receiver is licensed to receive radioactive material.

To ship or transport DU munitions or armor, DA contractors must register with DOT. The Army, other federal agencies and state governments are exempt from this requirement (49 CFR 107.601, 606).

DOT regulates the labeling and packaging of radioactive material for shipment. Packages of radioactive material for shipment must be labeled according to 49 CFR. Packages that contain no radioactive material except DU are exempt from these DOT labeling requirements if the DU packaging meets alternative DOT standards. DOT also requires placarding of freight containers and transport vehicles containing hazardous materials (49 CFR 173.424, 172.500).

DOT requires employers to train workers who transport hazardous material. This training includes hazard awareness training, function-specific training, safety training, driver training, and EPA or Occupational Health and Safety Administration (OSHA) training that fulfills OSHA requirements (29 CFR 1910). Employers must maintain training records.

Four other regulations also govern interstate transport by the Army:

• Army Technical Manual (TM) 55-315, Transportability Guidance for Safe Transport of Radioactive Materials.
• Army Technical Bulletin (TB) 9-1300-278, Guidelines for Safe Response to Handling, Storage, and Transportation Accidents Involving Army Tank Munitions or Armor Which Contain Depleted Uranium.
• AR 55-355, Defense Traffic Management Regulation.
• 49 CFR 171-179.

3.9.2ÝÝÝÝ International Transportation

Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal (1989) governs the movement of hazardous waste across national borders. The U.S. Senate ratified this convention in August 1992. Implementing legislation was introduced in the House of Representatives on March 7, 1994. As of July 1994, the State Department was awaiting the outcome of the House action.

In 1990, the U.N. International Atomic Energy Agency (IAEA) resolved to strengthen international cooperation on nuclear and radiological protection. It recommended that the U.S. adopt the Code of Practice on the International Transboundary Movement of Radioactive Waste as policy (IAEA, 1990).

The code sets forth guidelines for ensuring the safe international movement of radioactive waste. It mandates that such movement should only occur with prior consent of the sending, receiving and transit nations. In addition, it requires that the owner should conduct all stages of movement in a manner consistent with international safety standards. It also requires all nation states involved to have the administrative, technical and regulatory ability to fulfill their respective responsibilities for the movement. The code is advisory and does not affect existing or future arrangements among the nation states.

The code defines radioactive waste as ìany material that contains or is contaminated with radionuclides at concentrations or radioactivity levels greater than the exempt quantities established by the competent authorities and for which no use is foreseen.î DU may be covered by this definition. The U.S. has not yet adopted the code but has followed it.

According to customary international law, conventions such as the Basel Convention do not apply to vessels and aircraft with sovereign immunity (such as non-commercial craft on military or diplomatic missions). The Senateís ratification of the treaty and the Houseís implementing legislation both state this exemption to the convention.

The Army makes international shipments of DU systems under 49 CFR 173.421 or .424 (under DOT Exemptions E2136 or E9649) and the International Maritime Dangerous Goods (IMDG) codes for water shipments. Countries that do not accept DOT exceptions will accept U.N. Competent Authority Approvals signed by DOT.

3.10 Demilitarization

DODM 5160.65-M, Single Manager For Conventional Ammunition, covers the demilitarization of military items and implements conventional ammunition policies and procedures. Chapter 13, paragraph A, states, ìDemilitarization and disposal methods and procedures must be incorporated into the design and development of new or modified ammunition items. This technology must provide acceptable methods that comply with applicable environmental requirements.î Subparagraph 1d. states, ìIncluded in the design of all new or modified conventional ammunition items is the requirement to develop safe and environmentally acceptable demilitarization procedures.î

In addition to the DoD requirements, U.S. Army Materiel Command Regulation (US AMCR) 75-2, Demilitarization/Disposal Requirements Relating to the Design of New or Modification of Ammunition Items, requires a system developer to publish a demilitarization disposal plan before the system goes into production. Additional AMC directives detail how to demilitarize materials in an environmentally acceptable way.

A Depot Maintenance Work Requirement (DMWR) contains specific demilitarization procedures. These documents provide the minimum technical information necessary to prepare standard operating procedures (SOP) for maintenance and demilitarization. They specify special safety, technical and production inspection requirements; tooling and equipment to be used; methods; procedures; materials; waste stream analyses; and reference documents. AMCCOM or its designee has prepared a DMWR for each DU munition, tank and mine containing DU. These are listed in Table 3-2.

The historical philosophy for demilitarizing tank ammunition was to separate the components (cartridge case, propellant, penetrator, etc.); to salvage them, where possible, for use in new cartridges; and to dispose of the remainder. The earliest DMWR for DU munitions used this philosophy with the exception that DU penetrators could be stored until they were needed or appropriately disposed as low-level waste (LLW).

The Army has written DMWRs for all DU tank munitions; however, it has not demonstrated the technologies with pilot plant investigations. These investigations are required to confirm that proposed technologies are adequate. The Army believed the concept for demilitarizing DU rounds was similar to that for tungsten rounds. Written procedures for DU demilitarization are similar to those for tungsten. The Army has not conducted proof of concept studies (to confirm the demilitarization technology) on a tank round since it validated the M735, a tungsten tank round fielded in the late 1970s.

Table 3-2.Ý Depot Maintenance Work Requirements Documentation

A new approach to the demilitarization of DU ammunition has been proposed. This plan links production of DU tank ammunition to the recovery of DU from demilitarized ammunition. The objective is to recycle DU penetrator material into new tank rounds. The Army hopes to create a closed loop system where it recycles DU and thus reduces both disposal costs and production costs for the manufacture of DU alloy from DOE stocks of DUF₆Ý

AMCCOM designated the IAAP as the site for future processing of DU tank munitions to the projectile or subprojectile level (Kowalski et al., 1994). The AMC is contracting IAAP to build and install the necessary equipment. In addition, APG has disassembled 1,400 rounds of M774 tank ammunition to the component level and shipped it in equal amounts to each penetrator manufacturer. The contractors are evaluating the DU core chemistry for recycling. This evaluation will finalize the processes necessary to remelt and produce new DU penetrators. An AMC contractor will design, develop and install demilitarization equipment at IAAP during this evaluation. The Army plans to use about 1.5 million pounds of recycled DU for armor and penetrators in its purchase of M829A2 cartridges through 1997 (PM TMAS, 1993).

Propellant contaminated with DU may become a problem in the demilitarization operation. Batelle Pacific Northwest Laboratory (PNL) is investigating propellant disposal methods that are less likely to inject DU into the environment than open burning/detonation or incinera- tion processes currently used for waste propellant destruction.

Demilitarizing DU tank munitions, like any manufacturing operation involving DU, is regulated for health, safety and environmental consequences. These regulations have been described in earlier sections of this report.

To demilitarize tanks with DU armor, TACOM will remove the DU from the armor package and release the decontaminated vehicle for standard Army salvage procedures. The plan is for DU armor to be recycled into new armor or projectiles. However, this process has not been implemented by TACOM, because no undamaged DU armored tanks have been demilitarized.

All Army ammunition and armor containing DU is within its minimum design life of 20 years. Therefore, no installation has conducted a mass disassembly of DU ammunition or armor. To avoid disassembly costs, the Army typically sells older ammunition to allied countries or gives it to them as military assistance. Historically, foreign sales reduced the need to demilitarize ammunition to damaged or otherwise unserviceable rounds. In 1994, approximately 150,000 rounds of unserviceable DU tank ammunition were inventoried for demilitarization.

The ADAM and the PDM contain DU [approximately 0.1 gram (g) by weight] as a curing agent for their epoxy/plastic casings. The ADAM is used as a submunition in the 155 mm howitzer (AMCCOM, 1984b). Tooele Army Depot recently completed a test using the Army Peculiar Equipment (APE) 1236 Deactivation Furnace, which is designed to demilitarize the ADAM. Preliminary analysis of the waste from this operation did not detect radiation levels above background. At the time of writing, final test reports were pending from Tooele Army Depot. AMCCOM will update DMWRs for the 155 mm projectile to reflect the findings of the Tooele Army Depot tests when the final report is released.

The GAU-8A/PGU-14 30 mm round, which the Army manufactures and demilitarizes for the Air Force, has an aluminum projectile with a fully encapsulated DU core. The Army DMWR specifies a piece of APE 2214 to demilitarize this ammunition.The APE 2214 breaks the projectile from the cartridge case, burns out the tracer, vacuums away the propellant and separates the projectile from the empty cartridge case.

AMCCOM used the APE 2214 (with some modifications) to develop the DMWR for the M919 25 mm cannon caliber ammunition in 1993. The scope of this DMWR is to separate the projectile from the cartridge case, burn out the tracer, vacuum away the propellant, and separate the projectile from the empty cartridge case. The DMWR does not clearly define the final disposition of the DU projectiles accumulated by these operations.

3.11 Decontaminating / Decommissioning Army Installations

The Army has never decontaminated or decommissioned soft-target impact areas at its test centers, although it has disposed of some DU-contaminated soil as low-level waste. It does not expect to decontaminate its test centers, until it terminates the test missions or closes the installations. JPG discarded a small quantity of soil [less than 200 cubic feet (ft3 )] as LLW. The APG disposed of approximately 2,000 ft3 of surface soil from the hard- target site on the Fordís Farm Range before building enclosed ranges in 1980 and 1989. Both sites sent their waste to the low-level waste disposal facility in South Carolina. APG is decontaminating and decommissioning the Transuranic Range, which ARL-Aberdeen used for open- air testing and USACSTA used for a radioactive waste storage area.

YPG excavated a natural berm that impeded the flight of penetrators and stockpiled the soil near the line of fire at Gun Position 20 (Figure 3-15). YPG asked AMCCOM to dispose of the soil as radioactive waste in 1992, but AMCCOM delayed the project because it did not have funding. In an attempt to avoid unnecessary disposal costs, YPG then proposed to use the soil as a stopping media in future catch boxes. However, YPG has not received funding for a catch box at Gun Position 20, and moving the soil for use in the proposed catch box at Gun Position 17A would be too expensive. In August 1994 this soil was excavated, transported, and disposed at the Envirocare facility in Utah.

Figure 3-15.Ý Contaminated Soil Awaiting Disposal at YPG
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Ý

Dense vegetation at APG and JPG makes it hard to recover penetrators manually and increases the potential for injury from UXO (Figure 3-16). In the desert (YPG), it is easier to see UXO and recover penetrators. All three test centers have recovered spent penetrators from impact areas and returned them to manufacturers for demilitarization and recycling. Manufacturers have historically used the DU from these recovered penetrators in commercial products. The Army does not currently recycle the DU recovered from ranges into new penetrators.

USACSTA has discontinued recovery efforts until its catch boxes are decommissioned. The Army does not plan to decommission the catch boxes until they contain 100,000 kg of DU, or airborne DU contamination becomes a hazardÝ (as defined in 10 CFR 20, NRC, 1993b).Ý JPG conducts recovery operations twice a year, in the fall and spring when vegetation is dormant. YPG conducts recovery operations monthly between firing programs. Each year the test centers calculate a mass balance of DU expended/recovered. The amount recovered averages between 21 percent (at JPG and APG) and 50 percent (at YPG) of the rounds fired.

Figure 3-16.Ý DU Penetrator in Dense Vegetation at JPG
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As a result of a 1989 General Accounting Office (GAO) report to Congress, NRCís Decommissioning Procedures and Criteria Need to Be Strengthened, NRC developed the Site Decommissioning Management Plan (SDMP) in 1990. This plan seeks to identify and resolve issues associated with timely decontaminating and decommissioning of sites contaminated with low levels of radioactive material. The plan lists 46 sites with complex cleanup issues, excessive costs, or radiological hazards associated with decontamination. It also provides criteria for placing a site on the list or removing a site from the list. The list includes fourÝ Army installations contaminated with DU: APG, JPG, Watertown Arsenal and Lake City Army Ammunition Plant.

Test programs conducted by USACSTA at APG have contaminated approximately 1,200 acres of the test range with DU penetrators. Some groups have suggested that these penetrators could contaminate groundwater; however, evidence to date indicates that the soil characteristics at Aberdeen inhibit the formation of soluble DU compounds that could contaminate the groundwater.
Watertown Arsenal and Lake City Army Ammunition Plant are contaminated with DU from past operations. The SDMP list does not include JPG, YPG or ARL-Aberdeen. JPG has the same type of DU contamination as USACSTA at Aberdeen; thus, it meets the criteria for the SDMP list. DU penetrators are dispersed across 6,000 acres at YPG. ARL-Aberdeen has not decontaminated and decommissioned the Transuranic Range. (ARLís license is cited by the SDMP, but the activities described are USACSTAís.)

In April 1992, NRC developed a plan to accelerate remediation of the sites on the SDMP list (54 FR 13389). The Army has decommissioned Watertown Arsenal. Lake City Army Ammunition Plant has completed its site characterization and is developing its decommissioning plan. The NRC recently reviewed USACSTAís environ- mental sampling data at APG. These data showed that the groundwater is not contaminated and that the DU in the impact area does not present a health and safety hazard. For these reasons, NRC should be removing Watertown Arsenal, Lake City Army Ammunition Plant and APG from the SDMP list.

3.12ÝÝ Disposal

The Clean Air Act (CAA) classifies all substances containing radionuclides as hazardous substances (40 CFR 61; 42 USC 7412). Any substance classified as hazardous under CAA is also classified as hazardous under CERCLA (42 USC 9601). However, CERCLA excludes DU from its requirements if the release of DU into the environment occurs in compliance with a valid NRC permit, license, regulation or order (Stover, 1983). Furthermore, RCRA excludes DU in its definition of solid waste (Sharp, 1992). Disposal of DU is controlled by the Low-Level Radioactive Waste Policy Act (LLRWPA) and its amendments and by NRC regulations (10 CFR 61; 10 CFR 20). In the United States, the Army must manage expended DU ammunition and vehicles contaminated with DU according to LLRWPA. This act allows states to create regional compacts for low-level radioactive waste (LLRW) disposal. The Army must dispose of LLRW at either a federal disposal facility or a state compact facility. Two state compact disposal sites have been accepting LLRW from the federal government, but one of these (Snelling, S.C.) stopped accepting federal waste in July 1994; it is unclear how long the other (Richland, Wash.) will continue to accept government LLRW. Envirocare of Utah, a contractor-operated DOE facility, currently accepts DoD LLRW with some restrictions. The future of this disposal option also is uncertain.

The NRC regulations govern the transfer and disposal of low-level radioactive waste (10 CFR 30). They require that DU be transferred only to authorized recipients, and they establish a tracking system and extensive record-keeping requirements for such transfers (10 CFR 20.2001, 2006). The NRC requires that radioactive waste only be disposed of at licensed land disposal facilities (10 CFR 20.2002). NRC further requires a waste generator to properly classify, describe, label and package radioactive wastes to be transferred to a disposal facility and to certify that they are in proper condition to be transported according to DOT regulations (10 CFR 20.2006). NRC regulations also provide that ìland disposal facilities must be sited, designed, operated, closed, and controlled after closure so that reasonable assurance exists that exposures to humans are within the limits established in the performance objectives contained [within the regulations]î (10 CFR 61.40).

All applicants for NRC licenses must provide financial assurances that funding will be available to cleanup and decommission sites used for licensed activities (10 CFR 40.36; 10 CFR 30). NRC generally includes specific monitoring and/or cleanup conditions in the licenses it issues the Army. These conditions originally provided the Army with five disposal options, but now provide only two (46 FR 52061-63).

First, NRC allows the Army to bury low concentrations of DU with no restrictions on burial method. Under this option, the concentration of DU must meet EPA standards. In addition, the waste must not expose the public to more than 1 millirad per year (1 mrad per yr) of radiation to the lungs or 3 mrads per yr to the bone from inhalation and ingestion for any foreseeable use of the material or property. In addition, the concentrations must be low enough that no individual will receive an external dose in excess of 10 micro-roentgen ( R) per hour above background. These standards are compatible with guidelines recommended by EPA (42 FR 60956-60959; 46 FR 2556-2563).

Alternatively, NRC allows the Army to dispose of low concentrations of DU by burying them under prescribed conditions so that no subsequent land use restrictions and no continuing NRC licensing of the material are required. The concentration of DU must be low enough that no member of the public will receive more than 1 mrad per yr to the lungs, 3 mrads per yr to the bone, or 10Ý R per hour above background if they avoid excavation in the burial grounds (46 FR 52061-63).

3.13ÝÝ Army Radiation Protection Program

The Army has a peacetime radiation protection program for all phases of the DU life cycle to ensure that it does not expose Army personnel or the public to more radiation than allowed by NRC and EPA. The program has four cornerstones:

• NRC license requirements cover each phase of the DU life cycle. Therefore, the safety measures proposed for each phase are independently reviewed and, more importantly, independent inspections are conducted by NRC to ensure compliance with these safety measures. The Army maintains this oversight for both unclassified and classified portions of the program. The Army implements safety requirements equal to or more stringent than NRC license requirements in its overseas locations.

• The Army has developed regulations and established local programs (as required by NRC licenses) to ensure compliance with radiation safety regulations. These programs require the designation of a radiation protection officer (RPO) who is responsible for overseeing procedures involving DU, restricting access to areas containing DU munitions, and periodically testing for DU contamination on the exterior of munitions.

• Army regulations require personnel to comply with NRC contamination control and personnel monitoring procedures. NRC requirements vary from site to site, depending on specific missions. The site-specific procedures are reviewed by NRC, USACHPPM and the higher headquarters of each organization during inspections.

3.14ÝÝÝÝ Summary

Military, medical, space, aviation, heavy equipment and petroleum exploration applications all use DU. The Army uses it in kinetic energy penetrators, as a component in tank armor and as a catalyst for two land mine systems. One of these mines is used as a submunition for the 155 mm howitzer.

In acquiring new weapon systems, including DU systems, the Army follows DoDís Defense System Acquisition Process, which incorporates NEPA requirements. This process is implemented according to AR 70-1 and AR 200-2. To ensure system safety, the Army follows several regulations governing safety policies, procedures and testing: DoD Directive 5000.1, MIL-STD-882C, AR 385-16 and AR 40-10. Most control of DU production is handled by the NRC, which grants licenses to the Army and to Army contractors to possess and store DU and to use it in munitions production. The AMC subordinates hold a total of 14 NRC licenses to develop, test and deploy munitions and armor containing DU.

The Army is responsible for all conventional ammunition (including DU metal and explosives) for all the military services. DOT and NRC regulations govern domestic transportation of DU; the IAEA and several U.N. conventions and agreements govern international transportation.

According to DODM 5160.65-M, the design of all new or modified conventional ammunition items must include the requirement to develop safe and environmentally acceptable demilitarization procedures. Specific demilitarization procedures for each type of DU munition, tank and mine are provided in DMWRs.

Although the Army has disposed of some DU-contaminated soil as low-level waste, it has never decontaminated or decommissioned soft-target impact areas at its test centers. The Army does not expect to decontaminate test centers until it terminates the test missions or closes the installations.

The Army has a radiation protection program for all phases of the DU life cycle to ensure that it does not expose its personnel or the public to more radiation than allowed by NRC and EPA.