OFFICE OF THE SECRETARYCORRESPONDENCE CONTROL TICKET

Date Printed: Dec 08,2004 17:02

PAPER NUMBER:

ACTION OFFICE:

LTR-04-0734

EDO

LOGGING DATE: 12/08/2004

to0 -S. C-0daux II kI II

AUTHOR:

AFFILIATION:

ADDRESSEE:

James Salsman

CA

Patricia Pelke

EDODEDMRSDEDHDEDMAODEDR

SUBJECT: SUC-1380 license application for renewal ....... etc;

ACTION:

DISTRIBUTION:

LETTER DATE:

ACKNOWLEDGED

SPECIAL HANDLING:

Appropriate

Chairman, Comrs..Encls to: EDO

12/06/2004

No

Made publicly available in ADAMS via SECY/EDO/DPC

NOTES:

FILE LOCATION: ADAMS

DATE DUE: DATE SIGNED:

CMRDIAZ - Re: http://www.osc.army.mil/dm/DMWWEB/Lic%20pdf%20etc/1-DU%20RENEWAL%20PACKAGE.pdf Pag 111

From: James Salsman <james~bovik.org>To: <pjp2©nrc.gov>, <allegation~nrc.gov>, <biro.susan@epa.gov>,<gary.lang @ us.army.mil>Date: Mon, Dec 6,2004 10:23 PMSubject: Re:http://www.osc.army.mil/dm/DMWW EB/Lic%20pdf %20etc/1 -DU%20RENEWAL%20PACKAG E.pdf

Patricia J. PelkeChief, Materials Licensing BranchNuclear Regulatory Commission

Dear Ms. Pelke:

Thank you for your message:

>... the license contains a condition which specifically prohibits> any activity that would involve discharging ammunition that> contains DU. As identified above, license number SUC-1380 does> not authorize any operation that would generate DU combustion> products or DU aerosols.

What is the penalty for violating those terms? The U.S. Departmentof Defense has been in violation of those terms for well over tenyears now.

Is the license suspended? I ask that it be suspended at once.Please find the documents in support of this position cited at:

http://www.bovik.org/du/du-petition.htmland in:

http://www.bovik.org/du/bibliography.txtIn particular, please study the birth defects incidence rate graph:

http://www.bovik.org/dulbasrah.gifI believe that both U.S. and U.K. incidence rates, as reportedin the peer-reviewed medical literature, have followed anapproximately similar curve.

If there are any specific law(s), regulations, or orders whichcould inhibit license suspension proceedings in any way, pleasecite the authorities, and excerpt the pertinent portions of thecurrent documents involved.

This is an urgent matter resulting in ongoing death and injuryof U.S. citizens on a daily basis. If there is any reason thatthis situation does not qualify as an emergency, then pleasebring it to my attention.

Sincerely,James Salsman

CC: <JKH~nrc.gov>, <KJL~nrc.gov>, <LH1 @nrc.gov>, <OAC3@nrc.gov>,<du-list yahoogroups.com>, <murfraOrmail.va.gov>, <jonathan.perlin@hq.med.va.gov>,<arwilcock@sympatico.ca>, <millera@radm.afrri.usuhs.mi>, <b.spratt@ic.ac.uk>,<mmcdiarm © medicine.umaryland.edu>, <toby@ poison.org>, <ohcinfo @cdc.gov>,<haraneta @ ucsd.edu>, <pat.doyle © Ishtm .ac.uk>, <ileana.arias @ cdc.hhs.gov>, <info @ aapcc.org>,<llspt@safetycenter.army.mil>, <tara@miltoxproj.org>, <mmarty@oehha.ca.gov>, <cmrdiaz@nrc.gov>,

CMRDIAZ - Re: http://www.osc.army.mil/dm/DMWW EB/Lic%20pdf %20etc/1 -DU%20RENEWAL 0/o2OPACKAGE.pdf Page 2

<William.Murphie © Iex.doe.gov>, <ead@ anl.gov>, <duf6webmaster~anl.gov>, <hairemj ©ornl.gov>,<opcombat.arms © hrcstl.army.mil>, <ops ©safetycenter.army.miI>, <bero ©medicine.ucsf.edu>,<jones.steve @ epa.gov>, <somers.tarah @ epa.gov>

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Re: http://www.osc.army.mil/dm/DMWWEB/Lic%20pdf%20etc/l-DU%20RENEWAL%20PACKAGE.pdfMon, Dec 6,2004 10:14 PMJames Salsman <james@bovik.org>

james@bovik.org

Recipientsnrc.gov

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DEPARTMENT OF THE ARMYHEADQUARTERS, U.S. ARMY FIELD SUPPORT COMMAND

1 ROCK ISLAND ARSENALROCK ISLAND, IL 61299-6500

REPLY TOATTENTION OF:

March 4, 2004

Office of the Chief of Staff

Mr. John MaderaChief, Materials Licensing BranchUS Nuclear Regulatory CommissionRegion III801 Warrenville RoadLisle, Illinois 60532-4351

Dear Mr. Madera:

We are resubmitting our SUC-1380 license application forrenewal (reference control number 311964). In this cover letter,as well as in the enclosed Summary of Significant Changes andrenewal application, we address the comments from Mr. Hueter,Nuclear Regulatory Commission Region III.

a. The Nuclear Regulatory Commission acknowledged the Army'schange to the name of this command, the US Army Field SupportCommand, in amendment 42, January 22, 2004. We have enclosed acurrent diagram of the US Army Field Support Command organizationstructure.

b. Validation testing of ammunition peculiar equipment willtake place under the SUC-1380 license, and we have addedinformation to the renewal application. The US Army FieldSupport Command plans for this type of work to take place atMcAlester Army Ammunition Plant, but may use other Army locationsin the future. Due to the minimal radiological hazard, we see noneed to name locations for this type of work.

c. We base our justification for reducing the number ofammunition storage structures we will survey annually from50 percent to 25 percent on the negative survey data we havegathered over the last 4 years. We believe a 25-percent surveyeffort is more than adequate to continue to show thatcontainerized depleted uranium munitions do not causecontamination of storage structures.

Printed On Q Recycled Paper

-2-

d. We have reviewed license condition 14B and recommend thatthe Nuclear Regulatory Commission remove all letters they listthere, except for Army letter dated August 8, 2001 (withenclosures). This letter (which resulted in amendment 39)concerns deferral of remediation activities for the Lake CityArmy Ammunition Plant area-10 sandpile until December 2008.

The Nuclear Regulatory Commission considered our initialsubmission in April 2003 as timely. We will continue to operateunder the SUC-1380 license as it currently stands until theNuclear Regulatory Commission grants renewal.

We have made many changes in the enclosed license applicationand request renewal in its entirety. As stated above, we haveenclosed a Summary of Significant Changes for your convenience.Major Jason Dunavant, the US Army Materiel Command RadiationSafety Officer, has concurred with the license application, andwe are providing him a copy of this submittal.

Please direct questions or comments to Mr. Gary Buckrop,AMSFS-SF, (309) 782-2969/0338, electronic mail addressafsc-ofc-sf@osc.army.mil.

Sincerely,

//signed//

D. Scott WelkerChief of Staff

Enclosures

.I

Is --41

US Army Field Support Command& Joint Munitions Command

As of 1 Dec 03

DC;-o Svpr Opeatons (iMA)Sk't.>:./BG:Janiesl.W;i~afiery>i:.i';

H..',*:

SUMMARY OF SIGNIFICANT CHANGES TO THE SUC-1380LICENSE RENEWAL APPLICATION

NOTE: The following are significant changes to the SUC-1380license application. We request the Nuclear RegulatoryCommission renew the license in its entirety.

1. Command name: Since the last license renewal in 1997, theUS Army Industrial Operations Command changed its name to the USArmy Operations Support Command, and then to the US Army JointMunitions Command, and finally to the US Army Field SupportCommand.

2. Former bulk storage location: We request the NuclearRegulatory Commission remove Sierra Army Depot from the license.Sierra Army Depot no longer stores depleted uranium munitionsand has gone through the decommissioning process.

3. Posting: Installation personnel will no longer have to postindividual storage magazines with NRC Form 3, Public Law 93-438,and the notice informing employees where they can view thelicense, standard operating procedures, and Federal and Armyregulations. Installation personnel can now post thesedocuments in convenient locations, such as break rooms or whereworkers draw storage magazine keys.

4. Overseas posting: Posting Caution Radioactive Materialsigns on depleted uranium ammunition storage structures overseaswill be in accordance with host nation agreements or at thediscretion of the local commander.

5. Accountability: For clarification, we have addedinformation on accountability and removed reference to physicalinventory. The Army does have an accountability system in placefor ammunition and physically counts ammunition periodically.The Army does not plan to physically count all depleted uraniummunitions at all locations every year.

6. Shipping/Receiving: Installation personnel will no longerhave to wipe or take exposure readings on outgoing and incomingshipments of depleted uranium munitions unless evidence ofdamage or corrosion exists.

7. Prepositioned ships: We state our position in theapplication that prepositioned ships are in transit.

8. Disassembly operations: We have added ammunitiondisassembly operations for Government Owned Government Operatedinstallations when authorized by the US Army Field SupportCommand Safety/Rad Waste Directorate.

9. Radiation surveys: The license now requires fewer radiationsurveys for routine storage areas and provides more informationon radiation survey procedures. In addition, we grant relieffrom the annual survey requirement for US Army forts andoverseas installations in times of war or high threat of war.

10. Lake City Army Ammunition Plant firing range: The sectionon the Lake City firing range now reflects that the NuclearRegulatory Commission has released the 600-yard bullet catcherand the southeast wing of building 3A for unrestricted use.

11. Storage of contaminated equipment at McAlester ArmyAmmunition Plant: We removed this entire section from thelicense application. We transferred the equipment to a licensedcontractor, and the Nuclear Regulatory Commission released thestorage facilities for unrestricted use via amendment 30. TheArmy will continue to use McAlester for the storage of depleteduranium munitions.

12. Instruments: We have updated the section on radiationdetection instruments with information on the PDR-77 and VDR-2.

13. Authorized users: In addition to Department of the Armycivilian and military personnel, we have added contractor andforeign national personnel as authorized users at Armyinstallations within the United States or at overseas locations.

14. Modified ammunition items: We have added interim licensecoverage for storage of standard ammunition items at US ArmyField Support Command installations that Army research,development, test, and evaluation organizations have modifiedfor testing purposes.

15. Foreign/captured items: We have added interim licensecoverage, so that owning United States military organizationscan store foreign or captured ammunition items that containdepleted uranium.

16. Upload: We have removed upload language from the licenseapplication, because the Army only uploads depleted uraniumammunition for possible combat.

2

NRC FORM 313 U.S.NUCLEARREGULATORYCOMMISSION APPROVED BYOMB: NO.3150-0120 EXPIRES: 1013112005:11-2003) Estimated burden per response to comply with this mandatory collection request: 70 CFR 0. 32, 3. hours. Submittal of the applIcation is necessary to deternine that the applicant Is

34s 35, 3939. and 40 qualified and that adequate procedures exist to protect the public health and salety.Send comments regarding burden estimate to the Records Management Branch (T-6E6). U.S. Nuclear Regulatory Commission. Washington, DC 20555-0001. or by Intemete-mail to Infocollectstfnrcgov. and to the Desk Officer, Office of Information and

APPLICATION FOR MATERIAL LICENSE Regulatory Affairs. N&OB-10202. (3150-0120), Office of Management and BudgetWashington. DC 20503. It a means used to impose an Information collection does notdisplay a currently valid OMB control number, the NRC may not conduct or sponsor,and a person Is not required to respond to. the Information collection.

INSTRUCTIONS: SEE THE APPROPRIATE LICENSE APPLICATION GUIDE FOR DETAILED INSTRUCTIONS FOR COMPLETING APPLICATION.SEND TWO COPIES OF THE ENTIRE COMPLETED APPLICATION TO THE NRC OFFICE SPECIFIED BELOW.

APPLICATION FOR DISTRIBUTION OF EXEMPT PRODUCTS FILE APPLICATIONS WITH:

DIVISIOtN or INDUSTRIAL AND MEDICAL NUCLEAR SAFETYOFFICE OF NUCLEAR MATERLALS SAFETY ANO SAFEGUARDSU.S. NUCLEAR REGULATORY COMMISSIONWASHINGTON. DC 20555-CO01

ALL OTHER PERSONS FILE APPUCATIONS AS FOLLOWS:

IF YOU ARE LOCATED IN:

CONNECTICUT. DELAWARE, DISTRICT OF COLUMBLA, MAINE. MARYLAND,MASSACHUSETTS, NEW HAMPSHIRE, NEW JERSEY. NEW YORK. PENNSYLVANIA,RHODE ISLAND. OR VERMONT. SEND APPUCATIONS TO:

LICENSING ASSISTANT SECTIONNUCLEAR MATERIALS SAFETY BRANCHU.S. NUCLEAR REGULATORY COMMISSION, REGION I475 ALLENDALE ROADKING OF PRUSSIA. PA 19406-1415

ALABAMA, FLORIDA, GEORGIA. KENTUCKY. MISSISSIPPI, NORTH CAROUNA. PUERTORICO, SOUTH CAROUNA., TENNESSEE. VIRGINIA, VIRGIN ISLANDS, OR WEST VIRGINIA.SEND APPUCATIONS TO:

SAM NUNLN ATLANTA FEDERAL CENTERU. S. NUCLEAR REGULATORY COMMISSION. REGION II61 FORSYTH STREET, S.W.. SUITE 23T85ATLANTA. GEORGIA 303034931

PERSONS LOCATED IN AGREEMENT STATES SEND APPLICATIONS TO THE U.S. NUCLEAF

IF YOU ARE LOCATED IN:

ILUNOIS, INDIANA, IOWA, MICHIGAN, MINNESOTA, MISSOURI, OHIO, OR WISCONSIN, SEtSAPPLICATIONS TO:

MATERIALS LICENSING BRANCHU.S. NUCLEAR REGULATORY COMMISSION. REGION III801 WARRENVILLE RD.LISLE, IL 60532-4351

ALASKA, ARIZONA. ARKANSAS, CAUFORNIA. COLORADO. HAWAII. IDAHO, KANSAS.LOUISIANA, MONTANA, NEBRASKA, NEVADA. NEW MEXICO. NORTH DAKOTA, OKLAHOMA,OREGON. PACIFIC TRUST TERRITORIES. SOUTH DAKOTA, TEXAS, UTAH, WASHINGTON.OR WYOMING, SEND APPUCATIONS TO:

NUCLEAR MATERIALS LICENSING SECTIONU.S. NUCLEAR REGULATORY COMMISSION. REGION IV611 RYAN PLAZA DRIVE. SUITE 400ARLINGTON. TX 760114064

REGULATORY COMMISSION ONLY IF THEY WISH TO POSSESS AND USE UCENSEDMATERIAL IN STATES SUBJECT TO U.S.NUCLEAR REGULATORY COMMISSION JURISDICTIONS.

1. THIS IS AN APPLICATION FOR (Check oppopnate Ium) 2. NAME AND MAILING ADDRESS OF APPLICANT (inhude ZIPcode)

] A NEWUCENSE Department of the ArmySHO. US Army Field Support Command

. AMENDMENTTOLICENSENUMBER ATTN: AMSFS-SF

C. RENEWALOFUCENSENUMBER SUC-1380 1 Rock Island ArsenalLU - Rock Isalnd. IL 61299-6500

3. ADDRESS WHERE UCENSED MATERIAL WILL BE USED OR POSSESSED 4. NAME OF PERSON TO BE CONTACTED ABOUT THIS APPLICATION

Worldwride use Mr. Kelly Crooks

TELEPHONE NUMBER

(309) 782-0338

SUBMIT ITEMS S THROUGH 11 ON S-12 X 1 tPAPER. THE TYPE AND SCOPE OF INFORMATION TO BE PROVIDED IS DESCRIBED IN THE LICENSE APPLICATION GUIDE.

5. RADIOACTIVE MATERIALa Ebemwi and man number. b. dcemical and/or physical kmn and c. rnaianurn anount 6. PURPOSE(S) FOR WHICH LICENSED MATERIAL WILL BE USED.

.lctin Al the sl. at anv eme See su p ement1li P-eent 27. INDMDUAL(S) RESPONSIBLE FOR RADIATION SAFETY PROGRAM AND THEIR 8. TRAINING FOR INDMDUAIS WORKING IN OR FREQUENTING RESTRICTED AREAS.

TRAINING EXPERIENCE. (Medicat use appicant: t 3AT->2XrrX emen 1 s p t

9. FACILITIES AND EOUIPMENT. 10. RADIATION SAFETY PROGRAM.

Suppnlment 4 Sup ment 512. LICENSE FEES (See 1OCFR 170 andSecwon 170.31)

1 6. WASTE MANAGEMENT.A Exempt AOUNTSu JIplement FEE CATEGORY Exmp NCLOSED S

13. CERTIFICATION. {ist be conrIped by applicant) THE APPLICANT UNDERSTANDS THATALL STATEMENTS AND REPRESENTATIONS MADE IN THISAPPLICATION ARE BINDINGUPON

THE APPLICANT AND ANY OFFICIAL EXECUTING THIS CERTIFICATION ON BEHALF OF THE APPLICANT. NAMED IN ITEM 2. CERTIFY THAT THIS APPLICATION IS PREPARED INCONFORMITY WITH TITLE 10. CODE OF FEDERAL REGULATIONS. PARTS 30. 32.33.34.35.36.39, AND 40. AND THAT ALL INFORMATION CONTANED HEREIN IS TRUE ANDCORRECT TO THE BEST OF THEIR KNOWLEDGE AND BELIEF.

WARNING: 18 U S.C. SECTION 1001 ACT OF JUNE 25. 1948 62 STAT. 749 MAKES IT A CRIMINAL O5P"JSE TO tAKE A %w1LLF7LLY FALSE STATEMENT OR REPRESENTATION TOANY DEPARTMENT OR AGENCY OF THE UNITED STATES AS TO ANY MATTER WITHIN ITS JURISi9'tION '__

CERTIFYING OFFICER - TYPED/PRINTED NAME AND TITLE S.G.,' 7DATE}/

D. Scott Welker, Chief of StaffIFOR NRC USE ONLY

TYPE OF FEE FEE LOG FEE CATEGORY AMOUNT RECEIVED CHECK NUMBER COMMENTS

S

APPROVED BY DATE

NRIC FORM 313 (11-2003) PRINTED ON RECYCLED PAPER

INTRODUCTION

1. Headquarters, US Army Field Support Command, formerlyHeadquarters, US Army Joint Munitions Command, located at RockIsland, Illinois, has the logistical responsibility to provideammunition to the US Joint Military Services (Army, Air Force,Navy, and Marine Corps). This license application is for thepossession and handling of depleted uranium as cartridgepenetrators.

2. This license application is a request for renewal of licensenumber SUC-1380 in its entirety.

3. The Nuclear Regulatory Commission granted the originalSUC-1380 license in June 1980. The Nuclear Regulatory Commissiongranted the last license renewal on January 21, 1997, with anexpiration date of November 30, 2002. At the request of thelicensee, the Nuclear Regulatory Commission extended theexpiration date to April 30, 2003, in amendment 40. The US ArmyField Support Command submitted the SUC-1380 license for renewalin April 2003, and the Nuclear Regulatory Commission consideredit a timely submittal. This resubmission of the US Army FieldSupport Command renewal application addresses the comments of theNuclear Regulatory Commission.

4. The Army recognizes the jurisdiction of the NuclearRegulatory Commission within the boundaries of the United States.Overseas, the Army will abide by Army regulations or host nationagreements.

5. In brief, this license application authorizes the following:

a. Possession of depleted uranium ammunition and componentsfor, (1) storage and handling at Army locations worldwide as warreserve material for combat use by the US Joint Military Servicesand, (2) disassembly operations as approved by the US Army FieldSupport Command.

b. Possession of depleted uranium fragments on the firingrange at Lake City Army Ammunition Plant, Independence, Missouri.

6. This license application does not authorize firing ammunitioncontaining depleted uranium components. Since depleted uranium

i

ammunition is only uploaded in times of war or the threat of war,this license does not cover the upload of weapon systems.

7. Radiological hazards associated with the activitiesauthorized by this license application are minimal, and the Armywill practice the concept of "as low as reasonably achievable".

ii

Application for Nuclear Regulatory CommissionSource Material License for Possession of Depleted Uranium

as Component Parts of Ammunition Items

Index

Section

Supplement 1:

Supplement 2:

Supplement 3:

Supplement 4:

Supplement 5:

Supplement 6:

Appendix A

Description Page

Introduction i

Index ii

Radioactive Material 1-1

Purposes for which the Licensed 2-1Material will be Used

Section A - Depleted Uranium Ammunition 2-1

Section B - Lake City Firing Range 2-12

Enclosure 1 - Sierra Army Depot 2-15Closeout Documents

Individual(s) Responsible for the 3-1Radiation Safety Program andtheir Training and Experience

Enclosure: Qualifications of 3-3License Management Personnel

Facilities and Equipment 4-1

Radiation Safety Program 5-1

Enclosure 1: Example Warning Statements 5-14

Enclosure 2: Example Drawings 5-15

Waste Management 6-1

Record of Environmental Consideration A-1

iii

Supplement 1 (Reference: NRC Form 313, block 5)

RADIOACTIVE MATERIAL

1. Element and Mass Number: Uranium 238 depleted in the uranium235 isotope.

2. Chemical and Physical Form: Solid metal alloy, not less than95-percent uranium 238.

3. The maximum amounts that may be possessed at all locations atany one time are:

a. Depleted uranium as penetrators for conventionalammunition items: 42,000,000 kilograms.

b. Depleted uranium penetrator fragments on the Lake CityArmy Ammunition Plant firing range, Independence, Missouri:14,000 kilograms.

1-1

Supplement 2 (Reference: NRC Form 313, block 6)

PURPOSES FOR WHICH THE SOURCE MATERIAL WILL BE USED

INTRODUCTION: The following two sections describe how the USArmy will use the source material (depleted uranium). Section A,the largest section, describes the licensee's program forammunition items. Section B covers depleted uranium fragments onthe firing range at Lake City Army Ammunition Plant,Independence, Missouri.

SECTION A. DEPLETED URANIUM AMMUNITION

1. General: The licensee will use depleted uranium as acomponent part of conventional ammunition items. The depleteduranium component is in the form of a solid metal rod, commonlycalled a penetrator. The penetrators covered by this licensevary in weight according to the ammunition model. Depending onthe model of ammunition, some penetrators weigh several kilogramsand others less than 1 kilogram.

1.1 The licensee will consider newly developed depleted uraniumammunition items for license coverage only after the developingorganization, or service, has certified to the licensee that theitem has been properly tested and is suitable for military use.Once approved by the licensee, newly developed depleted uraniumammunition items will be covered by this license without licenseamendment unless significantly different in design from currentlyfielded depleted uranium ammunition items.

1.2 All depleted uranium ammunition components are manufacturedand assembled under separate Nuclear Regulatory Commission oragreement State licenses. The Headquarters, US Army FieldSupport Command, will receive newly produced ammunition itemsinto the SUC-1380 license with the depleted uranium componentsfully assembled and packaged.

1.3 The Headquarters, US Army Field Support Command, willprovide interim license coverage for standard depleted uraniummunitions that other Army license holders have modified fortesting purposes. This interim license coverage is to allowadequate time for these other license holders to decide on, andimplement, the final disposition of the modified munitions. Thislicense coverage is for US Army Field Support Commandstorage installations only (such as depots and ammunition

2-1

plants) and does not include installations (such as provinggrounds or research, development, test, and evaluationfacilities) that make the modifications or test the munitions.In addition, this license does not include testing or firing ofdepleted uranium munitions.

1.4 The Headquarters, US Army Field Support Command, willprovide interim license coverage for foreign or captured depleteduranium ammunition items. This interim license coverage willallow adequate time for the owning organization to determine theneed and use of the munitions and pay for their finaldisposition. Installations will store foreign or captureddepleted uranium munitions in accordance with the associatedexplosive hazard and in buildings separate from United Statesdepleted uranium munitions. Although the US Army Field SupportCommand is requesting authority to disassemble depleted uraniummunitions under this license, that request does not extend toforeign or captured depleted uranium ammunition items.

1.5 The licensee will not use the depleted uranium covered bythis license in any chemical, nuclear, or metallurgicalprocesses. Under limited conditions, trained ammunition workersmay briefly handle the depleted uranium component duringdisassembly operations, but no direct processing of the depleteduranium component, such as machining, cutting, grinding, etc.,will occur.

2. Authorized Operations: Ammunition containing depleteduranium components will be involved in the following peacetimeactivities: storage, inspection, minor maintenance,transportation, render-safe, and disassembly. We explain theseoperations in the following paragraphs:

2.1 Storage: Conventional ammunition items containing depleteduranium components developed by the various services within theDepartment of Defense are authorized for storage at Armyinstallations worldwide as war reserve material. Ammunition andcomponents may also be stored at Army facilities pending finaldisposition.

2.1.1 The Headquarters, US Army Field Support Command, does notprovide depleted uranium license coverage to other Armyorganizations that already have depleted uranium licenses foractivities such as manufacturing or research, development, test,and evaluation. It is the position of the US Army Field Support

2-2

Command that these organizations provide license coverage for thedepleted uranium munitions in their possession. Thisarrangement will reduce confusion by keeping the number ofdepleted uranium licenses in effect at any one installation to aminimum.

2.1.2 The Army primarily stores depleted uranium ammunition instandard ammunition storage structures and locates thesestructures inside security-fenced areas. Due to the security,sensitivity, and explosive hazard associated with ammunitionitems, the Army constructs these storage facilities to strictlylimit the access of personnel, reducing the potential for loss ofcontrol and exposure of personnel to hazards.

2.1.3 As operational necessity dictates, the Army may storeammunition temporarily outdoors within security fenced areas.Ammunition temporarily stored in outdoor areas will be kept onpallets, in their shipping containers, and/or inside transportvehicles. These temporary ammunition storage areas will belocated on Army installations that have 24-hour guard forces andwill be provided security patrols in accordance with ammunitionsecurity procedures.

2.1.4 The Army establishes storage limitations for ammunitionitems on an item-by-item basis. Limitations are based upon theexplosive hazard of each item and the physical capacity of thestorage structure or vehicle. The quantity of depleted uraniumwithin a storage structure or vehicle will not be a limitingfactor. The explosive hazard classification for ammunition itemsare determined in accordance with Department of Defense explosivehazard classification procedures.

2.1.5 There are two categories of storage covered by thisapplication; bulk storage and nonbulk storage. Bulk storagerepresents long-term storage of large amounts of ammunition.Bulk storage installations can store a maximum of 10 millionkilograms of depleted uranium each. We identify the following asbulk storage installations within the continental United States.The Army chooses not to identify overseas storage locations.

a. Anniston Army Depot, Anniston, Alabama.

b. Bluegrass Army Depot, Richmond, Kentucky.

c. Crane Army Ammunition Activity, Crane, Indiana.

2-3

d. Hawthorne Army Depot, Hawthorne, Nevada. Note:Hawthorne changed its name from Hawthorne Army AmmunitionPlant to Hawthorne Army Depot in 1994.

e. Letterkenny Army Depot, Chambersburg, Pennsylvania.

f. McAlester Army Ammunition Plant, McAlester, Oklahoma.

g. Red River Army Depot, Texarkana, Texas.

h. Tooele Army Depot, Tooele, Utah.

2.1.5.1 In the following paragraphs, we discuss the status oftwo Army depots (Seneca Army Depot and Sierra Army Depot) thathave been listed in the SUC-1380 license, but no longer storedepleted uranium ammunition.

a. Seneca Army Depot, Romulus, New York. Seneca Army Depotformerly stored depleted uranium munitions under their SUC-1275license as well as being listed in the US Army Field SupportCommand's SUC-1380 license. Seneca, through the US Army Corps ofEngineers, hired Argonne National Laboratory to provide technicalsupport and Parsons Engineering Sciences, Incorporated, toperform survey and sampling work. Seneca submitted a revisedlicense termination plan, to Nuclear Regulatory Commission Region1, on February 11, 2003. The Nuclear Regulatory Commissionapproved Seneca's termination plan in amendment 13 and letterdated September 17, 2003. The Seneca license termination planincludes provisions to close out Seneca Army Depot as a storageinstallation under the SUC-1380 license. Seneca Army Depot willremain listed in this license as a bulk storage installationuntil the US Army Field Support Command can provide documentationto the Nuclear Regulatory Commission that the decommissioningeffort for the SUC-1275 license also covers the SUC-1380 license.

b. Sierra Army Depot, Herlong, California. We request theNuclear Regulatory Commission remove Sierra Army Depot from thelist of bulk storage installations covered by the SUC-1380license. Sierra formerly stored depleted uranium munitions undertheir SUC-1274 license as well as being listed in the US ArmyField Support Command SUC-1380 license. The Nuclear RegulatoryCommission terminated Sierra's SUC-1274 license on December 5,2001, in amendment 19. The US Army Corps of Engineers and the USArmy Center for Health Promotion and Preventive Medicine did thesurvey and sampling work. The termination of the SUC-1274license also served to close out Sierra Army Depot as a storage

2-4

installation under the SUC-1380 license. We have enclosed tothis supplement the following documents on the termination of theSUC-1274 license and the closeout of Sierra Army Depot as astorage location under the SUC-1380 license.

a. Nuclear Regulatory Commission letter and amendment 19 tothe SUC-1274 license, both dated December 5, 2001.

b. The executive summary of US Army Corps of EngineersLicense Termination and Site Release Survey Report for SierraArmy Depot, dated January 2001.

2.1.6 Nonbulk storage covers any Army installation that has arequirement to store lesser amounts of depleted uraniumammunition in support of military operations. Nonbulk storageinstallations can store a maximum of 50,000 kilograms of depleteduranium. Typical examples are installations that store depleteduranium ammunition in support of deployment, retrograde, shipmentconsolidation, or repair of military vehicles. Storage ofdepleted uranium ammunition under this category can range from afew days to long term.

2.1.7 As stated above, only US Army installations are authorizedby this license for the storage and/or handling of depleteduranium ammunition. The US Air Force licenses air fields. TheUS Navy licenses Navy and Marine Corps facilities. Personnelworking in ammunition operations under this license will be USArmy civilian personnel, US Army military personnel, civilianpersonnel under contract to the US Army, or foreign nationalsauthorized to work at Army installations overseas.

2.2 Inspection: The Headquarters, US Army Field SupportCommand, directs ammunition inspections at Army installations.Most of the time, inspection procedures include a visualinspection of external surfaces for defects such as damage orcorrosion. Occasionally, the licensee may have a need todisassemble depleted uranium ammunition items to visually inspectinternal components. Inspection procedures that requirefunctioning, firing, direct processing, or destruction ofdepleted uranium ammunition items will be performed underseparate Nuclear Regulatory Commission or agreement Statelicense. Headquarters, US Army Field Support Command determinesdisposition of unserviceable munitions or depleted uraniumcomponents.

2-5

2.3 Minor Maintenance: Occasionally, inspection of depleteduranium ammunition items will reveal conditions that requireminor maintenance activities be performed to return them to afully serviceable condition. The following types of minormaintenance activities that do not require disassembly, thehandling of ammunition subassemblies, or the prolonged exposureof the depleted uranium component may be performed afterHeadquarters, US Army Field Support Command, grants approval:

a. Linking and delinking of belted ammunition.

b. Corrosion removal from nondepleted uranium components.

c. Touchup painting and remarking of complete rounds.

d. Repackaging of complete ammunition items.

e. Preservation and repair of packaging.

2.3.1 Since minor maintenance operations do not involve director prolonged contact with the depleted uranium component of themunitions, no additional instructions or safety precautions whichdeviate from normal handling and storage instructions arerequired. The Army considers warning statements in technicalmanuals to be adequate radiological instructions.

2.3.2 Ammunition items containing depleted uranium componentsmay reach a point where they require extensive renovation. TheArmy will return such ammunition items through the supply systemto a separately licensed facility to perform the required work.Typically, extensive renovation involves disassembly of theammunition round, so that work can be done on internalcomponents.

2.4 Transportation: Transportation of depleted uraniumammunition items and components will comply with alltransportation regulations applicable at the time of shipmentunless specifically addressed in the following paragraphs:

2.4.1 The Army ships depleted uranium ammunition items underDepartment of Transportation Exemption 9649. According to thisexemption, the Department of Defense can ship depleted uraniumammunition items according to the primary explosive hazard. Theexemption allows dose rates of 2.5 millirem per hour on contactwith packages and grants relief from marking and labelingshipments of depleted uranium ammunition as radioactive items.

2-6

Overseas shipments of depleted uranium ammunition will complywith host nation agreements.

2.4.2 Unless found damaged, depleted uranium munitions in theircontainers will not be subject to radiation surveys beforeshipment or upon receipt. This is because shipments of depleteduranium will never exceed the Type A quantity as described inAppendix A to Title 10 Code of Federal Regulations 71, which isunlimited. In addition, it has been the Army's experience thatcontainerized depleted uranium munitions have never been foundleaking contamination and have always been below the2.5-millirems-per-hour limit as required by the Department ofTransportation exemption referenced above.

2.4.3 The Army inspects ammunition packages before loading ontoa conveyance and when unloading from a conveyance. Installationpersonnel are to immediately notify the installation RadiationSafety Officer if they find damaged packages of depleted uraniumammunition. The Radiation Safety Officer or his/her designeewill survey damaged packages with radiation detection instrumentsand wipe for removable contamination. The Radiation SafetyOfficer or Transportation Officer will make notificationsrequired by Title 10 Code of Federal Regulations 20.1906(d) ifthe conveyance delivering the munitions is contaminated. Damagedpackages found to be contaminated will be segregated and storeduntil the Radiation Safety Officer obtains final disposition fromthe Headquarters, US Army Field Support Command.

2.4.4 Transport to overseas locations will normally be via ship.Some ships may linger for several months in regions where UnitedStates military units may need ammunition on short notice. Thelicensee considers the ammunition aboard these ships to be intransport and not in storage.

2.4.5 Under peacetime conditions, the Army transports ammunitionand weapon systems separately, although they may be on the sameship. Upload and stowage of depleted uranium ammunition intoweapon systems, such as tanks or Bradley fighting vehicles, onlyoccurs in war or the threat of war, and thus, are not covered inthis license.

2.5 Render-safe: Ammunition items containing depleted uraniumcomponents may be found unsafe for shipment or handling. Onthese occasions, personnel trained in the handling of suspectammunition items will render the item safe. The procedures

2-7

implemented by these individuals will be primarily based upon theexplosive hazard associated with the item.

2.5.1 Procedures to make a round of ammunition safe to handleresult in the separation of the two major components of theround; the cartridge case and the projectile assembly. Ifmechanical separation is considered unsafe, the ammunition itemwill be subjected to a destructive separation. Destructiveseparation techniques will leave the cartridge case unusable, butwill leave the projectile intact. The projectile, which containsthe depleted uranium component, will be wrapped in plastic andstored until the Headquarters, US Army Field Support Command,determines final disposition. Normally, depleted uraniumcomponents resulting from operations to make the components safeto handle will not be stored in the same structure as serviceablemunitions.

2.6 Disassembly: All ammunition items reach a point where theyexceed their useful life. When this occurs, the Army sends theammunition items back through the supply system to a facilitycapable of taking them apart. Disassembly renders the itemsunusable for their original military purpose. Because of this,the Army refers to disassembly operations as a form ofdemilitarization. The Headquarters, US Army Field SupportCommand, determines when ammunition items requiredemilitarization. Note: Supplements 4 and 5 of the licenseapplication contain more information on disassembly.

3. Amount of Material: The amount of depleted uranium involvedin the activities described in paragraph 2 above will be basedupon the explosive hazards associated with the ammunition item,the physical capacity of the storage structure or vehicle, andthe operational requirements associated with the activity. In-the following paragraphs, we discuss the anticipated quantitiesof depleted uranium that may be involved in each activity.

3.1 Storage: The anticipated quantity of depleted uranium in asingle earth-covered storage structure could typically rangebetween 4,536 and 136,078 kilograms (10,000 and 300,000 pounds),with some storage configurations approaching 204,117 kilograms(450,000 pounds). The quantity of depleted uranium in anaboveground structure could range between 45,356 and 272,155kilograms (100,000 and 600,000 pounds), with some storageconfigurations approaching 771,107 kilograms (1,700,000 pounds).The anticipated maximum quantity of depleted uranium to be held

2-8

in a temporary outdoor storage area is 36,287 kilograms (80,000pounds), which is the amount that can be carried by two railcars.

3.2 Transportation: The anticipated quantity of depleteduranium in a single road or rail transport vehicle is based uponthe gross weight limitation imposed on the vehicle. Railtransport vehicles could contain as much as 18,144 kilograms(40,000 pounds) of depleted uranium while road transport vehiclescould contain up to 6,804 kilograms (15,000 pounds) of depleteduranium. Typical peacetime shipments of depleted uraniumammunition by an ocean vessel could involve between 136,078 and408,233 kilograms (300,000 and 900,000 pounds) of depleteduranium.

3.3 Inspection: Inspection operations typically involve fromone box to several pallets of ammunition. The anticipatedquantity of depleted uranium involved in inspection operationscould range from 4.54 to 907 kilograms (10 to 2,000 pounds).

3.4 Minor maintenance: Installation personnel will positionworking quantities of ammunition awaiting maintenance near themaintenance line. Minor maintenance operations typically involvefrom one box to several pallets of ammunition. As installationpersonnel remove finished ammunition items from the maintenanceline, they will bring in additional items to keep theoperation going. The anticipated quantity of depleted uraniuminvolved in minor maintenance activities at any one time couldrange from 4.54 to 1,588 kilograms (10 to 3,500 pounds) ofdepleted uranium.

3.5 Render-safe: The Army implements render-safe operations onshort notice when ammunition items are found, or suspected to be,unsafe to handle or ship. Because the Army does not plan render-safe operations in advance, the quantity of depleted uraniuminvolved in such an operation cannot be forecast; however, it isanticipated that less than 15 kilograms (33 pounds) of depleteduranium would be involved at any one time.

3.6 Disassembly: Installation personnel will position workingquantities of ammunition awaiting disassembly near thedisassembly line. Typical working quantities will involve fromone box to several pallets of ammunition. As installationpersonnel take ammunition items apart and remove the componentsfrom the disassembly line, they will bring in additionalammunition items to keep the operation going. The anticipatedquantity of depleted uranium involved in disassembly activities

2-9

at any one time could range from 4.54 to 1,588 kilograms (10 to3,500 pounds) of depleted uranium.

4. Accountability: The Army has developed specific proceduresto provide for accountability of ammunition at storage locations,by military groups, and in transit between installations.Additionally, the Army has developed a centralized reportingsystem to provide worldwide stockpile visibility. This system isused to assist in stockpile, production, and logistics planning.The centralized reporting system used by the Army keeps track ofammunition in storage and transport in 100-round increments.Ammunition that has been issued to individual Army units is notmaintained within the centralized reporting system.

4.1 The inventory records maintained by each installation andeach military unit keep track of ammunition items in single roundincrements and are used for accountability proposes.Installations update their inventory records after each receipt,shipment, or disbursement. In addition to the rigorous inventoryand accountability procedures, all ammunition items aremaintained under constant physical security.

4.2 The Headquarters, US Army Field Support Command, comparesthe ammunition records of Government-owned, contractor-operatedinstallations to the Headquarters, US Army Field Support Command,accountable record annually. The Headquarters, US Army FieldSupport Command, compares the records of Government-owned,Government-operated installations to the accountable record on amonthly basis. If the records do not match, Headquarters, USArmy Field Support Command, personnel research the discrepancyand initiate an investigation if necessary.

4.3 Ammunition shipped to another location or unit is subject toa 100-percent inspection. This inspection includes verificationof the national stock number and quantity as part of the shipmentprocess. Installations shipping ammunition send a notice of theshipment to the receiving installation separate from the actualshipment. Upon receipt, the receiving installation verifies thequantity of ammunition in the shipment against the quantity onthe shipping documents. Additionally, a copy of the incominginventory is sent to the installation originating the shipment.This inventory notifies the point of origin that the shipment hasarrived.

4.4 Ammunition issued to individual military units isaccountable property. An individual within the unit that

2-10

receives the ammunition signs for it. This individual ispersonally accountable for all of the ammunition within the unit.This responsibility is relinquished only when the ammunition isexpended or turned in to an ammunition storage activity.Ammunition that is turned in to an installation is added to thatinstallation's inventory, and a receipt is issued to the unitshowing the disposition of the ammunition. Installations thatissue ammunition to military units perform a physical inventoryof their munitions at least once a year.

4.5 Physical security is maintained by storing ammunition insidesecure, limited access areas, such as: security fenced areasand/or locked storage structures. Army installations storingammunition have a 24-hour a day guard force, and ammunitionstorage areas are provided security patrols. Entry to ammunitionstorage areas is limited to specifically designated individuals.Additionally, only selected individuals are allowed access to thekeys to unlock storage areas.

2-11

SECTION B. DEPLETED URANIUM CONTAMINATED FIRING RANGE AT LAKECITY ARMY AMMUNITION PLANT

1. Lake City Army Ammunition Plant is a Government-owned,contractor-operated facility located in Independence, Missouri.From 1941, when the installation began operation, until 1985,Remington Arms Company operated the facility.

2. During the early 1960's, Remington Arms, while under Armycontract, developed, manufactured, and tested a 20-millimeterdepleted uranium spotter round known as the XM101. Manufacturingtook place in building 12A and the southeast wing of building 3A.Each round contained approximately 206 grams of depleted uranium.The testing program consisted of firing the projectiles ontodesignated impact areas at 1,750 and 2,188 yards from the firinghouse. Remington operated under Nuclear Regulatory Commissionlicense SUC-1195 until 1985. When Remington's contract was notextended in 1985, the Army assumed licensure for the depleteduranium on the firing range under this license (SUC-1380).

3. In 1968, the Army cancelled the XM101 project. Remingtonthen proceeded to demilitarize approximately 45,000 rounds byfiring them into a sand-filled bullet catcher 600 yards from thefiring house. The bullet catcher sand was sifted, and the largedepleted uranium fragments were collected, containerized, andshipped off site for burial at a low-level radioactive wastedisposal site. The residual sand was piled in an area (known asthe Area 10 sandpile) north of the active range.

4. In 1986, the licensee contracted with Chem-Nuclear Systems,Incorporated, to remediate building 12A. The Nuclear RegulatoryCommission released building 12A for unrestricted use in theirletter dated March 17, 1988, to the licensee.

5. In 1994, the licensee contracted with Allied TechnologyGroup, Incorporated, to characterize the firing range. Thecharacterization report served as the basis for remediationefforts at the 600-yard bullet catcher and the Area 10 sandpile.

6. In 2001, the licensee contracted with Cabrera Services toremediate the 600-yard bullet catcher. Also, in 2001, thelicensee contracted with the Allied Technology Group to remediatethe southeast wing of building 3A. The Nuclear RegulatoryCommission released the 600-yard bullet catcher and the southeastwing of Building 3A for unrestricted use in their letter datedAugust 23, 2001, to the licensee.

2-12

7. At the time of license renewal (February 2004), the remainingdepleted uranium contaminated areas left at Lake City ArmyAmmunition Plant are the two impact areas at 1,750 yards and2,188 yards and the Area 10 sand pile. The Army posts theseareas with "Caution Radioactive Materials" signs.

8. Per letter dated August 14, 2001, and amendment 39, theNuclear Regulatory Commission granted the Army permission todefer the Area 10 decommissioning until December 31, 2008, whenremedial activities will be conducted under the ComprehensiveEnvironmental Response, Compensation & Liability Act program.Note: Amendment 39 was the result of Army letter dated August 8,2001.

9. Per letter dated October 20, 1998, the Nuclear RegulatoryCommission deferred remedial activities of the Lake City ArmyAmmunition Plant firing range impact areas to the USEnvironmental Protection Agency. The Nuclear RegulatoryCommission continues to grant licensure to Headquarters, US ArmyField Support Command, under SUC-1380.

10. In its April 8, 2003, letter, the Headquarters, US ArmyField Support Command, updated its financial assurance document(statement of intent) to reflect an increase in soil in need ofremoval from the Area 10 sandpile and to reflect the release ofthe 600-yard bullet catcher and building 3A. We based ourprevious Area 10 decommissioning estimate on the 1994 rangecharacterization conducted by the Allied Technology Group. Ourestimate for Area 10 is based on information from the 1998partial Area 10 decommissioning effort and from the August 2000characterization report produced by IT Corporation.

11. The Lake City firing range is actively used (although NOTfor testing or demilitarization of depleted uranium ammunition)and admission to the range area is strictly controlled. Therange is completely enclosed and secured from unauthorized entryat all times.

12. The licensee has obtained water samples on an annual basisfrom several locations in and around the area of the firing rangesince 1988. The water samples are analyzed, and the resultsprovided to the Nuclear Regulatory Commission Region III officein Lisle, Illinois. To date, none of the samples have produced aradiological anomaly. The well monitoring program will continueas long as the Nuclear Regulatory Commission requires it.

2-13

13. If the Army finds significant amounts of depleted uraniumcontamination in any of the water samples, they will take actionto eliminate the source of contamination. Water sample testingwould be increased to quarterly until it is determined the sourceof contamination has been eliminated.

2-14

Supplement 2, Enclosure 1(Reference: NRC Form 313, block 6)

LICENSE TERMINATION DOCUMENTATION FOR THE SUC-1274 LICENSE ISSUEDTO SIERRA ARMY DEPOT AND LICENSE CLOSEOUT DOCUMENTATION FOR THESUC-1380 LICENSE WHICH LISTED SIERRA ARMY DEPOT AS A STORAGELOCATION.

2-15

L *:w- st *-. *

r,. - . , -'\. ,.s'.., , :-,.'

UNITED 8TATESNULAR REGULATORY COMMISSION

V1.'A L - .IDRIVYE. SUITE 400- -ARLINGTON, TJXAS 7601140U4 .

., .December 5, 2001

r ' -; ;p, --. ff - , .y

Departme'nt of the ArmySierra Amhy-Depot.-

' 'ATTN:.SMASI-bR,.Bob .WeisHerlong, Califomla* 96113-501 0

.', SiET . T F U R A

UBJECT' --TERMINATION OF YOUR NRC RADIOACTIVE iUATERIALS LICENSE

By letter and .NRC Form 314 dated September 27, 2001,you contacted the U.S. Nuclear'*Regulatory' Commission and indicated that you wvshed to terminate your NRC radioactive

*,;raterials license. ̀ The NRC staff has reviewed your: site release'survey and~associatedrecords.. Based 'on its.review', the'staff.has concluded that: 1) all licensable-radioactive.material has been' removed from y6ur facijityand2) fesidual radioactive material attributable tolicensed activities does not exceed curreit NRC crite'ria. . -

Based on these conclusions no further remediation or acti6ns with.respect-to NRC regulatedmaterial' is requlred;.'Your facility is suitable for unrestricted use and NRClicense number -

* SUC-1 274 for your facility at the Sierra Artny Depot, :Herloj, California, .ishereby' er'minated.

-If you have questions or-require clarification on any of the infornation stated above, pleasecontact me at (95) 673-9646.' . :. :

'Sincerely,

IRAl

-James L MontgomerySenior Health;'Physicist

,: . .'Nuclea~r Materials Licensing Branch

- Docket: 040-08527License: SUC-1274Control: 468811

Enclosure: As stated

o .

t, e N o '+

w '2' 6

MatenialsLicensi TetminationIRltiremgnt Fom'

LICENSE#:. SUC-.1274 . DOCKET #: 008527'

'' :LICENSEE: Department of the Army :..-EXPIRATION DATE: 313102.erra Army Depot .' .'''DATEFCOTACT:.10/11101'..

CONTACTED BY:BobWeis:ADDRESS: :.Herlong, CA **T . TITE: Envirornmntnl Coordinator

.. . TELEPHONE:.530-8274892.

LICENSE TERMINATED: Yes; LICENSE TRANSFERRED:

LICENSE'TRANSFERRED TO: NAME:`.:ADDRESS:

* .TELEPHONE:* BASIS FOR TERMINATION AND/OR RETIREMENT. Al licensed material transferred to

licensed authorized recipient;. NoAresIdual contamination above NRC regulatory limits exists at- licensee's faciliy. .ERMINATION

* . . ., .' . ; .TERMINATION DOCUMENTATION . .,. . '.:

I. 1.- License terminationmeetsTypeI criteiia:!' .. - Ye's :"No

Licensee used sealed sources only and the most recent leak test demonstrates'.'.'; 'that they did not leak while ir the llcensae's possession. . ..

. Licensee used radioactive mated al.WithT 60daysar~dit16sdecayed to less .. '.tha"ithe activity In 10 CFR Part 20, Appendix C. . .

' 2. License termination meets type ii criteria: .:Yes. -- No ;

-Licensee-possessed and used only sealed sources but cannot demonstrate that:the sources did not leak while in the licensee's possession.

Licensee possessed unsealed radioactive material with T. : 60 days but themaximulm 'activity authorized under the license has not decayed to less than the* '

* quantity specified in -10 CFR Part-20;-Appendix C:..-...

Licensee possessed unsealed radioactive material with T% > 60 days but T% s 120days.

* -. Licensee possessed C14 or H3 but-the total activity and use authorized under the'license warrants decommissioning under Type II (describe rationale above).

3. License termination meets Type IlIl criteria: /Yes No

X_ Decommissioning qualifies for a categorical exclusion under 10 CFR 51.22(c) and

X_ Licensee will decommission its facility In accordance with the'NRC's criteria.forunrestricted use.

2-17

- -

*.; ..., .'.io s' 4" uie "7 r"s 'Tt .

* 7 __Safvr~eids~stc fsaesu~e~rusae aiaty Jmt'ipl. -. ' .*; .. e.X. J~tterf~o Fon 31 ipint.: - -

.. 14 , . al4oo 14 cpet .' . . '. .;..

4", .. -....... :.....Yes .::.No(NA .......................'

i .Z SNR : . .: 'L: .; :-

..... zX-evda ssmn eplsblto helcne ihacp '~tecvretr................................

.: t NRC ' * . .

* .;,....,.:'u:-

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ioo '_ lse u 6d'sourn'erfrcnds.or.Untb: ed. . ":ti tei;l:;

X~~~. . .- cl to 31 fe.l - .

*. :--~ rSe' Irnspetr: c M.: .dsuidI 'OC R at ': . , '... 4.61 . 0.251.387.51:......

* ,. Cose~usureyp~rormd: 'Yes ,:.,./No '( '.WA .:)

* -osn.NRCf completiingfrm:u Yae: . :; ./N

* ~lo otnse n'pJaesr . ongoeri. . .'

On..

Sr Helt Phsiis

: . 2-18

NRC License Termination and Site ReleaseSurvey Report

SIERRA ARMY DEPOTLASSEN COUNTY, CALIFORNIA

. A..

%. -.- t .'

.. _,eI> .-

I

I . .

; l ,,

FINALReport Number CESWT-SO-RI-11-2000

U. S. Army Corpsof EngineersSacramento District, Tulsa District

Sierra Army DepotLassen County, CA

JANUARY 2001

2-19

.Rad Sutv No. USACESWT-SO-RI-1 1-2000, SIAD, Herlong, CA, Jun 2000.

:'.-.:NRC INCENSE TERGNUATION iAND:SITE RELEASE SURVEY

'REPORT NO. CESWT-SO-R1 1-2000

SIERRA ARMY DEPOT.-.

ER.LONG, CALIFORNIA: .

, 30 MAY-23 tJNE2000 , '

1.0 PURPOSE. The purpose of this survey is to provide an assessment of-the radiological

condition of the Nuclear Regulatory Commission (NRC) licensedradioactive material use areas

* . at Sierra Army Depot (STAD). Specifically,

. l.1.1ieobj&teof th finatatss'veywstodonste that the6 radologiclpadrameters

; from jotential 'residualradiboactive contaminiafion are below the releas'e criteria for :ech area: - .,* ~ ... ...vy~. ..... . -.. - -

7 a'SS*t -- * . , * ;.._ '. . .- , 4.

I . 1.2 The ob e s is to'provide the survey dataru e e RCad' the state- . .i y * s ev- kG.n tt

- of Califor'nia to enable the termiiiition-of the NRC licensf the tReelahasteb' of surveyed are as udrom

any potential restrictions due to the use of radioactive materials.

* 2.0 CONCLUSION. Areview ofthe surveyresults indicate that'ther6 is no radiological

contamination above the guidelines for release or distinguishable from background. There are,

therefore, no health hazards identified due to NRC licensed radiological material use at:SIAD.: A.

list of surveyed areas is included in Appendix B. This report serves as the license termination

survey report for license #SUC-1274 and will serve as a place of use termination survey report

for license numbers BML12-00722-07, SUC-1380, SUB-834, and 45-16023-IN.A.'

3.0 RECOMMENDATION. Recommend the surveyed areas listed in Appendix B be

released for future use without radiological restrictions. This constitutes the foliowing areas of

SIAD:2-20

C:ASIADMSIAD Suivey Report Final January 2001

Rad Surv No. USACSW T-SO-R1.-11.2000, SIAD, Herlong, CA, Jun 2000

.~~~~ .. .. I

* Depleted Uranium (DU) Storage areas

* Law Rocket Storage areas

* Shipping and Receiving

* DU inspection areas

.. '. U '. .. ...

4 * ..

*2-21 .

CASIAD\SIAD Survey Report FInal January 2001 hi

NRC FORM 374A U.S. NUCLEAR REGULATORY COMMISSION PAGE 1 of 1 PAGES

LIcense NumberSUC-1274

MATERIALS LICENSE . Docket or Reference NumberSUPPLEMENTARY SHEET 040-08527

Amendment No. 19

Department of the ArmySierra Army DepotATTN: SDSSI-S -Herlong, California 96113-5010 RFc.

In accordance with NRC Form 31 4Wt d September 27, 2001, Licens'o SUG 1274 is hereby terminated.

Ad ' @sC

forHF C)

4- t+k

FOR THE U.S. NUCLEAR REGULATORY COMMISSION

IRAIDate December 5. 2001 By

James L. MontgomeryNuclear Materials Licensing BranchRegion IVArlington, Texas 76011

2-22

Supplement 3 (Reference: NRC Form 313, blocks 7 and 8)

INDIVIDUALS RESPONSIBLE FOR RADIATION SAFETY PROGRAM AND THEIRTRAINING AND EXPERIENCE

1. Headquarters, US Army Field Support Command: The Commander,Headquarters, US Army Field Support Command, in his capacity asthe principal field operating command for the Single Manager forConventional Ammunition, is responsible for the life-cyclecommodity management of conventional ammunition. Thisresponsibility includes acting as custodian of the NuclearRegulatory Commission license for subject licensed material.The Headquarters, US Army Field Support Command, command levelradiation safety officer and alternates provide health physicsguidance and serve as the technical advisors to the Commander,Headquarters, US Army Field Support Command. The Headquarters,US Army Field Support Command, license manager acts for thecommander to ensure full compliance with the provisions of theSUC-1380 license.

1.1 As licensee, Commander, Headquarters, US Army Field SupportCommand, ensures the radiation safety officers at thoseinstallations storing depleted uranium ammunition implement therequirements of this license. The Headquarters, US Army FieldSupport Command, provides assistance and guidance to eachcommand or installation that stores depleted uranium munitionsunder the SUC-1380 license.

1.2 To verify that license requirements are met, the Armyinspects its installations periodically. The goal of theHeadquarters, US Army Field Support Command, is to inspect oneto three installations per year. The licensee also receives theresults of radiation safety related inspections done by otherArmy organizations.

2. Other Army Commands: Each command outside Headquarters, USArmy Field Support Command, is responsible for implementing theprovisions of the license. Per Army regulation, each usingcommand will designate a command-level radiation safety officerto have oversight of its subordinate installations.

3. Bulk Storage Installations and Installations PerformingDisassembly Operations: Each bulk storage installation and eachinstallation performing disassembly operations will designate aradiation safety officer and alternate and will ensure that they

3-1

have training commensurate with their responsibilities. Theinstallation radiation safety officer will have, as a minimum,one of the following:

a. Eighty (80) hours of formal training to include thefollowing:

(1) Principles and practices of radiation protection.

(2) Radioactivity measurements, standardization andmonitoring techniques and instruments.

(3) Mathematics and calculations basic to the use andmeasurement of radioactivity.

(4) Biological effects of radiation.

(5) Applicable Federal and Army regulations.

b. Successful completion of US Army Radiological SafetyCourse (4JF3) satisfies this requirement.

4. Nonbulk Storage Locations: Nonbulk storage installationswill designate a radiation safety officer and alternate. Theradiation safety officer at a nonbulk storage installation willhave at least 40 hours of radiation safety training. The topicswill essentially be the same as those above, with considerationgiven to the shorter length of the training time available.

3-2

Supplement 3, Enclosure(Reference: NRC Form 313, blocks 7 and 8)

QUALIFICATIONS: LICENSE MANAGER, RADIATION SAFETY OFFICER, ANDALTERNATE RADIATION SAFETY OFFICER

3-3

ROSALENE E. GRAHAM, CSP

Education:

Doctoral Studies in Public Administration with SafetyManagement and Methods Concentration, Virginia CommonwealthUniversity, Richmond, Virginia.

Masters of Science in Safety Management, University ofSouthern California, Los Angeles, California - 1986.

Masters of Science in Adult and Occupational Education,Kansas State University, Manhattan, Kansas - 1984.

Bachelor of Science in Secondary Education (ChemistryMajor), University of Wisconsin-LaCrosse, LaCrosse, Wisconsin -1972.

Current Position: July 1998 - Present:

Chief, Safety and Radioactive Waste (Management) Office:Serves as the Program Manager of the worldwide radioactive wasteprogram and related multifaceted projects on behalf of theDepartment of Defense. Also serves as the command safetymanager for a complex US Army Field Support Command SafetyProgram, including oversight the safety of military munitionsmanufacturing. Serves as license manager on Nuclear RegulatoryCommission licenses issued to the Field Support Command.Ensures adequate resources are provided for the management ofcommand licenses to ensure compliance with Federal, State, andDepartment of Defense regulations. Responsible forestablishing, implementing, and enforcing the policies andresponsibilities for the storage, transportation, and disposalof unwanted radioactive material. Responsible for establishingand providing uniform guidance and training for Department ofDefense personnel on storing, packaging, and transportingradioactive waste.

Previous Safety Management Positions:

1996 - 1998. Chief, Plans, Policies, and Programs, US ArmySafety Center: Directed US Army Safety Center Policy, Plans,and Programs Division activities. Served as technicalconsultant on developing Army-wide policy and procedures insafety and risk management. Possessed and applied knowledge ofthe principles and practices of risk management and risk

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management integration; formulated Headquarters, Department ofthe Army, policy; and analyzed policy results. Provided riskmanagement and safety support to Headquarters, Department of theArmy. Served as the Army Safety Program Element Manager forrange safety. Developed and maintained the Director of ArmySafety strategic plans for Army Safety Program improvement.

1992 - 1996. Safety Director, Fort Lee, Virginia:Integrated safety and risk management into combat servicesupport doctrine and Army Logistics Management Collegecurriculum. Managed installation safety program. Served ascore team member to Safety Installation Support Module.Provided adjunct instructor services to the Army LogisticsManagement College. Detailed to special project to assess theorganization using Malcolm Baldrige Award criteria.

1986 - 1991. Safety Director, VII Corps, Stuttgart,Germany: Technical safety oversight for 13 militarycommunities, 3 divisional, 10 nondivisional, and 4 combinedmaintenance center safety programs. Supervised a staff of 10who performed a variety of program functions including aviation,ammunition, range, tactical, Occupational Safety and Health Act,family, radiation protection, and accident analysis. Served asVII Corps Safety Manager during Operation Desert Storm. Risksincluded tactical operations, industrial operations, vehicle(air and ground) movement, range operations, ammunition storagein corps area.

1983 - 1986. Safety Specialist, US Army Safety Center:Team member assigned to track vehicle team. Tracked Army combatvehicle accidents in order to determine trends and developcountermeasures to prevent recurrence. Reviewed technicalmaterial from a safety perspective. Conducted classroominstruction. Developed instructional material on groundsystems. Developed maintenance accident-prevention measures forArmy-wide use.

Member

American Society of Safety Engineers (Professional Member)Association of the United States ArmyFederal Executive Institute Alumni Association

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NAME: Kelly W. Crooks

SERIES/GRADE:

JOB TITLE:

BIRTH DATE:

GS-1306-14

Health PhysicistUS Army Field Support CommandSafety/Rad Waste Directorate

April 5, 1960

POST HIGH SCHOOL EDUCATION:DATES SCHOOL1978-1982 University of Iowa15 hours post graduate study, 1983,

PLACE MAJOR DEGREEIowa City, Iowa Civil Engr. BSCEUniversity of Iowa, Civil Engineering

CAREER HIGHLIGHTS:DATES SERIES/GRADE1986 GS-1306-051987 GS-1306-071988 GS-1306-091989 GS-1306-111990 GS-1306-121991-95 GS-1306-131995-04 GS-1306-14

POSITIONHealth PhysicistHealth PhysicistHealth PhysicistHealth PhysicistHealth PhysicistHealth PhysicistHealth Physicist

ORGANIZATIONAMCCOM Safety OfficeAMCCOM Safety OfficeAMCCOM Safety OfficeAMCCOM Safety OfficeAMCCOM Safety OfficeAMCCOM Rad Waste OfcAFSC Rad Waste Dir

LOCATIONRock IslandRock IslandRock IslandRock IslandRock IslandRock IslandRock Island

SPECIAL QUALIFICATIONS: Radiation worker trained, OSHA hazardous materialstrained, emergency response trained, Contracting Officer's TechnicalRepresentative trained, secret clearance.

SIGNIFICANT GOVERNMENT TRAINING:

DATE COURSE SCHOOL LOCATION

Jun 03

May 01

Jun 00

Feb 00

May 98

Mar 97

Mar 95

DOD Radioactive Waste Guidance

Federal Express Dangerous Goods

Radioactive Materials ShippingBroker

Technical Transportation ofHazardous Materials

DOD Radioactive Waste Guidance

Health Physics in RadiationAccidents

Duratek

FEDEX

CNS

DAC

CNS

REACTS

Rock Island, IL

Rock Island, IL

Barnwell, SC

Fort Hood, TX

Columbia, SC

Oak Ridge, TN

Fort Lee, VAContracting Officers Representative USALMCCourse (ALMC-CL)

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DATE

May 94

Jan 94

Apr

May

93

92

Feb 92

Apr 90

Jun 89

Apr 89

Apr 88

Jan 88

COURSE

LLRW Packaging, Transportationand Disposal

Hazardous Materials IncidentResponse Operations

Applied Health Physics

LLRW Packaging, Transportationand Disposal

40 Hour OSHA Hazardous Materials

Nuclear Accident/IncidentResponse Force Training

Senior Officer NuclearAccident Course

Radioactive Waste Guidance

Health Physics Instrumentationand Air Sampling

Radiological Safety

SCHOOL

CN§I

Safety MgtConsulting

ORAU

US Ecology

CNSI

RIA

SONAC

CNSI

Army

Army

LOCATION

Hilton Head, SC

Rock Island, IL

Oak Ridge, TN

Las Vegas, NV

Barnwell, SC

Rock Island, IL

Kirtland AFB

Rock Island, IL

Fort Belvoir, VA

Fort McClellan,AL

Nov 87

Apr 87

Depleted Uranium Safety

Laser Microwave Hazards

Army

AEHA

Fort Belvoir, VA

Aberdeen ProvingGround, MD

3. EXPERIENCE WITH RADIONUCLIDES:

Am241 Soil density gauges, Alpha Testing, Dallas, TX,Csl37 1984-86

Am241 Quality assurance testing, license management,Co6O packing and shipping of radioactive and mixed waste,H3 and project management of radioactive and mixedNi63 waste remediations, US Army, 1986-present.Pml47Ra226Th232U238Various others

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4. GENERAL HEALTH PHYSICS BACKGROUND:

Health Physicist for Headquarters, US Army Field Support CommandSafety/Rad Waste Office, 1995 to present. Establishes, implements, andenforces the policies and responsibilities for the handling, packaging,storage, transport, processing, and recycle or disposal of low-levelradioactive waste and mixed waste. Provides instructions to Department ofDefense generators for shipments of low-level radioactive waste, acts as DODrepresentative on technical issues and manages the health physics programassociated with low-level radioactive waste. Also acts as Radiation SafetyOfficer for management of two Nuclear Regulatory Commission licenses.

Health Physicist for Headquarters, US Army Armament, Munitions andChemical Command (AMCCOM), 1986 to 1991. Includes advising Command Group onradiological safety matters; preparing NRC license applications, amendments,and renewals for AMCCOM-managed radioactive commodities; reviewing andformulating publications regulating radiation safety; serving as member ofOn-Scene Commander's Staff for response to radiation incidents/accidents;providing assistance and review of applications for NRC licenses andDepartment of the Army authorizations and permits for subordinateinstallations and depots storing licensed items of supply for compliance withFederal and US Army regulations; providing certification and direction on thepackaging, marking, labeling, and shipment of US Army-generated radioactivewaste for processing/storage/disposal; providing project management ofremedial activities.

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Resume of Training and ExperienceGary W. BuckropUS Army Field Support Command Health Physicist

1. General Educational Background:

Bachelor of Science, July 1987, Saint Ambrose University,Davenport, Iowa. Major: General Physics

Associates in Science, May 1978, Black Hawk College,Moline, Illinois. Major: Biological Science

2. Radiation Safety and Related Training:

Course /Organization/Location Du

Radioactive Waste Guidance, Duratek, 32Rock Island Arsenal, IL

Dangerous Goods Seminar, Federal Express, 24Rock Island Arsenal, IL

Radioactive Waste Guidance, Chem-Nuclear, 32Rock Island Arsenal, IL

Radiation Safety Officer, 40US Army CECOM, Atlanta, GA

Radioactive Material Handling Safety Course, 28US Army TACOM-RI, Rock Island Arsenal, IL

Conventional Ammunition Radiation Hazards, 24US Army DAC, McAlester AAP, OK

AMC License Cross Training, 16US Army Materiel Command, Aberdeen, MD

Army Low Level Rad Waste Packing and Shipping, 40Chem-Nuclear, Bettendorf, IA

Radiation Program Management, 40Fort Belvoir, VA

Hazardous Waste Site Worker, 40Scott Community College, Bettendorf, IA

Radiation Protection Officer Review, 40Consultec Scientific, Oak Ridge, TN

Radioactive Waste Guidance, 40Chem-Nuclear, Columbia, SC

,ration

hours

Date

Jun 2003

hours May 2001

hours May 2000

hours Oct 1999

hours Aug 1999

hours May 1999

hours Feb 1998

hours Aug 1997

hours Jul 1997

hours May 1997

hours Dec 1995

hours Jun 1995

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Radiological Safety Course, 120 hours Feb 1994U.S. Army Chemical School, Fort McClellan, AL

Basic Radiation Protection and Tritium Devices, 20 hours Nov 1992Allied Technology Group, Davenport, IA

Ammunition Manager Internship, 16 months Jan 1988US Army Defense Ammunition Center and School, -Apr 1989Savanna Army Depot, IL

3. General Health Physics Background:

a. November 1992 - July 1995. Health Physicist, US Army Armament,Munitions and Chemical Command (AMCCOM), Rock Island, Illinois. Major jobduties: preparing Nuclear Regulatory Commission license applications,amendments, and renewals for command managed commodities; reviewing andformulating publications regulating radiation safety; working issuesinvolving AMCCOM-licensed items; performing inspections; performingaccident/incident investigations; taking water samples; and providingassistance and review of applications for NRC licenses and Department of Armyauthorizations and permits for subordinate installations possessing licenseditems of supply for compliance with Federal and US Army regulations.

b. July 1995 - present. Health Physicist, US Army Field Support Command(JMC), Rock Island, Illinois. Major job duties: preparing NuclearRegulatory Commission license applications, amendments, and renewals forcommand-managed commodities; reviewing and formulating publicationsregulating radiation safety; working depleted uranium ammunition and lightantitank weapon license issues; performing inspections; performingaccident/incident investigations; taking water samples; setting up wipe testprograms; and providing assistance and review of applications for NRClicenses and Department of Army authorizations and permits for subordinateinstallations possessing licensed items of supply for compliance with Federaland US Army regulations.

4. Experience with Radioisotopes: Administrative license managementincluding wipe testing of radioisotopes in command-licensed items.Radioisotopes: Am241, Ni63, U238, Pml47, and tritium.

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Supplement 4 (Reference: NRC Form 313, block 9)

FACILITIES AND EQUIPMENT

1. Facilities:

1.1 The Army will store depleted uranium ammunition items onsecure facilities as described in supplement 2, section A.Disassembly operations will also occur on secure Army facilitiesand in buildings designed for ammunition and explosiveoperations. The general public will not have access tobuildings where depleted uranium munitions are stored ordisassembled.

2. Equipment:

2.1 Radiation safety equipment. The licensee will not grind,cut, machine, or involve the depleted uranium component in anyother direct processing operation that could generate fumes,dusts, mists, or gases. As a result, no special ventilationsystems, special handling equipment, or special protectiveequipment will be required, except for that addressed in thefollowing paragraph.

2.1.1 For the special case of disassembly operations involvingmunitions with depleted uranium corrosion product, the licenseewill install down-draft tables with high-particulate filtersystems at workstations where the corrosion product poses apotential risk. Munitions that normally do not exhibitcorrosion product are those with penetrators in aluminum jacketsor those that have an anticorrosion coating. Other munitionsthat normally do not exhibit corrosion product are those thathave not been out of their storage containers, as well as newlyproduced munitions. Typically, munitions that exhibit corrosionproduct are those that military units have removed from theirstorage containers for possible use and especially thosemunitions that have experienced inclement weather conditions.In addition, older munitions may exhibit corrosion product.

2.2 Automated equipment. Whenever possible, the Army automatesammunition operations to reduce the risk to personnel fromexplosive hazards. In the case of depleted uranium munitions,the use of automated equipment also limits worker exposure tothe depleted uranium component. The Army refers to automatedequipment it has designed for ammunition operations asammunition peculiar equipment. Before authorizing any type of

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ammunition peculiar equipment for general use, the Army subjectsit to a series of engineering tests. In the initial stages ofthe testing, the Army exclusively uses inert (dummy) cartridgesto identify mechanical design problems. In the final stage oftesting, the Army uses live munitions to "prove out" or"validate" the equipment. For example, when designingammunition peculiar equipment to disassemble depleted uraniummunitions, the final validation test will include cycling asmall number of depleted uranium munitions through it.

2.2.1 The Army only uses a small number of ammunition items forvalidation testing of ammunition peculiar equipment, and thechance for contamination and personnel exposure is extremelyremote. Locations that perform validation testing of ammunitionpeculiar equipment will survey the location and the equipmentupon completion of each validation project.

2.3 Radiation detection instruments. The following radiationdetection instruments, or their equivalent, are available tofacilities for routine and emergency monitoring:

a. The AN/PDR-77 radiation detection, identification, andcomputation set. This set consists of a radiation detection,identification, and computation meter and three probes (alpha,beta/gamma, and x-ray). The default readout for the alpha probeis in counts per minute (cpm), but the user has the option toselect microCurie (pCi) per square meter or disintegrations perminute (dpm) per 100-square centimeters. The ranges and theassociated units for the alpha probe are below:

0-999,000 cpm0-180 pCi per square meter0-999,000 dpm per 100-square centimeters

The range for the beta/gamma probe is 0-999,000milliRoentgen per hour (mR/hr) and the x-ray probe has a rangeof 0-999,000 cpm. The AN/PDR-77 radiation detection,identification, and computation set is also equipped withadjustable audio and visual alarms that can be set within arange of 0-999,000 cpm, for the alpha and x-ray probes or within0-999,000 mR/hr for the beta/gamma probe.

b. The VDR-2. The VDR-2 is a beta/gamma instrument only.It detects and displays the gamma radiation dose rate from 0.01microGray per hour (pGy/hr) to 100 Gray per hour (Gy/hr). It

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detects and displays the beta particle dose rate from 0.01 AGy/hrto 5 centiGray per hour (cGy/hr). The VDR-2 can also measure,store, and display accumulated dose from 0.01 pGy to 9.99 Gy.

2.3.1 Instrumentation used for health and safety purposes arecalibrated at least annually in accordance with standardcalibration procedures traceable through the National Instituteof Standards and Technology. The licensee will obtaincalibration services from the US Army Test, Measurement, andDiagnostic Equipment Activity, Redstone Arsenal, Alabama, orequivalent provider.

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Supplement 5 (Reference: NRC Form 313, block 10)

RADIATION SAFETY PROGRAM

1. Introduction. The Army, through the chain of command toindividual installations, has developed radiation safetyprograms to protect employees and the general public fromionizing radiation. In addition, each installation hasdeveloped safety procedures for the handling of ammunition andexplosives that reduce the likelihood of fires, explosions, andphysical damage to the ammunition items. These procedures haveresulted in a relatively accident-free environment. The smallnumber of incidents that have occurred have consisted ofscratches and scrapes on vehicles and packages, with little orno damage to the ammunition items. The safety proceduresimplemented for depleted uranium ammunition items include, butare not limited to, the following:

1.1 Radiological surveillance of storage and use areas.

1.2 Local inventory and accountability of ammunition itemscontaining depleted uranium components.

1.3 Periodic inspections and evaluations by commands havingjurisdiction over the facility.

1.4 Regular inspections of work and storage areas and transportvehicles by installation personnel.

1.5 Housekeeping procedures to minimize or eliminateunnecessary combustible material in and around storage areas,work areas, and transport vehicles.

1.6 Use of lightning protection systems around storage andwork areas.

1.7 Securing depleted uranium ammunition items within speciallydesigned areas and structures and in vehicles during transit.

1.8 Storing noncompatible ammunition and explosive itemsseparately from depleted uranium munitions.

1.9 Publishing basic radiological safety information in usermanuals. Some examples of this type of information are at thefirst enclosure to this supplement.

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1.10 Designating radiation safety officers to implement unit orinstallation radiation safety programs.

1.11 Maintaining a working environment where exposure toionizing radiation is as low as reasonably achievable.

2. Ammunition Surveillance: Supplementing the controlsdescribed in the paragraphs above, the Department of the Army,in its role as the Single Manager for Conventional Ammunitionfor the Joint Services, operates the Quality AssuranceSpecialist Ammunition Surveillance program. This programconsists of individuals trained specifically to performsurveillance inspections to verify the condition andserviceability of all ammunition items in the Department ofDefense stockpile.

2.1 The Quality Assurance Specialists Ammunition Surveillanceuse published inspection criteria to visually inspect depleteduranium ammunition at locations and times determined byHeadquarters, US Army Field Support Command. One of the thingsQuality Assurance Specialists Ammunition Surveillance look forwhen inspecting depleted uranium munitions is corrosion product.Evidence of depleted uranium corrosion may indicate thatadditional inspection and investigation is necessary todetermine the cause and extent of the problem. Inspectionintervals and criteria, as set by Headquarters, US Army FieldSupport Command, allows for adequate detection of problems.

3. Radiation Levels: The following paragraphs describe theradiation levels associated with depleted uranium ammunition.

3.1 Ammunition packages. The Department of Defensepredominantly stores depleted uranium ammunition in metalcontainers, but does use a number of wooden boxes. The maximumpenetrating dose rate on the surface of any ammunition packageor a pallet of packages is less than the 2.5-millirem-per-hourdose rate limit required for shipment under Department ofTransportation Exemption 9649. As an example, the maximumpenetrating dose rate on the surface of a single container ofthe largest currently existing depleted uranium ammunition round(the M829A3) is 0.34 millirad per hour. The highest dose oncontact with a pallet of these containers is 1.03 millirad perhour.

3.2 Routine operations. The Army does not require personalmonitoring devices for routine handling operations. For the

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majority of their lifetime, depleted uranium ammunition itemsremain in their containers and are stored in secure Armyfacilities. When outside of their container, ammunition itemsare handled for relatively short time periods. In addition,workers enter or work in ammunition storage buildings on a veryinfrequent basis.

'3.2.1 If unexpected situations arise, the installationradiation safety officer will institute a personnel dosimetryprogram if administrative protective measures cannot bereasonably implemented or fail to reduce exposures to within 10percent of the dose limits. If required, the installation willrequest dosimetry services from the US Army Test, Measurement,and Diagnostic Equipment Activity, Redstone Arsenal, Alabama, orequivalent provider.

3.2.2 Unless personnel dosimetry is required, routine handlingand storage areas are considered radiologically unrestrictedareas.

3.3 Disassembly operations. The Headquarters, US Army FieldSupport Command, Safety/Rad Waste Directorate contracted withAerojet, Incorporated, to provide a dose assessment report ondepleted uranium ammunition disassembly operations. Thefollowing information comes from that report:

3.3.1 The Aerojet report states, "It is likely that a workercould exceed 10 percent of the dose limits for the estimateddose criteria for the skin, extremity, and lens of the eye."The report goes on to say, "If safety glasses and medium weightgloves are worn while handling bare penetrators, the dose limitfor lens of the eye, extremity, and skin dose should not beexceeded."

3.3.2 The Aerojet report shows that whole body exposure is wellbelow 10 percent of the annual limit for disassembly of allmunitions except for the 25 millimeter, M919. The anticipatedwhole body exposure for the 25 millimeter, M919, is 0.251millirem per hour (2.51E-6 Sievert per hour). Assuming constantworkload throughout an entire year (2,000 hours), this equatesto 502 millirem per year or approximately 10 percent of theannual whole body dose limit. The anticipated whole bodyexposure for 105 millimeter rounds is slightly less than half ofthis, and the anticipated whole body exposure for 120-millimeterand 30-millimeter rounds is even less.

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3.3.3 The licensee will consider individuals involved indisassembly operations as occupational workers. As recommendedin the Aerojet dose assessment report, the licensee will requiresafety glasses, gloves, and extremity dosimeters for workers whohandle depleted uranium penetrators during disassembly lineoperations. The licensee will not require whole body dosimetersfor 30-, 105-, and 120-millimeter disassembly operations unlessexposure levels are found, or anticipated to be, in excess of 10percent of the annual whole body dose (10 percent of the wholebody dose is 500 millirem per year). The licensee believes itprudent to require whole body dosimeters for disassembly of25-millimeter, M919, munitions at least until experience with25-millimeter disassembly is obtained and actual exposure datashows clearly that workers receive less than 10 percent of theannual limit.

3.3.4 Personnel who briefly handle a small number of depleteduranium penetrators will wear gloves, but will not have to wearextremity or whole body dosimeters.

3.3.5 If necessary, installations will institute administrativecontrols to maintain exposures within 10 percent of the annualwhole body occupational worker limit (10 percent of 5,000millirem per year is 500 millirem per year). If required, theinstallation will request dosimetry services from the US ArmyTest, Measurement, and Diagnostic Equipment Activity, RedstoneArsenal, Alabama, or equivalent provider.

4. Posting and Employee Notification: Within the continentalUnited States, facilities used for storing or disassemblingdepleted uranium ammunition items will be posted with "CautionRadioactive Material" signs. Overseas, Army installations willpost "Caution Radioactive Material" signs in accordance withhost nation agreements or at the discretion of the installationcommander for security reasons.

4.1 Installation radiation safety officers will post Section206 of the 1974 Energy Reorganization Act and NRC Form 3 atcentral locations where ammunition workers can view them, suchas bulletin boards in break rooms or in the building where keysto the storage magazines are drawn. In addition, informationwill be posted with these two documents stating that otherapplicable documents, such as the license, Federal regulations,and Army regulations can be viewed in the office of theradiation safety officer.

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4.2 Installation personnel may request copies of the followingdocuments by contacting the Headquarters, US Army Field SupportCommand, radiation safety officer at commercial (309) 782-0338/2969/2989 or defense switched network 793-0338/2969/2989:

a. Title 10 Code of Federal Regulations Part 19 - Notices,Instructions, and Reports to Workers; Inspections.

b. Title 10 Code of Federal Regulations Part 20 - Standardsfor Protection Against Radiation.

c. Title 10 Code of Federal Regulations Part 21 - Reportingof Defects and Noncompliance.

d. Section 206 of the 1974 Energy Reorganization Act.

e. License application and amendment.

f. NRC Form 3.

g. NRC Regulatory Guide 8.13.

h. NRC Regulatory Guide 8.29.

5. Radiological Surveys. Each Army installation possessingdepleted uranium ammunition cartridges and/or components underthis license will perform radiological surveys of theirfacilities as outlined in this section. Surveys will includethe taking of wipes to check for removable contamination and theuse of a beta/gamma instrument to check exposure levels. It isthe responsibility of the installation radiation safety officerto ensure radiation surveys are done accurately.

5.1 Storage structures.

5.1.1 Structures storing complete rounds. Each installationwill perform annual surveys in 25 percent of the total number ofon-post structures storing complete depleted uranium ammunitioncartridges. Note: During times of war or threat of war,installations outside the continental United States in affectedtheatres of operation as well as continental United Statesinstallations (such as forts) heavily engaged in supporting theoverseas operation will be relieved of the annual surveyrequirement.

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5.1.2 Structures storing ammunition components. Installationsinvolved in disassembly operations will survey the building(s)where they store depleted uranium components twice a week. Whennot involved in disassembly operations, installations willsurvey buildings storing depleted uranium components at leasttwice a year.

5.2 Ammunition surveillance workshops. Each installation willperform a radiological survey of its ammunition surveillanceworkshop on a weekly basis when inspecting complete cartridges.Ammunition surveillance workshops will be surveyed daily ifdepleted uranium ammunition components are inspected.

5.3 Ammunition maintenance lines. Each installation willperform a radiological survey of depleted uranium ammunitionmaintenance lines on a weekly basis. As stated in supplement 2,section A, this license authorizes minor maintenance on completecartridges and does not authorize maintenance on cartridgesubassemblies.

5.4 Ammunition disassembly lines. During the first 2 weeks ofoperating a depleted uranium ammunition disassembly line, theinstallation will perform daily radiological surveys.Installations will pay particular attention to work areas whereworkers handle depleted uranium or components that have been indirect contact with the depleted uranium. After this initialtrial period, the frequency between surveys may be lengthened totwice a week if contamination is found below the contaminationlimits specified in paragraph 8 of this supplement.

5.5 Installation personnel will check radiological wipes with abeta/gamma detection instrument before sending the wipes to thelaboratory.

5.6 The licensee will obtain laboratory service from theUS Army Test, Measurement, and Diagnostic Equipment Activity,Redstone Arsenal, Alabama, or equivalent provider, or a labapproved by the US Army Test, Measurement, and DiagnosticEquipment Activity, Redstone Arsenal, Alabama, to analyzeradiological wipes.

6. Disassembly. All models of depleted uranium ammunition aresimilar in that they consist of two major components: theprojectile assembly and the cartridge case. During disassemblyoperations, the Army mechanically separates these two major

5-6

components. At the second enclosure of this supplement aredrawings of these major components for one model of depleteduranium ammunition. The drawings show: a complete round, acut-away of a complete round, and finally the cartridge case andprojectile assembly separated from each other. The Army mayship the projectile assemblies to a separately licensed facilityfor further disassembly or, when deemed advantageous, the Armywill take apart the projectile assembly. Workers involved intaking apart projectile assemblies will have some contact withthe depleted uranium penetrator.

6.1 Projects to disassemble depleted uranium munitions willinclude the removal and proper disposal of all explosivecomponents, and the removal of the depleted uranium forrecycling, reuse, or disposal as radioactive waste. Thelicensee will not subject the depleted uranium to any form ofdrilling, cutting, or mechanical abrasion.

6.2 Personnel involved in disassembly operations will typicallywear flame-retardant clothing, safety eyewear, conductive shoes,and gloves. Since the depleted uranium will not be subjected tooperations that could cause an airborne hazard, workers will notwear respiratory protective equipment. Before individuals leavethe disassembly area, they will be monitored for radiologicalcontamination.

6.2.1 No eating, drinking, gum chewing, tobacco use, or theapplication of cosmetics will be allowed in depleted uraniumammunition storage, handling, or disassembly areas. As requiredby Nuclear Regulatory Commission guidance, exposure to ionizingradiation will be limited to levels that are as low asreasonably achievable.

6.3 If possible, installations that store depleted uraniumpenetrators or contaminated components will do so in buildingsseparate from serviceable munitions. The Headquarters, US ArmyField Support Command, Safety/Rad Waste Directorate will provideinstructions to the installation for disposition of itemsgenerated during demilitarization operations.

6.4 At other licensed facilities, such as Savanna Army DepotActivity (Nuclear Regulatory Commission license SUC-1394,terminated) and the Iowa Army Ammunition Plant (Iowa Statelicense 0290-1-29-SM1, formerly Nuclear Regulatory Commissionlicense SUC-1381), the disassembly of ammunition items

5-7

containing depleted uranium has caused little, if any,contamination. Likewise, exposures to personnel have been low.

6.5 The Headquarters, US Army Field Support Command, willdetermine which Government-owned, Government-operatedinstallations will perform disassembly operations. When makingthese decisions, the Headquarters, US Army Field SupportCommand, will take into consideration the location of the assetsto be disassembled, the availability of adequate facilities andequipment, and the status of the installation's radiation safetyprogram to include the qualifications of radiation safetypersonnel.

6.5.1 The Headquarters, US Army Field Support Command,Safety/Rad Waste Directorate will approve each Government-owned,Government-operated installation for depleted uranium ammunitiondisassembly before operations begin at that installation. TheSafety/Rad Waste Directorate will base its approval upon theinstallation being able to meet all license requirements.

6.6 Worker training. Installations will ensure training isprovided to individuals who work in depleted uranium ammunitiondisassembly operations and that the training is documented.Normally, the installation radiation safety officer will providethe training, although other Government or contractor personnelcan provide the training as long as they are knowledgeable inradiation safety and can explain the topics identified in thefollowing paragraph:

6.6.1 Installations will provide initial training beforedisassembly operations begin and annual refresher trainingthereafter. Initial training will last approximately 1 hour andcover the following topics at a minimum; radiologicalcharacteristics of depleted uranium, biological effects ofradiation, methods of protection, emergency procedures,postings, and reference documents. Installations will alsoprovide an approximate 1-hour block of annual refresher trainingthat will cover the same topics. Workers will take a test foreach training session. The installation radiation safetyofficer will ensure Nuclear Regulatory Commission RegulatoryGuides 8.13 and 8.29 are available to interested personnel.

6.7 Operating procedures. Installation personnel will developoperating procedures for disassembly operations. The radiationsafety officer of the installation will assist in thedevelopment of these procedures and will coordinate with the

5-8

licensee on radiation safety aspects of the procedures. Theinstallation will obtain the approval of the licensee when theprocedures are finalized. Installation radiation safetyofficers will implement radiation protection programs at theirinstallations in accordance with license conditions as well asFederal and Army regulations.

6.8 The operations described in Section A of this license(including disassembly) do not require a decommissioning fundingplan per Title 10 Code of Federal Regulations, section 40.36,since the operations described in Section A will not involvedepleted uranium in dispersible form. The licensee does have afinancial assurance document (statement of intent) in place forthe depleted uranium on the Lake City Army Ammunition Plantfiring range. Information on the Lake City firing range is inSection B of supplement 2.

7. Emergency Response: The Army has developed emergencyprocedures for handling, storage, and transportation accidentsinvolving depleted uranium ammunition items. These proceduresare detailed in Technical Bulletin 9-1300-278, Guidelines forSafe Response to Handling, Storage, and Transportation AccidentsInvolving Army Tank Munitions which Contain Depleted Uranium,which is distributed throughout the Army. In addition, eachstorage and using location has developed specific emergencyprocedures for use with operations involving ammunition items.

7.1 Ammunition items are designed to withstand extremeenvironmental conditions and rough handling without being ahazard to either the user or the environment. Accidentsinvolving ammunition items containing depleted uraniumcomponents that are not associated with a fire or the threat ofa fire pose little or no radiological hazard and will be handledin accordance with local procedures that are based primarilyupon the explosive hazard of the item.

7.2 The response to a fire involving ammunition is generallybased upon the location of the fire, the potential threat tohuman life, and the explosive hazard associated with themunitions involved in the fire. In all cases, the senior fireofficer present will make fire-fighting decisions.

7.3 Fires involving depleted uranium ammunition items have adual hazard. The primary hazard is that of the explosivesassociated with the munitions. Secondary to the explosivehazard is the potential radiation hazard associated with

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oxidized depleted uranium. When depleted uranium ammunitionitems become involved in a fire, a very small portion of thedepleted uranium may become aerosolized and migrate with thesmoke plume. The Army considers the concentration of depleteduranium to be found in the inhalation exposure pathway from afire plume involving depleted uranium munitions and/or armor tobe low/insignificant based on data collected from variouslaboratory and field studies of burning depleted uraniumpenetrators and depleted uranium armor. The majority of thedepleted uranium involved in a fire remains at the scene. Thisdepleted uranium can pose an external radiation hazard if itremains in contact with the skin for an extended period of time.The depleted uranium remaining in the vicinity of the fire hasbeen analyzed and has been found to be highly nonrespirable andhighly nonsoluble in lung fluid. The small portion of thisdepleted uranium that is respirable can be an internal radiationhazard through inhalation if it is suspended in the air.Suspension could occur due to wind, explosion, or the activityof recovery crews. Because the depleted uranium, which remainsat the scene of the fire, is highly nonsoluble in lung fluid,the primary internal hazard of this depleted uranium is notchemical toxicity, but is the radiation exposure to the lung.

7.4 Historically, the occurrence of fires or explosionsinvolving finished ammunition items for all services is rare.Burn tests conducted by the Army and Air Force have shown thatonly small quantities of depleted uranium are released into theenvironment if a fire should involve ammunition items containingdepleted uranium components. The extreme density of depleteduranium tends to result in its being deposited in the immediatearea of the fire.

7.5 Fires aboard ocean-going vessels are generally fought tothe maximum extent possible by all available personnel.Land-based fires involving munitions with a mass detonation,fragmentation, or mass fire hazard are not fought on a routinebasis. For these types of fires, the area is generallyevacuated, and attempts are made to fight incipient fires thatare generated by the main fire. Fires involving munitions witha moderate fire hazard are generally fought. Additionally,fires posing a serious threat to human life may also be fought.

7.6 No special fire-fighting equipment is needed beyond thatcommonly worn by fire-fighting personnel. Typical fire-fightinggear and self-contained breathing apparatus is adequate.Although the smoke plume poses a small radiation hazard,

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personnel downwind of a fire involving depleted uraniumammunition should be evacuated mostly due to the possiblepresence of other nonradiological products in the smoke.

8. Surface Contamination Limits: Installations will consider asurface contaminated if one or more of the levels listed belowis exceeded. These levels apply to alpha emission of thematerial covered by this license and associated decay products.

AVERAGE (fixed and MAXIMUM (fixed and REMOVABLE ad

removable) ab removable) a"c

5,000 dpm / 100 cm2 15,000 dpm / 100 cm2 1,000 dpm / 100 cm2

Note a - As used here, dpm (disintegrations per minute) meansthe rate of emission by radioactive material as determined bycorrecting the counts per minute observed by an appropriatedetector for background, efficiency, and geometric factorsassociated with the instrumentation.

Note b - Measurements of average fixed and removable contaminantshould not be averaged over more than 1 square meter. Forobjects of less surface area, the average should be derived foreach such object.

Note c - The maximum fixed and removable contamination levelapplies to an area of not more than 100-square centimeters(100 cm 2 ).

Note d - The amount of removable radioactive material per100-square centimeters of surface area should be determined bywiping the area with dry filter or soft absorbent paper,applying moderate pressure, and then assessing the amount ofradioactive material on the wipe with an appropriate instrumentof known efficiency. When removable contamination on objects ofsurface area less than 100-square centimeters is determined, theactivity per unit area should be based on the actual area andthe entire surface should be wiped. It is not necessary to usewiping techniques to measure removable contamination levels ifdirect scan surveys show that the total residual surfacecontamination levels are within the limits for removablecontamination.

8.1 Cleanup of depleted uranium contaminated soil will be tolevels less than, or equal to, 35 picoCuries of depleteduranium/gram of soil. In addition, cleanup operations at

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accident sites will be conducted based upon the explosive andthe radiological hazards associated with the material involved.

8.2 In all cases, radiological cleanup will be to levels thatare as low as reasonably achievable.

9. Reporting: Accidents and incidents involving ammunitionitems containing depleted uranium components will be reported inaccordance with Army procedures to the local radiation safetyofficer. The local radiation safety officer will report anyaccident or incident to the license radiation safety officer.The license radiation safety officer will report accidents andincidents to the Nuclear Regulatory Commission as required.Reports to the Nuclear Regulatory Commission will be made to theNuclear Regulatory Commission regional office serving thelicense radiation safety officer regardless of the location ofthe accident or incident.

9.1 The following types of accidents and incidents will bereported as expeditiously as possible through the Army accidentreporting system to the local radiation safety officer andlicense radiation safety officer:

a. Theft or loss of control of ammunition items containingdepleted uranium components.

b. Functioning of ammunition items containing depleteduranium components.

c. Fires, explosions, or accidents involving storagestructures, transport vehicles, or Army weapon systems thatcontain depleted uranium ammunition where the ammunition itemsare or could be damaged.

d. Accidents or incidents that damage or expose thedepleted uranium components to the environment, or releasedepleted uranium to the environment.

9.2 Initial notification for the above types of accidents andincidents will be made telephonically or by priority messagewith a written followup report. When required, the licenseradiation safety officer will contact the Nuclear RegulatoryCommission. Followup reports will be submitted to the NuclearRegulatory Commission as the situation requires.

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9.3 Unless specifically directed otherwise, only unclassifiedinformation will be transmitted to the Nuclear RegulatoryCommission.

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Supplement 5, Enclosure 1(Reference: NRC Form 313, block 10)

EXAMPLES OF INFORMATION AND WARNINGS

1. As referenced in supplement 5, paragraph 1.9, the followingserve as examples of the type of safety information and userwarnings included in various Army publications:

The M829A1 is a full-service round, which is only firedduring war emergency. All peacetime firings are prohibitedexcept at locations having a Nuclear Regulatory Commissionlicense.

Loss or unauthorized firing of the M829A1 must be reportedto the Headquarters, US Army Field Support Command,Radiation Safety Officer.

Projectiles are not to be disposed of by burning ordetonation.

Depleted uranium ammunition must be grasped by the sabot -not the penetrator.

The penetrator should not be banged, used as a restingpoint, or stepped upon.

The depleted uranium (tank ammunition) is encapsulatedwithin the cartridge and poses no external or internalradiation hazard as long as the round remains intact. Ifextensive corrosion occurs or rounds are involved in afire, radiation contamination can result. Care should betaken to prevent inhalation or ingestion of the depleteduranium contamination. The procedures in TechnicalBulletin 9-1300-278 should be followed.

When handling depleted uranium ammunition, wear gloves. Ifcorrosion product is found on the round, contact your localradiation safety officer.

Regardless if gloves are worn or not, wash your hands afterhandling depleted uranium ammunition.

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Supplement 5, Enclosure 2(Reference: NRC Form 313, block 10)

DRAWINGS OF MAIN AMMUNITION COMPONENTS

As referenced in supplement 5, paragraph 6, the followingdrawings are of a typical round of depleted uranium ammunition.The drawings serve as an example to show the two main componentsof any round of depleted uranium ammunition; the cartridge caseand the projectile assembly.

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I ,

Complete Round

Complete Round Cutaway

Cartridge Case Projectile Assembly

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6 A l I r,

Projectilc

Assembly

Complete Round

Cartridge Case

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Supplement 6 (Reference: NRC Form 313, block 11)

WASTE MANAGEMENT

1. Normal storage and handling operations will not generateradioactive waste materials. Disassembly operations may resultin ammunition components that must be disposed as low-levelradioactive waste. In addition, render-safe operations,although infrequent, could also generate ammunition componentsto be disposed as low-level radioactive waste.

2. Headquarters, US Army Field Support Command, is the centralmanager for disposal of all low-level radiological wastematerials generated by the Joint Services, other than theNuclear Navy. Radioactive waste generated under the SUC-1380license will be disposed in accordance with Army Regulations andcurrent Nuclear Regulatory Commission and Department ofTransportation regulations. Headquarters, US Army Field SupportCommand, issues complete instructions to users on properpackaging and marking of shipments of radioactive waste.Headquarters, US Army Field Support Command, also conductson-site audits of radioactive waste shipments to ensure fullcompliance with Nuclear Regulatory Commission, Department ofTransportation, and burial-site criteria.

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APPENDIX A

RECORD OF ENVIRONMENTALCONSIDERATION

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S: 4 October 2002

AMSOS-SF (11-9k) 16 September 2002

MEMORANDUM FOR AMSOS-ISE

SUBJECT: Record of Environmental Consideration (REC) forNuclear Regulatory Commission (NRC) License Number SUC-1380

1. Reference NRC license number SUC-1380, January 1997,Possession of Depleted Uranium (DU) as Cartridge Penetrators.

2. We will submit the subject license for renewal to the NRC by30 October 2002 and require an updated REC. Please sign andreturn the enclosed REC to AMSOS-SF by 4 October 2002. Thecurrent REC is dated 16 August 1996.

3. The DU ammunition authorized by the license is located atnumerous Army installations within CONUS and OCONUS. Since itsinception in 1980, the license has authorized typical ammunitionhandling operations, to include storage, inspection, shipment,receipt, and minor maintenance. These operations have producedno known radiological contamination.

4. We are adding ammunition disassembly capability to thelicense and do not anticipate radiological contamination of theenvironment from disassembly operations. All planneddisassembly operations will occur inside standard Armyammunition facilities. Slight contamination of disassemblyequipment could occur. Such contamination should be easy tocontrol and remove.

5. The POCs are Messrs. Kelly Crooks and Gary Buckrop,AMSOS-SF, extensions 20338 and 22969 respectively, E-mailamsos-sf.

//signed//

Encl KRISTINE K. PRESTONActing Ch, Safety/Rad Waste Ofc

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RECORD OF ENVIRONMENTAL CONSIDERATION

PROJECT TITLE: Renewal of Nuclear Regulatory Commission LicenseNumber SUC-1380.

BRIEF DESCRIPTION: Renewal of license SUC-1380 is required forthe continued possession of depleted uranium components used inammunition.

ANTICIPATED DATE AND/OR DURATION OF PROPOSED ACTION: Durationis November 2002 to November 2007.

REASON FOR USING RECORD OF ENVIRONMENTAL CONSIDERATION:

This licensing action is categorically excluded IAW theFederal Register, 29 March 2002, Department of Defense, 32 Codeof Federal Regulations, Part 651, "Environmental Analysis ofArmy Actions; Final Rule". The specific categorical exclusionis at paragraph (h)(1) of Appendix B, section II, and reads asfollows:

(h) Hazardous materials/hazardous waste management andoperations:

(1) Use of gauging devices, analytical instruments, andother devices containing sealed radiological sources; use ofindustrial radiography; use of radioactive material in medicaland veterinary practices; possession of radioactive materialincident to performing services such as installation,maintenance, leak tests, and calibration; use of uranium asshielding material in containers or devices; and radioactivetracers.

SIGNED //signed// DATE 16 Sep 02KRISTINE K. PRESTONActing Ch, Safety/Rad Waste Ofc

SIGNED //signed// DATE 1 Oct 02C. R. HOBBYChief, Environmental Programs Division

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