As a word of background, on two military bases in Hawaii, the US Army has
admitted only to using toxic and radioactive Uranium in "spotting rounds" with
an old Davy Crockett nuke bomb back in the 1960s. Many have good reason to
believe that Uranium weapons were used in military training/testing throughout
the decades in weapons other than just the Davy Crockett alone. 
 
In the following paper, however, a geologist living in Hawaii gives the US Army
the most extremely generous benefit of the doubt, assuming for the purposes of
this analysis they are being totally on the "up and up" with its use of
DU limited to use in spotting rounds in connection with the Davy Crockett
back in the 60s. 
 
Even giving the Army this courtesy, however? The geologist explains why the US
military's testing of Uranium contamination has been inappropriate in terms
of testing techniques. In other words, the US military does the *wrong tests*
when it evaluates and reports on the impact of Uranium munitions use
upon human health and the environment. The geologist also expresses his
concerns for the health of Hawaiians - both civilians and the soldiers
stationed there.
 
Why would the military do the wrong tests when measuring radioactivity in
Hawaii?  Why, it stands to reason the Hawaiian tourist industry wouldn't
exactly flourish if news about excessive radiation levels were to get out!
Furthermore, with increased use of Hawaii as the military's sexiest playground
for war games, it is unlikely many military families would consider
it very desirable to be stationed at radioactive bases on the Hawaiian
Islands.
 
It is actually quite understandable why Uncle Sam would choose to use the
wrong tests when measuring its weaponized Uranium sins in the land of
Hawaiian Paradise. It really wouldn't do very well if the international
community were to find out it wasn't just Japan and its Pearl Harbor blitz
alone that has essentially "nuked" the lush, formerly pristine Land of Aloha,
now would it? 
 
Cathy Garger



 
 
From: shannon rudolph <shannonkona@...>
Subject: JUST AS WE SUSPECTED: ARMY DU STUDIES "FALL FAR SHORT"
To:
Date: Friday, March 13, 2009, 4:29 AM


PLEASE FORWARD



Dr. Pang and Dr. Busby agree with Dr. Reimer:
....Wrong testing being used to correctly measure depleted uranium on our
island.



"I am particularly concerned that what is proposed by the U.S. Army for future
(DU) studies at PTA will fall far short of providing the best information
possible at this time, or for that matter, provide any information that can be
used to develop a real rather than a speculative risk assessment."  from Mike
Reimer, PhD, Kona geologist, retired
 


Michael Reimer
75-6081 Ali`i Drive RR-103
Kailua-Kona, HI  96740
March 6, 2009
 
Colonel Howard Killian, Deputy Director
U.S. Army Installation Management Command
Pacific Region
132 Yamanaga Street
Fort Shafter, Hawaii 96858-5520
 
Dear Colonel Killian:
 
I have had an opportunity to review the reports released from DU studies at
Schofield Barracks and Pohakuloa Training Area.  I also spoke with Dr. Lorrin
Pang, some members of the Community Advisory Group, and met contractor Dr. Jeff
Morrow.
 
I agree with your statement that you mentioned in a previous communication we
had, and that is to let the science speak. 
 
In that light, I am particularly concerned that what is proposed by the U.S.
Army for future studies at PTA will fall far short of providing the best
information possible at this time, or for that matter, provide any information
that can be used to develop a real rather than a speculative risk assessment.
 
DU is an issue of evolving study results and knowledge.  There are some points
that are immutable fact.  We know that DU is present at Schofield and
Pohakuloa.   As I recall, the Army does not dispute the point of potential
health risk.  Therefore, we must take the best information we obtain today and
use it to address the concerns about the level of health risks from potential
exposure to DU. 
 
The citizens of the Big Island are concerned.  This is a natural, often
fearful, reaction anytime the word radiation is mentioned in our society.  Yet,
we live in a world with ubiquitous and unavoidable natural radiation, from
cosmic rays to the foodstuffs that provide our sustenance.  According to the
position of the U.S. EPA, any and all ionizing radiation has the potential of
causing cancer.  Thus, there has to be a reasoned balance between unavoidable
exposure and elective exposure.
 
The past use of DU on the Big Island places exposure to that type of radioactive
material in the “unavoidable exposure” category.  This brings forth the
question then of how much additional risk does it pose to the people of the Big
Island including the military personnel stationed and working at Pohakuloa.
 
I believe that with adequate study, this question can be answered with
reasonable assurance.  As I mentioned, I do not believe the currently planned
study has the capacity to answer that question.  The reason for my belief is
that the study design is to measure total uranium and to show that it is below
standards set by World Agencies for regulated exposures.  This may present
itself as a feel-good approach, but it is unfortunately misleading even with the
rudimentary information we have today about the form and occurrence of uranium
in the natural environment.  In other words, the study as currently planned
still leaves the door wide open on determining excess health risks, if any.
 
The attached commentary contains suggestions on what additional information
could be collected to help determine the risk.  It is fair to assume that the
information about the use of DU is as accurate as it can be.  That is, the only
use was in the Davy Crockett spotting rounds, no use of penetrating munitions
occurred, that is the 20mm or 30 mm rounds from various Gatling configurations,
smaller caliber rounds, or larger caliber armor penetrating munitions.  It
assumes that DU does not remain from any breach of containment if used as
ballast or armor reinforcement, or any other possible presentation of DU. 
 
My comments are intended for a reasonably informed individual about DU issues;
it is not overpoweringly technical but does use various standard abbreviations,
chemical, isotopic, and radiological inferences and acronyms.   For example, I
use DU for depleted uranium and its various components, and natural uranium or
NU for naturally occurring uranium.  I am not suggesting that the uranium has a
chemical, physical, or radiological difference.  However, it is different in
form and that is a significant difference for risk assessment.  In addition,
unless specifically mentioned, I do not separate radioactive decay into the
three common particles, alpha, beta, and gamma radiation.  Of special note is
my use of the term “form” in describing uranium.  Unlike the Hawaii
Department of Health presentation (November 2007), I use form not to refer to
the element uranium (and isotopes) but to describe its occurrence in a matrix
– natural, alloy DU, or
oxidized DU.
 
This is a commentary; it is not a formal, peer-reviewed technical report
although it may in some instances give the appearance of a peer review for the
program.  I do not duplicate information that can be found elsewhere and except
in unusual or compelling circumstances, I do not provide references.   For
detail not presented here, I am sure various contractors you have will be able
to address and clarify the concepts more fully.  However, I am also willing to
further explain my commentary for those issues that might be seen as some in a
gray area of meaning.
 
Sincerely,
 
 
 
Michael Reimer, Ph.D., geologist, retired
GeoMike5@...
 
Distribution:  Sherry Davis, Corey Hardin, Hawaii County Council, Pete
Hendricks, J. Morrow, Ph.D., L. Pang, M.D., LTC Richardson, S. Troute

 
 
Advisory Commentary of Michael Reimer on PTA Depleted Uranium Studies
 
Overview
Uranium in the natural environment occurs as an element within a mineral
matrix.  This is true for the oceanic basalts that comprise the bulk of the
volcano building material or even uranium mineralization associated with
economically recoverable uranium deposits.  This is in contrast with DU used as
munitions.  There, uranium is in a metallic form commonly alloyed with another
metal or as a component derived from that metallic form.  Regardless of
physical form or chemistry, uranium is radioactive.  In addition, uranium is a
heavy metal and can cause heavy metal toxicity if ingested in sufficient
quantities.
Any analysis of airborne materials that reveals uranium does not necessarily
distinguish between metallic or matrix-included uranium.  DU used at Pohakuloa
is reportedly 92 percent uranium alloyed with 8 percent molybdenum.  Other
alloy materials of DU munitions not known to have been used in Hawaii included
titanium, cobalt, and nickel.  Molybdenum as a heavy metal also has associated
toxicity.
There is a major difference in potential cellular radiation damage if exposed to
metallic uranium (or any particle with high uranium content, such as the 92
percent DU) versus exposure to oceanic basalt dust or aerosols where the uranium
content may be 0.1 to 1 part per million (0.00001 to 0.0001 percent).  The
reason for this is quite intuitive.  The more closely packed the uranium is, if
embedded in tissue, the greater the likelihood that its radioactive alpha
particles can provide multiple transits of the same cell during the cell’s
lifetime.
Chemical form is also important to consider.  DU and its alloys oxidize. 
Oxidized uranium (commonly valence VI) is more mobile in the environment that
reduced uranium (IV).  DU oxidizes as seen from the photographs of yellow
residues on spotting round assemblies.  The rate of oxidation is highly
dependent on the local environment in which the metallic alloy is deposited. 
One estimate from DU in soils indicated a 30 year time span before the DU would
be completely oxidized.  I find such a time frame incredibly quick and would
need conforming evidence to reinforce its validity.  From suspected oxidized
fragments found on Oahu, it does appear that the oxidization process may be
rapid in a moister environment.  The oxidization process of DU has been
observed for spotting rounds in Hawaii and while it occurs, it seems to be at a
much slower rate of progression as it has been perhaps over 40 years since the
munitions were fired on the Big Island.
In effect, there is a mixed scenario regarding the transport and migration of
DU, in both metallic and oxidized forms and there is a different health response
from both radioactive and heavy metal exposures.  Background surveys at
Schofield seemed to indicate that surface U radioactivity was less than that
found with samples taken from depth.  This is not unusual when you consider
that weather (leaching) of uranium and other metals can occur from surface
materials and it can be redeposited in lower horizons.  Migration of oxidized
DU could follow the same path but on a more rapid time frame.  I point this out
so that it may be considered as a mechanism for either form of uranium.
In response to finding DU at Schofield and Pohakuloa, the military performed
various scoping surveys and analyses to determine the probable extent of the
distribution of the DU munitions.  These surveys included soil sampling, plant
sampling, controlled burn of vegetation with ash collection and analysis, ground
surveys, aerial photographic surveys, and airborne fly-overs with a helicopter
fitted with sophisticated radiation detectors, and walk-overs with
scintillometers looking for spent rounds that have a rather unique shape.
 
DU, because of it purity of uranium, is difficult to find using common
radioactive detectors.  Its primary decay is through alpha particle emission. 
These alpha particles, have very limited range in air, perhaps 5 cm and even
less within any matrix material or soil cover.  There are limited emissions of
beta and low energy gamma rays from the decay and progeny, again with limited
range before all energy is transferred to the surrounding medium.  That medium
can be any combination of mineral matrix, soil, water, or air.  The progeny of
uranium decay are also radioactive until the end member is reached (Pb-206 in
the case of U-238).  Thus the radioactivity of purified U-238 begins to provide
greater radioactivity with the in-growth of progeny than that uranium
immediately after purification and the progeny can be detected just a few months
after pure uranium is cast.  In fact, within about 6 months after purification,
the radioactivity increases
from about 50 percent that of natural uranium (depending on the extent of U-235
separation) to about 75 percent.
If the DU was obtained from reprocessed fuel rods, the possibility of other
isotopes is real and they could include significant radiation emitters even in
trace quantities.  While one might be tempted to state factually that the
radiation of DU is less than natural uranium, it is the total radiation of the
spotter round that should be addressed.
 
The paper “Depleted Uranium, Natural Uranium and Other Naturally Occurring
Radioactive Elements in Hawaiian Environments” by Dr. Kenneth Rubin, of at
University of Hawaii (May 30, 2008) is an excellent overview paper covering many
details of uranium in the natural environment.  It is unfortunate that the copy
I read did not contain references.
 
Analysis
Uranium can be analyzed chemically and the surveys used ICP-MS that could even
provide isotopic analyses.  DU typically contains the naturally occurring
isotopes, U-238, U-235, and U-234.  If processed from spent fuel rods, it may
also contain U-232, U-233, and U-236, and nano-traces of other isotopes, as
well.  Typically, the presence of U-236 is an indicator of fuel rod
processing.  The energy of the alpha particle release is also indicative of the
particular isotopes.  Those energies can be resolved using alpha
spectrometry. 
All analytical measurements have detection limits.  That is, they have a
limiting number (concentration) below which the element of interest cannot be
detected.  The methods used in the scoping surveys probably provide the lowest
possible detection limit available by analytical instrumentation today.  For
example, if enough of the sample is available, ICP-MS can measure one part of
the element of interest in 1,000,000,000,000,000 parts of the other material;
that is 1 part in a million billion.  An advantage of the ICP-MS is that it can
measure isotopes of some elements, if enough material of the element of interest
is present.
Alpha spectrometry is another analytical means of detecting uranium isotopes and
was used for some sample analysis at Schofield.   It is capable of measuring
the alpha decay of individual atoms and the energy released is often
characteristic of the isotope!  Some care must be used in selecting a
calibrating isotope for this system so as to not interfere with the energy of
the particle of interest.
This is, of course, high praise for the potential of the analytical capability
but if not used properly in a well designed program, the analytical results can
be incorrect or misleading.
For example, if the analytical results are close to the minimum detection level
of the instrument, there is great uncertainty in the precision of the results. 
In other words, the standard deviation of the analysis can be so great that the
uncertainty (often shown as a plus or minus number indicating a range of the
result or expressed as standard deviation) pushes the analysis into a region
less than the minimum detection level. 
 
A note is in order here.  There is another limit commonly used, identified as
the reporting limit or RL.  It is typically higher than the minimum detection
level (MDL), often by an order of magnitude, just to avoid the great uncertainty
that accompanies analyses close to the MDL.  I would have to carefully check
Figure 3.1 on the Final Report of the ICM-MS results for total suspended air
filters to see if the RL is properly placed.
 
Analysis on the edge of the detection limit is particularly bothersome when
attempting to use the uranium isotope ratios from ICP-MS analyses to determine
if they are representative of natural or depleted uranium. 
Typically, U-235 and U-234 are lower in DU than in natural uranium.  U-236 does
not occur in natural uranium.  An isotopic analysis of uranium and comparison
of ratios of isotopes can reveal whether or not it is likely to be natural or
depleted uranium.  In addition, the presence of U-236 is nearly confirmatory
that DU is present.  Thus, the analysis of uranium isotopes presents many
internal controls for determining the possible existence of depleted uranium. 
In short, we know depleted uranium is there.  The question to be resolved is if
it has an airborne mobility vector.
From typical analytical results reported so far especially from the Schofield
studies, the total uranium concentrations are going to be between the MDL and
the RL.  Isotopic analysis if performed may not present any useful (resolvable)
information.
 
Next Sampling Phase
As I understand, the design of the continuing program to monitor airborne
particulates, I believe the results are going to be inconclusive whether DU has
mobility through an airborne vector.  I believe only ICP-MS is going to be used
for the analyses of particulates on the air filters.
Minimal modifications could enhance the monitoring to provide results that have
a better chance of revealing if DU is transported in the air.  I shall outline
them here with a brief explanation as to why they should be incorporated into
the study.
 
 
Recommendations
Alpha spectrometry.  Alpha spectrometry should be applied to all the samples
collected.  The alpha spectrometry is an important component to the overall
comprehension of the sample makeup.  It should detect U-234, U-235, and
U-236.  It could reveal U-236 if present that would be a clear indicator of 
depleted uranium and the sample should be counted long enough to detect any Po
and Ra, progeny of  U that could help distinguish between DU and naturally
occurring U.  I understand from Dr. Morrow when we met on March 3, 2009, that
alpha spectrometry is not part of the future studies.  I believe at least some
minimal number of samples should be designated for alpha spectrometry.  The
reason is that it might be able to detect the presence of isotopes
characterizing DU.  This may require extended sampling time or greater pumping
speeds.  Alpha spectrometry was performed at Schofield and should be continued
at PTA.  A total uranium analysis will not
distinguish DU from NU.
 
ICP-MS.  ICP-MS should be continued and additional elements included.  In
fact, there may be a suite of elements included that come as an analytical
packet for a minimal fixed cost.  Mo should definitely be included in the
analysis.  There is very little in Hawaiian basalts and larger quantities may
be an indicator of DU.  Additional analyses would be Ni, Co, and Ti.  Ti, a
later alloy of DU munitions might have a fairly high background in Hawaii as it
occurs in the percent range in some Hawaiian basalts.  Phosphorous may indicate
the use of fertilizer in the case where high uranium values are seen.  Although
ideally every sample should have a full analysis, I believe for at least 25
percent of the samples, a full suite of commonly run ICP-MS analyses should be
made.
The partial digestion analysis of a standing dust sample from Waiki`i ranch is
interesting in that it strains the analytical detection limits and vaguely hints
at the possibility of DU in airborne dust.  We have no information on the
quantity of the sample, counting times, particulate size distribution or
calibration and standards.  It is reasonable to suspect however that a rather
large quantity of sample was available for this ICP-MS analysis to include U-236
detection.
 
Duplicate, background, standards, and blank samples.  I recommend that
duplicate field samples be collected at certain times, even if this means
running two filters in parallel.  The issue of standards, blanks, backgrounds,
and replicates was poorly covered in the scoping reports.  Some indication of
reasonable measurement error range should be obtained and reported.  The
samples should be given to the laboratory unidentified as to whether they are
special category samples.  Typically, these samples represent 10 percent of all
samples.  Blanks are self explanatory; standards are those made by the lab to
calibrate the equipment and those prepared by the party submitting the
samples.  For background, see Sampling Frequency, below.
 
Particle observation.  I recommend that some of the filters be photographed
using an electron microscope to observe the particles that have been
collected.  Such photographs may indicate the nature of the particulate matter,
if it is amorphous or crystalline, organic (pollen) or inorganic.  It would
also be worthwhile to get some idea of the particle size distribution from a
range of 10 nanometers to 100 micrometers.  For some samples, I recommend that
an analysis be made of post-filter collections. There are multiple ways of
obtaining this information, including post-filter large surface area collectors,
that the contractor can recommend.
 
Sampling frequency.  I believe the sampling of aerosols is scheduled for
pumping 24 hours, once a week.  I would recommend that the sampling occur every
6 days or more frequently to obtain coverage for days of the week when different
scheduled activities may occur.  I also would like to see sampling stations set
up around the island.  *I understand from Dr. Morrow that such sampling has
already occurred as part of other, non-military sponsored monitoring, and some
information from those collections will be included in this study.  In
addition, the present sampling program is following a random day, US EPA
protocol.
 There should be some samples that are included as background.  These could be
upwind samples.  There are several air sampling programs in effect on the
Island, from government to university studies.  These monitor air quality for a
number of reasons, including particulates and elements related to volcanic
emissions and VOG.  I would suggest exploring the feasibility of including air
sampling for uranium as part of these ongoing operations and to have several
stations operating for several years in the quest for airborne DU.  A
collection and comparison of data from these other monitoring stations and their
ongoing analyses would be a good addition to discussion in a final report. 
This possibility of cooperation has been mentioned in various reports and I
encourage it as part of this survey.  For example, I highly recommend
discussions and data exchange (past, present and future) with researchers at the
Mauna Loa observatory.  They have been
measuring particulates and radioactivity as part of many different programs
over the years.
 
Training.  Personnel who traverse PTA should be given training in the
appearance of spotter rounds and potential fragments.  If seen, they should be
noted and reported for recovery.  I have seen that this training is included in
the license application to the NRC.
 
Aerosolization.  In spite of determined attempts to locate spent spotter
rounds, they were largely unsuccessful.  Only one round was located at PTA.
There could be many reasons for this.  One is the difficulty in finding DU via
radiometric surveys. 
The helicopter over-flights are another example of minimal detection
capabilities.  The helicopter flew at just feet off the ground but even that
small distance is equivalent to the inches of soil cover for attenuating
ionizing radiation.
There may have been several hundred to over 2,000 rounds fired.  The fact that
only one was recovered points out the difficulty of locating the rounds.  If a
suspicious material is found, that is physically located and recovered, alpha
particle detection can be used to determine if it is uranium.
Speculation can present a few additional scenarios besides inadequacies of
detection techniques that could provide explanation why more DU rounds are not
found.  The probable impact area is larger than the area being searched; upon
impact (and we do not know the target material), the rounds fragment highly,
including partial aerosolization; the rounds have mostly oxidized; the spotter
round impact area has been highly impacted by other activities including
exploding ordinance or vehicular traffic.  It should be pointed out that the
oxidized form is highly friable and can be dislodged easily from the host
metallic form.  It could be carried to deeper horizons by surface precipitation
and leaching or aerosolized more readily by mechanical means.   I doubt that
there is only one mechanism at work making the finding of rounds difficult.
 
Special sampling events.  Anytime there is a special event at the training
area, such as road construction or a firepower demonstration, sampling should be
done.  It is too bad that the helicopter did not include a dust sampling device
when it was searching for spotter rounds.  Such activities have the capability
of  placing aerosols and dust into the air and DU may be a part of that
release.  *I understand from Dr. Morrow that this is planned.
 
Minimum detection level or limit (MDL). There should be a concerted effort to
raise the analytical threshold above the MDL.  I recognize the difficulty of
this suggestion.   If this means collecting a sample for longer than 24 hours
or using multiple filters to collect more sample, it should be considered. 
As it currently stands, the reported concentrations of material analyzed is
about the same as the MDL.  This indicates that the concentrations of materials
are low and a conclusion is drawn that because the uranium is low, and below the
various exposure limits set by various health organizations, there is no threat
from exposure.  This is an inadequate approach, convenient, but inadequate.
As argued before, the form of the material is of great importance.  If a 10
nanometer diameter of DU is embedded in the lung, it will present a radiation
hazard even though it may only register as a small part of total uranium
collected on a filter.
 
Aerosol characterization.  These suggestions are made to enhance the
characterization of the aerosol sampling program.  The addition will impart
increased costs but it is needed to say with certainty what any increased health
risk might be if DU is present.  Aerosols can be created even when a spotter
round fragments.  This is noted from the dust released when any brittle object
is broken.  Of course, it is much less than burning an object and changing the
form into smoke or ash.  I have no information on whether or not the spotter
rounds were fired at a target and what that target might be.  Simple impact and
fragmentation will create aerosols.  The extent of this might be seen by
measuring the alloy metals (molybdenum) that would be part of the aerosol.
 
Health risk determination.  There are several means by which health risk from
exposure to DU can be determined.  Various models and worse case scenarios can
be used but the primary question is whether people were or are exposed to DU. 
For this, one hopes to have actual data for input.  The difficulty of obtaining
this for DU is discussed but I believe some modification to the sampling
program, also discussed, can obtain data that can be useful.   The selection
of risk determination can take many forms; the one used recently by the US EPA
for relative risk was particularly understandable by the public.  For soldiers
and contractors at Pohakuloa, the chance of being exposed to DU is greater than
for someone more distant from the site, but the risk is not negligible and the
magnitude of that risk will not be determined until data are available from the
aerosol monitoring.
For the Big Island, if you are exposed to SO2, you have an increased health
risk.  It is likely that most residents in their living locations are exposed
to very little SO2, so they do have an increased risk, albeit minimal, but an
increased risk nonetheless.  If it can be measured, it should be reported.
I depart here from my intent of making this a commentary and include some web
sites that may be of interest.  I mentioned that I feel sample collection must
be modified in order to determine if airborne DU is present.  Dust-size
particles are likely to be localized as they have a high settling velocity,
meaning they drop out of the air pretty quickly when the wind that carries them
decreases below a certain speed.  We know of course that dust can be carried
hundreds and even thousands of miles if it is elevated to high enough altitudes
but local winds do not appear to have the convective action to carry the dust
high to the altitudes needed for long-distance transport.  Aerosols, the
smaller particles, can be airborne for rather large distances.  They are
smaller and utilize the buoyancy effect for transport.  These are also the
particle sizes that are most likely to become inhaled to the deeper regions of
the lung.
Noting that various statements about radiation risk are attributed to the US
EPA, especially their position developed from radon that one ionizing particle
intercepting a single cell increases the cancer or mutation risk, I feel it is
prudent to use the EPA’s risk models.  They are pretty well developed and
even available on line. 
The reason for this approach is that DU has a different form than oxidized DU or
natural uranium.  It is possible that the aerosol particle is DU, 92 percent
uranium (920,000 ppm) rather than basalt with 1 part per million uranium.  This
potentially has a very different impact from alpha particles with cells in the
lung.   There are analogies to plutonium risk models and radon risk models. 
The use of a radon risk model has been independently suggested (Albright and
Barbour, 1999).  http://www.isis-online.org/publications/rp1.html
            The US EPA models and calculator are also available
on-line.  These were developed for Superfund sites and I would hope these would
be considered when developing the health risk determination of DU at PTA.  The
equivalent of U, Pu, and Rn can be run.
http://www.epa.gov/superfund/health/contaminants/radiation/pdfs/introglos.pdf
http://epa-prgs.ornl.gov/radionuclides
 
Historical input.  There are uncertainties dealing with the DU use at
Pohakola.  There is still time for contact to be made with individuals who were
stationed there at the time of the firing.  With luck, one might find a range
fire control officer.  They may know if there were 200 or 2,000 rounds fired,
if the testing was done in confined areas, and even if there were any hardened
targets involved.  In addition, perhaps a minor ecological health study could
be conducted using those stationed soldiers at the time before, during and after
firing, could be performed to see if there is a suggestion to conduct a case
controlled epidemiological study.  I include under this topic the historical
data and samples collected previously and available from archives.  I learned
from Dr. Morrow that these samples are available and predate the recent
recognition of DU use on the Big Island.
 
NRC license application.    The license application identifies at least 12
sites in the country that potentially have depleted uranium on site.  These are
very diverse ecologically and it may enhance the application if each was
discussed separately.  I make this suggestion in lieu of suggesting that a
separate application be filed for each area. 
The concept of providing training is sound but training must be an ongoing
program for as long or longer than there is DU at these sites.  The $1.9
million sought may be insufficient to accomplish and maintain this goal.  This
training goes along with the commentary I provided in the brief training section
above.
I believe the license application should make it perfectly clear that if DU is
found, it will be removed.  The license application includes a discussion of
detecting depleted uranium and talks about the quantity needed to be seen on
scintillometer devices.  I would restructure this section as it basically
states that unless a rather complete spotter round is found lying on the
surface, it will not be detected.  This comes from the calculation in the
application of the amount of DU needed to be detected and the weight of the DU
present in a spotter round.  Let me provide the example of this.  In the
application to the NRC for a license to handle, store and dispose of DU at
various military facilities, it is stated that a sophisticated radiometric
detection system will be assembled and used.  It further states that it will be
capable of detecting surface fragments 6 cubic centimeters of volume and those
buried 2 inches deep that contain 10 cubic
centers volume of DU.  As the density of U is 19 g/cm3 and the weight of DU in
a spotter round is 190 grams, this highly sophisticated instrument will likely
detect nothing.  Anything, particularly fragments buried a few inches below the
surface avoids detection completely. 
 
 
Summary
The present method proposed for air monitoring has very little chance of
revealing depleted uranium.  Several slight modifications to the sampling
program are recommended.  The major changes are to include alpha spectrometry
(U-233, 234, 235, 236, 238, Po, Ra), and additional ICP-MS elements such as
typical alloy compounds, Mo, Ti, Co, Ni, Cr, and even Pb.  Quantity of samples
should be sufficient to move the analysis above the RL level.  An attempt to
characterize size distribution from millimeter to nanometer should be made on a
few samples.  Sampling periods should be varied, every six days for example,
and include background, duplicate, replicate, and blanks.  Ideally, the air
monitoring sampling at the perimeter of the training area should be monitored
continuously.  The sampling program should include special events at PTA such
as those that may create a lot of dust and monitoring stations around the Big
Island should be set up with
monitoring continuing for several years.
 


 








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