Pohakuloa Training Area

1.0 Site Identification

2.0 Site Status Summary

The Pohakuloa Training Area is located on the island of Hawaii between Mauna Loa, Mauna Kea, and the Hualalai Volcanic Mountains. It extends up the lower slopes of Mauna Kea to approximately 6,800 feet in elevation and to about 9,000 feet on Mauna Loa. The training area is about midway between Hilo on the east coast and the Army landing site at Kawaihae Harbor on the west coast. The area is the largest Department of Defense (DOD) installation in Hawaii. The area is accessible by air with permission of military Air Traffic Control helicopter or land via Saddle Road from Hilo or Kona.

The initial discovery of depleted uranium from the M101 spotting round was at locations within the Schofield Barracks on the Oahu Island in Hawaii andthe Pohakuloa Training Area on the Big Island in Hawaii and at Fort Hood, TX. Additional installations where the M101 spotting round has been found include: Fort Benning, GA; Fort Campbell, KY; Fort Carson, CO; Fort Hood, TX; Fort Knox, KY; Fort Lewis, WA; and Fort Riley, KS. Installations currently subject to further investigation include: Aberdeen Proving Ground, MD; Fort Dix, NJ; and Makua Military Reservation, HI. A total of 75,318 M101 spotting rounds were originally produced. Each depleted uranium projectile body weighed approximately 3,180 grains. This equates to about 206 g or 0.45 lb. Given a composition of 92 percent depleted uranium and 8 percent molybdenum, 2926 grains or 190g of depleted uranium was contained within each round. The M101 spotting round was manufactured and distributed under NRC License SUB 459. In the 1970's, approximately 44,000 DU rounds were demilitarized under the Remington Arms license by firing them into the 600-Yard Bullet Catcher. In addition, about 2000 rounds were fired at Lake City Army Ammunition Plant in the 1960's for lot testing. As such, a total of about 46,000 rounds can be accounted for out of a total production of 75,318 leaving about 29,300 rounds for distribution to Army organizations. Details with regard to the specific number of rounds issued to a given installation, previously recovered from ranges or disposed of as radioactive waste is not currently known. Given 29,318 rounds each containing 206 grams of alloy equates to an actual maximum possession quantity of about 6040 Kg of alloy containing about 5560 Kg of depleted uranium. A common characteristic of the sites where the M101 spotting round fragments are located is that they are well within the installation boundary and are located in an impact area where access is strictly controlled. These impact areas contain a number of other hazards such as unexploded ordinance which require restricted access and additional training prior to entry. This limits the potential for inadvertent exposure and that members of the general public, including Army civilians and soldiers, are not directly exposed to the material. According to the Archives Search Report (ASR) On the Use of Cartridge, 20MM Spotting MI0N For Davy Crockett Light Weapon M28, Schofield Barracks and Associated Training Areas, Islands of Oahu and Hawaii (USACE 2007), training on the Davy Crockett weapons system was likely conducted at Pohakuloa between 1962 and 1968. Preliminary aerial reconnaissance conducted in 2007 and early 2008 identified the presence of pistons, spotter round bodies (SRB), DU fragments and other components indicative of the Davy Crockett system use at Pohakuloa.

3.0 Major Technical or Regulatory Issues

On On November 6, 2008, the Army filed its application for a possession-only license for Schofield Barracks and the Pohakuloa Training Area. On July 8, 2009 the Army provided the NRC their Generic Physical Security Plan and their generic Environmental Radiation Monitoring Plan (ERMP). In that submittal the Army also provided site specific ERMPs for Schofield and Pohakuloa. On August 3, 2009, the NRC accepted the Army s application for review and on August 13, 2009, a Federal Register notice was published which offered an opportunity for interested members of the public to comment and to request a hearing (74 FR 40855 ). Any requests for a hearing on the application were due by October 13, 2009. One Category 1 publicly noticed technical meeting was held with the Army on August 24, 2009 and three Category 3 public meetings were held on the evenings of August 25-27. There was has been a request for a hearing and to extend the comment period. The comment period has been extended two weeks for three individuals. Numerous individuals provided comments on the proposed license application. Several individuals requested a hearing but none were timely nor did they followed the procedures outlined in the Federal Register Notice. Nevertheless, five individuals were allowed to demonstrate that they had standing. On December 17, 2009 the Atomic Safety and Licensing Board (ASLB) issued an order identifying issues for oral argument. Oral arguments were held and a decision was issued by the ASLB on February 24, 2010 denying that the petitioners had demonstrated standing. On March 4, 2010, one of the individuals, Mr. Isaac Harp, appealed the Board's decision and requested that the NRC take enforcement action by initiating an investigation into the potential violation of License SUB-459 and, if it is determined that a violation has occurred, to apply the full penalty permissible by law. Mr. Harp also requested that any monetary fines should go toward environmental remediation of depleted uranium contamination at Schofield and Pohakuloa, if the law provided for such action. As a result of Mr. Harps request for the NRC to take enforcement action against the Army regarding activities at Schofield Barracks and the Pohakula Training Area, the staff convened a Petition Review Board and accepted the petitioners request under 10 CFR 2.206. On June 17, 2010, the Petition Review Board concluded: (1) There is no existing Army license which permits the Army to possess depleted uranium (DU) at Schofield Barracks and Pohakuloa Training Area; (2) The Army is required to have a license to possess DU; (3)The Army is potentially in violation of the NRC's Regulations; and (4) An Enforcement Review Panel will be convened July 15th to determine if a violation has occurred and, if one had, the severity level.

The staff has reviewed the Army's generic environmental monitoring plan and the specific monitoring plans for Schofield and Pohakuloa. The staff has concluded that all three are deficient and the staff has drafted a generic plan which should be the framework for monitoring all DU sites. The staff intends to transmit their findings in a letter to the Army. It is also intended that a public meeting be held with the Army in October to discuss the generic and site specific ERMPs. In a March 11, 2010 letter to the Army, the NRC requested that the Army provide applications for each of the seven remaining Army forts containing DU within 6 months. A September 9, 2010 letter from the Army requested a two week extension to the 6 month extension. In a September 13, 2010 letter, the Army indicated that it would be submitting Fort Benning with subsequent reports to follow on schedule of one plan/month basis. A conversation with the RSO indicated that DU spotting rounds are believed to be present at an additional 5-6 Army forts not previously identified. The NRC is developing a response to the September 9th and 13th letters.

4.0 Estimated Date For Closure