Since last October, I have been petitioning the U.S. Nuclear Regulatory Commission and other agencies to help with the problem of depleted uranium munitions, which produce fumes causing birth defects and other problems.
There are
now several
examples of
this effort in my diaries. Below the fold is my latest petition.
3 April 2005
Luis A. Reyes
Executive Director for Operations
U.S. Nuclear Regulatory Commission
BY EMAIL AS PER 10 CFR 2.206(a)
Dear Mr. Reyes:
Pursuant
to 10 CFR 2.202, I request that all licenses allowing the possession,
transport, storage, or use of pyrophoric uranium munitions be modified
to impose enforceable conditions on all such licensees in order to
rectify their misconduct as described below, and any other corrective
action as deemed proper.
The basis for this request is the gross
negligence on the part of the licensees, as documented by the as yet
undisputed facts set forth in NRC allegation number RI-2005-A-0035
below.
This is an exceptionally grave issue involving
significant safety and environmental issues. It is clear on the face of
the allegations that a result materially different from the issuance of
the existing licenses would have been likely had uranyl nitrate fume
emission from uranium munitions been considered upon the initial
applications for the licenses allowing them.
Because this
request involves the conduct of military functions, in accordance with
10 CFR 2.301, I ask that the Commission provide an alternative
procedure for adjudication allowing the immediate issuance of orders to
protect the health of United States armed forces currently at risk of
exposure to uranium munition combustion products. This request for an
alternative procedure includes but is not limited to: foreshortening of
the Commission's customary time limits in accordance with 10 CFR
2.307(a), expedited issuance of an initial
order in accordance with 10 CFR 2.339(a), and/or the use of expedited
proceedings in accordance with 10 CFR sections 2.1400 through 2.1407.
Please confirm receipt by return email with the case file number assigned to this request. Thank you.
Sincerely,
James Salsman
---- NRC ALLEGATION NUMBER RI-2005-A-0035 ----
16 March 2005
Commissioner Nils Diaz
Chair
Nuclear Regulatory Commission
and staff
Dr. Jofu Mishima
and colleagues
URANYL NITRATE ALLEGATION FACTS
Dear Ladies and Gentlemen:
This
message is intended to clarify and supplement my "Allegation and
Emergency Report" sent to the NRC on 12 March 2005. As yet there has
been no dispute of my allegations. However, my earlier message was
somewhat difficult to read because it preserves the format of several
messages of included correspondence. This is the essence of my
allegations:
1. The primary U.S. scientist responsible for the
study of depleted uranium munitions safety from no later than 1979
through at least 1999, was Dr. Jofu Mishima, who has worked with
several colleagues at Battelle Pacific Northwest Laboratory, under
contract from the Department of the Army.
2. Dr. Mishima is an author of the following and related publications:
Parkhurst, M.A., J.R. Johnson, J. Mishima,
and J.L. Pierce, "Evaluation of DU Aerosol Data: Its Adequacy for
Inhalation Modeling," PNL-10903, Richland, WA: Battelle Pacific
Northwest Laboratory, December 1995
Gilchrist, R.L., J.A. Glissmyer, and J.
Mishima, "Characterization of Airborne Uranium from Test Firings of
XM774 Ammunition," PNL-2944, Richland, WA: Battelle Pacific Northwest
Laboratory, November 1979
Parkhurst, M.A., J. Mishima, and M.H.
Smith, "Bradley Fighting Vehicle Burn Test," PNNL-12079, Richland, WA:
Battelle Pacific Northwest National Laboratory, February 1999
3. In email correspondence this year, Dr. Mishima wrote that he was unaware of the fact that uranium reacts with nitrogen at 700 degrees Celsius.
4.
Accordingly, Dr. Mishima indicated that he was unaware of any attempt
to detect uranyl nitrate in the combustion products of DU ordnance by
the Army. This is consistent with all of the published literature and
summaries of classified documents I have been able to find describing
the combustion products of uranium munitions. However, European
scientists did detect uranyl ion in an enclosed burn last year:
http://dx.doi.org/10.1016/j.jenvrad.2004.04.001
4.1. Quoting S. Cotton in _Lanthanides and Actinides_ (New York:
Oxford University Press, 1991) page 127: "Aerial oxidation of any
uranium compound eventually results in the formation of a uranyl
compound."
4.2. Quoting A. Pfister in Chapter 8, "The Chemical Toxicity of
Uranium," of _Depleted Uranium: Sources, Exposure and Health Effects_
(World Health Organization, Ionizing Radiation Unit, 2001 --
http://www.who.int/ionizing_radiation/pub_meet/en/Depluranium4.pdf),
page 103: "Until more information on the chemical form of uranium and
DU in the environment is obtained, it would be prudent to assume that
it is in a soluble form (ICRP Type F)."
4.3. Thirty days after submission of this original allegation,
having received no reply from any of the accused, or any contrary
viewpoints from any of the dozens of other original recipients, I
chose to post my petition and engage in a wide-ranging debate on
the health physics-oriented internet mailing list RADSAFE. My
posts to that e-mailing list and their replies are available here:
http://radlab.nl/pipermail/radsafe/2005-April/date.html
Because of replies I received from the readers of RADSAFE, I now
believe that the primary culprit in uranium combustion product
fume toxicity resulting in chromosome damage as described by
H. Schröder, et al. in Radiation Protection Dosimetry 103:211-220
(2003) -- http://rpd.oupjournals.org/cgi/content/abstract/103/3/211
-- and the 50% increase in birth defects among children fathered by
February, 1991 Gulf War veterans as of 1999 described in the two
peer-reviewed medical publications cited below, is primarily the
UO3 oxide species, which is similar in solubility to uranyl nitrate,
but light enough in density to waft away in the updraft from a
munitions fire so as not likely to be detected in the open-air
burns the licensees have been using (apparently exclusively.)
The UO3 oxide species also clumps less readily than the other
uranium oxides, which also serves to explain the fact that
while the Gmelin Handbook and other actinide references claim UO3
comprises one fifth of uranium's aerial combustion products, the
licensees have never detected it in their munitions burn tests.
5.
The basic fact that uranium reacts with nitrogen gas at 700 degrees
Celsius has been published in scientific literature since at least the
1950s. Many introductory chemistry texts which mention uranium point
out that uranium reacts with most all of the elements except the noble
gases. The fact is well known in the nuclear power industry, which has
been using airborne uranyl nitrate detectors in places where uranium
might react with air since at least the 1970s. I have no reason to
believe that Dr. Mishima or his associates deliberately suppressed the
basic fact, and his apparently forthright email responses, and his
reaction to the Salbu et al. paper linked above makes me think that he
was actually, somehow, simply unaware of it. However, for anyone with
responsibilities he and his colleagues shouldered, there is absolutely
no excuse for not knowing any fact so vital to his specific research
and general field of study. As a layman, it took me less than two days
of library research to learn the reaction temperature.
6. Uranyl
nitrate has a very low melting point compared to any of the uranium
oxides, and it has a very high vapor pressure, and precipitates as a
film. I haven't been able to determine exactly how long it stays
dissolved in air under different atmospheric conditions yet. (But I
have reason to believe that there are molecules of uranyl nitrate from
DU munitions used in Iraq currently in your lungs as you read this.
Those who know the magnitude of Avogadro's Number might not be as
impressed with that fact as others.) Uranyl nitrate is much more
poisonous than any of the oxides. The extent of the toxicities involved
need to be determined.
7. In conclusion, because of Dr. Mishima
and his colleagues' omissions, everything the U.S. government has ever
said about the safety of pyrophoric DU munitions is invalid.
Essentially all contemporary uranium ordnance safety studies must be
redone in order to determine the extent of uranyl nitrate combustion
product emissions.
8. The safety of uranium munitions must henceforth be established
from combustion product collection in enclosed, rather than
open-air ordnance burn tests. These tests must precisely quantify
and qualify at least 99.99% of all uranium combustion products
in terms of their chemical formulas, oxidation state, dissolution
in air, density, and physical state.
9. The risk from uranium munitions' combustion product inhalation
must be quantified in formal statistical terms, including the
expected risk ratios and their confidence intervals under several
sets of circumstances involving different distances and exposure
patterns which would be considered typical for military personnel
and civilians in and around the areas where uranium munitions may
be used, for expected ailments including nephrotoxicity, lung
cancer, bone cancer, leukocyte chromosome damage, gonad and sperm
chromosome damage, and the resulting congenital malformations in
children of the exposed.
10. Until the safety risks of pyrophoric uranium munitions are
determined accurately, their use should be suspended by all
licensees allowed to possess, store, or transport such ordnance.
11. Because of the misconduct brought to light in this allegation,
use of pyrophoric munitions without an accurate understanding of
the risks involved will henceforth be considered a willful and
reckless disregard for the safety of the potentially exposed.
Sincerely,
James Salsman
---- additional commentary, excerpts, and references ----
It
seems to me that since uranium will accumulate in testes, this explains
the increase in birth defects observed in children fathered by Gulf War
veterans, several years after exposure. See, e.g.:
"Overall, the
risk of any malformation among pregnancies reported by men was 50%
higher in Gulf War Veterans (GWV) compared with Non-GWVs" -- http://ije.oupjournals.org/cgi/content/full/33/1/74
"Infants conceived postwar to male GWVs had significantly higher prevalence of
tricuspid valve insufficicieny (relative risk [RR], 2.7; 95% confidence
interval [CI], 1.1-6.6; p = 0.039) and aortic valve stenosis (RR, 6.0;
95% CI, 1.2-31.0; p = 0.026) compared to infants conceived postwar to
nondeployed veteran males. Among infants of male GWVs, aortic valve
stenosis (RR, 163; 95% CI, 0.09-294; p = 0.011) and renal agenesis or
hypoplasia (RR, 16.3; 95% CI, 0.09-294; p = 0.011) were significantly
higher among infants conceived postwar than prewar." -- http://www.ncbi.nlm.nih.gov/entrez/query.fcgi?cmd=Retrieve&db=PubMed&list_uids=12854660&
dopt=Abstract
Here
are some quotes with their full citations from "A review of the effects
of uranium and depleted uranium exposure on reproduction and fetal
development," in Toxicology and Industrial Health, vol. 17, pp. 180-191
(2001), which is temporarily at:
http://www.bovik.org/du/reproduction-review-2001.pdf
"In
rats, there is strong evidence of DU accumulation in tissues including
testes, bone, kidneys, and brain." Pellmar, T.C., Fuciarelli, A.F.,
Ejnik, J.W., Hamilton, M., Hogan, J., Strocko, S., Edmond, C., Mottaz,
H.M. and Landauer, M.R. "Distribution of uranium in rats implanted with
depleted uranium pellets," Toxicol Sci, vol. 49, pp. 29-39 (1999.)
"Degenerative changes in the testes resulting in aspermia in the testes and epididymis ...
apparently a result of uranyl nitrate" Maynard, E.A., Downs, W.L. and
Hodge, H.C., "Oral toxicity of uranium compounds," in Voegtlin, C. and
Hodge, H.C., editors, Pharmacology and Toxicology of Uranium, Volume 3
(New York: McGraw-Hill, 1953), pp. 1221-1369.
"uranium exposure
causes morphologic changes in the rat testes possibly as the result of
a uranium-induced autoimmune response.... Average testes weight was
significantly (P0.05) decreased in rats exposed to uranyl nitrate....
Titers of testicular autoantibodies were described as fairly high for
rats with chronic exposure to uranium and the authors relate this
finding to the possibility that the observed testicular changes are an
autoimmune response to protein confirmation changes as a result of
uranium-protein interactions. Four other references are cited ...
as evidence of an interaction between uranium and the testes or thyroid
but are not reviewed here." Malenchenko, A.F., Barkun, N.A. and Guseva,
G.F., "Effect of uranium on the induction and course of experimental
autoimmune orchitis and thyroiditis," J Hyg Epidemiol Microbiol
Immunol, vol. 22, pp. 268-277 (1978.)
"The number of female mice
impregnated successfully was significantly reduced at all levels of
uranium exposure as compared with negative controls." Hu, Q. and Zhu,
S., "Induction of chromosomal aberrations in male mouse germ cells by
uranyl fluoride containing enriched uranium," Mutat Res, vol. 244, pp.
209-214 (1990.)
Testicular injection with ... uranyl fluoride ...
resulted in a dose-dependent increase in chromosomal aberrations (i.e.,
DNA breakage, SCEs) in spermatogonia, primary spermatocytes, and mature
sperm of adult mice." Zhu, S.P., Hu, Q.Y. and Lun, M.Y., "Studies on
reproductive toxicity induced by enriched uranium," Zhonghua Yu Fang Yi
Xue Za Zhi, vol. 28, pp. 219-222 (1994.)
"existing data indicate
that implanted DU translocates to the rodent testes and ovary, the
placenta, and fetus.... DU has been shown to be genotoxic...." Benson,
K.A., Evaluation of the health risks of embedded depleted uranium (DU)
shrapnel on pregnancy and offspring development, Annual Report No.
19981118065 (October 1998.) That quote also cites Pellmar, et al., as
above, and A. Miller et al., from the U.S. Armed Forces Radiobiology
Research Institute, whose work can be found on MEDLINE.
---- end of 3 April 2005 request to NRC Exec. Dir. for Ops. ----