TAB O - Guidance for Protecting Troops

The test and evaluation programs that paved the way for the fielding of DU munitions and armor acknowledged their potential for creating battlefield DU contamination. The Department of Defense (DoD) and the Services recognized the need to protect troops who might have to operate in such environments. Unfortunately, most of the guidance issued before and during the war was oriented toward peacetime accidents on US military installations, rather than addressing the very different demands of wartime/contingency operations. A number of memorandums and advisories containing simple, field expedient precautions and advice were sent to the theater, but often failed to reach units and troops who had to respond to accidents and events involving DU contamination.

The storage, handling and distribution of DU munitions and armor are governed by stringent guidelines based on Nuclear Regulatory Commission (NRC) licensing requirements. The Army used this guidance as the basis for developing procedures to respond to accidents such as tank fires or ammunition explosions where DU could be released into the environment. As such, the regulatory guidance was extremely restrictive, and in some respects poorly suited for operational deployments. Unfortunately, alternative guidance addressing battlefield requirements, and offering effective, field-expedient protective measures, was not widely disseminated during Operations Desert Shield/Desert Storm. Instead, the available, peacetime guidance was applied. The primary source of this guidance was TB 9-1300-278, which, as will be explained, mandated procedures that in a wartime context were often disproportionate to the actual hazard, or impractical.

1. Technical Bulletin 9-1300-278

Technical Bulletin (TB) 9-1300-278, Guidelines for Safe Response to Handling, Storage, and Transportation Accidents Involving Army Tank Munitions or Armor Which Contain Depleted Uranium, was the Army’s operative guidance for responding to incidents resulting in the localized release of DU. Dated November 20, 1987, it was revised in September 1990—in time for the Gulf War—and again in July 1996.

TB 9-1300-278 outlines procedures for responding to, and controlling the hazards resulting from, accidents and incidents involving DU. In addition to addressing the radiological and chemical toxicity hazard and contamination control, the guidelines also cover explosive and fire hazards, which are usually present as well. The TB was written to satisfy NRC licensing requirements. The NRC’s requirements relate to protection of workers and the public from radiation during peacetime operations. Contamination levels are derived from "NRC Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material." These guidelines set limits for returning formerly contaminated facilities (buildings, shops, etc.) to unrestricted use by members of the public. Similar limits have been adopted by the Department of Energy, in its Radiological Control Manual,[301] and by other agencies

The Technical Bulletin instructs crews, explosive ordnance disposal (EOD), and radiation protection and firefighter personnel on how to deal with tank fires involving DU munitions and armor in peacetime. The guidelines are intended to provide maximum safety while protecting life and property. Examples of the guidelines (with OSAGWI comments in italics) include:

These and other AMCCOM guidelines serve several purposes:

Many personnel whose missions required them to operate around DU-contamination, including at least one in-Theater Health Physicist with an active radiation control role, were not aware of the specific contents of TB 9-1300-278, or even of its existence.[302] In addition, a 1993 General Accounting Office (GAO) report found that TB 9-1300-278 was not widely available in late 1990 or 1991.[303] However, according to a former US Army major serving with the US Army Armament, Munitions, and Chemical Command (AMCCOM) at King Khalid Military City (KKMC) the manual was available at the time of the December 1990, tank fire in Saudi Arabia.[304] In any event, the guidelines contained in TB 9-1300-278 were largely unknown outside a few specialized teams (RADCON responders, Battle Damage Assessment Teams) deployed to the Gulf.

The DoD has acknowledged that pre-war DU awareness training was inadequate. Abrams crewmen received a brief block of training on the peacetime, regulatory requirements for handling DU munitions. More extensive training was provided to Nuclear-Biological-Chemical (NBC) response personnel assigned to most units, as well as EOD, RADCON, and safety personnel.[305] In general, this information was not shared outside these units or agencies. The lack of DU awareness was identified as a deficiency, as evidenced by a May 24, 1991, Memorandum from AMCCOM to TRADOC (Training and Doctrine Command) recommending that DU safety training be given to all armor and infantry soldiers and officers who required it.[306]

2. Other Warnings and Advisories

Before, during, and after the ground campaign, AMCCOM and other agencies issued warnings and advisories regarding specific measures to minimize exposures to DU. Too often, this information failed to reach commanders, officers, NCOs, and soldiers at the unit level. Many veterans have reported that they were completely unaware of DU, its properties, and safeguards and precautions to take against DU exposure.

Examples of supplemental guidance issued in support of the Gulf deployment include:

These messages were aimed at ensuring adherence to the ALARA principle to minimize potential exposures. Some guidance given to selected groups was less restrictive. The Battle Damage Assessment Team (BDAT), tasked with evaluating destroyed US combat vehicles, were instructed to wear anti-contamination suits (cotton overgarments) and surgical masks.[312] This protective posture was the same as that used by range personnel at Aberdeen Test Center, where several of the BDAT members worked prior to the war. This locally developed guidance applies to range workers who work with hard target impact testing, and has been validated by years of medical surveillance on the range workers, to include annual lung scans.[313]

3. Apparent Contradictions between Guidance and Wartime Practices.

A comparison of the guidelines outlined in TB 9-1300-278 and actual practices followed during the Gulf War invites criticisms that the Services disregarded regulatory guidance put in place to protect human health and ensure the proper handling of battlefield contamination. While the perception is understandable, the reality is more complex.

Shortcomings in pre-war training and awareness of DU were not effectively remedied by supplemental guidance—mainly warning messages and advisories—that in many cases did not reach tactical units. At the same time, a review of the operative guidance in force at the time of the Gulf War indicates that much of this guidance was in fact excessive and impractical in an operational setting. In particular, the emphasis on donning the MOPP 4 chemical warfare ensemble before working in or near DU-contaminated equipment deserves examination.

MOPP 4 is explicitly associated in most soldiers' minds with protection from Nuclear- Biological -Chemical hazards. "Nuclear" in this sense means fall-out from tactical nuclear detonations, which produce high-order concentrations of primarily gamma radiation, as opposed to DU, which produces mainly alpha particles which are too weak to penetrate the outer layer of skin.

Biological and chemical agents can take the form of gases, vapors, or liquids, necessitating the features found in MOPP 4 gear, i.e.: gas mask with protective hood, charcoal-filled overgarments, and rubber "booties" and gloves. DU, on the other hand, poses a credible hazard only when its oxides, residues, or fragments are internalized in the body via inhalation, ingestion, imbedding, or wound contamination, in sufficient quantity.

Exposure hazards, no matter how slight, require suitable protection under ALARA. The level of protection afforded by MOPP 4 was excessive, in the view of many experts. However, it was mandated largely because every soldier deployed to the Gulf had MOPP 4 gear and knew how to use it. Hence it was a viable, field-expedient means by which to prevent exposures. In addition, suitable alternatives such as surgical masks were often unavailable through normal supply channels.

Another potential inconsistency was the precautions taken by the Radiation Control (RADCON) personnel deployed to the Gulf. Unlike ordinary troops, these personnel were specifically trained and equipped to respond to DU contamination. However, they often elected to work on contaminated systems without such TB 9-1300-278-recommended protection as respirators or dust masks. The reason for this is simple: In their professional judgement, the radiological and chemical toxicity hazard was too low, in these instances, to warrant the wear of respirators or dust masks. This subjective judgement may seem at odds with existing guidance, but the reader should be reminded that guidance is just that—and the RADCON experts felt that they had the experience and expertise to determine the appropriate level of protection.

In short, the operative guidance available at the time of the Gulf War, based on peacetime regulatory requirements, set protection levels that proved to be disproportionate to the actual hazard. Unfortunately, formal guidance that would have satisfied regulatory requirements while more definitively addressing actual requirements had not been developed. Although supplemental guidance was developed and sent to the theater, it was not widely disseminated outside the very small community (mainly RADCON experts) with a specific DU-related mission. Among tactical units, awareness of DU’s characteristics and its potential hazard remained very low, in general. In consequence, many personnel were needlessly exposed to DU during clean up and recovery actions, or other activities.

The deficiencies in Gulf War guidance have been recognized by the Army, which has taken steps to remedy the situation. A meeting was conducted in April 1998 to discuss organizational roles and responsibilities relative to low level radioactive hazards in operational settings. An Integration Process Team (IPT) was formed to review low-level radiation as well as nuclear, biological, and chemical hazards, and associated environmental issues. At the soldier level, the Army has developed a new common training task "Respond to Depleted Uranium /Low-Level Radioactive Materials (DULLRAM) Hazards".

The DULLRAM training task, due to commence in FY99, should produce a dramatic, sustained improvement in troop awareness of DU. It addresses two primary concerns associated with earlier guidance:1) It protects health while recognizing the utility of field-expedient protective measures, and 2) While Gulf War-era guidance was not widely available or circulated outside of the small, specialized units with a radiation control or health physics role, the DULLRAM lesson plan will be universal. Every soldier will receive this training during their initial Army training, with refresher or periodic training held over the course of their military service.

Regarding the first point, the training task offers practical, field-expedient measures to protect soldiers from exposures without imposing excessive personal protection requirements. In contrast to earlier guidance, it advises soldiers to only use protective masks if working in an area where there is heavy smoke from burning vehicles or the dust plume from the impact has not settled.

The DULLRAM is a simple, uniform, and effective lesson plan that explains:

The DULLRAM task lesson plan and training requirement will impress on ordinary soldiers, as well as supervisors and leaders, the importance of recognizing DU contamination as a battlefield hazard, and responding appropriately.[314]

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