The munitions and armor tests and evaluations performed as part of DU's developmental acquisition process acknowledged DU's potential to contaminate battlefields. The Department of Defense (DoD) and Services recognized the need to protect personnel who might have to operate in such environments. The Army based its accident-response procedures for incidents such as tank fires or ammunition explosions that could release DU into the environment on Nuclear Regulatory Commission (NRC) licensing requirements. These requirements established stringent guidelines governing DU munitions and armor storage, handling, and distribution, although the regulatory guidance was extremely restrictive and in some respects poorly suited for operational deployments.

Unfortunately, most guidance issued before and during the war was oriented toward peacetime accidents on US military installations and did not address the very different demands of wartime and contingency operations in austere field conditions. The primary source of this guidance was Technical Bulletin (TB) 9-1300-278, which mandated procedures that in a wartime context often were disproportionate to the actual hazard or impractical. Several memoranda and advisories containing simple, field-expedient precautions and advice were sent to the theater, but these often failed to reach units and personnel responding to accidents and events involving DU contamination.

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 localized DU release. The Army published this Bulletin on November 20, 1987 and revised it in September 1990 -- in time for the Gulf War -- and again in July 1996.

TB 9-1300-278 outlines procedures to respond to and control the hazards resulting from accidents and incidents involving DU. These guidelines address radiological and chemical toxicity hazards, contamination control, and explosive and fire hazards, which usually are present as well. The Army wrote TB 9-1300-278 to satisfy NRC licensing requirements designed to protect workers and the public from radiation during peacetime operations. The Army derived its contamination levels 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," which set limits for returning formerly contaminated facilities (buildings, shops, etc.) to unrestricted public use. In its Radiological Control Manual^[542] the Department of Energy, among other agencies, has adopted similar limits.

The Technical Bulletin instructs crews, firefighters, and explosive ordnance disposal (EOD) and radiation protection personnel on how to respond to peacetime tank fires involving DU munitions and armor with maximum safety while protecting life and property. Sample guidelines (with added OSAGWI comments in italics) include:

• Personnel should remain upwind, if possible, and safety personnel should establish and maintain a safety perimeter of at least 1,200 feet around the involved vehicles and munitions to control access. These are standard initial actions for all incidents involving explosive hazards.
• Responding personnel should take these actions: seal any tank openings (hatches or penetrations) to prevent the spread of DU contaminants inside the hull; remove the tank; survey and decontaminate the ground around the tank as needed. No attempt should be made to decontaminate the tank's interior. These guidelines are intended to control and contain contamination, minimize exposure, and return surrounding surfaces to their pre-accident state as a matter of prudence.
• Only EOD personnel should enter the tank to ensure no explosive hazard is present. Only EOD personnel are qualified to render "safe" and remove explosive hazards, e.g. rounds remaining from on-board ammunition stores.
• EOD personnel should dress in protective coveralls, gloves, rubberized boots and protective mask (i.e. Mission Oriented Protective Posture [MOPP] Level 4), with all exposed openings taped. Like all US troops in the Gulf Theater, EOD troops deployed with MOPP 4 gear, making it the logical choice for personal protection. EOD troops, who were trained to operate in a DU-contaminated environment, generally chose not to follow these guidelines, as they would have severely hampered their physical activities and quite possibly, jeopardized their safety.

These and other US Army Armament, Munitions, and Chemical Command (AMCCOM) guidelines serve several purposes:

• Satisfy NRC license requirements.
• Protect soldiers and the public from radiological exposure to comply with ALARA (as low as reasonably achievable).
• Make sure responding personnel properly assess, control, and clean up any incident.

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, later reported they were not aware of TB 9-1300-278's specific contents or even of its existence.^[543] In addition, a 1993 General Accounting Office (GAO) report found TB 9-1300-278 was not widely available in late 1990 or 1991.^[544] However, according to a former US Army major serving with the AMCCOM at King Khalid Military City (KKMC), the manual was available at the time of the December 1990 tank fire in Saudi Arabia.^[545] In any event, the TB 9-1300-278 guidelines were largely unknown outside a few specialized teams [radiation control team (RADCON) responders, battle damage assessment teams (BDAT)] deployed to the Gulf.

DoD has acknowledged that pre-war DU awareness training was inadequate. Abrams tank crews received limited training on the peacetime, regulatory requirements for handling DU munitions. The Army trained nuclear-biological-chemical (NBC) personnel assigned to most units, and explosive ordnance disposal (EOD), RADCON, and safety personnel more extensively.^[546] Generally, these units or agencies did not share their knowledge with other units or personnel. AMCCOM, at least, identified the lack of DU awareness as a deficiency in a May 24, 1991, memorandum to the Army's Training and Doctrine Command (TRADOC) recommending that DU safety training be provided to all armor and infantry soldiers and officers who required it.^[547]

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

Examples of supplemental DU guidance during the Gulf deployment include:

• A February 1991 message to Army Central Command (ARCENT) described proper procedures to safely segregate and handle tanks posing a radiological hazard after their DU armor or munitions were involved in a fire. These precautions primarily were based on NRC's stringent peacetime DU contamination handling and disposal requirements. Each unit was to segregate, inspect, encapsulate, and tag equipment presenting a radiological risk before shipping it back to the US to satisfy peacetime radioactive material control requirements. Access to the contaminated equipment was to be limited to prevent the spread of contamination.^[548]
• A March 3, 1991 memorandum to the theater recommended that when exiting a contaminated vehicle, personnel should leave the clothing and gloves they wore inside and wash their hands. The memorandum also advised against eating or smoking inside a contaminated vehicle to decrease the probability of ingesting DU.^[549]
• On March 7, ARCENT sent a message advising, "Any system struck by a DU penetrator can be assumed to be contaminated with DU."^[550]
• As late as April 7, 1991, the AMCCOM team at KKMC requested advice from its higher headquarters on examination and monitoring requirements for crews of vehicles hit by DU penetrators.^[551] In reply, an April 11, 1991, memorandum stated the local Radiation Protection Officer (RPO) or medical authority must determine if and when a medical examination or bioassay was required as stated in Army Regulation 40-5. This same memorandum stated if "a vehicle is hit by a DU penetrator the likelihood that a crew member would receive an excessive dose of radiation is minimal." In the case of a tank fire or DU penetration, Headquarters expected the crew would have abandoned the vehicle before receiving an excessive dose.^[552]

These messages were aimed at ensuring personnel adhered to the ALARA principle of "as low as reasonably achievable" to minimize potential exposures. Some guidance to selected groups was less restrictive. The Army instructed the BDAT, who evaluated destroyed US combat vehicles, to wear anti-contamination suits (cotton over-garments) and dust masks,^[553] the same protective posture range personnel used at Aberdeen Test Center (ATC), where several BDAT members worked before the war. ATC developed this guidance for range workers working with hard-target impact testing; years of medical surveillance on the range workers, including annual lung scans, have validated these guidelines.^[554]

Comparing TB 9-1300-278's guidelines to the actual practices followed during the Gulf War invites criticism that the Services disregarded regulatory guidance to protect human health and ensure proper battlefield contamination response. While the perception is understandable, the reality is more complex.

Supplemental guidance -- mainly warnings and advisories -- that in many cases did not reach tactical units did not effectively remedy shortcomings in pre-war DU training and awareness. At the same time, a review of the operative guidance effective during the Gulf War indicates much of this guidance in fact was 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.

In most soldiers' minds MOPP 4 is explicitly associated with protection from nuclear-biological-chemical hazards. Biological and chemical agents can take the form of gases, vapors, liquids, or aerosols necessitating MOPP 4 gear (e.g., gas mask with protective hood, charcoal-filled over-garments, rubber "booties" and gloves). In this application "nuclear" means fall-out from tactical nuclear detonations, which produce high levels of primarily gamma radiation, in contrast to DU, which produces mainly alpha particles too weak to penetrate the outer layer of skin.

Under ALARA, efforts should be made to reduce exposure. In the Gulf setting, however, the available personnel protective equipment was essentially limited to standard-issue MOPP gear. MOPP gear (especially MOPP 4) was designed to counter acute, deadly chemical and biological warfare agents, and as such was less than ideal for countering industrial toxins such as DU. While it did offer protection (particularly against inhaled or ingested DU particles) these benefits were offset by significant drawbacks, including a rapid degradation in the wearer's:

• situational awareness (due to reduced vision, impaired hearing, speech recognition and communication);
• performance (more susceptible to fatigue, dehydration, and heat injuries); and
• ability to safely and effectively perform essential tasks and missions, e.g. avoiding or defusing unexploded ordnance.

However, wearing MOPP 4 was mandated largely because every soldier deployed to the Gulf had MOPP gear and had been trained to use it, and the supply channels did not have the capability or requirement to stock industrial hygiene personal protective equipment for general issue or use; nor were personnel trained to use it. Hence, MOPP gear offered a viable, field-expedient means by which to prevent exposures (the more so since suitable alternatives, e.g., surgical masks, were often unavailable through normal supply channels).

The Radiation Control (RADCON) personnel deployed to the Gulf demonstrated another potential inconsistency in their precautions. Unlike ordinary soldiers, these personnel were specifically trained and equipped to respond to DU contamination. However, they often elected to work on contaminated vehicles without such TB 9-1300-278-recommended protection as respirators or dust masks because in their professional judgement, the radiological and chemical toxicity hazard was too low in these instances to warrant wearing respirators or dust masks. The RADCON experts' subjective judgement and actual measurements of the radiological hazards may seem to contradict existing guidance, but the RADCON personnel believed they had the experience and expertise to determine the appropriate protective level.

In short, the Gulf War's operative guidance, based as it was on peacetime regulatory requirements, set protective levels that proved disproportionate to the actual hazard. Unfortunately, DoD had not developed formal guidance that would have satisfied regulatory requirements while more definitively addressing actual requirements. Although DoD developed and sent supplemental guidance to the theater, the recipients did not widely disseminate this guidance beyond the very small community, mainly RADCON experts, with a specific DU-related mission. Among tactical units, awareness of DU's characteristics and its potential hazards generally remained very low. Consequently, many personnel were exposed to DU during clean-up and recovery actions or other activities.

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