This report considered the health and environmental effects of the use of DU within the U.S. Army. Overall, the Army has done an excellent job of producing and fielding weapon systems that contain DU. The data gathered during this study clearly indicate that, from the onset of DU weapons research, the Department of the Army recognized its responsibility to seek ways to reduce risks. To this end, the Army complies with established statutes, regulations, and procedures.

Before the Army developed and fielded DU munitions and armor, it conducted extensive tests and repeated reviews to ensure that the items would be combat-effective and safe to use. It also continuously considered health and environmental challenges during development, testing and fielding of weapon systems containing DU.

Moreover, a commitment is embedded across DU weapon programs to minimize exposure of Army personnel, the public, and the environment to the potential hazards of DU. The Army's military and civilian employees manage chemical and radiological environmental hazards. These dedicated professionals daily demonstrate the Army's commitment to meeting DU environmental, safety and health criteria. Furthermore, as a result of discussions during this investigation, the Army has initiated and expanded several efforts to improve the management of DU health and environmental issues.

Nevertheless, AEPI identified several DU-related areas that require further attention. A few of these areas are potential weaknesses in Army programs, but most are ways to enhance current practices and procedures. The findings and conclusions identified herein are not intended to criticize those who have been responsible for managing DU. Instead, the options presented describe efforts to attain an even higher level of health and environmental security. AEPI believes these candidate options will further enhance a DU program that is already well-reasoned.

The Institute's findings presented below address the four areas of concern that Congress expressed in Senate Appropriations Committee Report Number 102-408. The findings are followed by major conclusions that address DU environmental safety and health issues.

8.1Ý Findings

The findings presented below address the four areas of concern that the Office of the Assistant Secretary of the Army (OASA) Installation, Logistics and Environment (IL&E) tasked AEPI to study in response to the Senate Appropriations Committee report:

• A battlefield may be contaminated with many dangerous things. The impact of DU contamination on the battlefield is a new issue and is not well-defined. Relative to many other hazards, such as unexploded ordnance, the hazards from DU contamination are probably small; however, additional environmental modeling and data are needed to support this judgment.

• DU remediation technologies involve one or more of the following processes: excavation and earth moving, physical separation, chemical separation, and in-place stabilization. Very few remediation technologies have actually been used to clean up DU-contaminated sites. The Army continues to identify and evaluate alternative remediation technologies.

• No available technologies can significantly change the inherent chemical and radiological toxicity of DU. These characteristics are fundamental to the element uranium.

• The Army has implemented range management and DU recovery systems and is improving these systems. The Army is also developing models to better describe the environmental fate and effects of DU. DU migration on test ranges in the United States appears to be insignificant because the soil and water conditions on the ranges tend to prevent formation of soluble DU.

8.2.1ÝÝÝÝÝ General Conclusions

DU Management Office

The Army or DoD should designate a single office, independent of DU systems development or use, to improve management and control of DU health, environmental, and regulatory issues.

An independent organization overseeing DU use in the Army could improve the coordination between acquisition, use, demilitarization and remediation activities. This DU management office, functioning as the principal expert, could:

• Assure compliance with applicable laws and regulations.

• Consolidate the Army's current 14 Nuclear Regulatory Commission, non-medical DU systems licenses into a single license. This single license would alleviate present monitoring, equipment, and operational inconsistencies.

• Establish a mechanism for scientific peer review of all DU health and environmental testing and research programs.

• Serve as a focal point and repository for all information on the health and environmental effects of DU.

• Design, coordinate, and evaluate health and environmental research programs.

• Assure that weapon testing programs include acquisition of well-reasoned environmental safety and health data.

The Army should revise its regulations and policy documents to explicitly link the acquisition, use, safety and health, disposal, demilitarization, and environmental management of DU. This could serve as a model for a DoD system.

Current regulations and policy documents adequately express the environmental, system safety and health hazard assessment issues associated with weapon systems during specific phases of their life cycles. However, no explicit cross-references exist between the policies of each regulation. Adequate cross-references would ensure that those responsible for acquiring a system would be exposed to the environmental regulations and would become familiar with environmental aspects of the ultimate demilitarization and disposal of the system. Specifically, demilitarization and disposal experts would know what to expect when accepting an obsolete system containing DU.

Analyze Life-Cycle Costs

The Army should determine the full life-cycle cost of DU weapon systems. This analysis must take into account not only production costs, but also demilitarization, disposal and recycling costs; facility decontamination costs; test-range remediation costs; and long-term health and environmental costs. Specifically, the Army should:

• Recommend changes to the DODM 5000 series to help the services focus on the ultimate financial impact of DU weapon systems over their life cycles.

• Recommend changes to the FAR to require that all contracts for weapon systems containing DU include the full cost of environmental control and cleanup of equipment and facilities contaminated during execution of the contract.

• Require that acquisition methodologies for alternative materials to replace DU include detailed analyses of their life-cycle environmental and health risks. These materials should be evaluated on the basis of unbiased estimates of the health and environmental risks (chemical and radioactive) and full life-cycle costs.

• Require that PMs use independent, expert peer review of proposals, data and reports on the health and environmental effects of DU systems. This would make it easier to better estimate full life-cycle costs for weapon systems.

• ÝModify laws and regulations that preclude escrow of funds to pay for future test range remediation costs. Currently, weapon system RDT&E projects cannot be charged for environmental remediation costs accrued by developers and PMs. This artifact obviates the life-cycle environmental management mandates in AR 200-2.

An Environmental Assessment is normally used to assess the incremental impact of systems at a specific site; however, within the DoD's acquisition process, an EA can also be item-specific (pertaining to a specific weapon system). Use of the same term for two entirely different types of assessments could lead to an inappropriate conclusion that the requisite environmental documentation has been prepared.

The Army does not publish EAs in media serving each site. This often leads to a perception of avoidance and deception in local communities. The Army could resolve this by aggressively seeking local comment on EA documents at all levels through local and national media.

8.2.2ÝÝÝ Test Ranges and Battlefields

Expand Training

The Army should continue to improve training programs for the wide variety of soldiers and support personnel who may come into contact with DU or DU-contaminated equipment. At a minimum, the Army should include armor, infantry, engineer, ordnance, transportation and medical personnel in this training. Specifically:

• Soldiers need additional training on the hazards and management of DU armor and ammunition.

• Soldiers need training on the hazards of DU, on the methods to detect DU, and on the protection and decontamination measures that can be used in the field.

• The Army needs to revise manuals for weapon systems that contain DU components so the documents clearly identify DU components and their potential hazards.

• Managers throughout the Army weapon system community (acquisition, field and demilitarization) need more training on health and environmental issues that may become important over the life cycle of weapon systems containing DU. The Army needs to audit environmental training programs for these managers. Data from this audit would provide a framework to expand or modify training programs to ensure adequate coverage of environmental safety and health issues.

• Medical personnel need to understand the radiological and toxicological properties of DU and the medical procedures required to treat patients with internal DU exposure.

Assess Medical Surveillance

The Army Surgeon General evaluates all Army weapon systems to ensure that potential health effects are satisfactorily mitigated before fielding. During combat operations, however, new health-related issues may emerge. For example, before Desert Storm the probability of human survival in a vehicle hit by a DU penetrator was estimated to be quite low; however, the actual survival rate for U.S. soldiers in vehicles that sustained friendly fire DU strikes was more than 80 percent among Bradley crews and more than 90 percent among Abrams crews.

For this reason, in future conflicts where DU weapons are used by either side, the Army should anticipate managing patients with DU-contaminated wounds. The Army Surgeon General should review its standard field medical procedures to ensure they are adequate to treat DU-contaminated battle wounds. Medical risks from DU to the patient and the health care provider, however, must be kept in perspective when treating trauma wounds.

To manage potential health impacts from the use of DU weapon systems, the Army Surgeon General should:

• Continue to identify veterans who may have been exposed to battlefield DU. Use the resulting data to develop a protocol to assess the extent of their exposure and manage their care.

• Develop a formalized standard procedure to identify and manage DU contamination during medical procedures. Medical personnel should use radiation detection instruments to help locate and remove DU contamination from patients and the treatment facility.

• Train medical personnel to manage DU-related health risks.

• Develop protocols for managing DU fragments, wound decontamination, and inhalation exposure.

• Develop or define procedures to measure the amount of DU internalized.

• Continue evaluating and monitoring veterans wounded by DU fragments.

• Continue to support research to determine the long-term consequences of embedded DU fragments. Continue follow-up efforts if warranted by the data generated from the Desert Storm soldiers currently under treatment or observation.

• Develop models to estimate the radiological and toxicological consequences of DU internalized as a result of inhalation, wound contamination, or embedded fragments.

• Continue to identify Desert Storm personnel who were involved in DU friendly fire incidents but were apparently not injured. This process will aid in documenting exposure levels and will provide valuable data on the inhalation potential of aerosols containing DU.

The Army should continue to investigate equipment modifications and procedures that will minimize exposure to the chemical and radiological hazards of DU. Specific projects should include:

• Develop a combat-oriented document, similar to TB 9-1300-278, that would define protective techniques for personnel dealing with vehicles potentially contaminated with DU. The new guidance must consider the trade-off between DU risks and combat risks. This trade-off should be a sliding scale because risk from combat decreases as a damaged vehicle is recovered from the active fire zone and returned to rear areas for maintenance or salvage.

• Develop standardized markings for all weapon systems containing DU. Current markings on Army items containing DU are inconsistent and sometimes misleading. Use of euphemisms, such as ìstaballoy,î should be eliminated.

• Inhalation presents a pathway for DU internalization for recovery and maintenance personnel who work in and around contaminated vehicles. The Army needs to conduct further experiments and analysis to better define these risks. Dataóincluding particle size, concentration, density, and oxidation stateóare required to evaluate re-suspension and inhalation potential. These data are also necessary to determine the protective measures that could protect personnel in future operations.

• Characterize the magnitude of DU contamination in gun tubes and equipment used to ventilate gun tubes after firing. Determine the potential for crew compartment contamination from gun bore gases or flashback incidents.

Army environmental policy goals must support the Army mission, contribute to readiness, and serve the collective national best interests. In recent years, Congress has substantially increased the breadth and depth of requirements that drive Army environmental policy. The conclusions presented below reflect candidate policy options the Army could invest in to improve environmental management of DU weapon systems. InvestmentÝ in all Army policies is tempered by the distribution of resources among competing needs.

Environmental Documentation

Army regulations implementing NEPA require program managers to generate and maintain life-cycle environmental documentation for weapon systems. Army policy also requires NEPA documentation for all NRC license applications. The Army should review all current environmental documentation on DU and consider preparing a programmatic LCED. If supported by the LCED, the Army should explore the need for preparing a comprehensive PEIS that considers all DU weapon systems.

DU Waste Disposal

The Low-Level Radioactive Waste Policy Act and Nuclear Regulatory Commission regulations control DU disposal. The act allows states to create regional compacts for low-level radioactive waste disposal. Compact restrictions regulating the amount of low-level waste that can be sent to regional waste sites could force weapon test sites to retain excess DU waste material. When the amount of DU waste at a test site approaches NRC license limitations, the Army will be forced to either suspend testing or violate the NRC license. The Army should encourage Congress to consider a system that allocates waste according to the value added in each phase of development, testing and fielding a DU weapon system. Under this approach, a proportional share of the waste generated during testing would be charged against the waste disposal capacities of the states that receive economic benefit from the process.

Under the current regulatory framework, the following policy options should be considered:

• Continue to aggressively participate in low-level waste compacts to ensure adequate capacity at both state and regional levels.

• Provide funding to support the current and projected waste disposal requirement at Army testing centers. Capacities for DU storage, recovery, recycling and disposal at Army test centers are inadequate for current and projected demand.

• Develop a viable program for the demilitarization of unspent R&D ammunition. Currently, unspent R&D ammunition containing DU is counted against the NRC radioactive material budget for Army testing centers. When testing is complete, the remaining ammunition permanently reduces the radioactive material budget at the test centers.

• Develop waste disposal options, including volume reduction, waste minimization, waste form modification, and waste disposal facilities.

The only systematic DU contamination of Army land occurs during the RDT&E cycle for DU ammunition. The following techniques could help the Army better manage DU contamination of test ranges:

• Plan site-remediation activities on Army installations to be consistent with long-term land-use goals. Consider the environmental impacts of remediation options when determining future land use.

• Develop a strategy to address the long-term liabilities from DU contamination on test ranges and perhaps on battlefields. This may require examining information on the early research and testing of weapons containing DU.

• Separate high-explosive ranges from new DU ranges so that DU recovery efforts will not be complicated by unexploded ordnance.

• Require catch boxes on all DU ranges because the boxes reduce the amount of DU available to migrate, contaminate, or expose ecosystems. The expense of periodically remediating contaminated sand to recover DU in catch boxes will increase the cost of testing DU penetrators. However, remediating a catch box is cheaper in the long term than remediating thousands of acres of a DU-contaminated test range.

• Maximize recovery of DU penetrators at test ranges.

• Maximize DU recycling within the Army. Recovering and reusing DU may reduce long-term liabilities for disposal and remediation. Efforts to recycle DU materials and to generate markets for these materials should be continued; however, the Army should recognize that DU testing will always produce wastes.

• Provide a means to ensure timely disposal of DU waste from test ranges.

Environmentally and financially sound remediation of DU contamination on Army test ranges requires an understanding of the fate and effects of DU. Therefore, site assessments, application of fate and effect models, and estimation of environmental risks and costs are all prerequisites to test range closure. A DU-contaminated range with DU cannot be efficiently remediated without a comprehensive contaminant survey and a risk assessment. These are not possible without well-crafted transport models that can predict DU migration and transformation. Many of the protocols and models required to construct DU models have been developed for application to other waste materials. However, a substantial effort is needed to adapt information to DU migration on Army test ranges. The adapted models would allow the Army to achieve a long-term, comprehensive, environmentally astute DU remediation program for test ranges.

Some of the immediate requirements are described below:

• Fund site investigations, research into remediation technologies and remediation activities.

• Evaluate the effectiveness and cost of remediation technologies (proposed and existing). Define the research requirements necessary to support the development of promising remediation technologies.

• Develop theoretical models that can be used to plan the most cost-effective experiments.

• Evaluate the environmental fate and effects of DU on U.S. test ranges. A better understanding of DU contamination at test ranges could produce data and models transferable to other sites, including battlefields.

• Review environmental and health hazard data obtained to date to ensure that they are consistent and scientifically defensible.

• Review DU-particle data from Army studies and elsewhere to determine data gaps.

• Develop and conduct experiments to generate the requisite data to fill these gaps. Data on DU-chemical species, mass-mean size, surface-mean size, size distribution, specific gravity by species and particle shape are required to support transport and risk models.

• Develop a better understanding of DU particles generated in fires or from hard-target or soft-target impacts.

• Develop environmental fate and effect models to determine relative risk as a function of migration. These models should be robust enough to provide defensible estimates of the air, surface water, groundwater, and soil migration of DU on test ranges and other contaminated sites.

• Apply data and models that were developed to determine the risks and costs associated with remediating areas contaminated by DU. Developers and PMs could use this data to estimate remediation costs in life-cycle cost analyses for weapon systems containing DU.

• Recognize that data base sampling costs would be inversely proportional to the environmental concentration of DU. Thus, highly contaminated analogs might provide particularly cost-efficient test beds for developing an environmental migration model. The Desert Storm battlefields may also offer some opportunities as analogs for environmental migration.

Remediation of battlefields is not historically the responsibility of the victor. This task typically belongs to the indigenous population. However, it may be appropriate for the Army to be prepared to provide guidance to other governments on the health and safety risks associated with DU for affected battlefields. It may also be appropriate to provide information on environmental measurement, monitoring, migration, and remediation techniques. From this perspective the Army is considering the following actions:

• Defining methods, including the salvage and use of maintenance and repair records to better characterize DU contamination in battlefield areas.

• Evaluating the forms of DU that are present and their transport characteristics under the soil/climate conditions in Southwest Asia. Most DU ammunition expended in Desert Storm was used on practice ranges. These firing sites are ideal for gathering data that could be used to verify theories on DU's environmental behavior. These sites also could provide valuable information for calibrating a risk/cost model.

• Evaluating fire and battle sites in Southwest Asia. These sites may provide valuable data to help develop accurate environmental models. Characterizing these sites may provide evidence of the environmental impact of DU on the battlefield.

Actions to implement the policies suggested by the findings and conclusions in this report should be weighed against the costs associated with the environmental safety and health issues presented. Decisions must be framed to ensure that the studies have the potential to mitigate the real costs of remediation and health management as related to Army DU-weapon systems.