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Exposure Cannot Be Adequately Supported' which was released on June 01, 
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Report to Congressional Requesters:

United States General Accounting Office:

GAO:

June 2004:

Gulf War Illnesses:

DOD's Conclusions about U.S. Troops' Exposure Cannot Be Adequately 
Supported:

GAO-04-159:

GAO Highlights:

Highlights of GAO-04-159, a report to Congressional Requesters 

Why GAO Did This Study:

Since the end of the Gulf War in 1991, many of the approximately 
700,000 U.S. veterans have experienced undiagnosed illnesses. They 
attribute these illnesses to exposure to chemical warfare (CW) agents 
in plumesclouds released from bombing of Iraqi sites. But in 2000, the 
Department of Defense (DOD) estimated that of the 700,000 veterans, 
101,752 troops were potentially exposed. GAO was asked to evaluate the 
validity of DOD, Department of Veterans Affairs (VA), and British 
Ministry of Defense (MOD) conclusions about troops exposure.

What GAO Found:

DODs and MODs conclusions about troops exposure to CW agents, based 
on DOD and CIA plume modeling, cannot be adequately supported. The 
models were not fully developed for analyzing long-range dispersion of 
CW agents as an environmental hazard. The modeling assumptions as to 
source term dataquantity and purity of the agentwere inaccurate 
because they were uncertain, incomplete, and nonvalidated. 

The plume heights used in the modeling were underestimated, and so were 
the hazard areas. Postwar field testing used to estimate the source 
term did not realistically simulate the actual conditions of bombings 
or demolitions. Finally, the results of all modelsDOD and non-DOD 
modelsshowed wide divergences as to plume size and path. 

DODs and VAs conclusions about no association between exposure to CW 
agents and rates of hospitalization and mortality, based on two 
epidemiological studies conducted and funded by DOD and VA, also cannot 
be adequately supported because of study weaknesses. In both studies, 
flawed criteriaDODs plume model and DODs estimation of potentially 
exposed troops based on this modelwere used to determine exposure. 
This may have resulted in large-scale misclassification. 

Troops under the path of the plume were classified as exposed; those 
not under the path, as not exposed. But troops classified as not 
exposed under one DOD model could be classified as exposed under 
another DOD model. Under non-DOD models, however, a larger number of 
troops could be classified as exposed. Finally, as an outcome measure, 
hospitalization rate failed to capture the types of chronic illnesses 
that Gulf War veterans report but that typically do not lead to 
hospitalization 

The Plume-Modeling Process: 

[See PDF for image]

[End of figure]

What GAO Recommends:

GAO recommends that the Secretary of Defense and the Secretary of 
Veterans Affairs not use the plume-modeling data for any other 
epidemiological studies of the 1991 Gulf War, since VA and DOD cannot 
know from the flawed plume modeling who was and who was not exposed. VA 
concurred with GAOs recommendation, but DOD did not concur. 

GAO also recommends that the Secretary of Defense require no additional 
plume modeling of Khamisiyah and other sites. DOD concurred with GAOs 
recommendation. 

The Central Intelligence (CIA) did not concur with the report, stating 
that it could not complete its review of the draft report in the time 
allotted.

www.gao.gov/cgi-bin/getrpt?GAO-04-159.

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Keith Rhodes at (202) 
512-6412 or rhodesk@gao.gov.

[End of section]

Contents:

Letter:

Scope and Methodology:

Results in Brief:

Background:

Modeling the Environmental and Health Effects of Fallout from CW 
Agents:

DOD's Conclusion about U.S. Troops' Exposure to CW Agents Cannot Be 
Adequately Supported:

Major Unresolved Issues Concerning Modeling:

DOD's Modeling Efforts Were Flawed:

The MOD Relied on U.S. Plume Modeling to Determine Its Troops' 
Exposure to CW Agents:

Total U.S. Plume-Modeling Costs:

DOD's and VA's Epidemiological Conclusions on CW Exposure and 
Hospitalization and Mortality Rates Cannot Be Adequately Supported:

Conclusions:

Recommendations for Executive Action:

Agency Comments and Our Evaluation:

Appendix I: DOD's Chronology of Khamisiyah Modeling Events:

Appendix II: Power-Law Formula:

Appendix III: DOD's Model Divergences:

Appendix IV: Divergence and Wind Field Models:

Appendix V: Comments from the Department of Veterans Affairs:

Appendix VI: Comments from the Department of Defense:

GAO Comments:

Appendix VII: Comments from the Central Intelligence Agency:

Tables:

Table 1: The Meteorological and Dispersion Models DOD Used to Model 
Khamisiyah:

Table 2: Gulf War Suspected Chemical Weapon Sites:

Table 3: Detector and Agent Identification Systems Deployed by 
Coalition Forces Reporting the Detection of CW Agents:

Table 4: Principal Reported Detections of Chemical Agents in Saudi 
Arabia, January 17-23, 1991:

Table 5: U.S. Direct Costs for Modeling Gulf War Illnesses:

Figures:

Figure 1: Timeline of Events Following the U.S. Demolition of CW Agents 
at Khamisiyah, 1991-2000:

Figure 2: The Plume-Modeling Process:

Figure 3: NOAA-11 Meteorological Imagery of Areas Occupied by Coalition 
Forces, January 18-24, 1991:

Figure 4: Meteorological Satellite Photography, Iraq, January 19, 1991:

Figure 5: Plume Height Trend Line by Weight of Explosive:

Figure 6: Boundary Layer Characteristics:

Figure 7: Three Types of Plume Geometry:

Figure 8: The Impact of Nocturnal Jets on a Plume at Higher Altitudes:

Figure 9: Lawrence Livermore National Laboratory Projection:

Figure 10: DOD Composite Projection:

Figure 11: DOD Composite Projection and Lawrence Livermore National 
Laboratory Projection:

Figure 12: Validation Runs of Various Models:

Figure 13: Divergence in Models Used to Construct DOD and CIA Composite 
Analyses:

Figure 14: Divergence in DOD Muhammadiyat Models:

Figure 15: Lawrence Livermore National Laboratory Diagnostic Wind 
Model, Based on Observational Data:

Figure 16: Lawrence Livermore National Laboratory Diagnostic Wind 
Model, Based on ECMWF Projections:

Figure 17: Wind Field Vector Model, Based on COAMPS:

Abbreviations:

ADPIC: Atmospheric Dispersion by Particle-in-Cell: 
AFTAC: Air Force Technical Applications Center:
BSS: body-system symptom:
CAPS: Clinician Administered Posttraumatic Stress: 
CDC: Centers for Disease Control and Prevention:
CES: Combat Exposure Scale: 
CIA: Central Intelligence Agency: 
COAMPS: Coupled Ocean-Atmosphere-Mesoscale Prediction System: 
CW: chemical warfare: 
DIA: Defense Intelligence Agency: 
DMDC: Defense Manpower Data Center: 
DOD: Department of Defense: 
DOE: Department of Energy: 
DTRA: Defense Threat Reduction Agency:
GDAS: Global Data Assimilation System: 
HPAC: Hazard Prediction and Assessment Capability: 
IDA: Institute for Defense Analyses: 
LLNL: Lawrence Livermore National Laboratory: 
MM5: Mesoscale Model Version 5: 
MOD: Ministry of Defense: 
NOAA: National Oceanic and Atmospheric Administration:
NOGAPS: Naval Operational Global Atmospheric Prediction System:
NUSSE: Non-Uniform Simple Surface Evaporation: 
OMEGA: Operational Multiscale Environmental Model with Grid Adaptivity: 
PON: paraoxonase/arylesterase enzyme: 
PTSD: Post-Traumatic Stress Disorder:
RAMS: Regional Atmospheric Modeling System: 
SAIC: Science Applications International Corporation: 
SCIPUFF: Second-order Closure Integrated Puff 
UNMOVIC: United Nations Monitoring, Verification, and Inspection 
Commission: UNSCOM: United Nations Special Commission: 
VA: Department of Veterans Affairs: 
VLSTRACK: Vapor, Liquid, and Solid Tracking: 
WMO: World Meteorological Organization:

United States General Accounting Office:

Washington, DC 20548:

June 1, 2004:

The Honorable Robert C. Byrd: 
Ranking Minority Member: 
Committee on Appropriations: 
United States Senate:

The Honorable Christopher Shays: 
Chairman: 
Subcommittee on National Security, Emerging Threats, and International 
Relations: 
Committee on Government Reform: 
House of Representatives:

Many of the approximately 700,000 U.S. veterans of the Gulf War have 
experienced undiagnosed illnesses since the war's end in 1991. Some 
veterans fear they are suffering from chronic disabling conditions 
because of exposure to chemical warfare (CW) agents, as well as 
vaccines, pesticides, and other hazardous substances with known or 
suspected adverse health effects. They believe that their exposure may 
have been caused by the Coalition forces' bombing of several sites in 
Iraq, including storage and production facilities for nuclear, 
biological, or chemical warfare agents. DOD's estimates based on 
available bomb damage assessment during the war are that 16 of the 21 
sites that were bombed were destroyed. Many U.S. and British troops 
were located near some of these sites. In addition, in March 1991, 
after the end of the war, U.S. troops conducted large-scale demolition 
operations to destroy munitions and facilities at Khamisiyah, a 
forward-deployed site in Iraq. These munitions were later found to have 
been filled with CW agents.

When the possible exposure of U.S. troops to low levels of CW agents 
first became an issue, during summer 1993, the Department of Defense 
(DOD) and the Central Intelligence Agency (CIA) concluded that no 
troops had been exposed because (1) there were no forward-deployed CW 
agent munitions and (2) plumes--clouds of CW agents released from the 
bombing that destroyed the chemical facilities--could not have reached 
the troops.

This conclusion was maintained until June 1996, when DOD publicly 
acknowledged that U.S. troops had destroyed stockpiles of chemical 
munitions at Khamisiyah after the war. Khamisiyah was a large 
ammunition storage depot that contained nearly 100 ammunition storage 
bunkers covering 25 sq km. Earlier, in October 1991, United Nations 
Special Commission (UNSCOM) inspectors had found evidence of munitions 
containing CW agents at Khamisiyah. Specifically, among the nearly 100 
bunkers at Khamisiyah, remnants of 122 mm rockets were identified at 
Bunker 73. The rockets were found to have been filled with a 
combination of sarin and cyclosarin nerve agents. Several hundred 122 
mm rockets containing the same nerve agents were also found at a pit 
area close to Bunker 73. It was not until 1996 that UNSCOM conclusively 
determined that CW agents were in Bunker 73.

Since DOD's 1996 recognition that the bombing and demolition of Iraqi 
facilities during the war did result in the release of plumes, DOD has 
conducted numerous investigations, studies, and analyses based on 
computer modeling. DOD has sought to determine the potential hazard 
area--the path of the plume--and the U.S. troops who may have been 
exposed to contamination from the bombing and demolition of storage 
facilities containing CW agents (see appendix. I).[Footnote 1] In June 
1996, DOD estimated that 300 to 400 U.S. troops participated in the 
demolition of Khamisiyah Bunker 73. In August 1996, the CIA, from the 
results of its computer modeling, stated that around Khamisiyah, an 
area as large as 25 km downwind and 8 km wide could have been 
contaminated.[Footnote 2]

In September 1996, DOD estimated that 5,000 troops had been within a 25 
km radius of Khamisiyah. In October 1996, DOD extended this radius to 
50 km: It estimated that 20,000 U.S. troops had been within this zone. 
In July 1997, from the first plume analyses, DOD estimated that 98,910 
U.S. troops had potentially been exposed. In 2000, additional analyses 
led DOD to reestimate that 101,752 U.S. troops had potentially been 
exposed.

In response to your request, we evaluated how well conclusions--about 
the extent of exposure of U.S. troops and the association between CW 
exposure and troops' hospitalization and mortality rates--are supported 
by available evidence. We presented our preliminary results to you in 
our testimony in June 2003.[Footnote 3] In this report, we present our 
final results. Specifically, we have assessed the following:

1. How valid is the DOD and British Ministry of Defense (MOD) 
conclusion--based on CIA and DOD plume-modeling results--about U.S. and 
British troops' exposure to CW agents?

2. What were the total costs for the CIA's and DOD's various plume-
modeling efforts?

3. How valid are the DOD and Department of Veterans Affairs (VA) 
conclusions from epidemiological studies, based on DOD's plume-modeling 
results, that there was no association between CW exposure at 
Khamisiyah and the troops' hospitalization and mortality rates?

Scope and Methodology:

To determine the validity of DOD's conclusion, based on its plume-
modeling analysis, that U.S. troops' exposure to CW agents was as low 
as it said it was, we examined the meteorological and dispersion models 
DOD used to model chemical agent releases from the U.S. demolition of 
Khamisiyah and Coalition bombings of Al Muthanna and Muhammadiyat in 
Iraq during the Gulf War. We evaluated the basis for technical and 
operational assumptions DOD made in the models and the specific data 
and information on source term, meteorological conditions, and other 
key parameters used for modeling chemical releases from Iraqi sites. We 
also evaluated the efforts of the CIA and DOD to collect and develop 
data on source term and other key parameters for the modeling.

We interviewed DOD and CIA modelers and officials involved with the 
modeling and obtained documents and reports from DOD's Deployment 
Health Support Directorate. We also interviewed and received documents 
from Department of Energy (DOE) officials who were involved with the 
modeling at DOE's Lawrence Livermore National Laboratory (LLNL). In 
addition, we interviewed officials and obtained documents from the:

* Institute for Defense Analyses (IDA) concerning the IDA expert panel 
assessment of CIA's modeling of Khamisiyah,

* U.S. Army Dugway Proving Ground in Utah to determine how CW agents in 
Iraq's rockets might have been released during the Khamisiyah pit area 
demolitions,

* U.S. Army Center for Health Promotion and Preventive Medicine to 
determine how specific troop unit exposures were identified, and:

* United Nations Monitoring, Verification, and Inspection Commission 
(UNMOVIC) to obtain information on source term from UNSCOM's analyses 
and investigations on Khamisiyah, Al Muthanna, and Muhammidiyat.

To determine the validity of DOD's and VA's conclusions--based on 
epidemiological studies--that there was no association between 
Khamisiyah exposure and the rates of hospitalization or mortality, we 
reviewed published epidemiological studies in which hospitalization and 
mortality among exposed and nonexposed U.S. troops were analyzed. We 
also interviewed the study authors and researchers involved with the 
studies and examined the Gulf War Khamisiyah population databases DOD 
provided in support of these studies. We interviewed Veterans Benefits 
Administration officials and obtained documents and reports on their 
analysis of DOD's population databases. We did not examine whether 
plume modeling data were being used by VA to determine eligibility for 
treatment or compensation.

To identify total costs associated with modeling and analysis of CW 
agent releases during the Gulf War, we interviewed officials and 
collected cost data from various DOD agencies and contractors who 
supported the modeling efforts. However, total costs incurred could not 
be determined because DOD agencies and other organizations could 
provide only direct costs, not their indirect costs, associated with 
the modeling.

To determine the extent of British troops' exposure to CW agent 
releases during the Gulf War, we interviewed MOD officials in London 
and Porton Down, and we reviewed MOD reports concerning the effect of 
exposure to CW agent releases on British forces.

We conducted our work from May 2002 through May 2004 in accordance with 
generally accepted government auditing standards.

Results in Brief:

DOD's and MOD's conclusions, based on DOD's plume modeling, about their 
troops' exposure to CW agents cannot be adequately supported. Given the 
inherent weaknesses associated with the specific models they used and 
the lack of accurate and appropriate meteorological and source term 
data in their analyses, we found five major reasons to question their 
conclusions. First, the models were not fully developed for analyzing 
long-range dispersion of CW agents as an environmental hazard. Second, 
assumptions regarding source term data used in the modeling--such as 
the quantity and purity of the agent--were inaccurate, since they were 
based on (1) uncertain and incomplete information and (2) data that 
were not validated. Third, the plume heights from the Gulf War bombings 
were underestimated in DOD's models. Fourth, postwar field testing at 
the U.S. Army Dugway Proving Ground to estimate the source term data 
did not reliably simulate the actual conditions of either the bombings 
or the demolition at Khamisiyah. Fifth, there is a wide divergence in 
results among the individual models DOD selected, as well as in the DOD 
and non-DOD models, with regard to the size and path of the plume and 
the extent to which troops were exposed. Therefore, given these 
inherent weaknesses, DOD and MOD cannot know which troops were and 
which troops were not exposed.

The total costs for the various plume-modeling efforts to analyze the 
potential exposure of U.S. troops--from the demolition at Khamisiyah 
and the bombing of several sites in Iraq--cannot be estimated. DOD 
organizations and other entities involved with the plume-modeling 
efforts could provide only their direct costs (that is, contractors' 
costs), which totaled about $13.7 million. However, this amount does 
not include an estimate of the considerable indirect costs associated 
with the salaries of DOD, VA, and contractors' staff or costs of 
facilities, travel, and equipment. We requested, but DOD could not 
provide, this estimate. In addition, the CIA would not provide direct 
and indirect costs for Gulf War plume modeling because, in its view, 
our request constituted oversight of an intelligence matter and is 
beyond our scope of authority. The CIA's contractor, the Science 
Applications International Corporation (SAIC), also did not respond to 
our request.

DOD's and VA's conclusions--that there was no association between 
exposure to CW agents at Khamisiyah and U.S. troops' rates of 
hospitalization and mortality--also cannot be adequately supported. DOD 
and VA based their conclusions on two epidemiological studies they 
funded, one conducted by DOD researchers, the other by VA 
researchers.[Footnote 4] In both of these studies, flawed criteria were 
used to determine the troops' exposure. For example, the studies' 
criteria were based on (1) the DOD plume model of exposure from postwar 
demolition of the Khamisiyah munitions depot and (2) DOD's estimation, 
using this modeling, of which troops might have been under the path of 
the plume. Troops under the path of the plume were classified as 
exposed, those not under the path as nonexposed. However, troops 
classified as nonexposed under one DOD model could be classified as 
exposed under another DOD model, thereby confounding the results. In 
the DOD models, a small area was identified as being under the path of 
the plume, resulting in a small number of troops identified as exposed. 
But in a model DOD used from LLNL, for example, a much larger area was 
identified under the path of the plume, resulting in a large number of 
troops exposed; in addition, these exposed troops included different 
troops from those in the DOD models.

These flaws may have resulted in large-scale misclassification of the 
exposure groups--that is, a number of exposed veterans may have been 
classified as nonexposed, and a number of nonexposed veterans may have 
been misclassified as exposed. In addition, in the hospitalization 
study, the outcome measure--number of hospitalizations--failed to 
capture the chronic illnesses of Gulf War veterans, which are commonly 
reported but typically do not lead to hospitalization. Some published 
scientific studies of exposure involving Gulf War veterans, studies of 
genetic anomalies, and animal exposure-response studies suggest an 
association between low-level exposure to CW agents and chronic 
illnesses.

We recommend that the Secretary of Defense and the Secretary of 
Veterans Affairs not use the plume-modeling data for future 
epidemiological studies of the 1991 Gulf War, since VA and DOD cannot 
know from the flawed plume modeling who was and who was not exposed.

We recommend that the Secretary of Defense require no further plume 
modeling of Khamisiyah and the other sites bombed during the 1991 Gulf 
War in order to determine troops' exposure. Given the uncertainties in 
the source term and meteorological data, additional modeling of the 
various sites bombed would likely result in additional costs while 
still not providing DOD with any definitive data on who was or was not 
exposed.

We obtained comments on a draft of this report from VA, DOD, and CIA. 
VA concurred with our first recommendation (see appendix V). DOD did 
not concur with our first recommendation, indicating that it apparently 
represents a blanket prohibition of plume modeling in the future. The 
intent of our recommendation is only directed at epidemiological 
studies involving the DOD and CIA plume modeling data from the 1991 
Gulf War and not a blanket prohibition of plume modeling in the future 
(see appendix VI). We have clarified the recommendation along these 
lines. DOD concurred with our second recommendation, indicating that 
despite enhancements in the modes, uncertainties will remain (see 
appendix VI). CIA did not concur with the report, indicating that it 
could not complete their review in the time allotted (see appendix 
VII).

Background:

In March 1991, after the Gulf War had ended, U.S. Army demolition units 
destroyed munitions in Bunker 73 and in an open pit at the Khamisiyah 
ammunition storage depot in southeastern Iraq. In October 1991, it was 
discovered, from inspections conducted by UNSCOM that hundreds of 122 
mm rockets destroyed at Khamisiyah had contained nerve agents sarin and 
cyclosarin.

U.S. and Coalition forces also bombed many other known or suspected 
Iraqi CW research, materiel, storage, and production sites. According 
to the CIA and DOD, Coalition aerial bombings resulted in damage to 
filled chemical munitions at only two facilities in central Iraq--Al 
Muthanna Bunker 2 and Muhammadiyat--and at one facility in southern 
Iraq--the Ukhaydir ammunition storage depot. During these aerial 
bombings, munitions were damaged at Al Muthanna containing an estimated 
17 metric tons of sarin and cyclosarin and at Muhammadiyat containing 
an estimated 2.9 metric tons of sarin and cyclosarin and 15 metric tons 
of the chemical agent mustard.

According to DOD, the connection between the CW agent munitions UNSCOM 
found at Khamisiyah and U.S. demolition operations there had not been 
immediately made. However, in 1996, concerns that the Presidential 
Advisory Committee on Gulf War Illnesses raised prompted the CIA to 
examine this issue.[Footnote 5] In early 1996, after linking Khamisiyah 
to the presence of CW agents, based on UNSCOM and other reporting, the 
CIA contracted with SAIC to conduct an initial analysis and modeling of 
the bombing of chemical munitions in Khamisiyah Bunker 73.

The CIA issued two reports. The first report, in August 1996, modeled a 
potential release of agents from Khamisiyah Bunker 73 and from Al 
Muthanna and Muhammadiyat.[Footnote 6] However, when modeling of the 
pit area at Khamisiyah began, the CIA realized that the source term 
data--such as the quantity and the purity of the agent and data on 
meteorological conditions, including the wind and the weather patterns-
-were not available. Because of these uncertainties, DOD and the CIA 
asked IDA to convene an independent panel of experts to review the 
modeling. The IDA expert panel conducted its review from November 1996 
to February 1997 and (1) reported that the initial analyses of the pit 
area were inadequate and (2) recommended taking different approaches to 
improve the modeling.

The CIA issued its second report jointly with DOD in September 1997, 
this time focusing on an open pit area at Khamisiyah.[Footnote 7] This 
report combined the results of five different meteorological and 
dispersion models that the CIA and DOD used to project the size and 
path of the plume from the demolition operations. In 2000, DOD 
remodeled the Khamisiyah pit site, using updated CIA source assessments 
and troop location data, which changed the projected hazard area. The 
1991-2000 timeline of major events at Khamisiyah is shown in figure 1.

Figure 1: Timeline of Events Following the U.S. Demolition of CW Agents 
at Khamisiyah, 1991-2000:

[See PDF for image]

[End of figure]

Modeling the Environmental and Health Effects of Fallout from CW 
Agents:

According to the CIA, modeling is the art and science of using 
interconnected mathematical equations to predict the activities of an 
actual event. In this case, modeling was used to determine the 
direction and extent of the plume from CW agents. In environmental 
hazard modeling, simulations recreate or predict the size and path 
(that is, the direction) of the plume, including the potential hazard 
area, and potential exposure levels are generated.

Modeling requires several components of accurate information:

* the characteristics or properties of the material that was released 
and the rate of release (for example, quantity and purity, the vapor 
pressure, the temperature at which the material burns, particle size, 
and persistency and toxicity),

* temporal information (for example, whether chemical agent was 
initially released during daylight hours, when it might rapidly 
disperse into the surface air, or at night, when a different set of 
breakdown and dispersion characteristics would pertain, depending on 
terrain, plume height, and rate of agent degradation),

* data that drive meteorological models during the modeled period (for 
example, temperature, humidity, barometric pressure, dew point, wind 
velocity and direction at varying altitudes, and other related measures 
of weather conditions), and:

* data from global weather models to simulate large-scale weather 
patterns and from regional and local weather models to simulate the 
weather in the area of the chemical agent release and throughout the 
area of dispersion.

* In addition, in modeling, information is required on the potentially 
exposed populations, animals, crops, and other assets that may be 
affected by the agent's release.

* The process flow for chemical plume modeling, to estimate the plume 
hazard area, is shown in figure 2.

Figure 2: The Plume-Modeling Process:

[See PDF for image]

[End of figure]

Meteorological Models:

Various plumes during the 1991 Gulf War were modeled with global-scale 
meteorological models, such as the National Centers for Environmental 
Prediction Global Data Assimilation System (GDAS) and the Naval 
Operational Global Atmospheric Prediction System (NOGAPS). Regional and 
local weather models were also used, including the Coupled Ocean-
Atmosphere Mesoscale Prediction System (COAMPS), the Operational 
Multiscale Environmental Model with Grid Adaptivity (OMEGA), and the 
Mesoscale Model Version 5 (MM5). Outputs from global weather models are 
mainly used as initial and boundary conditions for regional weather 
models.

Transport and Diffusion Models:

Transport and diffusion models were also used during the Gulf 
War.[Footnote 8] These models project both the path of a plume and the 
degree of potential hazard posed by the agents. Dispersion models used 
during the Gulf War included the Hazard Prediction and Assessment 
Capability (HPAC) model, along with the HPAC component, the Second-
order Closure Integrated Puff (SCIPUFF) model; the Vapor, Liquid, and 
Solid Tracking (VLSTRACK) model; the Non-Uniform Simple Surface 
Evaporation (NUSSE) model; and the Atmospheric Dispersion by Particle-
in-Cell (ADPIC) model.

The meteorological and dispersion models DOD used to model Khamisiyah 
are shown in table 1.

Table 1: The Meteorological and Dispersion Models DOD Used to Model 
Khamisiyah:

Model type: Meteorological: COAMPS: Coupled Ocean-Atmosphere Mesoscale 
Prediction System; 
Developer or sponsor: U.S. Navy.

Model type: Meteorological: MATHEW: Mass Consistent Wind Field[A]; 
Developer or sponsor: Department of Energy, Lawrence Livermore National 
Laboratory.

Model type: Meteorological: MM5: Mesoscale Model Version 5; 
Developer or sponsor: National Center for Atmospheric Research.

Model type: Meteorological: NOGAPS: Naval Operational Global 
Atmospheric Prediction System, Developer or sponsor: U.S. Navy.

Model type: Meteorological: OMEGA: Operational Multiscale Environment 
Model with Grid Adaptivity; 
Developer or sponsor: Defense Threat Reduction Agency.

Model type: Dispersion: ADPIC: Atmospheric Dispersion by Particle-in-
Cell[A]; 
Developer or sponsor: Department of Energy, Lawrence Livermore National 
Laboratory.

Model type: Dispersion: HPAC/SCIPUFF: Hazard Prediction and Assessment 
Capability/ Second-order Closure Integrated Puff; 
Developer or sponsor: Defense Threat Reduction Agency.

Model type: Dispersion: NUSSE4: Non-Uniform Simple Surface Evaporation, 
Version 4; 
Developer or sponsor: U.S. Army.

Model type: Dispersion: VLSTRACK: Vapor, Liquid, Solid Tracking; 
Developer or sponsor: U.S. Navy. 

Source: Department of Defense, Technical Report: Modeling and Risk 
Characterization of U.S. Demolition Operations at the Khamisiyah Pit 
(Washington, D.C.: Apr. 2002).

[A] Institute of Defense Analysis used this model in its analysis of 
Khamisiyah modeling, an analysis done at DOD's request.

[End of table]

DOD's Conclusion about U.S. Troops' Exposure to CW Agents Cannot Be 
Adequately Supported:

DOD's conclusion about the extent of U.S. troops' exposure to CW agents 
from the Gulf War, based on CIA and DOD plume models, cannot be 
adequately supported because of uncertainty associated with the source 
term data and meteorological data. The models are neither sufficiently 
certain nor sufficiently precise to draw definitive conclusions about 
the size or path (that is, the direction) of the plumes.

In particular, we found five reasons to question DOD's conclusion. 
First, the models DOD selected were not fully developed for analyzing 
long-range dispersion of CW agents as environmental hazards. Second, 
the assumptions about the source term data used in the models were 
inaccurate. Third, in most of the models, the plume height was 
significantly underestimated. Fourth, postwar field testing at the U.S. 
Army Dugway Proving Ground in Utah to estimate the source term data did 
not realistically simulate the actual conditions of the demolition 
operations at Khamisiyah or the effects of the bombings at any of the 
other sites in Iraq. And fifth, there are wide divergences among the 
individual models DOD selected with regard to the size and path of the 
plume and the extent to which troops were exposed.

DOD's Models Were Not Fully Developed for Analyzing Long-Range 
Environmental Hazards:

CIA and DOD officials selected several in-house models for plume 
models. For Khamisiyah and the other Iraqi sites, DOD selected the 
COAMPS and OMEGA meteorological models and the HPAC/SCIPUFF and 
VLSTRACK dispersion models. However, at the time, these models were not 
fully developed for long-range environmental hazards. In particular, 
they were inappropriate for the long-range tracking of chemical agents.

COAMPS and OMEGA Meteorological Models:

Although COAMPS was accepted by the DOD peer review panel, OMEGA was 
still under development. The DOD 1997 peer review panel that was 
reviewing the models chosen for the 1997 Khamisiyah analysis reported 
problems with OMEGA that resulted in major errors in its simulations. 
In the analyses of Khamisiyah, as well as Al Muthanna, according to an 
IDA technical review panel, OMEGA consistently underpredicted surface 
wind speeds by a factor of 2 to 3, compared with actual observations 
collected at five World Meteorological Organization (WMO) stations in 
the area.

VLSTRACK and HPAC Dispersion Models:

VLSTRACK had been developed primarily to predict immediate health 
hazards (that is, lethal or incapacitating effects) associated with 
troops' direct exposure to CW agents. It was not developed for 
predicting long-term health effects from indirect exposure to low 
levels of these agents. According to modeling experts at the Naval 
Surface Warfare Center, the 2-month IDA panel reanalysis and modeling 
was a developmental effort because existing models did not have the 
capability to perform the required predictions. Considerations of 
dispersion areas associated with low-level exposure to CW agents 
released in Iraq, such as nerve and blister agents, required these 
experts to make many extensions and modifications to some of the 
methodology in VLSTRACK.

HPAC was developed jointly by the Defense Intelligence Agency (DIA) and 
the Defense Special Weapons Agency--now the Defense Threat Reduction 
Agency (DTRA)--and was specifically tailored for counterproliferation 
contingency planning. In a 1998 scientific review and evaluation of the 
SCIPUFF dispersion model (an integral component of HPAC), the National 
Oceanic and Atmospheric Administration's (NOAA) Air Resources 
Laboratory reported that SCIPUFF was better suited for short-range 
dispersion applications of about 10 km than for long-range transport 
modeling. One of HPAC's weaknesses is that it does not provide 
definitive answers because of uncertainties about agent transport, 
plume location, and weather.

It is also evident, from NOAA's review, that a group using VLSTRACK 
might receive significantly divergent results from a group using HPAC. 
Further, neither model is sufficiently accurate to permit a conclusion 
that the path of the plume is confined to the hazard area that the 
model predicts.

In a September 1998 memorandum, the Deputy to the Secretary of Defense 
for Counterproliferation and Chemical and Biological Defense cited a 
DOD panel study team finding that the VLSTRACK and HPAC models generate 
hazard predictions that differ significantly from each other: "This 
occurred even when the source terms and weather inputs are as simple 
and as identical as possible. In operational deployment, the average 
model user could obtain different answers for the same threat."

A former Modeling and Simulation Adviser to the Deputy for 
Counterproliferation and Chemical and Biological Defense told us that 
the reliability of these models was of extreme concern. Also, in 1998, 
at IDA, a panel study's initial comparison of the hazard-prediction 
models HPAC and VLSTRACK documented substantial differences--by factors 
between 5 and 1,000--between the models for the prediction of the same 
event. The most significant errors in the coding and the potential for 
misuse were found in HPAC and its subcomponent models. Given these 
problems with the analyses conducted up to 1998, HPAC could not be 
considered reliable.

In 1997, the director of NOAA's Air Resources Laboratory stated that 
DOD's model selection resulted in the use of in-house models that were 
not well known outside DOD. As to the meteorological models, he noted 
that three mainstream mesoscale models were available, such as MM5 and 
Regional Atmospheric Modeling System (RAMS), that were well accepted 
for deriving site-specific flow conditions from large-scale 
meteorological information. DOD used MM5 in both its 1997 and 2000 
modeling.

DOD's Models Included Source Term Assumptions That Cannot Be Verified:

The source term data DOD used in the modeling for sites at Khamisiyah, 
as well as Al Muthanna and Muhammadiyat, contain significant unreliable 
assumptions. DOD and the CIA based assumptions on field testing, 
intelligence information, imagery, UNSCOM inspections, and Iraqi 
declarations to UNSCOM. However, these assumptions were based on 
limited, nonvalidated, and unconfirmed data concerning (1) the nature 
of the Khamisiyah pit demolition, (2) meteorology, (3) agent purity, 
(4) amount of agent released, and (5) other CW agent data. In addition, 
DOD and the CIA excluded, for modeling, many other sites and potential 
hazards associated with the destruction of binary chemical weapons, CW 
agent precursor materials, and the potential release of CW agents and 
toxic byproducts from other sites.[Footnote 9]

During the initial modeling of the demolition of CW agent munitions at 
the Khamisiyah pit, the CIA did not have the data--the number of 
rockets present, agent purity, amount of agent released into the 
atmosphere, agent reaction in an open-pit demolition, and prevailing 
meteorological conditions--on how rockets with chemical warheads would 
be affected by open-pit demolition compared with bunker demolition. A 
1996-97 IDA panel found substantial uncertainty about the number of 
damaged rockets that might have released CW agents and how rapidly they 
were released. The panel also found that the CIA and SAIC had used what 
were, "essentially, guesses" to make up for the lack of data on how 
much agent was released and over what period of time. For example, the 
CIA based the number of rockets on the number known to have been there 
before the demolition and the number UNSCOM found during inspections. 
But, according to the IDA panel, the difference between what was 
estimated and what UNSCOM found varied by a factor of 5 or 6.

Meteorological data at Khamisiyah were lacking because relatively few 
observations had been made, according to DOD modelers, and those that 
had been made were far from the site. This lack of meteorological 
observation applied also to the modeling of other sites. Observations 
were few because Iraq stopped reporting weather station measurement 
information to WMO in 1981. As a result, data on the meteorological 
conditions in Iraq during the Gulf War were not available.

At Khamisiyah, the only data available were for the surface wind 
observation site, 80 to 90 km away, and for the upper atmosphere, about 
200 km away. At other sites modeled, the nearest data were at even 
greater distances. The IDA panel recognized that wind patterns could 
contain areas of bifurcation--lines where winds move in one direction 
on one side and in another direction on another side--which migrate 
over time and are different at varying altitudes.

Assumptions about the purity of the CW agents sarin and cyclosarin 
established for Khamisiyah, Al Muthanna, Muhammadiyat, and Ukhaydir 
differed widely. In each case, agent purity was a key factor in the CIA 
and DOD methodology for determining the amount of agent released. For 
example, for modeling purposes, 10 tons of agents with a purity of 18 
percent would be represented as 1.8 tons of agent. The CIA relied on 
UNSCOM reporting on the amount of CW agents Iraq produced. But to 
establish these rates, UNSCOM relied primarily on Iraqi declarations 
and Iraqi production records, other UNSCOM testing, and assumptions 
about the extent of agent degradation.

For example, according to Iraqi production records UNSCOM obtained, the 
agent purity at Khamisiyah in early January 1991 was about 55 percent. 
The agent degraded to 10 percent purity by October 1991, when 
laboratory analysis had been completed on samples taken by UNSCOM from 
one of the rockets. On the basis of the initial sample purity and the 
projected degradation rate for sarin and cyclosarin, the CIA assessed 
that the ratio of sarin to cyclosarin when the munitions were blown up, 
in March 1991, was the same as that sampled in October 1991--3:1. 
According to the CIA, "assuming a conservative exponential degradation" 
of the sarin and cyclosarin, the purity on the date of demolition, 2 
months after production, was calculated at about 50 percent.

At Al Muthanna, where sarin was stored in a bunker, the CIA estimated 
that it had deteriorated to approximately 18 percent purity by early 
February 1991, when Bunker 2 was destroyed, leaving the equivalent of 
about 1,600 kg (1.6 metric tons) of viable sarin. Iraqi records 
recovered by UNSCOM inspectors suggested that the agent in Bunker 2 was 
from 1988 production runs. UNMOVIC confirmed that in UNSCOM testing of 
other sarin samples, produced during 1998, the maximum purity of agent 
had degraded to a range of 18 percent to 2 percent by 1991.

According to a 2002 CIA assessment, only 2.5 percent of sarin was 
released from the demolition of rockets in Bunker 73 at 
Khamisiyah.[Footnote 10] This assessment was based on comparisons with 
U.S. testing in the 1960s at Black Hills, South Dakota, on sarin-filled 
rockets.[Footnote 11] The CIA considered the 2.5 percent estimate 
conservative because agent-heating conditions were harsher in Bunker 73 
than in the Black Hills tests. The 2002 CIA assessment included this 
statement:

Far less agent (a maximum of 0.01 percent) would have been released in 
the Al Muthanna bunker incident than the 2.5 percent indicated by 1960s 
US field tests at Black Hills, South Dakota. The Black Hills tests used 
simulated bunkers that had a wood slat, sand ceiling, and earth walls. 
Those bunkers did not allow heat to build up as rapidly as in an Iraqi 
bunker with thick reinforced concrete ceiling and walls. However, we 
have chosen 10 kilograms as the release amount to account for unmodeled 
releases from rocket flyouts or transients at the beginning of the 
fire.[Footnote 12]

The CIA assessed that far less agent would have been released in the Al 
Muthanna bunker because, based on U.S. field testing with simulated 
bunkers, heat would build up rapidly in Iraqi bunkers made of thick 
reinforced concrete ceiling and walls, destroying most of the agent.

DOD's Postwar Field Testing Did Not Realistically Simulate Actual 
Conditions of Demolition Operations:

During the 1960s Black Hills testing, rockets filled with sarin and VX 
nerve agents were intentionally ignited by thermite grenades--alone and 
with the addition of diesel fuel--as well as by fused initiation of the 
burster explosive charge. According to the testing report, on the first 
trial, the 11 crates of rockets were stacked 18 in. from the front wall 
on the right side of the igloo. Because of safety considerations, a 
centrally located burster was ignited with a 10-min. safety time fuse 
instead of an electric blasting cap. Once detonated, there were 104 
major explosions during the 3 hrs. and 4 min. of observation. The 
maximum pressure recorded during the initial detonation was 19 lbs./sq. 
in. above atmospheric pressure. The maximum pressure during the trial 
was 621C, which was recorded 15 min. after the ignition of the 
burster. The igloo sustained three wide cracks in the arch and two 
large holes on either side of the door. The only major debris found 
outside the igloo was the partial body of one M55 rocket, located 
approximately 200 ft. away. Because of the damage to the igloo, the 
test was deemed an official disaster.

During a second trial, crated rockets, with bursters removed, were 
stacked as in the first trial. Two thermite grenades were set on top of 
the crates at the motor end and were ignited with a 10-min. safety time 
fuse. The grenades functioned properly but failed to ignite the rocket 
motors or crate material. One day later, 12 thermite grenades were 
placed in three groups of four, at the motor end of the crates, and 5 
gal. of diesel fuel were poured over the 11 crates just before ignition 
with a safety fuse. From 2 crates, 12 rocket motors were ignited and 
hit the rear wall of the igloo, but the only damage found was a slight 
bulge in the bottom of the igloo door. The igloo withstood the fire and 
contained the rockets.

According to a later DOD study, based on the analysis in the 1960s of 
Dugway Proving Ground Trial C505, from a fire within an igloo 
containing GB-filled M55 rockets, the estimated amount of agent 
released was assumed to be 2.52 percent over a 60-min. 
interval.[Footnote 13] This appears to be the basis for the conclusion 
that only approximately 2.5 percent of the agent would have been 
released.

However, the bunkers at Al Muthanna and other locations in Iraq were 
not deliberately set on fire with incendiary devices. They were 
targeted with high-explosive weapons such as Tomahawk missiles and 
laser-guided and nonguided bombs, which detonate and produce 
instantaneous and extreme blast forces, as well as shock and pressure 
waves and heat. A high explosive is one in which the speed of reaction 
(typically 5,000 to 8,000 m/s) is faster than the speed of sound in the 
explosive. High explosives produce a shock wave along with gas, and the 
characteristic duration of a high-explosive detonation is measured in 
microseconds (10-6 s). Further, if an explosion is confined within a 
chamber or room, the gas pressure increases rapidly to a sustained 
level and then decays by venting out. Under these conditions, shock 
reflections occur and the overall effect can be greater than that of 
the incident shock.[Footnote 14] While the CIA analysts gave much 
credibility to blast heat, no consideration was given to either the 
shock blast effects of the munitions or the higher altitude plumes 
generated from the transfer of mass associated with the shock waves. 
Further, the CIA stated that its conclusion was supported by UNSCOM's 
physical inspections of Bunker 2. UNMOVIC, however, informed us that 
UNSCOM had not physically inspected this bunker for safety reasons 
relating to structural instability.

At Muhammadiyat, DOD, using test data from Dugway Proving Ground, 
provided details about how source term characterizations for agent 
released were derived. However, the type and quantity of explosives 
used in the Dugway testing--and, therefore, the resulting effects--are 
not comparable with the type and quantity of munitions that were 
actually used at Muhammadiyat. At Dugway Proving Ground, small 
explosive charges were placed on boxed rockets; at Muhammadiyat, the 
munitions storage bunkers were targeted with multiple high-explosive 
bombs. Agent purity at Muhammadiyat was estimated at 15 percent. In 
addition, according to UNSCOM, there are many questions as to the 
accuracy of Iraqi records for the number of munitions filled with sarin 
at Muhammadiyat.

Major Unresolved Issues Concerning Modeling:

The major unresolved issues concerning DOD's modeling include 
assumptions about (1) CIA's modeling of Khamisiyah Bunker 73; (2) 
repeated aerial bombings of storage facilities; (3) repeated aerial 
bombings of other storage, as well as research and production, 
facilities; (4) binary munitions and combustion by-products; and (5) 
detection of CW agents.

CIA's Modeling Assumptions about Khamisiyah Bunker 73:

In July 1996, the CIA briefed the Presidential Advisory Committee on 
Gulf War Veterans' Illnesses on the results of its Bunker 73 model. In 
the August 2, 1996, report, identifying its modeling assumptions, the 
CIA concluded that any hazard area resulting from the demolition of 
Bunker 73 had moved east and northeast.[Footnote 15]According to CIA 
reporting, Bunker 73 and a number of other bunkers were destroyed on 
March 4, 1991. The pit, warehouses, and most of the remaining bunkers 
were destroyed on March 10, 1991. The CIA revised some of the source 
term assumptions for Bunker 73 in its 2002 report, but Bunker 73 was 
never remodeled.[Footnote 16] Among the CIA's more significant 
assumptions in the 1996 modeling of the demolition of Bunker 73 were 
these:

* Bunker 73 contained approximately 1,060 rockets filled with sarin 
(this figure was modified to 910 rockets in 2002).

* Each rocket was filled with 8 kg of a 2:1 ratio of sarin to 
cyclosarin.

* The demolition ejected an estimated 10 percent of the rockets from 
the bunker.

* U.S. tests showed that heat from the explosion, as well as burning 
motors and crates, degraded all but 2.5 percent of the agent in the 
bunker.

* Winds were light, northeast to east.

* The modeling did not include the effect of thermal energy released by 
the simultaneous burning and detonation of the other 32 to 37 bunkers 
at the site.

The models used to arrive at these conclusions, however, were not 
identified in the 1996 CIA report. According to the SAIC analyst who 
conducted this modeling, the models used, the NUSSE4 and DP2C, were 
dispersion models. (They were among the models that the IDA expert 
panel later evaluated as having been inadequate for assessing the 
pit.):

In addition, the potential for greater contamination than indicated by 
the initial models exists, given (1) UNMOVIC's assertion that UNSCOM 
did not physically inspect this bunker through 1996 for safety reasons 
related to contamination and structural instability and given DOD's 
conclusion that all but 2.5 percent of the agent was degraded and (2) 
the lack of correlation between the igloo testing studies and actual 
events.

Assumptions about Repeated Aerial Bombings of Storage Facilities:

DOD reported that the Al Muthanna storage, as well as research and 
production, facilities for CW agents was repeatedly attacked. Despite 
its repeated bombing, however, on only one occasion did the CIA and DOD 
express any concern about agent release. According to DOD analysis of 
the destruction of Bunker 2 at Al Muthanna on February 8, 1991, no 
trace residue from CW agents was detected in or around the 
bunker during UNSCOM inspections. However, UNMOVIC told us that UNSCOM 
never inspected this bunker for safety reasons. A low-level vapor 
hazard, however, probably emanating from damaged and leaking 122 mm 
rockets stored in the open, was detected around some of the other 
facilities. UNSCOM also reported contamination in several other 
facilities at Al Muthanna that produced CW agents. These observations 
suggest that additional releases may have resulted from the repeated 
attacks at this site. However, DOD did not analyze or model additional 
direct or incidental destruction from the numerous bombings at the 
site.

There were 17 discrete Coalition aerial bombings of the Muhammadiyat 
munitions storage facility. For Muhammadiyat models, we identified two 
issues: time for agent dissipation and number of aerial bombings. For 
agent dissipation, DOD assumed that agent concentration would have been 
reduced to miniscule amounts during the first 24 hours. Therefore, for 
this model, DOD chose a duration of 24 hours.

For number of aerial bombings, DOD made the assumption that all sarin 
at Muhammadiyat was released at one time; therefore, DOD modeled each 
aerial bombing as if it were the only bombing that caused a release. 
According to DOD, each model produced a freeze frame of the largest 
hazard area. The models suggest that the hazard area grows until it 
reaches its maximum size, which is about 10 to 12 hours after the 
release. However, in these models, DOD focused on a single bombing, 
failing to consider the cumulative effects of exposure resulting from 
multiple aerial bombings.

Assumptions about Repeated Aerial Bombings of Other Storage, as Well as 
Research and Production, Facilities:

CW agents could have been released from a number of suspected storage 
sites targeted for Coalition bombing, in addition to Al Muthanna and 
Muhammadiyat. As shown in table 2, the intelligence community 
identified numerous sites alleged to include research, production, or 
storage facilities for CW agents. Another element of uncertainty in the 
modeling site selection process results from the possibility that low-
level chemical agent exposures might have originated from bombing these 
other sites during the Gulf War. Many of these sites were entirely 
discounted for the purposes of the CIA's and DOD's models because the 
intelligence community's assessment was that potential plumes from 
these sites could not have reached U.S. troops.

Table 2: Gulf War Suspected Chemical Weapon Sites:

Site type: Facility; 
Site name and place: Al Muthanna (Samarra); 
Site name and place: Fallujah III (Habbaniyah I); 
Site name and place: Fallujah I (Habbaniyah III); 
Site name and place: Khamisiyah (Tall al Lahm); 
Site name and place: Fallujah II (Habbaniyah II); 
Site name and place: Muhammadiyat (Qubaysah Storage Depot).

Site type: Airbase, airfield; 
Site name and place: Al Bakr Airfield (Samarra East Airfield); 
Site name and place: Murasana Airbase (H3 NW Airfield); 
Site name and place: Al Taba'at Airstrip (H3 SW Airfield); 
Site name and place: Qadisiyah Airbase (Al Asad Airfield); 
Site name and place: Al Taqaddum Airfield; 
Site name and place: Qayyarah West Airfield; 
Site name and place: Al Tuz Airfield (Tuz Khurmatu Airfield); 
Site name and place: Saddam Airbase (Qayyarah West Airfield); 
Site name and place: Al Walid Airbase (H3 Airfield); 
Site name and place: Tallil Airfield; 
Site name and place: K-2 Airfield; 
Site name and place: Tammuz Airbase (Al Taqaddum Airfield); 
Site name and place: Kirkuk Airfield; 
Site name and place: Ubaydah Bin al Jarrah Airfield; 
Site name and place: Mosul Airfield. 

Site type: Ammo; 
Site name and place: Ad Diwaniyah Ammo Depot; 
Site name and place: Kirkuk Ammo Depot West; 
Site name and place: Al Fallujah Ammo Depot South; 
Site name and place: Qabatiyah Ammo Storage (Wadi al Jassiyah Ammo 
Storage); 
Site name and place: An Nasiriyah Ammo Storage Depot SW; 
Site name and place: Qayyarah West Ammo Storage Depot; 
Site name and place: Ash Shuaybah Ammo Storage Depot; 
Site name and place: Tikrit Ammo Depot (Salahadin); 
Site name and place: Baghdad Ammo Depot Taji; 
Site name and place: Ukhaider (Karbala Depot and Ammo Storage).

Site type: Other; 
Site name and place: Al Qaim Superphosphate Fertilizer Plant; 
Site name and place: Fallujah Chem Proving Gnd (Habbaniyah CW Training 
Center); 
Site name and place: Dujayl/Awarah (Sumaykah SSM Support Facility SE. 

Source: Central Intelligence Agency, CIA Report on Intelligence Related 
to Gulf War Illnesses (McLean, Va.: Aug. 2, 1996).

[End of table]

Assumptions about Binary Munitions and Combustion By-Products:

During our interview with UNSCOM and UNMOVIC officials, we were 
informed that Iraq had extensively deployed binary CW munitions 
components at a number of sites within range of the theater of 
operation. The chemical munitions were deployed unfilled but with 
chemical components that when mixed would make the nerve agent sarin. 
While there is no evidence that Iraq used these munitions offensively, 
it remains unknown whether these materials were mixed intentionally or 
inadvertently during combat engagements. In addition, Iraq declared 
that 823 metric tons of CW agent precursor materials, deployed 
throughout Iraq, were destroyed during the Gulf War. The hazards 
associated with environmental fallout from the destruction of these 
materials remain unknown. CIA assessments and DOD modeling specifically 
did not address potential exposure to binary CW agents, exposure to CW 
agent precursors, or the hazardous environmental consequences 
associated with the combustion by-products of sulfur mustard from the 
bombings at Muhammadiyat and other sites.[Footnote 17]

Assumption about the Detection of CW Agents:

Credible scientific evidence suggests that the reported detections of 
CW agents were reliable. These detections, during the early phases of 
the air war, included the use of an array of scientific methods. The 
CIA and DOD assert that the various detections are not valid because 
the source of the agents cannot be detected. Available evidence, 
however, can explain the detections and suggests that troop exposure 
may be far more widespread than that projected from the CIA and DOD 
modeling of the Khamisiyah release alone.

Coalition forces possessed a diverse array of CW detection and 
identification equipment. Czechoslovak chemical detection troops also 
used Warsaw Pact equipment, such as the GSP-1, GSP-11, and Czech mobile 
chemical agent laboratories. This broad array of equipment included 
various technologies to detect and confirm the presence of CW agents, 
as well as to identify specific agents. The different physical 
principles that were employed included wet chemistry, mass 
spectrometry, ion mobility spectrometry, chemical reaction, 
biochemical enzyme reactivity, flame photometry, and ionization. 
Detector (that is, sensor) and agent identification systems that 
Coalition forces deployed, reporting the detection of CW agents, are 
shown in table 3.

Table 3: Detector and Agent Identification Systems Deployed by 
Coalition Forces Reporting the Detection of CW Agents:

Nation: Czech Republic; 
System: Automatic Nerve Agent Detector Alarm GSP-11; 
Chemical agent: G-and V-series nerve agents; 
Sensitivity: 0.05 mg/m3; 
Method or technology: Air sampling, biochemical enzyme; 
(cholinesterase reactivity).

Nation: Czech Republic;
System: Mobile Laboratory CHP-71, PCHL-90, and PCHL-90; 
Chemical agent: Most CW agents; 
Sensitivity: Agent identification through wet chemistry analysis; 
Method or technology: Field portable chemical agent laboratory, 
chemical reagents, wet chemistry analysis.

Nation: France; 
System: Detalac F1; 
Chemical agent: G-and V-series nerve agents; 
Sensitivity: Not available; 
Method or technology: Biochemical enzyme detector.

Nation: France; 
System: Chemical Detection Control Kit (TDCC); 
Chemical agent: Tabun/sarin (GA/GB), 
Sensitivity: 1 mg/m3; 
Chemical agent: Hydrogen cyanide (AC), 
Sensitivity: 350 mg/m3; 
Chemical agent: Cyanogen chloride (CK); 
Sensitivity: 2000 mg/m3; 
Method or technology: Chemical biochemical detector.

Nation: France; 
System: Chemical Detection Unit for Fixed Installations (ADLIF); 
Chemical agent: Sarin/soman (GB/GD); 
Sensitivity: Not available; 
Method or technology: Flame spectrometry.

Nation: United Kingdom; 
System: Chemical Agent Monitor; 
Chemical agent: G-and V-series nerve agents; 
Sensitivity: 0.1 mg/m3; 
Chemical agent: Blister agents (H); 
Sensitivity: 2.0 mg/m3; 
Method or technology: Ion mobility spectrometry (quantitative feature).

Nation: United Kingdom; 
System: Nerve Agent Immobilized Enzyme Alarm and Detector (NAIAD); 
Chemical agent: G-series nerve agents; 
Sensitivity: 0.05mg/m3; 
Chemical agent: V-series nerve agents; 
Sensitivity: 0.005 mg/m3; 
Method or technology: Biochemical enzyme detector (cholinesterase 
reactivity).

Nation: United Kingdom; 
System: MARK I; 
Chemical agent: G-series nerve agents Blister agents (H); 
Sensitivity: Not available; 
Method or technology: Biochemical chemical reactivity.

Nation: United States; 
System: M8A1 Alarm; 
Chemical agent: G-series nerve agents; 
Sensitivity: 0.1 mg/m3; 
Chemical agent: V-series nerve agents; 
Sensitivity: 0.2 mg/m3; 
Method or technology: Ionization Automatic alarm.

Nation: United States; 
System: M8 Paper; 
M9 Paper; 
Chemical agent: G-and V- series nerve agents; 
Sensitivity: Yes/no; 
Method or technology: Chemical reactivity; 
Chemical agent: Blister agents (H); 
Sensitivity: Yes/no; 
Method or technology: Color interpretation.

Nation: United States; 
System: Chemical Agent Detector Kit M256 and M256A1; 
Chemical agent: G-series nerve agents; 
Sensitivity: 0.05 mg/m3
Chemical agent: V-series nerve agents; 
Sensitivity: 0.15 mg/m3; 
Chemical agent: Blister agents (H); 
Sensitivity: 3.0 mg/m3; 
Method or technology: Biochemical enzyme detector (cholin-esterase 
reactivity), Chemical reactivity.

Nation: United States; 
System: Chemical Agent Monitor; 
Chemical agent: G-and V-series nerve agents; 
Sensitivity: 0.1 mg/ m3; 
Chemical agent: Blister agents (H); 
Sensitivity: 2.0 mg/m3; 
Method or technology: Ion mobility spectrometry (quantitative feature).

Nation: United States; 
System: MM1 FOX NBC vehicle; 
Chemical agent: G-series nerve agents; 60 other preprogrammed agent 
spectra; 
Sensitivity: Several mg/m3 M8A1 (M43) ionization backup unit (early 
warning); 
Method or technology: Quadrapole gas chromatography, C-mass 
spectrometryS, Full GC-MS.

[End of table]

Sources: DOD FM Series 3; 
Chemical Research, Engineering, and Development Command, Aberdeen 
Proving Grounds, Md; manufacturers; Jane's NBC Protection Equipment 
(1991-92 and 1995-96); CIA, Chemical Warfare Agent Issues during the 
1991 Persian Gulf War (Apr. 2002); video footage of Czech chemical 
detection unit activity during the 1991 Gulf War; Czech Chemical 
Warfare Report, Intelligence Assessment of Chemical and Biological 
Warfare in the Gulf, prepared by U.S. Army Foreign Science and 
Technology Center and DIA for the Defense Science Board investigating 
the Desert Storm Syndrome.

Shortly after the air war began, the period between January 18 and 
January 23, 1991, was marked by a stationary frontal pattern and the 
development of low-level cloud and fog activity directly over the areas 
occupied by Coalition forces. Figure 3, based on NOAA-11 AVHRR 1B 
meteorological imagery, shows contemporaneous visual evidence of this 
anomaly.

Figure 3: NOAA-11 Meteorological Imagery of Areas Occupied by Coalition 
Forces, January 18-24, 1991:

[See PDF for image]

Note: NOAA-11 AVHRR 1B meteorological imagery, processed by Earth 
Satellite Corporation, Rockville, Md., was obtained from the National 
Center for Atmospheric Research, Ashville, N.C.

[End of figure]

During this prolonged period, a significant number of reported CW agent 
detections were reported in northern Saudi Arabia where Coalition 
forces were deployed (see table 4).

Table 4: Principal Reported Detections of Chemical Agents in Saudi 
Arabia, January 17-23, 1991:

Date: Jan. 17; 
Nation and unit: United States 2/5TH SFG; 
Place: NW Hafir Al Batin; 
Agent detected: Unknown nerve agent; 
Method or technology: Ionization, biochemical reaction; 
ion mobility spectrometry; 
M8A1, M256, CAM.

Date: Jan. 19; 
Nation and unit: Czech Republic Chemical Detection Unit; 
Place: N Hafir Al Batin; 
Agent detected: Sarin (GB); 
Method or technology: Biochemical reactivity; 
wet chemistry; 
GSP-1(11), mobile lab.

Date: Jan. 19; 
Nation and unit: Czech Republic Chemical Detection Unit; 
Place: NE Hafir Al Batin; 
Agent detected: Sarin (GB); 
Method or technology: Biochemical reactivity; wet chemistry; GSP-1(11), 
mobile lab.

Date: Jan. 19; 
Nation and unit: Czech Republic Chemical Detection Unit; 
Place: King Khalid Military City (KKMC); 
Agent detected: Unknown nerve agent; 
Method or technology: Biochemical reactivity; 
wet chemistry; 
GSP-1(11), mobile lab.

Date: Jan. 19; 
Nation and unit: France; 
Place: 30 km from KKMC; 
Agent detected: Unknown nerve agent; 
Method or technology: Biochemical reactivity.

Date: Jan. 19; 
Nation and unit: Czech Republic Chemical Detection Unit; 
Place: 30 km from KKMC; 
Agent detected: Confirm French detection; 
Method or technology: Wet chemistry mobile lab.

Date: Jan. 19; 
Nation and unit: Czech Republic Chemical Detection Unit; 
Place: KKMC; 
Agent detected: Sulfur mustard (HD); 
Method or technology: Wet chemistry mobile lab.

Date: Jan. 19; 
Nation and unit: United Kingdom; 
Place: Jubayl; 
Agent detected: Unknown blister (after unexplained explosions); 
Method or technology: Chemical reactivity; ion mobility spectrometry; 
M- 9, CAM.

Date: Jan. 19; 
Nation and unit: United States 24th Naval Reserve Construction 
Battalion (Seabees); 
Place: Jubayl; 
Agent detected: Unknown blister (after unexplained explosions); 
Method or technology: Chemical reactivity; M-256 (2/3 tests).

Date: Jan. 20; 
Nation and unit: Czech Republic Chemical Detection Unit; 
Place: Near KKMC; 
Agent detected: Sulfur mustard (HD) for 2 hours; 
Method or technology: Wet chemistry mobile lab.

Date: Jan. 20; 
Nation and unit: Czech Republic Chemical Detection Unit; 
Place: French sector KKMC; 
Agent detected: Sarin (GB)/tabun (GA); 
Method or technology: Biochemical reactivity; 
wet chemistry mobile lab.

Date: Jan. 20; 
Nation and unit: France; 
Place: Near KKMC; 
Agent detected: Unknown nerve agent; 
Method or technology: Biochemical reactivity.

Date: Jan. 20; 
Nation and unit: United States 800th MP BDE; 
Place: NW of KKMC; 
Agent detected: Unknown nerve agent; 
Method or technology: Ionization, biochemical reactivity; 
M8A1, M256.

Date: Jan. 20; 
Nation and unit: United Kingdom; 
Place: Dharan; 
Agent detected: Unknown nerve agent (after SCUD attack); 
Method or technology: Biochemical reactivity (separate devices); NAIAD, 
MARKI.

Date: Jan. 21; 
Nation and unit: Czech Republic Chemical Detection Unit; 
Place: KKMC; 
Agent detected: Sarin (GB)/tabun (GA), sulfur mustard (HD); 
Method or technology: Biochemical reactivity; 
wet chemistry mobile lab.

Date: Jan. 21; 
Nation and unit: France; 
Place: KKMC; 
Agent detected: Unknown nerve agent; 
Method or technology: Biochemical reactivity.

Date: Jan. 21; 
Nation and unit: France; 
Place: KKMC; 
Agent detected: Unknown CW agent; 
Method or technology: Chemical or biochemical reactivity.

Date: Jan. 22; 
Nation and unit: United States; 
Place: RAFHA; 
Agent detected: Unknown nerve agent; 
Method or technology: Ionization, biochemical reactivity; M8A1, M256.

Date: Jan. 23; 
Nation and unit: Czech Republic Chemical Detection Unit; 
Place: KKMC; 
Agent detected: Unknown CW agent; 
Method or technology: Wet chemistry mobile lab.

Date: Jan. 23; 
Nation and unit: Czech Republic Chemical Detection Unit; 
Place: Near KKMC; 
Agent detected: Patch of sulfur mustard (HD); 
Method or technology: Wet chemistry mobile lab. 

Sources: CENTCOM CCJ3-X log (partially declassified 1995), Defense 
Science Advisory Board report (June 1994), Czech government reports on 
detection activity during the Gulf War, and declassified Defense 
Intelligence Agency reports on chemical detection activity.

[End of table]

This period of reporting on chemical agent detection is attributable to 
the use of many of the instruments and methodologies cited in tables 3 
and 4 and coincides directly with the initial Coalition bombings of 
confirmed and suspected Iraqi CW research, production, and storage 
facilities during January 17-24, 1991.

That these detections were reported raises continued and unresolved 
concern that U.S. troop exposures may have been more frequent and more 
widespread than the CIA and DOD believe. In addition, these exposures 
may have involved different populations than can be assumed from the 
limited simulations performed with the CIA and DOD models we refer to 
in this report. For example, figure 4 shows NOAA-11 collected infrared 
satellite imagery data for January 19, 1991, that NOAA published, 
indicating a line of instability and an inversion coincident with, and 
possibly precipitating, the detection of CW agents in the vicinity of 
Hafir al Batin and King Khalid Military City, reported by Czech 
chemical detection units and other Coalition units in the region (as 
shown in table 4).

Figure 4: Meteorological Satellite Photography, Iraq, January 19, 1991:

[See PDF for image]

[End of figure]

The lighter areas in the image represent warmer air, the darker areas 
colder air. In the image, a collision is shown between cold and warm 
air masses, as well as what appears to be evidence of inversion 
activity. That is, colder upper air moves below the warmer air, which 
is normally closer to the surface, possibly precipitating the 
detections.

The assessment by the CIA that the detections of the Czech chemical 
detection units are not credible--despite earlier DOD technical 
assessments that Czech detections of sarin and mustard agent on two 
occasions were credible--are unsound because these assessments do not 
refute the underlying scientific evidence, according to DOD and DIA 
experts.[Footnote 18]

The presence of both sarin and mustard agents at subacute levels, and 
in such close proximity, could reasonably be explained as the result of 
fallout from Coalition bombings of Iraqi weapons facilities and storage 
bunkers. This possibility is supported not only by the atmospheric data 
but also by observing that the Czech nerve agent detections were made, 
according to DIA reporting, by multiple teams over a range of 20 to 50 
km, within 30 minutes of one another, during a strong weather 
inversion.[Footnote 19] According to U.S. reporting, during the period 
immediately before the detections, the following known Iraqi CW agent 
research, production, and storage sites (with geocoordinates and dates) 
were bombed:

* Al Muthanna (3350 N, 04348 E, January 17, 1991),

* Al Nasiriyah (3058 N, 04611 E, January 17, 1991), and:

* Qabatiyah (3353 N, 04239 E, January 19, 1991).

In addition, production sites for CW agent precursors were bombed 
during this period.[Footnote 20] The potential remains that sites that 
may have been incorrectly assessed as not containing CW agents were 
also bombed during this period. These activities may have resulted in 
additional releases of CW agents.

DOD's Modeling Efforts Were Flawed:

In this section, we discuss our findings about DOD's modeling efforts 
in more detail, explaining the ways in which we believe them to be 
lacking in credibility.

DOD's Models Significantly Underestimated Plume Height:

Actual plume height might have been significantly higher than the 
height DOD estimated from its models of demolition operations and 
bombings, given the assumptions DOD's modeling used for Khamisiyah and 
the other Iraqi storage facilities. The plume height estimates that the 
CIA provided for demolition operations at the Khamisiyah pit were 0 to 
100 meters. However, neither the CIA nor DOD conducted testing to 
support estimated plume height associated with the bombings of Al 
Muthanna, Muhammadiyat, or Ukhaydir. According to DOD modelers, neither 
plume height nor any other heat or blast effects associated with these 
bombings were calculated; instead, these data were taken from DOD's 
Office of the Special Assistant for Gulf War Illnesses.

In addition, according to a principal DTRA modeler, DOD's data on plume 
height were inconsistent with other test data for the types of 
facilities bombed. This expert cited test studies conducted at White 
Sands Proving Ground demonstrating that plume height would range from 
300 to 400 m. The CIA maintains, however, that the plume occurred near 
ground level because there was no altitude, burst of munitions, or any 
kinetic force such as bomb blast to force the agent to become airborne 
initially. DOD maintains that during the bombing of chemical agents, 
liquid agent absorbs the energy of the blast, greatly reducing plume 
heights. We asked the CIA and DOD to provide test data in support of 
their assertions but neither agency provided any evidence.

Modeling experts from LLNL who participated in only the initial 
modeling of the Khamisiyah pit site also said that they questioned the 
plume height estimates. In a prewar analysis, LLNL projected that the 
plume immediately following the bombing of Iraqi storage facilities for 
CW agents would be a surface-based plume with a horizontal radius of 54 
m (177 ft.) and a height of 493 m (1,617 ft.). A 1969 Sandia National 
Laboratories empirical study established a power-law formula for 
calculating plume heights attributable to high-explosive detonations 
(see appendix II). By this formula, a conventional MK-84 or GBU-24 bomb 
(containing 942.6 lb. of high explosives) of the type used to bomb 
sites other than those at Khamisiyah would generate a plume of 
approximately 421 m.

Impact by Weight of Explosive:

Figure 5 shows the trend line for a plume height predicted on the basis 
of the formula for calculating plume height resulting from detonating 
high explosives ranging from 100 to 2,000 lbs. in weight.

Figure 5: Plume Height Trend Line by Weight of Explosive:

[See PDF for image]

[End of figure]

According to DOD officials, the Sandia National Laboratories study is 
not accurate or scientifically valid because it did not account for 
weather effects. Further, they said, it based plume height on the 
detonation of conventional explosives, but the liquid agent of 
chemical-filled munitions would have absorbed much of the energy of the 
blast if these had been bombed; therefore, plume height would have been 
greatly reduced. However, DOD could not provide us with any data, 
studies, or testing of the explosive aspects and buoyancy of chemical 
agents to corroborate these observations.

At Muhammadiyat, DOD established a plume height of 0.5 m (roughly half 
the bomb height) for nerve agent and a plume height of 1.0 m (roughly 
half the median height of the various bomb stacks) for mustard agent 
destroyed at this location. Moreover, according to one internal DOD 
memorandum, an "initial cloud size" of 10 m, in both lateral and 
vertical directions, was "arbitrarily" established. According to DOD, 
no effort was made to validate these estimates by analyzing video 
images that showed some of the plume data, such as (1) those taken from 
ground level at Khamisiyah and (2) the available footage from the 
aircraft and munitions used to bomb the other sites.

Impact by Wind Speed:

Figure 6 shows that disparity in source term data for plume height 
could lead to vastly divergent results as to how far the plume travels 
and disperses. This observation is particularly relevant during 
nighttime periods, when a stable nocturnal boundary layer emerges.

Figure 6: Boundary Layer Characteristics:

[See PDF for image]

[End of figure]

Figure 6 shows the stable nocturnal boundary layer where winds often 
accelerate to higher speeds, in a phenomenon referred to as the low-
level or nocturnal jet--that is, winds are aloft in the nighttime 
hours. At altitudes on the order of 200 m above ground, winds may reach 
10 m to 30 m per second (22 to 67.5 mph) in the nocturnal jet. Higher 
plumes than those DOD postulated, coupled with this phenomenon, could 
result in chemical agents being transported rapidly until disturbed by 
turbulence or the return of the mixed layer, some time after dawn. 
However, this possibility was not taken into consideration in any of 
the modeling DOD performed. Consequently, the models may have 
dramatically underestimated the extent of plume coverage.

According to DOD, such winds are not known to be present in Iraq. DOD 
confirmed, however, that it has no available data on prevailing wind 
conditions in the region, over the varying terrain, or during the time 
period in question to rule them out. DOD also stated that data are not 
available for determining the presence of a low-level or nocturnal jet 
at the time of the Khamisiyah demolition. However, DOD acknowledged 
uncertainty as to whether a low-level jet was present on any specific 
date or at any specific location.

Impact by Plume Geometry:

According to plume geometry, the majority of plume mass associated with 
high-explosive discharges is located toward higher altitudes (see 
figure 7). This suggests that the majority of the plume mass would move 
to higher altitudes to be transported by higher wind speeds.

Figure 7: Three Types of Plume Geometry:

[See PDF for image]

[End of figure]

Similarly, the distribution of plume geometry may be affected by 
nocturnal jets, as shown in figure 8.

Figure 8: The Impact of Nocturnal Jets on a Plume at Higher Altitudes:

[See PDF for image]

[End of figure]

Empirical studies and observed events tend to refute the assumptions 
with which the CIA and DOD discounted the alternative assumption that 
the plume was transported by low-level jets. First, empirical testing 
suggests that the plume heights were much higher than postulated in the 
source term data. Second, no massive casualties or effects were 
claimed, reported, or observed in areas immediately surrounding the 
Iraqi CW research, production, and storage facilities bombed by 
Coalition forces. In the absence of an alternative explanation, acute 
effects should have been observed in areas near the bombed sites.

Third, since many of the bombings were at night, the explosive effects-
-coupled with higher-altitude plumes and a nocturnal boundary layer 
capable of moving hazardous materials hundreds of miles--could easily 
account for the phenomena reported above. These effects could also 
account for the numerous reports of CW agents detected in sites 
occupied by U.S. and Coalition forces. Fourth, these effects may 
account for reported nighttime detections of low levels of CW agents, 
associated with turbulence--resulting from aircraft-related sonic 
booms and incoming missiles and artillery--mixing the upper-level and 
lower-level atmospheric layers.

DOD's Field Testing Did Not Realistically Simulate Actual Conditions:

To simulate the effects of demolition on chemical nerve agent 
stockpiles, the CIA and DOD conducted postwar field testing at Dugway 
Proving Ground. They explored what percentages of agent would be 
deposited on the ground as a liquid, consumed by the demolition, and 
aerosolized. To obtain these source term data for their models of 
Khamisiyah, the Dugway Proving Ground testing center conducted seven 
field tests and two laboratory studies from May 1997 through November 
1999.

Demolition and Bombing Simulations Were Not Realistic:

For field testing to be effective, conditions have to be as close to 
the actual event as possible, but these tests did not provide more 
definitive data for the CIA's and DOD's models. The tests did not 
realistically simulate the conditions of the demolition of 122 mm 
chemical-filled rockets in Khamisiyah. The simulations took place under 
conditions that were not comparable with those at Khamisiyah. There 
were differences in meteorological and soil conditions; the 
construction material of munitions crates; rocket construction 
(including the use of concrete-filled pipes as rocket replacements to 
provide inert filler to simulate larger stacks); and the numbers of 
rockets, using far fewer rockets and, therefore, explosive materials. 
Additionally, the tests used an agent stimulant whose physical 
properties differed from those of the actual agent.

For example, of the 32 test rockets with simulant-filled warheads, a 
small sample was used to conduct all seven field tests: five tests were 
single-rocket demolitions and two involved multiple-rocket 
demolitions. One multiple-rocket field test demolition used 9 
functional rockets plus 3 dummy rockets; the other multiple-rocket 
field test used 19 functional rockets and 5 dummy rockets. In contrast, 
at the Khamisiyah pit, stacks of 122 mm rockets were detonated, 
estimated at about 1,250 rockets. Dugway officials acknowledged that 
detonating a larger number of rockets would have made a significant 
difference to the testing. In addition, aerial bombing with a heavy 
explosive load, such as had occurred at the sites other than 
Khamisiyah, would have had a far greater effect than was achieved with 
the Dugway testing.

Extrapolation Data Contained Acknowledged Limitations:

According to DOD officials, SAIC developed projection data, in support 
of the Dugway tests, to extrapolate the results to the larger 
stockpiles identified at Khamisiyah. However, in our review of these 
data, we found that the SAIC analysts acknowledged limitations to their 
study. They noted in their report:

This is the first attempt to develop an understanding of these 
processes and we lack sufficient data to either validate or completely 
calibrate our models. The models in many cases have diverged from first 
principles models and have become "engineering" models in the sense 
that explicit calculations have been based on the observations of 
others and these have not been well documented as yet. In some cases, 
it may be that further calculations and/or tests will determine that 
for different configurations than those calculated/tested, some of the 
understandings developed from examining the existing data may have to 
be modified.[Footnote 21]

Finally, SAIC acknowledged that calculations were performed in two 
dimensions, stating that full, three-dimensional calculations were not 
feasible.[Footnote 22]

SAIC's conclusion was that the test explosions did not produce gases 
likely to endure long enough to cook off--that is, ignite--a motor, 
even in a large stack. But SAIC pointed out that "the real world often 
holds surprises in chaotic situations of this sort." For example, if a 
rocket motor were to ignite and burn in place, its energy might 
sensitize adjacent motors or cause cook-off initiation: "these 
processes could walk their way through the aisles [stacks] with minutes 
between dramatic events."[Footnote 23] The potential for real world 
events like these points to the inadequacy of attempting to extrapolate 
from the small-scale controlled testing at Dugway Proving Ground to the 
large-scale and relatively uncontrolled conditions at Khamisiyah.

Testing Did Not Use Iraqi Soil and Wood:

According to DOD and CIA analysts, the type of soil and wood can have a 
significant effect on the dispersion of the agent. Their estimates of 
the evaporation and retention rates of the chemical agent spilled on 
the soil may not be similar to what actually evaporated from and was 
retained in the pit sand at Khamisiyah. Although Iraqi soil was 
available and used in the laboratory testing, it was not used in field 
testing. Similarly, assessments of DOD and CIA estimates of the amount 
of spilled agent evaporated from and retained in wooden crates are 
uncertain. This is because Dugway testing officials could not obtain 
actual wood from the Khamisiyah pit site. The aged and possibly damp 
wood at Khamisiyah might have absorbed less agent than the new wood 
used at Dugway. DOD and CIA determined that only about 32 percent of 
the agent was released and that most leaked into the soil and wood, 
with 18 percent of the leakage becoming part of the plume (2 percent 
through aerosolization and 16 percent through evaporation).

Field tests were also conducted at a time of year and time of day 
different from the actual Khamisiyah pit event. According to Dugway 
officials, testing was done in May and in the early morning hours, when 
drainage conditions prevail.[Footnote 24] When the March 10, 1991, U.S. 
demolition operations took place at the Khamisiyah pit, it was late 
afternoon with a mixed layer. The bombings of the other modeled storage 
and production sites often took place during evening and nighttime 
hours, when a stable nocturnal boundary layer emerges.

Despite the uncertainties in approximating the conditions at 
Khamisiyah, DOD and the CIA used these data not only for modeling 
Khamisiyah but also for modeling other sites. At the other sites, the 
CW munitions would have been destroyed by aerial bombings with much 
greater quantities of high-explosive charges and under significantly 
different meteorological conditions.

All Models, Including DOD's Composite Model, Showed Divergent and 
Unresolved Results:

The models DOD used to predict the fallout from Khamisiyah and the 
other sites showed great divergence, even with the same source term 
data. While the models' divergences included plume size and path, DOD 
made no effort to reconcile them (see appendix III). The IDA expert 
panel determined that the results were so divergent that it would not 
be possible to choose the most exposed areas or which U.S. troops might 
potentially have been exposed. IDA therefore recommended a composite 
model, which DOD adopted.[Footnote 25] However, this approach masked 
differences in individual model projections with respect to plume size 
and path.

In addition, DOD chose not to include in the composite model the 
results of the LLNL model, created at the IDA expert panel's request, 
which showed a different and larger plume size and path than DOD's 
models showed. The IDA panel regarded the LLNL model as less capable 
than other models because it modeled atmospheric phenomena with less 
fidelity. Finally, modeling of Khamisiyah that the Air Force Technical 
Applications Center (AFTAC) had done also showed differences from DOD's 
composite model.

LLNL's Model:

To determine plume size and path, LLNL conducted analyses using DOE's 
MATHEW meteorological model with the ADPIC dispersion model. During 
LLNL's presentations to the IDA panel in November 1996 and February 
1997, LLNL provided a 72-hour projection, assuming an instantaneous 
release of the contents of 550 rockets containing sarin (see figure 9). 
The results of LLNL's analyses show the plume covering an area 
extending south southeast from the release point to the Persian Gulf, 
then turning eastward at the Gulf coast, and then turning northeast 
over the Gulf and extending northeastward across central Iran.

Figure 9: Lawrence Livermore National Laboratory Projection:

[See PDF for image]

[End of figure]

LLNL's modeling assessment showed that the 72-hour exposure projection-
-for the instantaneous release of sarin from 550 rockets--covered a 
large hazard area. According to LLNL, 2,255 sq km were covered by agent 
concentration in excess of the dosage expected to cause a person 
minimal effects.[Footnote 26] This area extended approximately 130 km 
south southeast from the release point. Dosages in excess of the amount 
that would be allowed for a worker exposed to sarin in the workplace, 
the occupational limit, were predicted over 114,468 sq km--including 
Kuwait City, an area approximately 200 km wide across the Persian Gulf, 
and the higher elevations of the Zagros Mountain range of western 
Iran.[Footnote 27] The remaining area was determined to be at the 
general population limit.[Footnote 28]

DOD's Composite Model:

DOD's composite model was based on OMEGA and COAMPS meteorological 
models and HPAC/SCIPUFF and VLSTRACK dispersion models. In contrast to 
LLNL's modeling simulations, it showed the plume moving first southerly 
and then turning to the west southwest. The 72-hour plume overlay for 
DOD's composite model, resulting from using the VLSTRACK and HPAC/
SCIPUFF dispersion models with COAMPS and OMEGA meteorological models, 
is shown in figure 10.

Figure 10: DOD Composite Projection:

[See PDF for image]

[End of figure]

Composite modeling may be an appropriate methodology, but DOD's 
composite model understated the number of troops potentially exposed by 
not including the LLNL model. If LLNL's model were included, a far 
larger number of forces would potentially be shown as having been 
exposed (see figure 11). DOD's exclusion of this model seriously skewed 
the outcome of any epidemiological studies done thus far.

Figure 11: DOD Composite Projection and Lawrence Livermore National 
Laboratory Projection:

[See PDF for image]

[End of figure]

Explaining the Models' Divergent Results:

Further research was conducted to determine whether the models' 
divergent results could be explained. It was observed that the 
divergence in the modeling outcomes could be explained by a directional 
split--a line of diffluence--in the independently modeled 10 m wind 
field data near Khamisiyah in the first 2 days of the modeling period. 
While the precise location of this line is critical in determining 
which way the wind would have transported the CW agent, its precise 
location cannot be resolved with any degree of certainty. (Appendix IV 
illustrates this diffluence with three different data sets.):

In addition, DTRA officials said at the time of the modeling that they 
had conducted data-validation analyses of the various models against 
visible smoke plumes from the oil well fires in Kuwait. These analyses 
indicated a definite directional bias, shown in figure 12. This 
validation demonstrates that the actual area covered could have been 
from 10 to 50 degrees to the east and could have affected a different 
population from that indicated by the model results.

Figure 12: Validation Runs of Various Models:

[See PDF for image]

[A] East bias compared with OMEGA/HPAC.

[B] East bias compared with MM5/HPAC.

[C] East bias compared with COAMPS/VLSTRACK.

[End of figure]

In addition, in the 1997 DOD peer review panel report on the Khamisiyah 
models, a panel of experts in meteorological and turbulent diffusion 
modeling stated that the VLSTRACK and SCIPUFF/HPAC results were 
complicated by the use of significantly different source term 
inputs.[Footnote 29] According to DOD, the 2000 modeling used a 
consistent source term for SCIPUFF and VLSTRACK. For VLSTRACK, internal 
source algorithms had been used, while for SCIPUFF, source term inputs 
from the Dugway experiments had been used. These differences would lead 
to significant divergences in the dosage contours the two models 
predicted, which were then used to generate the composite.

In addition, the panel noted, while using a composite model is a valid 
method, successfully applied to other atmospheric modeling problems, 
using a composite model to reconstruct the dosage requires more 
advanced, state-of-the-art, high-resolution models, with the fewest 
physical limitations and assumptions. Furthermore, in 1998, the Air 
Force Human Effectiveness Directorate at Wright-Patterson Air Force 
Base reviewed the Muhammadiyat modeling and found that the work may 
have been flawed. According to the Chief of the Human Effectiveness 
Directorate, the protocol was not correct in that it constituted a 
"plume of plumes, rather than a plume based upon data."

AFTAC Modeling:

AFTAC modeling of Khamisiyah also showed differences from DOD's 
composite model. After DOD's Khamisiyah models were published in 1997, 
the Senate Committee on Veterans' Affairs asked AFTAC to conduct an 
analysis of the event.[Footnote 30] AFTAC is a principal modeling 
agency for DOD and, according to experts, the quality of its modeling 
system is among the highest. To conduct the analysis, AFTAC 
meteorologists used four models from their suite of atmospheric models, 
including two primary transport and diffusion models and the RAMS 
meteorological model.

While AFTAC's analysis was meteorologically consistent with the 
modeling efforts of the CIA and DOD, the results showed that some 
additional areas might have been exposed to at least low-level exposure 
dosages from the Khamisiyah plume. In particular, it showed the plume 
differing in several aspects from the plumes generated by the DOD and 
CIA analyses. Most significantly, the AFTAC plume is shown drifting 
across Kuwait and the northwestern Persian Gulf coast, an area not 
covered by the DOD and CIA plume. AFTAC's analysis was published in a 
report to the Senate Committee on Veterans' Affairs and was provided to 
DOD's Office of the Special Assistant to the Deputy Secretary of 
Defense for Gulf War Illnesses.[Footnote 31] The report recommended 
that AFTAC's results be integrated into the DOD and CIA modeling 
results to depict these additional areas of potential exposure.

However, in 1998, a DOD expert panel reviewed the AFTAC modeling 
simulations and recommended that AFTAC's modeling results not be 
included in DOD's composite plume model, given that (1) AFTAC's 
simulations were generally consistent with DOD's composite model 
results and that the effect of any differences would only have resulted 
in the additional notification of a small number of individuals, (2) 
continuing to refine DOD's modeling process rather than including 
AFTAC's modeling results would be the best use of DOD's resources, and 
(3) the decay capability of the agent in AFTAC's model was still 
immature and would have limited any efforts to identify potentially 
exposed individuals.

The MOD Relied on U.S. Plume Modeling to Determine Its Troops' 
Exposure to CW Agents:

According to British officials, the MOD did not collect any source term 
or meteorological data during the Gulf War. It also did not 
independently model the plume from Khamisiyah, relying instead on the 
1997 DOD and CIA modeling of Khamisiyah. According to British MOD 
officials, however, they were reassessing the extent of British troops' 
exposure, based on DOD's revised 2000 remodeling of Khamisiyah. We 
requested from the British MOD but did not receive information on the 
findings from this reassessment.

Responding to parliamentary concerns and questions raised in 1997, the 
British MOD reviewed the U.S. modeling of demolition operations at 
Khamisiyah, publishing a report in December 1999.[Footnote 32] The MOD 
concluded from the 1997 DOD and CIA composite model of the Khamisiyah 
demolitions that the maximum concentration of agent that British troops 
might have been exposed to was below the level that the most sensitive 
British warning device could have been expected to detect. Moreover, 
according to the MOD, the highest theoretical dosage troops received 
would have been 3.6 times lower than the level at which the first 
noticeable symptoms occur. Finally, the MOD said, this level of 
exposure would have had no detectable effect on health.

The MOD also determined that a number of British troops were within the 
boundary of the plume in the DOD and CIA composite model, and it 
estimated that the total number of British troops potentially exposed 
was about 9,000. The total number of troops definitely within the path 
of the plume, however, was estimated to be about 3,800. In addition, of 
53,500 British troops deployed, at least 44,000 were definitely not 
within the path of the plume. However, since the MOD relied exclusively 
on DOD's modeling and since we found that DOD could not know who was 
and who was not exposed, the MOD cannot know the extent of British 
troops' exposure.

Total U.S. Plume-Modeling Costs:

The CIA and DOD were the primary agencies in the modeling and analysis 
of U.S. troops' exposure from the demolition at Khamisiyah and bombing 
of chemical facilities at Al Muthanna, Muhammadiyat, and Ukhaydir, but 
several other agencies and contractors also participated. Funding to 
support the modeling efforts was provided to various DOD agencies and 
organizations, the military services, and non-DOD agencies and 
contractors. We collected data on the direct costs these agencies 
incurred or funds they spent. Table 5 shows direct costs to the United 
States for modeling the Gulf War of about $13.7 million.

Table 5: U.S. Direct Costs for Modeling Gulf War Illnesses:

Agency or contractor: BAHR Inc; 
Direct costs[A]: $11,796; 
Work done: Reviewed (1) processes and technology used to produce 
estimates of U.S. forces potentially exposed and (2) draft reports on 
Khamisiyah.

Agency or contractor: Central Intelligence Agency; 
Direct costs[A]: [B]; 
Work done: Computer-modeling analysis.

Agency or contractor: Chemical Biological Defense Command, Aberdeen 
Proving Ground; 
Direct costs[A]: 140,000; 
Work done: Wood- surface evaporative modeling and environmental data 
support efforts.

Agency or contractor: Defense Threat Reduction Agency; 
Direct costs[A]: 870,000; 
Work done: Computer-modeling analyses with HPAC/ SCIPUFF dispersion and 
OMEGA weather models.

Agency or contractor: Institute for Defense Analyses; 
Direct costs[A]: 149,429; 
Work done: Convened a panel of experts to review Khamisiyah pit 
modeling analyses.

Agency or contractor: Lawrence Livermore National Laboratory; 
Direct costs[A]: 60,000; 
Work done: Computer-modeling analyses with ADPIC dispersion and MATHEW 
weather models.

Agency or contractor: National Center for Atmospheric Research; 
Direct costs[A]: 308,000; 
Work done: Computer-modeling simulations using MM5 weather model.

Agency or contractor: Naval Research Laboratory; 
Direct costs[A]: 1,090,000; 
Work done: Meteorological analysis to identify downwind hazard 
assessment with NOGAPS and COAMPS weather models.

Agency or contractor: Naval Surface Warfare Center; 
Direct costs[A]: 522,000; 
Work done: Computer-modeling analyses with VLSTRACK dispersion and 
COAMPS weather models.

Agency or contractor: Office of the Special Assistant to the Deputy 
Secretary of Defense for Gulf War Illnesses; 
Direct costs[A]: 7,980,000; 
Work done: Internal costs for producing case narratives for Al 
Muthanna, Khamisiyah, Muhammadiyat, and Ukhaydir.

Agency or contractor: Science Applications International Corporation; 
Direct costs[A]: [C]; 
Work done: Computer-modeling analysis.

Agency or contractor: U.S. Army Center for Health Promotion and 
Preventative Medicine; 
Direct costs[A]: 731,000; 
Work done: Exposure assessment and environmental modeling to determine 
U.S. troops' exposed to chemical releases from multiple incidents 
during the Gulf War.

Agency or contractor: U.S. Army Dugway Proving Ground; 
Direct costs[A]: 1,861,950; 
Work done: Field trials and laboratory testing using 122 mm chemical-
simulant filled rockets to develop source term data for modeling.

Agency or contractor: White Sands Missile Range; 
Direct costs[A]: 2,600; 
Work done: Missiles for testing at Dugway Proving Ground.

Agency or contractor: Total; 
Direct costs[A]: $13,726,775. 

Sources: Agency and contractor responses provided to GAO on their 
modeling and analysis costs.

[A] Direct costs for agencies includes funding for contracts provided 
by the Office of the Special Assistant to the Deputy Secretary of 
Defense for Gulf War Illnesses.

[B] The CIA denied our request for its costs for modeling chemical 
releases from Khamisiyah, as well as Al Muthanna, Muhammadiyat, and 
Ukhaydir.

[C] SAIC did not respond to our requests for information.

[End of table]

Indirect costs were much more difficult to obtain because the modeling 
efforts involved many people, and some were full-time while others were 
part-time. However, these estimates do not include, and DOD could not 
provide, an estimate of the considerable indirect costs involved for 
salaries of DOD and VA staff, contractors, facilities, travel, and 
equipment. In addition, the CIA would not provide us with the direct 
and indirect costs for modeling Gulf War plume and determinations of 
source term because, in its view, our request constituted oversight of 
an intelligence matter and is beyond our scope of authority. The CIA's 
contractor, SAIC, also would not respond to our request for cost 
information.

DOD's and VA's Epidemiological Conclusions on CW Exposure and 
Hospitalization and Mortality Rates Cannot Be Adequately Supported:

DOD and VA each funded an epidemiological study on CW exposure--DOD's 
on hospitalization rates and VA's on mortality rates. From the 
hospitalization study conducted by DOD researchers and the mortality 
study conducted by VA researchers, DOD and VA each concluded that there 
was no significant difference in the rates of hospitalization and 
mortality between exposed and nonexposed troops. These conclusions, 
however, cannot be adequately supported by the available evidence. 
These studies contained two inherent weaknesses: (1) flawed criteria 
for classifying exposure, resulting in classification bias, and (2) an 
insensitive outcome measure, resulting in outcome bias. In addition, 
several other studies of Gulf War veterans, genetics, and animals found 
a strong association between exposure and illnesses.

DOD and VA Used Flawed Criteria for Determining Troops' Exposure:

In the two epidemiological studies, DOD and VA researchers used DOD's 
1997 plume model for determining which troops were under the path of 
the plume--that is, were exposed--and which troops were not--that is, 
were not exposed. However, this classification is flawed, given their 
inappropriate criteria for inclusion and exclusion.

In the hospitalization study, the DOD researchers included 349,291 Army 
troops "coded" as being in the Army on February 21, 1991. However, the 
researchers did not report a cutoff date for inclusion in the study--
that is, they did not indicate whether these troops were in the Persian 
Gulf between January 17, 1991, and March 13, 1991, the period during 
which bombing and demolition took place. Although we requested this 
date, DOD researchers failed to provide it. Finally, the total number 
of 349,291 troops is misleading because many troops left the service 
soon after returning from the Persian Gulf. Moreover, the researchers 
did not conduct any analyses to determine whether those who left were 
in the exposed or nonexposed group (including uncertain low-dose 
exposure or estimated subclinical exposure). Given all the 
methodological problems in this study, it is not possible to accurately 
determine the total number of the exposed and nonexposed groups.

In the mortality study, the VA researchers included 621,902 Gulf War 
veterans who arrived in the Persian Gulf before March 1, 1991. Troops 
who left before January 17, 1991--the beginning of the bombing of Iraqi 
research, production, and storage facilities for CW agents--were 
included in the study. This group was not likely to have been exposed. 
Therefore, including them resulted in VA's overestimation of the 
nonexposed group.

Troops who came after March 1, 1991--the period during which Khamisiyah 
demolition took place--were excluded from the VA study. The Defense 
Manpower Data Center (DMDC) identified 696,000 troops deployed to the 
Persian Gulf, but the mortality study included only the 621,902 troops 
deployed there before March 1, 1991. This decision excluded more than 
74,000 troops, approximately 11 percent of the total deployed. However, 
these troops were most likely to have been exposed. Therefore, 
excluding them resulted in underestimation of the size of the exposed 
group. In addition, 693 troops who were in the exposed group were 
excluded because identifying data, such as Social Security numbers, did 
not match the DMDC database. But VA researchers did not conduct follow-
up analysis to determine whether those who were excluded differed from 
those who were included in ways that would affect the classification.

DOD and VA Used an Insensitive Outcome Measure for Determining 
Hospitalization Rate:

Hospitalization rate--the outcome measure used in the hospitalization 
study--was insensitive because it failed to capture the chronic 
illnesses that Gulf War veterans commonly report but that typically do 
not lead to hospitalization. Studies that rely on this type of outcome 
as an end point are predetermined to overlook any association between 
exposure and illness.

Based on DOD's 1997 plume model, DOD's hospitalization study compared 
the rates for Gulf War veterans who were exposed with the rates for 
those who were not exposed. This study included 349,291 active duty 
Army troops who were deployed to the Persian Gulf. However, DOD 
researchers did not determine the resulting bias in their analyses, 
because they did not account for those who left the service.

The Institute of Medicine noted that the hospitalization study was 
limited to Army troops remaining on active duty and to events occurring 
in military hospitals. Conceivably, those who suffered from Gulf War-
related symptoms might leave active duty voluntarily or might take a 
medical discharge. Hospitalization for this group would be reflected in 
VA or private sector databases but not in DOD databases. The health or 
other characteristics of active duty troops could differ from those of 
troops who left active duty and were treated in nonmilitary hospitals. 
Moreover, economic and other factors not related to health are likely 
to affect the use of nonmilitary hospitals and health care 
services.[Footnote 33]

This limiting of the study to troops remaining on active duty produced 
a type of selection bias known as the healthy warrior effect.[Footnote 
34] It strongly biased the study toward finding no excess 
hospitalization among the active duty Army troops compared with those 
who left the service after the war.

Some Studies Suggest an Association between CW Exposure and Gulf War 
Illnesses:

We found some studies that suggest an association between CW exposure 
and Gulf War illnesses. They are Gulf War veterans studies, genetics 
studies, and animal studies. Each of these studies, described below, 
has strengths and limitations.

Gulf War Veterans Studies:

In a privately funded study, Haley and colleagues reported an 
association between a syndromic case definition of Gulf War illnesses, 
developed to model the ill veterans' symptomatic complaints, with 
exposure to CW agents.[Footnote 35] In this study, the authors 
developed questionnaires on symptoms and environmental exposure 
identified in pilot studies of ill Gulf War veterans, similar to 
epidemic investigations by the Centers for Disease Control and 
Prevention (CDC).[Footnote 36] These questionnaires were given to 249 
troops from a U.S. Navy Mobile Construction Battalion that participated 
in the Gulf War. Factor analysis of the data on symptoms was used to 
derive a case definition identifying six syndrome factors.[Footnote 37] 
Three syndrome factor variants found to be the most significant were 
(1) impaired cognition, (2) confusion-ataxia, and (3) arthro-myo-
neuropathy.

Impaired cognition (syndrome 1) was associated with troops' having worn 
flea collars that contained chlorpyrifos.[Footnote 38] Confusion-
ataxia (syndrome 2), the most severe clinically, was associated with 
three risk factors.[Footnote 39] The first was likely CW exposure; the 
second was the geographic location near the Saudi-Kuwaiti border around 
the fourth day of the air war, conducted January 18-23, 1991, when 
Czech chemical detection units detected sarin and mustard in ambient 
air near the Saudi-Kuwaiti border; and the third was side effects 
experienced after taking pyridostigmine. There was also a significant 
synergistic association between likely exposure to CW agents and the 
number of side effects from pyridostigmine.[Footnote 40] Arthro-myo-
neuropathy (syndrome 3) was associated with the amount of exposure to 
95 percent DEET in ethanol insect repellent and with the number of side 
effects of pyridostigmine.[Footnote 41]

The inference that these risk-factor associations represent causal 
effects is supported by (1) the large, highly significant relative 
risks; (2) the dose-response effects; and (3) the synergistic effect of 
the risk factor associations with the syndromic case definition. Risk 
factors found not to be significantly associated with the case 
definition include environmental pesticides, pesticides in uniforms, 
antibiotic or antimalarial prophylaxis, multiple immunizations, smoke 
from oil well fires, fumes from jet fuel, fumes from burning jet fuel 
in tents, petroleum in drinking water, depleted uranium munitions, 
smoking, alcohol use, and combat exposure.

Another study of Gulf War veterans by Nisenbaum and colleagues, funded 
by CDC, examined the risk factors in 1,002 Air Force 
reservists.[Footnote 42] They found, first, that the case definition of 
Fukuda and colleagues of "multisymptom illness" was strongly associated 
with at least one of the three chronic symptom groups fatigue, mood/
cognition, and musculoskeletal pain. And, next, they found that 
reported exposure to CW agents was most strongly associated with the 
"severe illness" case definition of Fukuda and colleagues and less 
strongly associated with their "mild-moderate illness" case 
definition.[Footnote 43]

Both case definitions were less strongly associated with the use of 
insect repellent (p = 0.006), the use of pyridostigmine (p = 0.01), and 
having an injury requiring medical attention (p = 0.03). But neither 
case definition was associated with smoke from oil well fires, coming 
under attack, seeing casualties, or having adverse health events in the 
family. The findings were attributed to the effects of stress but 
offered no empirical support for the explanation.

In a study that VA funded, Proctor and colleagues compared the exposure 
histories of 186 Gulf War veterans from Fort Devens, Massachusetts, and 
66 from New Orleans, including 48 who deployed only to Germany. 
Collectively, the 252 veterans are known as the Massachusetts-New 
Orleans cohort.[Footnote 44] The case definition was a set of eight 
body-system symptom scores (BSS, distributed from 0 to 4), each 
constructed by summing the 5-point frequency-of-occurrence scales (0 = 
occurs never, 4 = occurs almost every day) for three symptoms typical 
of a particular body system. The eight body systems were cardiac, 
dermatological, gastrointestinal, musculoskeletal, neurological, 
neuropsychological, psychological, and pulmonary. Post-traumatic 
stress disorder (PTSD) was diagnosed with the structural clinical 
interviews, Clinician Administered Posttraumatic Stress (CAPS) 
disorder scale, or a Mississippi Scale score of >89. The symptoms were 
obtained from the 52-item Expanded Health Symptom Checklist, the 
exposure measures from an environmental exposure questionnaire and an 
Expanded Combat Exposure Scale (CES) questionnaire. Multiple regression 
analysis--controlling for age, sex, education, study site, Expanded CES 
score, and PTSD status--was used to develop a risk-factor model for 
each BSS scale.

Exposure to CW agents and debris from SCUD missiles was associated with 
four BSS scales; exposure to smoke from tent heaters, with three BSS 
scales; exposure to pesticides, vehicle exhaust, and burning human 
waste, with two BSS scales; the Expanded CES, with only one BSS scale; 
and exposure to pyridostigmine bromide (antinerve gas pills) and smoke 
from oil well fires, with no BSS scale. Controlling for depression 
scores and excluding veterans diagnosed with PTSD did not substantially 
affect the associations.

Three additional studies conducted with VA and DOD funding extended the 
risk-factor research for the Massachusetts-New Orleans cohort. The 
association of self-reported CW agent (nerve agent) exposure was tested 
with different formulations of the case definition. White and 
colleagues used psychological and neuropsychological tests to define 
illness. They found that exposure to CW agents was associated with 
abnormal measures of mood, memory, and attention or executive 
function.[Footnote 45] Associations remained significant after 
controlling for age, sex, race, years of education, repeated grade in 
school, head injury, medication use, diagnosis of current PTSD (by 
CAPS), diagnosis of current depression (by structural clinical 
interviews), active duty versus Reserve or Guard status, seeking 
disability rating, and Vietnam service.

Lindem and colleagues developed multiple regression models for 
neuropsychological test measures as case definitions of Gulf War 
illnesses.[Footnote 46] Chemical warfare agent exposure was found to be 
associated with attention and executive function (continuous 
performance test), delayed verbal recall (California Verbal Learning 
Test and Visual Reproduction Test), and confusion and fatigue (Profile 
of Mood States). These associations remained significant when 
controlling for age, education, and PTSD diagnosis (by CAPS).

Wolfe and colleagues, studying 945 troops from the Massachusetts-New 
Orleans cohort, found that the CDC case definition of multisymptom 
illness was most strongly associated with having smelled a chemical 
odor, having taken up to 21 antinerve gas pills, or having experienced 
up to 10 formal alerts for CW agent attack.[Footnote 47]

Kang and colleagues conducted a random sample mail survey that VA 
funded. Obtaining responses from 11,441 Gulf War veterans and 9,476 
nondeployed Gulf War era veterans, they developed a case definition by 
factor analysis of symptoms measured by their questionnaire.[Footnote 
48] The first three syndrome factors closely resembled those that Haley 
and others derived (noted earlier). Finding that syndrome 2 was unique 
to the sample that had been deployed in the Gulf War (found in the 
deployed, but not the nondeployed, sample) and that the component 
symptoms were neurological in character, the researchers termed their 
syndrome 2 a possible unique Gulf War neurological syndrome. Four 
symptoms--blurred vision, loss of balance or dizziness, tremor or 
shaking, and speech difficulties--were associated with syndrome 2 only 
in the deployed sample. Consequently, Kang and colleagues established 
their case definition as having all four of these symptoms. In the 
deployed sample, 277 met the case definition and 6,730 who had none of 
the four symptoms constituted the control group. Of a large number of 
risk factors analyzed, only nine were associated with the case 
definition, with an odds ratio greater than 3.0. Of these, perceived 
exposure to nerve agent had the strongest association (odds ratio 15.1, 
95 percent, CI 11.5-19.9, p < 0.000001). This finding--a neurological 
syndrome appearing as the second factor in a factor analysis and being 
the most strongly associated risk factor, 15 times more common in ill 
veterans meeting the case definition than in controls--closely 
parallels the findings of Haley and colleagues. The finding received 
little notice, however, because the VA-funded mail survey did not (1) 
provide the odds ratio values in the table reporting the risk factor 
analysis results and (2) describe the finding in the text or abstract 
of the paper. When we noticed the finding, we manually calculated the 
odds ratios from the raw data in the table.

Smith and colleagues showed that hospitalization rates for several ICD-
9 diagnoses were higher in veterans categorized in the Khamisiyah 2000 
plume than in those not in the plume, and the association for cardiac 
arrhythmias was statistically significant. However, this study suffers 
from the same deficiencies as the earlier study that we cited: use, 
inappropriately, of hospitalization outcome measures rather than 
measures of Gulf War illness, which usually do not result in 
hospitalization, and use of plume modeling based on flawed 
data.[Footnote 49]

The 2002 Kang and Bullman study has not been published in a peer-
reviewed journal and therefore should not have been included in a 
review of the scientific epidemiologic literature. The DOD studies were 
invalid for two reasons: (1) Hospitalization and mortality were 
inappropriate outcomes because they do not measure Gulf War illnesses, 
which often do not lead to hospitalization, and (2) The DOD studies, no 
matter how powerful their techniques, could not control for the 
selection bias that resulted from the disproportionate early discharge 
of the ill Gulf War veterans soon after the Gulf War. Including only 
DOD hospital records of service members remaining on active duty 
resulted in the exclusion of veterans who left service for poor health. 
No amount of sophisticated techniques can correct for this selection 
bias toward finding no difference.[Footnote 50]

Genetics Studies:

In one genetics study, Haley and colleagues found an association 
between the case definition of Gulf War illnesses in U.S. Gulf War 
veterans and low blood levels of the Q-type isoenzyme of the 
paraoxonase/arylesterase enzyme group (PON).[Footnote 51] The PON group 
of enzymes is a potentially important predisposing factor in Gulf War 
illnesses because one of its major functions in normal body physiology 
is to protect the nervous system from organophosphate chemical toxins, 
such as pesticides and nerve agents. This finding was remarkable 
because the only function of Q type of the PON enzyme group is to 
protect the nervous system from nerve agents sarin, soman, tabun, and 
VX. The R-type isoenzyme has as its main function protection from 
organophosphate pesticides, such as diazinon, malathion, and parathion. 
Thus, an association between Gulf War illnesses and blood levels of 
only the Q-type isoenzyme of PON points specifically to nerve agent 
exposure. In addition, the total PON level--that is, the sum of the Q 
and R isoenzyme levels--was not associated with the illnesses. And the 
genotype (QQ, QR, or RR) was only marginally associated with them, as 
expected, because the level of the Q-type isoenzyme is a more important 
determinant of susceptibility to nerve agents than the genotype.

In another genetics study, Mackness and colleagues reported lower blood 
levels of total PON in ill British Gulf War veterans than in civilian 
controls in a previously published study; however, they did not measure 
the blood levels of the Q and R isoenzymes of PON, needed for a 
definitive study of Haley's hypothesis.[Footnote 52] This finding could 
indicate that ill British Gulf War veterans represented a mixture of 
some with low Q-type PON and others with low R-type PON. In some 
veterans, the illness would be associated with exposure to nerve 
agents; in others, with exposure to pesticides. Alternatively, the 
difference in total PON levels may have resulted from differences in 
the assays or in the veterans, since (1) the enzyme assays in the 
controls were performed years before those for the ill veterans and (2) 
the controls were civilians studied in an entirely different setting.

In yet a third genetics study, Hotopf and colleagues reported results 
of tests for total PON levels in blood samples--obtained in a study by 
Unwin and colleagues--for four groups of British troops: (1) ill 
veterans of the Gulf War, (2) well veterans of the Gulf War, (3) ill 
nondeployed veterans of the Gulf War era, and (4) ill veterans of the 
Bosnian conflict.[Footnote 53] The case definition of illness was a 
score below 72.2 on the SF-36 Physical Status questionnaire. Again, the 
researchers did not measure the levels of the Q and R isoenzymes of 
PON, making the findings difficult to interpret. The researchers found 
a low mean level of total PON in both ill and well groups deployed to 
the Gulf War and higher levels in the Gulf War era and ill Bosnian 
groups.

The depressing of the total PON level, the researchers suggested, might 
be the result of some deployment-related exposures. However, instead of 
looking at exposure to CW agents, the researchers investigated the 
possible effect of multiple immunizations on total PON levels and found 
no evidence for it. An alternative explanation is that total PON level 
in both ill and well deployed veterans was the result of 
misclassification of veterans by the case definition. A score of 72.2 
on the SF-36 scale is not a very low score, particularly in ill Gulf 
War veterans, and it is a nonspecific measure of illness, given that a 
low score indicates illness from any cause.[Footnote 54] Consequently, 
many veterans ill from causes unrelated to the war would be 
misclassified as cases of Gulf War illness and, conversely, many ill 
from the war but with less disability would be misclassified as 
controls. This conclusion is supported by a nonsignificant trend 
showing that ill veterans who had been deployed to the Gulf War had a 
lower median total PON level than well veterans who had also been 
deployed to the Gulf War.

The many flaws of design and methodology in both British studies of PON 
levels do not contribute to an understanding of the PON hypothesis and 
leave the finding of Haley and colleagues in need of better 
replication.

Animal Studies:

A series of laboratory studies with animals have established the 
biological plausibility that brain cell damage results from low-level 
exposure to sarin. Husain and colleagues demonstrated in two studies at 
the Division of Pharmacology and Toxicology at the Defense Research and 
Development Establishment in Gwalior, India, that repetitive 
administration of low-dose sarin (approximately 0.25 LD50) daily for 10 
days caused delayed onset damage to neurons in the spinal cords and 
brains of mice exposed by inhalation and of hens exposed by 
subcutaneous injection.[Footnote 55]

Privately funded studies by Abou-Donia and colleagues demonstrated that 
combinations of organophosphates and similar cholinesterase-inhibiting 
chemicals in hens produce greater neurotoxic effect on brain and nerve 
tissue than any of the agents alone.[Footnote 56] Abou-Donia's 
subsequent work, funded by DOD, extended the findings to synergistic 
combinations involving sarin at moderate concentrations (0.5 
LD50).[Footnote 57] A similar study by Husain and Somani, also funded 
by DOD, on the delayed brain effects of low-dose sarin (0.05 LD50) in 
combination with pyridostigmine and exercise, confirmed these findings. 
In particular, it demonstrated that the neuronal damage from very low 
doses of sarin affected primarily the basal ganglia region of the brain 
(striatum).[Footnote 58]

A study by Henderson and colleagues, with DOD funding, found that 
repeated inhalation exposure to low-level sarin at subsymptomatic doses 
(0.1 LCt50) for 5 or 10 days, with or without heat stress, produced no 
immediate effects.[Footnote 59] But at 30 days after exposure to sarin, 
damage was produced to cholinergic receptors in several brain regions, 
including the basal ganglia. In the same study, Henderson and 
colleagues identified evidence of an autonomic nervous system injury 
affecting the function of T-cells in the immune system as 
well.[Footnote 60] In addition, chronic abnormalities of neuronal 
metabolism in the basal ganglia have been implicated in ill Gulf War 
veterans by several investigators through the use of magnetic resonance 
spectroscopy.[Footnote 61]

Two recent laboratory studies at the U.S. Army Medical Research 
Institute of Chemical Defense, Aberdeen Proving Ground, support the 
animal studies. Scremin and colleagues demonstrated that moderate doses 
of sarin (0.5 LD50) in combination with pyridostigmine bromide produced 
prolonged elevations in rats' cerebral blood flow but that neither 
agent alone had a prolonged effect on cerebral blood flow.[Footnote 62] 
A companion study, by Roberson and colleagues, demonstrated that 
repeated administration of sarin to guinea pigs in doses of 0.2 or 0.4 
LD50 produced no immediate ill effects on behavior, weight, body 
temperature, flinch threshold, or EEG brain wave activity. But at 100 
days postdosing, abnormal brain function was found, indicating 
neurochemical or pathological brain cell changes that affect 
behavior.[Footnote 63]

Conclusions:

In evaluating the weaknesses of the plume models, we conclude that the 
results from the CIA and DOD modeling can never be definitive. Plume 
models can allow only estimates of what happens when CW agents are 
released in the environment. Such estimates are based on mathematical 
equations, which are used to predict an actual event--in this case, the 
direction and extent of the plume. However, in order to predict 
precisely what happens, one needs to have accurate data on source term 
and meteorological conditions. DOD had neither of these.

Given the unreliability of the input data, the lack of troop location 
data, and the divergent results of modeling, DOD's analyses cannot 
adequately determine the extent of U.S. troops' exposure. In 
particular, the models selected were not fully developed for projecting 
long-range environmental fallout, and the assumptions used to provide 
the source term data were flawed. Even when models used the same source 
term data, their results diverged. In addition, the models did not 
include many potential exposure events and some key materials--for 
example, binary chemical weapons, mustard agent combustion by-products, 
and CW agent precursor materials. It is likely that if models were more 
fully developed, and if more credible data for source term and 
meteorological conditions were included in them, particularly with 
respect to plume height as well as level and duration of exposure, the 
hazard area would be much larger and most likely would cover most of 
the areas where U.S. troops and Coalition forces were deployed. 
However, given the lack of verifiable data for analysis, it is unlikely 
that any further modeling efforts would be more accurate or helpful.

The results of DOD's modeling efforts were, nonetheless, used in 
epidemiological studies to determine the troops' CW exposure 
classification--exposed versus nonexposed. As we noted in 1997, to 
ascertain the causes of veterans' illnesses, it is imperative that 
investigators have valid and reliable data on exposure, especially for 
low-level or intermittent exposures to CW agents.[Footnote 64] To the 
extent that veterans are misclassified as to exposure, relationships 
will be obscured and conclusions misleading. In addition, DOD combined 
the results of individual models that showed smaller plume size and 
ignored the results of the LLNL model, which showed much larger plume 
size. Given the uncertainties in source term data and divergences in 
model results, DOD cannot determine--with any degree of certainty--the 
size and path of the plumes or who was or who was not exposed.

Recommendations for Executive Action:

We recommend that the Secretary of Defense and the Secretary of 
Veterans Affairs not use the plume-modeling data for future 
epidemiological studies of the 1991 Gulf War, since VA and DOD cannot 
know from the flawed plume modeling who was and who was not exposed.

We recommend that the Secretary of Defense require no further plume 
modeling of Khamisiyah and the other sites bombed during the 1991 Gulf 
War in order to determine troops' exposure. Given the uncertainties in 
the source term and meteorological data, additional modeling of the 
various sites bombed would likely result in additional cost while still 
not providing DOD with any definitive data on who was or was not 
exposed.

Agency Comments and Our Evaluation:

We obtained comments on a draft of this report from VA, DOD, and the 
CIA. VA concurred with our first recommendation (see appendix V). 
Nevertheless, VA stated that it has already completed three studies 
that incorporated the DOD plume model as part of the parameters for the 
research and has submitted these studies to scientific journals for 
publication. In addition, VA is currently collaborating with other 
research groups that may have used the DOD plume model. These studies 
are under way and will be completed as planned. Given our assessment, 
it is important that VA inform the researchers to include appropriate 
caveats, indicating the limitation of the conclusions based on flawed 
modeling data.

DOD did not concur with our first recommendation, indicating that the 
"GAO recommendation apparently represents a blanket prohibition against 
plume modeling in the future, where the limitations of the 1991 Gulf 
War may not apply" (see page 77). The intent of our recommendation was 
directed only at epidemiological studies involving the DOD and CIA 
plume modeling data from the 1991 Gulf War and was not a blanket 
prohibition of plume modeling in the future (see appendix VI). We have 
clarified the recommendation along these lines.

The CIA did not concur with the report, indicating that it could not 
complete a review in the time allotted. The CIA indicated that a 
comprehensive review would require 3 to 4 weeks. Nevertheless, from its 
preliminary review of our report, the CIA identified several statements 
that it considered inaccurate, such as those about source term data. 
The CIA contended that the agent source term is complete and accurate 
to a known certainty. Since our initiation of this inquiry in late 
2002, we have met with the CIA on a number of occasions, most recently 
on April 7, 2004, to identify the methodologies pursued in establishing 
source term parameters used in the modeling. At the suggestion of the 
CIA, we met with UNMOVIC officials to determine what UNSCOM inspections 
disclosed and the methodologies used in determining source term data.

Our point-by-point evaluation of the detailed comments provided by DOD 
are presented in appendix VI.

As we agreed with your offices, unless you publicly announce the 
contents of this report earlier, we plan no further distribution until 
30 days from its issue date. We will then send copies of the report to 
other interested congressional members and committees. In addition, the 
report will be available at no charge on GAO's Web site at http://
www.gao.gov.

If you or your staff have any questions about this report or would like 
additional information, please contact me at (202) 512-6412 or Sushil 
Sharma, Ph.D., Dr.PH., at (202) 512-3460. We can also be reached by e-
mail at rhodesk@gao.gov and sharmas@gao.gov.

Individuals who made key contributions to this report were Venkareddy 
Chennareddy, Susan Conlon, Neil Doherty, Jason Fong, Penny Pickett, 
Laurel Rabin, Katherine Raheb, and Joan Vogel. James J. Tuite III, a 
GAO consultant and recognized expert on Gulf War issues, provided 
technical expertise.

Signed by: 

Keith Rhodes, Chief Technologist: 
Center for Technology and Engineering: 
Applied Research and Methods:

[End of section]

Appendix I: DOD's Chronology of Khamisiyah Modeling Events:

Date: 1995: June; 
Event: DOD formed the Persian Gulf Illnesses Investigation Team; 
by October, it had identified some of the U.S. forces that had occupied 
the area around Khamisiyah during the Gulf War, including the 37th 
Engineer Battalion.

Date: 1995: Aug; 
Event: President Bill Clinton created the Presidential Advisory 
Committee on Gulf War Veterans' Illnesses.

Date: 1996: Spring; 
Event: The Presidential Advisory Committee on Gulf War Veterans' 
Illnesses directed the CIA to model chemical agent release from Bunker 
73.

Date: 1996: May; 
Event: UNSCOM inspected Khamisiyah.

Date: 1996: June; 
Event: DOD confirmed publicly that "US soldiers from the 37th Engineer 
Battalion destroyed ammunition bunkers [at Khamisiyah] in early March 
1991.. It now appears that one of these destroyed bunkers contained 
chemical weapons".

Date: 1996: July; 
Event: The CIA briefed the Presidential Advisory Committee on Bunker 73 
modeling results.

Date: 1996: Oct; 
Event: The CIA requested LLNL to perform atmospheric dispersion 
calculations, using a hypothetical release scenario; the Deputy 
Secretary of Defense sent a memorandum to 21,000 veterans who had been 
identified as being within 50 km of Khamisiyah.

Date: 1996: Nov; 
Event: The Secretary of Defense established the Office of the Special 
Assistant for Gulf War Illnesses (OSAGWI) to focus ongoing DOD 
investigations and expand the investigation into Gulf War veterans' 
complaints of undiagnosed illnesses.

Date: 1996: Dec; 
Event: IDA released its interim report, critical of the model the CIA 
used; it recommended rocket demolition testing to determine how rockets 
behaved without high explosives and an ensemble approach with 
prognostic models.

Date: 1997: Jan; 
Event: The Deputy Secretary of Defense sent letters with a survey to 
veterans, saying that chemical weapons had been present at Khamisiyah 
when the demolitions occurred and urging them to call the Persian Gulf 
Incident Hotline with any additional information they had about 
Khamisiyah.

Date: 1997: Jan.-Feb; 
Event: The Special Assistant agreed to remodel Khamisiyah, as well as 
Al Muthanna, Muhammadiyat, and Ukhaydir, following entreaties by the 
Presidential Advisory Committee on Gulf War Veterans' Illnesses and 
IDA's recommendations.

Date: 1997: May; 
Event: DOD and the CIA conducted open-field demolition tests on 122 mm 
rockets similar to those destroyed in the Khamisiyah pit at Dugway 
Proving Ground, Utah, to determine how CW agents in Iraq's rockets 
might have been released.

Date: 1997: May (to June 1998); 
Event: The Department of the Army and OSAGWI hosted G3/S3 conferences 
to elicit more correct information on unit locations during the war.

Date: 1997: June-July; 
Event: CW agent release was modeled at the pit.

Date: 1997: July; 
Event: IDA released its final report, "Report of the Panel Reviewing 
Analysis of the Khamisiyah Pit Release of Nerve Agent, March 1991"; 
DOD and the CIA jointly announced the results of Khamisiyah dispersion 
modeling. Given the unit locations available then, the modeling 
indicated a hazard area where troops may have been exposed to low 
levels of nerve agent. DOD sent written notices to 98,910 veterans in 
the potential hazard area and approximately 10,000 notices to those who 
had received the Deputy Secretary of Defense's letter and survey but 
were not in the potential hazard area.

Date: 1997: Dec; 
Event: An independent scientific panel (Anthes and others) reviewed and 
commented on the methodology used to complete the Khamisiyah modeling, 
making recommendations for improvements in future modeling[A].

Date: 1998: Jan; 
Event: President Clinton created the Presidential Special Oversight 
Board for the Department of Defense Investigations of Gulf War Chemical 
and Biological Incidents to provide recommendations, based on its 
review of DOD investigations into possible detection of, and exposures 
to, chemical or biological weapons agents, as well as environmental and 
other factors that might have contributed to Gulf War illnesses.

Date: 2000: Jan; 
Event: DOD completed efforts to remodel the Khamisiyah release using 
updated meteorological and dispersion models, with revised source terms 
from the CIA and with a better understanding of where U.S. forces had 
been. As a result, DOD's estimate of the number possibly exposed 
increased by about 2,000; almost 35,000 troops who had previously been 
notified of possible exposure were no longer in the possible hazard 
area, whereas about 37,000 newly identified troops probably were.

Date: 2000: Mar; 
Event: The scientific review committee completed its review of the 
revised methodology, commenting that "the methodologies are sound" and 
"the results .. very likely overestimate the dosages actually received 
by personnel".

Date: 2002: Apr; 
Event: DOD published its final Khamisiyah report, with complete 
technical report documenting methodologies. 

Source: Department of Defense, Office of the Assistant Secretary of 
Defense for Health Affairs, Deployment Health Support Directorate.

[A] Richard A. Anthes and others, "Comments by Review Panel on 
Khamisiyah Modeling Report and Presentations on November 4-5, 1997," 
report for the Directorate for Deployment Health Support of the Special 
Assistant to the Under Secretary of Defense (Personnel and Readiness) 
for Gulf War Illnesses, Medical Readiness, and Military Deployments, 
Fairfax, Virginia, December 11, 1997.

[End of table]

[End of section]

Appendix II: Power-Law Formula:

A 1969 Sandia National Laboratories empirical study established a 
power-law formula for calculating plume heights attributable to high-
explosive detonations. The power-law formula was derived from data on 
23 test shots, ranging from 140 lbs. to 2,242 lbs. of high explosives 
at DOE's Nevada Test Site (the National Exercise, Test, and Training 
Center), and it provides a cloud-top height at 2 minutes after 
detonation. Most of the shots were detonated during near-neutral 
conditions, where the clouds continued to rise after 2 minutes; data 
for 5 minutes after detonation on some shots show tops rising to nearly 
double the 2-minute values. The 2-minute values better represent the 
final cloud-top heights during stable conditions.

This formula is represented as:

h = 76 (w^1/4):

where:

h = height of plume in meters and:

w = weight of explosives in pounds:

According to this formula, an MK-84 or GBU-24 bomb (942.6 lbs. of high 
explosives) would generate a plume of 421 meters:

h = 76 (942.6 pounds of high explosives)^1/4:

h = 76 (5.541):

h 421 meters:

[End of section]

Appendix III: DOD's Model Divergences:

Even among the models selected for use by the DOD panel, widely 
divergent directional outcomes were observed. For example, in figure 
13, the differences among various models for hazard areas during the 
first 2 days of the modeling period for Khamisiyah can be seen.

Figure 13: Divergence in Models Used to Construct DOD and CIA Composite 
Analyses:

[See PDF for image]

[End of figure]

In the March 10, 1991, section of the figure, an approximately 40 to 45 
degree divergence between the HPAC/OMEGA and the HPAC/COAMPS models can 
be seen; in the March 11, 1991, section, an approximately 80 degree 
divergence can be seen.

The uncertainty attributed to this divergence is not limited to the 
Khamisiyah modeling. According to a modeling analyst involved with the 
modeling of Al Muthanna, the COAMPS and OMEGA weather models showed the 
plume going in different directions, at a difference of 110 to 120 
degrees. According to the analyst, COAMPS showed the plume going north 
northwest, while OMEGA showed it going south. Similar divergence among 
model projections was also observed in the modeling of Muhammadiyat, as 
shown in figure 14.

Figure 14: Divergence in DOD Muhammadiyat Models:

[See PDF for image]

[End of figure]

[End of section]

Appendix IV: Divergence and Wind Field Models:

In figure 15, LLNL projections for divergence of wind field vectors 6.0 
m above terrain are based on observational data the Meteorological Data 
Interpolation Code (MEDIC) model processed.

Figure 15: Lawrence Livermore National Laboratory Diagnostic Wind 
Model, Based on Observational Data:

[See PDF for image]

[End of figure]

Figure 16 shows the wind field vector model, based on European Centre 
for Medium-Range Weather Forecast (ECMWF) projections and processed by 
the MEDIC model.

Figure 16: Lawrence Livermore National Laboratory Diagnostic Wind 
Model, Based on ECMWF Projections:

[See PDF for image]

[End of figure]

The wind field vector model in figure 17 is based on COAMPS simulations 
at the U.S. Naval Research Laboratories.

Figure 17: Wind Field Vector Model, Based on COAMPS:

[See PDF for image]

[End of figure]

[End of section]

Appendix V: Comments from the Department of Veterans Affairs:

THE SECRETARY OF VETERANS AFFAIRS 
WASHINGTON:

May 26, 2004:

Mr. Keith Rhodes: 
Chief Technologist: 
Center for Technology and Engineering:
Acquisition and Sourcing Management Team: 
U.S. General Accounting Office:
441 G Street, NW Washington, DC 20548:

Dear Mr Rhodes:

The Department of Veterans Affairs (VA) has reviewed your draft report, 
GULF WAR ILLNESSES: DOD's Conclusions about U. S. Troops' Exposure 
Cannot Be Adequately Supported (GAO-04-159) and concurs with your 
recommendation to no longer use the nuclear, biological, chemical (NBC) 
plume model in future research studies on Gulf War veterans illnesses.

Nevertheless, it should be understood that VA has already completed 
three studies that incorporated the Department of Defense NBC plume 
model as part of the parameters for the research. In fact, VA has 
submitted these studies to scientific journals. Furthermore, VA is 
currently collaborating with other research groups that may have used 
the NBC plume model. These studies are underway and will be completed 
as planned.

The Department appreciates the opportunity to comment on your draft 
report.

Sincerely yours,

Signed by: 

Anthony J. Principi:

[End of section]

Appendix VI: Comments from the Department of Defense:

Note: GAO comments supplementing those in the report text appear at the 
end of this appendix.

ASSISTANT TO THE SECRETARY OF DEFENSE:
NUCLEAR AND CHEMICAL AND BIOLOGICAL DEFENSE PROGRAMS:

3050 DEFENSE PENTAGON 
WASHINGTON, DC 20301-3050:


MAY 21 2004:

Mr. Keith Rhodes: 
Chief Technologist Center for Technology and Engineering, 
Applied Research and Methods:

U. S. General Accounting Office: 
441 G Street, N.W. 
Washington, DC 20548:

Dear Mr. Rhodes:

This is the Department of Defense (DoD) response to the General 
Accounting Office (GAO) draft report, "GULF WAR ILLNESSES: DoD's 
Conclusions About U.S. Troops' Exposure Cannot Be Adequately 
Supported," dated May 11, 2004 (GAO Code 460530/GAO-04-159). The 
Department non-concurs with the first recommendation and concurs with 
the second recommendation. A detailed analysis explaining DoD's non-
concurrence and comments to the report for clarification purposes is 
enclosed.

We appreciate the opportunity to comment on the draft report. My point 
of contact for this report is Mr.Wayne Davis at (703) 697-5561, 
wayne.davis@osd.mil.

Sincerely,

Signed for: 

Klaus O. Schafer, MD, MPH:

Deputy for Chemical/Biological Defense 
Acting:

Enclosure: As stated:

GAO DRAFT REPORT - DATED MAY 11, 2004 GAO CODE 460530/GAO-04-159:

"GULF WAR ILLNESSES: DOD'S CONCLUSIONS ABOUT U.S. TROOPS' EXPOSURE 
CANNOT BE ADEQUATELY SUPPORTED":

DEPARTMENT OF DEFENSE COMMENTS TO THE REPORT:

Meteorological and dispersion models are powerful tools to study 
various atmospheric phenomena such as weather forecast, global climate 
change, and fate of chemical and biological agents once released into 
the atmosphere. State-of-the-art meteorological models are highly 
sophisticated because they need to account for a myriad of inter-
dependent atmospheric processes. Dispersion models also need to deal 
with inherently random, turbulent processes. Despite these challenges, 
meteorological and dispersion models continue to improve and make 
valuable contributions to many DoD missions. For example, during the 
2000 Presidential Inauguration in Washington, D.C., and the 2002 Winter 
Olympics in Salt Lake City, a suite of meteorological and dispersion 
models were run continuously to provide critical information in the 
event of a possible terrorist attack. During Operation Iraqi Freedom, a 
suite of meteorological and dispersion models run continuously to 
support many military operations.

The outputs of DoD models, as with all models, are limited and 
inherently uncertain as a result of the random, turbulent, and complex 
processes that are modeled, as well as a result of the data that feeds 
the models, which may be incomplete, absent, or uncertain. It is the 
strength of the DoD modeling process in 2000 to study the events of the 
1991 Gulf War that we use a disciplined, scientific process based on 
independent peer review to yield modeling results that are validated, 
and that limits bias in model design and defines limits of uncertainty. 
The Department accepts that uncertainty exists in models and source 
terms. Epidemiological and other studies based on DoD dispersion models 
recognize the inherent uncertainty. However, the Department does not 
accept the thesis posited in the GAO report that the existence of 
uncertainty is an indication of a "flawed" model nor that such models 
have limited or no value to support studies and assessments.

RECOMMENDATION 1: The GAO recommended that the Secretary of Defense not 
use the plume-modeling data for future epidemiological studies, since 
DOD cannot know from the flawed plume modeling who was and who was not 
exposed.

DOD RESPONSE: We recognize that modeling the possible chemical warfare 
agent releases during the 1991 Gulf War was an extremely difficult task 
due to lack of measured source data and onsite meteorological data. 
Nevertheless, the use of state-of-the-art, validated computer modeling 
techniques is the most feasible option to determine what might have 
happened. Computer modeling is routinely used to address many important 
issues. One such example is global climate change, where obviously 
future source and meteorological data are unavailable, and yet 
important economic and environmental policies must be made based on the 
results of computer modeling. Another example is the collateral damage 
analysis before bombing missions or military operations, where again 
the actual source and meteorological data would be unavailable.

The Department believes that to implement this recommendation would 
display negligence, by ignoring potentially beneficial analytic tools, 
and demonstrate a disregard for the safety, health, and welfare of the 
members of the military Services and veterans. Additionally, the 
implementation of this recommendation would replace any rational basis 
for epidemiological assessment with an irrational basis for such 
studies, namely, assessments of those potentially exposed based on 
incomplete data without logical extrapolation to probable areas of 
exposure.

We take exception to the term "flawed" in reference to the models. The 
modeling was not flawed. While the models were not able to counter the 
lack of information on the source terms or eliminate the inherent 
uncertainty in calculating for atmospheric turbulence, the models have 
been extensively and independently validated. The presence of 
uncertainty is a condition of all models. It does not indicate a flaw.

The GAO recommendation apparently represents a blanket prohibition 
against plume modeling in the future, where the limitations of the 1991 
Gulf War may not apply. Certainly, the narrow breadth of this audit 
does not support such a sweeping recommendation that extends well 
beyond incidents related to the 1991 Gulf War. The GAO cannot rule out 
that a future incident may present good source and meteorological data. 
The DoD may have even greater confidence in modeling and its ability to 
answer questions or predict the outcome or impact of events. Moreover, 
there is the risk of this recommendation spilling over into other areas 
beyond epidemiology - to other areas where modeling is used for 
planning purposes.

RECOMMENDATION 2: The GAO recommended that the Secretary of Defense 
require no further plume modeling of Khamisiyah and the sites bombed 
during the 1991 Gulf War in order to determine troops' exposure. (p. 
63/GAO Draft Report):

DOD RESPONSE: The Department concurs with this GAO recommendation. 
Despite significant enhancements in meteorological modeling as well as 
transport and diffusion modeling since the events at Khamisiyah were 
studied, uncertainties in the data will remain.

General comments concerning the GAO report:

The DoD used state-of-the-art meteorological and dispersion models to 
study the potential impacts associated with possible releases of 
chemical warfare agents during the 1991 Gulf War. Determined to use the 
best available methodology for the analysis, yet recognizing the 
difficulty due to lack of on-site source, meteorological, and exposure 
data, the DOD sought guidance in 1996 and 1997 from an Institute for 
Defense Analyses (IDA) panel consisting of world renowned scientists in 
the field of meteorology and dispersion. This independent panel 
provided recommendations adopted by the DoD, including the use of the 
ensemble approach to address issues of uncertainty. The US National 
Centers for Environmental Prediction and the European Centre for Medium 
Range Forecast use the ensemble approach to forecast weather by 
considering a suite of meteorological models. A 2003 report from the 
National Academies' Board on Atmospheric Sciences and Climate (http://
www.nap.edu/html/tracking/reportbrief.pdf) also suggests the use of 
ensemble modeling to account for uncertainty. These facts reinforce the 
ensemble approach adopted by the DoD as the best practice in the 
scientific community.

Used in the DoD/CIA modeling in 1997, the ensemble methodology was 
refined and improved in response to scientific peer review of the 1997 
results. Following its application of improved modeling in 2000, the 
DoD again asked a peer review panel consisting of nationally recognized 
modeling experts to review the results and the panel conclusion was 
that "the methodologies are sound." Consequently, we believe the GAO 
report errs when it accuses the DoD of using "flawed" plume modeling. 
In summary,

* This audit fails to objectively evaluate the modeling capabilities of 
the DoD.

* The audit contains errors of fact, confusion of facts, and 
conclusions without scientific evidence or support.

* The audit recounts events that occurred in 1996 and 1997, without 
regard for improvements made in modeling, analysis, and epidemiological 
research in the 1999 to 2002 time frame.

* The audit fails to document the inclusion of nationally recognized 
modeling experts who participated in or reviewed this work.

* The audit dismisses the conclusions of all epidemiological studies 
that used these data, including those done with the improved 2000 
modeling that was scientifically peer-reviewed and published in a 
technical report in April 2002.

The GAO's multi-year work on this audit shows some misunderstanding of 
the events of the Gulf War and little comprehension of modeling in 
general and the DoD modeling specifically. The report contains errors 
of fact, confusion of facts, and conclusions that evolve without 
scientific evidence or support. It is also apparent that this GAO team 
is stuck in 1996-7. The report reflects little analysis of the final 
modeling, choosing instead to point out weaknesses in 1996 efforts, 
which were improved by subsequent work. In addition, the report fails 
to address the conclusions of the 2000 DoD peer review panel, other 
than a single line of entry in Appendix I that concludes that the DoD's 
"methodologies are sound," which contradicts the GAO's position that 
the "DoD's modeling efforts were flawed."

The analysis of the epidemiology is equally rooted in 1997, reflecting 
none of the work done in 2000. The GAO never mentions several completed 
epidemiology studies that used the results of the 2000 plume modeling. 
The GAO's review of the epidemiological literature is selective, 
incomplete, and outdated. As for the scientific studies on the effects 
of exposures to chemical warfare agents, the GAO ignored the Department 
of Defense Low-Level Chemical Warfare Agents (CWAs) Research Master 
Plan, June 2003, or the results of any of the research indicated in the 
plan. The GAO does not explain what it thinks would be a better method 
to assess exposure. It appears to favor some studies of 1991 Gulf War 
veterans that are mentioned on pages 52 to 61, which seems to imply 
that GAO thinks these studies used a superior method of exposure 
assessment, compared to the DoD modeling. However, some of the studies 
GAO mentioned did not evaluate possible chemical warfare exposure at 
all.

Following are specific comments concerning the GAO report. (Page 
numbers (P) refer to the draft report and may not correspond to the 
page in the final report.):

P.1: "... 16 of the 21 sites that were bombed were destroyed. Many US 
and British troops were located near some of these sites..." This 
statement is not correct. The air campaign occurred from January 17 to 
February 24, 1991. US and British ground forces did not enter Iraq 
until February 25, 1991, well after any bombing pertinent to this 
study. In addition, many of the sites in question were well north of 
the fighting area, in parts of Iraq where US and British forces did not 
penetrate.

P.2, para 1: "...in October 1991, United Nations Special Commission 
(UNSCOM) inspectors had found evidence that US troops had destroyed 
munitions containing CW agents at Khamisiyah. [Evidence found only in 
the Pit.] Specifically, among the nearly 100 bunkers at Khamisiyah, 
remnants of 122 mm rockets were identified at Bunker 73. This is not 
correct. UNSCOM could not determine if Bunker 73 contained chemical 
warfare agents at this time because damaged munitions made it too 
dangerous to get close enough to sample or take Chemical Agent Monitor 
readings. However, on a return visit to the site in May 1996, UNSCOM 
conclusively determined that debris (e.g., burster tubes, fill plugs, 
and plastic inserts) in the rubble of Bunker 73 was characteristic of 
chemical munitions.

P.2, para 2: "In June 1996, DoD estimated that 300 to 400 US troops who 
participated in the demolition of Khamisiyah Bunker 73 had been 
exposed. This statement is not correct. The June 21, 1996, press 
conference, Mr. Bacon said, "300 to 400 troops were involved in the 
actual detonation of the bunkers." The DoD did not say that the 
demolition of Bunker 73 led to any possible exposures.

P.2, para 3: "within a 25 km radius of Khamisiyah and, therefore, had 
potentially been exposed." The GAO has misinterpreted the DoD. The 
Office of the Special Assistant for Gulf War Illnesses used the 25-
kilometer and 50-kilometer radii to identify the area where 
servicemembers might have information about the demolitions at 
Khamisiyah. In letters to those servicemembers, the DoD surveyed them 
for additional information, but did not identify them as "potentially 
exposed" as claimed by the GAO.

P.3, Scope and Methodology, para 1: "US demolitions and Coalition 
bombings of Khamisiyah..." Chemical warfare agent release at Khamisiyah 
was not due to Coalition bombings.

P.6, para 1: "Troops under the path of the plume were classified as 
exposed, those not under the path as nonexposed." This statement is not 
correct. The Office of the Special Assistant for Gulf War Illnesses 
said that servicemembers who were with their units within the hazard 
areas might have been exposed to levels of chemical warfare agents that 
exceeded the general population limit, but did not classify them as 
"exposed" or "nonexposed."

P.5, para 3: "DoD's and VA's conclusions-that there was no association 
between exposure to CW agents at Khamisiyah and U.S. troops' rates of 
hospitalization and mortality-also cannot be adequately supported." 
This implies that there is an association between exposure and 
hospitalization and mortality rates, yet the GAO offers no evidence to 
support this claim. The GAO's conclusion is inconsistent with its first 
finding that plume modeling cannot be used to determine who was 
exposed. If modeling cannot be used to determine which populations 
were more likely to have been exposed and which were less likely to 
have been exposed, then it must be assumed that all populations were 
exposed. If this were true, then hospitalization and mortality may be 
associated with exposure, yet good health (or lack of illness) would 
also be associated with exposure.

P.6, para 3: The DoD does not concur with this recommendation. It would 
be a reckless approach, without scientific basis, and could endanger 
the health of our servicemembers. The data the DoD used was and is the 
best data available and any research that desires to use it would know 
the limitations of the data. We have to make operational and health 
decisions based on the best information available. The purpose of 
modeling is to estimate conditions based on incomplete, but best 
available data. If all data were available, no modeling would be 
necessary. To postpone or deny decisions until all data are available 
is not putting the needs of the veterans first.

P.10, last bullet: This is not part of the modeling methodology. 
Information on potentially exposed populations, etc., is not necessary 
to complete the modeling, though it is necessary to complete the 
subsequent analysis to match the results of the modeling to determine 
who may have been exposed.

P.11: Figure 2 is incorrect. There should be an arrow connecting from 
global weather models to regional weather models, and only regional 
weather models should be connected to transport and diffusion models. 
Outputs from global weather models are mainly used as initial and 
boundary conditions for regional weather models, and should not be 
directly fed into transport and dispersion models. The first paragraph 
on P.11 should also mention this hierarchical relationship between 
global and regional weather models.

P.11, para 2: The relationship of HPAC and SCIPUFF is incorrect. The 
SCIPUFF is a component of the HPAC, rather than the other way around. 
Also, the DoD and CIA modeling efforts did not include NUSSE and ADPIC. 
If the paragraph intends to include all dispersion models that have 
ever been used by any research groups to study the 1991 Gulf War, then 
this list should be much longer.

P.12: The DoD and CIA modeling efforts were never intended to provide 
"definitive conclusions about the size or path (that is, the direction) 
of the plumes." This is clearly indicated by the ensemble approach 
adopted by DoD and CIA. Because turbulent diffusion is inherently a 
random process, there can never be any "definitive" conclusions.

P.12: Table 1 is incorrect. The DoD did not use MATHEW or ADPIC in its 
ensemble modeling of Khamisiyah. Lawrence Livermore Labs used these 
models in response to other requests, but the assumptions used by 
Lawrence Livermore were not related to the data collected by the DoD to 
document the demolition of Khamisiyah.

P.13-14: "DOD's Models Were Not Fully Developed for Analyzing Long-
Range Environmental Hazards" The GAO omits MM5 from its discussion 
here. MM5 is the most commonly used mesoscale meteorological model used 
in the scientific community with hundreds of peer-reviewed journal 
articles published on the model. The DoD used it in both the 1997 and 
2000 modeling. See 
http://www.mmm.ucar.edu/mm5/Publications/mm5-papers.html for a complete 
list of journal articles published on MM5. The GAO's claim that the 
models used by DoD were not fully developed for analyzing long-range 
environmental hazards is unfounded. First previous 
URL reference describes the long history of development and application 
for MM5. The Navy also has a long history of developing and running 
COAMPS. Refer to 
http://www.nrlmry.navy.mil/projects/coaml2s/framepub.htm for a 
comprehensive list of publications on the model. Although OMEGA is a 
relatively new model, partly developed with funding support from the 
Defense Threat Reduction Agency, there are many publications on OMEGA 
that describe its evaluation. See http://vortex.atgteam.com/papers/ for 
a comprehensive list. In addition, the developers for the three 
mesoscale meteorological models all published their modeling results 
for Khamisiyah in peer-reviewed journals. Section 4.3.2 of Verification 
and Validation report of HPAC 3.0[NOTE 1] describes the validation of 
HPAC for long-range diffusion applications, including ANATEX (Across 
North America Tracer Experiment) and ETEX (European Tracer Experiment). 
VLSTRACK has been validated with chemical agent releases up to 220 km. 
[NOTE 2]

P.13, para 2: "...OMEGA consistently underpredicted surface wind speeds 
by a factor of 2 to 3..." OMEGA did not under predict surface wind 
speeds. In fact, a diffcrcnt schcmc, donc outside OMEGA, extrapolated 
model predictions to a common comparison height. Because the three 
mesoscale meteorological models have different vertical grid 
structures, it was necessary to choose a common height for the purpose 
of comparing surface wind speeds. Once the extrapolation scheme was 
made consistent, the "under prediction" no longer existed. In short, 
DoD did not use these "factor of 2 to 3" under predicted winds for 
plume modeling.

P.14, para 3: "...comparison of the hazard-prediction models HPAC and 
VLSTRACK documented substantial differences-by factors between 5 and 
1,000-between the models..." The GAO report does not provide sufficient 
details on what is meant. Are these differences in terms of 
concentration, dosage, or hazard area? Furthermore, it is possible that 
the VLSTRACK results (which represent ensemble means) were compared to 
the 99% probabilistic output generated by HPAC.

P.14, para 3: "The most significant errors in the coding and the 
potential for misuse were found in HPAC and its subcomponent models. 
Given these problems with the analyses conducted up to 1998, HPAC could 
not be considered reliable." This statement is contradicted by numerous 
validation and verification studies by different research groups; all 
suggest the model's satisfactory performance. [NOTE 3]

P.14, para 4: "models were available but not used by DOD, such as MM5." 
This statement is not correct. The DoD used MM5 in both its 1997 and 
2000 modeling.

P.15: We agreed with the 1996-1997 IDA panel recommendations regarding 
the uncertainty in the source term. Subsequent Dugway testing was 
conducted to reduce uncertainty. It would be ideal to duplicate all the 
conditions associated with the Khamisiyah event at Dugway. However, 
practical constraints prevented this from happening. For example, lack 
of onsite meteorological data is a fact, rather than an optional 
deficiency that DoD could avoid.

P. 16: The GAO report seems to suggest that the agent purity should not 
differ widely for Khamisiyah, Al Muthanna, Muhammadiyat, and Ukhaydir. 
However, there is no basis to expect that agent purity would be the 
same for these locations because different manufacturing dates and 
different fill dates were involved. In addition, testing by UNSCOM and 
Iraq provided empirical evidence of the difference in purity.

P.18, para 3: "...shock blast effects of the munitions or the higher 
altitude plumes generated from the transfer of mass associated with the 
shock waves." It is incorrect to assume shock (blast) waves will lead 
to plume mass transfer. As mentioned in the GAO report, the typical 
time scale associated with shock waves is about 10-6 seconds. On the 
other hand, the typical time scale for dispersion is a few minutes to a 
few hours. Therefore, there is at least eight orders of magnitude 
difference between the two time scales, and shock waves will not have 
enough time to influence dispersion. In addition, the main purpose of 
the National Academy of Sciences cited in the GAO report is on damage 
to buildings due to shock waves, rather than "mass transfer" due to 
shock waves.

P.19, para 1: Concerning Al Muthanna, "UNMOVIC, however, informed us 
that UNSCOM had not physically inspected this bunker for safety reasons 
relating to structural instability." This information is misleading. 
UNSCOM, predecessor of UNMOVIC, inspected Al Muthanna and clearly 
visited Bunker 2. Pictures of the inside of Bunker 2, provided by 
UNSCOM, appear in the Persian Gulf War Illnesses Task Force's final 
report on chemical warfare issues in the 1991 Gulf War. [NOTE 4]

P.19, para 2: "... at Muhammadiyat, the munitions were targeted with 
multiple high-explosive bombs." Actually, any targeting was aimed at 
the munition storage bunkers, but at Muhammadiyat, Iraq had moved its 
chemical weapons out to open areas.

P.19, para 2: "However, the type and quantity of explosives used in the 
Dugway testing-and, therefore, the resulting effects-are not comparable 
with the type and quantity of munitions that were actually used at 
Muhammadiyat." The GAO misstates the relationship of the Dugway testing 
to Muhammadiyat modeling. The Dugway testing was conducted to better 
understand the Khamisiyah Pit event, not Muhammadiyat. Nevertheless, 
because the sarin releases at Muhammadiyat occurred due to leakage, the 
evaporation and degradation rates for the chemical warfare agent were 
appropriate for Muhammadiyat modeling.

P.19, para 3: "The major unresolved issues concerning DOD's modeling 
include assumptions about (1) Khamisiyah Bunker 73 ...". The DoD did 
not model a release from Khamisiyah Bunker 73.

P.20, para 7: "...given DOD's conclusion that all but 2.5 percent of 
the agent was degraded..." The DoD did not model a release at Bunker 73 
and the CIA developed the source term, not the DoD.

P.20, last para: "on only one occasion did the CIA and DOD express any 
concern about agent release." This is not correct. The DoD has on many 
occasions expressed concern about agent release. It modeled possible 
releases at multiple locations to determine if concerns were justified.

P.20, last para: Discussions of UNSCOM inspections of Al Muthanna seem 
to contradict the previous paragraph where UNMOVIC said UNSCOM didn't 
inspect Al Muthanna.

P.21, para 3: "Therefore, for [the Muhammadiyat] model, DOD chose a 
duration of 24 hours. However, if agent concentration would dissipate 
to a miniscule level after 24 hours, it is not clear why DOD would 
choose a 72-hour duration far Khamisiyah models." The explanation is 
clear in the DoD reports on these events. The DoD modeled Muhammadiyat 
for 24 hours for each air strike because the source duration was 
assumed to be one hour. Therefore, towards the end of the 24-hour 
simulation period, the agent cloud would have been sufficiently diluted 
and concentrations essentially zero. Since potential hazard areas are 
determined by time-integrated concentrations (or dosages), we could 
have simulated Muhammadiyat for 72 hours and potential hazard areas 
would have remained the same. This is because the additional simulation 
time, with nearly zero concentrations, would contribute little to time-
integrated concentrations. Khamisiyah was modeled for 72 hours because 
the source term lasted a much longer time due to evaporation of agents 
from soil and wood, with about 90% of the total agent released within 
the first 30 hours after the release. Different simulation times were 
chosen for Muhammadiyat and Khamisiyah is because of the fundamental 
difference in source durations for the two events.

For Muhammadiyat, we were unable to pinpoint the date of the release, 
so we assumed all agent was released at one time, which maximized the 
amount of chemical warfare agent for modeling. Total release at one 
time led to a higher estimate of concentration of dosage at any 
location than would be assumed if the agent release occurred over 
several days.

P23, para 2 and 3: "Credible scientific evidence suggests that the 
reported detections of CW agents were reliable." It is unclear to what 
"reported detections" this section refers. If the discussion is about 
the Czech and French reports of detection, the DoD did not "assert that 
the various detections are not valid because the source of the agents 
cannot be detected." In 1996, the DoD indicated that some detections 
appeared valid; the CIA called two of them credible. In fact, the Czech 
government acknowledged only two of the reports of detection, but the 
French have never acknowledged any detections. Based on the lack of 
confirmatory tests, no obvious source for the chemical warfare agents 
detected, and the fact that the governments never indicated these 
detections occurred nor provided information about them, these report 
were assessed as "Indeterminate."

P.26: Figure 3 should include the time of day for each satellite image. 
Also, improve the image quality because the axis labels and scales are 
not legible.

P.28, para 2: "This period of reporting on chemical agent detection ... 
coincides directly with the initial Coalition bombings of confirmed and 
suspected Iraqi CW research, production, and storage facilities January 
17-24,1991." While this is an interesting observation, the GAO provides 
no evidence to support a chemical warfare agent release of the 
magnitude required to generate even low-level detections hundreds of 
kilometers from the event.

P.28, para 2: "...figure 4 shows pressure gradient data ..." This is 
not correct. Figure 4 does not show pressure gradient data. Figure 4 
probably shows an infrared image that mainly reflects cloud-top (not 
ground) temperatures.

P.28, 30: The inversion argument is overly emphasized in the GAO 
report. As indicated in Figure 6, capping inversion is almost a 
constant feature in the atmosphere, as it separates the atmospheric 
boundary layer from the free atmosphere. The height of this elevated 
inversion can change during frontal passage. Therefore, the inversion 
argument cannot be selectively used to suggest agent detections.

P.29, Figure 4: The figure is incorrect. The x-axis labels should 
indicate "east" longitude. The figure should also include the time of 
day.

P.30, para 2: "The assessments by the CIA and DOD that the detections 
of the Czech Chemical Detection Units are not credible ... are 
unsound..." This is not correct. The DoD did not say the reports were 
not credible. In 1996, the DoD indicated that some detections appeared 
valid; the CIA called two of them credible. The Czech government 
acknowledged only two of the reports of detection, and the French have 
never acknowledged any detections. Based on the lack of confirmatory 
tests, no obvious source for the chemical warfare agents detected, and 
the fact that the governments never indicated these detections occurred 
nor provided information about them, the DoD assessed the detections as 
"Indeterminate."

P.31, para 4: "Modeling experts from LLNL [Lawrence Livermore National 
Laboratory] who participated in only the initial modeling of the 
Khamisiyah pit site ..." It is unclear what the GAO means by "initial 
modeling." In fact, the LLNL never participated in DoD's efforts to 
model the Khamisiyah demolition. The LLNL produced a capability 
modeling of Khamisiyah in response to the IDA panel's request but, as 
the GAO points out later, LLNL models were not part of the DoD 
ensemble.

P.31-35: The GAO report suggests that the actual plume height might 
have been significantly higher for the cases considered by DoD and CIA. 
The report then cites a power law formula based on a Sandia empirical 
study to claim that plume height can be in excess of 400 m. The report 
also cites an LLNL prewar analysis that the bombing of Iraqi storage 
facilities for CW agents would be a surface-based plume with a height 
of 493 m. These arguments are flawed or cannot be adequately supported 
based on at least three reasons.

1) The Khamisiyah pit demolition, the most significant event 
investigated by DoD and CIA, did not involve aerial bombings (i.e., the 
conditions assumed in the Sandia and LLNL studies). Instead, chemical 
agent-filled rockets were destroyed using explosives, and many of these 
rockets were cracked, rather than completely demolished by the 
explosions.

2) It appears that the GAO report refers to plume height as the top 
boundary of the plume (see Figure 8), rather than the centroid (center 
of mass) of the plume. All dispersion models track the plume according 
to its centroid height. Therefore, a plume top boundary might be as 
high as 400 m, but its centroid height might be roughly 200 m.

3) For some events modeled by DoD, chemical agents were not 
instantaneously released as a buoyant puff, as suggested by the Sandia 
and LLNL studies. Rather, a significant portion of the release occurred 
from evaporation or leakage of chemical agents, in which case no 
buoyancy was involved. For example, based on field and laboratory 
testing, DoD found that for the Khamisiyah pit demolition, less than 
10% of the total source term was instantaneously released into the 
atmosphere, and the remaining 90% of the source term was released due 
to slow evaporation from wood and soil. Furthermore, since the pit 
demolition occurred around 
4:15 PM local time when the atmospheric boundary layer was convective 
and well mixed, the initial plume would have been quickly well mixed 
vertically throughout the boundary layer, thus rendering the model 
results insensitive to the initial plume height and the argument of 
nocturnal low level jet irrelevant.

Page 32, last sentence: "...video images that showed some of the plume 
data, such as (1) those taken from ground level at Khamisiyah ..." This 
is misleading. There was no video of the demolition of the munitions in 
the Pit at Khamisiyah. Even if there had been a video, it would not 
show "data."

P.33: Figure 6 does not show "winds in the surface layer in the stable 
boundary layer often accelerate to higher speeds, in a phenomenon 
referred to as the low-level or nocturnal jet." In fact, the figure 
does not say anything regarding wind speed.

P.35, para 1: "Empirical studies and observed events tend to refute the 
assumptions with which the CIA and DOD supported the alternative 
assumption that the plume was transported by low-level jets." This is 
not correct. The Dob never assumed low-level jets transported the 
plume.

P.35: The GAO testimony many times mentions the nocturnal low-level jet 
(LLJ) as if it is a ubiquitous phenomenon in the atmosphere, i.e., 
occurring everywhere and every night. However, although LLJs are not 
rare, they are not ubiquitous either. For example, based on the 
analysis of two years of wind data from 47 rawinsonde stations in the 
United States, Bonner[NOTE 5] observes that LLJs most frequently occur 
in central plains, particularly in the Kansas and Oklahoma region, 
where 30% of all rawinsonde soundings have LLJs. In addition, Brook 
[NOTE 6] reports LLJs on 19% of the winter nights in parts of 
Australia. An LLJ generally forms at nighttime overland under clear sky 
conditions. Favorable conditions for the wind maximum of a LLJ include 
such factors as sloping terrain, radiative cooling in the air, surface 
cooling rates, conditions at sunset, and frictional decoupling of the 
air aloft from the surface. The GAO report does not present any 
evidence to support the assumption of the presence of LLJs on the days 
in question. In fact, without on-site meteorological measurements at 
the time, it is doubtful that such evidence would ever exist.

P.35, para 2: "nighttime detections of low levels of CW agents, 
associated with turbulence-resulting from aircraft-related sonic booms 
and incoming missiles and artillery-mixing the upper-level and lower-
level atmospheric layers." This statement lacks any technical merit. 
The GAO report seems to suggest that a plume can first be bodily 
transported by the LLJ hundreds of miles, and then mixed to the ground 
due to turbulence. This doesn't happen because transport and dispersion 
always happen simultaneously. A plume cannot travel while undiluted. 
Furthermore, the presence of the LLJ tends to generate more turbulence 
because of shear instability. In addition, all mesoscale meteorological 
models (COAMPS, MM5, and OMEGA) contain the relevant physics (e.g., 
pressure gradient, friction, radiative transfer, and the rotation of 
the earth) to simulate the evolution of an LLJ. However, the diagnostic 
MATHEW wind field model favored by the GAO cannot simulate the LLJ, 
because the model does not account for atmospheric dynamics. This is 
especially a deficiency when the observational data are sparse.

P.36-38: "DoD's Field Testing Did Not Realistically Simulate Actual 
Conditions" The report shows a lack of understanding of the purpose, 
goals, and results of the Dugway testing. The Dugway testing was not 
intended to recreate the demolition at Khamisiyah, to simulate the 
environmental conditions at Khamisiyah (except as related to the 
evaporation testing) or to estimate the plume height. Testing was 
intended to simulate portions of the Khamisiyah pit demolition to 
derive release characterization. The tests were to determine the mass 
balance of the release, that is, the amount vaporized, cast into the 
atmosphere as droplets, burned, or spilled. Subsequent work developed 
the evaporation and degradation rates.

Since explosion is a phenomenon involving a very short time scale, 
meteorology usually does not play a significant role. This is the 
reason why, for example, the methodology recommended by the EPA Risk 
Management Program to estimate the distance to one pound-per-square-
inch overpressure for vapor cloud explosions does not involve 
meteorology. In fact, the power law formula listed in Appendix II of 
the report for plume height due to high explosive detonations also does 
not involve meteorology. Nevertheless, the subsequent evaporation of 
liquid agents spilled unto soil and wood does depend on meteorology 
because of longer time scales, and the Dugway laboratory testing of 
agent evaporation accounted for appropriate temperatures.

Moreover, the Dugway study used a reduced scale of the rocket stacks in 
the pit because of financial and other practical constraints. It is a 
well-accepted practice in all disciplines of research to study a 
scaled-down model to estimate the effects of a full-scale phenomenon. 
For example, water tanks and scaled model ships are used to design 
warships, and the results from limited-scale field and laboratory 
experiments are used to develop dispersion models that are applicable 
to the atmospheric boundary layer.

P.38, para 4: "The models ... showed great divergence, even with the 
same source term data." Because the atmosphere is turbulent in nature, 
even the same release under the same meteorological conditions will 
lead to different observed concentrations at the same sampler location. 
In addition, because of different physics and methods of data 
processing, different models almost always yield different results even 
with the same input data. This is the reason why model uncertainty 
traditionally has been an important research topic in dispersion, 
meteorology, and many other disciplines. The ensemble approach, used by 
the DoD, is a state-of-the-art methodology to account for uncertainty.

Hanna and Yang [NOTE 7] report that the root-mean-square-error of 
predicted surface wind directions is about 50, and is 3 to 4 m/s for 
wind speeds. They suggest that these uncertainties in wind speeds and 
directions are primarily due to random turbulent processes that cannot 
be simulated by the models, and to sub-grid variations in terrain and 
land use. Therefore it is unlikely that the errors can be reduced much 
further.

The ensemble approach [NOTE 8] is routinely used in weather forecast to 
account for uncertainty due to the fact that different weather models 
give different forecasts, even when the same observational data are 
used. For example, the US National Centers for Environmental Prediction 
(NCEP) and 
the European Centre for Medium Range Forecast (ECMWF) all use the 
ensemble approach to forecast weather by considering a suite of 
meteorological models, and no attempt is made to resolve the difference 
among these models. Moreover, a 2003 report from the National 
Academies' Board on Atmospheric Sciences and Climate 
(http://www.nap.edu/html/trackinGreportbrief.pdf) also suggests the 
use of ensemble modeling to account for uncertainty. The DoD used the 
ensemble approach in its modeling because of the uncertainty associated 
with individual model simulations. There is, however, one important 
principle for the ensemble approach. For the sake of consistency, all 
model simulations included in an ensemble should be comparable (e.g., 
in terms of model capability and input data requirements).

It is important to point out that model uncertainty should not be 
treated as a "deficiency" in dispersion modeling because we will always 
be confronted with the same challenge regardless of model 
sophistication and data availability. In fact, Appendix IV of the GAO 
report presents two sets of wind vector plots generated by LLNL-ARAC 
(Figures 15 and 16), where there is also a great divergence between the 
two.

P.39: "In addition, DOD chose not to include in the composite model the 
results of the LLNL model, created at the IDA expert panel's request, 
which showed a different and larger plume size and path than DOD's 
models showed." This is not correct. The LLNL did not model the 
quantities and conditions developed by the CIA and the DoD; the LLNL 
was never part of the ensemble approach; and the LLNL results were for 
the benefit of the IDA panel, which regarded the LLNL models as less 
capable. In fact, since that time, the LLNL has replaced its 
meteorological models with one the DoD used.

P.42 and 44: Figures 10 and 11: It is misleading to overlay the DoD 
composite model results with the LLNL model because there are numerous 
differences in how hazard areas were calculated. For example:

The source term is different. The source term used by DoD assumed 
contents (both GB and GF) of 225 rockets released over several days, 
whereas the source term used by LLNL assumed contents of 550 rockets 
released instantaneously.

* The area-defining thresholds are different. The potential hazard area 
calculated by DoD is based on a threshold dosage of 0_0432 mg-min/m^3 
for GB, and 0.0144 mg-min/m^3 for GF, over a 24-hour exposure period. 
We believe the "general population limit" area calculated by LLNL is 
based on a threshold dosage of 0.01296 mg-min/m^3 (for GB only) over a 
72-hour exposure period.

The dosage accumulation times are different. The DoD calculations 
involve the estimation of potential hazard areas for each day, thus the 
24-hour exposure period mentioned above. This is because the troop 
location database has a 24-hour resolution. The composite "potential 
hazard area" is a superposition of three potential hazard areas for 10 
through 12 March 1991. On the other hand, the LLNL's "general 
population limit" area is based on a single total exposure period of 72 
hours.

* The meteorological fields are different. The DoD calculations are 
based on COAMPS, MM5, and OMEGA "prognostic" meteorological models that 
incorporate a wide range of atmospheric physics. The LLNL calculations 
are based on the MATHEW "diagnostic" 
meteorological model that mainly interpolates observational data and is 
not based on first principles. In a data-rich environment, the 
difference between diagnostic and prognostic models may not be great. 
However, in a data-sparse region, such as Iraq in 1991, the difference 
between the two types of models can be significant. Because prognostic 
models are based on fundamental conservation laws of mass, momentum, 
and energy, they can predict the evolution of weather systems such as 
fronts, land and sea breezes, and low-level jets. Diagnostic models, on 
the other hand, do not have such capability. In other words, if the 
observational data used by MATHEW do not already include these weather 
phenomena, due to either sparse data or absence of such phenomena, then 
the gridded wind fields generated by the model will also not include 
such phenomena.

P.45, para 1: "...divergence in the modeling outcomes could be 
explained by a directional split-a line of diffluence ..." This is not 
entirely correct. Diffluence in the predicted wind field is only one of 
the possible reasons for different model results. Another possible 
explanation is a time shift of flow patterns. For example, two 
meteorological models might predict exactly the same evolution of flow 
fields, but there is a slight time shift between the two, (e.g., one 
model predicted a frontal passage at 0200Z, but the other model 
predicted a frontal passage at 0300Z). Then the cloud trajectory driven 
by the two flow fields can differ as a result.

P.45: The inter-model bias shown in Figure 12 is consistent with the 
root-mean-square-errors in wind direction as suggested by Hanna and 
Yang, [NOTE 9] which further strengthens the need for ensemble modeling 
to account for model uncertainty.

P.46, para 1: "the VLSTRACK and SCIPUFF/HPAC results were complicated 
by the use of significantly different source term inputs." This 
statement is misleading. The GAO report fails to mention that the 2000 
modeling used a consistent source term for SCIPUFF and VLSTRACK.

P.46, para 2: "...a plume of plumes, rather than a plume based upon 
data."' This statement is misleading. The "plume of plumes" appears to 
refer to the DOD's ensemble approach. However, each "plume" in the 
ensemble is based on data, so the ensemble "plume of plumes" is based 
on data.

P.50-61: "DOD's And VA's Epidemiological Conclusions On CW Exposure And 
Hospitalization And Mortality Rates Cannot Be Adequately Supported." 
This is not correct. The GAO focuses on only two epidemiological 
studies related to Khamisiyah, one on hospitalization and one on 
mortality. Several major, relevant studies have been published related 
to Khamisiyah that GAO did not mention. Both the DoD hospitalization 
study and the VA mortality study have been updated, using 2000 plume 
modeling data. [NOTE 10]

First, the report only mentions the original DoD epidemiologic study 
based on the 1997 plume estimates [NOTE 11] (1). These estimates were 
revised. Additionally, although more than 695,000 were deployed to the 
first Gulf War, 351,299 were identified as Army with complete covariate 
data and those were used in this initial report. Only Army was used 
because those determined to be possibly exposed were also Army so this 
restriction was used in order to compare within a more homogeneous 
population.

The hazard areas changed with the remodeling in 2000 and the possibly 
exposed population changes accordingly. The revised population was used 
in the second epidemiologic paper[NOTE 12]. In both reports, the DoD 
used sophisticated techniques to allow those to be included in the 
follow-up period until they left active duty service. Follow-up time 
was nearly equal among the possibly exposed and non-exposed.

P.52-61: "Some Studies Suggest an Association between CW Exposure and 
Gulf War Illnesses." Studies of 1991 Gulf War Veterans that used self-
reported data on chemical warfare agent exposure - Some of the studies 
mentioned on these pages attempted to evaluate possible chemical 
exposure while others did not. The studies that attempted to evaluate 
exposure used self-reported exposures, based on questionnaires several 
years after the war. Some of these studies did not evaluate chemical 
warfare agents as a possible etiology of illnesses, [NOTE 13] so it is 
unclear why the GAO even mentions them, so no conclusions can be drawn 
on whether chemical warfare agents have an association with the 
symptoms reported by the study subjects in those particular studies. 
None of these articles focused on potential chemical exposure due to 
the demolitions at Khamisiyah.

Recall bias is a serious concern in any questionnaire study, when 
asking questions about possible exposures that may have taken place 
several years before the study is performed. Some studies have 
systematically evaluated the potential problem of recall bias in 
questionnaire studies of Gulf War veterans, and concluded that self-
reported exposure information needed to be validated. [NOTE 14] For 
example, in one Gulf War study, the authors concluded: "A veteran may 
report exposures that are highly improbable given the dates of 
deployment and, in many instances be 
unreliable when measured at two different time points in time ... 
Findings which make sole use of self-reported findings, for both 
outcome and exposure, must be viewed with caution or suspicion." [NOTE 
5]

P.50, para2; P.52, para3; and P.59, para 3: "Animal Studies" Most of 
the animal studies outlined on pages 59-61 cannot be directly 
extrapolated to the possible health effects of low-level satin exposure 
in 1991 Gulf War veterans. The 1991 Gulf War veterans did not report 
any symptoms at the time of the Khamisiyah demolitions. Many of these 
animal studies used very high satin exposures that led to immediate, 
severe symptoms. In addition, many studies administered satin through 
injection, which cannot be extrapolated to inhalation exposure, which 
was the potential route of exposure during the Gulf War. Some 1991Gulf 
War veterans have developed chronic symptoms years after the war. 
Animal studies would have to include long-term follow-up of health 
effects to be relevant to illnesses that developed years after the war. 
In most of these studies, the animals were sacrificed within hours to 
weeks of exposure, and there was no evaluation of long-term health 
effects. In addition, some of the studies mentioned by the GAO do not 
evaluate the health effects of satin or other organophosphate nerve 
agents, so it is unclear why GAO even mentioned them, e.g., Abou-Donia, 
1996a; Abou-Donia, 1996b; Abdel-Rahman and Abou-Donia, et al., 2002.

P.50, para 2; P. 51, para 4; and P. 52, para 1: "DoD and VA Used an 
Insensitive Outcome Measure for Determining Hospitalization Rate" The 
GAO's conclusion that hospitalization studies do not provide valid data 
to evaluate chronic illnesses is illogical and erroneous. GAO does not 
provide any examples of chronic illnesses in 1991 Gulf War veterans 
that would not lead to hospitalization. Many studies have demonstrated 
that 1991 Gulf War veterans have been diagnosed with chronic illnesses, 
related to nearly all organ systems. Similarly, in many studies, Gulf 
War veterans have been hospitalized with chronic illnesses, related to 
nearly all organ systems. The GAO did not mention several studies that 
evaluated various health outcomes, other than hospitalization, in 
relation to chemical warfare agent exposure.

The use of hospitalizations as a measure of health effects has 
limitations and strengths. This analysis would be limited to morbidity 
severe enough to require admission to a DoD hospital for inpatient care 
diminishing the ability for examination of the full spectrum of health 
effects. However, hospitalization data are very complete for active-
duty military personnel and they reflect a much more objective measure 
of illness than self-reported symptoms or illnesses.

Further, in a 2000 report the DoD investigated those who left the 
service soon after the war [NOTE 16]. There were no indications that 
1991 Gulf War veterans were suffering increased probability morbidity 
ratios for infectious diseases; neoplasms; endocrine diseases; blood 
diseases; skin conditions; or diseases of the nervous system; 
circulatory system, or musculoskeletal system. However, 1991 Gulf War 
veterans did experience proportionally more hospitalizations for 
various specific diagnoses, namely, fractures and bone and soft tissue 
injuries (from the DoD and 
California Office of statewide Health Planning and Development), 
various diseases of the respiratory and digestive systems (from the VA, 
and diverse symptom diagnoses (from the VA).

P.50 to 52, and 62, GAO's Review of the Epidemiological literature, The 
GAO does not define its criteria for including the studies they did or 
excluding many other relevant studies. Some major, relevant studies 
have been completed, which GAO did not mention. Several studies have 
evaluated the possible health effects of the release of chemical 
warfare agents due to Khamisiyah, including:

* One hospitalization study, performed by the Naval Health Research 
Center; [NOTE 17]

* One mortality study, performed by the VA Office of Public Health and 
Environmental Agents; [NOTE 18]

* Two studies of several symptoms and medical diagnoses, performed by 
the Oregon Health Sciences University [NOTE 19];

* Two studies about veterans who had chronic illnesses that were 
evaluated in the VA and DoD Gulf War registries, by the Naval Health 
Research Center; [NOTE 20] and:

* Three studies of mortality, hospitalizations, and symptoms, performed 
the Institute of Medicine (completed, but not published).

GAO did not mention these highly relevant studies, which have the 
following advantages over the studies that GAO favored:

* Large study populations that were randomly selected and, therefore, 
representative of the overall population of 1991 Gulf War veterans;

* Focus specifically on possible exposures due to the Khamisiyah 
demolitions, rather than on non-specific, unverified events;

* Exposure assessments of exposure that is methodologically superior to 
self-reported data;

* Various objective health outcomes, in addition to self-reported 
symptoms; and:

* Follow-up of health status of servicemembers after discharge from 
active-duty.

P.70-71: There is no indication of the "line of diffluence" as 
referenced on p. 45. "line of diffluence ... Appendix IV illustrates 
this diffluence with three different data sets."

P.72: The quality of Figure 17 should be improved. It is not legible, 
does not have a scale for the wind barbs, and the legend to the right 
of each plot is not explained. Furthermore, it appears that Figure 17 
is not based on the latest (2000) COAMPS results.

NOTES: 

[1] Bradley, S., T. Mazzola, R. Ross, D. Srinivasa, R. Fry, and D. 
Bacon, "Verification and Validation of HPAC 3.0," Prepared for Defense 
Threat Reduction Agency, 45045 Aviation Drive, Dulles, VA 20166-7517, 
DSWA-TR-98-66, 2000.

[2] Bauer, T. and M. Wolski, "Initial Validation of VLSTRACK Version 
1.2," NSWCDD/TR-92/647, Naval Surface Warfare Center, Dahlgren, VA, 
22448, 1993.

[3] Bradley, S., T. Mazzola, R. Ross, D. Srinivasa, R. Fry, and D. 
Bacon, "Verification and Validation of HPAC 3.0," Prepared for Defense 
Threat Reduction Agency, 45045 Aviation Drive, Dulles, VA 20166-7517, 
DSWA-TR-98-66, 2000.

[4] Persian Gulf War Illnesses Task Force, "Chemical Warfare Agent 
Issues During the Persian Gulf War, April 2002.

[5] Bonner, W.D., "Climatology of the Low Level Jet," Monthly Weather 
Review, 1968, Volume 96, p.833-850. 

[6] BROOK, R.R., "Koorin Nocturnal Low-level Jet," Boundary-Layer 
Meteorology, 1985, Volume 32, p.133 154.

[7] Hanna, S.R. and R. Yang, "Evaluations of Mesoscale Model 
Predictions of Near-Surface Winds, Temperature Gradients, and Mixing 
Depths," Journal of Applied Meteorology, 40, 1095-1104, 2001.

[8] Hamill, T.M., S.L. Mullen, C. Snyder, Z. Toth, and D.P. Baumhefner, 
"Ensemble Forecasting in the Short to Medium Range: Report From a 
Workshop," Bulletin of the American Meteorology Society, 2000, Volume 
81, p. 2653-2664.

[9] Hanna, S.R. and R. Yang, "Evaluations of Mesoscale Model 
Predictions of Near-Surface Winds, Temperature Gradients, and Mixing 
Depths," Journal of Applied Meteorology, 2001, Volume 40, p. 1095-1104.

[10] Smith, T.C., G.C. Gray, J.C. Weir, J.M. Heller, and M.A. Ryan, 
"Gulf War Veterans and Iraqi Nerve Agents at Khamisiyah: Postwar 
Hospitalization Data Revisited," American Journal of Epidemiology, 
September 1, 2003, Volume 158(5), p. 457-467; and Kang, H.K. and T.A. 
Bullman, "Mortality among US Gulf War Veterans who were Potentially 
Exposed to Nerve Gas at Khamisiyah, Iraq," Washington, DC: Department 
of Veterans Affairs, May 2002.

[11] Gray, G.C., T.C. Smith, J.D. Knoke, J.M. Heller, "The Postwar 
Hospitalization Experience Among Gulf War Veterans Exposed To Chemical 
Munitions Destruction At Khamisiyah, Iraq," American Journal of 
Epidemiology, September 1, 1999, Volume 150, No 5.

[12] Smith, T.C., G.C. Gray, J.C. Weir, J.M. Heller, M.A. Ryan, "Gulf 
War Veterans and Iraqi Nerve Agents at Khamisiyah. Postwar 
Hospitalization Data Revisited," American Journal of Epidemiology, 
September 1, 2003, Volume 158(5), p. 457-467.

[13] B.Mackness, et al., "Low Paraoxonase in Persian Gulf War Veterans 
Self-Reporting Gulf War Syndrome," Biochemical and Biophysical Research 
Communications, 2000, Volume 276, p. 729-733; M. Hotopf et al., 
"Paraoxonase in Persian Gulf War Veterans," Journal of Occupational and 
Environmental Medicine, 2003, Volume 45, p. 668-75; and D.J. Meyerhoff 
et al., "Reduced N-Acetylaspartate in the Right Basal Ganglia of Ill 
Gulf War Veterans by Magnetic Resonance Spectroscopy," Proceedings of 
the International Society of Magnetic Resonance Medicine, 2001, Volume 
9, p. 994.

[14] McCauley, L.A., S.K. Joos, P.S. Spencer, M. Lasarev, and T. Shuell, 
"Strategies to Assess Validity of Self-Reported Exposures During the 
Persian Gulf War," Environmental Research, October 1999, Volume 81(3): 
p. 195-205; Greenberg, N., A. Iversen, L. Hull, C. Unwin, M. Destrange, 
and S. Wessely, "Vaccination Records in Gulf War Veterans," Journal of 
Occupational and Environmental Medicine, March 2003, Volume 45(3), p. 
219; and Wessely, S., C. Unwin, M. Hotopf, L. Hull, K. Ismail, V. 
Nicolaou, and A. David, "Stability of Recall of Military Hazards Over 
Time: Evidence from the Persian Gulf War of 1991," British Journal of 
Psychiatry, October 1, 2003, Volume 183; p. 314-322.

[15] McCauley, L.A., S.K. Joos, P.S. Spencer, M. Lasarev, and T. 
Shuell, "Strategies to Assess Validity of Self-Reported Exposures 
During the Persian Gulf War," Environmental Research, October 1999, 
Volume 81(3): p. 195-205.

[16] Gray, G.C., T.C. Smith, H.K. Kang, J.D. Knoke, "Are Gulf War 
Veterans Suffering War-Related Illnesses? Federal And Civilian 
Hospitalizations Examined June 1991 To December 1994," American Journal 
of Epidemiology, January 1, 2000, Volume 151, No 1.

[17] Smith, T.C., G.C. Gray, J.C. Weir, J.M. Heller, and M.A. Ryan, 
"Gulf War Veterans and Iraqi Nerve Agents at Khamisiyah: Postwar 
Hospitalization Data Revisited," American Journal of Epidemiology, 
September 1, 2003, Volume 158(5), p. 457-467.

[18] Kang, H.K. and T.A. Bullman, "Mortality among US Gulf War Veterans 
who were Potentially Exposed to Nerve Gas at Khamisiyah, Iraq," 
Washington, DC: Department of Veterans Affairs, May 2002.

[19] McCauley, L.A., M. Lasarev, D. Sticker, D.G. Rischitelli, and P.S. 
Spencer, "Illness Experience of Gulf War Veterans Possibly Exposed to 
Chemical Warfare Agents," American Journal of Preventive Medicine, 
October 2002, Volume 23(3), p. 200-206; and Shapiro, S.E., M.R Lasarev, 
and L McCauley, "Factor Analysis of Gulf War Illness: What Does it Add 
to Our Understanding of Possible Health Effects of Deployment?" 
American Journal of Epidemiology, September 15, 2002, Volume 156(6), p. 
578-585.

[20] Smith, T.C., B. Smith, M.A. Ryan, G.C. Gray, T.I. Hooper, J.M. 
Heller, N.A. Dalager, H.K. Kang, and G.D.Gackstetter, "Ten Years And 100,000 Participants Later: Occupational 
And Other Factors Influencing Participation In US Gulf War Health 
Registries," Journal of Occupational and Environmental Medicine August 
2002, Volume 44(8), p.758-768; and Smith, T.C., D.L. Jimenez, B. Smith, 
G.C. Gray, T.I. Hooper, G.D. Gackstetter, J.M. Heller, N.A. Dalager, 
H.K. Kang, K.C. Hyams, and M.A. Ryan, "The Postwar Hospitalization 
Experience of Gulf War Veterans Participating in US Health Registries," 
Journal of Occupational and Environmental Medicine, April 2004, Volume 
46(4), p.386-397.

GAO Comments:

1. The use of the phrase "flawed plume modeling" in the report refers 
to the use of DOD models that were not fully developed for analyzing 
long-range dispersion of CW agents as an environmental hazard. In 
addition, the uncertain source term data used resulted in a flawed 
modeling outcome. Meteorological and dispersion modeling, as predictive 
and diagnostic tools, can have significant value in cases where 
detailed meteorological data are unavailable and in providing warning 
for potential environmental hazards, assuming that the necessary input 
data supplied to the model are accurate. DOD now asserts that it has 
made significant improvements in its models; however, we have not 
evaluated DOD's assertion, since it was beyond the scope of this study.

5. We revised the recommendation to state: "We recommend that the 
Secretary of Defense and the Secretary of VA not use the plume modeling 
data as a basis for future epidemiological studies of Gulf War 
Illnesses in Iraq, since DOD and VA cannot know who was or who was not 
exposed."

DOD correctly states that the necessary input data (i.e., source term 
and meteorological data) were not available. However, the models that 
DOD used were not fully developed for long-range dispersion of CW 
agents as an environmental hazard. Consequently, the modeling results 
were not fully reliable for determining which troops were exposed or 
were not exposed.

The report did not intend to suggest that modeling, in general, is a 
flawed approach for predicting the hazard potential resulting from the 
release of toxic materials; rather, it intends to suggest that for a 
retrospective event, such as events at Khamisiyah, the use of models 
that were not fully developed for deriving long-range environmental 
hazards, in conjunction with the uncertain source term data used, 
resulted in a flawed modeling outcome. As we mentioned before, DOD now 
asserts that it has made significant improvements in its models; 
however, we have not evaluated DOD's assertion, since this was beyond 
the scope of this study.

6. An ensemble approach can be a useful tool in addressing issues of 
uncertainty. However, the process DOD used discounted at least two 
simulations using models that resulted in plume footprints that either 
were much larger or traveled in different directions or both. To 
properly account for uncertainty, and the untested ability of the 
several DOD models to estimate long-range environmental fallouts, other 
more mature models such as the MATHEW/ADPIC models from LLNL should 
have been included in the model. In the absence of their inclusion, 
evidence that the plumes did not travel in a divergent direction needs 
to be produced.

7. Again, our conclusion was not intended to suggest that modeling, or 
even ensemble modeling, is a flawed approach to predicting the hazard 
potential resulting from the release of toxic materials. Rather, it was 
intended to suggest that using models that were not fully developed for 
deriving environmental fallout estimates in conjunction with uncertain 
source term data resulted in a flawed modeling outcome and unsupported 
results. In addition, the selection of data and sites for modeling has 
a profound impact on model predictions. It is this area of the use of 
incomplete and improbable data and uncertainty in the selection 
criteria for sites and times to model that has resulted in flawed 
modeling outcomes.

8. The objectives of this report were not to evaluate DOD's modeling 
capabilities in general but, rather, to (1) determine the validity of 
DOD and British Ministry of Defense (MOD) conclusions--based on CIA and 
DOD plume-modeling results--regarding U.S. and British troops' exposure 
to CW agents during the 1991 Gulf War; (2) determine the total costs 
for the CIA's and DOD's various plume-modeling efforts related to these 
exposures; and (3) determine DOD and VA conclusions from 
epidemiological studies, based on DOD's plume-modeling results, that 
there was no association between CW exposure at Khamisiyah and the 
troops' hospitalization and mortality rates. In other words, we 
examined how DOD's capabilities were applied to this specific case.

9. This comment is dealt with in detail in addressing specific DOD 
comments below.

10. Our observation regarding inaccurate, inappropriate, and incomplete 
source term data and assumptions would apply equally to simulations 
conducted throughout the period from 1996 to the present. Because 
flawed data were fed into those models, the fact remains that the 
modeling results are unsupported. As we mentioned before, DOD now 
asserts that it has made significant improvements in its models; 
however, we have not evaluated DOD's assertion, since it was beyond the 
scope of this study.

11. The report refers to panels of experts who reviewed DOD reports and 
made comments and recommendations regarding the DOD modeling efforts. 
In at least one case, we have documented where an expert made a 
recommendation regarding the potential presence of meteorological 
phenomena not addressed in the DOD modeling studies.

12. We reviewed all published studies as well as technical reports DOD 
and VA prepared. We agree with DOD that "scientifically peer-reviewed 
and published" is considered a high standard of validity when it 
implies anonymous review by scientists coordinated by the editor of a 
reputable scientific journal leading to publication of findings in that 
scientific journal. The peer review and 2000 publication to which DOD 
refers here had not gone through that process. The 2002 Kang and 
Bullman study has not been published in a peer-reviewed journal and 
therefore should not have been included in a review of the scientific 
epidemiologic literature. This subject is discussed in further detail 
in our response to DOD's comments on the section "DOD's and VA's 
Epidemiological Conclusions on CW Exposure and Hospitalization and 
Mortality Rates Cannot Be Adequately Supported."

13. As mentioned in response to comment 7 above, the inaccurate, 
inappropriate, and incomplete source term data and assumptions that we 
describe in the report would apply equally to simulations conducted 
throughout the period from 1996 to the present. The statement in 
appendix I reflects DOD's chronology of modeling events, not our 
assessment or conclusion.

14. One of the central conclusions of our report is that DOD's plume 
modeling was flawed, and this conclusion applied to the 2000 plume 
modeling as well as to the 1997 plume modeling. As for the comment that 
"GAO never mentions several completed epidemiology studies that used 
the results of the 2000 plume modeling," these studies were not 
mentioned for varying reasons. Smith and others, showed that 
hospitalization rates for several ICD-9 diagnoses were higher in 
veterans categorized in the Khamisiyah 2000 plume than in those not in 
the plume, and the association for cardiac arrhythmias was 
statistically significant. However, that study suffered from the same 
deficiencies as the earlier study that we cited--namely, inappropriate 
use of hospitalization outcome measures rather than appropriate use of 
measures of Gulf War illness, which usually do not result in 
hospitalization, and use of plume modeling based on flawed data. The 
2002 Kang and Bullman study has not been published in a peer-reviewed 
journal and therefore should not have been included in a review of the 
scientific epidemiologic literature. This subject is discussed in 
further detail in our response to DOD's comments on the section "DOD's 
and VA's Epidemiological Conclusions on CW Exposure and Hospitalization 
and Mortality Rates Cannot Be Adequately Supported."

In response to the comment that "GAO's review of the literature is 
selective [and] incomplete," we do not agree with this characterization 
of the literature review. We reviewed all published literature. The 
review of the literature was focused on assessing the validity of DOD 
and VA conclusions from the epidemiological studies, based on DOD's 
plume-modeling results that there was no association with CW exposures 
at Khamisiyah and troops' hospitalization and mortality rates. We 
address specific reasons for excluding reports DOD identified in our 
response to DOD's comments in the section "DOD's and VA's 
Epidemiological Conclusions on CW Exposure and Hospitalization and 
Mortality Rates Cannot Be Adequately Supported."

With respect to the comment that we ignored the Department of Defense 
Low-Level Chemical Warfare Agents (CWAs) Research Master Plan, June 
2003, or the results of any of the research indicated in the plan, we 
repeat that the review of the literature was focused on assessing the 
validity of DOD and VA conclusions from the epidemiological studies, 
based on DOD's plume-modeling results that there was no association 
with CW exposures at Khamisiyah and troops' hospitalization and 
mortality rates.

With regard to the comment that "GAO does not explain what it thinks 
would be a better method to assess exposure," we believe that some of 
the methodologies we cite in this report provide valuable insight into 
the identification of both the effects of exposure and those who were 
likely to have been affected by exposure. The methodologies include the 
identification of biomarkers or genetic polymorphisms, animal model 
studies that attempt to recreate the suspected event and evaluate the 
appearance of a similar outcome, epidemiological studies in which the 
cohort classifications can be safely made (such as deployed, 
nondeployed, or deployed outside the period of potential exposure).

Regarding the comment that we "appear to favor some studies of 1991 
Gulf War veterans that are mentioned on pages 52 to 61 [now 50 to 55], 
which seems to imply that GAO thinks these studies used a superior 
method of exposure assessment, compared to the DOD modeling," we 
believe that in the absence of more reliable meteorological and source 
term data relating to the 1991 Gulf War, the DOD plume modeling must be 
considered inferior to other methodologies that avoid the selection 
bias likely to be introduced as a result of using the DOD Khamisiyah 
ensemble plume modeling, for the reasons cited in this report.

Concerning the comment "some of the studies GAO mentioned did not 
evaluate possible chemical warfare exposure at all," we evaluated only 
studies that examined possible CW agent exposure, genetic polymorphisms 
believed to be associated with CW agent exposure, animal model studies 
associated with CW agent exposure, and studies that used the DOD 
ensemble plume models (1997, 2000).

15. The initiation of the bombing of Iraq's CW research, production, 
and storage sites began on January 17, 1991. The release of 
environmental hazards associated with the open-air destruction of these 
facilities would have commenced on that date rather than on the ground 
invasion that began on February 25, 1991. U.S .and British forces did 
not have to penetrate these sites to be at risk from the potential 
health consequences of the fallout of material released as a result of 
these bombings. In addressing fallout, we were referring to hazardous 
materials thrust into the air and potentially exposing troops to CW 
agents at subacute levels at significant distances downwind. "Located 
near" is a relative term intended only to reflect that the troops were 
close enough to be at risk for exposure. This is not only our 
observation; it was also a concern of the war planners before the onset 
of Operation Desert Storm, as reflected by requests for hazard 
assessments modeling the U.S. Air Force made to Lawrence Livermore 
National Laboratories.

16. We concur and the report has been clarified accordingly.

17. We concur and the report has been clarified accordingly.

18. We concur with this comment and have clarified the report 
accordingly.

19. We concur with this comment and have clarified the report 
accordingly.

20. Our statement addresses not how DOD classified the troops during 
the modeling process but, rather, how researchers later used these data 
to classify troops into exposed and not exposed study cohorts in 
conducting health-related studies.

21. Our determination that conclusive classification criteria are 
unsupported does not mean or assume that the entire population was 
exposed. But the classification by researchers is not supported by 
reliable scientific, or any other, evidence since the determination of 
who was and who was not exposed is based on flawed and inaccurate data 
and the exclusion from the ensemble modeling estimates of modeling 
simulations that projected larger and directionally divergent potential 
exposure areas. Given the uncertainty associated with determining who 
was and who was not exposed and with determining whether or not the 
demolition of the Khamisiyah pit represents a single exposure event, 
researchers will have to assess, independent of the modeling performed 
and the ensemble projections, who was and who was not exposed.

The observation that not all those who were exposed are ill applies 
equally, whether the DOD models and the ensemble estimates are viewed 
as accurate or flawed. This phenomenon is much more likely to be 
attributable to the genetic susceptibility of certain individuals to be 
physically affected by exposure at varying exposure levels.

22. The recommendation is intended to apply only to the 1991 Gulf War, 
and we have amended the recommendation to clarify its intent.

23. While it is not part of modeling methodology, it was part of the 
process DOD used in examining this issue. The report has been 
clarified.

24. We concur with this comment and have clarified the report 
accordingly.

25. DOD is correct in characterizing SCIPUFF as a component of HPAC and 
we have changed the language accordingly. DOD comments regarding NUSSE 
and ADPIC, however, are contradicted by the record. On September 4, 
1997, the CIA and DOD issued a report entitled "Modeling the Chemical 
Warfare Agent Release at the Khamisiyah Pit (U)." In that report, the 
CIA identified transport and diffusion models used in this effort to 
include SCIPUFF, VLSTRACK, and NUSSE4. The MATHEW/ADPIC suite of models 
were, based on documentation supplied to us by officials at the 
National Atmospheric Release and Advisory Capability, Lawrence 
Livermore National Laboratory, used in simulations of the Khamisiyah 
pit performed at the request of IDA in late 1996 and early 1997.

26. The section DOD cites does not imply that DOD or the CIA suggested 
that there can be "definitive conclusions" from the modeling process. 
Rather, it states that "The models are neither sufficiently certain nor 
precise to draw definitive conclusions about the size or path (that is, 
the direction) of the plumes." It was the use of this information to 
define study cohorts in follow-on government funded health-related 
research that resulted in our comment.

27. We concur with this comment and have clarified the report 
accordingly. However, the MATHEW/ADPIC models were used in the 
simulations of the Khamisiyah pit, performed at IDA's request in late 
1996 and early 1997.

28. DOD is correct that MM5 and COAMPS are commonly used mesocale 
meteorological models. However, when they were used with dispersion 
models (such as VLSTRACK), which were not fully developed for long-
range environmental hazards and in conjunction with uncertain 
meteorological and source term data, meteorological models such as MM5 
could not overcome the limitations of the dispersion models. The 
validation of VLSTRACK at 220 km still falls far short of the distances 
contemplated in this report.

29. This statement is based on an internal DOD memorandum, dated 
December 18, 1998, with the subject "Discounting the Results of the 
Omega Version 3.5 for the Khamisiyah Reanalysis and Al Muthanna 
Analysis." The memorandum states that the Omega consistently 
underpredicts surface wind speeds by a factor of 2 to 3 from actual 
observation collected at the five world meteorological stations in the 
area.

30. This statement is based on a 1999 IDA report evaluating the 
variance of VLSTRACK and HPAC predictions for the dispersion of 
chemical and biological warfare agents. The IDA report noted that for 
chemical releases, the HPAC and VLSTRACK predictions of areas of hazard 
differed substantially and that for biological releases they differed 
by factors of 5 and 1,000.

31. The statement DOD quotes is based on a 1998 memorandum from DOD's 
Deputy for Counterproliferation and Chemical and Biological Defense. 
This memo states: "VLSTRACK and HPAC generate hazard predictions that 
are significantly different from an operational perspective." 
Correspondence to GAO from the Deputy's Modeling and Simulation Advisor 
noted that "the 1998 project found significant errors in the coding of 
one of the models such that for analyses conducted prior to that date, 
I would not consider that model reliable for use."

32. We concur with this comment and have clarified the report 
accordingly.

33. It is, in part, this observation that causes us to view as 
uncertain the plume data DOD subsequently presented. Even the most 
elegant and precise model will provide inaccurate results if it uses 
inaccurate data.

34. We reported that "Assumptions about the purity of the CW agents 
sarin and cyclosarin established for Khamisiyah, Al Muthanna, 
Muhammadiyat, and Ukhaydir differed widely. In each case, agent purity 
was a key factor in the CIA and DOD methodology for determining the 
amount of agent released. For example, for modeling purposes, 10 tons 
of agents with a purity of 18 percent would be represented as 1.8 tons 
of agent. The CIA relied on UNSCOM reporting on the amount of CW agents 
Iraq produced. But to establish these rates, UNSCOM relied primarily on 
Iraqi declarations and Iraqi production records, as well as assumptions 
about the extent of agent degradation." This section was included to 
demonstrate that varying rather than consistent methodologies of 
differing levels of credibility were used in deriving the estimated 
agent purity. It was also used to explain the methodology used by the 
CIA and DOD in determining the maximum amount of agent available for 
dispersion. The report was clarified to address DOD's comment.

35. We were not suggesting that complete transfer occurred. Rather, we 
were providing other science-based evidence that is contrary to the 
earlier DOD observation that little or no transfer occurred. The 
overpressures generated by high explosives have to go somewhere. In a 
building, the structure would be destroyed. In a bunker, if the 
structure were not destroyed, this overpressure release would occur 
through the openings in the structure.

36. The photographs DOD referred to show the view from the opening in 
the top of Bunker 2, as well as several aerial views. According to 
UNMOVIC, however, UNSCOM did not physically inspect this bunker for 
safety reasons relating to structural instability. This observation 
seems to be confirmed by the photos referred to in the report DOD 
cited.

37. Given the images available, while the munitions may not have been 
targeted directly, they certainly seem to have been hit.

38. We are aware of the design of the Dugway testing and its purpose to 
simulate the demolitions at the Khamisiyah pit. Contrary to the DOD's 
assertion, the use of Dugway testing data for evaporation and 
degradation at Muhammadiyat is inappropriate for either leakage or 
destruction by high-explosive bombs, neither of which were approximated 
by the conditions at Dugway or at Khamisiyah. For example, the type and 
quantity of explosives used in the Dugway testing and, therefore, the 
resulting effects were not comparable to the type and quantity of 
munitions that were actually used at Muhammadiyat. At Dugway Proving 
Ground, small explosive charges were placed on boxed rockets; at 
Muhammadiyat, the munitions were targeted with multiple high-explosive 
bombs.

39. The CIA Report on Intelligence Related to Gulf War Illnesses, dated 
August 2, 1996, included modeling of Bunker 73 and identified the 
effort as being done by the CIA in parallel with DOD's Persian Gulf 
Investigative Team, to determine whether U.S. troops were exposed to 
chemical and biological warfare agents during the Gulf War. The CIA's 
effort did not seek to duplicate DOD's; however, CIA analysts drew on 
and examined DOD information to clarify intelligence, obtain leads, and 
ensure a thorough and comprehensive intelligence assessment. We have 
clarified the report to reflect that this was a CIA modeling effort.

40. According to Iraqi declarations and UNSCOM, the stocks at Bunker 73 
were part of the same lot as that discovered at the Khamisiyah pit, and 
the munitions in the pit were estimated to have a purity of up to 50 
percent when demolitions occurred. Therefore, a 2.5 percent purity rate 
is not supported. We concur that the earlier modeling and source term 
were performed by the CIA; however, later, after the IDA panel judged 
the models used in the early modeling efforts to be inappropriate, no 
effort was made to reexamine the releases from this site.

41. Our statement was taken out of context. The entire statement reads 
"DOD reported that the Al Muthanna research, production, and storage 
facility for CW agents was repeatedly attacked. Despite its repeated 
bombing, however, on only one occasion did the CIA and DOD express any 
concern about agent release. According to DOD analysis of the 
destruction of Bunker 2 at Al Muthanna on February 8, 1991 . . . ." 
This is to suggest not that the CIA and DOD are unconcerned about this 
issue but only that they were only sufficiently concerned to publish 
the results of their modeling in connection with this singular event at 
Al Muthanna, despite the repeated bombings of this principal Iraqi CW 
agent research, production, and storage facility.

42. We do not agree with DOD. According to UNMOVIC, UNSCOM never 
inspected this bunker for safety reasons.

43. We explained the methodology used by DOD and have clarified the 
report by deleting the comparison with Khamisiyah.

44. This section refers to the detections identified in table 4, of the 
report, now on p. 26. The comment that no confirmatory testing was 
conducted is not accurate. The Czech chemical detection unit reported 
the detections to U.S. command officials immediately, as is reflected 
in both the Czech and CENTCOM NBC logs, but the responding units were 
unable to confirm their findings when they arrived hours after the 
initial detections on January 19, 1991, and were unable to confirm 
these reports. However, in addition to the field detections, the Czech 
chemical detection units conducted reagent based wet chemistry 
confirmation tests that supported the findings of the initial 
detections. The French never officially acknowledged the detections 
attributed to their units; however, the CENTCOM NBC logs again noted 
that the French reported detecting chemical nerve agents on January 19, 
1991, and that the Czechs confirmed the French detections. In addition, 
according to an Agence France Presse report, on February 4, 1991, 
General Raymond Germanos, a spokesperson for the French Ministry of 
Defense, was attributed as having confirmed that chemical fallout, 
"probably neurotoxins" had been detected in small quantities, "a little 
bit everywhere," from allied air attacks of Iraqi CW facilities and the 
depots that stored them.

45. Since this NOAA-11 AVHRR-1B imagery was being used to demonstrate 
meteorological activity between January 18 and January 23, 1991, and 
not at some specific time, the exact time each image was captured will 
not add to or detract from its evaluation.

46. The coincidence between these and other events involving the 
destruction of Iraq's CW agent research, production, and storage 
infrastructure using aerial bombs and cruise missiles, and the reported 
airborne detections of CW agents by Czech, French, U.S., and British 
forces (see table 4) suggest that DOD and the CIA should have 
reassessed their positions regarding the potential for additional 
exposure events.

47. We concur and the figure has been clarified accordingly.

48. The discussion in this section of the report deals with temperature 
inversions. Unlike a capping inversion, which is almost a constant 
feature in the atmosphere, a temperature inversion is not. When a 
temperature inversion occurs, air pollutants can be trapped near the 
surface of the Earth.

49. Figure 4 has been corrected to axis labels and time of day 0008Z.

50. In the April 2002 Gulf War Illness Task Force Report, "Intelligence 
Update: Chemical Warfare Agent Issues during the Persian Gulf War," the 
CIA assessed that "the Czech detections were unlikely to be from a 
chemical agent." The Czech chemical detection units conducted wet 
chemistry confirmation tests supporting the initial detections. We have 
clarified the report to remove the reference to DOD in the relevant 
sentence.

51. We agree that the initial modeling referred to was that performed 
by LLNL for IDA and not included in the DOD ensemble model. This 
modeling effort actually assumed fewer rockets destroyed than were 
later assessed to be present at Khamisiyah and that produced a plume 
path considerably larger and more divergent from those selected for use 
in the DOD ensemble.

52. The use of the power-law formula was intended to illustrate the 
unreasonable heights assumed during the DOD modeling efforts. Clearly 
not all the agent would be released simultaneously into the atmosphere 
and the agent released would be distributed throughout the plume 
geometry, but the power-law formula also projects the plume height at 
time = 2 minutes. After that time, the plume continues to grow in 
height. In some cases, at time = 5 minutes the plume heights nearly 
double. Further, the distribution used in the Khamisiyah pit is based 
on field and laboratory testing conducted at Dugway Proving Ground that 
inadequately simulated the conditions at the pit and did not simulate 
conditions at the other sites modeled at all. We concur that the 
Khamisiyah pit demolition, which occurred around 4:15 pm local time, 
when the atmospheric boundary layer was convective and well mixed, 
would have been insensitive to the argument of nocturnal low-level jet. 
The other sites, however, were bombed during the nighttime, and 
therefore this argument remains valid. The power-law formula 
demonstrates the relationship between the amount of explosives 
detonated and the resultant plume height. Whether this occurs by 
demolition or aerial bombing is irrelevant. The issue of top boundary 
versus centroid of the plume is addressed in our report (see figure 8). 
Regarding buoyant puff at Khamisiyah, DOD based its comment on Dugway 
field testing, which did not realistically simulate actual conditions 
at the Khamisiyah site.

53. Videos of the demolition operations at Khamisiyah have been widely 
released. While we concur that videos do not show data, they can 
certainly demonstrate that DOD data assumptions, such as plume height 
estimates, are inaccurate, because the plume height was higher than DOD 
assumptions.

54. Figure 6 shows the layers in which these activities occur. We have 
changed the report to clarify this reference.

55. This statement should read "Empirical studies and observed events 
tend to refute the assumptions with which the CIA and DOD discounted 
the alternative assumption that the plume was transported by low-level 
jets." The empirical studies are those involving the likely plume 
heights reached in high-explosive explosions. The observed events are 
the reported detections of CW agents associated with temperature 
inversion activity and atmospheric turbulence. We changed the report 
accordingly.

56. We did not make this assumption; rather, it is a possibility we 
were obliged to consider when evaluating the potential for the long-
range transport of CW agents. It is precisely the absence of on-site 
measurements leading to this additional element of uncertainty for a 
phenomenon that is far from rare that has resulted in our questioning 
DOD's and CIA's discounting this phenomenon, despite having been 
cautioned to consider the possibility by a DOD expert consultant.

57. Nothing in this section of the report suggests that either long-
range advection (transport of pollution) or turbulence events occurs 
independent of dispersion or dilution. In fact, exposures occurring at 
these distances would almost by necessity be at low or subacute levels. 
The report also does not suggest that the low-level jets function 
independent of turbulence. But aircraft and artillery would produce a 
directional shift in turbulence, possibly resulting in mixing to the 
surface. The characterization of the MATHEW wind field model as one we 
favored is not accurate. The MATHEW/ADPIC suite simulations are simply 
demonstrative of the uncertainty associated with the modeling process.

58. We understand the financial and practical limitations in conducting 
this sort of testing. Still, differences in experimental conditions can 
result in profound differences in outcome. For example, there may have 
been more agent dispersed immediately, leaving less to evaporate over 
time had the simulations been conducted under different conditions.

59. We agree with this comment. Predictive modeling is a crucial asset 
and should be so considered. Retrospective modeling, however, in the 
absence of robust data is far more easily criticized as "deficient," 
not necessarily because of deficiencies in the models or the approach, 
but because of the lack of validated input data and a selection process 
that is subject to limited available data, an inexact intelligence 
assessment process, and the potential for individual bias.

60. We do not agree with DOD's characterization. Despite not having 
modeled the same quantities, LLNL modeled a variety of release 
scenarios and used the meteorological data available for the region. 
This modeling effort actually assumed a similar number of rockets 
destroyed as were later assessed to have been destroyed at Khamisiyah 
by the CIA in 2002, yet it produced a plume path considerably larger 
and quite divergent from the models selected for use in the DOD 
ensemble. We do not understand why IDA characterized the model as less 
capable. The LLNL models had an established history of modeling the 
release of hazardous materials, including the 1991 Kuwaiti oil fires.

In February 1991, during the last few days of the Gulf War, the Iraqis 
ignited about 605 oil wells, causing an unprecedented environmental 
disaster in the region. During spring and summer 1991, two working 
groups, one sponsored by the World Meteorological Organization in 
conjunction with the World Health Organization and the other consisting 
of the U.S. government's scientific community, conducted airborne 
sampling programs to evaluate the local and global consequences of 
these fires. The Atmospheric Release Advisory Capability (ARAC), 
incorporating the MATHEW/ADPIC modeling suite, provided daily forecasts 
of the location and density of the smoke plumes in support of these 
aircraft missions, and concurrently to all the countries affected.

The modeling was performed in the same region and during the same 
general time as the Khamisiyah event and the 1986 nuclear reactor 
accident at Chernobyl.[Footnote 65] In conjunction with the Chernobyl 
event, LLNL's long-range particle-in-cell model accurately simulated 
the spread of the radioactive cloud over the entire northern 
hemisphere, as verified later by radiological measurements. The NARAC 
emergency response central modeling system LLNL currently uses consists 
of a coupled suite of meteorological and dispersion models. The data 
assimilation model ADAPT constructs fields of such variables as the 
mean winds, pressure, precipitation, temperature, and turbulence, using 
a variety of interpolation methods and atmospheric parameterizations. 
Nondivergent wind fields are produced by an adjustment procedure based 
on the variational principle and a finite-element discretization. The 
dispersion model LODI solves the 3D advection-diffusion equation using 
a Lagrangian stochastic; LODI includes methods for simulating the 
processes of mean wind advection, turbulent diffusion, radioactive 
decay and production, bioagent degradation, first-order chemical 
reactions, wet deposition, gravitational settling, dry deposition, and 
buoyant/momentum plume rise. The models are coupled to NARAC databases 
providing topography, geographical data, chemical-biological-nuclear 
agent properties and health risk levels, real-time meteorological 
observational data, and global and mesoscale forecast model 
predictions. The NARAC modeling system also includes an in-house 
version of the Naval Research Laboratory's mesoscale weather forecast 
model COAMPS. This is a mesoscale meteorological model that LLNL has 
incorporated into its modeling suite.

61. Regarding the comment, "the source term is different," LLNL modeled 
a variety of release scenarios and used the meteorological data 
available for the region. This modeling effort actually assumed a 
similar number of rockets destroyed as were later assessed to have been 
destroyed at Khamisiyah by DOD in 2002, yet it produced a plume path 
considerably larger and quite divergent from the models selected for 
use in the DOD ensemble. According to DOD's technical report, "Modeling 
and Risk Characterization of U.S. Demolition Operations at the 
Khamisiyah Pit" (April 16, 2002), released by William Winkenwerder, 
Jr., Assistant Secretary of Defense (Health Affairs) and Special 
Assistant to the Under Secretary of Defense (Personnel and Readiness) 
for Gulf War Illnesses, Medical Readiness, and Military Deployments, 
the input source parameters used in the 1997 Khamisiyah pit modeling 
included a best estimate of 500 rockets damaged in demolition, based on 
UNSCOM reporting and intelligence information. According to the report, 
this number could be as high as 650 or as low as 170, based on number 
of rockets minus rockets found by UNSCOM that were undamaged. The same 
report estimated that the total number of rockets in the pit was 1,250. 
Again, according to the report, this number could be as high as 1,400 
or as low as 1,100, based on size of crates and stacks of rockets.

Regarding the comment "area-defining thresholds are different," we 
concur. However, the legend in figure 10 acknowledges this difference. 
Regarding the comment "dosage accumulation times are different," we 
concur. Again, however, this issue is addressed in the footnote 
defining these factors. Regarding the comment "meteorological fields 
are different," again, we concur with this observation. However, this 
comment is self-evident in that the plume is moving in a different 
direction. It is important to note that the corrections above do not 
have any effect on our conclusions. The use of the composite image is 
intended to illustrate that the use of different models, based on 
different underlying principles and assumptions, can result in 
different outcomes. In that regard, it is not misleading.

The fact that Iraq is a data-sparse region only serves to strengthen 
our observation that the uncertainty associated with attempting to 
model the fallout from the Khamisiyah pit, and to an equal or greater 
degree the other sites modeled, is too great to provide meaningful 
results. If an ensemble approach is to be attempted, then a range of 
methodologies needs to be incorporated.

62. That our language "could be explained" suggests that it is only one 
possible reason. When we interviewed researchers at LLNL, they noted 
that this diffluence may account for the different outcomes.

63. Figure 12 not only illustrates intermodel bias; it also illustrates 
model, and potential ensemble, bias. In the case illustrated, an 
ensemble of the three models would still not incorporate the area 
containing the actual hazard. We concur that ensemble modeling is 
essential in minimizing uncertainty and providing hazard warning. But 
as illustrated by figure 12, even in using an ensemble approach, 
significant uncertainty remains.

64. Our report has been clarified to reflect the use of consistent 
source term for SCIPUFF and VLSTRACK in the 2000 modeling. This 
reconciliation in source term does not, however, change any of our 
other observations or recommendations regarding the uncertainty 
associated with the source term, including the observation that, even 
with harmonized source, model projections still differ.

65. We do not agree that this is a misleading statement. While each of 
DOD's modeled plumes was based on data, the composite or ensemble plume 
was based on a simple graphic overlay of the projection of the three 
component plumes. The relationship between these plumes, therefore, was 
not based on data.

66. One of the central conclusions of our report is that DOD's plume 
modeling was flawed, and this conclusion applied to the 2000 plume 
modeling as well as to the 1997 plume modeling, because both suffered 
from the same weaknesses. That is, the models were not fully developed 
for long-range environmental hazards, and source term and input data 
were incomplete. Regarding the comment that "Several relevant studies 
have been published . . . that GAO did not mention," we have now 
incorporated these studies in our report.

67. As we explained in our report, the PON group of enzymes is a 
potentially important predisposing factor in Gulf War illnesses because 
one of its major functions in normal body physiology is to protect the 
nervous system from organophosphate chemical toxins, such as pesticides 
and nerve agents. This finding was remarkable because the only function 
of Q type of the PON enzyme group is to protect the nervous system from 
nerve agents sarin, soman, tabun, and VX. The R-type isoenzyme has as 
its main function protection from organophosphate pesticides, such as 
diazinon, malathion, and parathion. Thus, an association between Gulf 
War illnesses and blood levels of only the Q-type isoenzyme of PON 
points specifically to nerve agent exposure. Therefore, they were being 
cited to illustrate studies that have examined paraoxonase deficiencies 
in veterans reporting Gulf War Syndrome.

DOD's second paragraph is inaccurate. We did review the three studies 
cited in DOD, footnote 14. First, we rejected the Greenberg and others 
reference (second citation in DOD footnote 14). It is a letter to the 
editor merely commenting on possible errors in the recall of vaccine 
receipt in British Gulf War veterans; it did not deal with self-reports 
of CW agents and was not peer reviewed.

The two other studies DOD cited, McCauley and others (the first 
citation in DOD's footnote 14) and Wessely and others (the third 
citation in DOD's footnote 14) both reported studies that measured the 
level of agreement on self-reported endorsement of various wartime 
environmental exposures in ill and well Gulf War veteran populations. 
These studies do not demonstrate recall bias. In fact, they contradict 
that claim. DOD has overlooked that recall bias results from 
nondifferential misclassification of exposure measurements in the case 
and control groups. Simply finding that some veterans misreported their 
exposures does not establish recall bias; other criteria are required 
to establish that. Both studies showed moderate to good levels of test-
retest agreement (kappa >0.4) on self-reports of CW agent exposure, 
but, more importantly, the level of test-retest agreement (kappa 
statistic) did not differ between the ill and well groups. This means 
that whatever errors in recall occurred were nondifferential (occurred 
at the same rate in both groups), and therefore they did not bias the 
estimates of the relative risks for CW agent exposure. This means also 
that the errors in recall did not result in recall bias.

68. In suggesting that "Most" of the animal studies "cannot be directly 
extrapolated to the possible health effects of low-level sarin exposure 
in 1991 Gulf War veterans," DOD has missed the important developments 
in recent studies cited in our report that can be directly extrapolated 
to the health effects of low-level sarin exposure in the 1991 Gulf War. 
The best examples are the DOD-funded experiments by Henderson and 
others from the Lovelace Respiratory Research Institute and from the 
U.S. Army Medical Institute of Chemical Defense (Toxicol Appl Toxicol 
184 (2002): 67-76). This study modeled the low-level inhalation 
exposure in rodents to sarin, with and without heat stress. No 
immediate health effects were measured by clinical indicators and brain 
pathological examination. However, 30 days after cessation of exposure, 
the rodents were found to have developed physical evidence of brain 
cell damage, demonstrated using sophisticated microscopic, 
neurochemical brain examination techniques. Once structural changes are 
found, the capability of sarin to cause chronic brain illness is 
established, and following the animals in the longer term is 
unnecessary. Other studies we cited add depth to the significant 
findings of Henderson and others and establish a body of evidence 
demonstrating the potential of subacute sarin exposures to cause brain 
cell damage and related chronic symptoms.

69. DOD's response fails to distinguish between veterans having only 
symptoms relating to different organ systems and veterans having 
classic diseases of those organ systems to which physicians assign ICD-
9 codes and for which they often hospitalize patients. The public 
health problem of 1991 Gulf War veterans is characterized by a 
collection of symptoms of various organ systems in which physicians 
typically do not recognize classic, diagnosable diseases for which ICD-
9 codes exist. And since veterans with this problem are generally not 
critically ill enough to require hospitalization, their physicians do 
not hospitalize them more commonly than they do veterans without the 
condition. This is why DOD and VA studies with hospitalization as the 
outcome have not been productive.

The Gulf War illness manifested by serious symptoms but no physical 
signs is the example of chronic illness in 1991 Gulf War veterans that 
would not lead to hospitalization. Recent studies by several 
investigators at different institutions have shown that this set of 
conditions stems from physical damage to brain cells in deep parts of 
the brain.

By stressing that DOD "hospitalization data are very complete for 
active-duty personnel," DOD overlooks the significant selection bias 
that results from studies that rely on DOD hospitalization data alone 
as an outcome measure. Since most of the more severely ill Gulf War 
veterans left the military soon after the 1991 Gulf War, they were no 
longer eligible for hospitalization in DOD hospitals and, thus, their 
further hospitalizations were no longer counted. This "attrition" of 
the most ill veterans creates a strong selection bias in these studies 
toward falsely negative findings.

Gray and others (DOD's footnote 16) fails to address the observation 
that Gulf War illness does not satisfy the diagnostic criteria for ICD-
9 codes for the illness categories Gray and others studied--for 
example, infectious diseases, neoplasms, endocrine diseases, and blood 
diseases. Gray's finding that these classic diagnoses, defined by ICD-
9 codes, were no more common in those who left the military soon after 
the war does not address the issue of selection bias from using DOD 
hospital data. To the contrary, other data Gray and others provided in 
their 1996 paper, reviewed by Haley (Am J Epidemiol 148 (1998): 325-
23), demonstrated conclusively that military personnel discharged soon 
after the war did have largely different reasons for being discharged 
from the service, which points to a selection bias.

The references to the studies involving the California Office of 
Statewide Health Planning and Development and VA are not relevant in 
assessing the health effects of CW agent exposure, because these 
studies did not relate illness to CW agent exposure measures.

70. We did review all the studies cited but found them unsuitable for 
consideration for the following reasons. Smith and others (DOD's 
footnote 17) used inappropriate outcome measures (ICD-9 diagnoses made 
in hospitalized patients) and unsupported measures of CW agent 
exposure--that is, the 2000 Khamisiyah plume model addressed in the 
report. Consequently, no useful conclusions can be derived from it. 
Kang and Bullman (DOD's footnote 18) is an internal VA technical report 
that has not been peer reviewed or published in a scientific journal 
and therefore is not appropriate for inclusion in a review of the 
scientific epidemiologic literature. McCauley and others (the first 
citation in DOD's footnote 19) found that 1991 Gulf War veterans who 
witnessed the Khamisiyah demolition (a more valid measure of Khamisiyah 
exposure than the flawed plume models) had more chronic symptoms on 
average than those who did not witness it. This study suggests a causal 
role of Khamisiyah-associated sarin exposure in chronic Gulf War 
illness. We did not include the paper by Shapiro, Lasarev, and McCauley 
(second citation in DOD's footnote 19) because an anomalous problem 
with its factor analysis method appeared to disqualify its findings on 
a methodological basis. The investigators performed factor analysis of 
symptoms in a random sample of 1991 Gulf War veterans and found that 
those who actually witnessed the Khamisiyah demolition were 
significantly more likely to have their syndrome factor 2 ("dysesthesia 
syndrome"). While this appears to support a causal role of Khamisiyah-
associated sarin exposure in chronic Gulf War illness, the authors also 
reported that their factor analysis method was unreliable when applied 
to randomly generated variables. If this study were included, however, 
it would suggest a causal link with CW agent exposure. As for the two 
studies by Smith and others (DOD's footnote 20), we did not include 
these because both used participation in the DOD and VA registries as a 
proxy case-definition for Gulf War illness. Since military personnel 
and veterans were free to participate in the registry, regardless of 
whether or not they were ill or, if ill, the nature of their illness, 
registry participation is an entirely nonspecific measure and not 
suitable for scientific research on the problem. The two studies showed 
that registry participation and hospitalization were more common in 
veterans who were present at the Khamisiyah risk area than those who 
were not. Although the findings would support a causal link of CW agent 
exposure and illness, their methods do merit inclusion in a scientific 
literature review.

71. We believe that the images in figure 17 are adequate to demonstrate 
the modeled diffluence in wind field data. While we cannot improve the 
quality of the figure, we have added an arrow to show the diffluence.

[End of section]

Appendix VII: Comments from the Central Intelligence Agency:

25 May 2004:

MEMORANDUM FOR:	Mr. Jason Fong, General Accounting Office (GAO):

SUBJECT: Central Intelligence Agency (CIA) Interim Response to GAO Draft 
Report "DOD's Conclusions about U.S. Troops' Exposure Cannot Be 
Adequately Supported" (GAO-04-159):

1. We appreciate your providing a copy of the draft report, Gulf War 
Illnesses: DOD conclusions about U.S. Troops' Exposure Cannot Be 
Adequately Supported (GAO-04 159), for CIA's review and comments. We 
regret, however, that we cannot complete our review in the ten days 
allotted and therefore must nonconcur with the report pending 
completion of a comprehensive review, which we estimate will require 
three to four weeks.

2. The CIA's Biological and Chemical Group conducted a preliminary 
review of the report and identified numerous statements that they 
consider inaccurate, such as 'source term data quantity and purity of 
the agent were inaccurate because they were uncertain, incomplete, and 
nonvalidated." They contend that the agent source term is complete and 
accurate to a known certainty. The agent source term is based on 
testing by an Iraqi quality control laboratory as well as later by 
UNSCOM-sponsored testing in world-class laboratories.

3. The CIA will provide a formal response outlining all of our concerns 
in the coming weeks.

Sincerely, 

Signed by: 

Hannah P. Marter: 
Liaison Group: 
Office of Congressional Affairs 
Central Intelligence Agency:

c.c. Mr. John Davies 
Chief, Iraq Team Biological and Chemical Group:

[End of section]

FOOTNOTES

[1] Appendix I contains a detailed chronology of DOD's modeling events.

[2] Central Intelligence Agency, CIA Report on Intelligence Related to 
Gulf War Illnesses (McLean, Va.: Aug. 2, 1996).

[3] U.S. General Accounting Office, Gulf War Illnesses: Preliminary 
Assessment of DOD Plume Modeling for U.S. Troops' Exposure to Chemical 
Agents, GAO-03-833T (Washington, D.C.: June 2, 2003). www.gao.gov.

[4] G. C. Gray and others, "The Postwar Hospitalization Experience of 
Gulf War Veterans Possibly Exposed to Chemical Munitions Destruction at 
Khamisiyah, Iraq," American Journal of Epidemiology 150 (1999); H. K. 
Kang and T.A. Bullman, "Mortality among U.S. Veterans of the Persian 
Gulf War: 7 Year Follow-Up, "American Journal of Epidemiology 154 
(2001): 399-409.

[5] The Presidential Advisory Committee on Gulf War Veterans' Illnesses 
was established by Executive Order 12961 on May 26, 1995, to provide 
oversight for Gulf War illness investigations; it terminated in 
November 1997. http://www.gwvi.ncr.gov/ (Apr. 26, 2004).

[6] Central Intelligence Agency, CIA Report on Intelligence.

[7] Central Intelligence Agency and the Department of Defense, Modeling 
the Chemical Warfare Agent Release at the Khamisiyah Pit (McLean, Va.: 
Sept. 1997).

[8] We use dispersion in this report to refer to both transport and 
diffusion models.

[9] A binary weapon mixes two less toxic materials to create a toxic 
nerve agent within the weapon when it is fired or dropped.

[10] Central Intelligence Agency, Intelligence Update: Chemical Warfare 
Agent Issues during the Persian Gulf War (McLean, Va.: Apr. 2002).

[11] U.S. Army Dugway Proving Ground, Hazard Classification Tests of 
Igloo Storage of GB-and VX-Filled M55 Rockets, RTD&E Project 
1B650312D624, USATECOM Project 5-3-0135-02, DPGDR C-505 (Dugway, Utah: 
Apr. 1966).

[12] Central Intelligence Agency, Intelligence Update, p. 62.

[13] U.S. Army Armament, Munitions, and Chemical Command, Chemical 
Research Development and Engineering Center, Source Characteristics of 
a Fire within an Igloo Filled with M55 Chemical Munitions, CRDEC-TR-
87056 (Rock Island, Ill.: May 1987).

[14] National Academy of Sciences, Commission on Engineering and 
Technical Systems, Protecting Buildings from Bomb Damage: Transfer of 
Blast-Effects Mitigation Technologies from Military to Civilian 
Applications (Washington, D.C.: 1995), pp. 28-29.

[15] Central Intelligence Agency, CIA Report on Intelligence.

[16] Central Intelligence Agency, Intelligence Update.

[17] Precursors are chemicals and other materials used in producing CW 
agents

[18] See Czech chemical warfare report, Intelligence Assessment of 
Chemical and Biological Warfare in the Gulf, prepared by the U.S. Army 
Foreign Science and Technology Center and DIA for the Defense Science 
Board investigating Desert Storm Syndrome.

[19] Defense Intelligence Agency, Detection of Chemical Warfare Agents 
by Czechoslovak Unit during Desert Storm, Part III (U), IIR 6 284 0008 
94 (Washington, D.C.: Oct. 14, 1993).

[20] U.S. Army Operations Group, UNSCOM, Inspection of Chemical Warfare 
Facilities, IIR 2 201 0022 92 (Washington, D.C.: Oct. 3, 1991, 
declassified 1995). 

[21] G. I. Kent and others, Interim Report: Calculations and 
Measurements in Support of the Rocket Testing at Dugway Proving Ground 
(Dugway, Utah: June 17, 1997), p. 2.

[22] Kent and others, Interim Report: Calculations and Measurements, p. 
2.

[23] G. I. Kent and others, Interim Report: Rocket Motor Ignition/
Explosives Issue (Dugway, Utah: June 17, 1997), p. 15.

[24] Drainage winds, also called mountain or gravity winds, are caused 
by the cooling air along the slopes of a mountain. Drainage wind 
periods were intentionally chosen for Dugway testing to minimize the 
dispersion of the test materials to the surrounding areas. According to 
Dugway officials, these winds are common to Dugway Proving Ground in 
the morning before the development of the mixing layer.

[25] The composite approach DOD used is also known as the ensemble 
approach.

[26] "Minimal effect" is the lowest concentration expected to have 
noticeable effects on human beings.

[27] "Occupational limit" is about one-tenth of the minimal effects 
value and the maximum concentration level that would be allowed for a 
worker who could become exposed to sarin in the course of performing 
job duties.

[28] "General population limit" represents the limit below which any 
member of the general population could be exposed--by, for example, 
exhaling--7 days a week, every week, for a lifetime without 
experiencing any adverse health effects.

[29] Richard A. Anthes and others, "Comments by Review Panel on 
Khamisiyah Modeling Report and Presentations on November 4-5, 1997," 
report for the Directorate for Deployment Health Support of the Special 
Assistant to the Under Secretary of Defense (Personnel and Readiness) 
for Gulf War Illnesses, Medical Readiness, and Military Deployments, 
Fairfax, Virginia, December 11, 1997.

[30] In early 1997, the Senate Committee on Veterans' Affairs 
established a Special Investigation Unit on Gulf War Illnesses to 
conduct a bipartisan review of the U.S. government's response to the 
unexplained illnesses suffered by veterans of the Gulf War. The year-
long effort produced a detailed report on the actions by DOD before and 
during the war and by VA in its aftermath, relating to the current 
health of Gulf War veterans. See Arlen Specter, William F. Tuerk, and 
James R. Gottlieb, Report of the Special Investigation Unit on Gulf War 
Illnesses, U.S. Senate, Committee on Veterans' Affairs (Washington, 
D.C.: U.S. Government Printing Office, 1998).

[31] U.S. Air Force, Technical Applications Center, Report on 
Atmospheric Modeling of the 10 Mar 91 Chemical Warfare Agent Release at 
the Khamisiyah (Iraq) Munitions Pit (Patrick Air Force Base, Fla.: Dec. 
15, 1997).

[32] "Review of Events Concerning 32 Field Hospital and the Release of 
Nerve Agent Arising from U.S. Demolition of Iraqi Munitions at the 
Khamisiyah Depot in March 1991," December 1999.

[33] Institute of Medicine, Gulf War Veterans: Measuring Health 
(Washington, D.C.: National Academy Press, 1999), p. 36.

[34] R. W. Haley, "Point: Bias from the 'Healthy-Warrior Effect' and 
Unequal Follow-Up in Three Government Studies of Health Effects of the 
Gulf War," American Journal of Epidemiology 148 (1998): 315-38.

[35] R. W. Haley and T. L. Kurt, "Self-Reported Exposure to Neurotoxic 
Chemical Combinations in the Gulf War," JAMA 277 (1997): 231-37.

[36] See Michael B. Gregg, ed., Field Epidemiology, 2nd ed. (New York: 
Oxford University Press, 2002).

[37] R. W. Haley and others, "Is There a Gulf War Syndrome? Searching 
for Syndromes by Factor Analysis of Symptoms," JAMA 277 (1997): 215-22. 
The six syndrome factors were impaired cognition, confusion-ataxia, 
arthro-myo-neuropathy, phobia-apraxia, fever-adenopathy, and weakness-
incontinence.

[38] Impaired cognition is characterized by problems with attention, 
memory, and reasoning, as well as insomnia, depression, daytime 
sleepiness, and headache. (Study results showed relative risk 8.2, 95 
percent, CI 2.9-23.5, p = 0.001.)

[39] Confusion-ataxia is characterized by problems with thinking, 
disorientation, balance disturbances, vertigo, and impotence.

[40] (1) CW exposure, relative risk 7.8, 95 percent, CI 2.3-25.9, p < 
0.0001; (2) geographic location, relative risk 4.3, 95 percent, CI 1.9-
10.0, p = 0.004; (3) pyridostigmine side effects, dose-response trend 
up to relative risk 32.4, 95 percent, CI 7.8-135.0, p < 0.0001; (4) 
synergistic association, Rothman synergy statistic 5.3, 95 percent, CI 
1.04-26.7, p < 0.05. See Jonathan B. Tucker, "Evidence Iraq Used 
Chemical Weapons during the 1991 Persian Gulf War," The 
Nonproliferation Review 4:3 (Spring-Summer 1997): 114-22. Center for 
Nonproliferation Studies, Monterey Institute of International Studies, 
http://cns.miis.edu/pubs (Apr. 28, 2004); and U.S. Department of 
Defense, Office of the Special Assistant for Gulf War Illnesses, 
Coalition Chemical Detections and Health of Coalition Troops in 
Detection Area (Washington, D.C.: Aug. 5, 1996). http://
www.gulflink.osd.mil/czech_french/czfr_refs/n08en011/coalitn.html 
(Apr. 28, 2004).

[41] Arthro-myo-neuropathy is characterized by joint and muscle pains, 
muscle fatigue, difficulty lifting, and paresthesias of the 
extremities. (Results showed for exposure, dose-response effect to 
relative risk 7.8, 95 percent, CI 2.4-24.7, p < 0.0001; for side 
effects, dose-response effect to relative risk 3.9, 95 percent, CI 1.3-
12.1, p < 0.0001.)

[42] R. Nisenbaum and others, "Deployment Stressors and a Chronic 
Multisymptom Illness among Gulf War Veterans," Journal of Nervous and 
Mental Disease 188 (2000): 259-66.

[43] Association with "severe illness," adjusted OR 3.46, 95 percent, 
CI 1.73-6.91, p < 0.0001; association with "mild-moderate illness," 
adjusted OR 2.25, 95 percent, CI 1.54-3.27, p < 0.0001. See K. Fukuda 
and others, "A Chronic Multisymptom Illness Affecting Air Force 
Veterans of the Persian Gulf War," JAMA 280 (1998): 981-88.

[44] S. P. Proctor and others, "Health Status of Persian Gulf War 
Veterans: Self-Reported Symptoms, Environmental Exposures, and the 
Effect of Stress," International Journal of Epidemiology 27 (1998): 
1000-10.

[45] R. F. White and others, "Neuropsychological Function in Gulf War 
Veterans: Relationships to Self-Reported Toxicant Exposures," American 
Journal of Industrial Medicine 40 (2001): 42-54.

[46] K. Lindem and others, "Neuropsychological Performance in Gulf War 
Era Veterans: Traumatic Stress Symptomatology and Exposure to Chemical-
Biological Warfare Agents, Journal of Psychopathology and Behavioral 
Assessment 25:2 (2003): 105-19.

[47] Chemical odor, OR = 6.2, 95 percent, CI 3.9-9.9; antinerve gas 
pills, OR = 3.7, 95 percent, CI 2.4-5.6; formal alerts for CW attack, 
OR = 2.7, 95 percent, CI 2.0-3.7. See J. Wolfe and others, "Risk 
Factors for Multisymptom Illness in U.S. Army Veterans of the Gulf 
War," Journal of Occupational and Environmental Medicine 44:3 (2002): 
271-81.

[48] H. K. Kang and others, "Evidence for a Deployment-Related Gulf War 
Syndrome by Factor Analysis," Archives of Environmental Health 57:1 
(2002): 61-68.

[49] T. C. Smith and others, "Gulf War Veterans and Iraqi Nerve Agents 
at Khamisiyah: Postwar Hospitalization Data Revisited," American 
Journal of Epidemiology 158 (2003): 457-67.

[50] H. K. Kang and T. A. Bullman, Mortality among U.S. Gulf War 
Veterans Who Were Potentially Exposed to Nerve Gas at Khamisiyah, Iraq 
(Washington, DC: Department of Veterans Affairs, May 2002).

[51] R. W. Haley and others, "Association of Low PON1 Type Q (Type A) 
Arylesterase Activity with Neurologic Symptom Complexes in Gulf War 
Veterans," Toxicology and Applied Pharmacology 157 (1999): 227-33.

[52] B. Mackness and others, "Low Paraoxonase in Persian Gulf War 
Veterans Self-Reporting Gulf War Syndrome," Biochemical and Biophysical 
Research Communications 276 (2000): 729-33.

[53] See Matthew Hotopf and others, "Paraoxonase in Persian Gulf War 
Veterans," Journal of Occupational and Environmental Medicine 45 
(2003): 668-75, and C. Unwin and others, "Health of UK Servicemen Who 
Served in the Persian Gulf War," Lancet 353 (1999): 169-78.

[54] R. W. Haley and others, "Severely Reduced Functional Status in 
Veterans Fitting a Case Definition of Gulf War Syndrome," American 
Journal of Public Health 92 (2002): 46-47.

[55] K. Husain and others, "Delayed Neurotoxic Effect of Sarin in Mice 
after Repeated Inhalation Exposure," Journal of Applied Toxicology 13 
(1993): 143-45, and "A Comparative Study of Delayed Neurotoxicity in 
Hens Following Repeated Administration of Organophosphorus Compounds," 
Indian Journal of Physiology and Pharmacology 39 (1995): 47-50.

[56] Mohamed B. Abou-Donia and others, "Neurotoxicity Resulting from 
Coexposure to Pyridostigmine Bromide, DEET, and Permethrin," Journal of 
Toxicology and Environmental Health 48 (1996): 35-56, and "Increased 
Neurotoxicity Following Concurrent Exposure to Pyridostigmine Bromide, 
DEET, and Chlorpyrifos," Fundamentals of Applied Toxicology 34 (1996): 
201-22.

[57] Mohamed B. Abou-Donia and others, "Combined Exposure to Sarin and 
Pyridostigmine Bromide Increased Levels of Rat Urinary 3-Nitrotyrosine 
and 8-Hydroxy-2'-Deoxyguanosine, Biomarkers of Oxidative Stress," 
Toxicology Letters 123 (2001): 51-58; "Disruption of the Blood-Brain 
Barrier and Neuronal Cell Death in Cingulate Cortex, Dentate Gyrus, 
Thalamus, and Hypothalamus in a Rat Model of Gulf-War Syndrome," 
Neurobiology of Disease 10 (2002): 306-26; and "Sarin: Health Effects, 
Metabolism, and Methods of Analysis," Food and Chemical Toxicology 40 
(2002): 1327-33.

[58] K. Husain and S. Somani, "Delayed Toxic Effects of Nerve Gas Sarin 
and Pyridostigmine under Physical Stress in Mice," Journal of Burns and 
Surgical Wound Care 2 (2003): 2-19.

[59] R. F. Henderson and others, "Response of F344 Rats to Inhalation 
of Subclinical Levels of Sarin: Exploring Potential Causes of Gulf War 
Illness," Journal of Toxicology and Industrial Health 17 (2001): 294-97 
and 18:1 (2002): 48.

[60] See Henderson and others, "Response of Rats to Low Levels of 
Sarin," and "Subclinical Doses of the Nerve Gas Sarin Impair T Cell 
Responses through the Autonomic Nervous System," Journal of Toxicology 
and Applied Pharmacology 184 (2002): 82-87.

[61] See R. W. Haley and others, "Brain Abnormalities in Gulf War 
Syndrome: Evaluation by 1H Magnetic Resonance Spectroscopy," Radiology 
215 (2000): 807-17, and "Effect of Basal Ganglia Injury on Central 
Dopamine Activity in Gulf War Syndrome: Correlation of Proton Magnetic 
Resonance Spectroscopy and Plasma Homovanillic Acid," Archives of 
Neurology 57 (2000): 1280-85, as well as D. J. Meyerhoff and others, 
"Reduced N-Acetylaspartate in the Right Basal Ganglia of Ill Gulf War 
Veterans by Magnetic Resonance Spectroscopy," Proceedings of the 
International Society of Magnetic Resonance Medicine 9 (2001): 994.

[62] O. U. Scremin and others, "Effects of Chronic Exposure to Low 
Levels of Cholinesterase Inhibitors on Cerebral Blood Flow," paper for 
the Society for Neuroscience Meeting, Orlando, Florida, 2002.

[63] Melinda Roberson and others, "Depression of Cholinesterase 
Activity by Low-Dose Sarin Exposure May Lead to Persistent Changes That 
Influence Behavior," Society for Neuroscience, Washington, D.C., 
Program no. 205.3 (Abstract, 2002).

[64] U.S. General Accounting Office, Gulf War Illnesses: Improved 
Monitoring of Clinical Progress and Reexamination of Research Emphasis 
Are Needed, GAO/NSIAD-97-163 (Washington, D.C.: June 23, 1997).

[65] F. W. Whicker and others, "PATHWAY: A Dynamic Food-Chain Model to 
Predict Radionuclide Ingestion after Fallout Deposition," Health 
Physics 52 (1987): 717-37; L. R. Anspaugh and others, "The Global 
Impact of the Chernobyl Reactor Accident," Science 242 (1988): 1513-19; 
T. Straume and others, "The Feasibility of Using I129 to Reconstruct 
I131 Deposition from the Chernobyl Reactor Accident," Health Physics 
71:5 (1996): 733-40; K. T. Bogen and others, Uncertainty and 
Variability in Updated Estimates of Potential Dose and Risk at a U.S. 
Nuclear Test Site Bikini Atoll, UCRL-JC-122616 (Livermore, Calif.: 
Lawrence Livermore National Laboratory, 1995).

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