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 
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. 

Highlights of GAO-04-159, a report to 

Congressional Requesters 

June 2004

GULF WAR ILLNESSES

DOD's Conclusions about U.S. Troops' 

Exposure Cannot Be Adequately 

Supported 

DOD’s and MOD’s 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 data—quantity and purity of the agent—were 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 models—DOD and non-DOD models—showed wide 

divergences as to plume size and path. 

DOD’s and VA’s 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 criteria—DOD’s plume model and DOD’s estimation of potentially 

exposed troops based on this model—were 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 

Meteorological

data

Regional

weather models

Transport and

diffusion models

Plume hazard

area

Global

weather models

Source term

data

Source: GAO.

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 plumes—clouds 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. 

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 GAO’s 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 GAO’s 

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. 
Page i GAO-04-159 Gulf War Illnesses 

Letter 1

Scope and Methodology 3

Results in Brief 4

Background 7

Modeling the Environmental and Health Effects of Fallout from 

CW Agents 10

DOD’s Conclusion about U.S. Troops’ Exposure to CW Agents 

Cannot Be Adequately Supported 12

Major Unresolved Issues Concerning Modeling 19

DOD’s Modeling Efforts Were Flawed 30

The MOD Relied on U.S. Plume Modeling to Determine Its Troops’ 

Exposure 47

to CW Agents 47

Total U.S. Plume-Modeling Costs 47

DOD’s and VA’s Epidemiological Conclusions on CW Exposure and 

Hospitalization and Mortality Rates Cannot Be Adequately 

Supported 49

Conclusions 61

Recommendations for Executive Action 62

Agency Comments and Our Evaluation 62

Appendix I DOD’s Chronology of Khamisiyah Modeling Events 64 

Appendix II Power-Law Formula 66 

Appendix III DOD’s Model Divergences 67 

Appendix IV Divergence and Wind Field Models 69 

Appendix V Comments from the Department of Veterans Affairs 73 

Appendix VI Comments from the Department of Defense 74 

GAO Comments 92

Contents 
Page ii GAO-04-159 Gulf War Illnesses 

Appendix VII Comments from the Central Intelligence Agency 109 

Tables 

Table 1: The Meteorological and Dispersion Models DOD Used to 

Model Khamisiyah 12

Table 2: Gulf War Suspected Chemical Weapon Sites 22

Table 3: Detector and Agent Identification Systems Deployed by 

Coalition Forces Reporting the Detection of CW Agents 24

Table 4: Principal Reported Detections of Chemical Agents in Saudi 

Arabia, January 17–23, 1991 26

Table 5: U.S. Direct Costs for Modeling Gulf War Illnesses 48

Figures 

Figure 1: Timeline of Events Following the U.S. Demolition of CW 

Agents at Khamisiyah, 1991–2000 9

Figure 2: The Plume-Modeling Process 11

Figure 3: NOAA-11 Meteorological Imagery of Areas Occupied by 

Coalition Forces, January 18–24, 1991 25

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

1991 28

Figure 5: Plume Height Trend Line by Weight of Explosive 31

Figure 6: Boundary Layer Characteristics 32

Figure 7: Three Types of Plume Geometry 33

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

Altitudes 34

Figure 9: Lawrence Livermore National Laboratory Projection 39

Figure 10: DOD Composite Projection 41

Figure 11: DOD Composite Projection and Lawrence Livermore 

National Laboratory Projection 43

Figure 12: Validation Runs of Various Models 44

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

Composite Analyses 67

Figure 14: Divergence in DOD Muhammadiyat Models 68

Figure 15: Lawrence Livermore National Laboratory Diagnostic 

Wind Model, Based on Observational Data 70

Figure 16: Lawrence Livermore National Laboratory Diagnostic 

Wind Model, Based on ECMWF Projections 71

Figure 17: Wind Field Vector Model, Based on COAMPS 72
Page iii GAO-04-159 Gulf War Illnesses 

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 
Page iv GAO-04-159 Gulf War Illnesses 

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Page 1 GAO-04-159 Gulf War Illnesses 

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 

United States General Accounting Office 

Washington, DC 20548 
Page 2 GAO-04-159 Gulf War Illnesses 

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).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.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 

 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). 
Page 3 GAO-04-159 Gulf War Illnesses 

testimony in June 2003.3 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 plumemodeling efforts? 

3. How valid are the DOD and Department of Veterans Affairs (VA) 

conclusions from epidemiological studies, based on DOD’s plumemodeling results, that there was no association between CW exposure 

at Khamisiyah and the troops’ hospitalization and mortality rates? 

To determine the validity of DOD’s conclusion, based on its plumemodeling 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, 

 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. 

Scope and 

Methodology 
Page 4 GAO-04-159 Gulf War Illnesses 

• 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. 

DOD’s and MOD’s conclusions, based on DOD’s plume modeling, about 

their troops’ exposure to CW agents cannot be adequately supported. Results in Brief 
Page 5 GAO-04-159 Gulf War Illnesses 

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 longrange 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 
Page 6 GAO-04-159 Gulf War Illnesses 

funded, one conducted by DOD researchers, the other by VA researchers.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 lowlevel 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 

 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. 
Page 7 GAO-04-159 Gulf War Illnesses 

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). 

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 

Background 
Page 8 GAO-04-159 Gulf War Illnesses 

the CIA to examine this issue.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.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.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. 

 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). 
Page 9 GAO-04-159 Gulf War Illnesses 

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

1995 1996 1997 2000

March and June:

The CIA begins reexamination of 

relevant intelligence, and DOD forms 

the Persian Gulf Illnesses Investigation 

Team. 

October:

The DOD investigation team identifies 

some of the U.S. forces that had 

occupied the area around Khamisiyah.

June:

DOD confirms that some of the munitions 

destroyed by U.S. troops in March 1991, 

at Khamisiyah, were filled with the 

chemical warfare agents sarin and 

cyclosarin.

November–February 1997:

The CIA and DOD task the Institute for 

Defense Analysis to establish an expert 

panel, so as to assess the models being 

used to estimate the potential hazard area 

from the destruction of the chemical 

warfare agent munitions at Khamisiyah.

September:

The CIA and DOD present their first 

composite model, delineating the size, 

path, and exposure levels of the 

potential hazard area.

January:

The CIA and DOD complete

a remodeling and present a revised 

composite model that redefines the 

1997 hazard area.

March:

U.S. troops conduct large-scale 

demolition operations to destroy 

ammunition bunkers and warehouses 

at the Khamisiyah munitions storage 

site in southern Iraq.

October:

United Nations Special Commission 

(UNSCOM) inspection team find the 

presence of sarin-filled 122mm rockets 

at the Khamisiyah munitions storage 

site. 

November:

U.S. intelligence and DOD become 

aware of the UNSCOM findings, but no 

action is taken.

February and March: 

UNSCOM destroy 463 sarin- and 

cyclosarin-filled 122 mm rockets at 

Khamisiyah. 

June:

U.S. Navy personnel testify before the 

U.S. Senate Committee on Armed 

Forces to possible chemical exposures 

following explosions and chemical 

agent alarm soundings on January 19, 

1991, at the Port of Al Jubayl, Saudi 

Arabia.

May:

In testimony before the U.S. Senate 

Committee on Banking, Housing, and 

Urban Affairs, DOD and intelligence 

community witnesses admit that 

USCOM found chemical weapons at 

Khamisiyah during its inspections.

1991 1992 1993 1994

July:

The Czech Minister of Defense 

announced that a Czechoslovak 

chemical decontamination unit detected 

sarin in areas of northern Saudi Arabia 

during the early phases of the 1991 

Persian Gulf War.

Baghdad

Khamisiyah

Iran

31st parallel

Kuwait theater

of operations

Al Jubayl

Tigris

River

Euphrates

River

Saudi Arabia

Egypt

Iraq

Syria

Turkey

Jordan

Mediterranean Sea

Red

Sea Arabian Sea

Source: GAO. 
Page 10 GAO-04-159 Gulf War Illnesses 

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. 

Modeling the 

Environmental and 

Health Effects of 

Fallout from CW 

Agents 
Page 11 GAO-04-159 Gulf War Illnesses 

Figure 2: The Plume-Modeling Process 

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 OceanAtmosphere 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 were also used during the Gulf War.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. 

 8

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

Meteorological Models 

Transport and Diffusion 

Models 

Meteorological

data

Regional

weather models

Transport and

diffusion models

Plume hazard

area

Global

weather models

Source term

data

Source: GAO.
Page 12 GAO-04-159 Gulf War Illnesses 

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

Model type Developer or sponsor 

Meteorological 

COAMPS: Coupled Ocean-Atmosphere Mesoscale Prediction System U.S. Navy 

MATHEW: Mass Consistent Wind Fielda Department of Energy, Lawrence Livermore 

National Laboratory 

MM5: Mesoscale Model Version 5 National Center for Atmospheric Research 

NOGAPS: Naval Operational Global Atmospheric Prediction System, U.S. Navy 

OMEGA: Operational Multiscale Environment Model with Grid Adaptivity Defense Threat Reduction Agency 

Dispersion 

ADPIC: Atmospheric Dispersion by Particle-in-Cella Department of Energy, Lawrence Livermore 

National Laboratory 

HPAC/SCIPUFF: Hazard Prediction and Assessment Capability/Secondorder Closure Integrated Puff Defense Threat Reduction Agency 

NUSSE4: Non-Uniform Simple Surface Evaporation, Version 4 U.S. Army 

VLSTRACK: Vapor, Liquid, Solid Tracking 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. 

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 longrange 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 Conclusion 

about U.S. Troops’ 

Exposure to CW 

Agents Cannot Be 

Adequately Supported 
Page 13 GAO-04-159 Gulf War Illnesses 

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. 

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 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 longterm 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. 

DOD’s Models Were Not 

Fully Developed for 

Analyzing Long-Range 

Environmental Hazards 

COAMPS and OMEGA 

Meteorological Models 

VLSTRACK and HPAC 

Dispersion Models 
Page 14 GAO-04-159 Gulf War Illnesses 

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. 

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 

DOD’s Models Included 

Source Term Assumptions 

That Cannot Be Verified 
Page 15 GAO-04-159 Gulf War Illnesses 

agent precursor materials, and the potential release of CW agents and 

toxic byproducts from other sites.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 

 9

A binary weapon mixes two less toxic materials to create a toxic nerve agent within the 

weapon when it is fired or dropped. 
Page 16 GAO-04-159 Gulf War Illnesses 

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.10 This 

assessment was based on comparisons with U.S. testing in the 1960s at 

Black Hills, South Dakota, on sarin-filled rockets.11 The CIA considered the 

2.5 percent estimate conservative because agent-heating conditions were 

 10Central Intelligence Agency, Intelligence Update: Chemical Warfare Agent Issues during 

the Persian Gulf War (McLean, Va.: Apr. 2002). 

11U.S. Army Dugway Proving Ground, Hazard Classification Tests of Igloo Storage of GBand VX-Filled M55 Rockets, RTD&E Project 1B650312D624, USATECOM Project 5-3-0135-

02, DPGDR C-505 (Dugway, Utah: Apr. 1966). 
Page 17 GAO-04-159 Gulf War Illnesses 

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.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. 

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 621oC, 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 

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

DOD’s Postwar Field 

Testing Did Not 

Realistically Simulate 

Actual Conditions of 

Demolition Operations 
Page 18 GAO-04-159 Gulf War Illnesses 

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.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.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. 

 13U.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). 

14National 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. 
Page 19 GAO-04-159 Gulf War Illnesses 

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. 

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. 

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.15According 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.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. 

 15Central Intelligence Agency, CIA Report on Intelligence.

16Central Intelligence Agency, Intelligence Update. 

Major Unresolved 

Issues Concerning 

Modeling 

CIA’s Modeling 

Assumptions about 

Khamisiyah Bunker 73 
Page 20 GAO-04-159 Gulf War Illnesses 

• 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. 

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. 

Assumptions about 

Repeated Aerial Bombings 

of Storage Facilities 
Page 21 GAO-04-159 Gulf War Illnesses 

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. 

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. 

Assumptions about 

Repeated Aerial Bombings 

of Other Storage, as Well 

as Research and 

Production, Facilities 
Page 22 GAO-04-159 Gulf War Illnesses 

Table 2: Gulf War Suspected Chemical Weapon Sites 

Site type Site name and place Site name and place 

Facility Al Muthanna (Samarra) Fallujah III (Habbaniyah I) 

 Fallujah I (Habbaniyah III) Khamisiyah (Tall al Lahm) 

 Fallujah II (Habbaniyah II) Muhammadiyat (Qubaysah Storage Depot) 

Airbase, airfield Al Bakr Airfield (Samarra East Airfield) Murasana Airbase (H3 NW Airfield) 

 Al Taba’at Airstrip (H3 SW Airfield) Qadisiyah Airbase (Al Asad Airfield) 

 Al Taqaddum Airfield Qayyarah West Airfield 

 Al Tuz Airfield (Tuz Khurmatu Airfield) Saddam Airbase (Qayyarah West Airfield) 

 Al Walid Airbase (H3 Airfield) Tallil Airfield 

 K-2 Airfield Tammuz Airbase (Al Taqaddum Airfield) 

 Kirkuk Airfield Ubaydah Bin al Jarrah Airfield 

 Mosul Airfield 

Ammo Ad Diwaniyah Ammo Depot Kirkuk Ammo Depot West 

 Al Fallujah Ammo Depot South Qabatiyah Ammo Storage (Wadi al Jassiyah Ammo 

Storage) 

 An Nasiriyah Ammo Storage Depot SW Qayyarah West Ammo Storage Depot 

 Ash Shuaybah Ammo Storage Depot Tikrit Ammo Depot (Salahadin) 

 Baghdad Ammo Depot Taji Ukhaider (Karbala Depot and Ammo Storage) 

Other Al Qaim Superphosphate Fertilizer Plant Fallujah Chem Proving Gnd (Habbaniyah CW 

Training Center) 

 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). 

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 

Assumptions about Binary 

Munitions and Combustion 

By-Products 
Page 23 GAO-04-159 Gulf War Illnesses 

combustion by-products of sulfur mustard from the bombings at 

Muhammadiyat and other sites.17

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. 

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

Assumption about the 

Detection of CW Agents 
Page 24 GAO-04-159 Gulf War Illnesses 

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

Nation System Chemical agent Sensitivity Method or technology 

Czech 

Republic 

Automatic Nerve Agent 

Detector Alarm GSP-11 

G- and V-series nerve agents 0.05 mg/m3 Air sampling, biochemical enzyme

(cholinesterase reactivity) 

 Mobile Laboratory CHP-71, 

PCHL-90, and PCHL-90 

Most CW agents Agent identification 

through wet 

chemistry analysis 

Field portable chemical agent 

laboratory, chemical reagents, 

wet chemistry analysis 

France Detalac F1 G- and V-series nerve agents Not available Biochemical enzyme detector 

 Chemical Detection Control 

Kit (TDCC) 

Tabun/sarin (GA/GB) 

Hydrogen cyanide (AC) 

Cyanogen chloride (CK) 

1 mg/m3 

350 mg/m3 

2000 mg/m3 

Chemical biochemical detector 

 Chemical Detection Unit for 

Fixed Installations (ADLIF) 

Sarin/soman (GB/GD) Not available Flame spectrometry 

United 

Kingdom 

Chemical Agent Monitor G- and V-series nerve agents

Blister agents (H) 

0.1 mg/m3 

2.0 mg/m3 

Ion mobility spectrometry 

(quantitative feature) 

 Nerve Agent Immobilized 

Enzyme Alarm and Detector 

(NAIAD) 

G-series nerve agents 

V-series nerve agents 

0.05mg/m3 

0.005 mg/m3 

Biochemical enzyme detector 

(cholinesterase reactivity) 

 MARK I G-series nerve agents 

Blister agents (H) 

Not available Biochemical chemical reactivity 

United 

States 

M8A1 Alarm G-series nerve agents 

V-series nerve agents 

0.1 mg/m3 

0.2 mg/m3 

Ionization 

Automatic alarm 

 M8 Paper; M9 Paper G- and V-series nerve agents

Blister agents (H) 

Yes/no 

Yes/no 

Chemical reactivity 

Color interpretation 

 Chemical Agent Detector Kit 

M256 and M256A1 

G-series nerve agents 

V-series nerve agents 

Blister agents (H) 

0.05 mg/m3 

0.15 mg/m3 

3.0 mg/m3 

Biochemical enzyme detector 

(cholin-esterase reactivity) 

Chemical reactivity 

 Chemical Agent Monitor G- and V-series nerve agents

Blister agents (H) 

0.1 mg/m3 

2.0 mg/m3 

Ion mobility spectrometry 

(quantitative feature) 

 MM1 FOX NBC vehicle G-series nerve agents 

60 other preprogrammed 

agent spectra 

Several mg/m3 

M8A1 (M43) 

ionization backup 

unit (early warning) 

Quadrapole gas chromatography 

C-mass spectrometryS 

Full GC-MS 

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. 
Page 25 GAO-04-159 Gulf War Illnesses 

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

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. 

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). 

Source: NOAA.
Page 26 GAO-04-159 Gulf War Illnesses 

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

Date Nation and unit Place Agent detected Method or technology 

Jan. 17 United States 2/5TH SFG NW Hafir Al Batin Unknown nerve agent Ionization, biochemical reaction; ion 

mobility spectrometry; M8A1, M256, 

CAM 

Jan. 19 Czech Republic Chemical 

Detection Unit 

N Hafir Al Batin Sarin (GB) Biochemical reactivity; wet chemistry; 

GSP-1(11), mobile lab 

 NE Hafir Al Batin Sarin (GB) Biochemical reactivity; wet chemistry; 

GSP-1(11), mobile lab 

 King Khalid Military 

City (KKMC) 

Unknown nerve agent Biochemical reactivity; wet chemistry; 

GSP-1(11), mobile lab 

 France 30 km from KKMC Unknown nerve agent Biochemical reactivity 

 Czech Republic Chemical 

Detection Unit 

30 km from KKMC Confirm French detection Wet chemistry mobile lab 

 KKMC Sulfur mustard (HD) Wet chemistry mobile lab 

 United Kingdom Jubayl Unknown blister (after 

unexplained explosions) 

Chemical reactivity; ion mobility 

spectrometry; M-9, CAM 

 United States 24th Naval 

Reserve Construction 

Battalion (Seabees) 

Jubayl Unknown blister (after 

unexplained explosions) 

Chemical reactivity; M-256 (2/3 tests) 

Jan. 20 Czech Republic Chemical 

Detection Unit 

Near KKMC Sulfur mustard (HD) for 

2 hours 

Wet chemistry mobile lab 

 French sector 

KKMC 

Sarin (GB)/tabun (GA) Biochemical reactivity; wet chemistry 

mobile lab 

 France Near KKMC Unknown nerve agent Biochemical reactivity 

 United States 800th MP 

BDE 

NW of KKMC Unknown nerve agent Ionization, biochemical reactivity; 

M8A1, M256 

 United Kingdom Dharan Unknown nerve agent (after 

SCUD attack) 

Biochemical reactivity (separate 

devices); NAIAD, MARKI 

Jan. 21 Czech Republic Chemical 

Detection Unit 

KKMC Sarin (GB)/tabun (GA), sulfur 

mustard (HD) 

Biochemical reactivity; wet chemistry 

mobile lab 

 France KKMC Unknown nerve agent Biochemical reactivity 

 KKMC Unknown CW agent Chemical or biochemical reactivity 

Jan. 22 United States RAFHA Unknown nerve agent Ionization, biochemical reactivity; 

M8A1, M256 

Jan. 23 Czech Republic Chemical 

Detection Unit 

KKMC Unknown CW agent Wet chemistry mobile lab 

 Near KKMC Patch of sulfur mustard (HD) 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. 
Page 27 GAO-04-159 Gulf War Illnesses 

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). 
Page 28 GAO-04-159 Gulf War Illnesses 

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

28 0'00"N o

29 0'00"N o

30 0'00"N o

31 0'00"N o

32 0'00"N o

33 0'00"N o

34 0'00"N o

35 0'00"N o

36 0'00"N o

39 0'00"E o40 0'00"E o41 0'00"E o42 0'00"E o43 0'00"E o44 0'00"E o45 0'00"E o46 0'00"E o47 0'00"E o48 0'00"E o49 0'00"E o

Miles

100 0 100 200 300 400

Scale

39 0'00"E o40 0'00"E o41 0'00"E o42 0'00"E o43 0'00"E o44 0'00"E o45 0'00"E o46 0'00"E o 47 0'00"E o48 0'00"E o 49 0'00"E o

28 0'00"N

29 0'00"N

30 0'00"N

31 0'00"N

32 0'00"N

33 0'00"N o

34 0'00"N o

35 0'00"N

36 0'00"N

NOAA-11 January 19, 1991 (0008Z)

Muthanna

King Khalid 

Military City

Hafir al Batin

Rafha

Muhammadiyat

Fallujah 

Baghdad

Khamisiyah 

Ukhaider

(Karbala Depot and Storage) 

Iraqi suspected CW storage sites

U.S. and coalition troop locations

Source: GAO analysis of NOAA data.

o

o

o

o

o

o

o
Page 29 GAO-04-159 Gulf War Illnesses 

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.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.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.20 The potential remains that sites that may have been 

incorrectly assessed as not containing CW agents were also bombed 

 18See 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. 

19Defense 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). 

20U.S. Army Operations Group, UNSCOM, Inspection of Chemical Warfare Facilities, IIR 2 

201 0022 92 (Washington, D.C.: Oct. 3, 1991, declassified 1995). 
Page 30 GAO-04-159 Gulf War Illnesses 

during this period. These activities may have resulted in additional 

releases of CW agents. 

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. 

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. 

DOD’s Modeling 

Efforts Were Flawed 

DOD’s Models Significantly 

Underestimated Plume 

Height 
Page 31 GAO-04-159 Gulf War Illnesses 

of high explosives) of the type used to bomb sites other than those at 

Khamisiyah would generate a plume of approximately 421 m. 

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 

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 

Impact by Weight of Explosive 

Weight of high explosives

100lb

Height in meters

500lb 1000lb 2000lb

0

100

200

300

400

500

600

Source: GAO.
Page 32 GAO-04-159 Gulf War Illnesses 

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. 

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 

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. 

Impact by Wind Speed 

Cloud Layer

2000 

1000 

Convective

Mixed Layer

Surface Layer 

Noon Sunset Midnight

Surface Layer

Local Time

Height (Meters)

Sunrise Noon

S1 S2 S3 S4 S5 S6 

0

Entrainment Zone

Entrainment Zone

Capping Inversion

Residual Layer Mixed

Layer

Surface Layer

Stable (Nocturnal) Boundary Layer

Free Atmosphere 

Source: Roland B. Stull, An Introduction to Boundary Layer Meteorology (Boston, MA: Kluwer Academic Publishers, 1988), p. 11. Used with kind permission of Kluwer Academic Publishers.
Page 33 GAO-04-159 Gulf War Illnesses 

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. 

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 

Similarly, the distribution of plume geometry may be affected by nocturnal 

jets, as shown in figure 8. 

Impact by Plume Geometry

Stack Fire Explosion

Source: Department of Energy, Lawrence Livermore National Laboratory.
Page 34 GAO-04-159 Gulf War Illnesses 

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

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. 

200 Meters 493 Meters

Nocturnal Jets

20 - 60 MPH

36 - 108 KPH

Source: Department of Energy, Lawrence Livermore National Laboratory.
Page 35 GAO-04-159 Gulf War Illnesses 

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. 

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 singlerocket 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. 

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: 

DOD’s Field Testing Did 

Not Realistically Simulate 

Actual Conditions 

Demolition and Bombing 

Simulations Were Not Realistic 

Extrapolation Data Contained 

Acknowledged Limitations 
Page 36 GAO-04-159 Gulf War Illnesses 

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.21

Finally, SAIC acknowledged that calculations were performed in two 

dimensions, stating that full, three-dimensional calculations were not 

feasible.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.”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. 

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 

 21G. 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. 

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

23G. I. Kent and others, Interim Report: Rocket Motor Ignition/Explosives Issue (Dugway, 

Utah: June 17, 1997), p. 15. 

Testing Did Not Use Iraqi Soil 

and Wood 
Page 37 GAO-04-159 Gulf War Illnesses 

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.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. 

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.25 However, this approach masked differences in 

individual model projections with respect to plume size and path. 

 24Drainage 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. 

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

All Models, Including 

DOD’s Composite Model, 

Showed Divergent and 

Unresolved Results 
Page 38 GAO-04-159 Gulf War Illnesses 

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. 

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. 

LLNL’s Model 
Page 39 GAO-04-159 Gulf War Illnesses 

Figure 9: Lawrence Livermore National Laboratory Projection 

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 

Source: Department of Energy, Lawrence Livermore National Laboratory.

Baghdad

Al Hillah

Al Qatif

As Saffaniyah

Al Qaysumah

Kuwait City

Al Basrah

Khvaz

Khorramabad

Bakhlaran

Aiak

Estahan

Persian

Gulf

Neutral Zone

Euphrates

River

IRAQ

KUWAIT

SAUDI ARABIA

BAHRAIN

IRAN

30 N

30 N

60 E

45 E

Minimal

Occupational Limit

General population limit
Page 40 GAO-04-159 Gulf War Illnesses 

by agent concentration in excess of the dosage expected to cause a person 

minimal effects.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.27 The 

remaining area was determined to be at the general population limit.28

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. 

 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. 

DOD’s Composite Model 
Page 41 GAO-04-159 Gulf War Illnesses 

Figure 10: DOD Composite Projection 

Source: Department of Defense, Office of the Special Assistant for Gulf War Issues.

Potential hazard area

Iraq

Iran

Kuwait

Persian

Saudi Gulf

Arabia

As Salman

Al Bussayah

Hafir Al

BatinHafir Al

Batin

Al

Jubayl

43 44 45 46 47 48 49 50

27

28

29

30

31

32

De Facto

Boundary

Khamisiyah Al Basrah

Kuwait City

2000 Composite Overlay

N 0 50 100 miles

0 80 160 kilometers

Khamisiyah Pit Demolition - Potential Hazard Area

Each dot represents a troop unit’s location or part of a unit’s location. Each unit can range in size from a company to a batallion.
Page 42 GAO-04-159 Gulf War Illnesses 

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. 
Page 43 GAO-04-159 Gulf War Illnesses 

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

Source: GAO analysis of Department of Defense and Department of Energy, Lawrence Livermore National Laboratory, models.

Potential hazard area

General population limit

Occupational Limit

Iraq Iran

Kuwait

Persian

Saudi Gulf

Arabia

As Salman

Al Bussayah

Hafir Al

BatinHafir Al

Batin

Al

Jubayl

43 44 45 46 47 48 49 50

27

28

29

30

31

32

De Facto

Boundary

Khamisiyah Al Basrah

Kuwait City

N 0 50 100 miles

0 80 160 kilometers

Each dot represents a troop unit’s location or part of a unit’s location. Each unit can range in size from a company to a batallion.
Page 44 GAO-04-159 Gulf War Illnesses 

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 

a

East bias compared with OMEGA/HPAC. 

b

East bias compared with MM5/HPAC. 

c

East bias compared with COAMPS/VLSTRACK. 

Explaining the Models’ 

Divergent Results 

10-15 degreesa

25-30 degreesb

40-50 degreesc

COAMPS

VLSTRACK

MM5

HPAC

OMEGA

HPAC

Visible plume

Source: GAO.
Page 45 GAO-04-159 Gulf War Illnesses 

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.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 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.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 

 29Richard 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. 

30In 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). 

AFTAC Modeling 
Page 46 GAO-04-159 Gulf War Illnesses 

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.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. 

 31U.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). 
Page 47 GAO-04-159 Gulf War Illnesses 

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 1999.32 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. 

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 

 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. 

The MOD Relied on 

U.S. Plume Modeling 

to Determine Its 

Troops’ Exposure 

to CW Agents 

Total U.S. PlumeModeling Costs 
Page 48 GAO-04-159 Gulf War Illnesses 

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 Direct costsa Work done 

BAHR Inc. $11,796 Reviewed (1) processes and technology used to produce 

estimates of U.S. forces potentially exposed and (2) draft reports 

on Khamisiyah 

Central Intelligence Agency b Computer-modeling analysis 

Chemical Biological Defense Command, 

Aberdeen Proving Ground 

 140,000 Wood-surface evaporative modeling and environmental data 

support efforts 

Defense Threat Reduction Agency 870,000 Computer-modeling analyses with HPAC/SCIPUFF dispersion 

and OMEGA weather models 

Institute for Defense Analyses 149,429 Convened a panel of experts to review Khamisiyah pit modeling 

analyses 

Lawrence Livermore National Laboratory 60,000 Computer-modeling analyses with ADPIC dispersion and 

MATHEW weather models 

National Center for Atmospheric Research 308,000 Computer-modeling simulations using MM5 weather model 

Naval Research Laboratory 1,090,000 Meteorological analysis to identify downwind hazard assessment 

with NOGAPS and COAMPS weather models. 

Naval Surface Warfare Center 522,000 Computer-modeling analyses with VLSTRACK dispersion and 

COAMPS weather models 

Office of the Special Assistant to the Deputy 

Secretary of Defense for Gulf War Illnesses 

 7,980,000 Internal costs for producing case narratives for Al Muthanna, 

Khamisiyah, Muhammadiyat, and Ukhaydir 

Science Applications International Corporation c Computer-modeling analysis 

U.S. Army Center for Health Promotion and 

Preventative Medicine 

 731,000 Exposure assessment and environmental modeling to determine 

U.S. troops’ exposed to chemical releases from multiple incidents 

during the Gulf War 

U.S. Army Dugway Proving Ground 1,861,950 Field trials and laboratory testing using 122 mm chemicalsimulant filled rockets to develop source term data for modeling 

White Sands Missile Range 2,600 Missiles for testing at Dugway Proving Ground 

Total $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. 
Page 49 GAO-04-159 Gulf War Illnesses 

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 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. 

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 

DOD’s and VA’s 

Epidemiological 

Conclusions on CW 

Exposure and 

Hospitalization and 

Mortality Rates 

Cannot Be Adequately 

Supported 

DOD and VA Used Flawed 

Criteria for Determining 

Troops’ Exposure 
Page 50 GAO-04-159 Gulf War Illnesses 

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. 

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 

DOD and VA Used an 

Insensitive Outcome 

Measure for Determining 

Hospitalization Rate 
Page 51 GAO-04-159 Gulf War Illnesses 

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.33

This limiting of the study to troops remaining on active duty produced a 

type of selection bias known as the healthy warrior effect.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. 

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. 

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.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).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 

 33Institute of Medicine, Gulf War Veterans: Measuring Health (Washington, D.C.: National 

Academy Press, 1999), p. 36. 

34R. 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. 

35R. W. Haley and T. L. Kurt, “Self-Reported Exposure to Neurotoxic Chemical 

Combinations in the Gulf War,” JAMA 277 (1997): 231–37. 

36See Michael B. Gregg, ed., Field Epidemiology, 2nd ed. (New York: Oxford University 

Press, 2002). 

Some Studies Suggest an 

Association between CW 

Exposure and Gulf War 

Illnesses 

Gulf War Veterans Studies 
Page 52 GAO-04-159 Gulf War Illnesses 

a case definition identifying six syndrome factors.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.38 Confusion-ataxia (syndrome 2), 

the most severe clinically, was associated with three risk factors.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.40 Arthro-myoneuropathy (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.41

 37R. 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, feveradenopathy, and weakness-incontinence. 

38Impaired 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.) 

39Confusion-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). 

41Arthro-myo-neuropathy is characterized by joint and muscle pains, muscle fatigue, 

difficulty lifting, and paresthesias of the extremities. (Results showed for exposure, doseresponse effect to relative risk 7.8, 95 percent, CI 2.4–24.7, p < 0.0001; for side effects, doseresponse effect to relative risk 3.9, 95 percent, CI 1.3–12.1, p < 0.0001.) 
Page 53 GAO-04-159 Gulf War Illnesses 

The inference that these risk-factor associations represent causal effects is 

supported by (1) the large, highly significant relative risks; (2) the doseresponse 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.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.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 

 42R. Nisenbaum and others, “Deployment Stressors and a Chronic Multisymptom Illness 

among Gulf War Veterans,” Journal of Nervous and Mental Disease 188 (2000): 259–66. 

43Association 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. 
Page 54 GAO-04-159 Gulf War Illnesses 

Orleans cohort.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.45 Associations 

remained significant after controlling for age, sex, race, years of education, 

repeated grade in school, head injury, medication use, diagnosis of current 

 44S. 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. 

45R. 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. 
Page 55 GAO-04-159 Gulf War Illnesses 

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.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.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.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 

 46K. 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. 

47Chemical 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. 

48H. K. Kang and others, “Evidence for a Deployment-Related Gulf War Syndrome by Factor 

Analysis,” Archives of Environmental Health 57:1 (2002): 61–68. 
Page 56 GAO-04-159 Gulf War Illnesses 

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.49 

The 2002 Kang and Bullman study has not been published in a peerreviewed 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 

 49T. 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.
Page 57 GAO-04-159 Gulf War Illnesses 

techniques can correct for this selection bias toward finding no 

difference.50

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).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.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 

 50H. 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).

51R. 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. 

52B. Mackness and others, “Low Paraoxonase in Persian Gulf War Veterans Self-Reporting 

Gulf War Syndrome,” Biochemical and Biophysical Research Communications 276 

(2000): 729–33. 

Genetics Studies 
Page 58 GAO-04-159 Gulf War Illnesses 

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.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.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. 

 53See 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. 

54R. 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. 
Page 59 GAO-04-159 Gulf War Illnesses 

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.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.56 Abou-Donia’s subsequent work, 

funded by DOD, extended the findings to synergistic combinations 

involving sarin at moderate concentrations (0.5 LD50).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).58

A study by Henderson and colleagues, with DOD funding, found that 

repeated inhalation exposure to low-level sarin at subsymptomatic doses 

 55K. 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. 

56Mohamed 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. 

57Mohamed 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. 

58K. 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. 

Animal Studies 
Page 60 GAO-04-159 Gulf War Illnesses 

(0.1 LCt50) for 5 or 10 days, with or without heat stress, produced no 

immediate effects.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.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.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.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.63

 59R. 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. 

60See 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. 

61See R. W. Haley and others, “Brain Abnormalities in Gulf War Syndrome: Evaluation by 1

H 

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. 

62O. 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. 

63Melinda 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). 
Page 61 GAO-04-159 Gulf War Illnesses 

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 lowlevel or intermittent exposures to CW agents.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 

 64U.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). 

Conclusions 
Page 62 GAO-04-159 Gulf War Illnesses 

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. 

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. 

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 

Recommendations for 

Executive Action 

Agency Comments 

and Our Evaluation 
Page 63 GAO-04-159 Gulf War Illnesses 

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. 

Keith Rhodes, Chief Technologist 

Center for Technology and Engineering 

Applied Research and Methods 
Appendix I: DOD’s Chronology of Khamisiyah 

Modeling Events 

Page 64 GAO-04-159 Gulf War Illnesses 

 Date Event 

1995 

June 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 

Aug. President Bill Clinton created the Presidential Advisory Committee on Gulf War Veterans’ Illnesses 

1996 

Spring The Presidential Advisory Committee on Gulf War Veterans’ Illnesses directed the CIA to model chemical agent 

release from Bunker 73 

May UNSCOM inspected Khamisiyah 

June 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” 

July The CIA briefed the Presidential Advisory Committee on Bunker 73 modeling results 

Oct. 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 

Nov. 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 

Dec. 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 

1997 

Jan. 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 

Jan.–Feb. 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 

May 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 

May (to June 

1998) 

The Department of the Army and OSAGWI hosted G3/S3 conferences to elicit more correct information on unit 

locations during the war 

June–July CW agent release was modeled at the pit 

July 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 

Dec. 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 modelinga

Appendix I: DOD’s Chronology of Khamisiyah 

Modeling Events 
Appendix I: DOD’s Chronology of Khamisiyah 

Modeling Events 

Page 65 GAO-04-159 Gulf War Illnesses 

 Date Event 

1998: Jan. 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 

2000 

Jan. 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 

Mar. 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” 

2002: Apr. 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. 
Appendix II: Power-Law Formula 

Page 66 GAO-04-159 Gulf War Illnesses 

A 1969 Sandia National Laboratories empirical study established a powerlaw 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 (w1/4) 

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 

Appendix II: Power-Law Formula 
Appendix III: DOD’s Model Divergences 

Page 67 GAO-04-159 Gulf War Illnesses 

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 

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 

Appendix III: DOD’s Model Divergences 

Source: Naval Surface Warfare Center.

Khamisiyah Pit Demolition - March 10, 1991

Modeled Exposure (Deposition and Degradation)

March 10,1991 March 11, 1991

Angle approximately equal

to 40-45 degrees

Each dot represents a troop unit’s location or part of a unit’s location. Each unit can range in size from a

company to a batallion. 

Angle approximately equal

to 80 degrees

Khamisiyah Pit Demolition - March 11, 1991

Modeled Exposure (Deposition and Degradation)

VLSTRACK/COAMPS

VLSTRACK/COAMPS

HPAC/COAMPS

N

HPAC/COAMPS

HPAC/OMEGA HPAC/OMEGA

HPAC/MM5

HPAC/MM5

N

0 50 100 miles 0 50 100 miles
Appendix III: DOD’s Model Divergences 

Page 68 GAO-04-159 Gulf War Illnesses 

among model projections was also observed in the modeling of 

Muhammadiyat, as shown in figure 14. 

Figure 14: Divergence in DOD Muhammadiyat Models 

Nerve Agent Release, Muhammadiyat, Potential Hazard Area

February 6, 1991

Angle approximately equal

to 65 degrees

Source: Department of Defense.

Each dot represents a troop unit’s location or part of a unit’s location. Each unit can range in size from a

company to a batallion. 

Potential

Hazard Area

Potential

Hazard Area

N

N

0 50 100 miles

Syria Iraq

Saudi

Arabia

Kuwait

Iran

Jordan

Syria

Iraq

Saudi

Arabia

Kuwait

Iran

Jordan

0 150 300 kilometers

0 50 100 miles

0 150 300 kilometers

Nerve Agent Release, Muhammadiyat, Potential Hazard Area

February 19, 1991

Angle approximately equal

to 90 degrees
Appendix IV: Divergence and Wind Field 

Models 

Page 69 GAO-04-159 Gulf War Illnesses 

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. 

Appendix IV: Divergence and Wind Field 

Models 
Appendix IV: Divergence and Wind Field 

Models 

Page 70 GAO-04-159 Gulf War Illnesses 

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

March 10, 1991, 13:30:00Z (16:30 local)

Based on observational data only, processed by MEDIC Model

March 11, 1991, 00:30:00Z (03:30 local)

Based on observational data only, processed by MEDIC Model

3

5

0

0

3

0

0

0

500 1000

500 1000

Source: Lawrence Livermore National Laboratory.

3

0

0

0

3

5

0

0
Appendix IV: Divergence and Wind Field 

Models 

Page 71 GAO-04-159 Gulf War Illnesses 

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 

Annotation line: approximate streamline

Annotation line: approximate streamline

March 10, 1991, 12:00:00Z (15:00 local)

Based on ECMWF data, processed by MEDIC Model

MEDVEL __10MAR91__1200__00__000__0600__001.BIF

Barbs every 2

Level: 1

X Center value: 699.37

Y Center value: 3250.62

X Range: 925.00

Y Range: 925.00

March 11, 1991, 00:00:00Z (03:00 local)

Based on ECMWF data, processed by MEDIC Model

3800

3600

3400

3200

3000

2800

400 600 800 1000 1200 1400

3800

3600

3400

3200

3000

2800

400 600 800 1000 1200 1400

Source: Lawrence Livermore National Laboratory.

MEDVEL __11MAR91__0000__00__000__0600__001.BIF

Barbs every 2

Level: 1

X Center value: 699.37

Y Center value: 3250.62

X Range: 925.00

Y Range: 925.00
Appendix IV: Divergence and Wind Field 

Models 

Page 72 GAO-04-159 Gulf War Illnesses 

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 

Blue Line: approximate streamline

NRL COAMPS Simulation Wind analysis for 12z,

10 March 1991

COAMPS GRID 3, 100 X 100 X 30 5.00 km

10.0 m wind field analysis at 1991031012

surface land sea analysis at 1991031012

NRL COAMPS Simulation Wind forecast for 00Z,

11 March 1991

COAMPS GRID 3, 100 X 100 X 30 5.00 km

10.0 m wind field

12 h 0 m 0 s forcast valid at 1991031100 from 1991031012

surface land sea

12 h 0 m 0 s forcast valid at 1991031100 from 1991031012

Source: Lawrence Livermore National Laboratory.

Blue Line: approximate streamline

Red line: line of diffluence (note very strong diffluence near Kamisiyah)
Appendix V: Comments from the Department 

of Veterans Affairs 

Page 73 GAO-04-159 Gulf War Illnesses 

Appendix V: Comments from the Department 

of Veterans Affairs 
Appendix VI: Comments from the Department of Defense 

Page 74 GAO-04-159 Gulf War Illnesses 

Appendix VI: Comments from the 

Department of Defense 

Note: GAO comments 

supplementing those in 

the report text appear at 

the end of this appendix. 
Appendix VI: Comments from the Department of Defense 

Page 75 GAO-04-159 Gulf War Illnesses 

See comment 1. 
Appendix VI: Comments from the Department of Defense 

Page 76 GAO-04-159 Gulf War Illnesses 

See comment 2. 

See comment 3. 

Now on p. 60. 
Appendix VI: Comments from the Department of Defense 

Page 77 GAO-04-159 Gulf War Illnesses 

Now on pp. 50–55. 

See comment 11. 

See comment 10. 

See comment 9. 

See comment 8. 

See comment 7. 

See comment 6. 

See comment 5. 

See comment 4. 
Appendix VI: Comments from the Department of Defense 

Page 78 GAO-04-159 Gulf War Illnesses 

Now on p. 5. 

See comment 18. 

Now on p. 6. 

See comment 17. 

Now on p. 3. 

See comment 16. 

Now on p. 2. 

See comment 15. 

Now on p. 2. 

See comment 14, 

Now on p. 2. 

See comment 13. 

Now on p. 1. 

See comment 12. 
Appendix VI: Comments from the Department of Defense 

Page 79 GAO-04-159 Gulf War Illnesses 

Now on pp. 13–14. 

See comment 25. 

Now on p. 12. 

See comment 24. 

Now on p. 12. 

See comment 23. 

Now on p. 11. 

See comment 22. 

Now on p. 11. 

See comment 21. 

Now on p. 10. 

See comment 20. 

See comment 19. 
Appendix VI: Comments from the Department of Defense 

Page 80 GAO-04-159 Gulf War Illnesses 

Now on p. 15. 

See comment 30. 

Now on p. 14. 

See comment 29. 

Now on p. 14. 

See comment 28. 

Now on p. 14. 

See comment 27. 

Now on p. 13. 

See comment 26. 
Appendix VI: Comments from the Department of Defense 

Page 81 GAO-04-159 Gulf War Illnesses 

Now on p. 20. 

See comment 38. 

Now on p. 20 

See comment 37. 

Now on p.19. 

See comment 36. 

Now on p. 19. 

See comment 35. 

Now on p. 19. 

See comment 34. 

Now on p. 18. 

See comment 33. 

Now on p. 18. 

See comment 32. 

Now on p. 16. 

See comment 31. 
Appendix VI: Comments from the Department of Defense 

Page 82 GAO-04-159 Gulf War Illnesses 

Now on p. 27. 

See comment 44. 

Now on p. 27. 

See comment 43. 

Now on p. 25. 

See comment 42. 

Now on p. 23. 

See comment 41. 

Now on p. 21. 

See comment 40. 

Now on p. 20. 

See comment 39. 
Appendix VI: Comments from the Department of Defense 

Page 83 GAO-04-159 Gulf War Illnesses 

Now on pp. 30-34. 

See comment 49. 

Now on p. 30. 

See comment 48. 

Now on p. 29. 

See comment 47. 

Now on p. 28. 

See comment 46. 

Now on pp. 27 and 29. 

See comment 45. 
Appendix VI: Comments from the Department of Defense 

Page 84 GAO-04-159 Gulf War Illnesses 

Now on p. 34. 

See comment 54. 

Now on p. 34. 

See comment 53. 

Now on p. 34. 

See comment 52. 

Now on p. 32. 

See comment 51. 

Now on p. 31-32. 

See comment 50. 
Appendix VI: Comments from the Department of Defense 

Page 85 GAO-04-159 Gulf War Illnesses 

Now on p. 37. 

See comment 55. 

Now on pp. 35–37. 
Appendix VI: Comments from the Department of Defense 

Page 86 GAO-04-159 Gulf War Illnesses 

See comment 58. 

Now on pp. 41 and 43. 

Now on p. 38. 

See comment 57. 

See comment 56. 
Appendix VI: Comments from the Department of Defense 

Page 87 GAO-04-159 Gulf War Illnesses 

Now on pp. 49–60. 

See comment 63. 

Now on p. 45. 

See comment 62. 

Now on p. 45. 

See comment 61. 

Now on p. 44. 

See comment 60. 

Now on p. 44. 

See comment 59. 
Appendix VI: Comments from the Department of Defense 

Page 88 GAO-04-159 Gulf War Illnesses 

See comment 64. 

Now on pp. 51–60. 
Appendix VI: Comments from the Department of Defense 

Page 89 GAO-04-159 Gulf War Illnesses 

Now on pp. 50–51. 

See comment 66. 

Now on pp. 59–60. 

See comment 65. 
Appendix VI: Comments from the Department of Defense 

Page 90 GAO-04-159 Gulf War Illnesses 

Now on pp. 70–72. 

See comment 68. 

Now on pp. 49–50. 

See comment 67. 
Appendix VI: Comments from the Department of Defense 

Page 91 GAO-04-159 Gulf War Illnesses 

Now on p. 72. 

See comment 68. 
Appendix VI: Comments from the Department of Defense 

Page 92 GAO-04-159 Gulf War Illnesses 

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. 

2. 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.

3. 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. 

GAO Comments 
Appendix VI: Comments from the Department of Defense 

Page 93 GAO-04-159 Gulf War Illnesses 

4. 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. 

5. 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 plumemodeling 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. 

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

7. 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. 

8. 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. 

9. 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 
Appendix VI: Comments from the Department of Defense 

Page 94 GAO-04-159 Gulf War Illnesses 

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.” 

10. 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. 

11. 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 LowLevel 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 
Appendix VI: Comments from the Department of Defense 

Page 95 GAO-04-159 Gulf War Illnesses 

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). 

12. 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. 
Appendix VI: Comments from the Department of Defense 

Page 96 GAO-04-159 Gulf War Illnesses 

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

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

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

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

17. 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. 

18. 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. 

19. The recommendation is intended to apply only to the 1991 Gulf War, and we have 

amended the recommendation to clarify its intent. 

20. 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. 

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

22. 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 
Appendix VI: Comments from the Department of Defense 

Page 97 GAO-04-159 Gulf War Illnesses 

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. 

23. 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. 

24. 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. 

25. 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. 

26. 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. 

27. 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. 

28. 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.” 

29. We concur with this comment and have clarified the report accordingly. 
Appendix VI: Comments from the Department of Defense 

Page 98 GAO-04-159 Gulf War Illnesses 

30. 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. 

31. 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. 

32. 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. 

33. 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. 

34. Given the images available, while the munitions may not have been targeted 

directly, they certainly seem to have been hit. 

35. 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. 
Appendix VI: Comments from the Department of Defense 

Page 99 GAO-04-159 Gulf War Illnesses 

36. 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. 

37. 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. 

38. 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. 

39. We do not agree with DOD. According to UNMOVIC, UNSCOM never inspected 

this bunker for safety reasons. 

40. We explained the methodology used by DOD and have clarified the report by 

deleting the comparison with Khamisiyah. 

41. 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, 
Appendix VI: Comments from the Department of Defense 

Page 100 GAO-04-159 Gulf War Illnesses 

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. 

42. 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. 

43. 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. 

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

45. 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. 

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

47. 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. 

48. 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. 

49. 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 
Appendix VI: Comments from the Department of Defense 

Page 101 GAO-04-159 Gulf War Illnesses 

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. 

50. 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. 

51. Figure 6 shows the layers in which these activities occur. We have changed the 

report to clarify this reference. 

52. 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. 

53. 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. 

54. 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 
Appendix VI: Comments from the Department of Defense 

Page 102 GAO-04-159 Gulf War Illnesses 

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.

55. 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. 

56. 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. 

57. 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. 
Appendix VI: Comments from the Department of Defense 

Page 103 GAO-04-159 Gulf War Illnesses 

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.1

 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 advectiondiffusion 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 inhouse 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. 

58. 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 

 1

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). 
Appendix VI: Comments from the Department of Defense 

Page 104 GAO-04-159 Gulf War Illnesses 

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. 

59. 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. 

60. 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. 

61. 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. 

62. 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 
Appendix VI: Comments from the Department of Defense 

Page 105 GAO-04-159 Gulf War Illnesses 

simple graphic overlay of the projection of the three component plumes. The 

relationship between these plumes, therefore, was not based on data. 

63. 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. 

64. 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 
Appendix VI: Comments from the Department of Defense 

Page 106 GAO-04-159 Gulf War Illnesses 

relative risks for CW agent exposure. This means also that the errors in recall did 

not result in recall bias. 

65. 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. 

66. 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 ICD9 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 
Appendix VI: Comments from the Department of Defense 

Page 107 GAO-04-159 Gulf War Illnesses 

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. 

67. 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 
Appendix VI: Comments from the Department of Defense 

Page 108 GAO-04-159 Gulf War Illnesses 

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. 

68. 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. 
Appendix VII: Comments from the Central Intelligence 

Agency 

Page 109 GAO-04-159 Gulf War Illnesses 

Appendix VII: Comments from the Central 

Intelligence Agency 

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