Description

This source is a letter concerning the implementation of a confined space entry program for missile operations ashore and afloat. It describes efforts to implement necessary requirements, including performing gas analyses to ensure safe operating conditions. It emphasizes ensuring required training and certification standards are incorporated and identifying work performers well-versed in safety procedures related to potential hazards. The objective is the methodical and comprehensive development of a formal confined space program.

Abstract

This letter discusses the implementation of a confined space entry program for missile operations, emphasizing the need for gas analyses, training, and safety procedures to address potential hazards in confined spaces.

Submarine Toxic, Hazardous, and Radiation Exposures

Executive Summary

Situation

• Active duty Submariners make up less than 7% of the Navy’s personnel. By comparison, this means that Submariners equate to less than 0.5% of current US military manpower and account for less than 300,000 veterans.
• Generations of Submarine Veterans are suffering from serious health issues.
• VA claims filed by submariners under the PACT Act are declined at a disproportionate rate.

Problem

• Unknown number of Submariners diagnosed annually with illnesses potentially linked to toxins found in submarine atmospheres.
• Lack of consistent and accurate scientific data on submarine atmospheric toxicity available to prove or disprove illnesses.
• Inefficient bureaucratic processes extend VA claims processing times for Submariners requesting PACT Act consideration.

Solution

• Expand PACT Act eligibility to include Submariners serving onboard US Navy submarines from 1950 through the present day.
• Conduct definitive studies on atmospheric contaminants for all operational classes of nuclear submarines.
• Improve VA claim processing efficiencies by removing unnecessary complexity and provide VSRs with factual data-driven evidence.

Call to Action

• Swift and aggressive leadership is needed to recognize this as a long-term problem faced by Submariners.
• Acknowledgement that previous scientific research associated with the Submarine environment, especially the atmosphere, has been insufficient, and that Submarine Veterans need official recognition to that effect.
• Commission scientific and medical studies using advanced atmosphere monitoring and diagnostic equipment aboard deployed submarines.

Background

U.S. Navy submarines are described as the most technologically advanced and stealthy warship in the world. For 125 years, Submariners have confidently and proudly volunteered to sail under all the world’s oceans to protect national interests, prevent nuclear war, and provide a silent and unseen global presence.

A small group of veteran Submariners began discussing the various toxins and hazardous chemicals they were exposed to while deployed onboard submerged submarines. Eventually, these discussions turned to the countless stories of brother and sister Submariners who had developed health issues during or after their Naval service. These discussions led to the formation of the Submariners’ Advocacy Group (SAG) in April 2024. SAG was founded by 15 Submariners who recognized the need for action on behalf of the estimated less than 300,000 Submariners in the U.S. population.

Submariners

Every Submariner is a volunteer. They are expected to become an expert not only in their career field but also in the submarine itself. Every crew member must learn the purpose, function, and how every system on board works, including basics of nuclear power, electrical distribution, ventilation and atmosphere control, hydraulics, weapons systems, and boat construction. They must become experts in combatting casualties like flooding and fires, know the location and use of damage control equipment.

In addition to tangible skills, they must form a mutual bond of trust and respect with every member of the crew. Every Submariner must undergo an intense and challenging qualification process designed to test them mentally and physically. Once they have demonstrated their knowledge, trust, and gained the respect of the crew, they earn the coveted warfare insignia of a U.S. Submariner – Dolphins. Earning one’s Dolphins is described as demonstrating a commitment to excellence unmatched by any other branch in the U.S. Military.

Submarine Atmosphere and Monitoring

In 1955, nuclear power changed submarine technology forever, providing an unlimited source of power for propulsion and electricity, allowing submarines to remain submerged for much longer periods. Maintaining a habitable atmosphere was critical.

To prolong submerged time, three critical pieces of atmosphere control equipment were developed:

• The Oxygen (O2) Generator, which creates oxygen using electrolysis from distilled, filtered, and deionized seawater.
• The Carbon Dioxide (CO2) Scrubber, which removes CO2 from the atmosphere using the chemical monoethanolamine (MEA or amine). MEA absorbs CO2 at room temperature and releases it when heated for disposal overboard.
• The Carbon Monoxide – Hydrogen (CO-H2) Burner, which uses a high-temperature baseplate to convert carbon monoxide into carbon dioxide and hydrogen gas into water vapor.

These systems work together with the ship’s ventilation system, which includes recirculation fans, dampers, blowers, and the emergency diesel engine (which can be used as a high-powered exhaust fan).

A sophisticated monitoring system known as CAMS keeps the submarine’s atmosphere in check. Sensors in every habitable space sample the atmosphere and monitor for abnormalities. Readings are reviewed hourly, and alarms sound if an out-of-specification reading is detected, prompting immediate crew actions to regain control of the atmosphere.

Based on publicly available information, it is presumed that atmospheres on U.S. Navy submarines have not been adequately studied, measured, or monitored. There is a need for the collection of more substantial data on the long-term effects of exposure to the submarine atmosphere and its contaminants.

Toxic & Hazardous Chemicals

There are potentially 130 or more chemicals that could be classified as submarine atmospheric contaminants. A 2007 NRC report only focused on 26 individual chemicals or gases, which is only 20% of the known or possible contaminants. Surveys recommended by 1983 and 1988 reports were not performed by the time the NRC COT subcommittee was established in 2002. Failure to conduct these studies has resulted in an inadequate understanding of the toxicity of the atmospheres onboard submarines. As a result, tens of thousands of Submariners have been continuously exposed to these hazardous chemicals.

The three-volume report from 2007 to 2009 admitted the failure to address exposure to chemical mixtures and the potential for antagonistic, additive, or synergistic interactions between contaminants. Findings were based on widely accepted industry standards regarding exposure limits but failed to consider that onboard a submerged submarine, human exposures are continuous for 24 hours a day for months on end in a sealed environment.

The report focuses on specific gasses and chemicals:

• Oxygen: Submariners are routinely subjected to O2 levels below the normal atmospheric level of 20.9% and often in hypoxic levels less than 19.5%.
• Carbon Dioxide: The atmosphere often runs with higher than accepted exposure limits for CO2. The NRC recommended 90-day levels be increased to 0.8%, which is 20 times greater than normal air (0.04%).
• Monoethanolamine (MEA / Amine): Amine vapor escapes from CO2 Scrubbers and permeates every porous material onboard (skin, clothing, bedding, paper). There have been no studies on the long-term exposure to amine experienced by Submariners. Amine is described as acutely toxic.
• 2,6-di-tert-butyl-4-nitrophenol (DBNP): This chemical was formed from DBP, a preservative in the main lube oil (2190 TEP), when TEP was released into the atmosphere and went through electrostatic precipitators. DBNP has been identified as an acute toxin.
• Benzene: Widely studied and identified as a carcinogen and acutely toxic. It is used in many applications throughout submarines.
• Asbestos: Hazards are common knowledge. In the past, it was used extensively in insulation and other applications as a fire retardant on submarines.