United States Government Accountability Office

GAO Testimony 

Before the Subcommittee on Oversight 

and Investigations, Committee on Energy 

and Commerce, House of Representatives

DEFENSE HEALTH CARE

Issues Related to Past 

Drinking Water 

Contamination at Marine 

Corps Base Camp Lejeune 

Statement of Marcia Crosse 

Director, Health Care 

For Release on Delivery

Expected at 10:00 a.m. EDT 

Tuesday, June 12, 2007

 

GAO-07-933T 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

June 12, 2007

DEFENSE HEALTH CARE 

Issues Related to Past Drinking Water 

Contamination at Marine Corps Base 

Camp Lejeune 

Highlights of GAO-07-933T, a testimony 

before the Subcommittee on Oversight 

and Investigations, Committee on Energy 

and Commerce, House of Representatives 

In the early 1980s, volatile organic

compounds (VOC) were discovered 

in some of the water systems 

serving housing areas on Marine 

Corps Base Camp Lejeune. 

Exposure to certain VOCs may 

cause adverse health effects, 

including cancer. Since 1991, the 

Department of Health and Human

Services’ Agency for Toxic 

Substances and Disease Registry 

(ATSDR) has been examining 

whether individuals who were

exposed to the contaminated 

drinking water are likely to have

adverse health effects. ATSDR’s 

current study is examining whether 

individuals who were exposed in

utero are more likely to have

developed certain childhood 

cancers or birth defects. 

GAO was asked to testify on its 

May 11, 2007 report: Defense 

Health Care: Activities Related to

Past Drinking Water 

Contamination at Marine Corps 

Base Camp Lejeune (GAO-07-276).

This testimony summarizes

findings from the report about 

(1) efforts to identify and address 

the past drinking water 

contamination, (2) the provision of 

funding and information from the 

Department of Defense (DOD) to

ATSDR, and (3) an assessment of

the design of the current ATSDR 

study. GAO reviewed documents, 

interviewed officials and former

residents, and contracted with the 

National Academy of Sciences to 

convene an expert panel to assess 

the current ATSDR study.

Efforts to identify and address the past drinking water contamination at 

Camp Lejeune began in the 1980s, when Navy water testing at Camp Lejeune 

detected VOCs in some base water systems. In 1982 and 1983, continued 

testing identified two VOCs—trichloroethylene (TCE), a metal degreaser,

and tetrachloroethylene (PCE), a dry cleaning solvent—in two water 

systems that served base housing areas, Hadnot Point and Tarawa Terrace. 

In 1984 and 1985 a Navy environmental program identified VOCs, such as

TCE and PCE, in some of the individual wells serving the Hadnot Point and 

Tarawa Terrace water systems. Ten wells were subsequently removed from 

service. DOD and North Carolina officials concluded that on- and off-base 

sources were likely to have caused the contamination. It has not been 

determined when contamination at Hadnot Point began. ATSDR has 

estimated that well contamination at Tarawa Terrace from an off-base dry 

cleaner began as early as 1957. 

Since ATSDR began its Camp Lejeune-related work in 1991, the agency has 

not always received requested funding and has experienced delays in 

receiving information from DOD. However, ATSDR officials said that while 

funding and access to records were probably slowed down and made more 

expensive by DOD officials’ actions, their actions did not significantly 

impede ATSDR’s Camp Lejeune-related health study efforts. The ATSDR 

officials also stated that while issues such as limitations in access to DOD 

data had to be addressed, such situations are normal during the course of a 

study. 

Members of the expert panel that the National Academy of Sciences 

convened for GAO generally agreed that many parameters of ATSDR’s 

current study are appropriate, including the study population, the exposure 

time frame, and the selected health effects. Regarding the study’s proposed 

completion date of December 2007, the panel experts had mixed opinions: 

three of the five panel experts who commented said that the projected date

appeared reasonable, while two said that the date might be optimistic. 

DOD, the Environmental Protection Agency, and the Department of Health 

and Human Services provided technical comments on a draft of the May 11, 

2007 report, which GAO incorporated where appropriate. Three members of 

an ATSDR community assistance panel for Camp Lejeune provided oral 

comments on issues such as other VOCs that have been detected at Camp 

Lejeune, and compensation, health benefits, and additional notification for 

former residents. GAO focused its review on TCE and PCE because they 

were identified by ATSDR as the chemicals of primary concern. GAO’s 

report notes that other VOCs were detected. GAO incorporated the panel 

members’ comments where appropriate, but some issues were beyond the 

scope of the report. 

www.gao.gov/cgi-bin/getrpt?GAO-07-933T.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Marcia Crosse 

at (202) 512-7119 or crossem@gao.gov. 
Mr. Chairman and Members of the Subcommittee: 

I am pleased to be here today as you examine issues related to past 

drinking water contamination at Camp Lejeune. In the early 1980s, 

Department of the Navy water testing at Marine Corps Base Camp Lejeune 

identified contamination in water systems that served housing areas on the 

base.1

 Further water testing revealed that some of the individual wells 

serving two of the water systems were contaminated with volatile organic

compounds (VOC), such as trichloroethylene (TCE), which is a metal 

degreaser and an ingredient in adhesives and paint removers, and 

tetrachloroethylene (PCE), which is a solvent used in the textile industry 

and a dry cleaning solvent. Although it is not known precisely when the 

wells became contaminated, the Department of Health and Human 

Services’ (HHS) Agency for Toxic Substances and Disease Registry 

(ATSDR), which is investigating the issue, has estimated that the 

contamination may have begun as early as the 1950s. According to ATSDR, 

the VOCs of primary concern at Camp Lejeune were TCE and PCE, and 

the agency notes that exposure to these chemicals may cause adverse 

health effects. For example, exposure to low levels of TCE may cause 

headaches and difficulty concentrating.2

 Exposure to high levels of both 

TCE and PCE may cause dizziness, headaches, nausea, unconsciousness, 

cancer, and possibly death.3

Former residents of Camp Lejeune have taken legal action against the 

federal government for injuries alleged to have resulted from exposure to

the contaminated water. As of June 2007, about 850 former residents and 

former employees of Camp Lejeune have filed tort claims with the 

Department of the Navy related to the past drinking water contamination. 

Two of these claims have resulted in the filing of lawsuits in Federal 

District Courts in Texas and Mississippi.4

 In addition, some former 

 1

Water testing was conducted at Camp Lejeune in preparation for meeting future drinking

water regulations and to address concerns about chemicals that had been buried on base. 

2

According to ATSDR, health effects from exposure to low levels of PCE are unknown. 

3

ATSDR did not define “low levels” or “high levels” of TCE or PCE. 

4

Snyder et al. v. U.S., Civ. No. 627 (S.D. Miss. filed July 27, 2004); Gros et al. v. U.S., Civ. 

No. 4665 (S. D. Tex. filed Dec. 13, 2004). The Federal Tort Claims Act requires that a claim 

must be presented in writing within 2 years after the claim accrues and that after a claim 

has been filed the agency has 6 months to make a decision. If the claim is denied or if no 

decision has been made after 6 months, the individual can then file a lawsuit against the 

federal government. 28 U.S.C. § 2675. The lawsuits were filed in the districts where the 

individuals resided at the time.

Page 1 GAO-07-933T
residents have expressed concern over the Marine Corps’ handling of and 

response to the drinking water contamination, noting that even though 

contaminants were detected as early as 1980, the wells that were 

determined to be contaminated were not removed from service until 1985. 

Some former residents have also asserted that there have been delays in 

the provision of funding and information from the Department of Defense 

(DOD) to ATSDR.5

My statement is based on our May 11, 2007 report, Defense Health Care: 

Activities Related to Past Drinking Water Contamination at Marine

Corps Base Camp Lejeune (GAO-07-276). For this report, the Ronald W. 

Reagan National Defense Authorization Act for Fiscal Year 2005 directed 

that we study and report on the past drinking water contamination and 

related adverse health effects at Camp Lejeune, including identifying the

type, source, and duration of the contamination and determining the 

actions taken to address the contamination, and assessing the current 

ATSDR health study.6

 My remarks today will summarize our findings 

related to the history of events related to drinking water contamination at

Camp Lejeune, specifically, (1) efforts to identify and address the past 

contamination; (2) the provision of funding and information from DOD to 

ATSDR for its work related to the past contamination at Camp Lejeune; 

and (3) an assessment by an independent panel of experts of the design of 

the current ATSDR health study, including the study’s population, the 

exposure time frame, selected health effects being measured, and the 

reasonableness of the projected completion date.

To do this work, we reviewed more than 1,600 documents related to past 

and current drinking water activities at Camp Lejeune. We focused our 

review on the past TCE and PCE contamination7

 because ATSDR had 

noted that these chemicals were the VOCs of primary concern at Camp 

Lejeune. However, we also reviewed documentation regarding other VOCs 

detected at Camp Lejeune. For this testimony we focused on 

 5

DOD is required by law to provide funding and data as necessary for ATSDR to carry out

certain health-related activities, including public health assessments. 

6

Pub. L. No. 108-375, § 317, 118 Stat. 1811, 1844. 

7

Throughout this testimony we use the term “contamination,” which is also used by the law

requiring us to do this work, as well as by the EPA and DOD, to describe the drinking water 

at Camp Lejeune in the early 1980s. However, EPA had not yet established maximum 

contaminant levels for the chemicals TCE and PCE during this period. See 40 C.F.R. §§

141.2 and 141.12 (1975-1985). 

Page 2 GAO-07-933T
contamination in Camp Lejeune’s Hadnot Point, Tarawa Terrace, and 

Holcomb Boulevard water systems, as they provided drinking water to 

most of the installation’s housing areas during the period of interest. We 

interviewed current and former officials from various DOD entities, 

including Camp Lejeune, Headquarters Marine Corps, and the Department 

of the Navy, to obtain information about the history of events related to 

the past drinking water contamination at Camp Lejeune, including efforts 

to identify and address the contamination. The current and former officials 

interviewed often provided information based on their memory of events 

that occurred more than 20 years ago. We attempted to corroborate their 

testimonial evidence with documentation whenever possible. The former 

officials we interviewed were responsible for environmental activities at 

Camp Lejeune or the Department of the Navy during the time in which the 

contamination was detected. The current officials we interviewed are 

responsible for environmental activities at Camp Lejeune, Headquarters 

Marine Corps, or the Department of the Navy. Some of these current 

officials were also responsible for environmental activities during the time 

in which the contamination was detected. We also met with 19 interested 

former residents and individuals who worked on the base during the 

1960s, 1970s, and 1980s, in order to obtain their perspective on historical 

events and to learn about their concerns related to the drinking water 

contamination. A former resident who is active in matters related to the 

past drinking water contamination at Camp Lejeune identified most of the 

interested former residents; others were identified at an ATSDR public 

meeting. Additionally, we examined reports from and interviewed officials 

with the Environmental Protection Agency (EPA) and with the North 

Carolina Department of Environment and Natural Resources who were 

knowledgeable about activities and costs related to the cleanup of the 

suspected sources of contamination. We also interviewed ATSDR officials 

and reviewed ATSDR’s Camp Lejeune-related documents and publications, 

including a 1997 public health assessment and an ATSDR health study 

released in 1998. We also interviewed officials with the Department of the 

Navy and the U.S. Army Center for Health Promotion and Preventive

Medicine, which serves as a liaison between DOD and ATSDR. To assess 

the design of the current ATSDR health study, we contracted with the 

National Academy of Sciences (NAS) to convene a panel of seven subject

area experts for a 1-day meeting. The expert panel was charged with 

evaluating the study’s population, exposure time frame, selected health 

effects, and completion date. We relied primarily on information gleaned 

from the expert panel meeting and the panel experts’ subsequent written 

responses to the set of questions that were discussed during the 1-day 

meeting. Not all panel members commented individually about each of the 

questions discussed during the 1-day meeting. Additionally, some panel 

Page 3 GAO-07-933T
members noted that certain questions addressed subjects that were 

outside their areas of expertise. We also reviewed study-related 

documentation furnished by officials from ATSDR, the Marine Corps, and 

the Navy Environmental Health Center, and interviewed officials from 

those agencies. We conducted our work from May 2005 through April 2007 

in accordance with generally accepted government auditing standards. 

In summary, we found that efforts to identify and address past drinking 

water contamination at Camp Lejeune began in the 1980s, when the Navy

initiated water testing, and are continuing with long-term cleanup and 

monitoring. In 1980, VOCs, including TCE, were first detected at Camp 

Lejeune during an analysis by a Navy-contracted laboratory that combined

treated water from all base water systems. During the same year, the Navy

began monitoring Camp Lejeune’s treated water for total trihalomethanes 

(TTHMs), contaminants that are a by-product of the water treatment 

process. The TTHM monitoring indicated interference from unidentified 

chemicals. In 1982 and 1983, continued TTHM monitoring identified TCE 

and another VOC, PCE, as contaminants in two separate water systems 

that served base housing areas, Hadnot Point and Tarawa Terrace. 

Sampling results indicated that the levels of TCE and PCE found in the 

water systems varied. Former Camp Lejeune environmental officials said

that they did not take additional steps to address the contamination after 

TCE and PCE were identified. The former officials recalled that they did 

not act because at that time they had little knowledge about TCE and PCE, 

there were no drinking water regulations that gave enforceable limits for 

these chemicals, and variation in water testing results raised questions 

about the tests’ validity. Also in 1982, a Navy environmental program 

began investigating potentially contaminated sites at many Marine Corps 

and Navy bases, including Camp Lejeune. Testing initiated under that 

program in 1984 and 1985 found that individual wells in the Hadnot Point 

and Tarawa Terrace water systems were contaminated with TCE, PCE, 

and other VOCs. Camp Lejeune officials removed 10 contaminated wells 

from service in 1984 and 1985. Camp Lejeune officials determined that 

several areas on base where hazardous waste and other materials were 

disposed of may have been the sources of contamination for the Hadnot 

Point water system, and North Carolina environmental officials 

determined that an off-base dry cleaner was the likely source of 

contamination for the Tarawa Terrace water system. Efforts are ongoing

by ATSDR to determine when contamination at Hadnot Point began. In 

2006, ATSDR estimated that well contamination from the off-base dry 

cleaner began as early as 1957. In 1989, both Camp Lejeune and the offbase dry cleaner were placed on EPA’s National Priorities List. 

Page 4 GAO-07-933T
Regarding the provision of funding and information from DOD to ATSDR 

for its work related to the past contamination at Camp Lejeune, we found 

that since ATSDR began its Camp Lejeune-related work in 1991, the

agency has not always received requested DOD funding and experienced

delays in receiving information from DOD. For example, for 3 of the 16 

fiscal years during which ATSDR has conducted its Camp Lejeune-related

work (fiscal years 1998 through 2000), no funding was provided to ATSDR 

by the Navy or any DOD entity. ATSDR also had difficulties getting 

documents needed from Camp Lejeune while it was conducting a public

health assessment for the base. However, ATSDR officials said that while 

funding and access to records were probably slowed down and their Camp 

Lejeune related work made more expensive by DOD officials’ actions, 

their actions did not significantly impede ATSDR’s Camp Lejeune-related 

health study efforts. The ATSDR officials also stated that while issues such 

as limitations in access to DOD data had to be addressed, such situations 

are normal during the course of a study. 

The experts convened by NAS to assess the design of the current ATSDR 

health study generally agreed that many parameters of ATSDR’s current 

study are appropriate. Regarding the study population, all seven panel

experts agreed that ATSDR’s study population of individuals who were 

potentially exposed in utero to the contaminated drinking water at Camp 

Lejeune between 1968 and 1985 was appropriate, as this population was 

arguably the most vulnerable to the effects of the contamination. Panel 

experts generally agreed that the 1968-1985 study time frame was 

reasonable, based on limitations in data availability for the years prior to 

1968. Regarding the health effects studied, five of the seven panel experts 

discussed health effects and said that the selected birth defects and 

childhood cancers were relevant. Regarding the proposed completion 

date, the panel experts had mixed opinions: three of the five panel experts 

who commented said that the projected December 2007 date appeared 

reasonable, while two said that the date might be optimistic. 

DOD, EPA, and HHS provided technical comments on a draft of the 

May 11, 2007 report, which we incorporated where appropriate. We 

provided the seven former Camp Lejeune residents who are members of 

an ATSDR community assistance panel for Camp Lejeune the opportunity

to provide comments on our draft—three of the panel members provided 

both technical and general oral comments, and four declined to review the 

draft report. The three panel members commented generally on issues 

such as VOCs other than TCE and PCE that have been detected at Camp 

Lejeune, compensation and health benefits for former residents, and 

additional notification for former residents. We incorporated the panel 

Page 5 GAO-07-933T
members’ technical comments where appropriate, but some issues they 

discussed were beyond the scope of the report. 

Drinking water can come from either groundwater sources, via wells, or 

from surface water sources, such as rivers, lakes, and streams. All sources 

of drinking water contain some naturally occurring contaminants. As 

water flows in streams, sits in lakes, and filters thorough layers of soil and 

rock in the ground, it dissolves or absorbs the substances that it touches. 

Some of these contaminants are harmless, but others can pose a threat to 

drinking water, such as improperly disposed-of chemicals, pesticides, and

certain naturally occurring substances. Likewise, drinking water that is not 

properly treated or disinfected, or which travels through an improperly 

maintained water system, may pose a health risk. However, the presence

of contaminants does not necessarily indicate that water poses a health 

risk—all drinking water may reasonably be expected to contain at least 

small amounts of some contaminants. As of July 2006, EPA had set 

standards for approximately 90 contaminants in drinking water that may 

pose a risk to human health. According to EPA, water that contains small 

amounts of these contaminants, as long as they are below EPA’s 

standards, is safe to drink. However, EPA notes that people with severely 

compromised immune systems and children may be more vulnerable to 

contaminants in drinking water than the general population. 

Background 

General Information about 

Camp Lejeune and Its 

Water Systems 

Camp Lejeune covers approximately 233 square miles in Onslow County, 

North Carolina, and includes training schools for infantry, engineers, 

service support, and medical support, as well as a Naval Hospital and 

Naval Dental Center. The base has nine family housing areas, and families 

live in base housing for an average of 2 years. Base housing at Camp 

Lejeune consists of enlisted family housing, officer family housing, and 

bachelor housing (barracks for unmarried service personnel). 

Additionally, schools, day care centers, and administrative offices are 

located on the base. Approximately 54,000 people currently live and work

at Camp Lejeune, including about 43,000 active duty personnel and 11,000 

military dependents and civilian employees. 

In the 1980s, Camp Lejeune obtained its drinking water from as many as 

eight water systems, which were fed by more than 100 individual wells 

that pumped water from a freshwater aquifer located approximately 180

feet below the ground. Each of Camp Lejeune’s water systems included 

wells, a water treatment plant, reservoirs, elevated storage tanks, and 

distribution lines to provide the treated water to the systems’ respective 

Page 6 GAO-07-933T
service areas. Drinking water at Camp Lejeune has been created by 

combining and treating groundwater from multiple individual wells that 

are rotated on and off, so that not all wells are providing water to the 

system at any given time. Water is treated in order to remove minerals and 

particles and to protect against microbial contamination. (See fig. 1 for a 

description of how a Camp Lejeune water system operates.) 

Figure 1: Conceptual Model of a Camp Lejeune Water System 

Sources: GAO, Art Explosion, and Marine Corps Base Camp Lejeune.

Untreated water

Treated water

 The drinking water at Camp Lejeune is obtained from groundwater pumped from a freshwater aquifer 

located approximately 180 feet below the ground. Groundwater is pumped through wells located near the 

water treatment plant. In the water treatment plant, the untreated water is mixed and treated through several 

processes: removal of minerals to soften the water, filtration through layers of sand and carbon to remove 

particles, chlorination to protect against microbial contamination, and fluoride addition to help prevent tooth 

decay. After the water is treated, it is stored in ground and elevated storage reservoirs. When needed, 

treated water is pumped from the reservoirs and tanks to facilities such as offices, schools, or houses on the base. 

 

3

5

2

1

4

1

Water

Treatment

Plant

3 School

Office

Wells

2

House

5

4

Reservoir

Note: Water treatment processes may not remove all contaminants present in untreated water. 

Page 7 GAO-07-933T
From the 1970s through 1987, Hadnot Point, Tarawa Terrace, and 

Holcomb Boulevard water systems provided drinking water to most of 

Camp Lejeune’s housing areas. The water treatment plants for the Hadnot 

Point and Tarawa Terrace water systems were constructed during the 

1940s and 1950s. The water treatment plant for the Holcomb Boulevard 

water system began operating at Camp Lejeune in 1972; prior to this time, 

the Hadnot Point water system provided water to the Holcomb Boulevard 

service area. In the 1980s, each of these three systems had between 8 and 

35 wells that could provide water to their respective service areas. In 1987 

the Tarawa Terrace water treatment plant was shut down and the 

Holcomb Boulevard water distribution system was expanded to include 

the Tarawa Terrace water service area. 

Generally, housing units served by the Tarawa Terrace and Holcomb 

Boulevard water systems consisted of family housing, which included 

single- and multifamily homes and housing in trailer parks. Housing units 

served by the Hadnot Point water system included mainly bachelor 

housing with limited family housing. Based on available housing data for 

the late 1970s and the 1980s,8

 the estimated annual averages of the number 

of people living in family housing units9

 served by these water systems at 

that time were: 

• 5,814 people in units served by the Tarawa Terrace water system, 

• 6,347 people in units served by the Holcomb Boulevard water system, and 

• 71 people in units served by the Hadnot Point water system. 

In addition to serving housing units, all three water systems provided 

water to base administrative offices. The Tarawa Terrace, Holcomb 

Boulevard, and Hadnot Point water systems also served schools and other 

recreational areas. Additionally, the Hadnot Point water system also 

served an industrial area and the base hospital. 

 8

To determine the estimated annual average of people who lived in family housing units 

served by these four water systems, we used limited housing data from 1977 to 1989 

provided to us by Camp Lejeune officials. Camp Lejeune officials could not provide 

housing data prior to 1977. 

9

Camp Lejeune housing officials could not provide occupancy rates for bachelor housing. 

Page 8 GAO-07-933T
Certain Navy entities provide support functions for Marine Corps bases 

such as Camp Lejeune. Two entities provide support for environmental 

issues: 

Department of the Navy 

Environmental Functions 

• The Naval Facilities Engineering Command began providing 

environmental support for bases in the 1970s. The Naval Facilities 

Engineering Command, Atlantic Division (LANTDIV) provides 

environmental support for Navy and Marine Corps bases in the Atlantic 

and mid-Atlantic regions of the United States.10 For example, LANTDIV 

officials work with Camp Lejeune officials to establish environmental 

cleanup priorities and cost estimates and to allocate funding to ensure 

compliance with state and federal environmental regulations. 

• The Navy Environmental Health Center (NEHC) has provided

environmental and public health consultation services for Navy and 

Marine Corps environmental cleanup sites since 1991. NEHC is also 

designated as the technical liaison between Navy and Marine Corps 

installations and ATSDR and, as a part of this responsibility, reviews and 

comments on all ATSDR reports written for Navy and Marine Corps sites 

prior to publication. Prior to 1991, no agency was designated to provide 

public health consultation services for Navy and Marine Corps sites. 

In 1980, the Department of the Navy established the Navy Assessment and 

Control of Installation Pollutants (NACIP) program to identify, assess, and 

control environmental contamination from past hazardous material 

storage, transfer, processing, and disposal operations. Under the NACIP 

program, initial assessment studies were conducted to determine the 

potential for environmental contamination at Navy and Marines Corps 

bases. If, as a result of the study, contamination was suspected, a followup confirmation study and corrective measures were initiated. In 1986 the 

Navy replaced its NACIP program with the Installation Restoration 

Program. The purpose of the Installation Restoration Program is to reduce, 

in a cost-effective manner, the risk to human health and the environment 

from past waste disposal operations and hazardous material spills at Navy 

and Marine Corps bases. Cleanup is done in partnership with EPA, state 

regulatory agencies, and members of the community. 

 10LANTDIV also manages the planning, design, construction, contingency engineering, real 

estate, and public works support at Navy and Marine Corps facilities in the United States. 

Page 9 GAO-07-933T
Congress passed the Safe Drinking Water Act in 197411 to protect the 

public’s health by regulating the nation’s public drinking water supply. The 

Safe Drinking Water Act, as amended, is the key federal law protecting 

public water supplies from harmful contaminants. For example, the act 

requires that all public water systems conduct routine tests of treated 

water to ensure that the water is safe to drink. Required water testing 

frequencies vary and range from weekly testing for some contaminants to 

testing every 3 years for other contaminants. The act also established a 

federal-state arrangement in which states may be delegated primary 

implementation and enforcement authority for the drinking water 

program. For contaminants that are known or anticipated to occur in 

public water systems and that EPA determines may have an adverse 

impact on health, the act requires EPA to set a nonenforceable maximum 

contaminant level goal, at which no known or anticipated adverse health 

effects occur and that allows an adequate margin of safety. Once the 

maximum contaminant level goal is established, EPA sets an enforceable

standard for water as it leaves the treatment plant, the maximum 

contaminant level. A maximum contaminant level is the maximum 

permissible level of a contaminant in water delivered to any user of a 

public water system. The maximum contaminant level must be set as close 

to the goal as is feasible using the best technology or other means 

available, taking costs into consideration. The North Carolina Department 

of Environment and Natural Resources and its predecessors12 have had 

primary responsibility for implementation of the Safe Drinking Water Act 

in North Carolina since 1980. 

In 1979, EPA promulgated final regulations applicable to certain 

community water systems establishing the maximum contaminant levels 

for the control of TTHMs, which are a type of VOC that are formed when 

disinfectants—used to control disease-causing contaminants in drinking 

water—react with naturally occurring organic matter in water. The 

regulations required that water systems that served more than 10,000 

people and that added a disinfectant as part of the drinking water 

Environmental Laws and 

Regulations Related to 

Drinking Water 

Contamination and 

Hazardous Waste 

Contamination at Camp 

Lejeune 

 11Pub. L. No. 93-523, 88 Stat. 1660 (codified, as amended, at 42 U.S.C. §§ 300f et seq.). 

12In the 1980s, the North Carolina Department of Human Resources administered the Safe

Drinking Water Act and the Department of Natural Resources and Community 

Development was responsible for other environmental functions in the state of North 

Carolina. In 1989, sections of these departments underwent a reorganization and name 

change, becoming the Department of Environment, Health, and Natural Resources. In 1997, 

the department was again reorganized and took on its current name, the Department of 

Environment and Natural Resources.

Page 10 GAO-07-933T
treatment process begin mandatory water testing for TTHMs by November 

1982 and comply with the maximum contaminant level by November 1983.

TCE and PCE were not among the contaminants included in these 

regulations.

In 1979 and 1980, EPA issued nonenforceable guidance establishing 

“suggested no adverse response levels” for TCE and PCE in drinking water 

and in 1980 issued “suggested action guidance” for PCE in drinking 

water.13 Suggested no adverse response levels provided EPA’s estimate of 

the short- and long-term exposure to TCE and PCE in drinking water for 

which no adverse response would be observed and described the known 

information about possible health risks for these chemicals. Suggested 

action guidance recommended remedial actions within certain time 

periods when concentrations of contaminants exceeded specific levels. 

Suggested action guidance was issued for PCE related to drinking water 

contamination from coated asbestos-cement pipes, which were used in 

water distribution lines.

The initial regulation of TCE and PCE under the Safe Drinking Water Act 

began in 1989 and 1992, respectively, when maximum contaminant levels 

became effective for these contaminants. (See table 1 for the suggested no

adverse response levels, suggested action guidance, and maximum 

contaminant level regulations for TCE and PCE.) 

 13Neither issuance was published in The Federal Register. 

Page 11 GAO-07-933T
Table 1: EPA Guidance and Regulations for Trichloroethylene (TCE) and Tetrachloroethylene (PCE) in Drinking Water 

Nonenforceable guidance

Enforceable 

regulation

Suggested no adverse response levela

for various exposure periods in parts per 

billion (ppb) issued in 1979 (TCE) and

1980 (PCE) 

Suggested action guidanceb

 for 

various exposure periods in ppb

issued in 1980 (PCE) 

Maximum 

contaminant 

level in milligrams 

per liter (mg/l) and 

ppbc

 effective in

1989 (TCE) and

1992 (PCE)

Chemical 1-Dayd10-DayeLong-termf1-Dayd10-DayeLong-termf

TCE 2,000 200 75 N/AgN/AgN/Ag0.005 mg/l or 5 ppb

PCE 2,300 175 20 2,300 180 40 0.005 mg/l or 5 ppb

Source: GAO analysis of EPA data. 

a

Suggested no adverse response levels are EPA-issued nonenforceable guidance for community

water systems regarding TCE and PCE in drinking water. 

b

Suggested action guidance is EPA-issued nonenforceable guidance suggesting that remedial action 

be taken when PCE exceeded specific levels. 

c

These are the maximum permissible levels of a contaminant in water that is delivered to a public

water system. Maximum contaminant levels are not specific to period of exposure. The maximum 

contaminant level for TCE became effective in 1989. See 52. Fed. Reg. 25716 (July 8, 1987). The 

maximum contaminant level for PCE became effective in 1992. See 52. Fed. Reg. 3593 (Jan. 30, 

1991). The maximum contaminant levels were issued in milligrams per liter. EPA also reports these 

contaminant levels in the equivalent ppb. 

d

One-day suggested no adverse response levels and suggested action guidance were the maximum 

levels for one 24-hour period of exposure. 

e

Ten-day suggested no adverse response levels and suggested action guidance were the maximum 

levels each day for 10 days of exposure. 

f

Long-term suggested no adverse response levels and suggested action guidance were the maximum 

levels each day for long-term exposure. Long-term exposure was based on a 70-year exposure. 

g

There was no suggested action guidance for TCE.

The Comprehensive Environmental Response, Compensation, and 

Liability Act (CERCLA) of 198014 established what is known as the 

Superfund program to clean up highly contaminated waste sites and 

address the threats that these sites pose to human health and the 

environment, and assigned responsibility to EPA for administering the 

 14Pub. L. No. 96-510, 94 Stat. 2767 (codified, as amended, at 42 U.S.C. §§ 9601 et seq.). 

Page 12 GAO-07-933T
program.15 CERCLA was amended by the Superfund Amendments and 

Reauthorization Act (SARA) of 1986.16 Among other things, SARA requires 

that federal agencies, including DOD, that own or operate facilities on 

EPA’s CERCLA list of seriously contaminated sites, known as the National

Priorities List, enter into an interagency agreement with EPA.17 The 

agreement is to specify what cleanup activities, if any, are required and to 

set priorities for carrying out those activities.18 SARA also established the 

Defense Environmental Restoration Program, through which DOD 

conducts environmental cleanup activities at military installations.19 Under 

the environmental restoration program, DOD’s activities addressing 

hazardous substances, pollutants, or contaminants are required to be 

carried out consistent with the provisions of CERCLA governing 

environmental cleanups at federal facilities.20 Based on environmental 

contamination at various areas on the base, Camp Lejeune was designated

as a National Priorities List site in 1989. EPA, the Department of the Navy,

and the state of North Carolina entered into a Federal Facilities Agreement 

concerning cleanup of Camp Lejeune with an effective date of March 1, 

1991. 

ATSDR’s Assessment of 

the Adverse Health Effects 

of Hazardous Substances 

at DOD Superfund Sites 

ATSDR was created by CERCLA and established within the Public Health 

Service of HHS in April 1983 to carry out Superfund’s health-related 

activities. These activities include conducting health studies, laboratory 

projects, and chemical testing to determine relationships between 

exposure to toxic substances and illness. In 1986, SARA expanded 

 15At privately owned sites, EPA can require that responsible parties either perform the 

cleanup themselves or reimburse EPA for the costs of Superfund-funded cleanups. Federal 

agencies generally must pay for cleanups and other Superfund activities from their own 

appropriations. 

16Pub. L. No. 99-499, 100 Stat. 1613 (1986) (codified, as amended, at various sections of 

titles 10, 26, 29, and 42 U.S.C.). 

17To determine which sites are eligible for listing on the National Priorities List, EPA uses 

the Hazard Ranking System, a numerical scoring system that assesses the hazards a site 

poses to human health and the environment as its principal determining factor. Once EPA

has determined that the risks posed by a site make it eligible for the National Priorities List, 

EPA regions then consider many other factors in selecting the sites to submit to EPA

headquarters for proposal to be added to the National Priorities List. 

18See 42 U.S.C. § 9620(e). 

19See 10 U.S.C. §§ 2701-2709. 

20See 10 U.S.C. § 2701(a)(2). 

Page 13 GAO-07-933T
ATSDR’s responsibilities to include, among other things, conducting 

public health assessments, toxicological databases, information 

dissemination, and medical education. SARA requires that ATSDR conduct 

a public health assessment at each site proposed for or on the National 

Priorities List, and that ATSDR conduct additional follow-up health studies 

if needed. Potentially responsible parties, including federal agencies, are 

liable for the costs of any health assessment or health effects study carried 

out by ATSDR.21

SARA requires that ATSDR and DOD enter into a memorandum of 

understanding to set forth the authorities, responsibilities, and procedures 

between DOD and ATSDR for conducting public health activities at DOD 

Superfund sites.22 Based on the memorandum of understanding signed 

between ATSDR and DOD, ATSDR is required to submit an annual plan of 

work to DOD, in which it must describe the public health activities it plans 

to conduct at DOD sites in the following fiscal year, as well as the amount 

of funding required to conduct these activities. After the annual plan of

work has been submitted, DOD has 45 days to respond and negotiate the 

scope of work to be conducted by ATSDR. The memorandum of 

understanding states that DOD must seek sufficient funding through the 

DOD budgetary process to carry out the work agreed upon. 

From 1991 to 1997, ATSDR conducted a public health assessment at Camp 

Lejeune that was required by law because of the base’s listing on the 

National Priorities List. The health assessment evaluated several ways in 

which people on base had been exposed to hazardous substances, 

including exposure to the VOC-contaminated drinking water.23 In its 1997

report, ATSDR recommended that a study be carried out to evaluate the 

risks of childhood cancer in those who were exposed in utero to the 

contaminated drinking water and also noted that adverse pregnancy

outcomes were of concern. In 1995, while the health assessment was being 

conducted, ATSDR initiated a study to determine whether there was an 

association between exposure to VOCs in drinking water and specific 

adverse pregnancy outcomes among women who had lived at Camp 

 21See 42 U.S.C. § 9607(a)(4)(D). 

22See 10 U.S.C. § 2704(c). 

23While conducting the health assessment, ATSDR also considered two other types of past

exposures at Camp Lejeune as possibly posing a public health hazard: lead in tap water and

pesticides in soil at a former day care facility. 

Page 14 GAO-07-933T
Lejeune from 1968 through 1985.24 The study, released in 1998, originally 

concluded that there was a statistically significant elevated risk for several 

poor pregnancy outcomes, including (1) small for gestational age among 

male infants born to mothers living at Hadnot Point, (2) small for 

gestational age for infants born to mothers over 35 years old living at 

Tarawa Terrace, and (3) small for gestational age for infants born to 

mothers with two or more prior fetal losses living at Tarawa Terrace.25

However, ATSDR officials said they are reanalyzing the findings of this 

study because of an error in the original assessment of exposure to VOCs 

in drinking water. While the study originally assessed births from 1968 to 

1972 in the Holcomb Boulevard service area as being unexposed to VOCs, 

these births were exposed to contaminants from the Hadnot Point water 

system. An ATSDR official said the reanalysis may alter the study’s results. 

In 1999, ATSDR initiated its current study examining whether certain birth

defects and childhood cancers are associated with exposure to TCE or 

PCE at Camp Lejeune. The study examines whether individuals born 

during 1968 through 1985 to mothers who were exposed to the 

contaminated drinking water at any time while they were pregnant and

living at Camp Lejeune were more likely than those who were not exposed 

to have neural tube defects, oral cleft defects, or childhood hematopoietic

cancers.26 The current study began with a survey to identify potential cases 

of the selected birth defects and childhood cancers. The study is also using 

water modeling27 to help ATSDR determine the potential sources of past 

contamination and estimate when the water became contaminated and

which housing units received the contaminated water. The water modeling 

data will help ATSDR identify which pregnant women may have been 

exposed to the contaminated water, and will also help ATSDR estimate the 

 24Although there was no evidence of an increased rate of adverse pregnancy outcomes at

Camp Lejeune at that time, the 1998 study report states that the agency believed it was 

prudent to research this topic because fetuses tend to be more sensitive to toxic chemical 

exposures and many pregnant women had resided in housing areas supplied with 

contaminated water. In addition to small for gestational age, other adverse pregnancy 

outcomes evaluated in the study included pre-term birth and mean birth weight. 

25U.S. Department of Health and Human Services, Agency for Toxic Substances and 

Disease Registry, Volatile Organic Compounds in Drinking Water and Adverse 

Pregnancy Outcomes (Atlanta, Ga.: 1998). 

26Childhood hematopoietic cancers include childhood leukemia and non-Hodgkin’s

lymphoma. 

27Water modeling is a scientific method that is used to help estimate past water system 

conditions. 

Page 15 GAO-07-933T
amount of TCE and PCE that may have been in the drinking water. ATSDR 

officials said that the study is expected to be completed by December 

2007. 

Possible Adverse Health 

Effects of TCE and PCE 

According to ATSDR’s Toxicological Profile, inhaling small amounts of 

TCE may cause headaches, lung irritation, poor coordination, and 

difficulty concentrating, and inhaling or drinking liquids containing high 

levels of TCE may cause nervous system effects, liver and lung damage,

abnormal heartbeat, coma, or possibly death.28 ATSDR also notes that 

some animal studies suggest that high levels of TCE may cause liver, 

kidney, or lung cancer, and some studies of people exposed over long 

periods to high levels of TCE in drinking water or workplace air have 

shown an increased risk of cancer. ATSDR’s Toxicological Profile notes 

that the National Toxicology Program has determined that TCE is 

reasonably anticipated to be a human carcinogen and the International 

Agency for Research on Cancer has determined that TCE is probably 

carcinogenic to humans. Unlike TCE, the health effects of inhaling or 

drinking liquids containing low levels of PCE are unknown, according to 

ATSDR. However, ATSDR reports that exposure to very high 

concentrations of PCE may cause dizziness, headaches, sleepiness, 

confusion, nausea, difficulty in speaking and walking, unconsciousness, or 

death.29 HHS has determined that PCE may reasonably be anticipated to be

a carcinogen. 

 28ATSDR did not define “small amounts” or “high levels” of TCE. According to ATSDR’s

Toxicological Profiles, when exposure to TCE or PCE occurs many factors determine 

whether an individual will be harmed. These factors include the amount of exposure, 

duration of exposure, and how an individual came in contact with these chemicals (i.e., 

ingestion, inhalation, or contact with the skin). 

29ATSDR did not define “low levels” or “high concentrations” of PCE. 

Page 16 GAO-07-933T
Efforts to identify and address past drinking water contamination at Camp 

Lejeune began in the 1980s, when the Navy initiated water testing at Camp 

Lejeune. In 1980, one water test identified the presence of VOCs and a 

separate test indicated contamination by unidentified chemicals. In 1982 

and 1983, water monitoring for TTHMs by a laboratory contracted by

Camp Lejeune led to the identification of TCE and PCE as the 

contaminants in two water systems at Camp Lejeune. Sampling results 

indicated that the levels of TCE and PCE varied. Former Camp Lejeune 

environmental officials said they did not take additional steps to address 

the contamination after TCE and PCE were identified. The former officials 

recalled that they did not take additional steps because at that time they 

had little knowledge of TCE and PCE, there were no regulations 

establishing enforceable limits for these chemicals in drinking water, and

variations in water testing results raised questions about the tests’ validity. 

In 1984 and 1985, the NACIP program identified VOCs, including TCE and 

PCE, in 12 of the wells serving the Hadnot Point and Tarawa Terrace water 

systems. Camp Lejeune officials removed 10 wells from service in 1984

and 1985. Additionally, information about the contamination was provided 

to residents. Upon investigating the contamination, DOD and North 

Carolina officials concluded that both on- and off-base sources were likely 

to have caused the contamination in the Hadnot Point and Tarawa Terrace 

water systems. Since 1989, federal, state, and Camp Lejeune officials have

partnered to take actions to clean up the sources of contamination and to 

monitor and protect the base’s drinking water. 

Efforts to Identify and 

Address Past Drinking 

Water Contamination 

at Camp Lejeune 

Began in the 1980s 

and Continue with 

Long-term Cleanup 

and Monitoring 

Navy Water Testing 

Beginning in 1980 

Identified VOCs in Camp 

Lejeune Water Systems 

The presence of VOCs in Camp Lejeune water systems was first detected 

in October 1980. On October 1, 1980, samples of water were collected from 

all eight water systems at Camp Lejeune by an official from LANTDIV, a 

Navy entity that provided environmental support to Camp Lejeune. The 

water samples were combined into a single sample, and a “priority 

pollutant scan” was conducted in order to detect possible contaminants in 

the water systems. The results of this analysis, conducted by a Navycontracted private laboratory and sent to LANTDIV, identified 11 VOCs, 

including TCE, at their detection limits, that is, the lowest level at which 

the chemicals could be reliably identified by the instruments being used.30

 30Additionally, two metals—cadmium and selenium—were identified at levels slightly 

above detection limits. 

Page 17 GAO-07-933T
Separately, in 1980 the Navy began monitoring programs for TTHMs at 

various Navy and Marine Corps bases, including Camp Lejeune, in 

preparation for meeting a future EPA drinking water regulation.31

LANTDIV arranged for an Army laboratory to begin testing the treated 

water from two Camp Lejeune water systems, Hadnot Point and New 

River, in October 1980. At that time, these two water systems were the 

only ones that served more than 10,000 people and therefore would be 

required to meet the future TTHM regulation. From October 1980 to 

September 1981, eight samples were collected from the Hadnot Point 

water system and analyzed for TTHMs. Results from four of the eight 

samples indicated the presence of unidentified chemicals that were 

interfering with the TTHM analyses.32 Reports for each of the four analyses

contained an Army laboratory official’s handwritten notes about the 

unidentified chemicals: two of the notes classified the water as “highly 

contaminated” and notes for the other two analyses recommended 

analyzing the water for organic compounds. 

The exact date when LANTDIV officials began receiving results from 

TTHM testing is not known, and LANTDIV officials told us that they had

no recollection of how or when the results were communicated from the 

Army laboratory. Available Marine Corps documents indicate that Camp 

Lejeune environmental officials33 learned in July 1981 that LANTDIV had 

been receiving the results of TTHM testing and was holding the results 

until all planned testing was complete. Subsequently, Camp Lejeune 

environmental officials requested copies of the TTHM results that 

LANTDIV had received to date, and LANTDIV provided these results in 

 31According to an August 1980 memorandum, which cited a 1979 amendment to the 

National Interim Primary Drinking Water Regulations, LANTDIV initiated monitoring

programs at various naval facilities, including Camp Lejeune, in order to develop a TTHM 

database prior to the effective dates for the enforcement of the maximum contaminant 

levels. For Camp Lejeune community water systems such as Hadnot Point and New River 

that served 10,000 to 74,999 individuals, the maximum contaminant levels for TTHMs took 

effect in November 1983 and an EPA requirement to begin monitoring TTHM levels in the 

systems began 1 year prior to that date. See 44 Fed. Reg. 68641 (Nov. 29, 1979) (to be

codified at 40 C.F.R. § 141.6). 

32The results from the other four samples did not note the presence of unidentified 

chemicals. 

33In the early 1980s the environmental staff at Camp Lejeune consisted of three primary 

staff members: a director specializing in natural resources, a supervisory ecologist, and a

chemist. These staff members were responsible for water monitoring and compliance with 

environmental regulations, among other responsibilities. Over time as environmental laws 

have changed, the environmental staff has grown and obtained additional responsibilities. 

Page 18 GAO-07-933T
August 1981. The next documented correspondence from LANTDIV to 

Camp Lejeune regarding TTHM monitoring occurred in a February 1982 

memorandum in which LANTDIV recommended that TTHM monitoring be 

expanded to all of Camp Lejeune’s water systems and noted that Camp 

Lejeune should contract with a North Carolina state-certified laboratory 

for the testing. Current and former LANTDIV officials recalled that their

agency played a limited role in providing information or guidance 

regarding environmental issues at Camp Lejeune, and that this assistance 

generally would have been at the request of Camp Lejeune officials. 

However, former Camp Lejeune environmental officials recalled that at

that time they had little experience in water quality issues and relied on 

LANTDIV to serve as their environmental experts. 

Further Tests Identified 

TCE and PCE in Two 

Camp Lejeune Water 

Systems in 1982 and 1983; 

Camp Lejeune Officials Do 

Not Recall Taking Action 

to Address the 

Contamination at That 

Time

Following LANTDIV’s recommendation to expand TTHM monitoring to all 

base water systems, Camp Lejeune officials contracted with a private 

state-certified laboratory to test samples of treated water from all eight of

their water systems. According to an August 1982 memorandum, in May 

1982 a Camp Lejeune official was informed during a telephone

conversation with a private laboratory official that organic cleaning 

solvents, including TCE, were present in the water samples for TTHM 

monitoring from the Hadnot Point and Tarawa Terrace water systems. In 

July 1982, additional water samples from the two systems were collected

in an effort to investigate the presence of these chemicals. In August 1982 

the contracted laboratory sent a letter to base officials informing them that

TCE and PCE were identified as the contaminants in the May and July 

samples. According to the letter, the testing determined that the Hadnot 

Point water system was contaminated with both TCE and PCE and the 

Tarawa Terrace water system was contaminated with PCE. The letter also

noted that TCE and PCE “appeared to be at high levels” and were “more 

important from a health standpoint” than the TTHM monitoring. Sampling 

results indicated that the levels of TCE and PCE varied. The letter noted 

that one sample taken in May 1982 from the Hadnot Point water system 

contained TCE at 1,400 parts per billion and two samples taken in July 

1982 contained TCE at 19 and 21 parts per billion. Four samples taken in 

May 1982 and July 1982 from the Tarawa Terrace water system contained

levels of PCE that ranged from 76 to 104 parts per billion. (See table 2 for 

the May and July 1982 sampling results.) 

Page 19 GAO-07-933T
Table 2: Sampling Results from Hadnot Point and Tarawa Terrace Water Systems 

for May 1982 and July 1982 

Concentrations of chemicals in parts per 

billiona 

Housing area SamplesbTCEcPCEd

May samplese

Hadnot Point 1 1,400 15

Tarawa Terrace 2 —f80

July samples

Hadnot Point 3 19 <1

4 21 <1

5 No datag 1.0

Tarawa Terrace 6 —f76

7 —f82

8 —f104

Source: GAO analysis of Headquarters Marine Corps data. 

a

The August 1982 letter from the contracted laboratory that provided these sampling results did not 

include the detection limit. The detection limit is the lowest level at which the chemicals could be 

reliably identified by the instruments being used. 

b

Camp Lejeune’s samples were identified by nonconsecutive numbers. We renumbered the samples 

to provide consecutive number identifiers. 

c

Trichloroethylene (TCE) is a volatile organic compound typically used as a metal degreaser. 

d

Tetrachloroethylene (PCE) is a volatile organic compound typically used as a dry cleaning solvent. 

e

The May samples were analyzed in July. 

f

The laboratory did not report results for TCE in these samples. 

g

A memorandum by a Camp Lejeune environmental official indicated that this sample was analyzed 

for TCE, but exact quantities were not determined. 

Former Camp Lejeune environmental officials recalled that after the 

private laboratory identified the TCE and PCE in the two water systems, 

they did not take additional steps to address the contamination for three 

reasons. First, they had limited knowledge of these chemicals; second, 

there were no regulations establishing enforceable limits for these 

chemicals in drinking water; and third, they made assumptions about why 

the levels of TCE and PCE varied and about the possible sources of the 

TCE and PCE. The former Camp Lejeune environmental officials told us 

that they were aware of EPA guidance, referred to as “suggested no 

adverse response levels,” for TCE and PCE when these contaminants were 

identified at Camp Lejeune. However, they noted that the levels of these 

contaminants detected at Camp Lejeune generally were below those 

Page 20 GAO-07-933T
outlined in the guidance. One Camp Lejeune environmental official also 

recalled that at the time they were unsure what the health effects would be 

for the lower amounts detected at the base. Additionally, in an August 

1982 document and during our interviews with current Camp Lejeune

environmental officials, it was noted that EPA had not issued regulations 

under the Safe Drinking Water Act for TCE and PCE when the private 

laboratory identified these chemicals in the drinking water. The former 

Camp Lejeune environmental officials also said that they made 

assumptions about why the levels of TCE and PCE varied. For example, 

they attributed the higher levels to short-term environmental exposures, 

such as spilled paint inside a water treatment plant, or to laboratory or 

sampling errors. Additionally, in an August 1982 memorandum, a Camp 

Lejeune environmental official suggested that based on the sampling 

results provided by the private laboratory, the levels of PCE detected 

could be the result of using coated pipes in the untreated water lines at 

Tarawa Terrace. The former Camp Lejeune environmental officials told us

that in retrospect, it was likely that well rotation in these water systems 

contributed to the varying sampling results because the contaminated 

wells may not have been providing water to the Hadnot Point and Tarawa 

Terrace systems at any given time. However, both they and current Camp 

Lejeune environmental officials said that at that time the base 

environmental staff did not know that the wells serving both systems were

rotated. 

After August 1982, the private laboratory continued to communicate with 

Camp Lejeune officials about the contamination of treated water from the 

Hadnot Point and Tarawa Terrace water systems. All eight of Camp 

Lejeune’s water systems were sampled again for TTHMs in November 

1982. In a December 1982 memorandum, a Camp Lejeune environmental 

official noted that during a phone conversation with a chemist from the 

private laboratory the chemist expressed concern that TCE and PCE were 

interfering with Tarawa Terrace and Hadnot Point TTHM samples. The 

chemist said the levels of TCE and PCE were “relatively high” in the 

November 1982 samples, though the specific levels of TCE and PCE were 

not provided to Camp Lejeune officials. The private laboratory report 

providing the November 1982 results said that the samples from Tarawa 

Terrace “show contamination” from PCE and the samples from Hadnot 

Point “show contamination” from both TCE and PCE. All eight of Camp 

Lejeune’s water systems were sampled again for TTHMs in August 1983, 

and the private laboratory report providing these results said that the 

samples from Tarawa Terrace “show contamination” from PCE and the

samples from Hadnot Point “show contamination” from both TCE and 

Page 21 GAO-07-933T
PCE.34 Former Camp Lejeune environmental officials recalled that they did 

not take any actions related to these findings. 

Discovery of 

Contamination in 

Individual Wells in 1984 

and 1985 Prompted Their 

Removal from Service, and 

Information Was Provided 

to Residents and the Media 

In 1982, Navy officials initiated the NACIP program at Camp Lejeune with 

an initial assessment study, which was designed to collect and evaluate 

evidence that indicated the existence of pollutants that may have 

contaminated a site or that posed a potential health hazard for people 

located on or off a military installation. The initial assessment study 

determined that further investigation was warranted at 22 priority sites 

and a confirmation study to investigate these sites was initiated in July 

1984. 

As a part of the confirmation study, a Navy contractor took water samples 

from water supply wells located near priority sites where groundwater 

contamination was suspected. Current and former Camp Lejeune officials 

told us that previous water samples usually had been collected from 

treated water at sites such as reservoirs or buildings within the water 

systems rather than being collected directly from individual wells at Camp 

Lejeune. In November 1984, Camp Lejeune officials received sampling 

results for one Hadnot Point well located near a priority site, which 

showed that TCE and PCE, among other VOCs, were detected in the well. 

This well was removed from service, and in December 1984, water 

samples from six Hadnot Point wells that were located in the same general 

area and treated water samples from the Hadnot Point water plant were 

also tested. Results of the analysis of the well samples indicated that both 

TCE and PCE were detected in one well, TCE was detected in two 

additional wells, and other VOCs were detected in all six wells. Results for 

the treated water samples also detected TCE and PCE. Four of these six 

wells were removed from service in addition to the original well removed 

from service. For the two wells that were not taken out of service, while 

initial results indicated levels of VOCs, including TCE, other test results 

showed no detectable levels of VOCs. Documents we reviewed show that 

continued monitoring of those two wells indicated no detectable levels of 

TCE. During December 1984, seven additional samples were taken from 

the treated water at Hadnot Point water plant and revealed no detectable 

levels of TCE and PCE. According to two former Camp Lejeune 

environmental officials, once the wells had been taken out of service and 

 34The reports of the November 1982 and August 1983 TTHM analyses did not provide 

further details about the levels of TCE and PCE detected. 

Page 22 GAO-07-933T
the samples from the water plant no longer showed detectable levels of 

TCE or PCE, they believed the water from the Hadnot Point water system 

was no longer contaminated. 

Although the December 1984 testing of water from the Hadnot Point water 

system showed no detectable levels of TCE or PCE, in mid-January 1985

Camp Lejeune environmental staff began collecting water samples from all 

wells on the base. Sampling results were received in February 1985 and 

detected VOCs, including TCE and PCE, in 3 wells serving the Hadnot 

Point water system and 2 wells serving the Tarawa Terrace water system. 

As a result, those 5 wells were removed from service. According to current

Camp Lejeune officials, all 10 wells had been removed from service by 

February 8, 1985. According to memoranda dated March 1985 and May 

1985, 1 of the 2 wells removed from service at Tarawa Terrace was used 

on 1 day in March 1985 and on 3 days in April 1985 for short periods of 

time to meet water needs at the base. See table 3 for the dates that wells 

were removed from service and for the levels of TCE and PCE that were 

detected in the wells prior to their removal from service in 1984 and 1985.

See app. I for the levels of all VOCs that were detected in the wells prior to 

their removal from service in 1984 and 1985. 

Page 23 GAO-07-933T
Table 3: Dates Wells Were Removed from Service in 1984 and 1985 at Hadnot Point 

and Tarawa Terrace Water Systems, and TCE and PCE Levels Detected in Each Well 

Prior to Removal from Service 

Concentrations of chemicals in 

parts per billiona 

Water 

systems Wells

Date removed 

from service TCEb

PCEc

Hadnot 602 Nov. 30, 1984 1,600 24

Point 601 Dec. 6, 1984 210 5

608 Dec. 6, 1984 110 ND

634dDec. 14, 1984 ND ND

637dDec. 14, 1984 ND ND

651 Feb. 4, 1985 3,200 386

652 Feb. 8, 1985 9 ND

653 Feb. 8, 1985 5.5 ND

Tarawa TT-26 Feb. 8, 1985 57 1,580

Terrace TT-23e Feb. 8, 1985 ND 132

Source: GAO analysis of Headquarters Marine Corps data. 

Notes: The detection limit for the instruments used to analyze the samples was 10 parts per billion. 

The detection limit is the lowest level at which the chemicals could be reliably identified by the 

instruments being used. A Marine Corps document providing the sampling results stated that ND

meant “none detected.” 

a

The concentrations provided are those detected prior to each well’s removal from service and are 

one-time sampling results. We did not find documentation that tied the decision to remove the wells 

from service to any particular level of contamination included in related EPA guidance or enforceable 

regulation. DOD sampling also detected other VOCs. (See app. I.) 

b

Trichloroethylene (TCE) is a volatile organic compound typically used as a metal degreaser. 

c

Tetrachloroethylene (PCE) is a volatile organic compound typically used as a dry cleaning solvent. 

d

TCE and PCE were not detected in this well prior to its removal from service. Documents indicate

that this well was taken out of service after detection of “significant levels” of methylene chloride, a 

VOC used in various industrial processes such as paint stripping, paint remover manufacturing, and 

metal cleaning and degreasing. 

e

Tarawa Terrace well TT-23 is also referred to as “TT-new well” in Marine Corps documents. 

In addition, while base officials were waiting for sampling results from 

January 1985 of samples collected from wells serving Hadnot Point, water 

from this system was provided to a third water system for about 2 weeks.

In late January 1985, a fuel line break caused gasoline to leak into the 

Holcomb Boulevard water treatment plant. During the approximately 

2-week period the treatment plant was shut down, water from the Hadnot 

Point system was pumped into the Holcomb Boulevard water lines. 

Former Camp Lejeune environmental officials said that they used water 

Page 24 GAO-07-933T
from the Hadnot Point water system because it was the only water system 

interconnected with the Holcomb Boulevard water system, and because

they believed the water from the Hadnot Point water system was no longer

contaminated. Prior to restarting the Holcomb Boulevard water system, 

samples of treated water were tested and no gasoline was detected in any 

of these samples. However, the samples were found to contain various 

levels of TCE; these results were attributed to the use of water from the 

Hadnot Point water system. About 5 days after these samples were taken, 

the Holcomb Boulevard water system was restarted because the fuel line 

had been repaired. 

Following the discovery of contamination at individual wells in 1984, 

Camp Lejeune published articles in the base newspaper, provided one 

notification to residents of housing areas served by the Tarawa Terrace 

water system, and created a press release about issues related to drinking 

water at Camp Lejeune. In December 1984 the base newspaper published 

its first story about sampling efforts, detection of VOCs, and removal of 

wells from service in the Hadnot Point water system. At this time, Camp 

Lejeune environmental officials had not begun sampling all other wells on 

the base, including those at the Tarawa Terrace water system. 

Subsequently, in April 1985 the Commanding General of Camp Lejeune 

issued a notice to residents who lived in housing areas served by the 

Tarawa Terrace water system.35 According to the notice: 

“Two of the wells that supply Tarawa Terrace have had to be taken off line because minute 

(trace) amounts of several organic chemicals have been detected in the water. There are no 

definitive State or Federal regulations regarding a safe level of these compounds, but as a

precaution, I have ordered the closure of these wells for all but emergency situations when 

fire protection or domestic supply would be threatened.” 

The notice asked residents to reduce water use until early June, when the 

construction of a new water line was to be completed. In May 1985, 

another article in the base newspaper stated the number of wells that had 

been removed from service, stated why the wells were removed from 

service, and noted the potential for water shortage at Tarawa Terrace as a

result. In addition, the Marine Corps provided us with copies of three 

North Carolina newspaper articles published from May 1985 to September 

 35Documents do not indicate how this notice was provided to residents. 

Page 25 GAO-07-933T
1985 discussing contamination at Camp Lejeune.36 All three articles 

included information about the drinking water contamination and noted

that 10 wells serving two water treatment systems at Camp Lejeune had 

been removed from service. 

Past Contamination Was 

Estimated to Have 

Originated from Both Onbase and Off-base Sources, 

and Cleanup Activities at 

These Sources Are Under 

Way 

The sources of past contamination for the Hadnot Point water system have 

not been conclusively determined. However, DOD officials have estimated 

that eight contaminated on-base sites in the proximity of the Hadnot Point 

water system may be the sources of contamination for that water system. 

These eight sites were contaminated by leaking underground storage tanks 

containing fuel, by degreasing solvents, by hazardous chemical spills, and 

by other waste disposal practices.37 Efforts by ATSDR are ongoing to 

conclusively determine the sources of past contamination in the Hadnot 

Point water system, as well as when the contamination began. For the 

Tarawa Terrace water system, North Carolina officials determined that the

contamination likely came from a dry cleaning solvent that had been

released into a leaking septic tank at an off-base dry cleaning facility—

ABC One Hour Cleaners—which built its septic system and began 

operation in 1954. Both the dry cleaning facility and its septic tank were 

located off base but adjacent to a supply well for the Tarawa Terrace 

water system. Based on the environmental contamination at this site, ABC 

One Hour Cleaners was designated as a National Priorities List site in 

1989. As part of its current health study, ATSDR has estimated that 

beginning as early as 1957 individuals were exposed to PCE in treated 

drinking water at levels equal to or greater than what became effective in 

1992 as EPA’s maximum contaminant level of 5 parts per billion. 

Since 1989, officials from Camp Lejeune, North Carolina, and federal 

agencies, including EPA, have taken actions to clean up the suspected 

sources of the contamination in the Hadnot Point and Tarawa Terrace 

water systems. Because the contamination is thought to have come from 

both on- and off-base sources, and because those sources are part of two 

separate National Priorities List sites—Camp Lejeune and ABC One Hour 

 36According to a May 1985 memorandum, Camp Lejeune officials issued a press release 

regarding removal of wells from service at Camp Lejeune in May 1985. However, the 

memorandum did not describe the contents of the press release, and the Marine Corps was

unable to locate a copy of the press release for our review.

37The sources of contamination at these eight sites were identified through the NACIP 

program and the Installation Restoration Program, which replaced NACIP as the Navy and 

Marine Corps environmental program. 

Page 26 GAO-07-933T
Cleaners—cleanup activities for the suspected sources of contamination 

are being managed separately. Cleanup activities have included the 

removal of contaminated soils and gasoline storage tanks and the 

treatment of contaminated groundwater and soils. 

Since ATSDR began its Camp Lejeune-related work in 1991, the agency did 

not always receive requested funding and experienced delays in receiving

information from DOD entities. Although concerns have been raised by 

former Camp Lejeune residents, ATSDR officials said these issues have 

not significantly delayed its work and that such situations are normal 

during the course of a study. 

Although ATSDR Did 

Not Always Receive 

Requested Funding 

and Experienced 

Delays in Receiving 

Information from 

DOD, Officials Said 

Their Work Has Not 

Been Significantly 

Delayed 

Funding of ATSDR’s Camp 

Lejeune Work 

ATSDR received funding from DOD for 13 of the 16 fiscal years during 

which it has conducted its Camp Lejeune-related work, and ATSDR 

provided its own funding for Camp Lejeune-related work during the other 

3 years. Under federal law and in accordance with a memorandum of 

understanding between DOD and ATSDR, DOD is responsible for funding 

public health assessments and any follow-up public health activities, such

as health studies or toxicological profiles related to DOD sites as agreed to 

in an annual plan of work. For fiscal year 1997, funding for ATSDR’s Camp 

Lejeune-related work came from the Navy. 

From fiscal year 1998 through fiscal year 2000, no funding was provided to 

ATSDR by the Navy or any DOD entity for its Camp Lejeune-related work 

because the agencies could not reach agreement about the funding for 

Camp Lejeune. In June 1997, ATSDR proposed conducting a study of 

childhood leukemia and birth defects associated with TCE and PCE 

exposure at Camp Lejeune during fiscal years 1998 and 1999 at an 

estimated cost of almost $1.8 million. In a July 1997 letter to the Navy, an 

ATSDR official noted that during a June meeting the Navy appeared to be

reluctant to fund the proposed study; however, the official noted that DOD 

was liable for the costs of the study under federal law. In an October 1997 

letter responding to ATSDR, a senior Navy official stated that the Navy did 

Page 27 GAO-07-933T
not believe it should be required to fund ATSDR’s proposed study because 

the cause of the contamination was an off-base source, ABC One Hour 

Cleaners. The Navy official said that it was more appropriate for ATSDR to 

seek funding for the study from the responsible party that caused the 

contamination.38 However, ATSDR officials told us that while they 

expected that the study would focus primarily on contamination from the 

dry cleaner, the study was also expected to include people who were 

exposed to on-base sources of contamination. An ATSDR official reported 

that the agency submitted its funding proposals for the Camp Lejeune 

study to DOD in each of the annual plans of work from fiscal year 1998 to

fiscal year 2000, but that during that time period the agency received no 

DOD funding and funded its Camp Lejeune-related work from general 

ATSDR funding. 

In fiscal year 2001 the Navy resumed funding of ATSDR’s Camp Lejeunerelated work. We could not determine why the Navy decided to resume 

funding of ATSDR’s work at that time. Since fiscal year 2003, funding for 

ATSDR’s Camp Lejeune-related work has been provided by the Marine 

Corps. According to a DOD official, the Marine Corps has committed to 

funding the current ATSDR study. The DOD official also noted that per a 

supplemental budget request from ATSDR for fiscal year 2006, the Marine 

Corps agreed to fund community assistance panel meetings and portions 

of a feasibility assessment for future studies that will include 

computerization of Camp Lejeune housing records. 

Provision of Information to 

ATSDR by DOD 

ATSDR has experienced some difficulties obtaining information from 

Camp Lejeune and DOD officials. For example, while conducting its public 

health assessment in September 1994, ATSDR sent a letter to the 

Department of the Navy noting that ATSDR had had difficulties getting 

documents needed for the public health assessment from Camp Lejeune,

such as Remedial Investigation39 documents for Camp Lejeune. The letter 

 38Additionally, the EPA Criminal Investigation Division, which conducted an investigation 

related to the drinking water contamination at Camp Lejeune, concluded that funding for 

the current study was apparently delayed because of opposition characterized as a 

professional difference of opinion as to the scientific value of the study by a midlevel 

manager at the Navy Environmental Health Center. 

39A Remedial Investigation is performed at a site after it is listed on the National Priorities 

List. The Remedial Investigation serves as a mechanism for collecting data. Data collected 

during the Remedial Investigation influence the development of remedial alternatives for

the site. 

Page 28 GAO-07-933T
also noted that ATSDR had sent several requests for information, and 

Camp Lejeune’s responses had been in most cases inadequate and no 

supporting documentation had been forwarded. ATSDR also had difficulty 

in obtaining access to DOD records while preparing to conduct its survey,

the first phase of the current ATSDR health study. In October 1998, ATSDR 

requested assistance from the Defense Manpower Data Center, which 

maintains archives of DOD data, in locating residents of Camp Lejeune 

who gave birth between 1968 and 1985 on or off base. An official at the 

Defense Manpower Data Center initially did not provide the requested 

information because he believed that doing so could constitute a violation 

of the Privacy Act.40 Between February and April 1999, Headquarters 

Marine Corps facilitated discussion between ATSDR and relevant DOD 

entities about these Privacy Act concerns and some information was 

subsequently provided to ATSDR by DOD. In April 2001, Headquarters 

Marine Corps sent a letter to the Defense Privacy Office suggesting that 

the Defense Manpower Data Center had only provided a limited amount of

information to ATSDR.41 However, in a July 2001 reply to Headquarters 

Marine Corps, the Defense Privacy Office noted that it believed that 

relevant data had been provided to ATSDR by the Defense Manpower Data 

Center in 1999 and 2001.

In December 2005, ATSDR officials told us that they had recently learned

of a substantial number of additional documents that had not been 

previously provided to them by Camp Lejeune officials. ATSDR then sent a 

letter to Headquarters Marine Corps seeking assistance in resolving 

outstanding issues related to delays in the provision of information and 

data to ATSDR. In an attachment to the letter, ATSDR provided a list of 

data and information needed from the Marine Corps in order to complete 

water modeling activities for its current study. In a January 2006 response,

a Headquarters Marine Corps official noted that a comprehensive review 

was conducted of responses to ATSDR’s requests for information and that 

the Marine Corps believed it had made a full and timely disclosure of all 

known and available requested documents. The official also noted that 

while ATSDR had requested that the Marine Corps identify and provide 

 40The Privacy Act of 1974 provides safeguards for individuals against invasions of privacy 

as a result of the collection of personal information by the federal government. Pub. L. No. 

93-579, § 3, 88 Stat. 1896, 1897 (codified as amended at 5 U.S.C. § 552a). 

41The Defense Privacy Office is responsible for implementation of DOD’s Privacy Program,

which regulates how and when DOD collects, maintains, uses, or disseminates personal 

information on individuals. 

Page 29 GAO-07-933T
documents that were relevant or useful to ATSDR’s study, the Marine 

Corps did not always have the subject matter expertise to determine the 

relevance of documents. The official noted that the Marine Corps would 

attempt to comply with this request; however, the official also noted that 

ATSDR was the agency with the expertise necessary to determine the 

relevance of documents. 

Effect on ATSDR’s Work Despite difficulties, ATSDR officials said the agency’s Camp Lejeunerelated work had not been significantly delayed or hindered by DOD. 

Officials said that while funding and access to records were probably 

slowed down and made more expensive by DOD officials’ actions, their 

actions did not significantly impede ATSDR’s health study efforts. The 

ATSDR officials also stated that while issues such as limitations in access 

to DOD data had to be addressed, such situations are normal during the 

course of a study. The officials stated that ATSDR’s progress on the study 

has been reasonable in light of the complexity of the project. Nonetheless, 

as some former residents have learned that ATSDR has not always 

received requested funding and information from DOD entities, they have 

raised questions about DOD’s commitment to supporting ATSDR’s work.42

For example, when some former residents learned during a community 

assistance panel meeting that it took about 4 months for DOD to respond 

to a supplemental budget request from ATSDR for fiscal year 2006, they 

questioned DOD entities’ commitment to ATSDR’s Camp Lejeune-related 

work. However, DOD and ATSDR officials described this delay in 

responding as typical during the funding process. 

 42The Marine Corps has issued multiple public statements indicating support for ATSDR’s 

work at Camp Lejeune. 

Page 30 GAO-07-933T
The seven members of an expert panel convened by NAS at our request 

generally agreed that specific parameters of ATSDR’s current study were 

appropriate, including the study population, the exposure time frame, and 

the selected health effects. The expert panel members had mixed opinions 

on ATSDR’s projected completion date. 

Experts Convened by 

NAS Generally Agreed 

That Many 

Parameters of 

ATSDR’s Current 

Study Were 

Appropriate 

Study Population The seven panel experts concurred that ATSDR logically limited its study 

population to those individuals who were in utero while their mothers 

were pregnant and lived at Camp Lejeune during the 1968 through 1985 

time frame, and who may have been exposed to the contaminated drinking

water.43 The current study follows recommendations from the agency’s 

1997 public health assessment of Camp Lejeune, which noted that studies 

of cancer among those who were exposed in utero should be conducted to 

further the understanding of the health effects in this susceptible 

population. Panel experts said that ideally a study would attempt to 

include all individuals who were potentially exposed, but that limited 

resources and data availability were practical reasons for limiting the 

study population. Additionally, panel experts agreed that those exposed 

while in utero were an appropriate study population because they could be

considered at higher risk of adverse health outcomes than others, such as

those exposed as children or adults. In addition, two panel experts said 

that studying only those who lived on base was reasonable because they 

likely had a higher risk of inhalation exposure to VOCs such as TCE and 

PCE, which may be more potent than ingestion exposure.44 Thus, pregnant

women who lived in areas of base housing with contaminated water and 

 43ATSDR’s current study population of those individuals who were in utero includes

individuals whom ATSDR determined were exposed during specific time periods of the

mother’s pregnancy or after their birth to contaminated drinking water because they lived 

in an area that was served by the Hadnot Point or Tarawa Terrace water systems, and those 

that ATSDR determined through its study analysis were not exposed because they did not

live in those areas or were not exposed during specific time periods. 

44According to ATSDR, inhalation of TCE and PCE that have evaporated from drinking 

water is likely to result in higher exposures than ingestion. Additionally, 1991 EPA 

guidance on estimating exposure to VOCs during showering noted that scientific studies

found that this exposure is approximately equivalent to exposure from ingesting two liters

of the contaminated water per day. 

Page 31 GAO-07-933T
conducted activities during which they could inhale water vapor—such as 

bathing, showering, or washing dishes or clothing—likely faced greater 

exposure than those who did not live on base but worked on base in areas 

served by the contaminated drinking water. 

The seven panel experts agreed that the 1968 through 1985 study time 

frame was reasonable, based on limitations in data availability. This time 

frame was adopted from ATSDR’s 1998 study of adverse pregnancy 

outcomes, which limited the study population to include those potentially

exposed between 1968 and 1985. According to ATSDR’s study protocol, 

these years were chosen because 1968 was the first year that birth 

certificates were computerized in North Carolina and 1985 was when the 

affected water wells were removed from service. Four of the panel experts 

said they did not see any benefit in using an earlier start date than 1968 

because collecting birth records before 1968 could require a significant 

amount of resources to collect data. In addition, while the initial exposure 

to contaminated drinking water may have occurred as early as the 1950s, 

at the time the ATSDR study time frame was selected officials were unable 

to determine precisely when the contamination began. Four of the panel 

experts commented that exposure was likely highest in the latter part of 

the study time frame—presumably, they said, as a result of a higher 

accumulated level of contamination over time—thus making the 

uncertainty of when the contamination began less significant and 

supporting ATSDR’s decision to study the later time frame. 

Study Time Frame 

Study Health Effects The five panel experts who discussed health effects said that those 

selected for the study were valid for individuals who were potentially 

exposed in utero at Camp Lejeune.45 Based on previous ATSDR work and 

existing literature, the health effects chosen for the study were neural tube 

defects, oral cleft defects, and childhood hematopoietic cancers, including

leukemia and non-Hodgkin’s lymphoma.46 Two panel experts said that 

 45The two panel experts who did not discuss health effects said that this discussion was

outside their areas of expertise. One expert is a professor of geochemistry and the second

is an environmental engineer. 

46An ATSDR document listing frequently asked questions about its health study states that 

the agency chose to study these birth defects and cancers based on the results of previous 

studies; two previous studies suggested that the chemicals in the drinking water at Camp 

Lejeune might cause these birth defects, while three studies suggested that these chemicals 

in drinking water might cause childhood leukemia. Additionally, ATSDR’s study protocol 

noted that ATSDR’s study could add to the body of scientific knowledge. 

Page 32 GAO-07-933T
ATSDR had limited its study to health effects that are rare and that 

generally occur at higher levels of exposure to VOCs such as TCE and PCE 

than are expected to have occurred at Camp Lejeune. They said that this 

may result in ATSDR not identifying enough individuals with these health 

effects to determine meaningful results in the study.47

ATSDR has projected a December 2007 completion date for the study, 

which would include activities such as identifying and enrolling study 

participants, conducting a parental interview, confirming each reported 

diagnosis, modeling the water system to quantify the amount and extent of 

each individual’s exposure, analyzing the data, and drafting a final report. 

Panel experts had mixed opinions regarding ATSDR’s completion date. Of

the five panel experts who commented on the proposed completion date,

three said that the date appeared reasonable, and two others said that 

based on the complexity of the water modeling the projected completion 

date might be optimistic.48

Mr. Chairman, this completes my prepared statement. I would be happy to

respond to any question you or other Members of the Subcommittee may 

have at this time. 

For further information about this testimony, please contact Marcia 

Crosse at (202) 512-7119 or crossem@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on the 

last page of this testimony. Bonnie Anderson, Assistant Director; Karen 

Doran, Assistant Director; Danielle Organek; and Christina Ritchie made 

key contributions to this testimony. 

Study Completion Date 

Contacts and 

Acknowledgments 

 47ATSDR’s public health assessment noted that the exposure levels experienced at Camp 

Lejeune were expected to be relatively low and experienced over a relatively short

duration. 

48One of the panel experts did not discuss the completion date of the study. A second

expert said he did not have sufficient data to make a determination on whether the 

projected completion date was reasonable. 

Page 33 GAO-07-933T
Appendix I: Volatile Organic Compounds 

Detected in Wells at Hadnot Point and Tarawa

Terrace Water Systems 

Page 34 GAO-07-933T

Appendix I: Volatile Organic Compounds 

Detected in Wells at Hadnot Point and 

Tarawa Terrace Water Systems 

Concentrations of chemicals in parts per billiona

Water 

systems Wells 

Date removed 

from service TCEb

PCEcBenzened

Trans1,2-DCEe

1,1-DCEf

Methylene 

chlorideg

Tolueneh

Vinyl 

chloridei

Hadnot 602 Nov. 30, 1984 1,600 24 120 630 2.4 — 5.4 18

Point 601 Dec. 6, 1984 210 5 ND 88 ND ND ND ND

608 Dec. 6, 1984 110 ND 3.7 5.4 ND ND ND ND

634 Dec. 14, 1984 ND ND ND 2.3 — 130 — ND

637 Dec. 14, 1984 ND ND ND ND — 270 — —

651 Feb. 4, 1985 3,200 386 — 3,400 187 — — 655

652 Feb. 8, 1985 9 ND — ND ND — — ND

653 Feb. 8, 1985 5.5 ND — ND ND — — ND

Tarawa TT-26 Feb. 8, 1985 57 1,580 ND 92 — — — 27

Terrace TT-23j Feb. 8, 1985 ND 132 ND 11 — — — ND

Source: GAO analysis of Headquarters Marine Corps data. 

Notes: The detection limit for the instruments used to analyze the samples was 10 parts per billion. 

The detection limit is the lowest level at which the chemicals could be reliably identified by the 

instruments being used. A Marine Corps document providing the sampling results stated that ND

meant “none detected.” Where no concentration or ND is provided, the laboratory did not report 

results for these samples. 

a

The concentrations provided are those detected prior to each well’s removal from service in 1984 

and 1985 and are one-time sampling results. We did not find documentation that tied the decision to 

remove the wells from service to any particular level of contamination included in related 

Environmental Protection Agency (EPA) guidance or enforceable regulation. 

b

Trichloroethylene (TCE) is a volatile organic compound typically used as a metal degreaser. 

c

Tetrachloroethylene (PCE) is a volatile organic compound typically used as a dry cleaning solvent. 

d

Benzene is a widely used chemical formed from both natural processes and human activities. Some 

industries use benzene to make other chemicals which are used to make plastics, resins, and nylon 

and synthetic fibers. Benzene is also a natural part of crude oil, gasoline, and cigarette smoke. 

Breathing benzene can cause drowsiness, dizziness, and unconsciousness; long-term benzene 

exposure causes effects on the bone marrow and can cause anemia and leukemia. The Department 

of Health and Human Services (HHS) has determined that benzene is a known carcinogen. 

e

Trans-1,2-dichloroethylene (Trans-1,2-DCE) is an odorless organic liquid used as a solvent for 

waxes and resins; in the extraction of rubber; as a refrigerant; in the manufacture of pharmaceuticals 

and artificial pearls; in the extraction of oils and fats from fish and meat; and in making other organics.

EPA has found trans-1,2-DCE to potentially cause central nervous system depression when people 

are exposed to it at levels above 100 parts per billion for relatively short periods of time. Trans-1,2-

DCE has the potential to cause liver, circulatory, and nervous system damage from long-term 

exposure at levels above 100 parts per billion. 

f

1,1-dichloroethylene (1,1-DCE) is an organic liquid with a mild, sweet, chloroform-like odor. Virtually 

all of it is used in making adhesives, synthetic fibers, refrigerants, food packaging, and coating resins. 

EPA has found 1,1-DCE to potentially cause liver damage when people are exposed to it at levels

above 7 parts per billion for relatively short periods of time. In addition, 1,1-DCE has the potential to 

cause liver and kidney damage as well as toxicity to the developing fetus and cancer from a lifetime 

exposure at levels above 7 parts per billion. 
Appendix I: Volatile Organic Compounds 

Detected in Wells at Hadnot Point and Tarawa

Terrace Water Systems 

g

Methylene chloride is a volatile organic compound used in various industrial processes, including 

paint stripping, paint remover manufacturing, and metal cleaning and degreasing. Breathing in large 

amounts of methylene chloride can damage the central nervous system. Contact of eyes or skin with 

methylene chloride can result in burns. HHS has determined that methylene chloride can be 

reasonably anticipated to be a cancer-causing chemical. 

h

Toluene is a clear, colorless liquid which occurs naturally in crude oil and in the tolu tree. It is also 

produced in the process of making gasoline and other fuels from crude oil and making coke from 

coal. Toluene may affect the nervous system. Low to moderate levels can cause tiredness, confusion, 

weakness, drunken-type actions, memory loss, nausea, loss of appetite, and hearing and color vision 

loss. Inhaling high levels of toluene in a short time can result in feelings of light-headedness, 

dizziness, or sleepiness. It can also cause unconsciousness, and even death. High levels of toluene 

may affect kidneys. Studies in humans and animals generally indicate that toluene does not cause 

cancer. 

i

Vinyl chloride is a colorless gas. It is a manufactured substance that does not occur naturally. It can 

be formed when other substances such as trichloroethane, TCE, and PCE are broken down. 

Breathing high levels of vinyl chloride for short periods of time can cause dizziness, sleepiness, and 

unconsciousness and at extremely high levels can cause death. Breathing vinyl chloride for long 

periods of time can result in permanent liver damage, immune reactions, nerve damage, and liver 

cancer. HHS has determined that vinyl chloride is a known carcinogen. 

j

Well TT-23 is also referred to as “TT-new well” in Marine Corps documents. 

(290641) Page 35 GAO-07-933T
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