Defense Health Care: Activities Related to Past Drinking Water Contamination at Marine Corps Base Camp Lejeune
Published: 2007-05-11T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In the early 1980s, volatile organic compounds (VOCs) 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. In 1999, the Department of Health and Human Services' (HHS) Agency for Toxic Substances and Disease Registry (ATSDR) began a study to examine whether individuals who were exposed in utero to the contaminated drinking water are more likely to have developed certain childhood cancers or birth defects. ATSDR has projected a December 2007 completion date for the study. The National Defense Authorization Act of Fiscal Year 2005 required GAO to report on past drinking water contamination and related health effects at Camp Lejeune. In this report GAO describes (1) efforts to identify and address the past contamination, (2) activities resulting from concerns about possible adverse health effects and government actions related to the past contamination, and (3) the design of the current ATSDR study, including the study's population, time frame, selected health effects, and the reasonableness of the projected completion date. GAO reviewed documents, interviewed officials and former residents, and contracted with the National Academy of Sciences to convene an expert panel to assess the design of the current ATSDR study.
section_title: What GAO Found
paragraphs: 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. Department of Defense (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. Activities related to concerns about possible adverse health effects began in 1991, when ATSDR initiated a public health assessment evaluating the possible health risks from exposure to the contaminated drinking water. The health assessment was followed by two health studies, one of which is ongoing. While ATSDR did not always receive requested funding and experienced delays in receiving information from DOD for its Camp Lejeune-related work, ATSDR officials said this has not significantly delayed their work. Former residents and employees have filed about 750 claims against the federal government. Additionally, three federal inquiries into issues related to the contamination have been conducted--one by a Marine Corps-chartered panel and two by the Environmental Protection Agency (EPA). Members of the expert panel that the National Academy of Sciences convened 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. ATSDR's study is examining whether individuals who were exposed in utero to the contaminated drinking water at Camp Lejeune between 1968 and 1985 were more likely to have specific birth defects or childhood cancers than those not exposed. DOD, EPA, and HHS provided technical comments on a draft of this 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 this report.

section_title: Letter
paragraphs: 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. Further water testing revealed that some of the  individual wells serving two of the water systems were contaminated with  volatile organic compounds (VOCs), 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. By 1985, 10 wells that were  determined to be contaminated with VOCs had been removed from  service. 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. Exposure to high levels of both TCE and PCE  may cause dizziness, headaches, nausea, unconsciousness, cancer, and  possibly death.
As required by federal law, ATSDR conducted a public health assessment  at Camp Lejeune after the Environmental Protection Agency (EPA)  designated the base as a National Priorities List site in 1989. The health  assessment recommended that studies be conducted to evaluate the risks  of childhood cancer related to VOC exposure at Camp Lejeune and noted  that adverse pregnancy outcomes were also of concern. The first study  based on the health assessment was released in 1998 and found a  statistically significant association between exposure and some adverse  pregnancy outcomes. In 1999, ATSDR initiated a second study that  currently is examining whether individuals who were exposed in utero  (i.e., as developing fetuses during gestation) and as infants up to 1 year of  age to the contaminated drinking water at Camp Lejeune between 1968  and 1985 are more likely to have developed specific childhood cancers or  birth defects than those who were not exposed. ATSDR has projected a  December 2007 completion date for the study. In addition to ATSDR’s  Camp Lejeune-related work, three inquiries into the issues related to the  past drinking water contamination have been conducted, one by a Marine  Corps-chartered panel, one by EPA’s Office of Inspector General (OIG),  and one by EPA’s Criminal Investigation Division (CID).
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. In addition, some former 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, and have said that DOD and EPA’s responses to their requests for  drinking water contamination-related documents have sometimes been  inadequate. Finally, some former residents have raised concerns about  various aspects of ATSDR’s ongoing study, including whether the study  population, time frame, and selected health effects are too limited to  adequately represent those who were potentially affected, and about  ATSDR’s projected December 2007 study completion date because the  federal government plans to wait to adjudicate their claims until the study  is complete.
The Ronald W. Reagan National Defense Authorization Act of 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,  determining the actions taken to address the contamination, and assessing  the current ATSDR health study. The act also requires that our study  consider information and opinions from individuals who lived and worked  at Camp Lejeune during the period when the drinking water may have  been contaminated. As discussed with the committees of jurisdiction, in  this report we examine the history of events related to drinking water  contamination at Camp Lejeune. Specifically, we (1) examine efforts to  identify and address the past contamination; (2) describe activities  resulting from concerns about possible adverse health effects and  government actions related to the past contamination, such as the current  ATSDR health study; and, (3) describe 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 examine efforts to identify and address the past contamination, 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 contamination 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.  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 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.
To describe activities resulting from concerns about the possible adverse  health effects and government actions related to past drinking water  contamination, including efforts to study potential health effects and  federal inquiries into the response to the contamination, we reviewed  documents, interviewed agency officials, and attended agency meetings.  To examine the activities undertaken by ATSDR to study possible adverse  health effects related to the drinking water contamination, we interviewed  ATSDR officials and reviewed ATSDR’s Camp Lejeune-related documents  and publications, including the 1997 public health assessment and the  ATSDR health study released in 1998. We did not evaluate the  methodology or findings of the health assessment or health study. We also  attended the meetings and reviewed the reports of expert review panels  convened by ATSDR in 2005 regarding improving the study’s water  modeling efforts and future studies of health effects. We attended the  February and April 2006 meetings of the ATSDR community assistance  panel which is made up of seven former residents of Camp Lejeune. We  also reviewed meeting transcripts from the July and September 2006  meetings. 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. We also interviewed  officials with the Department of the Navy Judge Advocate General and the  Department of Justice regarding the status of the legal claims related to  Camp Lejeune. To describe the three federal inquiries into issues related  to the drinking water contamination, we reviewed the reports of a Marine  Corps panel, the EPA OIG, and the EPA CID, and we interviewed EPA  officials.
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 on July 29, 2005. The expert panel  was charged with evaluating the study’s population, exposure time frame,  selected health effects, and completion date. For the assessment of the  ATSDR study, 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. Panel  members were invited as individual experts, not as organizational  representatives, and were not asked to reach consensus on any topics.  NAS was not asked to provide advice or produce any report, and the  comments made during the meeting of the expert panel should not be  interpreted to represent the views of NAS, of the organizations with which  the panel members were affiliated, or of all experts regarding health  studies related to drinking water contamination. Not all panel members  commented individually about each of the questions discussed during the  1-day meeting. Additionally, some panel 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, Marine Corps, and 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. (See app. I for further detail on our scope  and methodology.)
subsections: section_title: Background
paragraphs: 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.
subsections: section_title: General Information about Camp Lejeune and Its Water Systems
paragraphs: Camp Lejeune began operations in the 1940s. The base 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.  Base housing at Camp Lejeune consists of enlisted family housing, officer  family housing, and bachelor housing, which consists of barracks for  unmarried service personnel. The base has nine family housing areas, and  families live in base housing for an average of 2 years. 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  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.)
From the 1970s through 1987, Hadnot Point, Tarawa Terrace, Holcomb  Boulevard, and Rifle Range water systems provided drinking water to  most of Camp Lejeune’s housing areas. (See fig. 2 for the locations of these  water service areas.) The water treatment plants for the Hadnot Point and  Tarawa Terrace water systems were constructed during the 1940s and  1950s. The Rifle Range water system was constructed in 1965. 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 four systems had between 4 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. The housing area served by the Rifle  Range water system included both family housing and bachelor housing.  Based on available housing data for the late 1970s and the 1980s, the  estimated annual averages of the number of people living in family housing  units 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,    71 people in units served by the Hadnot Point water system, and    14 people in units served by the Rifle Range water system.
In addition to serving housing units, all four 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, and the Rifle Range water  system also served an area used for weapons training.
section_title: Department of the Navy Environmental Functions
paragraphs: The Department of the Navy consists of the Navy and the Marine Corps;  consequently, certain Navy entities provide support functions for Marine  Corps bases, such as Camp Lejeune. Two entities provide support for  environmental issues:    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. 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 follow- up 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.
section_title: EPA and Environmental Laws and Regulations Related to Drinking Water Contamination and Hazardous Waste Contamination at Camp Lejeune
paragraphs: EPA was established in 1970 to consolidate in one agency a variety of  federal research, monitoring, standard-setting, and enforcement activities  to ensure environmental protection. EPA’s primary roles and functions  include developing and enforcing environmental regulations; conducting  environmental research; providing financial assistance to states,  educational institutions, and other nonprofit entities that conduct  environmental research; and furthering public environmental education.
Congress passed the Safe Drinking Water Act in 1974 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 predecessors 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 which added a disinfectant as part of the drinking water  treatment process to 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. 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.)
The Comprehensive Environmental Response, Compensation, and  Liability Act (CERCLA) of 1980 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  program. CERCLA was amended by the Superfund Amendments and  Reauthorization Act (SARA) of 1986. 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. The  agreement is to specify what cleanup activities, if any, are required, and to  set priorities for carrying out those activities. SARA also established the  Defense Environmental Restoration Program, through which DOD  conducts environmental cleanup activities at military installations. 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. 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.
section_title: ATSDR’s Assessment of the Adverse Health Effects of Hazardous Substances at DOD Superfund Sites
paragraphs: 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  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.
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. 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.
section_title: Possible Adverse Health Effects of TCE and PCE
paragraphs: 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. 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. HHS has determined that PCE may reasonably be anticipated to be  a carcinogen.
section_title: Efforts to Identify and Address Past Drinking Water Contamination at Camp Lejeune Began in the 1980s and Continue with Long-Term Cleanup and Monitoring
paragraphs: 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, NACIP, a Navy environmental 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.
subsections: section_title: Navy Water Testing Beginning in 1980 Identified VOCs in Camp Lejeune Water Systems
paragraphs: 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 which 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 Navy- contracted 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.  LANTDIV officials we interviewed said they do not remember why this  testing was conducted. A memorandum written by a Camp Lejeune  environmental official noted that LANTDIV initiated the testing because  North Carolina had assumed responsibility in March 1980 for oversight of  the Safe Drinking Water Act and therefore would have the right to sample  and test the drinking water at Camp Lejeune for any contaminants  regulated under the act. The memorandum stated that LANTDIV officials  were concerned that the state’s testing might discover problems that the  Navy had not previously identified. The Camp Lejeune memorandum  characterized the 1980 analysis as indicating “no problems” from the  pollutants when the samples from eight water systems were tested as one  combined sample, but also noted that this might not have been true if the  samples had been analyzed individually. Current and former LANTDIV  officials told us that they did not recall any actions taken as a result of this  analysis.
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.  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. 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 officials 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  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.
In early 1981, additional water testing unrelated to the TTHM monitoring  began at the Rifle Range area within Camp Lejeune for various  contaminants, including TCE and PCE. A former Camp Lejeune official  recalled that the testing was initiated because of concerns about chemicals  that had been buried at Rifle Range. In March, April, and May 1981, water  samples were collected from areas surrounding the chemical dump,  including a nearby creek; treated water from the Rifle Range water system;  and untreated water from the individual wells serving the water system.  These water samples were sent to a Navy-contracted private laboratory for  analysis, and the results were sent to a LANTDIV official in April and May  1981. The results for the samples collected from the areas surrounding the  chemical dump identified VOCs, including TCE and PCE. The results for  the samples collected from the water system’s treated water and for the  samples from the untreated water from the individual wells also identified  VOCs. In July 1981, LANTDIV communicated the results to Camp Lejeune  officials and noted that one of the VOCs detected was a trihalomethane  and arrangements had been made to add the Rifle Range water system to  the base TTHM testing. LANTDIV also recommended that no further  action be taken until additional data became available from TTHM  monitoring or the planned NACIP program to identify, assess, and control  environmental contamination.
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. Documents from 1981 indicate that LANTDIV  officials continuously communicated information about the Rifle Range  area to Camp Lejeune environmental officials, including providing  sampling results, discussing the implications of these results, providing  copies of related regulations and standards, and making recommendations  for additional action. (See app. II for a more detailed description of  selected events related to drinking water contamination at Camp Lejeune  from 1980 through 1981.)
section_title: 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
paragraphs: 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 from the May and July samples as the  contaminants. 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.)
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  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 in sampling  results and about the possible sources of the TCE and PCE. Specifically,  because the levels of TCE and PCE varied, 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  PCE. Former Camp Lejeune environmental officials recalled that they did  not take any actions related to these findings. (See app. III for a more  detailed timeline of selected events from 1982 through 1983.)
section_title: Discovery of Contamination at Individual Wells in 1984 and 1985 Prompted Their Removal from Service, and Information Was Provided to Residents and the Media
paragraphs: In 1982, Navy officials initiated the NACIP program at Camp Lejeune as  part of its overall strategy to identify, assess, and control environmental  contamination at Navy and Marine Corps bases. The first step of the  NACIP program was 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 for Camp Lejeune, which was completed in April 1983, determined  that further investigation was warranted at 22 priority sites with potential  contamination, including a site near wells that served the Hadnot Point  water system.
In July 1984, the base initiated a NACIP confirmation study to investigate  the 22 priority sites. 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 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 which were  detected in the wells prior to their removal from service in 1984 and 1985.  See app. IV for the levels of other VOCs which were detected in the wells  prior to their removal from service in 1984 and 1985.
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  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. “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  1985 discussing contamination at Camp Lejeune. 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. (See app. V for a more detailed timeline of  selected documented events from 1984 through 1985.)
section_title: Past Contamination Was Estimated to Have Originated from Both On- base and Off-base Sources
paragraphs: 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.  (See table 4.) 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. 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 an off-base source was the likely cause of the drinking water  contamination. After the Marine Corps requested assistance in identifying  the source of the contamination, North Carolina state officials conducted  an investigation from April 1985 through September 1985 to determine  whether two off-base dry cleaning facilities located near the two  contaminated wells were the sources of the PCE contamination at Tarawa  Terrace. The state officials concluded that the contamination likely came  from dry cleaning solvent that had been released into a leaking septic tank  at one of the cleaners—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.
section_title: Cleanup and Monitoring Activities Are Under Way to Address the Contamination
paragraphs: 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  Cleaners—cleanup activities for the suspected sources of contamination  are being managed separately.
Following Camp Lejeune’s listing as a National Priorities List site in  October 1989 and the signing of a Federal Facilities Agreement in  February 1991, on-base cleanup activities have been managed by a  partnership of DOD, EPA, and North Carolina environmental officials.  Cleanup of the eight sites suspected to be possible sources of  contamination for the Hadnot Point water system has included the  removal of contaminated soils and gasoline storage tanks and the  treatment of contaminated groundwater and soils. The cleanup activities  at four of the eight sites were completed by 2006. The estimated  completion date for cleanup activities of contaminated groundwater and  soils at three of the other four sites is 2025. There is no estimated  completion date for the fourth site. Funding for the cleanup of the on-base  sites has come from Department of the Navy Environmental Restoration  Program funds, and Navy officials estimated that about $70 million would  be needed to complete the cleanup of all eight sites.
Efforts to clean up the suspected source of contamination that affected  the Tarawa Terrace water system began after ABC One Hour Cleaners was  listed as a National Priorities List site in 1989. Cleanup activities at the site,  which have been designed to address both the contaminated groundwater  and soil, have been managed by EPA, with support from North Carolina  officials. While treatment of some of the areas with contaminated soil has  been completed, the EPA official who serves as project manager for the  ABC One Hour Cleaners site could not provide an estimated completion  date for cleanup of either the soil or the groundwater. Funding for the  cleanup of this site comes primarily from the Superfund, though a portion  of the funds has been provided by ABC One Hour Cleaners and North  Carolina. The total estimated cost for the cleanup of this site is about   $4.3 million. According to a North Carolina official, North Carolina will  assume authority for cleanup at the site in August 2013.
Currently, Camp Lejeune uses various methods to monitor and protect the  base’s drinking water. In drinking water reports published in 2004 and  available on the Camp Lejeune Web site, base officials stated that their  efforts to monitor the drinking water supply had met or exceeded all  required testing standards. For example, Camp Lejeune reported that “in  accordance with Safe Drinking Water Act sampling requirements” it had  regularly tested its treated drinking water for more than 80 different EPA- regulated contaminants and additional unregulated contaminants. The  reports noted that testing of treated water for VOCs had been conducted  on a monthly basis—exceeding the requirement to test every 3 years—“in  order to show that there should be no concern about current VOC  contamination.” The Camp Lejeune reports stated that the base had  sampled the wells at least annually for VOCs. Additionally, the Water  Quality Program at Camp Lejeune produces annual reports about each  drinking water system on the base in order to inform water consumers  about the quality of their water. The 2004 reports also stated that Camp  Lejeune officials have undertaken numerous efforts to protect the drinking  water supply, including restricting land uses near well fields, locating  well fields in undeveloped areas, constructing wells in a manner that  minimizes the potential for contamination, and using new technologies to  prevent groundwater contamination. Examples of some of these new  technologies included a computer-based monitoring system for  underground storage tanks that immediately alerts personnel when a leak  occurs, and the installation of bullet traps at firing areas, which prevent  lead and copper bullets from contaminating the groundwater and soil.
section_title: Concerns about Possible Adverse Health Effects and Government Actions Related to the Past Contamination Have Led to Additional Activities
paragraphs: Concerns about possible adverse health effects and government actions  related to the past drinking water contamination have led to additional  activities, including health studies, claims against the federal government,  and federal inquiries. Activities resulting from concerns about possible  adverse health effects began in 1991, when ATSDR initiated a public health  assessment that evaluated the possible health risks from past exposure to  the contaminated drinking water at Camp Lejeune. The health assessment  was followed by two studies, one of which was ongoing as of April 2007.  Since ATSDR began its work, the agency did not always receive requested  funding and experienced delays in receiving information from DOD  entities. However, ATSDR officials said that the agency’s Camp Lejeune- related work was not significantly delayed by DOD. As of January 2007,  about 750 claims had been filed by former Camp Lejeune residents and  employees against the federal government for injuries alleged to have  resulted from past exposure to the contaminated drinking water at Camp  Lejeune. Additionally, three federal inquiries into issues related to the  drinking water contamination at Camp Lejeune have been conducted, one  by a Marine Corps-chartered panel, one by the EPA OIG, and one by the  EPA CID. The inquiry conducted by the Marine Corps-chartered panel  found that the Marine Corps acted responsibly and found no evidence that  the Marine Corps had attempted to cover up information that indicated  contamination in Camp Lejeune’s drinking water. However, the Marine  Corps-chartered panel also criticized some actions taken by Camp Lejeune  and Department of the Navy officials, such as inadequate communications  among these entities about the drinking water contamination. The EPA  OIG found that some EPA officials’ responses to a citizen’s requests  regarding Camp Lejeune-related documents were inadequate or  inappropriate. The EPA CID investigation did not find any violations of  federal law but criticized some actions taken by Marine Corps and  Department of the Navy officials, such as a lack of diligence by a Navy  environmental support entity in providing technical expertise to Camp  Lejeune’s environmental officials.
subsections: section_title: ATSDR Has Undertaken Several Activities to Study Possible Adverse Health Effects Related to the Drinking Water Contamination at Camp Lejeune
paragraphs: Beginning in 1991, ATSDR has undertaken several activities to study the  possible adverse health effects related to the past drinking water  contamination at Camp Lejeune, including a public health assessment and  two studies. 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. ATSDR concluded that (1) cancerous and noncancerous  health effects were unlikely in adults exposed to VOC-contaminated  drinking water, (2) the likelihood of either noncancerous or cancerous  health effects in children could not be determined because of insufficient  scientific information, and (3) there was evidence that suggested that,  because of their developing systems, individuals who were exposed in  utero were potentially more sensitive to the effects of VOCs than  individuals who were exposed as adults or children. 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. ATSDR officials said that the health assessment did not  recommend a study of adverse pregnancy outcomes because such a study  was already under way.
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 Lejeune from 1968  through 1985. 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. 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. 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 modeling 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  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.
ATSDR also has hosted two expert panel meetings related to the past  drinking water contamination at Camp Lejeune. In February 2005, ATSDR  hosted an expert scientific advisory panel to explore opportunities for  conducting additional health studies of people who were potentially  exposed to contaminated drinking water at Camp Lejeune. The agency  noted that it convened this panel in response to continuing public concern  about health effects from past exposure to contaminated drinking water.  ATSDR received nine recommendations from its scientific advisory panel  in a final report released in June 2005, which include a recommendation to  create an advisory panel to oversee future studies and a recommendation  that funding for future studies should come from appropriations to  ATSDR, not from DOD’s budget. In an August 2005 published response,  ATSDR agreed with all but three of the scientific advisory panel’s  recommendations. (See app. VI for ATSDR’s panel recommendations and  ATSDR’s response.)
ATSDR has taken steps to accomplish three of the recommended  activities. In February 2006, ATSDR created a community assistance panel  to respond to the two recommendations urging a closer partnership with  former Camp Lejeune residents and development of an advisory panel to  oversee health studies related to VOC exposures at Camp Lejeune. As of  January 2007, the community assistance panel had held four meetings. The  panel includes seven former Camp Lejeune residents. Also participating in  CAP meetings are one representative from DOD, two independent  scientific experts, and ATSDR staff. ATSDR officials said the community  assistance panel is comparable with other panels that ATSDR had set up  for community participation at National Priorities List sites similar to  Camp Lejeune. In response to a recommendation to conduct feasibility or  pilot studies before beginning full-scale health studies, ATSDR had begun  conducting a feasibility assessment to determine the availability and  sufficiency of data needed to conduct several additional health studies  related to past drinking water contamination. At the February 2006  community assistance panel meeting, the panel members and ATSDR  officials agreed that ATSDR should move forward with the initial stages of  planning a mortality study and an adult cancer incidence study of those  potentially exposed to contaminated water at Camp Lejeune so long as  necessary data are available. ATSDR officials said that they had identified  databases such as the National Death Index, which contains death  records, and state cancer registries that could be used to assist ATSDR  with conducting these studies. An ATSDR official said that mortality and  cancer incidence studies would potentially be easier to carry out than  some other health studies because of the existence of these databases.  Since the February 2006 community assistance panel meeting, ATSDR  officials have begun reviewing additional databases at the Defense  Manpower Data Center and Naval Health Research Center to determine if  those databases could be linked to both the National Death Index and  state cancer registries, and to Camp Lejeune family housing records. If  the feasibility assessment shows that these databases can be used, ATSDR  will likely proceed with the two studies, officials said. Additionally,  ATSDR officials said they plan to computerize the family housing records  at Camp Lejeune that were still in paper format. Officials noted that the  fully computerized family housing records might be used as the basis for  defining a registry of potentially affected residents, as recommended by  the scientific advisory panel, if the feasibility assessment indicates that it  is possible to obtain social security numbers and dates of birth for each  potential member of the registry.
In March 2005, ATSDR hosted a separate expert peer review panel to  evaluate the agency’s water modeling and data-gathering efforts at Camp  Lejeune. In a report published in October 2005, the expert peer review  panel on water modeling made two primary recommendations urging the  agency to make additional effort and expend more resources on more  rigorous record searches to improve the information for the historical  reconstruction of events. ATSDR agreed and had hired new staff and  consultants to begin record searches at Camp Lejeune; however, ATSDR  officials did not proceed with their record search after they learned that  the Marine Corps had separately hired a private contractor to conduct  such a search. The Marine Corps’ private contractor completed its  document search in August 2006, which yielded more than 6,000  documents. An ATSDR official told us that during a preliminary review of  the documents in July 2006, ATSDR determined that the documents were  “extremely useful” for its water modeling activities. The remaining three  recommendations of the expert peer review panel on water modeling were  technical comments related to modeling activities, such as a  recommendation to use simplified models that required less effort and  resources. ATSDR officials said that they agreed with these technical  recommendations and had subsequently used them to refine their  modeling procedures.
section_title: 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
paragraphs: 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.
subsections: section_title: Funding of ATSDR’s Camp Lejeune Work
paragraphs: 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. While ATSDR conducted the health assessment  at Camp Lejeune, from fiscal year 1991 to fiscal year 1996 funding was  provided by DOD as part of an annual payment for all ATSDR activities at  DOD sites. These annual payments were provided from Defense  Environmental Restoration Program funds. In fiscal year 1997, the  individual military services assumed responsibility for making these  payments. Therefore, for fiscal year 1997, funding for ATSDR’s Camp  Lejeune-related work came directly from the Navy (see Table 5).
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  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. 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 Lejeune- related work. We could not determine why the Navy decided to resume  funding of ATSDR’s work at that time. Beginning in 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.
section_title: Provision of Information to ATSDR by DOD
paragraphs: 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 Investigation documents for Camp Lejeune. The letter  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. 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. 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  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.
section_title: Effect on ATSDR’s Work
paragraphs: Despite difficulties, ATSDR officials said the agency’s Camp Lejeune- related 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.  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.
section_title: Some Former Residents and Employees Have Filed Claims against the Federal Government
paragraphs: Some former residents have filed tort claims and lawsuits against the  federal government related to the past drinking water contamination. As  of January 2007, about 750 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. According to an official  with the U.S. Navy Judge Advocate General (JAG)—which is handling the  claims on behalf of the Department of the Navy—the agency is currently  maintaining a database of all claims filed. The official said that JAG is  awaiting completion of the current ATSDR health study before deciding  whether to settle or deny the pending claims in order to base its response  on as much objective scientific and medical information as possible.
As of February 2007, two of these claims had resulted in the filing of  lawsuits in Federal District Courts in Texas and Mississippi. Among other  things, both lawsuits seek damages for various physical ailments and  emotional distress alleged to have resulted from the government’s  negligence in protecting the water supply at Camp Lejeune. In the first  lawsuit, a former servicemember’s son alleged that he suffered a  congenital heart defect as a result of his mother’s exposure (while  pregnant with him) as well as his subsequent direct exposure to  contaminated water at Camp Lejeune during the early 1970s. The  outcome of the lawsuit was still pending as of February 2007. In the  second lawsuit, a former servicemember and his family alleged injuries as  a result of their past exposure to TCE and PCE while living at Camp  Lejeune. The claims of the former service member and his wife were  dismissed because his alleged injuries occurred while he was on active  duty in the Marine Corps. An appeal of the claims of the former service  member and his family members remained pending in February 2007.
section_title: Several Federal Inquiries Have Examined Events Related to the Drinking Water Contamination
paragraphs: Three federal inquiries into issues related to the drinking water  contamination at Camp Lejeune have been conducted, each of which cited  concerns by former residents as one of the reasons for conducting its  inquiry. These include one by a Marine Corps-chartered panel, one by  EPA’s OIG, and one by EPA’s CID.
subsections: section_title: Marine Corps-Chartered Panel Review
paragraphs: In March 2004 the Commandant of the Marine Corps created a fact-finding  panel charged with conducting a review of the facts surrounding the  decisions made following the 1980 discovery of VOCs in drinking water at  Camp Lejeune. The panel focused its review on the 1980 to 1985 time  period. The panel released a report in October 2004 which found that the  Marine Corps acted responsibly and found no evidence that the Marine  Corps had attempted to cover up information that indicated contamination  in Camp Lejeune’s drinking water. Additionally, the panel concluded that  Camp Lejeune provided residents with drinking water at a level of quality  consistent with general utility practices at the time. However, the panel  noted that while Camp Lejeune made every effort to comply with existing  regulations, it did not anticipate or independently evaluate health risks  associated with chemicals such as TCE or PCE that were not yet  regulated, and for which there was developing concern about possible  adverse health effects. The panel noted that this “compliance-based  approach to regulations,” combined with factors including inadequate  funding, staffing, and training of Camp Lejeune’s Environmental Division,  contributed to a lack of understanding about the potential significance of  the contamination. Additionally, the panel identified other factors that  appeared to have hindered Camp Lejeune personnel from quickly  recognizing the significance of VOC contamination, including the absence  of regulatory standards, no records of resident complaints about water  quality, sampling errors, and inconsistent sampling results.
The panel also made several other findings critical of Camp Lejeune and  the Department of the Navy, noting that:    LANTDIV, as a technical advisory organization, was “not aggressive” in  providing Camp Lejeune with the technical expertise to help base officials  understand the significance of the contamination and how it could have  been addressed;   communications both internally among Camp Lejeune officials, and  between Camp Lejeune and LANTDIV, were inadequate; and   communications to Camp Lejeune residents regarding drinking water  contamination were not detailed enough to completely characterize the  contamination found at the time of the well closures.
section_title: EPA’s OIG Inquiry
paragraphs: In January 2005 EPA’s OIG completed an internal report describing a  preliminary review of five complaints reported by three citizens regarding  issues indirectly or directly related to the drinking water contamination at  Camp Lejeune. The complaints were as follows:  1.  EPA inadequately responded to a Freedom of Information Act  2.  EPA inappropriately responded to a Freedom of Information Act fee  3.  EPA did not adequately perform oversight of Camp Lejeune based on  its responsibilities listed in the Safe Drinking Water Act,  4.  EPA did not devote adequate resources to the review that was being  conducted by its Criminal Investigation Division, and  5.  the 1998 study conducted by ATSDR was inadequate.
The OIG conducted a preliminary review of these complaints to determine  whether the complaints merited a full-scale audit of EPA activities.  Regarding the first two complaints, the OIG determined that EPA’s  response to a Freedom of Information Act request for documents related  to Camp Lejeune contamination was inadequate and that its denial of an  associated fee waiver request was inappropriate and insensitive. The third  complaint was closed because the OIG concluded that EPA had little  oversight responsibility for the Safe Drinking Water Act until 1996,  significantly later than the contamination occurred at Camp Lejeune. The  OIG found no merit with the fourth complaint, noting that although only  one agent was assigned to the case, that agent had access to other agents  and resources when needed. OIG officials said the fifth complaint was  closed in part because they knew we would also be reviewing this  concern, and also because complaints regarding ATSDR’s study are not  related to any actions by EPA and are therefore outside the scope of an  EPA review. Based on this preliminary review, a full audit of EPA officials’  actions was not initiated.
section_title: EPA’s Criminal Investigation
paragraphs: A criminal investigation conducted by EPA and reviewed by the  Department of Justice (DOJ) did not find any violations of federal law, but  criticized some of the actions taken by Marine Corps and Navy officials.  From 2003 through 2005, EPA’s CID conducted an investigation of  allegations made by former residents that federal law was violated by the  individuals and entities addressing the drinking water contamination at  Camp Lejeune, including officials from the Marine Corps, Navy, and  ATSDR. With regard to the Navy and Marine Corps, the CID investigated  five principal allegations of violation of federal law:  1.  violation of the Safe Drinking Water Act,  2.  conspiracy to violate the Safe Drinking Water Act,  3.  conspiracy to conceal records and prevent persons from talking with a  federal agency conducting a congressionally mandated health study,  4.  conspiracy to conceal Freedom of Information Act records from the  5.  providing material false statements to a federal law enforcement  officer.
The CID concluded that in the absence of enforceable regulatory  standards for both TCE and PCE between 1980 and 1985, there was no  violation of the Safe Drinking Water Act at that time, and drinking water  provided by Camp Lejeune during that time appeared to have met all state  and federal regulatory requirements. A CID investigator told us that he  looked for evidence of conspiracy from the 1980s, when the events  occurred, through 2004. With regard to allegations that Marine Corps or  Navy officials conspired to violate the Safe Drinking Water Act or to  conceal records, the CID’s report noted that investigators were unable to  substantiate that a conspiracy by military or civilian employees of either  entity existed. Regarding allegations that false statements were provided  to a federal law enforcement officer, investigators noted that while they  were concerned that LANTDIV officials were not completely forthcoming  during their interviews, there was never any direct evidence that LANTDIV  officials were aware of the contamination prior to 1984.
With regard to ATSDR, the CID investigated two principal allegations  made by former residents of Camp Lejeune:  1.  destruction of a federal agency’s records, and  2.  conspiracy to improperly administer a congressionally mandated  health study.
Regarding an alleged order by an ATSDR official to destroy records related  to the Camp Lejeune health study, CID investigators found that the records  in question were never destroyed. Concerning allegations that ATSDR  failed to properly address the drinking water contamination at Camp  Lejeune because of influence from the Navy, the CID found no evidence  that ATSDR’s scientific work was influenced by regular meetings between  ATSDR and Navy officials.
Although the CID found no evidence that federal law had been violated,  because of the unique history and complexity of the case and an  evaluation of statements from persons they interviewed, investigators  noted that the case warranted a review by DOJ. Additionally, several of the  allegations from the public had also been forwarded by DOJ to the CID for  investigation. Following the CID’s referral of this case to DOJ for its  review, DOJ discussed its findings at an August 2005 meeting with former  residents and officials from the Navy and Marine Corps. DOJ concluded  that it would not seek criminal prosecution, saying that the government’s  investigation had concluded that no federal criminal law was broken nor  was there an attempt to conceal evidence regarding a violation of any law.
In addition to investigating whether federal law had been violated, the CID  also investigated additional questions that were relevant to the case but  were determined not to be violations of federal law. The CID noted that  some of these matters appeared to have contributed to confusion,  suspicion, and concern by retired Marines. Additionally, the CID  commented on and criticized certain actions taken by Navy and Marine  Corps officials. For example:    The CID concluded that as a technical advisory agency to Camp Lejeune,  LANTDIV was not diligent in providing technical expertise to the base’s  environmental officials and noted that LANTDIV officials appeared to have  been better suited by virtue of their training and expertise to recognize  and address VOC contamination and the possible effects on public health  than the environmental officials at Camp Lejeune.
The CID commented that former Camp Lejeune environmental officials  failed to properly investigate the contamination and determine the  contamination was coming from individual wells. Until 1984, the Camp  Lejeune environmental officials never sampled individual water wells and  the CID noted that this was arguably their most significant lapse in  judgment.
Because of questions raised by Congress and former residents, the CID  also investigated the provision of DOD funding for ATSDR’s work. The  CID 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, and that coupled with this opposition  was confusion within the Navy hierarchy regarding what entity was  responsible for the contaminated wells.
Regarding the provision of records and data to ATSDR by the Marine  Corps, the CID found no instances when data or records were  intentionally withheld or false data were provided by Marine Corps  officials to ATSDR. The CID noted the Marine Corps appeared not to have  recognized the complexity and degree of attention this issue required in  1997 and that prior to 1997, the Marine Corps admitted that it failed to  adequately address concerns and data requests from the public and  ATSDR.
section_title: Experts Convened by NAS Generally Agreed That Many Parameters of ATSDR’s Current Study Were Appropriate but Some Experts Suggested Potential Modifications to the Study
paragraphs: The seven members of an expert panel convened by the National Academy  of Sciences (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. Some panel experts suggested modifying the study to use  a simpler method of analysis, with alternative ways to define exposure  categories, in order to complete the study sooner. Some panel experts also  identified other potential modifications to the study, such as conducting  separate analyses for those who were born on the base and those born off  the base. (See app. VII for a more detailed description of ATSDR’s study.)
subsections: section_title: Experts Agreed That Study Population of Individuals Who Were Potentially Exposed in Utero Was Appropriate and Studying Children and Adults Could Also Be Reasonable
paragraphs: 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. 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. Thus, pregnant  women who lived in areas of base housing with contaminated water and  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.
While supporting the decision to limit the study population to individuals  who were in utero, the panel experts did not discount the possibility that  children and adults who lived or worked on base may also be at risk for  adverse health effects because of their potential exposure to contaminated  drinking water. For example, four panel experts pointed out that exposed  children and adults might have an elevated risk for neurological effects,  and one of the four experts said exposed adults might have an elevated  risk for certain cancers. Similarly, the ATSDR scientific advisory panel  convened in February 2005 identified at least four groups of individuals at  Camp Lejeune who might be at higher risk for adverse health effects  because they could have been exposed to the contaminated drinking  water. In addition to individuals who were in utero, these groups included  children who lived on base, adults who lived on base, and adults who lived  off base but worked on base, because they too spent time at Camp Lejeune  and were potentially exposed to the contaminated drinking water.
section_title: Experts Agreed That the Study Time Frame of 1968 through 1985 Was Reasonable, but Could Be Extended Beyond 1985
paragraphs: 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 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.
Six of the panel experts said that extending the time frame past 1985 could  help strengthen ATSDR’s study by adding an additional unexposed  population for comparison. Having an additional comparison population  could help researchers reinforce any conclusions about whether TCE or  PCE are associated with adverse health outcomes, panel experts said. For  example, if the study found some association between adverse health  outcomes and the pre-1985 exposed population, but no association with an  additional unexposed comparison group, it would support any finding that  TCE or PCE exposure was associated with adverse health outcomes, since  the exposure ended in 1985. Two of the expert panel members said that if  adverse health effects continued to be found in a comparison population  after 1985, that finding could mean that exposure to the contaminated  drinking water was not associated with the adverse health effects.  However, one of the six experts also noted that extending the study time  frame would be cost effective only if a significant association between  TCE or PCE exposure and adverse health outcomes was first found among  those exposed before 1985.
section_title: Experts Said Health Effects Selected for the Study Were Valid, Though Other Neurological and Behavioral Health Effects May Also Occur
paragraphs: 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. 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. Two panel experts said that  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.
Four panel experts added that other adverse health outcomes not included  in the study could also be related to exposure to drinking water  contaminated with TCE or PCE, including adverse neurological or  behavioral effects, or pregnancy loss. However, three of these four panel  experts said that studying adverse neurological or behavioral health  effects would likely be difficult because of limited access to needed  records, such as school records for children, or because there might be  few databases for researchers to use to study these effects in adults.
section_title: Experts Had Mixed Opinions on ATSDR’s Projected Completion Date and Some Said a Simpler Analysis Could Provide Earlier Results
paragraphs: 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.
While none of the panel experts said that ATSDR’s projected completion  date should be earlier, several said that one way to provide analytical  results sooner would be to conduct the study without using the water  modeling analysis. Three of the experts explained that water modeling  would be useful if it improved the classification of the study participants  as either exposed or unexposed to contaminated water or provided more  accurate estimates of individual exposure levels, as ATSDR intends.  ATSDR officials said that a precise and accurate exposure assessment  would enhance the scientific credibility of a study and strengthen the  study’s ability to identify any important exposure effects. But all of the  panel experts raised concerns about the limited historical record of the  amount of PCE or TCE concentration identified at individual Camp  Lejeune wells. They said that with limited historical data there would be  minimal potential for water modeling to provide accurate information  about the level of concentration of the contamination and thus about each  individual’s total amount of exposure. As an alternative to estimating the  extent of each study individual’s exposure using the water modeling  results, four panel experts suggested ATSDR could use simpler categories  of whether and to what extent individuals were exposed to water  contamination. These four experts said that analyzing the data on birth  defects and childhood cancers by using the same exposure categories that  were used in the 1998 ATSDR study could yield an effective study sooner  than December 2007. The current ATSDR study expects to use more  categories of exposure than were used in the 1998 study, based on data  from its water modeling activities and from information gathered on the  mothers’ usage and consumption of the contaminated water.
section_title: Experts Identified Additional Potential Modifications to the ATSDR Study
paragraphs: Panel experts identified several other possibilities for modifying the design  of the ATSDR study. Four panel experts suggested conducting separate  analyses for study individuals born in the county where Camp Lejeune is  located, and for individuals who were born outside the county but whose  mothers were pregnant with them while living in base housing. Word of  mouth among current and former residents and media campaigns were the  primary methods used to identify and recruit those individuals born  outside the county as study participants. According to three panel experts,  the methods used to identify these study participants raise the possibility  of selection bias for that group. Specifically, the experts suggested that  eligible study individuals born out of county, or their parents, who had  concerns about potential exposure to TCE or PCE or about existing health  problems may have been more likely to sign up for the study than those  who did not have these concerns. Selection bias could result in a mistaken  estimate of an exposure’s effect on the risk of disease.
As another potential study modification, two panel experts suggested  conducting separate analyses for those with childhood leukemias and non- Hodgkin’s lymphoma, which they said ATSDR had inappropriately  combined into one category of hematopoietic cancers. ATSDR study  investigators had combined these health outcomes into one category  following advice from the ATSDR scientific advisory panel at its meeting  in February 2005. Before the February meeting, ATSDR study investigators  had dropped plans to separately analyze childhood non-Hodgkin’s  lymphoma because they were unable to confirm a large enough number of  individuals with this type of cancer to further study this health outcome.
section_title: Agency Comments
paragraphs: DOD, EPA, and HHS provided technical comments on a draft of this  report, which we incorporated where appropriate. We provided the seven  former Camp Lejeune residents who are members of the ATSDR  community assistance panel for Camp Lejeune the opportunity to provide  comments on our draft—three of the panel members provided technical  and general oral comments, and four declined to review the draft report.
Two of the panel members said that the report should address  contaminants other than TCE and PCE with potential adverse health  effects, such as benzene, that were identified at Camp Lejeune. Our report  focused on TCE and PCE because ATSDR’s health studies have focused on  these chemicals and their associated health effects and ATSDR has  identified TCE and PCE as the chemicals of primary concern at Camp  Lejeune. However, in response to technical comments from ATSDR and  the panel members’ comments, we have added the sampling results for all  other VOCs detected in wells that were taken out of service at Camp  Lejeune during 1984 and 1985. Additionally, the three members expressed  the belief that the Marine Corps had not fully disclosed information related  to the past drinking water contamination and two of the members  expressed disappointment that our report was not more critical of the  Marine Corps. We believe that we have accurately described efforts to  identify and address the past contamination and described activities  resulting from concerns about possible adverse health effects and  government actions related to the past contamination. Finally, the three  members raised various other issues, such as compensation and health  benefits for former residents and their families and the need for additional  notification to be provided to former residents regarding the past drinking  water contamination; however, these issues were beyond the scope of this  report.
We are sending copies of this report to the Secretary of Defense, the  Administrator of EPA, the Secretary of Health and Human Services,  appropriate congressional committees, and other interested parties. We  will also make copies available to others upon request. In addition, the  report is available at no charge on the GAO Web site at  http://www.gao.gov. If you or your staff have questions about this report,  please contact me at (202) 512-7119. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. GAO staff who made major contributions are listed in  appendix VIII.
section_title: Appendix I: Scope and Methodology
paragraphs: To examine efforts to identify and address the past drinking water  contamination at Camp Lejeune, we obtained and reviewed more than  1,600 documents related to past and current drinking water activities at  Camp Lejeune. We focused our review on the past trichloroethylene (TCE)  and tetrachloroethylene (PCE) contamination at Camp Lejeune because  the Agency for Toxic Substances and Disease Registry (ATSDR) had noted  that these chemicals were the VOCs of primary concern. However, we also  reviewed documentation regarding other volatile organic compounds  (VOCs) detected at Camp Lejeune. The documents we reviewed were  obtained from Headquarters Marine Corps and had been collected and  organized by a contractor for the Commandant of the Marine Corps’  Drinking Water Fact-Finding Panel for Camp Lejeune. Documents related  to past and current drinking water activities were also obtained during a  visit to Camp Lejeune. The authors of the documents we collected  included officials with Camp Lejeune, Headquarters Marine Corps, the  Department of the Navy, other federal agencies such as the Environmental  Protection Agency (EPA), the state of North Carolina, and private  laboratories. The types of documents that were collected included results  of laboratory analyses of drinking water samples, e-mails, memorandums,  letters, reports, site maps, federal and state regulations, press releases,  and newspaper articles.
Additionally, we reviewed a list of more than 6,000 historical documents  collected by a contractor hired by Headquarters Marine Corps; this list was  compiled by the contractor and included detailed descriptions and dates  of the historical documents. We requested and reviewed more than 100  documents from this list that we thought might be relevant to the past  drinking water contamination.
We interviewed 39 current and former officials from various Department  of Defense (DOD) entities, including Camp Lejeune, Headquarters Marine  Corps, and the Department of the Navy, who were involved in activities  related to or knowledgeable about historical environmental activities at  Camp Lejeune. 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. The current and former officials interviewed often provided  information based on their memory of events which occurred more than  20 years ago. We attempted to corroborate their testimonial evidence with  documentation whenever possible. 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. 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. We also  interviewed current Camp Lejeune housing officials in order to obtain  estimated historical occupancy rates, including the limitations of the  occupancy data that were provided. Additionally, we examined reports  from and interviewed current officials from Camp Lejeune, EPA, and the  North Carolina Department of Environment and Natural Resources who  were involved with or knowledgeable about past and current activities and  costs related to the cleanup of the suspected sources of contamination.  Finally, we obtained and analyzed information from ATSDR and EPA on  drinking water contaminated with TCE and PCE, the possible adverse  health effects related to exposure to these chemicals, and relevant federal  regulations for TCE and PCE.
To describe activities resulting from concerns about the possible adverse  health effects and government actions related to past drinking water  contamination, including efforts to study potential health effects and  federal inquiries into the response to the contamination, we reviewed  documents, interviewed agency officials, and attended agency meetings.  To examine the activities undertaken by ATSDR to study potential health  effects related to the drinking water contamination at Camp Lejeune, we  reviewed the agency’s 1997 Public Health Assessment that evaluated the  risks of adverse health effects from exposure to the contaminated drinking  water, as well as released documents regarding ATSDR’s 1998 health study  of the association between exposure to TCE and PCE in drinking water at  Camp Lejeune and a variety of adverse pregnancy outcomes. We did not  evaluate the methodology or findings of the public health assessment or  health study. For ATSDR’s current study, we examined the study protocol,  a progress report, and other documents describing ATSDR’s current study  examining whether birth defects and childhood cancers are associated  with exposure to TCE or PCE at Camp Lejeune. We interviewed ATSDR  officials involved with the Public Health Assessment, the 1998 study, and  the current study, and also attended ATSDR expert panel meetings  convened to evaluate and provide recommendations regarding the  agency’s work related to Camp Lejeune. In order to examine the sources  of and issues surrounding funding for ATSDR’s Camp Lejeune-related  work, we obtained documents from and interviewed officials with ATSDR,  the Department of the Navy, and the U.S. Army Center for Health  Promotion and Preventive Medicine, which currently executes the  memorandum of understanding between DOD and ATSDR and negotiates  an annual plan of work with ATSDR. We examined documentation and  interviewed DOD, ATSDR, and EPA officials about efforts to address the  concerns of the former Camp Lejeune residents. To examine the  recommendations of additional review panels convened by ATSDR in 2005  regarding improving the study’s water modeling efforts and future studies  of health effects, we attended two panel meetings and obtained and  reviewed the final reports of both panels, which included ATSDR’s  response to the panels’ recommendations. To determine the actions taken  by ATSDR to address the panel recommendations, we interviewed  relevant ATSDR officials and observed and subsequently reviewed  transcripts of meetings of the Camp Lejeune community assistance panel  held in 2006, where ATSDR officials reported on their activities. In order  to describe the lawsuits and tort claims filed against the federal  government for injuries alleged to have resulted from exposure to the  contaminated drinking water at Camp Lejeune, we interviewed officials  with the Department of the Navy’s Judge Advocate General and the  Department of Justice. To describe three federal inquiries into issues  related to the drinking water contamination at Camp Lejeune, we reviewed  the reports and statements of the Drinking Water Fact-Finding Panel for  Camp Lejeune, the EPA Office of Inspector General, the EPA Criminal  Investigation Division, and the Department of Justice. We also interviewed  officials from the EPA Office of Inspector General and the EPA Criminal  Investigation Division about their examinations of allegations made by  former residents. We did not evaluate the methodology used by the  officials who conducted these three inquiries.
When the source of evidence we cited is from an interview, we identified  the respondent’s agency and noted whether the individual was a current or  former official. Whenever possible, we reviewed documents to verify  testimonial evidence from DOD and ATSDR officials. When this was not  possible, we attempted to corroborate testimonial evidence by  interviewing multiple individuals about the information we obtained.
To assess the design of the current study by ATSDR on the possible health  effects associated with the contaminated drinking water at Camp Lejeune,  including the study population, time frame, health effects, and completion  date, we contracted with the National Academy of Sciences (NAS) to  convene a 1-day meeting of scientific experts in the areas of drinking  water contamination, hydrologic modeling, and reproductive health. We  identified for NAS the categories of expertise preferred at the meeting and  expressed a preference that each participant have no conflict of interest  with ATSDR, DOD, or EPA. NAS identified participants according to the  preferred categories. Once we concurred with the proposed participants,  NAS contacted the potential participants to determine interest and  availability to participate in the meeting. In total, seven experts and one  moderator participated in the meeting. The experts and the moderator had  combined research expertise in environmental engineering; reproductive,  environmental, and occupational epidemiology; statistics and modeling;  public health investigations, risk assessment, and decision analysis;  geochemistry; and water and wastewater treatment and water modeling.  We observed the meeting, which took place in July 2005, and subsequently  reviewed the written transcript of the meeting. The experts’ discussion  during the meeting was guided by a set of questions we prepared regarding  the ATSDR study population, time frame, health effects, and completion  date. Participants were invited as individual experts, not as organizational  representatives, and were not asked to reach consensus on any topics.  NAS was not asked to provide advice or produce any report, and the  comments made during the meeting of the expert panel should not be  interpreted to represent the views of NAS or of all experts regarding  health studies related to drinking water contamination. As we requested,  each of the experts also provided written responses to the set of questions  that were discussed during the meeting. During the meeting and in their  written responses, not all panel members commented individually about  each of the questions discussed during the 1-day meeting. Additionally,  some panel members noted that certain questions addressed subjects that  were outside their areas of expertise. In addition to convening and  attending the expert panel meeting, we also reviewed ATSDR documents  related to the current study, including the study protocol and progress  reports, and interviewed ATSDR officials involved in the study’s  epidemiologic and water modeling activities.
We conducted our work from May 2005 through April 2007 in accordance  with generally accepted government auditing standards.
section_title: Appendix II: Selected Events Related to Past Drinking Water Contamination at Camp Lejeune from 1980 through 1981
paragraphs: Appendix II: Selected Events Related to Past  Drinking Water Contamination at Camp  Lejeune from 1980 through 1981 An official with the Naval Facilities Engineering Command, Atlantic Division (LANTDIV),  collected samples from all eight water systems at Camp Lejeune to be combined into a single  sample and analyzed in order to detect any potential contaminants in the water systems.
At the direction of LANTDIV, Camp Lejeune collected separate samples to be analyzed for total  trihalomethanes (TTHMs) at two base water systems, Hadnot Point and New River. LANTDIV  arranged for the U.S. Army Environmental Hygiene Agency (USAEHA) laboratory to conduct  the testing.
A LANTDIV-contracted private laboratory reported results from the samples collected on  October 1, 1980, from all eight water systems at Camp Lejeune. The results, sent to LANTDIV,  indicated that 11 volatile organic compounds (VOCs) were detected, including trichloroethylene  (TCE). All VOCs detected in this analysis were identified at their detection limits, which were  the lowest level at which the chemicals could be reliably identified by the instruments being  used.
A report from USAEHA of the results of the analysis of samples collected on October 21, 1980,  contained a USAEHA official’s handwritten notes which indicated unidentified chlorinated  hydrocarbons were interfering with the testing for TTHMs at the Hadnot Point water system.
Handwritten notes from a USAEHA official on a USAEHA report indicated that continued  interference with the TTHM analysis of samples collected on December 29, 1980, for the  Hadnot Point water system, and recommended conducting analyses for chlorinated organics.
Handwritten notes from a USAEHA official on a USAEHA report indicated continued  interference with the TTHM analysis of samples collected on January 30, 1980, for the Hadnot  Point water system, and recommended conducting analyses for chlorinated organics.
Handwritten notes from a USAEHA official on a USAEHA report indicated that water samples  collected on March 9, 1981, for analysis for TTHMs at the Hadnot Point water system were  “highly contaminated” with other chlorinated hydrocarbons.
According to the private laboratory report sent to LANTDIV, an analysis of water samples  collected on March 30, 1981, from areas surrounding the Camp Lejeune Rifle Range chemical  dump detected VOCs. However, TCE and tetrachloroethylene (PCE) were not among the  VOCs detected in these samples.
According to the private laboratory report sent to LANTDIV, an analysis of water samples  collected on April 10, 1981, was conducted from the untreated water in the wells that served the  Rifle Range water system, from treated water from the Rifle Range water system, and from  areas surrounding the Rifle Range chemical dump. VOCs, including TCE and PCE, were  detected in water samples from the areas surrounding the chemical dump. VOCs, including  TCE, were also detected in the well samples. TCE was detected at 1.8 parts per billion in one  of the well samples.
The Commander of LANTDIV wrote a memorandum to the Commanding General of Camp  Lejeune that recommended resampling the Rifle Range area because of variation in the results  from the April 7 and April 16 analysis reports. LANTDIV noted that three contaminants were  detected in the treated and untreated water in the Rifle Range water system. Two of these  contaminants, methylene chloride and TCE, were not regulated and the third chemical, a  TTHM, was detected at levels within the new regulatory standards. The LANTDIV official noted  that no imminent threat to human health was presented by consumption of water from the Rifle  Range water system.
According to the private laboratory report sent to LANTDIV, an analysis of water samples  collected on May 20, 1981, from treated water in the Rifle Range water system and from areas  surrounding the Rifle Range chemical dump detected VOCs in the treated water at the Rifle  Range water system and also detected VOCs, including TCE, in areas surrounding the Rifle  Range chemical dump.
The Commander of LANTDIV wrote a memorandum to the Commanding General of Camp  Lejeune that described the analyses of the additional water samples taken from the Rifle Range  area. The official noted that of the organic contaminants detected at the Rifle Range area, only  one, a TTHM, had an established regulation with a maximum contaminant level though it did  not apply to the Rifle Range water system because this system did not serve more than 10,000  people. The official noted that LANTDIV would add the Rifle Range water system to the TTHM  testing that had been initiated in 1980. Additionally, he suggested no further action be taken  until the Navy Assessment and Control of Installation Pollutants program and TTHM analysis  provided additional data. According to a handwritten note at the end of the memorandum, an  environmental official at Camp Lejeune recommended arranging a meeting with the state in  order to share these results.
The Commander of LANTDIV wrote a memorandum to the Commanding General of Camp  Lejeune noting that in accordance with Camp Lejeune’s request, it was providing the summary  of TTHM regulations and copies of the TTHM testing reports for the two water systems that met  the requirement to be tested.   0 to  identify, assess, and control environmental contamination from past hazardous materials storage,  transfer, processing, and disposal operations.
section_title: Appendix III: Selected Events Related to Past Drinking Water Contamination at Camp Lejeune from 1982 through 1983
subsections: section_title: Camp Lejeune environmental officials began collecting monthly samples for monitoring of total trihalomethanes (TTHMs) at all eight base water systems.
paragraphs: A private laboratory contracted by Camp Lejeune to conduct the TTHM analysis informed Camp  Lejeune by telephone that synthetic organic cleaning solvents, including trichloroethylene (TCE),  were detected in the samples that were collected from April 19 to April 22, 1982, from the Tarawa  Terrace and Hadnot Point water systems. Grainger Laboratory stated that TCE interference with the  analysis of the Hadnot Point samples prevented the detection of a precise reading for TTHMs.
Camp Lejeune environmental officials took a second set of monthly water samples at the base water  systems because of problems with the collection of earlier samples taken from May 17 through   May 24, 1982.
The private laboratory report of the results of the analysis of monthly samples collected May 27 and  May 28, 1982, noted that an unknown compound was interfering with the testing for TTHMs at the  Hadnot Point water system.
The private laboratory report of the results of the analysis of monthly samples collected June 24 and  June 25, 1982, did not specifically note interference with the testing for TTHMs at the Hadnot Point  water system, but, as in previous reports, noted that there was some uncertainty in the  measurements for this water system.
Camp Lejeune environmental officials collected samples, which were in addition to the monthly  samples, from the Hadnot Point and Tarawa Terrace water systems. An internal Camp Lejeune  memorandum noted that the additional sampling was conducted because the private laboratory  identified interference by TCE and another synthetic organic cleaning solvent while analyzing earlier  samples from the Hadnot Point and Tarawa Terrace water systems for TTHMs.
The private laboratory sent a letter to Camp Lejeune officials stating that the contaminants interfering  with the TTHM monitoring at the Tarawa Terrace and Hadnot Point water systems were TCE and  tetrachloroethylene (PCE). The laboratory noted that these chemicals appeared to be at high levels  and were thus more important from a health standpoint than the TTHM levels. The laboratory further  noted that the levels of PCE detected in the Tarawa Terrace water system had been relatively stable  over the time period examined, while levels of TCE and PCE detected in the Hadnot Point water  system had varied, and the most recent Hadnot Point readings had been at significantly lower levels  than the levels detected in May.
Camp Lejeune officials decided to reduce monitoring for TTHMs from monthly to quarterly for six of  the eight water systems, including Tarawa Terrace and Hadnot Point, beginning in September 1982.  Officials noted in a memorandum that federal and state regulations required only quarterly sampling.
A Camp Lejeune environmental official sent a memorandum to her supervisor that discussed the  TTHM sampling and interference at the Tarawa Terrace and Hadnot Point water systems. She  explained that the additional samples had been collected on July 28, 1982, to identify the source of  the interference in the earlier TTHM testing; TCE and PCE were identified as the interfering  chemicals. The official detailed the possible adverse health effects from both TCE and PCE, but  further explained that TCE and PCE were not regulated under the Safe Drinking Water Act. However,  she noted that the EPA had issued “suggested no adverse response levels” and “suggested action  guidance,” which provided some guidance on unregulated contaminants. The official explained that  levels of TCE and PCE detected in the Hadnot Point water system were presently within the limits  suggested by the suggested no adverse response levels, but she offered no explanation for the  higher level detected in samples taken in May 1982 and analyzed in July 1982. She also noted that it  was possible that the levels of PCE detected in the Tarawa Terrace water system were the result of  the use of asbestos-coated pipe in the water lines carrying untreated water.
The private laboratory report of the results of the analysis of samples collected in November from all  eight water systems for quarterly TTHM testing was provided to Camp Lejeune officials. This report  stated that all samples from Tarawa Terrace indicated contamination from PCE and all samples from  Hadnot Point indicated contamination from TCE and PCE.
An environmental official at Camp Lejeune wrote a memorandum to her supervisor about the TTHM  analysis from November 1982. She noted that during a telephone conversation with a chemist at the  private laboratory, the chemist had expressed concerns over the solvents that interfered with the  Tarawa Terrace and Hadnot Point samples, particularly those from Hadnot Point. According to the  memorandum, the chemist told the Camp Lejeune official that while the levels of TCE and PCE had  dropped for a period of time, the November samples showed levels of TCE and PCE that were  relatively high again.
The private laboratory report of the results of the analysis of samples collected on August 25 and  August 26, 1983, from all eight water systems for TTHM testing was provided to Camp Lejeune  officials. The report stated that all samples from Tarawa Terrace exhibited contamination from PCE  and all samples from Hadnot Point exhibited contamination from both TCE and PCE.   uired that water  systems serving more than 10,000 people and adding a disinfectant as part of the drinking water  treatment process to begin mandatory water testing for TTHMs by November 192 and comply with  the maximum contaminant level by November 193. Only two water systems at Camp Lejeune,  Hadnot Point and New River, served more than 10,000 people when TTHM testing was initiated at  Camp Lejeune.  0.
section_title: Appendix IV: Selected Volatile Organic Compounds Detected in Wells at Hadnot Point and Tarawa Terrace Water Systems
paragraphs: Concentrations of chemicals in parts per billion  602  Nov. 30, 1984  601  Dec. 6, 1984  608  Dec. 6, 1984  634  Dec. 14, 1984  637  Dec. 14, 1984  4  and 195 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.  uid 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.  uid 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. 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.  uid 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.
Well TT-23 is also referred to as “TT-new well” in Marine Corps documents.
section_title: Appendix V: Selected Events Related to Past Drinking Water Contamination at Camp Lejeune from 1984 through 1985
paragraphs: Appendix V: Selected Events Related to Past  Drinking Water Contamination at Camp  Lejeune from 1984 through 1985 Camp Lejeune initiated the Navy Assessment and Control of Installation Pollutants  (NACIP) confirmation study. The purpose of the confirmation study was to further  investigate potential contamination at 22 priority sites at Camp Lejeune that were  identified in an initial assessment study. As part of the confirmation study, sampling began  at any well in the vicinity of a priority site where groundwater contamination was  suspected. Prior water samples at Camp Lejeune had usually been drawn at the water  treatment plants or in the distribution system—not from individual wells.
Camp Lejeune officials received results from the confirmation study sampling which  detected trichloroethylene (TCE) and tetrachloroethylene (PCE), among other volatile  organic compounds (VOC), at a well serving the Hadnot Point water system, one of eight  water systems at Camp Lejeune. This well was removed from service.
Water samples were collected from six Hadnot Point wells and from the untreated and  treated water at the Hadnot Point water treatment plant. These wells were sampled  because of their proximity to the contaminated well that was removed from service on  November 30, 1984.
Camp Lejeune officials received results of the analysis of samples collected on   December 4, 1984, that indicated three additional wells and the untreated and treated  water from the Hadnot Point water system had levels of TCE and PCE, among other  VOCs. In one of the wells, TCE was detected at 210 parts per billion (ppb) and PCE was  detected at 5 ppb. In the second well, TCE was detected at 110 ppb. In the third well, TCE  was detected at 4.6 ppb. The first two wells were removed from service.
A Camp Lejeune official contacted a North Carolina state environmental official by  telephone to discuss suspected contamination found in wells, untreated water, and  treated water from the Hadnot Point water system. The Camp Lejeune official explained  Camp Lejeune anticipated that a resampling program would be initiated, and indicated  that some form of information might be released to the public.
Samples were again collected from the same seven Hadnot Point wells and the treated  water at the Hadnot Point water treatment plant.
Separately, daily samples were collected from the untreated water at the Hadnot Point  water treatment plant.
The base newspaper published its first article about water testing, VOC contamination,  and corrective actions taken by base officials, including removing wells from service. The  article did not identify TCE or PCE as the VOC contaminants.
Camp Lejeune officials received results of the analysis of samples collected on   December 10, 1984, that indicated two additional wells in the Hadnot Point water system  had significant levels of a VOC, methylene chloride, while a third well also indicated  levels of methylene chloride. TCE and PCE were not detected in these wells. Two of  these three wells were removed from service.
Camp Lejeune officials received the results of the analysis of samples that were collected  from December 13 to December 19, 1984, at the Hadnot Point water treatment plant. TCE  and PCE were not detected in these samples.
The director of the NACIP program at Camp Lejeune received a report reviewing the  December 1984 sampling of wells, untreated water, and treated water at the Hadnot Point  water system. In the report, sampling of all the wells and the water treatment plants at  Camp Lejeune was proposed.
Samples were collected at all wells serving the Hadnot Point and Holcomb Boulevard  water systems to be tested for VOCs.
Samples were collected at all wells serving four other water systems, including Tarawa  Terrace, to be tested for VOCs.
A fuel line from Holcomb Boulevard water treatment plant leaked fuel into the water  system. The Holcomb Boulevard water treatment plant was subsequently shut down and  water from the Hadnot Point water system was pumped into the Holcomb Boulevard water  lines.
Samples were collected at various locations within the Hadnot Point and Holcomb  Boulevard water systems for analysis required by North Carolina prior to restarting the  Holcomb Boulevard water treatment plant.
Camp Lejeune officials received results of the analysis of the samples collected on  January 16, 1985, that indicated one additional well in the Hadnot Point water system had  significant levels of TCE and PCE, among other VOCs. TCE was detected at 3,200 ppb  and PCE was detected at 386 ppb. This well was removed from service.
The results also noted that trace amounts of TCE were detected in two other Hadnot Point  wells. In one well, TCE was detected at 9 ppb and in the other well TCE was detected at  5.5 ppb.
Camp Lejeune officials received results of the analysis of the samples collected on  January 31, 1985, from various locations within the Hadnot Point and Holcomb Boulevard  water systems. No gasoline was detected in samples from Holcomb Boulevard. However,  various levels of TCE were detected in all of the samples; TCE was detected at levels  ranging from 24 ppb to 1,148 ppb.
The Holcomb Boulevard water treatment plant was restarted.
Camp Lejeune officials received results of the analysis of the samples collected on  January 23, 1985, that indicated that two wells in the Tarawa Terrace water system had  levels of TCE and PCE. In one well, TCE was detected at 57 ppb and PCE was detected  at 158 ppb. In the other well, TCE was detected at 5.8 ppb and PCE was detected at 132  ppb.
The two wells in the Tarawa Terrace water system that were found to be contaminated  with TCE and PCE on February 7, 1985, were removed from service. Additionally, the two  wells in the Hadnot Point water system that were found to be contaminated with trace  levels of TCE and PCE on February 4, 1985, were removed from service.
According to an internal Camp Lejeune memorandum, one of the wells removed from  service on February 8, 1985, was restarted on March 11, 1985, after samples were taken.  After 24 hours of operation, additional samples were taken and the well was removed  from service.
The Commanding General of Camp Lejeune issued a notice to the residents of Tarawa  Terrace housing area regarding problems with the water supply. According to the notice,  two of the wells that supplied water to the Tarawa Terrace water system were taken off  line because “minute (trace)” amounts of several organic chemicals were detected in the  water. The notice stated that there were no regulations regarding safe levels of the  organic chemicals found in these wells, but as a precaution the Commanding General had  ordered the wells to be removed from service in all but emergency situations. Additionally,  the notice provided ways for residents to reduce water usage because of concerns that a  water shortage might result following the removal of these wells from service.
An article was published in the base newspaper explaining that 10 wells that served the  Tarawa Terrace and Hadnot Point water systems were removed from service because of  contamination. The article also noted the potential for water shortages in the Tarawa  Terrace water system and included information about how to conserve water.
An article was published in a North Carolina newspaper providing similar information as  that included in the May 9, 1985, base newspaper article regarding the contamination in  the Tarawa Terrace and Hadnot Point water systems.
An article was published in a second North Carolina newspaper providing similar  information as that included in the May 9, 1985, base newspaper article regarding the  contamination in the Tarawa Terrace and Hadnot Point water systems.
Camp Lejeune officials sent a memorandum to Headquarters Marine Corps and LANTDIV  noting that all 10 contaminated wells remained out of service, although 1 of the  contaminated wells at Tarawa Terrace had been used on April 22, 23, and 29 to maintain  water production.
An article was published in a third North Carolina newspaper that provided similar  information as that included in the May 9, 1985, base newspaper article regarding the  contamination in the Tarawa Terrace and Hadnot Point water systems.
section_title: Appendix VI: Agency for Toxic Substances and Disease Registry’s Response to its 2005 Scientific Advisory Panel’s Recommendations
subsections: section_title: Scientific advisory panel’s recommendations regarding future health studies of past drinking water contamination at Camp Lejeune
paragraphs: Agency for Toxic Substances and Disease Registry’s  (ATSDR) response  1. Create an advisory panel to oversee health studies related to  Volatile Organic Chemical (VOC) exposures at Camp Lejeune.
Agreed. ATSDR will create a community assistance panel (CAP)  comparable to other panels it has set up for community  participation at National Priorities List sites. ATSDR  recommended that its Camp Lejeune CAP be comprised of five  or more community members and one or two scientific advisers,  along with ex officio members from the Navy.
Agreed. ATSDR said it considered interaction with the community  an important aspect of its on-site work and planned to continue to  work closely with organized community advocacy groups. It  agreed to be responsive to recommendations from the CAP.
3. Establish a registry to identify groups of potentially exposed  individuals to study, including exposed and unexposed  individuals who had lived and/or worked at Camp Lejeune  during the period of interest, which would serve as the  population base for further studies.
Agreed. In order to identify various distinct groups of individuals  with potential exposure, ATSDR said that efforts or activities  should be conducted to determine if potential databases exist that  would identify these groups, such as children who lived on base  and adults who lived or worked on base. However, the agency  said that it believed that it had already identified as completely as  possible those who may have been exposed while in utero for the  years 1968-1985.
4. Conduct various types of feasibility or pilot studies—to  determine whether study individuals can be identified and  tracked and what types of medical records are available— before embarking on full-scale studies of the impact on health   of exposures at Camp Lejeune.
Agreed. ATSDR will conduct a feasibility assessment to  determine the number of adults and children that could be  identified through available data sources.
5. Study additional health outcomes, such as mortality and cancer  incidence. Also, conduct feasibility studies of other adverse  health outcomes, such as autoimmune diseases; spontaneous  abortion; neurological effects; organ failure; adult heart disease;  reproductive outcomes of male and female children who were  born (or were in utero) at Camp Lejeune; birth defects beyond  those considered by ATSDR; and ocular problems.
Agreed. ATSDR agreed that mortality and cancer incidence  should receive the highest priority and are the outcomes most  feasible to study. The agency said that decisions concerning  study period, study population, and study outcomes should be  made in consultation with the CAP, and said that ATSDR would  defer decisions about additional health studies until feasibility  studies were completed and reviewed by the CAP.
6. Conduct future research activities in parallel with the current  study and without awaiting completion of current ATSDR  activities.
Agreed. The agency said that its highest priority is to complete  the current study. Development of a CAP and further research  activities would likely require additional staffing and resources,  which ATSDR said it would request from the Department of  Defense (DOD).
7. Amend the 1997 public health assessment to include the  possibility that adult cancers and other adverse health  outcomes may be related to VOC exposures. Additionally,   in the period since release of the original public health  assessment, much additional information on exposures at  Camp Lejeune and their potential risks has been developed,  and this additional material should be incorporated into an  amended document.
Did not agree. ATSDR said revisions to the assessment would be  needed only if new information changed the assessment’s  conclusions or recommendations. ATSDR noted that its  assessment acknowledged that the science was inconclusive and  did not rule out the possibility of cancerous health effects from  low-dose exposure to VOCs.
Did not respond directly. ATSDR indicated that it would work with  the CAP to determine effective ways to disseminate information  about its current study and any future health studies.
Agency for Toxic Substances and Disease Registry’s  (ATSDR) response  9. Obtain future funding for Camp Lejeune health studies through  direct congressional appropriation, not through DOD’s budget,  to avoid even the appearance of a conflict of interest.
Did not agree. ATSDR said it recognized that the affected  community had some distrust of ATSDR and DOD, and said that  the CAP was intended to help mitigate this distrust. However,  ATSDR suggested that DOD is the most likely funding source for  these research activities because no other funds are available  outside those budgeted to complete the current study.
section_title: Appendix VII: Description of Current Agency for Toxic Substances and Disease Registry (ATSDR) Health Study
paragraphs: ATSDR is conducting a study of the potential health effects of exposure  while in utero and as infants up to 1 year of age to trichloroethylene (TCE)  and tetrachloroethylene (PCE)—two volatile organic chemicals found in  drinking water at Marine Corps Base Camp Lejeune in the 1980s. ATSDR’s  study will analyze whether exposure to the TCE or PCE-contaminated  drinking water at Camp Lejeune before birth is associated with increased  risks of specific birth defects or childhood cancers. These birth defects  include (1) neural tube defects, (2) oral cleft defects, and (3) childhood  leukemias and non-Hodgkin’s lymphoma, which have been combined into  one category of hematopoietic cancers.
ATSDR’s efforts to conduct this study began in 1999 with a telephone  survey conducted with parents of 12,598 individuals born to women who  were pregnant with them while living in on-base housing at Camp Lejeune  any time from 1968 through 1985. Parents were asked if their child had a  birth defect or developed a childhood cancer, along with other questions  such as those to confirm residency on base during the specific time period  and questions regarding water usage. A total of 106 potential cases of the  childhood cancers or birth defects were reported by the interviewed  parents. ATSDR reviewed health records in order to verify the reported  health problems and had confirmed 57 cases of the childhood cancers or  birth defects as of June 2006. (See table 6.) The study population includes  the 57 individuals with confirmed health problems and 548 comparison  individuals chosen randomly from among the remaining individuals  identified in the survey.
As part of this study, ATSDR officials are also conducting computer  modeling of the drinking water system at Camp Lejeune from 1968 through  1985 in order to determine which pregnant women were probably exposed  to the contaminated drinking water and to estimate their levels of  exposure. ATSDR’s drinking water distribution system model is based on  current and historical information for the base water system as well as  historical information on the sources of the contamination. The results of  the model are intended to establish whether the mothers of the individuals  with the birth defects or childhood cancers were more likely to have been  exposed during their pregnancy to the drinking water contaminants than  were the mothers of the comparison individuals. ATSDR officials said they  did not expect to finalize exposure categories for the current study until  February or March 2007, after most water modeling activities were  completed, but noted that they would use the water modeling results to  assign multiple exposure levels to each study participant. Additionally,  data gathered from the survey about the mothers’ drinking water and other  home water use activities, such as dishwashing, clothes washing, and  bathing, will be combined with the estimated exposures levels to create  another exposure measure. ATSDR officials also said the current study  will analyze results for individuals who were exposed to TCE separately  from those exposed to PCE and will analyze cancer and each type of birth  defect separately. The study is expected to be completed by December  2007.
section_title: Appendix VIII: GAO Contact and Staff Acknowledgments
subsections: section_title: Acknowledgments
paragraphs: In addition to the contact named above, Bonnie Anderson, Assistant  Director; Karen Doran, Assistant Director; George Bogart; Helen  Desaulniers; Cathleen Hamann; Danielle Organek; Roseanne Price;  Christina Ritchie; and Stuart Ryba made key contributions to this report.