Defense Health Care: Activities Related to Past Drinking Water	 
Contamination at Marine Corps Base Camp Lejeune (11-MAY-07,	 
GAO-07-276).							 
                                                                 
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.	 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-07-276 					        
    ACCNO:   A69492						        
  TITLE:     Defense Health Care: Activities Related to Past Drinking 
Water Contamination at Marine Corps Base Camp Lejeune		 
     DATE:   05/11/2007 
  SUBJECT:   Birth defects					 
	     Cancer						 
	     Cancer research					 
	     Chemical agents					 
	     Chemical exposure					 
	     Chemicals						 
	     Contaminants					 
	     Contamination					 
	     Environmental monitoring				 
	     Health hazards					 
	     Investigations by federal agencies 		 
	     Naval bases					 
	     Potable water					 
	     Public health					 
	     Volatile organic compounds 			 
	     Water pollution					 
	     Water pollution control				 
	     Camp Lejeune (NC)					 
	     EPA National Priorities List			 

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GAO-07-276

   

     * [1]Results in Brief
     * [2]Background

          * [3]General Information about Camp Lejeune and Its Water Systems
          * [4]Department of the Navy Environmental Functions
          * [5]EPA and Environmental Laws and Regulations Related to Drinki
          * [6]ATSDR's Assessment of the Adverse Health Effects of Hazardou
          * [7]Possible Adverse Health Effects of TCE and PCE

     * [8]Efforts to Identify and Address Past Drinking Water Contamin

          * [9]Navy Water Testing Beginning in 1980 Identified VOCs in Camp
          * [10]Further Tests Identified TCE and PCE in Two Camp Lejeune Wat
          * [11]Discovery of Contamination at Individual Wells in 1984 and 1
          * [12]Past Contamination Was Estimated to Have Originated from Bot
          * [13]Cleanup and Monitoring Activities Are Under Way to Address t

     * [14]Concerns about Possible Adverse Health Effects and Governmen

          * [15]ATSDR Has Undertaken Several Activities to Study Possible Ad
          * [16]Although ATSDR Did Not Always Receive Requested Funding and

               * [17]Funding of ATSDR's Camp Lejeune Work
               * [18]Provision of Information to ATSDR by DOD
               * [19]Effect on ATSDR's Work

          * [20]Some Former Residents and Employees Have Filed Claims agains
          * [21]Several Federal Inquiries Have Examined Events Related to th

               * [22]Marine Corps-Chartered Panel Review
               * [23]EPA's OIG Inquiry
               * [24]EPA's Criminal Investigation

     * [25]Experts Convened by NAS Generally Agreed That Many Parameter

          * [26]Experts Agreed That Study Population of Individuals Who Were
          * [27]Experts Agreed That the Study Time Frame of 1968 through 198
          * [28]Experts Said Health Effects Selected for the Study Were Vali
          * [29]Experts Had Mixed Opinions on ATSDR's Projected Completion D
          * [30]Experts Identified Additional Potential Modifications to the

     * [31]Agency Comments
     * [32]Appendix I: Scope and Methodology
     * [33]Appendix II: Selected Events Related to Past Drinking Water
     * [34]Appendix III: Selected Events Related to Past Drinking Water
     * [35]Appendix IV: Selected Volatile Organic Compounds Detected in
     * [36]Appendix V: Selected Events Related to Past Drinking Water C
     * [37]Appendix VI: Agency for Toxic Substances and Disease Registr
     * [38]Appendix VII: Description of Current Agency for Toxic Substa
     * [39]Appendix VIII: GAO Contact and Staff Acknowledgments

          * [40]GAO Contact
          * [41]Acknowledgments

               * [42]Order by Mail or Phone

Report to Congressional Committees

United States Government Accountability Office

GAO

May 2007

DEFENSE HEALTH CARE

Activities Related to Past Drinking Water Contamination at Marine Corps
Base Camp Lejeune

GAO-07-276

Contents

Letter 1

Results in Brief 6
Background 9
Efforts to Identify and Address Past Drinking Water Contamination at Camp
Lejeune Began in the 1980s and Continue with Long-Term Cleanup and
Monitoring 20
Concerns about Possible Adverse Health Effects and Government Actions
Related to the Past Contamination Have Led to Additional Activities 34
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 51
Agency Comments 56
Appendix I Scope and Methodology 58
Appendix II Selected Events Related to Past Drinking Water Contamination
at Camp Lejeune from 1980 through 1981 62
Appendix III Selected Events Related to Past Drinking Water Contamination
at Camp Lejeune from 1982 through 1983 64
Appendix IV Selected Volatile Organic Compounds Detected in Wells at
Hadnot Point and Tarawa Terrace Water Systems 66
Appendix V Selected Events Related to Past Drinking Water Contamination at
Camp Lejeune from 1984 through 1985 68
Appendix VI Agency for Toxic Substances and Disease Registry's Response to
its 2005 Scientific Advisory Panel's Recommendations 71
Appendix VII Description of Current Agency for Toxic Substances and
Disease Registry (ATSDR) Health Study 73
Appendix VIII GAO Contact and Staff Acknowledgments 75

Tables

Table 1: EPA Guidance and Regulations for Trichloroethylene (TCE) and
Tetrachloroethylene (PCE) in Drinking Water 17
Table 2: Sampling Results from Hadnot Point and Tarawa Terrace Water
Systems for May 1982 and July 1982 24
Table 3: Dates Wells Were Removed from Service in 1984 and 1985 at Hadnot
Point and Tarawa Terrace Water Systems, and TCE and PCE Levels Detected in
Each Well 28
Table 4: Information about Potential Sites of Contamination for the Hadnot
Point Water System 31
Table 5: Funding of ATSDR Activities at Camp Lejeune from Fiscal Years
1991 through 2006 40
Table 6: Potential and Confirmed Cases of Childhood Cancers and Birth
Defects as of April 2006 74

Figures

Figure 1: Conceptual Model of a Camp Lejeune Water System 11
Figure 2: Selected Water Service Areas at Camp Lejeune Serving Base
Housing from the 1970s through 1987 12

Abbreviations

1, 1-DCE 1,1-dichloroethylene
ATSDR Agency for Toxic Substances and Disease Registry
CERCLA Comprehensive Environmental Response, Compensation, and Liability
  Act
CID Criminal Investigation Division
DERP Defense Environmental Restoration Program
DOD Department of Defense
DOJ Department of Justice
EPA Environmental Protection Agency
HHS Department of Health and Human Services
JAG Judge Advocate General
LANTDIV Naval Facilities Engineering Command, Atlantic Division
NACIP Navy Assessment and Control of Installation Pollutants
NAS National Academy of Sciences
NEHC Navy Environmental Health Center
OIG Office of Inspector General
PCE tetrachloroethylene
SARA Superfund Amendments and Reauthorization Act
TCE trichloroethylene
Trans-1,2-DCE trans-1,2-dichloroethylene
TTHMs total trihalomethanes
USAEHA U.S. Army Environmental Hygiene Agency
VOC volatile organic compound

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United States Government Accountability Office

Washington, DC 20548

May 11, 2007

The Honorable Carl Levin
Chairman
The Honorable John McCain
Ranking Member
Committee on Armed Services
United States Senate

The Honorable Daniel Inouye
Chairman
The Honorable Ted Stevens
Ranking Member
Subcommittee on Defense
Committee on Appropriations
United States Senate

The Honorable Ike Skelton
Chairman
The Honorable Duncan Hunter
Ranking Member Committee on Armed Services
House of Representatives

The Honorable John P. Murtha
Chairman
The Honorable C. W. Bill Young
Ranking Member
Subcommittee on Defense
Committee on Appropriations
House of Representatives

In the early 1980s, Department of the Navy water testing at Marine Corps
Base Camp Lejeune identified contamination in water systems that served
housing areas on the base.1 Further water testing revealed that some of
the individual wells serving two of the water systems were contaminated
with volatile organic compounds (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.2
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.3 Exposure to high levels of
both TCE and PCE may cause dizziness, headaches, nausea, unconsciousness,
cancer, and possibly death.4

1Water testing was conducted at Camp Lejeune in preparation for meeting
future drinking water regulations and to address concerns about chemicals
that had been buried on base.

As required by federal law,5 ATSDR conducted a public health assessment at
Camp Lejeune after the Environmental Protection Agency (EPA) designated
the base as a National Priorities List6 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.7 The first study based on
the health assessment was released in 19988 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).

2VOCs had initially been detected in two other wells. Additional test
results did not detect VOCs and these wells were not removed from service.

3According to ATSDR, health effects from exposure to low levels of PCE are
unknown.

4ATSDR did not define "low levels" or "high levels" of TCE or PCE.

5Superfund Amendments and Reauthorization Act of 1986, Pub. L. No. 99-499,
S110, 100 stat. 1613, 1642 (codified at 42 U.S.C. S 9604(i).

6The National Priorities List is a list of seriously contaminated
hazardous waste sites that have been identified by EPA's Superfund
Program. Under the Superfund Program, EPA may compel parties responsible
for contaminated sites to clean them up or reimburse EPA for its cleanup
costs. Camp Lejeune was designated as a National Priorities List site due
to environmental contamination at various areas on the base.

7Agency for Toxic Substances and Disease Registry, Public Health
Assessment U.S. Marine Corps Camp Lejeune Onslow County, North Carolina
(Atlanta, Ga: 1997).

8U.S. Department of Health and Human Services, Agency for Toxic Substances
and Disease Registry, Volatile Organic Compounds in Drinking Water and
Adverse Pregnancy Outcomes (Atlanta, Ga: 1998).

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,9 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.10 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.

9DOD is required by law to provide funding and data as necessary for ATSDR
to carry out certain health-related activities, including public health
assessments.

To examine efforts to identify and address the past contamination,11 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.

10Pub. L. No. 108-375, S 317, 118 Stat. 1811, 1844.

11Throughout this report we use the term "contamination," which is also
used by the law requiring us to do this work, as well as by EPA and DOD,
to describe the drinking water at Camp Lejeune in the early 1980s.
However, EPA had not yet established maximum contaminant levels for the
chemicals TCE and PCE during this period. See 40 C.F.R. SS 141.2 and
141.12 (1975-1985).

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.)

Results in Brief

Efforts to identify and address past drinking water contamination at Camp
Lejeune began in the 1980s, when the Navy initiated water testing, and are
continuing with long-term cleanup and monitoring. In 1980, VOCs, including
TCE, were first detected at Camp Lejeune during an analysis by a
Navy-contracted laboratory that combined treated water from all base water
systems. During the same year, the Navy began monitoring Camp Lejeune's
treated water for total trihalomethanes (TTHMs), contaminants that are a
byproduct of the water treatment process. The TTHM monitoring indicated
interference from unidentified chemicals. In 1982 and 1983, continued TTHM
monitoring identified TCE and another VOC, PCE, as contaminants in two
separate water systems that served base housing areas, Hadnot Point and
Tarawa Terrace. Sampling results indicated that the levels of TCE and PCE
found in the water systems varied. Former Camp Lejeune environmental
officials said that they did not take additional steps to address the
contamination after TCE and PCE were identified. The former officials
recalled that they did not act because at that time they had little
knowledge about TCE and PCE, there were no drinking water regulations that
gave enforceable limits for these chemicals, and variation in water
testing results raised questions about the tests' validity. Also in 1982,
a Navy environmental program began investigating potentially contaminated
sites at many Marine Corps and Navy bases, including Camp Lejeune. Testing
initiated under that program in 1984 and 1985 found that individual wells
in the Hadnot Point and Tarawa Terrace water systems were contaminated
with TCE, PCE, and other VOCs. Camp Lejeune officials removed 10
contaminated wells from service in 1984 and 1985. Camp Lejeune officials
determined that several areas on base where hazardous waste and other
materials were disposed may have been the sources of contamination for the
Hadnot Point water system, and North Carolina environmental officials
determined that an off-base dry cleaner was the likely source of
contamination for the Tarawa Terrace water system. Efforts are ongoing by
ATSDR to determine when contamination at Hadnot Point began. In 2006,
ATSDR estimated that well contamination from the off-base dry cleaner
began as early as 1957. In 1989, EPA placed both Camp Lejeune and the
off-base dry cleaner on the National Priorities List. Since that time,
federal, state, and Camp Lejeune officials have partnered to take
long-term actions to clean up the sources of contamination and to monitor
and protect the base's drinking water. Cleanup activities have included
the removal of contaminated soils and gasoline storage tanks and the
treatment of contaminated groundwater and soils.

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. From 1991 to 1997, ATSDR conducted a
public health assessment at Camp Lejeune. The assessment recommended that
studies be carried out to evaluate the risks of childhood cancer related
to exposure to the contaminated drinking water. In 1998, an ATSDR study
found a statistically significant association between exposure to the
contaminated drinking water at Camp Lejeune and some adverse pregnancy
outcomes, such as small for gestational age.12 In 1999, ATSDR began its
current study to determine whether individuals who were exposed in utero
and as infants up to 1 year of age to the contaminated drinking water at
Camp Lejeune between 1968 and 1985 were more likely to have developed
specific birth defects or childhood cancers. Since ATSDR began its Camp
Lejeune-related work in 1991, the agency has not always received requested
funding and experienced delays in receiving information from DOD. For
example, for 3 of the 16 fiscal years during which ATSDR has conducted its
Camp Lejeune-related work (fiscal years 1998 through 2000), no funding was
provided to ATSDR by the Navy or any DOD entity. However, ATSDR officials
said that these funding and information issues had not significantly
delayed ATSDR's work at Camp Lejeune. Former Camp Lejeune residents and
employees have filed about 750 tort claims against the federal government
for injuries alleged to have resulted from exposure to the contaminated
drinking water. Additionally, three federal inquiries into issues related
to the drinking water contamination at Camp Lejeune have been
conducted--one in 2004 by a Marine Corps-chartered panel, one in 2005 by
the EPA OIG, and one from 2003 through 2005 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.

12Small for gestational age means that a fetus or an infant is smaller in
size than is expected for the baby's gender, race and ethnicity, and
length of time from conception until the baby is delivered.

The experts convened by the National Academy of Sciences generally agreed
that many parameters of ATSDR's current study are appropriate, but some
experts suggested potential modifications to the study. Regarding the
study population, all seven panel experts agreed that ATSDR's study
population of individuals who were potentially exposed in utero to the
contaminated drinking water at Camp Lejeune between 1968 and 1985 was
appropriate, as this population was arguably the most vulnerable to the
effects of the contamination. Panel experts generally agreed that the
1968-1985 study time frame was reasonable, based on limitations in data
availability for the years prior to 1968. However, six of the panel
experts said that extending the time frame after 1985 to include a
comparison population of individuals who were not exposed to the
contamination could help strengthen the ATSDR study. Regarding the health
effects studied, the five panel experts who discussed health effects said
that the selected birth defects and childhood cancers were relevant. Four
panel experts said that additional adverse health outcomes not included in
the study could also be related to this exposure, including adverse
neurological or behavioral effects and pregnancy loss. Regarding the
proposed completion date, the panel experts had mixed opinions: three of
the five panel experts who commented said that the projected December 2007
date appeared reasonable, while two said that the date might be
optimistic. Four panel experts said that if ATSDR modified its study to
use a simpler method of analysis, it could expedite completion of the
study. Panel experts identified some potential modifications to the design
of the current ATSDR study, such as conducting separate analyses for
individuals who were born on base and for those who were born off base.

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 both technical and general oral comments,
and four declined to review the draft report. The three panel members
commented generally on issues such as VOCs other than TCE and PCE that
have been detected at Camp Lejeune, compensation and health benefits for
former residents, and additional notification for former residents. We
incorporated the panel members' technical comments where appropriate, but
some issues they discussed were beyond the scope of this report.

Background

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.

General Information about Camp Lejeune and Its Water Systems

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.)

Figure 1: Conceptual Model of a Camp Lejeune Water System

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

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.

Figure 2: Selected Water Service Areas at Camp Lejeune Serving Base
Housing from the 1970s through 1987

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,13 the estimated
annual averages of the number of people living in family housing units14
served by these water systems at that time were:

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

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

           o 71 people in units served by the Hadnot Point water system, and

           o 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.
		   
		   Department of the Navy Environmental Functions

           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:

           o 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.15 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.
           o 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.
		   
13To determine the estimated annual average of people who lived in family
housing units served by these four water systems, we used limited housing
data from 1977 to 1989 provided to us by Camp Lejeune officials. Camp
Lejeune officials could not provide housing data prior to 1977.

14Camp Lejeune housing officials could not provide occupancy rates for
bachelor housing.

15LANTDIV also manages the planning, design, construction, contingency
engineering, real estate, and public work support at Navy and Marine Corps
facilities in the United States.

           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.
		   
		   EPA and Environmental Laws and Regulations Related to Drinking
		   Water Contamination and Hazardous Waste Contamination at Camp
		   Lejeune

           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.
		   
16Pub. L. No. 93-523, 88 Stat. 1660 (codified, as amended, at
42 U.S.C. SS 300f et seq.).
		   
           Congress passed the Safe Drinking Water Act in 197416 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
           predecessors17 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.

17In the 1980s the North Carolina Department of Human Resources
administered the Safe Drinking Water Act and the Department of Natural
Resources and Community Development was responsible for other
environmental functions in the state of North Carolina. In 1989, sections
of these departments underwent a reorganization and name change, becoming
the Department of Environment, Health, and Natural Resources. In 1997, the
department was again reorganized and took on its current name, the
Department of Environment and Natural Resources.

           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.18 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.
		   
18Neither issuance was published in The Federal Register.

           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.)

Table 1: EPA Guidance and Regulations for Trichloroethylene (TCE) and
Tetrachloroethylene (PCE) in Drinking Water

                                                                  Enforceable 
                          Nonenforceable guidance                  regulation 
                                                                      Maximum 
                                                                  contaminant 
                                                                     level in 
                                                                   milligrams 
                                                                    per liter 
               Suggested no adverse                                (mg/l) and 
               response levela for                                       ppbc 
             various exposure periods      Suggested action         effective 
            in parts per billion (ppb)   guidanceb for various        in 1989 
             issued in 1979 (TCE) and   exposure periods in ppb     (TCE) and 
                    1980 (PCE)           issued in 1980 (PCE)      1992 (PCE) 
Chemical  1-Dayd 10-Daye Long-termf 1-Dayd 10-Daye Long-termf              
TCE        2,000     200         75   N/Ag    N/Ag       N/Ag   0.005 mg/l 
                                                                     or 5 ppb 
PCE        2,300     175         20  2,300     180         40   0.005 mg/l 
                                                                     or 5 ppb 

Source: GAO analysis of EPA data.

aSuggested no adverse response levels are EPA-issued nonenforceable
guidance for community water systems regarding TCE and PCE in drinking
water.

bSuggested action guidance is EPA-issued nonenforceable guidance
suggesting that remedial action be taken when PCE exceeded specific
levels.

cThese are the maximum permissible levels of a contaminant in water that
is delivered to a public water system. Maximum contaminant levels are not
specific to period of exposure. The maximum contaminant level for TCE
became effective in 1989. See 52. Fed. Reg. 25716 (July 8, 1987). The
maximum contaminant level for PCE became effective in 1992. See 52. Fed.
Reg. 3593 (January 30, 1991). The maximum contaminant levels were issued
in milligrams per liter. EPA also reports these contaminant levels in the
equivalent ppb.

dOne-day suggested no adverse response levels and suggested action
guidance were the maximum levels for one 24-hour period of exposure.

eTen-day suggested no adverse response levels and suggested action
guidance were the maximum levels each day for 10 days of exposure.

fLong-term suggested no adverse response levels and suggested action
guidance were the maximum levels each day for long-term exposure.
Long-term exposure was based on a 70-year exposure.

gThere was no suggested action guidance for TCE.

The Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) of 198019 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.20 CERCLA was amended
by the Superfund Amendments and Reauthorization Act (SARA) of 1986.21
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.22 The agreement is to specify what cleanup
activities, if any, are required, and to set priorities for carrying out
those activities.23 SARA also established the Defense Environmental
Restoration Program, through which DOD conducts environmental cleanup
activities at military installations.24 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.25 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.

19Pub. L. No. 96-510, 94 Stat. 2767 (codified, as amended, at 42 U.S.C. SS
9601 et seq.).

20At privately owned sites, EPA can require that responsible parties
either perform the cleanup themselves, or reimburse EPA for the costs of
Superfund-funded cleanups. Federal agencies generally must pay for
cleanups and other Superfund activities from their own appropriations.

ATSDR's Assessment of the Adverse Health Effects of Hazardous Substances at DOD
Superfund Sites

ATSDR was created by CERCLA and established within the Public Health
Service of HHS in April 1983 to carry out Superfund's health-related
activities. These activities include conducting health studies, laboratory
projects, and chemical testing to determine relationships between exposure
to toxic substances and illness. In 1986, SARA expanded 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.26

21Pub. L. No. 99-499, 100 Stat. 1613 (1986) (codified, as amended, at
various sections of titles 10, 26, 29, and 42 U.S.C.).

22To determine which sites are eligible for listing on the National
Priorities List, EPA uses the Hazard Ranking System, a numerical scoring
system that assesses the hazards a site poses to human health and the
environment as its principal determining fact. Once EPA has determined
that the risks posed by a site make it eligible for the National
Priorities List, EPA regions then consider many other factors in selecting
the sites to submit to EPA headquarters for proposal to the National
Priorities List.

23See 42 U.S.C. S 9620(e).

24See 10 U.S.C. SS 2701-2709.

25See 10 U.S.C. S 2701(a)(2).

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.27 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.

Possible Adverse Health Effects of TCE and PCE

According to ATSDR's Toxicological Profile, inhaling small amounts of TCE
may cause headaches, lung irritation, poor coordination, and difficulty
concentrating, and inhaling or drinking liquids containing high levels of
TCE may cause nervous system effects, liver and lung damage, abnormal
heartbeat, coma, or possibly death.28 ATSDR also notes that some animal
studies suggest that high levels of TCE may cause liver, kidney, or lung
cancer, and some studies of people exposed over long periods to high
levels of TCE in drinking water or workplace air have shown an increased
risk of cancer. ATSDR's Toxicological Profile notes that the National
Toxicology Program has determined that TCE is reasonably anticipated to be
a human carcinogen and the International Agency for Research on Cancer has
determined that TCE is probably carcinogenic to humans. Unlike TCE, the
health effects of inhaling or drinking liquids containing low levels of
PCE are unknown, according to ATSDR. However, ATSDR reports that exposure
to very high concentrations of PCE may cause dizziness, headaches,
sleepiness, confusion, nausea, difficulty in speaking and walking,
unconsciousness, or death.29 HHS has determined that PCE may reasonably be
anticipated to be a carcinogen.

26See 42 U.S.C. S 9607(a)(4)(D).

27See 10 U.S.C. S 2704(c).

28ATSDR did not define "small amounts" or "high levels" of TCE. According
to ATSDR's Toxicological Profiles, when exposure to TCE or PCE occurs many
factors determine whether an individual will be harmed. These factors
include the amount of exposure, duration of exposure, and how an
individual came in contact with these chemicals (i.e., ingestion,
inhalation, or contact with the skin).

Efforts to Identify and Address Past Drinking Water Contamination at Camp
Lejeune Began in the 1980s and Continue with Long-Term Cleanup and Monitoring

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.

Navy Water Testing Beginning in 1980 Identified VOCs in Camp Lejeune Water
Systems

The presence of VOCs in Camp Lejeune water systems was first detected in
October 1980. On October 1, 1980, samples of water were collected from all
eight water systems at Camp Lejeune by an official from LANTDIV, a Navy
entity 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.30
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.31 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.

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

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.32 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.33
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.

30Additionally, two metals--cadmium and selenium--were identified at
levels slightly above detection limits.

31This memorandum was prepared after Camp Lejeune officials received these
testing results in 1982.

32According to an August 1980 memorandum, which cited a 1979 amendment to
the National Interim Primary Drinking Water Regulations, LANTDIV initiated
monitoring programs at various naval facilities, including Camp Lejeune,
in order to develop a TTHM database prior to the effective dates for the
enforcement of the maximum contaminant levels. For Camp Lejeune community
water systems such as Hadnot Point and New River that served 10,000 to
74,999 individuals, the maximum contaminant levels for TTHMs took effect
in November 1983 and an EPA requirement to begin monitoring TTHM levels in
the systems began 1 year prior to that date. See 44 Fed. Reg. 68641 (Nov.
29, 1979) (to be codified at 40 C.F.R. S 141.6).

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 officials34 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.

33The results from the other four samples did not note the presence of
unidentified chemicals.

34In the early 1980s the environmental staff at Camp Lejeune consisted of
three primary staff members: a director specializing in natural resources,
a supervisory ecologist, and a chemist. These staff members were
responsible for water monitoring and compliance with environmental
regulations, among other responsibilities. Over time as environmental laws
have changed, the environmental staff has grown and obtained additional
responsibilities.

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.)

Further Tests Identified TCE and PCE in Two Camp Lejeune Water Systems in 1982
and 1983; Camp Lejeune Officials Do Not Recall Taking Action to Address the
Contamination at That Time

Following LANTDIV's recommendation to expand TTHM monitoring to all base
water systems, Camp Lejeune officials contracted with a private
state-certified laboratory to test samples of treated water from all eight
of their water systems. According to an August 1982 memorandum, in May
1982 a Camp Lejeune official was informed during a telephone conversation
with a private laboratory official that organic cleaning solvents,
including TCE, were present in the water samples for TTHM monitoring from
the Hadnot Point and Tarawa Terrace water systems. In July 1982,
additional water samples from the two systems were collected in an effort
to investigate the presence of these chemicals. In August 1982 the
contracted laboratory sent a letter to base officials informing them that
TCE and PCE were identified 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.)

Table 2: Sampling Results from Hadnot Point and Tarawa Terrace Water
Systems for May 1982 and July 1982

                           Concentrations of chemicals in parts per billiona
Housing area   Samplesb                       TCEc                   PCEd 
May samplese                                                              
Hadnot Point          1                      1,400                     15 
Tarawa Terrace        2                        --f                     80 
July samples   
Hadnot Point          3                         19                        
                         4                         21                        
                         5                   No datag                    1.0 
Tarawa Terrace        6                        --f                     76 
                         7                        --f                     82 
                         8                        --f                    104 

Source: GAO analysis of Headquarters Marine Corps data.

aThe August 1982 letter from the contracted laboratory in which these
sampling results were provided did not include the detection limit. The
detection limit is the lowest level at which the chemicals could be
reliably identified by the instruments being used.

bCamp Lejeune's samples were identified by nonconsecutive numbers. We
renumbered the samples to provide consecutive number identifiers.

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

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

eThe May samples were analyzed in July.

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

gA memorandum by a Camp Lejeune environmental official indicated that this
sample was analyzed for TCE, but exact quantities were not determined.

Former Camp Lejeune environmental officials recalled that after the
private laboratory identified the TCE and PCE in the two water systems,
they did not take additional steps to address the contamination for three
reasons. First, they had limited knowledge of these chemicals; second,
there were no regulations establishing enforceable limits for these
chemicals in drinking water; and third, they made assumptions about why
the levels of TCE and PCE varied and about the possible sources of the TCE
and PCE. The former Camp Lejeune environmental officials told us that they
were aware of EPA guidance, referred to as "suggested no adverse response
levels," for TCE and PCE when these contaminants were identified at Camp
Lejeune. However, they noted that the levels of these contaminants
detected at Camp Lejeune generally were below those 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.35 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.)

Discovery of Contamination at Individual Wells in 1984 and 1985 Prompted Their
Removal from Service, and Information Was Provided to Residents and the Media

In 1982, Navy officials initiated the NACIP program at Camp Lejeune as
part of its overall strategy to identify, assess, and control
environmental contamination at Navy and Marine Corps bases.36 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.37 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.

35The reports of the November 1982 and August 1983 TTHM analyses did not
provide further details about the levels of TCE and PCE detected.

36The NACIP program at Camp Lejeune was unrelated to the prior water
testing that identified TCE and PCE contamination.

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,
1985.38 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.

37During the water testing conducted at the Rifle Range area, samples were
also collected from the individual wells serving the Rifle Range water
system.

38Although 1981 sampling results from a well that served the Rifle Range
water system indicated the presence of VOCs, including TCE, the subsequent
1985 sampling results of Rifle Range wells performed under NACIP showed no
detectable levels of VOCs.

Table 3: Dates Wells Were Removed from Service in 1984 and 1985 at Hadnot
Point and Tarawa Terrace Water Systems, and TCE and PCE Levels Detected in
Each Well

                                            Concentrations of chemicals in
                                                  parts per billiona
                         Date removed from                            
Water systems   Wells service                         TCEb           PCEc
Hadnot Point      602 Nov. 30, 1984                  1,600             24
                     601 Dec. 6, 1984                     210              5
                     608 Dec. 6, 1984                     110             ND
                    634d Dec. 14, 1984                     ND             ND
                    637d Dec. 14, 1984                     ND             ND
                     651 Feb. 4, 1985                   3,200            386
                     652 Feb. 8, 1985                       9             ND
                     653 Feb. 8, 1985                     5.5             ND
Tarawa Terrace  TT-26 Feb. 8, 1985                      57          1,580
                  TT-23e Feb. 8, 1985                              ND     132

Source: GAO analysis of Headquarters Marine Corps data.

Notes: The detection limit for the instruments used to analyze the samples
was 10 parts per billion. The detection limit is the lowest level at which
the chemicals could be reliably identified by the instruments being used.
A Marine Corps document providing the sampling results stated that ND
meant "none detected."

aThe concentrations provided are those detected prior to each well's
removal from service and are one-time sampling results. We did not find
documentation that tied the decision to remove the wells from service to
any particular level of contamination included in related EPA guidance or
enforceable regulation. DOD sampling also detected other VOCs. (See app.
IV).

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

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

dTCE and PCE were not detected in this well prior to its removal from
service. Documents indicate that this well was taken out of service after
detection of "significant levels" of methylene chloride, a VOC used in
various industrial processes such as paint stripping, paint remover
manufacturing, and metal cleaning and degreasing.

eTarawa Terrace well TT-23 is also referred to as "TT-new well" in Marine
Corps documents.

In addition, while base officials were waiting for sampling results from
January 1985 of samples collected from wells serving Hadnot Point, water
from this system was provided to a third water system for about 2 weeks.
In late January 1985, a fuel line break caused gasoline to leak into the
Holcomb Boulevard water treatment plant. During the approximately 2-week
period the treatment plant was shut down, water from the Hadnot Point
system was pumped into the Holcomb Boulevard water lines. Former Camp
Lejeune environmental officials said that they used water from the Hadnot
Point water system because it was the only water system interconnected
with the Holcomb Boulevard water system, and because they believed the
water from the Hadnot Point water system was no longer contaminated. Prior
to restarting the Holcomb Boulevard water system, samples of treated water
were tested and no gasoline was detected in any of these samples. However,
the samples were found to contain various levels of TCE; these results
were attributed to the use of water from the Hadnot Point water system.
About 5 days after these samples were taken, the Holcomb Boulevard water
system was restarted because the fuel line had been repaired.

Following the discovery of contamination at individual wells in 1984, Camp
Lejeune published articles in the base newspaper, provided one
notification to residents of housing areas served by the Tarawa Terrace
water system, and created a press release about issues related to drinking
water at Camp Lejeune. In December 1984 the base newspaper published its
first story about sampling efforts, detection of VOCs, and removal of
wells from service in the Hadnot Point water system. At this time, Camp
Lejeune environmental officials had not begun sampling all other wells on
the base, including those at the Tarawa Terrace water system.
Subsequently, in April 1985 the Commanding General of Camp Lejeune issued
a notice to residents who lived in housing areas served by the Tarawa
Terrace water system.39 According to the notice:

"Two of the wells that supply Tarawa Terrace have had to be taken off line
because minute (trace) amounts of several organic chemicals have been
detected in the water. There are no definitive State or Federal
regulations regarding a safe level of these compounds, but as a
precaution, I have ordered the closure of these wells for all but
emergency situations when fire protection or domestic supply would be
threatened."

39Documents do not indicate how this notice was provided to residents.

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.40 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.)

Past Contamination Was Estimated to Have Originated from Both On-base and
Off-base Sources

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.41 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.

40According to a May 1985 memorandum, Camp Lejeune officials issued a
press release regarding removal of wells from service at Camp Lejeune in
May 1985. However, the memorandum did not describe the contents of the
press release, and the Marine Corps was unable to locate a copy of the
press release for our review.

41The sources of contamination at these eight sites were identified
through the NACIP program and the Installation Restoration Program, which
replaced NACIP as the Navy and Marine Corps environmental program.

Table 4: Information about Potential Sites of Contamination for the Hadnot
Point Water System

Sites                                  Uses of the sitea                   
Open field storage lots                Storage, disposal, and handling of  
                                          potentially hazardous waste and     
                                          materials, such as cleaning         
                                          solvents, used batteries, and waste 
                                          oils                                
Piney Green Road, an area adjacent to  Storage, disposal, and handling of  
the open field storage lots            potentially hazardous waste and     
                                          materials, such as pesticides, used 
                                          batteries, and fuel                 
Transformer storage lot                Pesticide mixing and cleaning and   
                                          disposal of oil from electric       
                                          transformers                        
Firefighting training pit              Firefighting training exercises in  
                                          which flammable liquids (including  
                                          used oil, solvents, and fuels) were 
                                          used                                
An industrial fly ash dump             Disposal of waste, including fly    
                                          ash (which is residue resulting     
                                          from the combustion of ground or    
                                          powdered coal), solvents, water     
                                          treatment sludge, and used paint    
                                          stripping compounds                 
An industrial area which includes 75   Mixed uses; due to the industrial   
buildings and facilities such as       nature of the site, many spills and 
maintenance shops, gas stations,       leaks of gas-related products and   
administrative offices, commissaries,  solvents occurred                   
snack bars, warehouses, and storage                                        
yards                                                                      
A service station within the           Fuel storage; includes four         
industrial area                        underground gasoline storage tanks  
A fuel farm within the industrial area Fuel storage; includes 15 fuel      
                                          storage tanks, 14 of which are      
                                          underground                         

Sources: Camp Lejeune Site Management Plan, Fiscal Year 2006, EPA
Superfund Record of Decision for Camp Lejeune 1993 and 1994, and
interviews with current Camp Lejeune officials.

aSome sites may have multiple uses. The only uses of the sites that were
included were those that may be related to the contamination.

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.

Cleanup and Monitoring Activities Are Under Way to Address the Contamination

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,42 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.

42Well fields are areas containing one or more wells that produce usable
amounts of water.

Concerns about Possible Adverse Health Effects and Government Actions Related to
the Past Contamination Have Led to Additional Activities

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.

ATSDR Has Undertaken Several Activities to Study Possible Adverse Health Effects
Related to the Drinking Water Contamination at Camp Lejeune

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.43 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.44 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 1985.45 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.46 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.

43While conducting the health assessment, ATSDR also considered two other
types of past exposures at Camp Lejeune as possibly a public health
hazard: lead in tap water and pesticides in soil at a former day care
facility.

44Agency for Toxic Substances and Disease Registry, Public Health
Assessment U.S. Marine Corps Camp Lejeune Onslow County, North Carolina
(Atlanta, Ga.: 1997).

45Although there was no evidence of an increased rate of adverse pregnancy
outcomes at Camp Lejeune at that time, the 1998 study report states that
the agency believed it was prudent to research this topic because fetuses
tend to be more sensitive to toxic chemical exposures and many pregnant
women had resided in housing areas supplied with contaminated water. In
addition to small for gestational age, other adverse pregnancy outcomes
evaluated in the study included pre-term birth and mean birth weight.

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.47 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
modeling48 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.49 In an August 2005 published response, ATSDR
agreed with all but three of the scientific advisory panel's
recommendations.50 (See app. VI for ATSDR's panel recommendations and
ATSDR's response.)

46U.S. Department of Health and Human Services, Agency for Toxic
Substances and Disease Registry, Volatile Organic Compounds in Drinking
Water and Adverse Pregnancy Outcomes (Atlanta, Ga.: 1998).

47Childhood hematopoietic cancers include childhood leukemia and
non-Hodgkin's lymphoma.

48Water modeling is a scientific method that is used to help estimate past
water system conditions.

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.51 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,52 which contains death records, and state cancer
registries53 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.54 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.

49U.S. Department of Health and Human Services, Agency for Toxic
Substances and Disease Registry, Report of the Camp Lejeune Scientific
Advisory Panel (Atlanta, Ga.: 2005).

50Agency for Toxic Substances and Disease Registry, ATSDR Response to the
Report of the Camp Lejeune Scientific Advisory Panel Held February 17-18,
2005 (Atlanta, Ga.: 2005).

51In 1992, ATSDR announced that it was developing community assistance
panels at selected Superfund sites in order to enhance effective
communication of environmental health concerns to ATSDR by the public and
provide a means for community participation in ATSDR activities. ATSDR
noted that among the factors that influence its decision to establish a
community assistance panel at a particular site are the degree of
community interest, whether there are varying viewpoints regarding the
health issues, and a willingness on the part of the public to actively
participate in the process. 57 Fed. Reg. 27779 (June 22, 1992).

52The National Death Index is a central computerized index of death record
information on file in state vital statistics offices. Working with these
state offices, the National Center for Health Statistics established the
index as a resource to aid epidemiologists and other health and medical
investigators with mortality ascertainment activities.

53Cancer registries collect data about the occurrence of cancer, the types
of cancer that occur, the cancer's location in the body, the extent of
disease at the time of diagnosis, and the kinds of treatment patients
receive. Cancer data are reported to a central statewide registry from
various medical facilities including hospitals, physicians' offices,
therapeutic radiation facilities, freestanding surgical centers, and
pathology laboratories.

54The Defense Manpower Data Center maintains the largest archive of
personnel, manpower, training, and financial data in DOD. The personnel
data holdings are broad in scope and extend back to the early 1970s to
cover all military services and all phases of the military personnel life
cycle. The Naval Health Research Center is a laboratory that supports
fleet operational readiness through research, development, test, and
evaluation on the biomedical and psychological aspects of the Navy and
Marine Corps.

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.55 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.

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

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.

55U.S. Department of Health and Human Services, Agency for Toxic
Substances and Disease Registry, Expert Peer Review Panel Evaluating
ATSDR's Water-Modeling Activities in Support of the Current Study of
Childhood Birth Defects and Cancer at U.S. Marine Corps Base Camp Lejeune,
North Carolina (Atlanta, Ga.: 2005).

  Funding of ATSDR's Camp Lejeune Work

ATSDR received funding from DOD for 13 of the 16 fiscal years during which
it has conducted its Camp Lejeune-related work, and ATSDR provided its own
funding for Camp Lejeune-related work during the other 3 years. Under
federal law and in accordance with a memorandum of understanding between
DOD and ATSDR, DOD is responsible for funding public health assessments
and any follow-up public health activities such as health studies or
toxicological profiles related to DOD sites as agreed to in an annual plan
of work. 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).

Table 5: Funding of ATSDR Activities at Camp Lejeune from Fiscal Years
1991 through 2006

Fiscal year Total amounta  Funding source                                  
1991               95,018  Defense Environmental Restoration Program       
                              (DERP)b                                         
1992               33,868  DERP                                            
1993               97,000  DERP                                            
1994              230,795  DERP                                            
1995              434,328  DERP                                            
1996              141,405  DERP                                            
1997              109,045  Navy Environmental Restoration Programc         
1998              731,247  ATSDR                                           
1999              390,000  ATSDR                                           
2000              935,312  ATSDR                                           
2001            1,241,003  Navy Environmental Restoration Program          
2002            1,021,437  Navy Environmental Restoration Program          
2003              567,389  Marine Corps Operations & Maintenanced          
2004            1,723,000  Marine Corps Operations & Maintenance           
2005            1,549,000  Marine Corps Operations & Maintenance           
2006           1,376,263e  Marine Corps Operations & Maintenance, Navy     
                              Environmental Restoration Program               

Sources: ATSDR and DOD.

aExpenditure amounts, in dollars, as reported by ATSDR and DOD.

bThe DERP was established by the Superfund Amendments and Reauthorization
Act of 1986. Through the DERP, DOD conducts environmental cleanup
activities at military installations. The Office of the Secretary of
Defense provides oversight for the DERP. Each of the military departments
is responsible for implementing DERP requirements.

cBeginning in fiscal year 1997, the individual military services assumed
responsibility for making payments to ATSDR. The Department of the Navy
conducts DERP-related activies through the Navy Environmental Restoration
Program.

dMarine Corps Operation & Maintenance appropriations provide the funding
for various Marine Corps missions, functions, activities, and facilities.

eIn fiscal year 2006, the Marine Corps provided $1,269,263 to support
ATSDR's current study, and the Navy Environmental Restoration Program
provided an additional $107,000, as submitted in a supplemental request by
ATSDR to conduct community assistance panel meetings and a feasibility
assessment to determine whether additional health studies could be
conducted for the Camp Lejeune site.

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.56
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.

56Additionally, the EPA 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.

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.

  Provision of Information to ATSDR by DOD

ATSDR has experienced some difficulties obtaining information from Camp
Lejeune and DOD officials. For example, while conducting its public health
assessment in September 1994, ATSDR sent a letter to the Department of the
Navy noting that ATSDR had had difficulties getting documents needed for
the public health assessment from Camp Lejeune, such as Remedial
Investigation57 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.58
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.59 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.

57A Remedial Investigation is performed at a site after it is listed on
the National Priorities List. The Remedial Investigation serves as a
mechanism for collecting data. Data collected during the Remedial
Investigation influence the development of remedial alternatives for the
site.

58The Privacy Act of 1974 provides safeguards for individuals against
invasions of privacy as a result of the collection of personal information
by the federal government. Pub. L. No. 93-579, S 3, 88 Stat. 1896, 1897
(codified as amended at 5 U.S.C. S 552a).

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.

  Effect on ATSDR's Work

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.60
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.

59The Defense Privacy Office is responsible for implementation of DOD's
Privacy Program, which regulates how and when DOD collects, maintains,
uses, or disseminates personal information on individuals.

Some Former Residents and Employees Have Filed Claims against the Federal
Government

Some former residents have filed tort claims and lawsuits against the
federal government related to the past drinking water contamination.61 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.62

As of February 2007, two of these claims had resulted in the filing of
lawsuits in Federal District Courts in Texas and Mississippi.63 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.64 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.65 An appeal of the claims of the former service member and
his family members remained pending in February 2007.66

60The Marine Corps has issued multiple public statements indicating
support for ATSDR's work at Camp Lejeune.

61The Federal Tort Claims Act provides a system for making claims against
the federal government for, among other things, personal injury, property
damage, or wrongful death allegedly caused by the negligence of its
employees. Act of Aug. 2, 1946, ch. 753, 60 Stat. 842 (codified, as
amended, to various sections of 28 U.S.C.). An individual must file a
valid claim with the federal agency alleged to have caused the harm before
filing a lawsuit against the federal government for negligence. 28 U.S.C.
S 2675.

62DOD officials noted that other considerations may lead to an earlier
adjudication of some claims.

63Snyder et al. v. U.S., Civ. No. 627 (S.D. Miss. filed July 27, 2004);
Gros et al. v. U.S., Civ. No. 4665 (S. D. Tex. filed Dec. 13, 2004). The
Federal Tort Claims Act requires that a claim must be presented in writing
within 2 years after the claim accrues and that after a claim has been
filed the agency has 6 months to make a decision. If the claim is denied
or if no decision has been made after 6 months, the individual can then
file a lawsuit against the federal government. 28 U.S.C. S 2675. The
lawsuits were filed in the districts where the individuals resided at the
time.

Several Federal Inquiries Have Examined Events Related to the Drinking Water
Contamination

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.

  Marine Corps-Chartered Panel Review

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.67 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.68 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.

64Plaintiffs' Complaint, Snyder et al. (Civ. No. 627).

65Order Granting Defendant's Motion to Dismiss, Gros et al. (Civ. No.
4665). The Supreme Court has held that under the Federal Tort Claims Act
the federal government is not liable for injuries to members of the armed
forces sustained while on active duty and resulting from the negligence of
others in the armed forces. Feres v. U.S., 340 U.S. 135, 146 (1950). The
claims of the former service member and his wife were dismissed on the
grounds that the husband's alleged exposure to contaminated water occurred
while he was on active duty in the military. Subsequently, in March 2006,
the District Court entered a final judgment for the government on all
individual claims alleged by the former service member's family members in
this case. Final Judgment in Favor of Defendant, Gros et al. (Civ. No.
4665).

66Gros et al. v. U.S., No. 06-20354 (5th Cir. filed May 8, 2006).

67Members of the panel consisted of a former member of Congress; an
adviser on water management, treatment, and protection issues; a retired
assistant commandant of the Marine Corps; a former acting Secretary of the
Navy; and a former branch chief of EPA.

The panel also made several other findings critical of Camp Lejeune and
the Department of the Navy, noting that:

           o 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;

           o communications both internally among Camp Lejeune officials, and
           between Camp Lejeune and LANTDIV, were inadequate; and

           o 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.

           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:
		   
68Drinking Water Fact-Finding Panel for Camp Lejeune, Report to the
Commandant United States Marine Corps (October 2004).		  

                        1. EPA inadequately responded to a Freedom of
                        Information Act69 request,
                        2. EPA inappropriately responded to a Freedom of
                        Information Act fee waiver request,70 
                        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.
		   
69The Freedom of Information Act generally ensures public access to
federal agency records. Upon written request, federal government agencies
are required to disclose those records, unless they can be lawfully
withheld from disclosure under specific exemptions in the act. 5 U.S.C. S
552.

70The Freedom of Information Act also provides that documents shall be
furnished at no or reduced charge under specified circumstances.

             EPA's Criminal Investigation

           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.71 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 public, and
                        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.
		   
71According to EPA, as part of the agency's responsibility for ensuring
compliance with environmental laws, the CID investigates allegations that
environmental laws have been violated and refers the cases that pose risks
to human health and the environment for criminal prosecution.		   

           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.72 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:
		   
72The former residents at this meeting were those who helped initiate this
investigation.

           o 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.

           o 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.

           o 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.

           o 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.
		   
		   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

           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.)
		   
           Experts Agreed That Study Population of Individuals Who Were
		   Potentially Exposed in Utero Was Appropriate and Studying Children
		   and Adults Could Also Be Reasonable

           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.73 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.74
           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.

73ATSDR's current study population of those individuals who were in utero
includes individuals whom ATSDR determined were exposed during specific
time periods of the mother's pregnancy or after their birth to
contaminated drinking water because they lived in an area that was served
by the Hadnot Point or Tarawa Terrace water systems, and those that ATSDR
determined through its study analysis were not exposed because they did
not live in those areas or were not exposed during specific time periods.

           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.
		   
           Experts Agreed That the Study Time Frame of 1968 through 1985 Was
		   Reasonable, but Could Be Extended Beyond 1985

           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.
		   
74According to ATSDR, inhalation of TCE and PCE that have evaporated from
drinking water is likely to result in higher exposures than ingestion.
Additionally, a 1991 EPA guidance on estimating exposure to VOCs during
showering noted that scientific studies found that this exposure is
approximately equivalent to exposure from ingesting two liters of the
contaminated water per day.

           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.
		   
		   Experts Said Health Effects Selected for the Study Were Valid,
		   Though Other Neurological and Behavioral Health Effects May Also
		   Occur

           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.75 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.76 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.77

           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.

           Experts Had Mixed Opinions on ATSDR's Projected Completion Date
		   and Some Said a Simpler Analysis Could Provide Earlier Results

           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.78

75The two panel experts who did not discuss health effects said that this
discussion was outside their areas of expertise. One expert is a professor
of geochemistry and the second is an environmental engineer.

76An ATSDR document setting out frequently asked questions about its
health study states that the agency chose to study these birth defects and
cancers based on the results of previous studies; two previous studies
suggested that the chemicals in the drinking water at Camp Lejeune might
cause these birth defects, while three studies suggested that these
chemicals in drinking water might cause childhood leukemia. Additionally,
ATSDR's study protocol noted that ATSDR's study could add to the body of
scientific knowledge.

77ATSDR's public health assessment noted that the exposure levels
experienced at Camp Lejeune were expected to be relatively low and
experienced over a relatively short duration.

78One of the panel experts did not discuss the completion date of the
study. A second expert said he did not have sufficient data to make a
determination on whether the projected completion date was reasonable.

           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.
		   
		   Experts Identified Additional Potential Modifications to the ATSDR
		   Study

           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.79 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.80

           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.
		   
		   Agency Comments

           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.
		   
79The current study includes only those individuals whose mothers were
pregnant with them and living on base at any time from 1968 through 1985
and who were born in Onslow County, where Camp Lejeune is located.
Additionally, the study identified individuals whose mothers were pregnant
with them while living on base during this time, but who gave birth
outside Onslow County.

80Leon Gordis, Epidemiology, 1st ed. (Philadelphia, Pa.: W.B. Saunders
Company, 1996), 183.		   

           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.

           Marcia Crosse
		   Director, Health Care
		   
		   Appendix I: Scope and Methodology

           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.
		   
Appendix II: Selected Events Related to Past Drinking Water Contamination at
Camp Lejeune from 1980 through 1981		   
		   
Date             Event                                                     
October 1, 1980  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.   
October 21 and   At the direction of LANTDIV, Camp Lejeune collected       
October 24, 1980 separate samples to be analyzed for total trihalomethanes 
                    (TTHMs)a 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.                                                  
October 31, 1980 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).b 
                    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.                                   
October 31, 1980 A reportc 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.       
January 22, 1981 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.             
February 9, 1981 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.                        
March 9, 1981    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.                                             
April 7, 1981    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)d were not among the VOCs        
                    detected in these samples.                                
April 16, 1981   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 billione in one of the  
                    well samples.                                             
May 8, 1981      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  
                    chloridef 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.   
May 29, 1981     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.                                            
July 31, 1981    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 levelg 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 programh 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.                                            
August 26, 1981  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.                                 


           Source: GAO analysis of Headquarters Marine Corps documents.

           Note: We use the term "contamination," which is also used by the
           law requiring us to do this work, as well as by EPA and DOD, to
           describe the drinking water at Camp Lejeune in the early 1980s.
           However, EPA had not yet established maximum contaminant levels
           for the chemicals TCE and PCE during this period. See 40 C.F.R. SS
           141.2 and 141.12 (1975-1985).

           aTTHMs are a type of volatile organic compound and are formed when
           disinfectants--used to control disease-causing contaminants in
           drinking water--react with naturally occurring organic matter in
           water.

           bMany volatile organic compounds (VOCs) are human-made chemicals
           such as industrial solvents or components of fuels, paint
           thinners, and dry cleaning agents. TCE is a VOC typically used as
           a metal degreaser.

           cGenerally, the USAEHA reports did not indicate to whom they were
           sent.

           dPCE is a VOC typically used as a dry cleaning solvent.

           eParts per billion are units commonly used to express
           contamination ratios of the amount of a contaminant in water,
           land, or air.

           fMethylene chloride is a VOC used in various industrial processes
           including paint stripping, paint remover manufacturing, and metal
           cleaning and degreasing.

           gMaximum contaminant levels are the maximum permissible level of a
           contaminant in water delivered to a public water system.

           hThe Navy Assessment and Control of Installation Pollutants
           program was established in 1980 to identify, assess, and control
           environmental contamination from past hazardous materials storage,
           transfer, processing, and disposal operations.
		   
Appendix III: Selected Events Related to Past Drinking Water Contamination
at Camp Lejeune from 1982 through 1983

Date               Event                                                   
April 19, 1982     Camp Lejeune environmental officials began collecting   
                      monthly samples for monitoring of total trihalomethanes 
                      (TTHMs)a at all eight base water systems.               
May 6, 1982        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),b 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.                                              
May 27 and May 28, Camp Lejeune environmental officials took a second set  
1982               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.         
June 9, 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.                                     
July 13, 1982      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.  
July 28, 1982      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.                        
August 10, 1982    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).c 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.           
August 18, 1982    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.d                      
August 19, 1982    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"e and "suggested action guidance,"f     
                      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.                         
December 9, 1982   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.         
December 21, 1982  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.                                                  
September 16, 1983 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.    

           Source: GAO analysis of Headquarters Marine Corps documents.

           Note: We use the term "contamination," which is also used by the
           law requiring us to do this work, as well as by EPA and DOD, to
           describe the drinking water at Camp Lejeune in the early 1980s.
           However, EPA had not yet established maximum contaminant levels
           for the chemicals TCE and PCE during this period. See 40 C.F.R. SS
           141.2 and 141.12 (1975-1985).

           aTTHMs are a type of volatile organic compound and are formed when
           disinfectants--used to control disease-causing contaminants in
           drinking water--react with naturally occurring organic matter in
           water.

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

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

           dAmendments in 1979 to the National Interim Primary Drinking Water
           Regulations required 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 1982 and comply with the maximum contaminant level by
           November 1983. 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.

           eEPA's suggested no adverse response levels were nonenforceable
           guidance for community water systems regarding TCE and PCE in
           drinking water issued in 1979 and 1980.

           fEPA's suggested action guidance was a nonenforceable guidance
           suggesting that remedial action be taken when PCE exceeded
           specific levels.
		   
Appendix IV: Selected Volatile Organic Compounds Detected in Wells at
Hadnot Point and Tarawa Terrace Water Systems 

                             Concentrations of chemicals in parts per billiona
               Date                                                                  
               removed                                                               
Water          from                                     Methylene              Vinyl 
systems  Wells service Benzeneb Trans-1,2-DCEc 1,1-DCEd chloridee Toluenef chlorideg 
Hadnot     602 Nov.         120            630      2.4        --      5.4        18 
Point          30,                                                                   
               1984                                                                  
           601 Dec. 6,       ND             88       ND        ND       ND        ND 
               1984                                                                  
           608 Dec. 6,      3.7            5.4       ND        ND       ND        ND 
               1984                                                                  
           634 Dec.          ND            2.3       --       130       --        ND 
               14,                                                                   
               1984                                                                  
           637 Dec.          ND             ND       --       270       --        -- 
               14,                                                                   
               1984                                                                  
           651 Feb. 4,       --          3,400      187        --       --       655 
               1985                                                                  
           652 Feb. 8,       --             ND       ND        --       --        ND 
               1985                                                                  
           653 Feb. 8,       --             ND       ND        --       --        ND 
               1985                                                                  
Tarawa   TT-26 Feb. 8,       ND             92       --        --       --        27 
Terrace        1985                                                                  
        TT-23h Feb. 8,       ND             11    --      --        --            ND
               1985  		   

           Source: GAO analysis of Headquarters Marine Corps data.

           Notes: The detection limit for the instruments used to analyze the
           samples was 10 parts per billion. The detection limit is the
           lowest level at which the chemicals could be reliably identified
           by the instruments being used. A Marine Corps document providing
           the sampling results stated that ND meant "none detected." Where
           no concentration or ND is provided, the laboratory did not report
           results for these samples.

           aThe concentrations provided are those detected prior to each
           well's removal from service in 1984 and 1985 and are one-time
           sampling results. We did not find documentation that tied the
           decision to remove the wells from service to any particular level
           of contamination included in related Environmental Protection
           Agency (EPA) guidance or enforceable regulation.

           bBenzene is a widely used chemical formed from both natural
           processes and human activities. Some industries use benzene to
           make other chemicals which are used to make plastics, resins, and
           nylon and synthetic fibers. Benzene is also a natural part of
           crude oil, gasoline, and cigarette smoke. Breathing benzene can
           cause drowsiness, dizziness, and unconsciousness; long-term
           benzene exposure causes effects on the bone marrow and can cause
           anemia and leukemia. The Department of Health and Human Services
           (HHS) has determined that benzene is a known carcinogen.

           cTrans-1,2-dichloroethylene (Trans-1,2-DCE) is an odorless organic
           liquid used as a solvent for waxes and resins; in the extraction
           of rubber; as a refrigerant; in the manufacture of pharmaceuticals
           and artificial pearls; in the extraction of oils and fats from
           fish and meat; and in making other organics. EPA has found
           trans-1,2-DCE to potentially cause central nervous system
           depression when people are exposed to it at levels above 100 parts
           per billion for relatively short periods of time. Trans-1,2-DCE
           has the potential to cause liver, circulatory, and nervous system
           damage from long-term exposure at levels above 100 parts per
           billion.

           d1,1-dichloroethylene (1,1-DCE) is an organic liquid with a mild,
           sweet, chloroform-like odor. Virtually all of it is used in making
           adhesives, synthetic fibers, refrigerants, food packaging, and
           coating resins. EPA has found 1,1-DCE to potentially cause liver
           damage when people are exposed to it at levels above 7 parts per
           billion for relatively short periods of time. 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.

           eMethylene chloride is a VOC used in various industrial processes,
           including paint stripping, paint remover manufacturing, and metal
           cleaning and degreasing. Breathing in large amounts of methylene
           chloride can damage the central nervous system. Contact of eyes or
           skin with methylene chloride can result in burns. HHS has
           determined that methylene chloride can be reasonably anticipated
           to be a cancer-causing chemical.

           fToluene is a clear, colorless liquid which occurs naturally in
           crude oil and in the tolu tree. It is also produced in the process
           of making gasoline and other fuels from crude oil and making coke
           from coal. Toluene may affect the nervous system. Low to moderate
           levels can cause tiredness, confusion, weakness, drunken-type
           actions, memory loss, nausea, loss of appetite, and hearing and
           color vision loss. Inhaling high levels of toluene in a short time
           can result in feelings of light-headedness, dizziness, or
           sleepiness. It can also cause unconsciousness, and even death.
           High levels of toluene may affect kidneys. Studies in humans and
           animals generally indicate that toluene does not cause cancer.

           gVinyl chloride is a colorless gas. It is a manufactured substance
           that does not occur naturally. It can be formed when other
           substances such as trichloroethane, trichloroethylene, and
           tetrachloroethylene are broken down. Breathing high levels of
           vinyl chloride for short periods of time can cause dizziness,
           sleepiness, unconsciousness, and at extremely high levels can
           cause death. Breathing vinyl chloride for long periods of time can
           result in permanent liver damage, immune reactions, nerve damage,
           and liver cancer. HHS has determined that vinyl chloride is a
           known carcinogen.

           hWell TT-23 is also referred to as "TT-new well" in Marine Corps
           documents.
		   
Appendix V: Selected Events Related to Past Drinking Water Contamination
at Camp Lejeune from 1984 through 1985 Appendix V: Selected Events Related
to Past Drinking Water Contamination at Camp Lejeune from 1984 through
1985

Date                 Event                                                 
July 1984            Camp Lejeune initiated the Navy Assessment and        
                        Control of Installation Pollutants (NACIP)a           
                        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.                    
November 30, 1984    Camp Lejeune officials received results from the      
                        confirmation study sampling which detected            
                        trichloroethylene (TCE) and tetrachloroethylene       
                        (PCE), among other volatile organic compoundsb (VOC), 
                        at a well serving the Hadnot Point water system, one  
                        of eight water systems at Camp Lejeune. This well was 
                        removed from service.                                 
December 4, 1984     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.                                    
December 6, 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)c 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.d           
December 10, 1984    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.          
December 10, 1984    Samples were again collected from the same seven      
                        Hadnot Point wells and the treated water at the       
                        Hadnot Point water treatment plant.                   
December 13, 1984    Separately, daily samples were collected from the     
through December 19, untreated water at the Hadnot Point water treatment   
1984                 plant.                                                
December 13, 1984    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.                       
December 14, 1984    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,e 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.f                     
December 21, 1984    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.                                        
January 8, 1985      The director of the NACIP program at Camp Lejeune     
                        received a reportg 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.                  
January 16, 1985     Samples were collected at all wells serving the       
                        Hadnot Point and Holcomb Boulevard water systems to   
                        be tested for VOCs.                                   
January 23, 1985     Samples were collected at all wells serving four      
                        other water systems, including Tarawa Terrace, to be  
                        tested for VOCs.                                      
January 27, 1985     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.        
January 31, 1985     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.                                                
February 4, 1985     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.                          
February 4, 1985     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.                                     
February 4, 1985     The Holcomb Boulevard water treatment plant was       
                        restarted.                                            
February 7, 1985     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.  
February 8, 1985     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.                                 
March 12, 1985       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.                                              
April 30, 1985       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.                             
May 9, 1985          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.                          
May 10, 1985         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.                           
May 11, 1985         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.                           
May 31, 1985         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.                            
September 15, 1985   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.             		   

           Source: GAO analysis of Headquarters Marine Corps documents.

           Note: We use the term "contamination," which is also used by the
           law requiring us to do this work, as well as by the Environmental
           Protection Agency (EPA) and the Department of Defense (DOD), to
           describe the drinking water at Camp Lejeune in the early 1980s.
           However, EPA had not yet established maximum contaminant levels
           for the chemicals TCE and PCE during this period. See 40 C.F.R. SS
           141.2 and 141.12 (1975-1985).

           aAs part of the Navy Assessment and Control of Installations
           Pollutants (NACIP) program, initial assessment studies were
           conducted to determine the potential for environmental
           contamination and if potential contamination was identified, a
           follow-up confirmation study was initiated.

           bMany volatile organic compounds (VOCs) are human-made chemicals
           such as industrial solvents or components of fuels, paint
           thinners, and dry cleaning agents. TCE is a VOC typically used as
           a metal degreaser. PCE is a VOC typically used as a dry cleaning
           solvent.

           cParts per billion are units commonly used to express
           contamination ratios of the amount of a contaminant in water,
           land, or air.

           dThe Marine Corps were not able to provide documents that
           indicated why one of these three wells was not removed from
           service.

           eMethylene chloride is a VOC used in various industrial processes
           including paint stripping, paint remover manufacturing, and metal
           cleaning and degreasing

           fThe Marine Corps were not able to provide documents that
           indicated why one of these three wells was not removed from
           service.

           gThe report did not indicate from whom it was sent.
		   
Appendix VI: Agency for Toxic Substances and Disease Registry's Response
to its 2005 Scientific Advisory Panel's Recommendations

Scientific advisory panel's                                                
recommendations regarding future                                           
health studies of past drinking water  Agency for Toxic Substances and     
contamination at Camp Lejeune          Disease Registry's (ATSDR) response 
      1. Create an advisory panel to      Agreed. ATSDR will create a         
      oversee health studies related to   community assistance panel (CAP)    
      Volatile Organic Chemical (VOC)     comparable to other panels it has   
      exposures at Camp Lejeune.          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.   
      2. Conduct future studies in full   Agreed. ATSDR said it considered    
      partnership with the potentially    interaction with the community an   
      exposed community.                  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 Agreed. In order to identify        
      groups of potentially exposed       various distinct groups of          
      individuals to study, including     individuals with potential          
      exposed and unexposed individuals   exposure, ATSDR said that efforts   
      who had lived and/or worked at Camp or activities should be conducted   
      Lejeune during the period of        to determine if potential databases 
      interest, which would serve as the  exist that would identify these     
      population base for further         groups, such as children who lived  
      studies.                            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         Agreed. ATSDR will conduct a        
      feasibility or pilot studies--to    feasibility assessment to determine 
      determine whether study individuals the number of adults and children   
      can be identified and tracked and   that could be identified through    
      what types of medical records are   available data sources.             
      available--before embarking on                                          
      full-scale studies of the impact on                                     
      health of exposures at Camp                                             
      Lejeune.                                                                
      5. Study additional health          Agreed. ATSDR agreed that mortality 
      outcomes, such as mortality and     and cancer incidence should receive 
      cancer incidence. Also, conduct     the highest priority and are the    
      feasibility studies of other        outcomes most feasible to study.    
      adverse health outcomes, such as    The agency said that decisions      
      autoimmune diseases; spontaneous    concerning study period, study      
      abortion; neurological effects;     population, and study outcomes      
      organ failure; adult heart disease; should be made in consultation with 
      reproductive outcomes of male and   the CAP, and said that ATSDR would  
      female children who were born (or   defer decisions about additional    
      were in utero) at Camp Lejeune;     health studies until feasibility    
      birth defects beyond those          studies were completed and reviewed 
      considered by ATSDR; and ocular     by the CAP.                         
      problems.                                                               
      6. Conduct future research          Agreed. The agency said that its    
      activities in parallel with the     highest priority is to complete the 
      current study and without awaiting  current study. Development of a CAP 
      completion of current ATSDR         and further research activities     
      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     Did not agree. ATSDR said revisions 
      assessment to include the           to the assessment would be needed   
      possibility that adult cancers and  only if new information changed the 
      other adverse health outcomes may   assessment's conclusions or         
      be related to VOC exposures.        recommendations. ATSDR noted that   
      Additionally, in the period since   its assessment acknowledged that    
      release of the original public      the science was inconclusive and    
      health assessment, much additional  did not rule out the possibility of 
      information on exposures at Camp    cancerous health effects from       
      Lejeune and their potential risks   low-dose exposure to VOCs.          
      has been developed, and this                                            
      additional material should be                                           
      incorporated into an amended                                            
      document.                                                               
      8. Notify all persons potentially   Did not respond directly. ATSDR     
      affected by exposure to VOCs in the indicated that it would work with   
      drinking water at Camp Lejeune.     the CAP to determine effective ways 
                                          to disseminate information about    
                                          its current study and any future    
                                          health studies.                     
      9. Obtain future funding for Camp   Did not agree. ATSDR said it        
      Lejeune health studies through      recognized that the affected        
      direct congressional appropriation, community had some distrust of      
      not through DOD's budget, to avoid  ATSDR and DOD, and said that the    
      even the appearance of a conflict   CAP was intended to help mitigate   
      of interest.                        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.   
										  
           Appendix VII: Description of Current Agency for Toxic Substances
		   and Disease Registry (ATSDR) Health Study										                     

           Sources: U.S. Department of Health and Human Services, Agency for
           Toxic Substances and Disease Registry, Report of the Camp Lejeune
           Scientific Advisory Panel (Atlanta, Ga.: 2005). Agency for Toxic
           Substances and Disease Registry, ATSDR Response to the Report of
           the Camp Lejeune Scientific Advisory Panel Held February 17-18,
           2005 (Atlanta, Ga.: 2005).

           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.1 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.

1There were 103 potential cases reported during the survey; 3 additional
potential cases were reported to ATSDR after the survey was closed.

Table 6: Potential and Confirmed Cases of Childhood Cancers and Birth
Defects as of April 2006

                                 Confirmed                 Cases confirmed as 
                                cases with                     without health 
               Reported cases diagnosis of Cases not    condition, refused to 
Health           of health       health       yet          participate, or 
condition       conditions    condition confirmed               ineligible 
Neural tube             35           17         2                       16 
defects                                                                    
Oral clefts             42           24         4                       14 
Childhood               29           16         2                       11 
cancers                                                                    
Total                  106           57         8                       41 

Source: ATSDR.

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.

Appendix VIII: GAO Contact and Staff Acknowledgments

GAO Contact

Marcia Crosse (202) 512-7119 or [email protected]

Acknowledgments

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.

(290456)

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Highlights of [52]GAO-07-276 , a report to congressional committees

May 2007

DEFENSE HEALTH CARE

Activities Related to Past Drinking Water Contamination at Marine Corps
Base Camp Lejeune

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.

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.

References

Visible links
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