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
This is a work of the U.S. government and is not subject to copyright
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separately.
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
52. file:///home/webmaster/infomgt/d07276.htm#http://www.gao.gov/cgi-bin/getrpt?GAO-07-276
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