Defense Health Care: Issues Related to Past Drinking Water	 
Contamination at Marine Corps Base Camp Lejeune (12-JUN-07,	 
GAO-07-933T).							 
                                                                 
In the early 1980s, volatile organic compounds (VOC) were	 
discovered in some of the water systems serving housing areas on 
Marine Corps Base Camp Lejeune. Exposure to certain VOCs may	 
cause adverse health effects, including cancer. Since 1991, the  
Department of Health and Human Services' Agency for Toxic	 
Substances and Disease Registry (ATSDR) has been examining	 
whether individuals who were exposed to the contaminated drinking
water are likely to have adverse health effects. ATSDR's current 
study is examining whether individuals who were exposed in utero 
are more likely to have developed certain childhood cancers or	 
birth defects. GAO was asked to testify on its May 11, 2007	 
report: Defense Health Care: Activities Related to Past Drinking 
Water Contamination at Marine Corps Base Camp Lejeune		 
(GAO-07-276). This testimony summarizes findings from the report 
about (1) efforts to identify and address the past drinking water
contamination, (2) the provision of funding and information from 
the Department of Defense (DOD) to ATSDR, and (3) an assessment  
of the design of the current ATSDR study. GAO reviewed documents,
interviewed officials and former residents, and contracted with  
the National Academy of Sciences to convene an expert panel to	 
assess the current ATSDR study. 				 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-07-933T					        
    ACCNO:   A70593						        
  TITLE:     Defense Health Care: Issues Related to Past Drinking     
Water Contamination at Marine Corps Base Camp Lejeune		 
     DATE:   06/12/2007 
  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)					 

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GAO-07-933T

   

     * [1]Background

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

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

          * [8]Navy Water Testing Beginning in 1980 Identified VOCs in Camp
          * [9]Further Tests Identified TCE and PCE in Two Camp Lejeune Wat
          * [10]Discovery of Contamination in Individual Wells in 1984 and 1
          * [11]Past Contamination Was Estimated to Have Originated from Bot

     * [12]Although ATSDR Did Not Always Receive Requested Funding and

          * [13]Funding of ATSDR's Camp Lejeune Work
          * [14]Provision of Information to ATSDR by DOD
          * [15]Effect on ATSDR's Work

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

          * [17]Study Population
          * [18]Study Time Frame
          * [19]Study Health Effects
          * [20]Study Completion Date

     * [21]Contacts and Acknowledgments
     * [22]Appendix I: Volatile Organic Compounds Detected in Wells at

          * [23]Order by Mail or Phone

Testimony

Before the Subcommittee on Oversight and Investigations, Committee on
Energy and Commerce, House of Representatives

United States Government Accountability Office
GAO

For Release on Delivery
Expected at 10:00 a.m. EDT
Tuesday, June 12, 2007

DEFENSE HEALTH CARE

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

Statement of Marcia Crosse
Director, Health Care

GAO-07-933T

Mr. Chairman and Members of the Subcommittee:

I am pleased to be here today as you examine issues related to past
drinking water contamination at Camp Lejeune. In the early 1980s,
Department of the Navy water testing at Marine Corps Base Camp Lejeune
identified contamination in water systems that served housing areas on the
base.^1 Further water testing revealed that some of the individual wells
serving two of the water systems were contaminated with volatile organic
compounds (VOC), such as trichloroethylene (TCE), which is a metal
degreaser and an ingredient in adhesives and paint removers, and
tetrachloroethylene (PCE), which is a solvent used in the textile industry
and a dry cleaning solvent. Although it is not known precisely when the
wells became contaminated, the Department of Health and Human Services'
(HHS) Agency for Toxic Substances and Disease Registry (ATSDR), which is
investigating the issue, has estimated that the contamination may have
begun as early as the 1950s. According to ATSDR, the VOCs of primary
concern at Camp Lejeune were TCE and PCE, and the agency notes that
exposure to these chemicals may cause adverse health effects. For example,
exposure to low levels of TCE may cause headaches and difficulty
concentrating.^2 Exposure to high levels of both TCE and PCE may cause
dizziness, headaches, nausea, unconsciousness, cancer, and possibly
death.^3

Former residents of Camp Lejeune have taken legal action against the
federal government for injuries alleged to have resulted from exposure to
the contaminated water. As of June 2007, about 850 former residents and
former employees of Camp Lejeune have filed tort claims with the
Department of the Navy related to the past drinking water contamination.
Two of these claims have resulted in the filing of lawsuits in Federal
District Courts in Texas and Mississippi.^4 In addition, some former
residents have expressed concern over the Marine Corps' handling of and
response to the drinking water contamination, noting that even though
contaminants were detected as early as 1980, the wells that were
determined to be contaminated were not removed from service until 1985.
Some former residents have also asserted that there have been delays in
the provision of funding and information from the Department of Defense
(DOD) to ATSDR.^5

^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.

^2According to ATSDR, health effects from exposure to low levels of PCE
are unknown.

^3ATSDR did not define "low levels" or "high levels" of TCE or PCE.

^4Snyder 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.

My statement is based on our May 11, 2007 report, Defense Health Care:
Activities Related to Past Drinking Water Contamination at Marine Corps
Base Camp Lejeune ( [24]GAO-07-276 ). For this report, the Ronald W.
Reagan National Defense Authorization Act for Fiscal Year 2005 directed
that we study and report on the past drinking water contamination and
related adverse health effects at Camp Lejeune, including identifying the
type, source, and duration of the contamination and determining the
actions taken to address the contamination, and assessing the current
ATSDR health study.^6 My remarks today will summarize our findings related
to the history of events related to drinking water contamination at Camp
Lejeune, specifically, (1) efforts to identify and address the past
contamination; (2) the provision of funding and information from DOD to
ATSDR for its work related to the past contamination at Camp Lejeune; and
(3) an assessment by an independent panel of experts of the design of the
current ATSDR health study, including the study's population, the exposure
time frame, selected health effects being measured, and the reasonableness
of the projected completion date.

To do this work, we reviewed more than 1,600 documents related to past and
current drinking water activities at Camp Lejeune. We focused our review
on the past TCE and PCE contamination^7 because ATSDR had noted that these
chemicals were the VOCs of primary concern at Camp Lejeune. However, we
also reviewed documentation regarding other VOCs detected at Camp Lejeune.
For this testimony we focused on contamination in Camp Lejeune's Hadnot
Point, Tarawa Terrace, and Holcomb Boulevard water systems, as they
provided drinking water to most of the installation's housing areas during
the period of interest. We interviewed current and former officials from
various DOD entities, including Camp Lejeune, Headquarters Marine Corps,
and the Department of the Navy, to obtain information about the history of
events related to the past drinking water contamination at Camp Lejeune,
including efforts to identify and address the contamination. The current
and former officials interviewed often provided information based on their
memory of events that occurred more than 20 years ago. We attempted to
corroborate their testimonial evidence with documentation whenever
possible. The former officials we interviewed were responsible for
environmental activities at Camp Lejeune or the Department of the Navy
during the time in which the contamination was detected. The current
officials we interviewed are responsible for environmental activities at
Camp Lejeune, Headquarters Marine Corps, or the Department of the Navy.
Some of these current officials were also responsible for environmental
activities during the time in which the contamination was detected. We
also met with 19 interested former residents and individuals who worked on
the base during the 1960s, 1970s, and 1980s, in order to obtain their
perspective on historical events and to learn about their concerns related
to the drinking water contamination. A former resident who is active in
matters related to the past drinking water contamination at Camp Lejeune
identified most of the interested former residents; others were identified
at an ATSDR public meeting. Additionally, we examined reports from and
interviewed officials with the Environmental Protection Agency (EPA) and
with the North Carolina Department of Environment and Natural Resources
who were knowledgeable about activities and costs related to the cleanup
of the suspected sources of contamination. We also interviewed ATSDR
officials and reviewed ATSDR's Camp Lejeune-related documents and
publications, including a 1997 public health assessment and an ATSDR
health study released in 1998. We also interviewed officials with the
Department of the Navy and the U.S. Army Center for Health Promotion and
Preventive Medicine, which serves as a liaison between DOD and ATSDR. To
assess the design of the current ATSDR health study, we contracted with
the National Academy of Sciences (NAS) to convene a panel of seven subject
area experts for a 1-day meeting. The expert panel was charged with
evaluating the study's population, exposure time frame, selected health
effects, and completion date. We relied primarily on information gleaned
from the expert panel meeting and the panel experts' subsequent written
responses to the set of questions that were discussed during the 1-day
meeting. Not all panel members commented individually about each of the
questions discussed during the 1-day meeting. Additionally, some panel
members noted that certain questions addressed subjects that were outside
their areas of expertise. We also reviewed study-related documentation
furnished by officials from ATSDR, the Marine Corps, and the Navy
Environmental Health Center, and interviewed officials from those
agencies. We conducted our work from May 2005 through April 2007 in
accordance with generally accepted government auditing standards.

^5DOD is required by law to provide funding and data as necessary for
ATSDR to carry out certain health-related activities, including public
health assessments.

^6Pub. L. No. 108-375, S 317, 118 Stat. 1811, 1844.

^7Throughout this testimony we use the term "contamination," which is also
used by the law requiring us to do this work, as well as by the EPA and
DOD, to describe the drinking water at Camp Lejeune in the early 1980s.
However, EPA had not yet established maximum contaminant levels for the
chemicals TCE and PCE during this period. See 40 C.F.R. SS 141.2 and
141.12 (1975-1985).

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

Regarding the provision of funding and information from DOD to ATSDR for
its work related to the past contamination at Camp Lejeune, we found that
since ATSDR began its Camp Lejeune-related work in 1991, the agency has
not always received requested DOD funding and experienced delays in
receiving information from DOD. For example, for 3 of the 16 fiscal years
during which ATSDR has conducted its Camp Lejeune-related work (fiscal
years 1998 through 2000), no funding was provided to ATSDR by the Navy or
any DOD entity. ATSDR also had difficulties getting documents needed from
Camp Lejeune while it was conducting a public health assessment for the
base. However, ATSDR officials said that while funding and access to
records were probably slowed down and their Camp Lejeune related work made
more expensive by DOD officials' actions, their actions did not
significantly impede ATSDR's Camp Lejeune-related health study efforts.
The ATSDR officials also stated that while issues such as limitations in
access to DOD data had to be addressed, such situations are normal during
the course of a study.

The experts convened by NAS to assess the design of the current ATSDR
health study generally agreed that many parameters of ATSDR's current
study are appropriate. Regarding the study population, all seven panel
experts agreed that ATSDR's study population of individuals who were
potentially exposed in utero to the contaminated drinking water at Camp
Lejeune between 1968 and 1985 was appropriate, as this population was
arguably the most vulnerable to the effects of the contamination. Panel
experts generally agreed that the 1968-1985 study time frame was
reasonable, based on limitations in data availability for the years prior
to 1968. Regarding the health effects studied, five of the seven panel
experts discussed health effects and said that the selected birth defects
and childhood cancers were relevant. Regarding the proposed completion
date, the panel experts had mixed opinions: three of the five panel
experts who commented said that the projected December 2007 date appeared
reasonable, while two said that the date might be optimistic.

DOD, EPA, and HHS provided technical comments on a draft of the May 11,
2007 report, which we incorporated where appropriate. We provided the
seven former Camp Lejeune residents who are members of an ATSDR community
assistance panel for Camp Lejeune the opportunity to provide comments on
our draft--three of the panel members provided both technical and general
oral comments, and four declined to review the draft report. The three
panel members commented generally on issues such as VOCs other than TCE
and PCE that have been detected at Camp Lejeune, compensation and health
benefits for former residents, and additional notification for former
residents. We incorporated the panel members' technical comments where
appropriate, but some issues they discussed were beyond the scope of the
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 covers approximately 233 square miles in Onslow County, North
Carolina, and includes training schools for infantry, engineers, service
support, and medical support, as well as a Naval Hospital and Naval Dental
Center. The base has nine family housing areas, and families live in base
housing for an average of 2 years. Base housing at Camp Lejeune consists
of enlisted family housing, officer family housing, and bachelor housing
(barracks for unmarried service personnel). Additionally, schools, day
care centers, and administrative offices are located on the base.
Approximately 54,000 people currently live and work at Camp Lejeune,
including about 43,000 active duty personnel and 11,000 military
dependents and civilian employees.

In the 1980s, Camp Lejeune obtained its drinking water from as many as
eight water systems, which were fed by more than 100 individual wells that
pumped water from a freshwater aquifer located approximately 180 feet
below the ground. Each of Camp Lejeune's water systems included wells, a
water treatment plant, reservoirs, elevated storage tanks, and
distribution lines to provide the treated water to the systems' respective
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, and Holcomb
Boulevard water systems provided drinking water to most of Camp Lejeune's
housing areas. The water treatment plants for the Hadnot Point and Tarawa
Terrace water systems were constructed during the 1940s and 1950s. The
water treatment plant for the Holcomb Boulevard water system began
operating at Camp Lejeune in 1972; prior to this time, the Hadnot Point
water system provided water to the Holcomb Boulevard service area. In the
1980s, each of these three systems had between 8 and 35 wells that could
provide water to their respective service areas. In 1987 the Tarawa
Terrace water treatment plant was shut down and the Holcomb Boulevard
water distribution system was expanded to include the Tarawa Terrace water
service area.

Generally, housing units served by the Tarawa Terrace and Holcomb
Boulevard water systems consisted of family housing, which included
single- and multifamily homes and housing in trailer parks. Housing units
served by the Hadnot Point water system included mainly bachelor housing
with limited family housing. Based on available housing data for the late
1970s and the 1980s,^8 the estimated annual averages of the number of
people living in family housing units^9 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, and

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

           In addition to serving housing units, all three water systems
           provided water to base administrative offices. The Tarawa Terrace,
           Holcomb Boulevard, and Hadnot Point water systems also served
           schools and other recreational areas. Additionally, the Hadnot
           Point water system also served an industrial area and the base
           hospital.
			  
^8To 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.

^9Camp Lejeune housing officials could not provide occupancy rates for
bachelor housing.

           Department of the Navy Environmental Functions

           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.^10 For
           example, LANTDIV officials work with Camp Lejeune officials to
           establish environmental cleanup priorities and cost estimates and
           to allocate funding to ensure compliance with state and federal
           environmental regulations.

           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.

           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.
			  
^10LANTDIV also manages the planning, design, construction, contingency
engineering, real estate, and public works support at Navy and Marine
Corps facilities in the United States.

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

           Congress passed the Safe Drinking Water Act in 1974^11 to protect
           the public's health by regulating the nation's public drinking
           water supply. The Safe Drinking Water Act, as amended, is the key
           federal law protecting public water supplies from harmful
           contaminants. For example, the act requires that all public water
           systems conduct routine tests of treated water to ensure that the
           water is safe to drink. Required water testing frequencies vary
           and range from weekly testing for some contaminants to testing
           every 3 years for other contaminants. The act also established a
           federal-state arrangement in which states may be delegated primary
           implementation and enforcement authority for the drinking water
           program. For contaminants that are known or anticipated to occur
           in public water systems and that EPA determines may have an
           adverse impact on health, the act requires EPA to set a
           nonenforceable maximum contaminant level goal, at which no known
           or anticipated adverse health effects occur and that allows an
           adequate margin of safety. Once the maximum contaminant level goal
           is established, EPA sets an enforceable standard for water as it
           leaves the treatment plant, the maximum contaminant level. A
           maximum contaminant level is the maximum permissible level of a
           contaminant in water delivered to any user of a public water
           system. The maximum contaminant level must be set as close to the
           goal as is feasible using the best technology or other means
           available, taking costs into consideration. The North Carolina
           Department of Environment and Natural Resources and its
           predecessors^12 have had primary responsibility for implementation
           of the Safe Drinking Water Act in North Carolina since 1980.

           In 1979, EPA promulgated final regulations applicable to certain
           community water systems establishing the maximum contaminant
           levels for the control of TTHMs, which are a type of VOC that are
           formed when disinfectants--used to control disease-causing
           contaminants in drinking water--react with naturally occurring
           organic matter in water. The regulations required that water
           systems that served more than 10,000 people and that added a
           disinfectant as part of the drinking water treatment process begin
           mandatory water testing for TTHMs by November 1982 and comply with
           the maximum contaminant level by November 1983. TCE and PCE were
           not among the contaminants included in these regulations.
			  
^11Pub. L. No. 93-523, 88 Stat. 1660 (codified, as amended, at 42 U.S.C.
SS 300f et seq.).

^12In the 1980s, the North Carolina Department of Human Resources
administered the Safe Drinking Water Act and the Department of Natural
Resources and Community Development was responsible for other
environmental functions in the state of North Carolina. In 1989, sections
of these departments underwent a reorganization and name change, becoming
the Department of Environment, Health, and Natural Resources. In 1997, the
department was again reorganized and took on its current name, the
Department of Environment and Natural Resources.

           In 1979 and 1980, EPA issued nonenforceable guidance establishing
           "suggested no adverse response levels" for TCE and PCE in drinking
           water and in 1980 issued "suggested action guidance" for PCE in
           drinking water.^13 Suggested no adverse response levels provided
           EPA's estimate of the short- and long-term exposure to TCE and PCE
           in drinking water for which no adverse response would be observed
           and described the known information about possible health risks
           for these chemicals. Suggested action guidance recommended
           remedial actions within certain time periods when concentrations
           of contaminants exceeded specific levels. Suggested action
           guidance was issued for PCE related to drinking water
           contamination from coated asbestos-cement pipes, which were used
           in water distribution lines.

           The initial regulation of TCE and PCE under the Safe Drinking
           Water Act began in 1989 and 1992, respectively, when maximum
           contaminant levels became effective for these contaminants. (See
           table 1 for the suggested no adverse response levels, suggested
           action guidance, and maximum contaminant level regulations for TCE
           and PCE.)
			  
^13Neither issuance was published in The Federal Register.			  

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 
                                                                      (mg/l) and 
             Suggested no adverse                                          ppb^c 
         response level^a for various                                  effective 
          exposure periods in parts    Suggested action guidance^b       in 1989 
         per billion (ppb) issued in   for various exposure periods    (TCE) and 
          1979 (TCE) and 1980 (PCE)    in ppb issued in 1980 (PCE)    1992 (PCE) 
Chemical 1-Day^d 10-Day^e Long-term^f  1-Day^d 10-Day^e Long-term^f              
TCE        2,000      200          75    N/A^g    N/A^g       N/A^g  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 (Jan. 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 1980^14 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.^15 CERCLA was amended
by the Superfund Amendments and Reauthorization Act (SARA) of 1986.^16
Among other things, SARA requires that federal agencies, including DOD,
that own or operate facilities on EPA's CERCLA list of seriously
contaminated sites, known as the National Priorities List, enter into an
interagency agreement with EPA.^17 The agreement is to specify what
cleanup activities, if any, are required and to set priorities for
carrying out those activities.^18 SARA also established the Defense
Environmental Restoration Program, through which DOD conducts
environmental cleanup activities at military installations.^19 Under the
environmental restoration program, DOD's activities addressing hazardous
substances, pollutants, or contaminants are required to be carried out
consistent with the provisions of CERCLA governing environmental cleanups
at federal facilities.^20 Based on environmental contamination at various
areas on the base, Camp Lejeune was designated as a National Priorities
List site in 1989. EPA, the Department of the Navy, and the state of North
Carolina entered into a Federal Facilities Agreement concerning cleanup of
Camp Lejeune with an effective date of March 1, 1991.

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

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.^21

^15At privately owned sites, EPA can require that responsible parties
either perform the cleanup themselves or reimburse EPA for the costs of
Superfund-funded cleanups. Federal agencies generally must pay for
cleanups and other Superfund activities from their own appropriations.

^16Pub. L. No. 99-499, 100 Stat. 1613 (1986) (codified, as amended, at
various sections of titles 10, 26, 29, and 42 U.S.C.).

^17To determine which sites are eligible for listing on the National
Priorities List, EPA uses the Hazard Ranking System, a numerical scoring
system that assesses the hazards a site poses to human health and the
environment as its principal determining factor. Once EPA has determined
that the risks posed by a site make it eligible for the National
Priorities List, EPA regions then consider many other factors in selecting
the sites to submit to EPA headquarters for proposal to be added to the
National Priorities List.

^18See 42 U.S.C. S 9620(e).

^19See 10 U.S.C. SS 2701-2709.

^20See 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.^22 Based on the memorandum of understanding signed between ATSDR
and DOD, ATSDR is required to submit an annual plan of work to DOD, in
which it must describe the public health activities it plans to conduct at
DOD sites in the following fiscal year, as well as the amount of funding
required to conduct these activities. After the annual plan of work has
been submitted, DOD has 45 days to respond and negotiate the scope of work
to be conducted by ATSDR. The memorandum of understanding states that DOD
must seek sufficient funding through the DOD budgetary process to carry
out the work agreed upon.

From 1991 to 1997, ATSDR conducted a public health assessment at Camp
Lejeune that was required by law because of the base's listing on the
National Priorities List. The health assessment evaluated several ways in
which people on base had been exposed to hazardous substances, including
exposure to the VOC-contaminated drinking water.^23 In its 1997 report,
ATSDR recommended that a study be carried out to evaluate the risks of
childhood cancer in those who were exposed in utero to the contaminated
drinking water and also noted that adverse pregnancy outcomes were of
concern. In 1995, while the health assessment was being conducted, ATSDR
initiated a study to determine whether there was an association between
exposure to VOCs in drinking water and specific adverse pregnancy outcomes
among women who had lived at Camp Lejeune from 1968 through 1985.^24 The
study, released in 1998, originally concluded that there was a
statistically significant elevated risk for several poor pregnancy
outcomes, including (1) small for gestational age among male infants born
to mothers living at Hadnot Point, (2) small for gestational age for
infants born to mothers over 35 years old living at Tarawa Terrace, and
(3) small for gestational age for infants born to mothers with two or more
prior fetal losses living at Tarawa Terrace.^25 However, ATSDR officials
said they are reanalyzing the findings of this study because of an error
in the original assessment of exposure to VOCs in drinking water. While
the study originally assessed births from 1968 to 1972 in the Holcomb
Boulevard service area as being unexposed to VOCs, these births were
exposed to contaminants from the Hadnot Point water system. An ATSDR
official said the reanalysis may alter the study's results.

^21See 42 U.S.C. S 9607(a)(4)(D).

^22See 10 U.S.C. S 2704(c).

^23While conducting the health assessment, ATSDR also considered two other
types of past exposures at Camp Lejeune as possibly posing a public health
hazard: lead in tap water and pesticides in soil at a former day care
facility.

In 1999, ATSDR initiated its current study examining whether certain birth
defects and childhood cancers are associated with exposure to TCE or PCE
at Camp Lejeune. The study examines whether individuals born during 1968
through 1985 to mothers who were exposed to the contaminated drinking
water at any time while they were pregnant and living at Camp Lejeune were
more likely than those who were not exposed to have neural tube defects,
oral cleft defects, or childhood hematopoietic cancers.^26 The current
study began with a survey to identify potential cases of the selected
birth defects and childhood cancers. The study is also using water
modeling^27 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.

^24Although there was no evidence of an increased rate of adverse
pregnancy outcomes at Camp Lejeune at that time, the 1998 study report
states that the agency believed it was prudent to research this topic
because fetuses tend to be more sensitive to toxic chemical exposures and
many pregnant women had resided in housing areas supplied with
contaminated water. In addition to small for gestational age, other
adverse pregnancy outcomes evaluated in the study included pre-term birth
and mean birth weight.

^25U.S. Department of Health and Human Services, Agency for Toxic
Substances and Disease Registry, Volatile Organic Compounds in Drinking
Water and Adverse Pregnancy Outcomes (Atlanta, Ga.: 1998).

^26Childhood hematopoietic cancers include childhood leukemia and
non-Hodgkin's lymphoma.

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

Possible Adverse Health Effects of TCE and PCE

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

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

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

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, the
NACIP program identified VOCs, including TCE and PCE, in 12 of the wells
serving the Hadnot Point and Tarawa Terrace water systems. Camp Lejeune
officials removed 10 wells from service in 1984 and 1985. Additionally,
information about the contamination was provided to residents. Upon
investigating the contamination, DOD and North Carolina officials
concluded that both on- and off-base sources were likely to have caused
the contamination in the Hadnot Point and Tarawa Terrace water systems.
Since 1989, federal, state, and Camp Lejeune officials have partnered to
take actions to clean up the sources of contamination and to monitor and
protect the base's drinking water.

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

The presence of VOCs in Camp Lejeune water systems was first detected in
October 1980. On October 1, 1980, samples of water were collected from all
eight water systems at Camp Lejeune by an official from LANTDIV, a Navy
entity that provided environmental support to Camp Lejeune. The water
samples were combined into a single sample, and a "priority pollutant
scan" was conducted in order to detect possible contaminants in the water
systems. The results of this analysis, conducted by a 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

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

Separately, in 1980 the Navy began monitoring programs for TTHMs at
various Navy and Marine Corps bases, including Camp Lejeune, in
preparation for meeting a future EPA drinking water regulation.^31 LANTDIV
arranged for an Army laboratory to begin testing the treated water from
two Camp Lejeune water systems, Hadnot Point and New River, in October
1980. At that time, these two water systems were the only ones that served
more than 10,000 people and therefore would be required to meet the future
TTHM regulation. From October 1980 to September 1981, eight samples were
collected from the Hadnot Point water system and analyzed for TTHMs.
Results from four of the eight samples indicated the presence of
unidentified chemicals that were interfering with the TTHM analyses.^32
Reports for each of the four analyses contained an Army laboratory
official's handwritten notes about the unidentified chemicals: two of the
notes classified the water as "highly contaminated" and notes for the
other two analyses recommended analyzing the water for organic compounds.

The exact date when LANTDIV officials began receiving results from TTHM
testing is not known, and LANTDIV officials told us that they had no
recollection of how or when the results were communicated from the Army
laboratory. Available Marine Corps documents indicate that Camp Lejeune
environmental officials^33 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. 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.

^31According to an August 1980 memorandum, which cited a 1979 amendment to
the National Interim Primary Drinking Water Regulations, LANTDIV initiated
monitoring programs at various naval facilities, including Camp Lejeune,
in order to develop a TTHM database prior to the effective dates for the
enforcement of the maximum contaminant levels. For Camp Lejeune community
water systems such as Hadnot Point and New River that served 10,000 to
74,999 individuals, the maximum contaminant levels for TTHMs took effect
in November 1983 and an EPA requirement to begin monitoring TTHM levels in
the systems began 1 year prior to that date. See 44 Fed. Reg. 68641 (Nov.
29, 1979) (to be codified at 40 C.F.R. S 141.6).

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

^33In the early 1980s the environmental staff at Camp Lejeune consisted of
three primary staff members: a director specializing in natural resources,
a supervisory ecologist, and a chemist. These staff members were
responsible for water monitoring and compliance with environmental
regulations, among other responsibilities. Over time as environmental laws
have changed, the environmental staff has grown and obtained additional
responsibilities.

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

Following LANTDIV's recommendation to expand TTHM monitoring to all base
water systems, Camp Lejeune officials contracted with a private
state-certified laboratory to test samples of treated water from all eight
of their water systems. According to an August 1982 memorandum, in May
1982 a Camp Lejeune official was informed during a telephone conversation
with a private laboratory official that organic cleaning solvents,
including TCE, were present in the water samples for TTHM monitoring from
the Hadnot Point and Tarawa Terrace water systems. In July 1982,
additional water samples from the two systems were collected in an effort
to investigate the presence of these chemicals. In August 1982 the
contracted laboratory sent a letter to base officials informing them that
TCE and PCE were identified as the contaminants in the May and July
samples. According to the letter, the testing determined that the Hadnot
Point water system was contaminated with both TCE and PCE and the Tarawa
Terrace water system was contaminated with PCE. The letter also noted that
TCE and PCE "appeared to be at high levels" and were "more important from
a health standpoint" than the TTHM monitoring. Sampling results indicated
that the levels of TCE and PCE varied. The letter noted that one sample
taken in May 1982 from the Hadnot Point water system contained TCE at
1,400 parts per billion and two samples taken in July 1982 contained TCE
at 19 and 21 parts per billion. Four samples taken in May 1982 and July
1982 from the Tarawa Terrace water system contained levels of PCE that
ranged from 76 to 104 parts per billion. (See table 2 for the May and July
1982 sampling results.)

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

                                Concentrations of chemicals in parts per
                                                billion^a
Housing area   Samples^b                       TCE^c                 PCE^d 
May samples^e                                                              
Hadnot Point           1                       1,400                    15 
Tarawa Terrace         2                        --^f                    80 
July samples   
Hadnot Point           3                          19                       
                          4                          21                       
                          5                   No data^g                   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 that provided these
sampling results did not include the detection limit. The detection limit
is the lowest level at which the chemicals could be reliably identified by
the instruments being used.

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. For example, they attributed the higher levels to
short-term environmental exposures, such as spilled paint inside a water
treatment plant, or to laboratory or sampling errors. Additionally, in an
August 1982 memorandum, a Camp Lejeune environmental official suggested
that based on the sampling results provided by the private laboratory, the
levels of PCE detected could be the result of using coated pipes in the
untreated water lines at Tarawa Terrace. The former Camp Lejeune
environmental officials told us that in retrospect, it was likely that
well rotation in these water systems contributed to the varying sampling
results because the contaminated wells may not have been providing water
to the Hadnot Point and Tarawa Terrace systems at any given time. However,
both they and current Camp Lejeune environmental officials said that at
that time the base environmental staff did not know that the wells serving
both systems were rotated.

After August 1982, the private laboratory continued to communicate with
Camp Lejeune officials about the contamination of treated water from the
Hadnot Point and Tarawa Terrace water systems. All eight of Camp Lejeune's
water systems were sampled again for TTHMs in November 1982. In a December
1982 memorandum, a Camp Lejeune environmental official noted that during a
phone conversation with a chemist from the private laboratory the chemist
expressed concern that TCE and PCE were interfering with Tarawa Terrace
and Hadnot Point TTHM samples. The chemist said the levels of TCE and PCE
were "relatively high" in the November 1982 samples, though the specific
levels of TCE and PCE were not provided to Camp Lejeune officials. The
private laboratory report providing the November 1982 results said that
the samples from Tarawa Terrace "show contamination" from PCE and the
samples from Hadnot Point "show contamination" from both TCE and PCE. All
eight of Camp Lejeune's water systems were sampled again for TTHMs in
August 1983, and the private laboratory report providing these results
said that the samples from Tarawa Terrace "show contamination" from PCE
and the samples from Hadnot Point "show contamination" from both TCE and
PCE.^34 Former Camp Lejeune environmental officials recalled that they did
not take any actions related to these findings.

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

In 1982, Navy officials initiated the NACIP program at Camp Lejeune with
an initial assessment study, which was designed to collect and evaluate
evidence that indicated the existence of pollutants that may have
contaminated a site or that posed a potential health hazard for people
located on or off a military installation. The initial assessment study
determined that further investigation was warranted at 22 priority sites
and a confirmation study to investigate these sites was initiated in July
1984.

As a part of the confirmation study, a Navy contractor took water samples
from water supply wells located near priority sites where groundwater
contamination was suspected. Current and former Camp Lejeune officials
told us that previous water samples usually had been collected from
treated water at sites such as reservoirs or buildings within the water
systems rather than being collected directly from individual wells at Camp
Lejeune. In November 1984, Camp Lejeune officials received sampling
results for one Hadnot Point well located near a priority site, which
showed that TCE and PCE, among other VOCs, were detected in the well. This
well was removed from service, and in December 1984, water samples from
six Hadnot Point wells that were located in the same general area and
treated water samples from the Hadnot Point water plant were also tested.
Results of the analysis of the well samples indicated that both TCE and
PCE were detected in one well, TCE was detected in two additional wells,
and other VOCs were detected in all six wells. Results for the treated
water samples also detected TCE and PCE. Four of these six wells were
removed from service in addition to the original well removed from
service. For the two wells that were not taken out of service, while
initial results indicated levels of VOCs, including TCE, other test
results showed no detectable levels of VOCs. Documents we reviewed show
that continued monitoring of those two wells indicated no detectable
levels of TCE. During December 1984, seven additional samples were taken
from the treated water at Hadnot Point water plant and revealed no
detectable levels of TCE and PCE. According to two former Camp Lejeune
environmental officials, once the wells had been taken out of service and
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.

^34The reports of the November 1982 and August 1983 TTHM analyses did not
provide further details about the levels of TCE and PCE detected.

Although the December 1984 testing of water from the Hadnot Point water
system showed no detectable levels of TCE or PCE, in mid-January 1985 Camp
Lejeune environmental staff began collecting water samples from all wells
on the base. Sampling results were received in February 1985 and detected
VOCs, including TCE and PCE, in 3 wells serving the Hadnot Point water
system and 2 wells serving the Tarawa Terrace water system. As a result,
those 5 wells were removed from service. According to current Camp Lejeune
officials, all 10 wells had been removed from service by February 8, 1985.
According to memoranda dated March 1985 and May 1985, 1 of the 2 wells
removed from service at Tarawa Terrace was used on 1 day in March 1985 and
on 3 days in April 1985 for short periods of time to meet water needs at
the base. See table 3 for the dates that wells were removed from service
and for the levels of TCE and PCE that were detected in the wells prior to
their removal from service in 1984 and 1985. See app. I for the levels of
all VOCs that were detected in the wells prior to their removal from
service in 1984 and 1985.

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

                                              Concentrations of chemicals in
                                                   parts per billion^a
                            Date removed from                         
Water systems     Wells  service                     TCE^b          PCE^c
Hadnot Point        602  Nov. 30, 1984               1,600             24
                      601   Dec. 6, 1984                          210       5
                       608  Dec. 6, 1984                  110             ND
                     634^d  Dec. 14, 1984                  ND             ND
                     637^d  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-23^e   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.
I.)

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.^35 According to the notice:

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

The notice asked residents to reduce water use until early June, when the
construction of a new water line was to be completed. In May 1985, another
article in the base newspaper stated the number of wells that had been
removed from service, stated why the wells were removed from service, and
noted the potential for water shortage at Tarawa Terrace as a result. In
addition, the Marine Corps provided us with copies of three North Carolina
newspaper articles published from May 1985 to September 1985 discussing
contamination at Camp Lejeune.^36 All three articles included information
about the drinking water contamination and noted that 10 wells serving two
water treatment systems at Camp Lejeune had been removed from service.

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

Past Contamination Was Estimated to Have Originated from Both On-base and
Off-base Sources, and Cleanup Activities at These Sources Are Under Way

The sources of past contamination for the Hadnot Point water system have
not been conclusively determined. However, DOD officials have estimated
that eight contaminated on-base sites in the proximity of the Hadnot Point
water system may be the sources of contamination for that water system.
These eight sites were contaminated by leaking underground storage tanks
containing fuel, by degreasing solvents, by hazardous chemical spills, and
by other waste disposal practices.^37 Efforts by ATSDR are ongoing to
conclusively determine the sources of past contamination in the Hadnot
Point water system, as well as when the contamination began. For the
Tarawa Terrace water system, North Carolina officials determined that the
contamination likely came from a dry cleaning solvent that had been
released into a leaking septic tank at an off-base dry cleaning
facility--ABC One Hour Cleaners--which built its septic system and began
operation in 1954. Both the dry cleaning facility and its septic tank were
located off base but adjacent to a supply well for the Tarawa Terrace
water system. Based on the environmental contamination at this site, ABC
One Hour Cleaners was designated as a National Priorities List site in
1989. As part of its current health study, ATSDR has estimated that
beginning as early as 1957 individuals were exposed to PCE in treated
drinking water at levels equal to or greater than what became effective in
1992 as EPA's maximum contaminant level of 5 parts per billion.

Since 1989, officials from Camp Lejeune, North Carolina, and federal
agencies, including EPA, have taken actions to clean up the suspected
sources of the contamination in the Hadnot Point and Tarawa Terrace water
systems. Because the contamination is thought to have come from both on-
and off-base sources, and because those sources are part of two separate
National Priorities List sites--Camp Lejeune and ABC One Hour
Cleaners--cleanup activities for the suspected sources of contamination
are being managed separately. Cleanup activities have included the removal
of contaminated soils and gasoline storage tanks and the treatment of
contaminated groundwater and soils.

^36According to a May 1985 memorandum, Camp Lejeune officials issued a
press release regarding removal of wells from service at Camp Lejeune in
May 1985. However, the memorandum did not describe the contents of the
press release, and the Marine Corps was unable to locate a copy of the
press release for our review.

^37The sources of contamination at these eight sites were identified
through the NACIP program and the Installation Restoration Program, which
replaced NACIP as the Navy and Marine Corps environmental program.

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.

Funding of ATSDR's Camp Lejeune Work

ATSDR received funding from DOD for 13 of the 16 fiscal years during which
it has conducted its Camp Lejeune-related work, and ATSDR provided its own
funding for Camp Lejeune-related work during the other 3 years. Under
federal law and in accordance with a memorandum of understanding between
DOD and ATSDR, DOD is responsible for funding public health assessments
and any follow-up public health activities, such as health studies or
toxicological profiles related to DOD sites as agreed to in an annual plan
of work. For fiscal year 1997, funding for ATSDR's Camp Lejeune-related
work came from the Navy.

From fiscal year 1998 through fiscal year 2000, no funding was provided to
ATSDR by the Navy or any DOD entity for its Camp Lejeune-related work
because the agencies could not reach agreement about the funding for Camp
Lejeune. In June 1997, ATSDR proposed conducting a study of childhood
leukemia and birth defects associated with TCE and PCE exposure at Camp
Lejeune during fiscal years 1998 and 1999 at an estimated cost of almost
$1.8 million. In a July 1997 letter to the Navy, an ATSDR official noted
that during a June meeting the Navy appeared to be reluctant to fund the
proposed study; however, the official noted that DOD was liable for the
costs of the study under federal law. In an October 1997 letter responding
to ATSDR, a senior Navy official stated that the Navy did not believe it
should be required to fund ATSDR's proposed study because the cause of the
contamination was an off-base source, ABC One Hour Cleaners. The Navy
official said that it was more appropriate for ATSDR to seek funding for
the study from the responsible party that caused the contamination.^38
However, ATSDR officials told us that while they expected that the study
would focus primarily on contamination from the dry cleaner, the study was
also expected to include people who were exposed to on-base sources of
contamination. An ATSDR official reported that the agency submitted its
funding proposals for the Camp Lejeune study to DOD in each of the annual
plans of work from fiscal year 1998 to fiscal year 2000, but that during
that time period the agency received no DOD funding and funded its Camp
Lejeune-related work from general ATSDR funding.

In fiscal year 2001 the Navy resumed funding of ATSDR's Camp
Lejeune-related work. We could not determine why the Navy decided to
resume funding of ATSDR's work at that time. Since fiscal year 2003,
funding for ATSDR's Camp Lejeune-related work has been provided by the
Marine Corps. According to a DOD official, the Marine Corps has committed
to funding the current ATSDR study. The DOD official also noted that per a
supplemental budget request from ATSDR for fiscal year 2006, the Marine
Corps agreed to fund community assistance panel meetings and portions of a
feasibility assessment for future studies that will include
computerization of Camp Lejeune housing records.

Provision of Information to ATSDR by DOD

ATSDR has experienced some difficulties obtaining information from Camp
Lejeune and DOD officials. For example, while conducting its public health
assessment in September 1994, ATSDR sent a letter to the Department of the
Navy noting that ATSDR had had difficulties getting documents needed for
the public health assessment from Camp Lejeune, such as Remedial
Investigation^39 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.^40
Between February and April 1999, Headquarters Marine Corps facilitated
discussion between ATSDR and relevant DOD entities about these Privacy Act
concerns and some information was subsequently provided to ATSDR by DOD.
In April 2001, Headquarters Marine Corps sent a letter to the Defense
Privacy Office suggesting that the Defense Manpower Data Center had only
provided a limited amount of information to ATSDR.^41 However, in a July
2001 reply to Headquarters Marine Corps, the Defense Privacy Office noted
that it believed that relevant data had been provided to ATSDR by the
Defense Manpower Data Center in 1999 and 2001.

^38Additionally, the EPA Criminal Investigation Division, which conducted
an investigation related to the drinking water contamination at Camp
Lejeune, concluded that funding for the current study was apparently
delayed because of opposition characterized as a professional difference
of opinion as to the scientific value of the study by a midlevel manager
at the Navy Environmental Health Center.

^39A Remedial Investigation is performed at a site after it is listed on
the National Priorities List. The Remedial Investigation serves as a
mechanism for collecting data. Data collected during the Remedial
Investigation influence the development of remedial alternatives for the
site.

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.

^40The Privacy Act of 1974 provides safeguards for individuals against
invasions of privacy as a result of the collection of personal information
by the federal government. Pub. L. No. 93-579, S 3, 88 Stat. 1896, 1897
(codified as amended at 5 U.S.C. S 552a).

^41The Defense Privacy Office is responsible for implementation of DOD's
Privacy Program, which regulates how and when DOD collects, maintains,
uses, or disseminates personal information on individuals.

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.^42 For example, when some former residents learned during a
community assistance panel meeting that it took about 4 months for DOD to
respond to a supplemental budget request from ATSDR for fiscal year 2006,
they questioned DOD entities' commitment to ATSDR's Camp Lejeune-related
work. However, DOD and ATSDR officials described this delay in responding
as typical during the funding process.

^42The Marine Corps has issued multiple public statements indicating
support for ATSDR's work at Camp Lejeune.

Experts Convened by NAS Generally Agreed That Many Parameters of ATSDR's Current
Study Were Appropriate

The seven members of an expert panel convened by NAS at our request
generally agreed that specific parameters of ATSDR's current study were
appropriate, including the study population, the exposure time frame, and
the selected health effects. The expert panel members had mixed opinions
on ATSDR's projected completion date.

Study Population

The seven panel experts concurred that ATSDR logically limited its study
population to those individuals who were in utero while their mothers were
pregnant and lived at Camp Lejeune during the 1968 through 1985 time
frame, and who may have been exposed to the contaminated drinking
water.^43 The current study follows recommendations from the agency's 1997
public health assessment of Camp Lejeune, which noted that studies of
cancer among those who were exposed in utero should be conducted to
further the understanding of the health effects in this susceptible
population. Panel experts said that ideally a study would attempt to
include all individuals who were potentially exposed, but that limited
resources and data availability were practical reasons for limiting the
study population. Additionally, panel experts agreed that those exposed
while in utero were an appropriate study population because they could be
considered at higher risk of adverse health outcomes than others, such as
those exposed as children or adults. In addition, two panel experts said
that studying only those who lived on base was reasonable because they
likely had a higher risk of inhalation exposure to VOCs such as TCE and
PCE, which may be more potent than ingestion exposure.^44 Thus, pregnant
women who lived in areas of base housing with contaminated water and
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.

^43ATSDR's current study population of those individuals who were in utero
includes individuals whom ATSDR determined were exposed during specific
time periods of the mother's pregnancy or after their birth to
contaminated drinking water because they lived in an area that was served
by the Hadnot Point or Tarawa Terrace water systems, and those that ATSDR
determined through its study analysis were not exposed because they did
not live in those areas or were not exposed during specific time periods.

^44According to ATSDR, inhalation of TCE and PCE that have evaporated from
drinking water is likely to result in higher exposures than ingestion.
Additionally, 1991 EPA guidance on estimating exposure to VOCs during
showering noted that scientific studies found that this exposure is
approximately equivalent to exposure from ingesting two liters of the
contaminated water per day.

Study Time Frame

The seven panel experts agreed that the 1968 through 1985 study time frame
was reasonable, based on limitations in data availability. This time frame
was adopted from ATSDR's 1998 study of adverse pregnancy outcomes, which
limited the study population to include those potentially exposed between
1968 and 1985. According to ATSDR's study protocol, these years were
chosen because 1968 was the first year that birth certificates were
computerized in North Carolina and 1985 was when the affected water wells
were removed from service. Four of the panel experts said they did not see
any benefit in using an earlier start date than 1968 because collecting
birth records before 1968 could require a significant amount of resources
to collect data. In addition, while the initial exposure to contaminated
drinking water may have occurred as early as the 1950s, at the time the
ATSDR study time frame was selected officials were unable to determine
precisely when the contamination began. Four of the panel experts
commented that exposure was likely highest in the latter part of the study
time frame--presumably, they said, as a result of a higher accumulated
level of contamination over time--thus making the uncertainty of when the
contamination began less significant and supporting ATSDR's decision to
study the later time frame.

Study Health Effects

The five panel experts who discussed health effects said that those
selected for the study were valid for individuals who were potentially
exposed in utero at Camp Lejeune.^45 Based on previous ATSDR work and
existing literature, the health effects chosen for the study were neural
tube defects, oral cleft defects, and childhood hematopoietic cancers,
including leukemia and non-Hodgkin's lymphoma.^46 Two panel experts said
that ATSDR had limited its study to health effects that are rare and that
generally occur at higher levels of exposure to VOCs such as TCE and PCE
than are expected to have occurred at Camp Lejeune. They said that this
may result in ATSDR not identifying enough individuals with these health
effects to determine meaningful results in the study.^47

45The two panel experts who did not discuss health effects said that this
discussion was outside their areas of expertise. One expert is a professor
of geochemistry and the second is an environmental engineer.

^46An ATSDR document listing frequently asked questions about its health
study states that the agency chose to study these birth defects and
cancers based on the results of previous studies; two previous studies
suggested that the chemicals in the drinking water at Camp Lejeune might
cause these birth defects, while three studies suggested that these
chemicals in drinking water might cause childhood leukemia. Additionally,
ATSDR's study protocol noted that ATSDR's study could add to the body of
scientific knowledge.

Study Completion Date

ATSDR has projected a December 2007 completion date for the study, which
would include activities such as identifying and enrolling study
participants, conducting a parental interview, confirming each reported
diagnosis, modeling the water system to quantify the amount and extent of
each individual's exposure, analyzing the data, and drafting a final
report. Panel experts had mixed opinions regarding ATSDR's completion
date. Of the five panel experts who commented on the proposed completion
date, three said that the date appeared reasonable, and two others said
that based on the complexity of the water modeling the projected
completion date might be optimistic.^48

Mr. Chairman, this completes my prepared statement. I would be happy to
respond to any question you or other Members of the Subcommittee may have
at this time.

Contacts and Acknowledgments

For further information about this testimony, please contact Marcia Crosse
at (202) 512-7119 or [email protected]. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last page
of this testimony. Bonnie Anderson, Assistant Director; Karen Doran,
Assistant Director; Danielle Organek; and Christina Ritchie made key
contributions to this testimony.

^47ATSDR's public health assessment noted that the exposure levels
experienced at Camp Lejeune were expected to be relatively low and
experienced over a relatively short duration.

^48One of the panel experts did not discuss the completion date of the
study. A second expert said he did not have sufficient data to make a
determination on whether the projected completion date was reasonable.

Appendix I: Volatile Organic Compounds Detected in Wells at Hadnot Point
and Tarawa Terrace Water Systems 

                                      Concentrations of chemicals in parts per billion^a
                Date                                                                                    
                removed                                                                                 
Water           from                                                     Methylene                Vinyl 
systems   Wells service TCE^b PCE^c Benzene^d Trans-1,2-DCE^e 1,1-DCE^f chloride^g Toluene^h chloride^i 
Hadnot      602 Nov.    1,600    24       120             630       2.4         --       5.4         18 
Point           30,                                                                                     
                1984                                                                                    
            601 Dec. 6,  210      5                ND                88     ND            ND         ND ND 
                1984                                                                                       
            608 Dec. 6,   110    ND       3.7             5.4        ND         ND        ND         ND 
                1984                                                                                    
            634 Dec.       ND    ND        ND             2.3        --        130        --         ND 
                14,                                                                                     
                1984                                                                                    
            637 Dec.       ND    ND        ND              ND        --        270        --         -- 
                14,                                                                                     
                1984                                                                                    
            651 Feb. 4, 3,200   386        --           3,400       187         --        --        655 
                1985                                                                                    
            652 Feb. 8,     9    ND        --              ND        ND         --        --         ND 
                1985                                                                                    
            653 Feb. 8,   5.5    ND        --              ND        ND         --        --         ND 
                1985                                                                                    
Tarawa    TT-26 Feb. 8,    57 1,580        ND              92        --         --        --         27 
Terrace         1985                                                                                    
        TT-23^j Feb. 8,   ND    132                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.

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.

dBenzene 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.

eTrans-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.

f1,1-dichloroethylene (1,1-DCE) is an organic liquid with a mild, sweet,
chloroform-like odor. Virtually all of it is used in making adhesives,
synthetic fibers, refrigerants, food packaging, and coating resins. EPA
has found 1,1-DCE to potentially cause liver damage when people are
exposed to it at levels above 7 parts per billion for relatively short
periods of time. In addition, 1,1-DCE has the potential to cause liver and
kidney damage as well as toxicity to the developing fetus and cancer from
a lifetime exposure at levels above 7 parts per billion.

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

hToluene 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.

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

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

(290641)

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

To view the full product, including the scope
and methodology, click on the link above.

For more information, contact Marcia Crosse at (202) 512-7119 or
[email protected].

Highlights of [32]GAO-07-933T , a testimony before the Subcommittee on
Oversight and Investigations, Committee on Energy and Commerce, House of
Representatives

June 12,2007

DEFENSE HEALTH CARE

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

In the early 1980s, volatile organic compounds (VOC) were discovered in
some of the water systems serving housing areas on Marine Corps Base Camp
Lejeune. Exposure to certain VOCs may cause adverse health effects,
including cancer. Since 1991, the Department of Health and Human Services'
Agency for Toxic Substances and Disease Registry (ATSDR) has been
examining whether individuals who were exposed to the contaminated
drinking water are likely to have adverse health effects. ATSDR's current
study is examining whether individuals who were exposed in utero are more
likely to have developed certain childhood cancers or birth defects.

GAO was asked to testify on its May 11, 2007 report: Defense Health Care:
Activities Related to Past Drinking Water Contamination at Marine Corps
Base Camp Lejeune (GAO-07-276). This testimony summarizes findings from
the report about (1) efforts to identify and address the past drinking
water contamination, (2) the provision of funding and information from the
Department of Defense (DOD) to ATSDR, and (3) an assessment of the design
of the current ATSDR study. GAO reviewed documents, interviewed officials
and former residents, and contracted with the National Academy of Sciences
to convene an expert panel to assess the current ATSDR study.

Efforts to identify and address the past drinking water contamination at
Camp Lejeune began in the 1980s, when Navy water testing at Camp Lejeune
detected VOCs in some base water systems. In 1982 and 1983, continued
testing identified two VOCs--trichloroethylene (TCE), a metal degreaser,
and tetrachloroethylene (PCE), a dry cleaning solvent--in two water
systems that served base housing areas, Hadnot Point and Tarawa Terrace.
In 1984 and 1985 a Navy environmental program identified VOCs, such as TCE
and PCE, in some of the individual wells serving the Hadnot Point and
Tarawa Terrace water systems. Ten wells were subsequently removed from
service. DOD and North Carolina officials concluded that on- and off-base
sources were likely to have caused the contamination. It has not been
determined when contamination at Hadnot Point began. ATSDR has estimated
that well contamination at Tarawa Terrace from an off-base dry cleaner
began as early as 1957.

Since ATSDR began its Camp Lejeune-related work in 1991, the agency has
not always received requested funding and has experienced delays in
receiving information from DOD. However, ATSDR officials said that while
funding and access to records were probably slowed down and made more
expensive by DOD officials' actions, their actions did not significantly
impede ATSDR's Camp Lejeune-related health study efforts. The ATSDR
officials also stated that while issues such as limitations in access to
DOD data had to be addressed, such situations are normal during the course
of a study.

Members of the expert panel that the National Academy of Sciences convened
for GAO generally agreed that many parameters of ATSDR's current study are
appropriate, including the study population, the exposure time frame, and
the selected health effects. Regarding the study's proposed completion
date of December 2007, the panel experts had mixed opinions: three of the
five panel experts who commented said that the projected date appeared
reasonable, while two said that the date might be optimistic.

DOD, the Environmental Protection Agency, and the Department of Health and
Human Services provided technical comments on a draft of the May 11, 2007
report, which GAO incorporated where appropriate. Three members of an
ATSDR community assistance panel for Camp Lejeune provided oral comments
on issues such as other VOCs that have been detected at Camp Lejeune, and
compensation, health benefits, and additional notification for former
residents. GAO focused its review on TCE and PCE because they were
identified by ATSDR as the chemicals of primary concern. GAO's report
notes that other VOCs were detected. GAO incorporated the panel members'
comments where appropriate, but some issues were beyond the scope of the
report.

References

Visible links
  24. http://www.gao.gov/cgi-bin/getrpt?GAO-07-276
  25. http://www.gao.gov/
  26. http://www.gao.gov/
  27. http://www.gao.gov/fraudnet/fraudnet.htm
  28. mailto:[email protected]
  29. mailto:[email protected]
  30. mailto:[email protected]
  31. http://www.gao.gov/cgi-bin/getrpt?GAO-07-933T
  32. http://www.gao.gov/cgi-bin/getrpt?GAO-07-933T
*** End of document. ***