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entitled 'Defense Health Care: Activities Related to Past Drinking 
Water Contaminating at Marine Corps Base Camp Lejeune' which was 
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Report to Congressional Committees: 

United States Government Accountability Office: 

GAO: 

May 2007: 

Defense Health Care: 

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

GAO-07-276: 

GAO Highlights: 

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

Why GAO Did This Study: 

In the early 1980s, volatile organic compounds (VOCs) were discovered 
in some of the water systems serving housing areas on Marine Corps Base 
Camp Lejeune. Exposure to certain VOCs may cause adverse health 
effects, including cancer. In 1999, the Department of Health and Human 
Services’ (HHS) Agency for Toxic Substances and Disease Registry 
(ATSDR) began a study to examine whether individuals who were exposed 
in utero to the contaminated drinking water are more likely to have 
developed certain childhood cancers or birth defects. ATSDR has 
projected a December 2007 completion date for the study. 

The National Defense Authorization Act of Fiscal Year 2005 required GAO 
to report on past drinking water contamination and related health 
effects at Camp Lejeune. In this report GAO describes (1) efforts to 
identify and address the past contamination, (2) activities resulting 
from concerns about possible adverse health effects and government 
actions related to the past contamination, and (3) the design of the 
current ATSDR study, including the study’s population, time frame, 
selected health effects, and the reasonableness of the projected 
completion date. GAO reviewed documents, interviewed officials and 
former residents, and contracted with the National Academy of Sciences 
to convene an expert panel to assess the design of the current ATSDR 
study. 

What GAO Found: 

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

Activities related to concerns about possible adverse health effects 
began in 1991, when ATSDR initiated a public health assessment 
evaluating the possible health risks from exposure to the contaminated 
drinking water. The health assessment was followed by two health 
studies, one of which is ongoing. While ATSDR did not always receive 
requested funding and experienced delays in receiving information from 
DOD for its Camp Lejeune-related work, ATSDR officials said this has 
not significantly delayed their work. Former residents and employees 
have filed about 750 claims against the federal government. 
Additionally, three federal inquiries into issues related to the 
contamination have been conducted—one by a Marine Corps-chartered panel 
and two by the Environmental Protection Agency (EPA). 

Members of the expert panel that the National Academy of Sciences 
convened generally agreed that many parameters of ATSDR’s current study 
are appropriate, including the study population, the exposure time 
frame, and the selected health effects. ATSDR’s study is examining 
whether individuals who were exposed in utero to the contaminated 
drinking water at Camp Lejeune between 1968 and 1985 were more likely 
to have specific birth defects or childhood cancers than those not 
exposed. 

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

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-276]. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Marcia Crosse at (202) 
512-7119 or crossem@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

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

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

Experts Convened by NAS Generally Agreed That Many Parameters of 
ATSDR's Current Study Were Appropriate but Some Experts Suggested 
Potential Modifications to the Study: 

Agency Comments: 

Appendix I: Scope and Methodology: 

Appendix II: Selected Events Related to Past Drinking Water 
Contamination at Camp Lejeune from 1980 through 1981: 

Appendix III: Selected Events Related to Past Drinking Water 
Contamination at Camp Lejeune from 1982 through 1983: 

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

Appendix V: Selected Events Related to Past Drinking Water 
Contamination at Camp Lejeune from 1984 through 1985: 

Appendix VI: Agency for Toxic Substances and Disease Registry's 
Response to its 2005 Scientific Advisory Panel's Recommendations: 

Appendix VII: Description of Current Agency for Toxic Substances and 
Disease Registry (ATSDR) Health Study: 

Appendix VIII: GAO Contact and Staff Acknowledgments: 

Tables: 

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

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

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: 

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

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

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

Figures: 

Figure 1: Conceptual Model of a Camp Lejeune Water System: 

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

Abbreviations: 

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

United States Government Accountability Office: 
Washington, DC 20548: 

May 11, 2007: 

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

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

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

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

In the early 1980s, Department of the Navy water testing at Marine 
Corps Base Camp Lejeune identified contamination in water systems that 
served housing areas on the base.[Footnote 1] Further water testing 
revealed that some of the individual wells serving two of the water 
systems were contaminated with volatile organic compounds (VOCs), such 
as trichloroethylene (TCE), which is a metal degreaser and an 
ingredient in adhesives and paint removers, and tetrachloroethylene 
(PCE), which is a solvent used in the textile industry and a dry 
cleaning solvent. By 1985, 10 wells that were determined to be 
contaminated with VOCs had been removed from service.[Footnote 2] 
Although it is not known precisely when the wells became contaminated, 
the Department of Health and Human Services' (HHS) Agency for Toxic 
Substances and Disease Registry (ATSDR), which is investigating the 
issue, has estimated that the contamination may have begun as early as 
the 1950s. According to ATSDR, the VOCs of primary concern at Camp 
Lejeune were TCE and PCE, and the agency notes that exposure to these 
chemicals may cause adverse health effects. For example, exposure to 
low levels of TCE may cause headaches and difficulty 
concentrating.[Footnote 3] Exposure to high levels of both TCE and PCE 
may cause dizziness, headaches, nausea, unconsciousness, cancer, and 
possibly death.[Footnote 4] 

As required by federal law,[Footnote 5] ATSDR conducted a public health 
assessment at Camp Lejeune after the Environmental Protection Agency 
(EPA) designated the base as a National Priorities List[Footnote 6] 
site in 1989. The health assessment recommended that studies be 
conducted to evaluate the risks of childhood cancer related to VOC 
exposure at Camp Lejeune and noted that adverse pregnancy outcomes were 
also of concern.[Footnote 7] The first study based on the health 
assessment was released in 1998[Footnote 8] and found a statistically 
significant association between exposure and some adverse pregnancy 
outcomes. In 1999, ATSDR initiated a second study that currently is 
examining whether individuals who were exposed in utero (i.e., as 
developing fetuses during gestation) and as infants up to 1 year of age 
to the contaminated drinking water at Camp Lejeune between 1968 and 
1985 are more likely to have developed specific childhood cancers or 
birth defects than those who were not exposed. ATSDR has projected a 
December 2007 completion date for the study. In addition to ATSDR's 
Camp Lejeune-related work, three inquiries into the issues related to 
the past drinking water contamination have been conducted, one by a 
Marine Corps-chartered panel, one by EPA's Office of Inspector General 
(OIG), and one by EPA's Criminal Investigation Division (CID). 

Former residents of Camp Lejeune have taken legal action against the 
federal government for injuries alleged to have resulted from exposure 
to the contaminated water. In addition, some former residents have 
expressed concern over the Marine Corps' handling of and response to 
the drinking water contamination, noting that even though contaminants 
were detected as early as 1980, the wells that were determined to be 
contaminated were not removed from service until 1985. Some former 
residents have also asserted that there have been delays in the 
provision of funding and information from the Department of Defense 
(DOD) to ATSDR,[Footnote 9] and have said that DOD and EPA's responses 
to their requests for drinking water contamination-related documents 
have sometimes been inadequate. Finally, some former residents have 
raised concerns about various aspects of ATSDR's ongoing study, 
including whether the study population, time frame, and selected health 
effects are too limited to adequately represent those who were 
potentially affected, and about ATSDR's projected December 2007 study 
completion date because the federal government plans to wait to 
adjudicate their claims until the study is complete. 

The Ronald W. Reagan National Defense Authorization Act of Fiscal Year 
2005 directed that we study and report on the past drinking water 
contamination and related adverse health effects at Camp Lejeune, 
including identifying the type, source, and duration of the 
contamination, determining the actions taken to address the 
contamination, and assessing the current ATSDR health study.[Footnote 
10] The act also requires that our study consider information and 
opinions from individuals who lived and worked at Camp Lejeune during 
the period when the drinking water may have been contaminated. As 
discussed with the committees of jurisdiction, in this report we 
examine the history of events related to drinking water contamination 
at Camp Lejeune. Specifically, we (1) examine efforts to identify and 
address the past contamination; (2) describe activities resulting from 
concerns about possible adverse health effects and government actions 
related to the past contamination, such as the current ATSDR health 
study; and, (3) describe an assessment by an independent panel of 
experts of the design of the current ATSDR health study, including the 
study's population, the exposure time frame, selected health effects 
being measured, and the reasonableness of the projected completion 
date. 

To examine efforts to identify and address the past 
contamination,[Footnote 11] we reviewed more than 1,600 documents 
related to past and current drinking water activities at Camp Lejeune. 
We focused our review on the past TCE and PCE contamination because 
ATSDR had noted that these chemicals were the VOCs of primary concern 
at Camp Lejeune. However, we also reviewed documentation regarding 
other VOCs detected at Camp Lejeune. We interviewed current and former 
officials from various DOD entities, including Camp Lejeune, 
Headquarters Marine Corps, and the Department of the Navy, to obtain 
information about the history of events related to the past drinking 
water contamination at Camp Lejeune, including efforts to identify and 
address the contamination. The current and former officials interviewed 
often provided information based on their memory of events that 
occurred more than 20 years ago. We attempted to corroborate their 
testimonial evidence with documentation whenever possible. The former 
officials we interviewed were responsible for environmental activities 
at Camp Lejeune or the Department of the Navy during the time in which 
the contamination was detected. The current officials we interviewed 
are responsible for environmental activities at Camp Lejeune, 
Headquarters Marine Corps, or the Department of the Navy. Some of these 
current officials were also responsible for environmental activities 
during the time in which the contamination was detected. We also met 
with 19 interested former residents and individuals who worked on the 
base during the 1960s, 1970s, and 1980s, in order to obtain their 
perspective on historical events and to learn about their concerns 
related to the drinking water contamination. A former resident who is 
active in matters related to the past drinking water contamination at 
Camp Lejeune identified most of the interested former residents; others 
were identified at an ATSDR public meeting. Additionally, we examined 
reports from and interviewed officials with EPA and with the North 
Carolina Department of Environment and Natural Resources who were 
knowledgeable about activities and costs related to the cleanup of the 
suspected sources of contamination. 

To describe activities resulting from concerns about the possible 
adverse health effects and government actions related to past drinking 
water contamination, including efforts to study potential health 
effects and federal inquiries into the response to the contamination, 
we reviewed documents, interviewed agency officials, and attended 
agency meetings. To examine the activities undertaken by ATSDR to study 
possible adverse health effects related to the drinking water 
contamination, we interviewed ATSDR officials and reviewed ATSDR's Camp 
Lejeune-related documents and publications, including the 1997 public 
health assessment and the ATSDR health study released in 1998. We did 
not evaluate the methodology or findings of the health assessment or 
health study. We also attended the meetings and reviewed the reports of 
expert review panels convened by ATSDR in 2005 regarding improving the 
study's water modeling efforts and future studies of health effects. We 
attended the February and April 2006 meetings of the ATSDR community 
assistance panel which is made up of seven former residents of Camp 
Lejeune. We also reviewed meeting transcripts from the July and 
September 2006 meetings. We also interviewed officials with the 
Department of the Navy and the U.S. Army Center for Health Promotion 
and Preventive Medicine, which serves as a liaison between DOD and 
ATSDR. We also interviewed officials with the Department of the Navy 
Judge Advocate General and the Department of Justice regarding the 
status of the legal claims related to Camp Lejeune. To describe the 
three federal inquiries into issues related to the drinking water 
contamination, we reviewed the reports of a Marine Corps panel, the EPA 
OIG, and the EPA CID, and we interviewed EPA officials. 

To assess the design of the current ATSDR health study, we contracted 
with the National Academy of Sciences (NAS) to convene a panel of seven 
subject area experts for a 1-day meeting on July 29, 2005. The expert 
panel was charged with evaluating the study's population, exposure time 
frame, selected health effects, and completion date. For the assessment 
of the ATSDR study, we relied primarily on information gleaned from the 
expert panel meeting and the panel experts' subsequent written 
responses to the set of questions that were discussed during the 1-day 
meeting. Panel members were invited as individual experts, not as 
organizational representatives, and were not asked to reach consensus 
on any topics. NAS was not asked to provide advice or produce any 
report, and the comments made during the meeting of the expert panel 
should not be interpreted to represent the views of NAS, of the 
organizations with which the panel members were affiliated, or of all 
experts regarding health studies related to drinking water 
contamination. Not all panel members commented individually about each 
of the questions discussed during the 1-day meeting. Additionally, some 
panel members noted that certain questions addressed subjects that were 
outside their areas of expertise. We also reviewed study-related 
documentation furnished by officials from ATSDR, Marine Corps, and Navy 
Environmental Health Center, and interviewed officials from those 
agencies. We conducted our work from May 2005 through April 2007 in 
accordance with generally accepted government auditing standards. (See 
app. I for further detail on our scope and methodology.) 

Results in Brief: 

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

Concerns about possible adverse health effects and government actions 
related to the past drinking water contamination have led to additional 
activities, including health studies, claims against the federal 
government, and federal inquiries. From 1991 to 1997, ATSDR conducted a 
public health assessment at Camp Lejeune. The assessment recommended 
that studies be carried out to evaluate the risks of childhood cancer 
related to exposure to the contaminated drinking water. In 1998, an 
ATSDR study found a statistically significant association between 
exposure to the contaminated drinking water at Camp Lejeune and some 
adverse pregnancy outcomes, such as small for gestational age.[Footnote 
12] In 1999, ATSDR began its current study to determine whether 
individuals who were exposed in utero and as infants up to 1 year of 
age to the contaminated drinking water at Camp Lejeune between 1968 and 
1985 were more likely to have developed specific birth defects or 
childhood cancers. Since ATSDR began its Camp Lejeune-related work in 
1991, the agency has not always received requested funding and 
experienced delays in receiving information from DOD. For example, for 
3 of the 16 fiscal years during which ATSDR has conducted its Camp 
Lejeune-related work (fiscal years 1998 through 2000), no funding was 
provided to ATSDR by the Navy or any DOD entity. However, ATSDR 
officials said that these funding and information issues had not 
significantly delayed ATSDR's work at Camp Lejeune. Former Camp Lejeune 
residents and employees have filed about 750 tort claims against the 
federal government for injuries alleged to have resulted from exposure 
to the contaminated drinking water. Additionally, three federal 
inquiries into issues related to the drinking water contamination at 
Camp Lejeune have been conducted--one in 2004 by a Marine Corps- 
chartered panel, one in 2005 by the EPA OIG, and one from 2003 through 
2005 by the EPA CID. The inquiry conducted by the Marine Corps- 
chartered panel found that the Marine Corps acted responsibly and found 
no evidence that the Marine Corps had attempted to cover up information 
that indicated contamination in Camp Lejeune's drinking water. However, 
the Marine Corps-chartered panel also criticized some actions taken by 
Camp Lejeune and Department of the Navy officials, such as inadequate 
communications among these entities about the drinking water 
contamination. The EPA OIG found that some EPA officials' responses to 
a citizen's requests regarding Camp Lejeune-related documents were 
inadequate or inappropriate. The EPA CID investigation did not find any 
violations of federal law but criticized some actions taken by Marine 
Corps and Department of the Navy officials, such as a lack of diligence 
by a Navy environmental support entity in providing technical expertise 
to Camp Lejeune's environmental officials. 

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

DOD, EPA, and HHS provided technical comments on a draft of this 
report, which we incorporated where appropriate. We provided the seven 
former Camp Lejeune residents who are members of the ATSDR community 
assistance panel for Camp Lejeune the opportunity to provide comments 
on our draft--three of the panel members provided both technical and 
general oral comments, and four declined to review the draft report. 
The three panel members commented generally on issues such as VOCs 
other than TCE and PCE that have been detected at Camp Lejeune, 
compensation and health benefits for former residents, and additional 
notification for former residents. We incorporated the panel members' 
technical comments where appropriate, but some issues they discussed 
were beyond the scope of this report. 

Background: 

Drinking water can come from either groundwater sources, via wells, or 
from surface water sources such as rivers, lakes, and streams. All 
sources of drinking water contain some naturally occurring 
contaminants. As water flows in streams, sits in lakes, and filters 
thorough layers of soil and rock in the ground, it dissolves or absorbs 
the substances that it touches. Some of these contaminants are 
harmless, but others can pose a threat to drinking water, such as 
improperly disposed-of chemicals, pesticides, and certain naturally 
occurring substances. Likewise, drinking water that is not properly 
treated or disinfected, or which travels through an improperly 
maintained water system, may pose a health risk. However, the presence 
of contaminants does not necessarily indicate that water poses a health 
risk--all drinking water may reasonably be expected to contain at least 
small amounts of some contaminants. As of July 2006, EPA had set 
standards for approximately 90 contaminants in drinking water that may 
pose a risk to human health. According to EPA, water that contains 
small amounts of these contaminants, as long as they are below EPA's 
standards, is safe to drink. However, EPA notes that people with 
severely compromised immune systems and children may be more vulnerable 
to contaminants in drinking water than the general population. 

General Information about Camp Lejeune and Its Water Systems: 

Camp Lejeune began operations in the 1940s. The base covers 
approximately 233 square miles in Onslow County, North Carolina, and 
includes training schools for infantry, engineers, service support, and 
medical support, as well as a Naval Hospital and Naval Dental Center. 
Base housing at Camp Lejeune consists of enlisted family housing, 
officer family housing, and bachelor housing, which consists of 
barracks for unmarried service personnel. The base has nine family 
housing areas, and families live in base housing for an average of 2 
years. Additionally, schools, day care centers, and administrative 
offices are located on the base. Approximately 54,000 people currently 
live and work at Camp Lejeune, including about 43,000 active duty 
personnel and 11,000 military dependents and civilian employees. 

In the 1980s, Camp Lejeune obtained its drinking water from as many as 
eight water systems, which were fed by more than 100 individual wells 
that pumped water from a freshwater aquifer located approximately 180 
feet below the ground. Each of Camp Lejeune's water systems included 
wells, a water treatment plant, reservoirs, elevated storage tanks, and 
distribution lines to provide the treated water to the systems' 
respective service areas. Drinking water at Camp Lejeune has been 
created by combining and treating groundwater from multiple individual 
wells that are rotated on and off, so that not all wells are providing 
water to the system at any given time. Water is treated in order to 
remove minerals and particles and to protect against microbial 
contamination. (See fig. 1 for a description of how a Camp Lejeune 
water system operates.) 

Figure 1: Conceptual Model of a Camp Lejeune Water System: 

[See PDF for image] 

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

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

[End of figure] 

From the 1970s through 1987, Hadnot Point, Tarawa Terrace, Holcomb 
Boulevard, and Rifle Range water systems provided drinking water to 
most of Camp Lejeune's housing areas. (See fig. 2 for the locations of 
these water service areas.) The water treatment plants for the Hadnot 
Point and Tarawa Terrace water systems were constructed during the 
1940s and 1950s. The Rifle Range water system was constructed in 1965. 
The water treatment plant for the Holcomb Boulevard water system began 
operating at Camp Lejeune in 1972; prior to this time, the Hadnot Point 
water system provided water to the Holcomb Boulevard service area. In 
the 1980s, each of these four systems had between 4 and 35 wells that 
could provide water to their respective service areas. In 1987 the 
Tarawa Terrace water treatment plant was shut down and the Holcomb 
Boulevard water distribution system was expanded to include the Tarawa 
Terrace water service area. 

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

[See PDF for image] 

Source: ATSDR. 

[End of figure] 

Generally, housing units served by the Tarawa Terrace and Holcomb 
Boulevard water systems consisted of family housing, which included 
single-and multifamily homes and housing in trailer parks. Housing 
units served by the Hadnot Point water system included mainly bachelor 
housing with limited family housing. The housing area served by the 
Rifle Range water system included both family housing and bachelor 
housing. Based on available housing data for the late 1970s and the 
1980s,[Footnote 13] the estimated annual averages of the number of 
people living in family housing units[Footnote 14] served by these 
water systems at that time were: 

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

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

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

* 14 people in units served by the Rifle Range water system. 

In addition to serving housing units, all four water systems provided 
water to base administrative offices. The Tarawa Terrace, Holcomb 
Boulevard, and Hadnot Point water systems also served schools and other 
recreational areas. Additionally, the Hadnot Point water system also 
served an industrial area and the base hospital, and the Rifle Range 
water system also served an area used for weapons training. 

Department of the Navy Environmental Functions: 

The Department of the Navy consists of the Navy and the Marine Corps; 
consequently, certain Navy entities provide support functions for 
Marine Corps bases, such as Camp Lejeune. Two entities provide support 
for environmental issues: 

* 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.[Footnote 15] For example, 
LANTDIV officials work with Camp Lejeune officials to establish 
environmental cleanup priorities and cost estimates and to allocate 
funding to ensure compliance with state and federal environmental 
regulations. 

* 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. 

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

EPA was established in 1970 to consolidate in one agency a variety of 
federal research, monitoring, standard-setting, and enforcement 
activities to ensure environmental protection. EPA's primary roles and 
functions include developing and enforcing environmental regulations; 
conducting environmental research; providing financial assistance to 
states, educational institutions, and other nonprofit entities that 
conduct environmental research; and furthering public environmental 
education. 

Congress passed the Safe Drinking Water Act in 1974[Footnote 16] 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[Footnote 17] have had primary 
responsibility for implementation of the Safe Drinking Water Act in 
North Carolina since 1980. 

In 1979, EPA promulgated final regulations applicable to certain 
community water systems establishing the maximum contaminant levels for 
the control of TTHMs, which are a type of VOC that are formed when 
disinfectants--used to control disease-causing contaminants in drinking 
water--react with naturally occurring organic matter in water. The 
regulations required that water systems that served more than 10,000 
people and which added a disinfectant as part of the drinking water 
treatment process to begin mandatory water testing for TTHMs by 
November 1982 and comply with the maximum contaminant level by November 
1983. TCE and PCE were not among the contaminants included in these 
regulations. 

In 1979 and 1980 EPA issued nonenforceable guidance establishing 
"suggested no adverse response levels" for TCE and PCE in drinking 
water and in 1980 issued "suggested action guidance" for PCE in 
drinking water.[Footnote 18] Suggested no adverse response levels 
provided EPA's estimate of the short-and long-term exposure to TCE and 
PCE in drinking water for which no adverse response would be observed 
and described the known information about possible health risks for 
these chemicals. Suggested action guidance recommended remedial actions 
within certain time periods when concentrations of contaminants 
exceeded specific levels. Suggested action guidance was issued for PCE 
related to drinking water contamination from coated asbestos-cement 
pipes, which were used in water distribution lines. 

The initial regulation of TCE and PCE under the Safe Drinking Water Act 
began in 1989 and 1992, respectively, when maximum contaminant levels 
became effective for these contaminants. (See table 1 for the suggested 
no adverse response levels, suggested action guidance, and maximum 
contaminant level regulations for TCE and PCE.) 

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

Chemical: TCE; 
Nonenforceable guidance: Suggested no adverse response level[A] for 
various exposure periods in parts per billion (ppb) issued in 1979 
(TCE) and 1980 (PCE): 1-Day[D]: 2,000; 
Nonenforceable guidance: Suggested no adverse response level[A] for 
various exposure periods in parts per billion (ppb) issued in 1979 
(TCE) and 1980 (PCE): 10-Day[E]: 200; 
Nonenforceable guidance: Suggested no adverse response level[A] for 
various exposure periods in parts per billion (ppb) issued in 1979 
(TCE) and 1980 (PCE): Long-term[F]: 75; 
Nonenforceable guidance: Suggested action guidance[B] for various 
exposure periods in ppb issued in 1980 (PCE): 1-Day[D]: N/A[G]; 
Nonenforceable guidance: Suggested action guidance[B] for various 
exposure periods in ppb issued in 1980 (PCE): 10-Day[E]: N/A[G]; 
Nonenforceable guidance: Suggested action guidance[B] for various 
exposure periods in ppb issued in 1980 (PCE): Long-term[F]: N/A[G]; 
Enforceable regulation: Maximum contaminant level in milligrams per 
liter (mg/l) and ppb[C] effective in 1989 (TCE) and 1992 (PCE): 0.005 
mg/l or 5 ppb. 

Chemical: PCE; 
Nonenforceable guidance: Suggested no adverse response level[A] for 
various exposure periods in parts per billion (ppb) issued in 1979 
(TCE) and 1980 (PCE): 1-Day[D]: 2,300; 
Nonenforceable guidance: Suggested no adverse response level[A] for 
various exposure periods in parts per billion (ppb) issued in 1979 
(TCE) and 1980 (PCE): 10-Day[E]: 175; 
Nonenforceable guidance: Suggested no adverse response level[A] for 
various exposure periods in parts per billion (ppb) issued in 1979 
(TCE) and 1980 (PCE): Long-term[F]: 20; 
Nonenforceable guidance: Suggested action guidance[B] for various 
exposure periods in ppb issued in 1980 (PCE): 1-Day[D]: 2,300; 
Nonenforceable guidance: Suggested action guidance[B] for various 
exposure periods in ppb issued in 1980 (PCE): 10-Day[E]: 180; 
Nonenforceable guidance: Suggested action guidance[B] for various 
exposure periods in ppb issued in 1980 (PCE): Long-term[F]: 40; 
Enforceable regulation: Maximum contaminant level in milligrams per 
liter (mg/l) and ppb[C] effective in 1989 (TCE) and 1992 (PCE): 0.005 
mg/l or 5 ppb. 

Source: GAO analysis of EPA data. 

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

[B] Suggested action guidance is EPA-issued nonenforceable guidance 
suggesting that remedial action be taken when PCE exceeded specific 
levels. 

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

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

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

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

[G] There was no suggested action guidance for TCE. 

[End of table] 

The Comprehensive Environmental Response, Compensation, and Liability 
Act (CERCLA) of 1980[Footnote 19] 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.[Footnote 20] CERCLA was amended by the Superfund Amendments 
and Reauthorization Act (SARA) of 1986.[Footnote 21] Among other 
things, SARA requires that federal agencies, including DOD, that own or 
operate facilities on EPA's CERCLA list of seriously contaminated 
sites, known as the National Priorities List, enter into an interagency 
agreement with EPA.[Footnote 22] The agreement is to specify what 
cleanup activities, if any, are required, and to set priorities for 
carrying out those activities.[Footnote 23] SARA also established the 
Defense Environmental Restoration Program, through which DOD conducts 
environmental cleanup activities at military installations.[Footnote 
24] Under the environmental restoration program, DOD's activities 
addressing hazardous substances, pollutants, or contaminants are 
required to be carried out consistent with the provisions of CERCLA 
governing environmental cleanups at federal facilities.[Footnote 25] 
Based on environmental contamination at various areas on the base, Camp 
Lejeune was designated as a National Priorities List site in 1989. EPA, 
the Department of the Navy, and the state of North Carolina entered 
into a Federal Facilities Agreement concerning cleanup of Camp Lejeune 
with an effective date of March 1, 1991. 

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.[Footnote 26] 

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.[Footnote 27] Based on the memorandum 
of understanding signed between ATSDR and DOD, ATSDR is required to 
submit an annual plan of work to DOD, in which it must describe the 
public health activities it plans to conduct at DOD sites in the 
following fiscal year, as well as the amount of funding required to 
conduct these activities. After the annual plan of work has been 
submitted, DOD has 45 days to respond and negotiate the scope of work 
to be conducted by ATSDR. The memorandum of understanding states that 
DOD must seek sufficient funding through the DOD budgetary process to 
carry out the work agreed upon. 

Possible Adverse Health Effects of TCE and PCE: 

According to ATSDR's Toxicological Profile, inhaling small amounts of 
TCE may cause headaches, lung irritation, poor coordination, and 
difficulty concentrating, and inhaling or drinking liquids containing 
high levels of TCE may cause nervous system effects, liver and lung 
damage, abnormal heartbeat, coma, or possibly death.[Footnote 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.[Footnote 29] HHS has determined that PCE may reasonably be 
anticipated to be a carcinogen. 

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

Efforts to identify and address past drinking water contamination at 
Camp Lejeune began in the 1980s, when the Navy initiated water testing 
at Camp Lejeune. In 1980, one water test identified the presence of 
VOCs and a separate test indicated contamination by unidentified 
chemicals. In 1982 and 1983, water monitoring for TTHMs by a laboratory 
contracted by Camp Lejeune led to the identification of TCE and PCE as 
the contaminants in two water systems at Camp Lejeune. Sampling results 
indicated that the levels of TCE and PCE varied. Former Camp Lejeune 
environmental officials said they did not take additional steps to 
address the contamination after TCE and PCE were identified. The former 
officials recalled that they did not take additional steps because at 
that time they had little knowledge of TCE and PCE, there were no 
regulations establishing enforceable limits for these chemicals in 
drinking water, and variations in water testing results raised 
questions about the tests' validity. In 1984 and 1985, NACIP, a Navy 
environmental program, identified VOCs, including TCE and PCE, in 12 of 
the wells serving the Hadnot Point and Tarawa Terrace water systems. 
Camp Lejeune officials removed 10 wells from service in 1984 and 1985. 
Additionally, information about the contamination was provided to 
residents. Upon investigating the contamination, DOD and North Carolina 
officials concluded that both on-and off-base sources were likely to 
have caused the contamination in the Hadnot Point and Tarawa Terrace 
water systems. Since 1989, federal, state, and Camp Lejeune officials 
have partnered to take actions to clean up the sources of contamination 
and to monitor and protect the base's drinking water. 

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

The presence of VOCs in Camp Lejeune water systems was first detected 
in October 1980. On October 1, 1980, samples of water were collected 
from all eight water systems at Camp Lejeune by an official from 
LANTDIV, a Navy entity which provided environmental support to Camp 
Lejeune. The water samples were combined into a single sample, and a 
"priority pollutant scan" was conducted in order to detect possible 
contaminants in the water systems. The results of this analysis, 
conducted by a Navy-contracted private laboratory and sent to LANTDIV, 
identified 11 VOCs, including TCE, at their detection limits, that is, 
the lowest level at which the chemicals could be reliably identified by 
the instruments being used.[Footnote 30] LANTDIV officials we 
interviewed said they do not remember why this testing was conducted. A 
memorandum written by a Camp Lejeune environmental official noted that 
LANTDIV initiated the testing because North Carolina had assumed 
responsibility in March 1980 for oversight of the Safe Drinking Water 
Act and therefore would have the right to sample and test the drinking 
water at Camp Lejeune for any contaminants regulated under the 
act.[Footnote 31] The memorandum stated that LANTDIV officials were 
concerned that the state's testing might discover problems that the 
Navy had not previously identified. The Camp Lejeune memorandum 
characterized the 1980 analysis as indicating "no problems" from the 
pollutants when the samples from eight water systems were tested as one 
combined sample, but also noted that this might not have been true if 
the samples had been analyzed individually. Current and former LANTDIV 
officials told us that they did not recall any actions taken as a 
result of this analysis. 

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.[Footnote 32] LANTDIV arranged for an Army laboratory to 
begin testing the treated water from two Camp Lejeune water systems, 
Hadnot Point and New River, in October 1980. At that time, these two 
water systems were the only ones that served more than 10,000 people 
and therefore would be required to meet the future TTHM regulation. 
From October 1980 to September 1981, eight samples were collected from 
the Hadnot Point water system and analyzed for TTHMs. Results from four 
of the eight samples indicated the presence of unidentified chemicals 
that were interfering with the TTHM analyses.[Footnote 33] Reports for 
each of the four analyses contained an Army laboratory official's 
handwritten notes about the unidentified chemicals: two of the notes 
classified the water as "highly contaminated" and notes for the other 
two analyses recommended analyzing the water for organic compounds. 

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[Footnote 34] learned in July 1981 that LANTDIV 
had been receiving the results of TTHM testing and was holding the 
results until all planned testing was complete. Subsequently, Camp 
Lejeune environmental officials requested copies of the TTHM results 
that LANTDIV had received to date, and LANTDIV provided these results 
in August 1981. The next documented correspondence from LANTDIV to Camp 
Lejeune regarding TTHM monitoring occurred in a February 1982 
memorandum in which LANTDIV recommended that TTHM monitoring be 
expanded to all of Camp Lejeune's water systems and noted that Camp 
Lejeune should contract with a North Carolina state-certified 
laboratory for the testing. 

In early 1981, additional water testing unrelated to the TTHM 
monitoring began at the Rifle Range area within Camp Lejeune for 
various contaminants, including TCE and PCE. A former Camp Lejeune 
official recalled that the testing was initiated because of concerns 
about chemicals that had been buried at Rifle Range. In March, April, 
and May 1981, water samples were collected from areas surrounding the 
chemical dump, including a nearby creek; treated water from the Rifle 
Range water system; and untreated water from the individual wells 
serving the water system. These water samples were sent to a Navy- 
contracted private laboratory for analysis, and the results were sent 
to a LANTDIV official in April and May 1981. The results for the 
samples collected from the areas surrounding the chemical dump 
identified VOCs, including TCE and PCE. The results for the samples 
collected from the water system's treated water and for the samples 
from the untreated water from the individual wells also identified 
VOCs. In July 1981, LANTDIV communicated the results to Camp Lejeune 
officials and noted that one of the VOCs detected was a trihalomethane 
and arrangements had been made to add the Rifle Range water system to 
the base TTHM testing. LANTDIV also recommended that no further action 
be taken until additional data became available from TTHM monitoring or 
the planned NACIP program to identify, assess, and control 
environmental contamination. 

Current and former LANTDIV officials recalled that their agency played 
a limited role in providing information or guidance regarding 
environmental issues at Camp Lejeune, and that this assistance 
generally would have been at the request of Camp Lejeune officials. 
However, former Camp Lejeune environmental officials recalled that at 
that time they had little experience in water quality issues and relied 
on LANTDIV to serve as their environmental experts. Documents from 1981 
indicate that LANTDIV officials continuously communicated information 
about the Rifle Range area to Camp Lejeune environmental officials, 
including providing sampling results, discussing the implications of 
these results, providing copies of related regulations and standards, 
and making recommendations for additional action. (See app. II for a 
more detailed description of selected events related to drinking water 
contamination at Camp Lejeune from 1980 through 1981.) 

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

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

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

May samples[E]. 

Housing area: Hadnot Point; 
Samples[B]: 1; 
Concentrations of chemicals in parts per billion[A]: TCE[C]: 1,400; 
Concentrations of chemicals in parts per billion[A]: PCE[D]: 15. 

Housing area: Tarawa Terrace; 
Samples[B]: 2; 
Concentrations of chemicals in parts per billion[A]: TCE[C]: --[F]; 
Concentrations of chemicals in parts per billion[A]: PCE[D]: 80. 

July samples. 

Housing area: Hadnot Point; 
Samples[B]: 3; 
Concentrations of chemicals in parts per billion[A]: TCE[C]: 19; 
Concentrations of chemicals in parts per billion[A]: PCE[D]: <1. 

Samples[B]: 4; 
Concentrations of chemicals in parts per billion[A]: TCE[C]: 21; 
Concentrations of chemicals in parts per billion[A]: PCE[D]: <1. 

Samples[B]: 5; 
Concentrations of chemicals in parts per billion[A]: TCE[C]: No 
data[G]; 
Concentrations of chemicals in parts per billion[A]: PCE[D]: 1.0. 

Housing area: Tarawa Terrace; 
Samples[B]: 6; 
Concentrations of chemicals in parts per billion[A]: TCE[C]: --[F]; 
Concentrations of chemicals in parts per billion[A]: PCE[D]: 76. 

Samples[B]: 7; 
Concentrations of chemicals in parts per billion[A]: TCE[C]: --[F]; 
Concentrations of chemicals in parts per billion[A]: PCE[D]: 82. 

Samples[B]: 8; 
Concentrations of chemicals in parts per billion[A]: TCE[C]: --[F]; 
Concentrations of chemicals in parts per billion[A]: PCE[D]: 104. 

Source: GAO analysis of Headquarters Marine Corps data. 

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

[B] Camp Lejeune's samples were identified by nonconsecutive numbers. 
We renumbered the samples to provide consecutive number identifiers. 

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

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

[E] The May samples were analyzed in July. 

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

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

[End of table] 

Former Camp Lejeune environmental officials recalled that after the 
private laboratory identified the TCE and PCE in the two water systems, 
they did not take additional steps to address the contamination for 
three reasons. First, they had limited knowledge of these chemicals; 
second, there were no regulations establishing enforceable limits for 
these chemicals in drinking water; and third, they made assumptions 
about why the levels of TCE and PCE varied and about the possible 
sources of the TCE and PCE. The former Camp Lejeune environmental 
officials told us that they were aware of EPA guidance, referred to as 
"suggested no adverse response levels," for TCE and PCE when these 
contaminants were identified at Camp Lejeune. However, they noted that 
the levels of these contaminants detected at Camp Lejeune generally 
were below those outlined in the guidance. One Camp Lejeune 
environmental official also recalled that at the time they were unsure 
what the health effects would be for the lower amounts detected at the 
base. Additionally, in an August 1982 document and during our 
interviews with current Camp Lejeune environmental officials, it was 
noted that EPA had not issued regulations under the Safe Drinking Water 
Act for TCE and PCE when the private laboratory identified these 
chemicals in the drinking water. The former Camp Lejeune environmental 
officials also said that they made assumptions about why the levels of 
TCE and PCE varied in sampling results and about the possible sources 
of the TCE and PCE. Specifically, because the levels of TCE and PCE 
varied, they attributed the higher levels to short-term environmental 
exposures, such as spilled paint inside a water treatment plant, or to 
laboratory or sampling errors. Additionally, in an August 1982 
memorandum, a Camp Lejeune environmental official suggested that, based 
on the sampling results provided by the private laboratory, the levels 
of PCE detected could be the result of using coated pipes in the 
untreated water lines at Tarawa Terrace. The former Camp Lejeune 
environmental officials told us that in retrospect, it was likely that 
well rotation in these water systems contributed to the varying 
sampling results because the contaminated wells may not have been 
providing water to the Hadnot Point and Tarawa Terrace systems at any 
given time. However, both they and current Camp Lejeune environmental 
officials said that at that time the base environmental staff did not 
know that the wells serving both systems were rotated. 

After August 1982, the private laboratory continued to communicate with 
Camp Lejeune officials about the contamination of treated water from 
the Hadnot Point and Tarawa Terrace water systems. All eight of Camp 
Lejeune's water systems were sampled again for TTHMs in November 1982. 
In a December 1982 memorandum, a Camp Lejeune environmental official 
noted that during a phone conversation with a chemist from the private 
laboratory the chemist expressed concern that TCE and PCE were 
interfering with Tarawa Terrace and Hadnot Point TTHM samples. The 
chemist said the levels of TCE and PCE were "relatively high" in the 
November 1982 samples, though the specific levels of TCE and PCE were 
not provided to Camp Lejeune officials. The private laboratory report 
providing the November 1982 results said that the samples from Tarawa 
Terrace "show contamination" from PCE and the samples from Hadnot Point 
"show contamination" from both TCE and PCE. All eight of Camp Lejeune's 
water systems were sampled again for TTHMs in August 1983, and the 
private laboratory report providing these results said that the samples 
from Tarawa Terrace "show contamination" from PCE and the samples from 
Hadnot Point "show contamination" from both TCE and PCE.[Footnote 35] 
Former Camp Lejeune environmental officials recalled that they did not 
take any actions related to these findings. (See app. III for a more 
detailed timeline of selected events from 1982 through 1983.) 

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

In 1982, Navy officials initiated the NACIP program at Camp Lejeune as 
part of its overall strategy to identify, assess, and control 
environmental contamination at Navy and Marine Corps bases.[Footnote 
36] The first step of the NACIP program was an initial assessment 
study, which was designed to collect and evaluate evidence that 
indicated the existence of pollutants that may have contaminated a site 
or that posed a potential health hazard for people located on or off a 
military installation. The initial assessment study for Camp Lejeune, 
which was completed in April 1983, determined that further 
investigation was warranted at 22 priority sites with potential 
contamination, including a site near wells that served the Hadnot Point 
water system. 

In July 1984, the base initiated a NACIP confirmation study to 
investigate the 22 priority sites. As a part of the confirmation study, 
a Navy contractor took water samples from water supply wells located 
near priority sites where groundwater contamination was suspected. 
Current and former Camp Lejeune officials told us that previous water 
samples usually had been collected from treated water at sites such as 
reservoirs or buildings within the water systems rather than being 
collected directly from individual wells at Camp Lejeune.[Footnote 37] 
In November 1984, Camp Lejeune officials received sampling results for 
one Hadnot Point well located near a priority site, which showed that 
TCE and PCE, among other VOCs, were detected in the well. This well was 
removed from service, and in December 1984, water samples from six 
Hadnot Point wells that were located in the same general area and 
treated water samples from the Hadnot Point water plant were also 
tested. Results of the analysis of the well samples indicated that both 
TCE and PCE were detected in one well, TCE was detected in two 
additional wells, and other VOCs were detected in all six wells. 
Results for the treated water samples also detected TCE and PCE. Four 
of these six wells were removed from service, in addition to the 
original well removed from service. For the two wells that were not 
taken out of service, while initial results indicated levels of VOCs, 
including TCE, other test results showed no detectable levels of VOCs. 
Documents we reviewed show that continued monitoring of those two wells 
indicated no detectable levels of TCE. During December 1984, seven 
additional samples were taken from the treated water at Hadnot Point 
water plant and revealed no detectable levels of TCE and PCE. According 
to two former Camp Lejeune environmental officials, once the wells had 
been taken out of service and the samples from the water plant no 
longer showed detectable levels of TCE or PCE, they believed the water 
from the Hadnot Point water system was no longer contaminated. 

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.[Footnote 38] According to memoranda dated 
March 1985 and May 1985, 1 of the 2 wells removed from service at 
Tarawa Terrace was used on 1 day in March 1985 and on 3 days in April 
1985 for short periods of time to meet water needs at the base. See 
table 3 for the dates that wells were removed from service and for the 
levels of TCE and PCE which were detected in the wells prior to their 
removal from service in 1984 and 1985. See app. IV for the levels of 
other VOCs which were detected in the wells prior to their removal from 
service in 1984 and 1985. 

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: 

Water systems: Hadnot Point; 
Wells: 602; 
Date removed from service: Nov. 30, 1984; 
Concentrations of chemicals in parts per billion[A]: TCE[B]: 1,600; 
Concentrations of chemicals in parts per billion[A]: PCE[C]: 24. 

Wells: 601; 
Date removed from service: Dec. 6, 1984; 
Concentrations of chemicals in parts per billion[A]: TCE[B]: 210; 
Concentrations of chemicals in parts per billion[A]: PCE[C]: 5. 

Wells: 608; 
Date removed from service: Dec. 6, 1984; 
Concentrations of chemicals in parts per billion[A]: TCE[B]: 110; 
Concentrations of chemicals in parts per billion[A]: PCE[C]: ND. 

Wells: 634[D]; 
Date removed from service: Dec. 14, 1984; 
Concentrations of chemicals in parts per billion[A]: TCE[B]: ND; 
Concentrations of chemicals in parts per billion[A]: PCE[C]: ND. 

Wells: 637[D]; 
Date removed from service: Dec. 14, 1984; 
Concentrations of chemicals in parts per billion[A]: TCE[B]: ND; 
Concentrations of chemicals in parts per billion[A]: PCE[C]: ND. 

Wells: 651; 
Date removed from service: Feb. 4, 1985; 
Concentrations of chemicals in parts per billion[A]: TCE[B]: 3,200; 
Concentrations of chemicals in parts per billion[A]: PCE[C]: 386. 

Wells: 652; 
Date removed from service: Feb. 8, 1985; 
Concentrations of chemicals in parts per billion[A]: TCE[B]: 9; 
Concentrations of chemicals in parts per billion[A]: PCE[C]: ND. 

Wells: 653; 
Date removed from service: Feb. 8, 1985; 
Concentrations of chemicals in parts per billion[A]: TCE[B]: 5.5; 
Concentrations of chemicals in parts per billion[A]: PCE[C]: ND. 

Water systems: Tarawa Terrace; 
Wells: TT-26; 
Date removed from service: Feb. 8, 1985; 
Concentrations of chemicals in parts per billion[A]: TCE[B]: 57; 
Concentrations of chemicals in parts per billion[A]: PCE[C]: 1,580. 

Wells: TT-23[E]; 
Date removed from service: Feb. 8, 1985; 
Concentrations of chemicals in parts per billion[A]: TCE[B]: ND; 
Concentrations of chemicals in parts per billion[A]: PCE[C]: 132. 

Source: GAO analysis of Headquarters Marine Corps data. 

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

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

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

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

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

[E] Tarawa Terrace well TT-23 is also referred to as "TT-new well" in 
Marine Corps documents. 

[End of table] 

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.[Footnote 39] According to 
the notice: 

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

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.[Footnote 40] 
All three articles included information about the drinking water 
contamination and noted that 10 wells serving two water treatment 
systems at Camp Lejeune had been removed from service. (See app. V for 
a more detailed timeline of selected documented events from 1984 
through 1985.) 

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

The sources of past contamination for the Hadnot Point water system 
have not been conclusively determined. However, DOD officials have 
estimated that eight contaminated on-base sites in the proximity of the 
Hadnot Point water system may be the sources of contamination for that 
water system. (See table 4.) These eight sites were contaminated by 
leaking underground storage tanks containing fuel, by degreasing 
solvents, by hazardous chemical spills, and by other waste disposal 
practices.[Footnote 41] Efforts by ATSDR are ongoing to conclusively 
determine the sources of past contamination in the Hadnot Point water 
system, as well as when the contamination began. 

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

Sites: Open field storage lots; 
Uses of the site[A]: Storage, disposal, and handling of potentially 
hazardous waste and materials, such as cleaning solvents, used 
batteries, and waste oils. 

Sites: Piney Green Road, an area adjacent to the open field storage 
lots; 
Uses of the site[A]: Storage, disposal, and handling of potentially 
hazardous waste and materials, such as pesticides, used batteries, and 
fuel. 

Sites: Transformer storage lot; 
Uses of the site[A]: Pesticide mixing and cleaning and disposal of oil 
from electric transformers. 

Sites: Firefighting training pit; 
Uses of the site[A]: Firefighting training exercises in which flammable 
liquids (including used oil, solvents, and fuels) were used. 

Sites: An industrial fly ash dump; 
Uses of the site[A]: Disposal of waste, including fly ash (which is 
residue resulting from the combustion of ground or powdered coal), 
solvents, water treatment sludge, and used paint stripping compounds. 

Sites: An industrial area which includes 75 buildings and facilities 
such as maintenance shops, gas stations, administrative offices, 
commissaries, snack bars, warehouses, and storage yards; 
Uses of the site[A]: Mixed uses; due to the industrial nature of the 
site, many spills and leaks of gas-related products and solvents 
occurred. 

Sites: A service station within the industrial area; 
Uses of the site[A]: Fuel storage; includes four underground gasoline 
storage tanks. 

Sites: A fuel farm within the industrial area; 
Uses of the site[A]: Fuel storage; includes 15 fuel storage tanks, 14 
of which are underground. 

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

[A] Some sites may have multiple uses. The only uses of the sites that 
were included were those that may be related to the contamination. 

[End of table] 

For the Tarawa Terrace water system, North Carolina officials 
determined that an off-base source was the likely cause of the drinking 
water contamination. After the Marine Corps requested assistance in 
identifying the source of the contamination, North Carolina state 
officials conducted an investigation from April 1985 through September 
1985 to determine whether two off-base dry cleaning facilities located 
near the two contaminated wells were the sources of the PCE 
contamination at Tarawa Terrace. The state officials concluded that the 
contamination likely came from dry cleaning solvent that had been 
released into a leaking septic tank at one of the cleaners--ABC One 
Hour Cleaners--which built its septic system and began operation in 
1954. Both the dry cleaning facility and its septic tank were located 
off base but adjacent to a supply well for the Tarawa Terrace water 
system. Based on the environmental contamination at this site, ABC One 
Hour Cleaners was designated as a National Priorities List site in 
1989. As part of its current health study, ATSDR has estimated that 
beginning as early as 1957 individuals were exposed to PCE in treated 
drinking water at levels equal to or greater than what became effective 
in 1992 as EPA's maximum contaminant level of 5 parts per billion. 

Cleanup and Monitoring Activities Are Under Way to Address the 
Contamination: 

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

Following Camp Lejeune's listing as a National Priorities List site in 
October 1989 and the signing of a Federal Facilities Agreement in 
February 1991, on-base cleanup activities have been managed by a 
partnership of DOD, EPA, and North Carolina environmental officials. 
Cleanup of the eight sites suspected to be possible sources of 
contamination for the Hadnot Point water system has included the 
removal of contaminated soils and gasoline storage tanks and the 
treatment of contaminated groundwater and soils. The cleanup activities 
at four of the eight sites were completed by 2006. The estimated 
completion date for cleanup activities of contaminated groundwater and 
soils at three of the other four sites is 2025. There is no estimated 
completion date for the fourth site. Funding for the cleanup of the on- 
base sites has come from Department of the Navy Environmental 
Restoration Program funds, and Navy officials estimated that about $70 
million would be needed to complete the cleanup of all eight sites. 

Efforts to clean up the suspected source of contamination that affected 
the Tarawa Terrace water system began after ABC One Hour Cleaners was 
listed as a National Priorities List site in 1989. Cleanup activities 
at the site, which have been designed to address both the contaminated 
groundwater and soil, have been managed by EPA, with support from North 
Carolina officials. While treatment of some of the areas with 
contaminated soil has been completed, the EPA official who serves as 
project manager for the ABC One Hour Cleaners site could not provide an 
estimated completion date for cleanup of either the soil or the 
groundwater. Funding for the cleanup of this site comes primarily from 
the Superfund, though a portion of the funds has been provided by ABC 
One Hour Cleaners and North Carolina. The total estimated cost for the 
cleanup of this site is about $4.3 million. According to a North 
Carolina official, North Carolina will assume authority for cleanup at 
the site in August 2013. 

Currently, Camp Lejeune uses various methods to monitor and protect the 
base's drinking water. In drinking water reports published in 2004 and 
available on the Camp Lejeune Web site, base officials stated that 
their efforts to monitor the drinking water supply had met or exceeded 
all required testing standards. For example, Camp Lejeune reported that 
"in accordance with Safe Drinking Water Act sampling requirements" it 
had regularly tested its treated drinking water for more than 80 
different EPA-regulated contaminants and additional unregulated 
contaminants. The reports noted that testing of treated water for VOCs 
had been conducted on a monthly basis--exceeding the requirement to 
test every 3 years--"in order to show that there should be no concern 
about current VOC contamination." The Camp Lejeune reports stated that 
the base had sampled the wells at least annually for VOCs. 
Additionally, the Water Quality Program at Camp Lejeune produces annual 
reports about each drinking water system on the base in order to inform 
water consumers about the quality of their water. The 2004 reports also 
stated that Camp Lejeune officials have undertaken numerous efforts to 
protect the drinking water supply, including restricting land uses near 
well fields,[Footnote 42] locating well fields in undeveloped areas, 
constructing wells in a manner that minimizes the potential for 
contamination, and using new technologies to prevent groundwater 
contamination. Examples of some of these new technologies included a 
computer-based monitoring system for underground storage tanks that 
immediately alerts personnel when a leak occurs, and the installation 
of bullet traps at firing areas, which prevent lead and copper bullets 
from contaminating the groundwater and soil. 

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

Concerns about possible adverse health effects and government actions 
related to the past drinking water contamination have led to additional 
activities, including health studies, claims against the federal 
government, and federal inquiries. Activities resulting from concerns 
about possible adverse health effects began in 1991, when ATSDR 
initiated a public health assessment that evaluated the possible health 
risks from past exposure to the contaminated drinking water at Camp 
Lejeune. The health assessment was followed by two studies, one of 
which was ongoing as of April 2007. Since ATSDR began its work, the 
agency did not always receive requested funding and experienced delays 
in receiving information from DOD entities. However, ATSDR officials 
said that the agency's Camp Lejeune-related work was not significantly 
delayed by DOD. As of January 2007, about 750 claims had been filed by 
former Camp Lejeune residents and employees against the federal 
government for injuries alleged to have resulted from past exposure to 
the contaminated drinking water at Camp Lejeune. Additionally, three 
federal inquiries into issues related to the drinking water 
contamination at Camp Lejeune have been conducted, one by a Marine 
Corps-chartered panel, one by the EPA OIG, and one by the EPA CID. The 
inquiry conducted by the Marine Corps-chartered panel found that the 
Marine Corps acted responsibly and found no evidence that the Marine 
Corps had attempted to cover up information that indicated 
contamination in Camp Lejeune's drinking water. However, the Marine 
Corps-chartered panel also criticized some actions taken by Camp 
Lejeune and Department of the Navy officials, such as inadequate 
communications among these entities about the drinking water 
contamination. The EPA OIG found that some EPA officials' responses to 
a citizen's requests regarding Camp Lejeune-related documents were 
inadequate or inappropriate. The EPA CID investigation did not find any 
violations of federal law but criticized some actions taken by Marine 
Corps and Department of the Navy officials, such as a lack of diligence 
by a Navy environmental support entity in providing technical expertise 
to Camp Lejeune's environmental officials. 

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

Beginning in 1991, ATSDR has undertaken several activities to study the 
possible adverse health effects related to the past drinking water 
contamination at Camp Lejeune, including a public health assessment and 
two studies. From 1991 to 1997, ATSDR conducted a public health 
assessment at Camp Lejeune that was required by law because of the 
base's listing on the National Priorities List. The health assessment 
evaluated several ways in which people on base had been exposed to 
hazardous substances, including exposure to the VOC-contaminated 
drinking water.[Footnote 43] ATSDR concluded that (1) cancerous and 
noncancerous health effects were unlikely in adults exposed to VOC- 
contaminated drinking water, (2) the likelihood of either noncancerous 
or cancerous health effects in children could not be determined because 
of insufficient scientific information, and (3) there was evidence that 
suggested that, because of their developing systems, individuals who 
were exposed in utero were potentially more sensitive to the effects of 
VOCs than individuals who were exposed as adults or children.[Footnote 
44] In its 1997 report, ATSDR recommended that a study be carried out 
to evaluate the risks of childhood cancer in those who were exposed in 
utero to the contaminated drinking water and also noted that adverse 
pregnancy outcomes were of concern. ATSDR officials said that the 
health assessment did not recommend a study of adverse pregnancy 
outcomes because such a study was already under way. 

In 1995, while the health assessment was being conducted, ATSDR 
initiated a study to determine whether there was an association between 
exposure to VOCs in drinking water and specific adverse pregnancy 
outcomes among women who had lived at Camp Lejeune from 1968 through 
1985.[Footnote 45] The study, released in 1998, originally concluded 
that there was a statistically significant elevated risk for several 
poor pregnancy outcomes, including (1) small for gestational age among 
male infants born to mothers living at Hadnot Point, (2) small for 
gestational age for infants born to mothers over 35 years old living at 
Tarawa Terrace, and (3) small for gestational age for infants born to 
mothers with two or more prior fetal losses living at Tarawa 
Terrace.[Footnote 46] However, ATSDR officials said they are 
reanalyzing the findings of this study because of an error in the 
original assessment of exposure to VOCs in drinking water. While the 
study originally assessed births from 1968 to 1972 in the Holcomb 
Boulevard service area as being unexposed to VOCs, these births were 
exposed to contaminants from the Hadnot Point water system. An ATSDR 
official said the reanalysis may alter the study's results. 

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.[Footnote 47] The current study began with a 
survey to identify potential cases of the selected birth defects and 
childhood cancers. The study is also using water modeling[Footnote 48] 
to help ATSDR determine the potential sources of past contamination and 
estimate when the water became contaminated and which housing units 
received the contaminated water. The water modeling data will help 
ATSDR identify which pregnant women may have been exposed to the 
contaminated water, and will also help ATSDR estimate the amount of TCE 
and PCE that may have been in the drinking water. ATSDR officials said 
that the study is expected to be completed by December 2007. 

ATSDR also has hosted two expert panel meetings related to the past 
drinking water contamination at Camp Lejeune. In February 2005, ATSDR 
hosted an expert scientific advisory panel to explore opportunities for 
conducting additional health studies of people who were potentially 
exposed to contaminated drinking water at Camp Lejeune. The agency 
noted that it convened this panel in response to continuing public 
concern about health effects from past exposure to contaminated 
drinking water. ATSDR received nine recommendations from its scientific 
advisory panel in a final report released in June 2005, which include a 
recommendation to create an advisory panel to oversee future studies 
and a recommendation that funding for future studies should come from 
appropriations to ATSDR, not from DOD's budget.[Footnote 49] In an 
August 2005 published response, ATSDR agreed with all but three of the 
scientific advisory panel's recommendations.[Footnote 50] (See app. VI 
for ATSDR's panel recommendations and ATSDR's response.) 

ATSDR has taken steps to accomplish three of the recommended 
activities. In February 2006, ATSDR created a community assistance 
panel to respond to the two recommendations urging a closer partnership 
with former Camp Lejeune residents and development of an advisory panel 
to oversee health studies related to VOC exposures at Camp 
Lejeune.[Footnote 51] As of January 2007, the community assistance 
panel had held four meetings. The panel includes seven former Camp 
Lejeune residents. Also participating in CAP meetings are one 
representative from DOD, two independent scientific experts, and ATSDR 
staff. ATSDR officials said the community assistance panel is 
comparable with other panels that ATSDR had set up for community 
participation at National Priorities List sites similar to Camp 
Lejeune. In response to a recommendation to conduct feasibility or 
pilot studies before beginning full-scale health studies, ATSDR had 
begun conducting a feasibility assessment to determine the availability 
and sufficiency of data needed to conduct several additional health 
studies related to past drinking water contamination. At the February 
2006 community assistance panel meeting, the panel members and ATSDR 
officials agreed that ATSDR should move forward with the initial stages 
of planning a mortality study and an adult cancer incidence study of 
those potentially exposed to contaminated water at Camp Lejeune so long 
as necessary data are available. ATSDR officials said that they had 
identified databases such as the National Death Index,[Footnote 52] 
which contains death records, and state cancer registries[Footnote 53] 
that could be used to assist ATSDR with conducting these studies. An 
ATSDR official said that mortality and cancer incidence studies would 
potentially be easier to carry out than some other health studies 
because of the existence of these databases. Since the February 2006 
community assistance panel meeting, ATSDR officials have begun 
reviewing additional databases at the Defense Manpower Data Center and 
Naval Health Research Center to determine if those databases could be 
linked to both the National Death Index and state cancer registries, 
and to Camp Lejeune family housing records.[Footnote 54] If the 
feasibility assessment shows that these databases can be used, ATSDR 
will likely proceed with the two studies, officials said. Additionally, 
ATSDR officials said they plan to computerize the family housing 
records at Camp Lejeune that were still in paper format. Officials 
noted that the fully computerized family housing records might be used 
as the basis for defining a registry of potentially affected residents, 
as recommended by the scientific advisory panel, if the feasibility 
assessment indicates that it is possible to obtain social security 
numbers and dates of birth for each potential member of the registry. 

In March 2005, ATSDR hosted a separate expert peer review panel to 
evaluate the agency's water modeling and data-gathering efforts at Camp 
Lejeune. In a report published in October 2005, the expert peer review 
panel on water modeling made two primary recommendations urging the 
agency to make additional effort and expend more resources on more 
rigorous record searches to improve the information for the historical 
reconstruction of events.[Footnote 55] ATSDR agreed and had hired new 
staff and consultants to begin record searches at Camp Lejeune; 
however, ATSDR officials did not proceed with their record search after 
they learned that the Marine Corps had separately hired a private 
contractor to conduct such a search. The Marine Corps' private 
contractor completed its document search in August 2006, which yielded 
more than 6,000 documents. An ATSDR official told us that during a 
preliminary review of the documents in July 2006, ATSDR determined that 
the documents were "extremely useful" for its water modeling 
activities. The remaining three recommendations of the expert peer 
review panel on water modeling were technical comments related to 
modeling activities, such as a recommendation to use simplified models 
that required less effort and resources. ATSDR officials said that they 
agreed with these technical recommendations and had subsequently used 
them to refine their modeling procedures. 

Although ATSDR Did Not Always Receive Requested Funding and Experienced 
Delays in Receiving Information from DOD, Officials Said Their Work Has 
Not Been Significantly Delayed: 

Since ATSDR began its Camp Lejeune-related work in 1991, the agency did 
not always receive requested funding and experienced delays in 
receiving information from DOD entities. Although concerns have been 
raised by former Camp Lejeune residents, ATSDR officials said these 
issues have not significantly delayed its work and that such situations 
are normal during the course of a study. 

Funding of ATSDR's Camp Lejeune Work: 

ATSDR received funding from DOD for 13 of the 16 fiscal years during 
which it has conducted its Camp Lejeune-related work, and ATSDR 
provided its own funding for Camp Lejeune-related work during the other 
3 years. Under federal law and in accordance with a memorandum of 
understanding between DOD and ATSDR, DOD is responsible for funding 
public health assessments and any follow-up public health activities 
such as health studies or toxicological profiles related to DOD sites 
as agreed to in an annual plan of work. While ATSDR conducted the 
health assessment at Camp Lejeune, from fiscal year 1991 to fiscal year 
1996 funding was provided by DOD as part of an annual payment for all 
ATSDR activities at DOD sites. These annual payments were provided from 
Defense Environmental Restoration Program funds. In fiscal year 1997, 
the individual military services assumed responsibility for making 
these payments. Therefore, for fiscal year 1997, funding for ATSDR's 
Camp Lejeune-related work came directly from the Navy (see Table 5). 

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

Fiscal year: 1991; 
Total amount[A]: 95,018; 
Funding source: Defense Environmental Restoration Program (DERP)[B]. 

Fiscal year: 1992; 
Total amount[A]: 33,868; 
Funding source: DERP. 

Fiscal year: 1993; 
Total amount[A]: 97,000; 
Funding source: DERP. 

Fiscal year: 1994; 
Total amount[A]: 230,795; 
Funding source: DERP. 

Fiscal year: 1995; 
Total amount[A]: 434,328; 
Funding source: DERP. 

Fiscal year: 1996; 
Total amount[A]: 141,405; 
Funding source: DERP. 

Fiscal year: 1997; 
Total amount[A]: 109,045; 
Funding source: Navy Environmental Restoration Program[C]. 

Fiscal year: 1998; 
Total amount[A]: 731,247; 
Funding source: ATSDR. 

Fiscal year: 1999; 
Total amount[A]: 390,000; 
Funding source: ATSDR. 

Fiscal year: 2000; 
Total amount[A]: 935,312; 
Funding source: ATSDR. 

Fiscal year: 2001; 
Total amount[A]: 1,241,003; 
Funding source: Navy Environmental Restoration Program. 

Fiscal year: 2002; 
Total amount[A]: 1,021,437; 
Funding source: Navy Environmental Restoration Program. 

Fiscal year: 2003; 
Total amount[A]: 567,389; 
Funding source: Marine Corps Operations & Maintenance[D]. 

Fiscal year: 2004; 
Total amount[A]: 1,723,000; 
Funding source: Marine Corps Operations & Maintenance. 

Fiscal year: 2005; 
Total amount[A]: 1,549,000; 
Funding source: Marine Corps Operations & Maintenance. 

Fiscal year: 2006; 
Total amount[A]: 1,376,263[E]; 
Funding source: Marine Corps Operations & Maintenance, Navy 
Environmental Restoration Program. 

Sources: ATSDR and DOD. 

[A] Expenditure amounts, in dollars, as reported by ATSDR and DOD. 

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

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

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

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

[End of table] 

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.[Footnote 56] However, ATSDR officials told us that while 
they expected that the study would focus primarily on contamination 
from the dry cleaner, the study was also expected to include people who 
were exposed to on-base sources of contamination. An ATSDR official 
reported that the agency submitted its funding proposals for the Camp 
Lejeune study to DOD in each of the annual plans of work from fiscal 
year 1998 to fiscal year 2000, but that during that time period the 
agency received no DOD funding and funded its Camp Lejeune-related work 
from general ATSDR funding. 

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

Provision of Information to ATSDR by DOD: 

ATSDR has experienced some difficulties obtaining information from Camp 
Lejeune and DOD officials. For example, while conducting its public 
health assessment in September 1994, ATSDR sent a letter to the 
Department of the Navy noting that ATSDR had had difficulties getting 
documents needed for the public health assessment from Camp Lejeune, 
such as Remedial Investigation[Footnote 57] 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.[Footnote 58] Between 
February and April 1999, Headquarters Marine Corps facilitated 
discussion between ATSDR and relevant DOD entities about these Privacy 
Act concerns and some information was subsequently provided to ATSDR by 
DOD. In April 2001, Headquarters Marine Corps sent a letter to the 
Defense Privacy Office suggesting that the Defense Manpower Data Center 
had only provided a limited amount of information to ATSDR.[Footnote 
59] However, in a July 2001 reply to Headquarters Marine Corps, the 
Defense Privacy Office noted that it believed that relevant data had 
been provided to ATSDR by the Defense Manpower Data Center in 1999 and 
2001. 

In December 2005, ATSDR officials told us that they had recently 
learned of a substantial number of additional documents that had not 
been previously provided to them by Camp Lejeune officials. ATSDR then 
sent a letter to Headquarters Marine Corps seeking assistance in 
resolving outstanding issues related to delays in the provision of 
information and data to ATSDR. In an attachment to the letter, ATSDR 
provided a list of data and information needed from the Marine Corps in 
order to complete water modeling activities for its current study. In a 
January 2006 response, a Headquarters Marine Corps official noted that 
a comprehensive review was conducted of responses to ATSDR's requests 
for information and that the Marine Corps believed it had made a full 
and timely disclosure of all known and available requested documents. 
The official also noted that while ATSDR had requested that the Marine 
Corps identify and provide documents that were relevant or useful to 
ATSDR's study, the Marine Corps did not always have the subject matter 
expertise to determine the relevance of documents. The official noted 
that the Marine Corps would attempt to comply with this request; 
however, the official also noted that ATSDR was the agency with the 
expertise necessary to determine the relevance of documents. 

Effect on ATSDR's Work: 

Despite difficulties, ATSDR officials said the agency's Camp Lejeune- 
related work had not been significantly delayed or hindered by DOD. 
Officials said that while funding and access to records were probably 
slowed down and made more expensive by DOD officials' actions, their 
actions did not significantly impede ATSDR's health study efforts. The 
ATSDR officials also stated that while issues such as limitations in 
access to DOD data had to be addressed, such situations are normal 
during the course of a study. The officials stated that ATSDR's 
progress on the study has been reasonable in light of the complexity of 
the project. Nonetheless, as some former residents have learned that 
ATSDR has not always received requested funding and information from 
DOD entities, they have raised questions about DOD's commitment to 
supporting ATSDR's work.[Footnote 60] For example, when some former 
residents learned during a community assistance panel meeting that it 
took about 4 months for DOD to respond to a supplemental budget request 
from ATSDR for fiscal year 2006, they questioned DOD entities' 
commitment to ATSDR's Camp Lejeune-related work. However, DOD and ATSDR 
officials described this delay in responding as typical during the 
funding process. 

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

Some former residents have filed tort claims and lawsuits against the 
federal government related to the past drinking water 
contamination.[Footnote 61] As of January 2007, about 750 former 
residents and former employees of Camp Lejeune have filed tort claims 
with the Department of the Navy related to the past drinking water 
contamination. According to an official with the U.S. Navy Judge 
Advocate General (JAG)--which is handling the claims on behalf of the 
Department of the Navy--the agency is currently maintaining a database 
of all claims filed. The official said that JAG is awaiting completion 
of the current ATSDR health study before deciding whether to settle or 
deny the pending claims in order to base its response on as much 
objective scientific and medical information as possible.[Footnote 62] 

As of February 2007, two of these claims had resulted in the filing of 
lawsuits in Federal District Courts in Texas and Mississippi.[Footnote 
63] Among other things, both lawsuits seek damages for various physical 
ailments and emotional distress alleged to have resulted from the 
government's negligence in protecting the water supply at Camp Lejeune. 
In the first lawsuit, a former servicemember's son alleged that he 
suffered a congenital heart defect as a result of his mother's exposure 
(while pregnant with him) as well as his subsequent direct exposure to 
contaminated water at Camp Lejeune during the early 1970s.[Footnote 64] 
The outcome of the lawsuit was still pending as of February 2007. In 
the second lawsuit, a former servicemember and his family alleged 
injuries as a result of their past exposure to TCE and PCE while living 
at Camp Lejeune. The claims of the former service member and his wife 
were dismissed because his alleged injuries occurred while he was on 
active duty in the Marine Corps.[Footnote 65] An appeal of the claims 
of the former service member and his family members remained pending in 
February 2007.[Footnote 66] 

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

Three federal inquiries into issues related to the drinking water 
contamination at Camp Lejeune have been conducted, each of which cited 
concerns by former residents as one of the reasons for conducting its 
inquiry. These include one by a Marine Corps-chartered panel, one by 
EPA's OIG, and one by EPA's CID. 

Marine Corps-Chartered Panel Review: 

In March 2004 the Commandant of the Marine Corps created a fact-finding 
panel charged with conducting a review of the facts surrounding the 
decisions made following the 1980 discovery of VOCs in drinking water 
at Camp Lejeune.[Footnote 67] The panel focused its review on the 1980 
to 1985 time period. The panel released a report in October 2004 which 
found that the Marine Corps acted responsibly and found no evidence 
that the Marine Corps had attempted to cover up information that 
indicated contamination in Camp Lejeune's drinking water.[Footnote 68] 
Additionally, the panel concluded that Camp Lejeune provided residents 
with drinking water at a level of quality consistent with general 
utility practices at the time. However, the panel noted that while Camp 
Lejeune made every effort to comply with existing regulations, it did 
not anticipate or independently evaluate health risks associated with 
chemicals such as TCE or PCE that were not yet regulated, and for which 
there was developing concern about possible adverse health effects. The 
panel noted that this "compliance-based approach to regulations," 
combined with factors including inadequate funding, staffing, and 
training of Camp Lejeune's Environmental Division, contributed to a 
lack of understanding about the potential significance of the 
contamination. Additionally, the panel identified other factors that 
appeared to have hindered Camp Lejeune personnel from quickly 
recognizing the significance of VOC contamination, including the 
absence of regulatory standards, no records of resident complaints 
about water quality, sampling errors, and inconsistent sampling 
results. 

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

* LANTDIV, as a technical advisory organization, was "not aggressive" 
in providing Camp Lejeune with the technical expertise to help base 
officials understand the significance of the contamination and how it 
could have been addressed; 

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

* communications to Camp Lejeune residents regarding drinking water 
contamination were not detailed enough to completely characterize the 
contamination found at the time of the well closures. 

EPA's OIG Inquiry: 

In January 2005 EPA's OIG completed an internal report describing a 
preliminary review of five complaints reported by three citizens 
regarding issues indirectly or directly related to the drinking water 
contamination at Camp Lejeune. The complaints were as follows: 

1. EPA inadequately responded to a Freedom of Information Act[Footnote 
69] request, 

2. EPA inappropriately responded to a Freedom of Information Act fee 
waiver request,[Footnote 70] 

3. EPA did not adequately perform oversight of Camp Lejeune based on 
its responsibilities listed in the Safe Drinking Water Act, 

4. EPA did not devote adequate resources to the review that was being 
conducted by its Criminal Investigation Division, and: 

5. the 1998 study conducted by ATSDR was inadequate. 

The OIG conducted a preliminary review of these complaints to determine 
whether the complaints merited a full-scale audit of EPA activities. 
Regarding the first two complaints, the OIG determined that EPA's 
response to a Freedom of Information Act request for documents related 
to Camp Lejeune contamination was inadequate and that its denial of an 
associated fee waiver request was inappropriate and insensitive. The 
third complaint was closed because the OIG concluded that EPA had 
little oversight responsibility for the Safe Drinking Water Act until 
1996, significantly later than the contamination occurred at Camp 
Lejeune. The OIG found no merit with the fourth complaint, noting that 
although only one agent was assigned to the case, that agent had access 
to other agents and resources when needed. OIG officials said the fifth 
complaint was closed in part because they knew we would also be 
reviewing this concern, and also because complaints regarding ATSDR's 
study are not related to any actions by EPA and are therefore outside 
the scope of an EPA review. Based on this preliminary review, a full 
audit of EPA officials' actions was not initiated. 

EPA's Criminal Investigation: 

A criminal investigation conducted by EPA and reviewed by the 
Department of Justice (DOJ) did not find any violations of federal law, 
but criticized some of the actions taken by Marine Corps and Navy 
officials.[Footnote 71] From 2003 through 2005, EPA's CID conducted an 
investigation of allegations made by former residents that federal law 
was violated by the individuals and entities addressing the drinking 
water contamination at Camp Lejeune, including officials from the 
Marine Corps, Navy, and ATSDR. With regard to the Navy and Marine 
Corps, the CID investigated five principal allegations of violation of 
federal law: 

1. violation of the Safe Drinking Water Act, 

2. conspiracy to violate the Safe Drinking Water Act, 

3. conspiracy to conceal records and prevent persons from talking with 
a federal agency conducting a congressionally mandated health study, 

4. conspiracy to conceal Freedom of Information Act records from the 
public, and: 

5. providing material false statements to a federal law enforcement 
officer. 

The CID concluded that in the absence of enforceable regulatory 
standards for both TCE and PCE between 1980 and 1985, there was no 
violation of the Safe Drinking Water Act at that time, and drinking 
water provided by Camp Lejeune during that time appeared to have met 
all state and federal regulatory requirements. A CID investigator told 
us that he looked for evidence of conspiracy from the 1980s, when the 
events occurred, through 2004. With regard to allegations that Marine 
Corps or Navy officials conspired to violate the Safe Drinking Water 
Act or to conceal records, the CID's report noted that investigators 
were unable to substantiate that a conspiracy by military or civilian 
employees of either entity existed. Regarding allegations that false 
statements were provided to a federal law enforcement officer, 
investigators noted that while they were concerned that LANTDIV 
officials were not completely forthcoming during their interviews, 
there was never any direct evidence that LANTDIV officials were aware 
of the contamination prior to 1984. 

With regard to ATSDR, the CID investigated two principal allegations 
made by former residents of Camp Lejeune: 

1. destruction of a federal agency's records, and: 

2. conspiracy to improperly administer a congressionally mandated 
health study. 

Regarding an alleged order by an ATSDR official to destroy records 
related to the Camp Lejeune health study, CID investigators found that 
the records in question were never destroyed. Concerning allegations 
that ATSDR failed to properly address the drinking water contamination 
at Camp Lejeune because of influence from the Navy, the CID found no 
evidence that ATSDR's scientific work was influenced by regular 
meetings between ATSDR and Navy officials. 

Although the CID found no evidence that federal law had been violated, 
because of the unique history and complexity of the case and an 
evaluation of statements from persons they interviewed, investigators 
noted that the case warranted a review by DOJ. Additionally, several of 
the allegations from the public had also been forwarded by DOJ to the 
CID for investigation. Following the CID's referral of this case to DOJ 
for its review, DOJ discussed its findings at an August 2005 meeting 
with former residents and officials from the Navy and Marine 
Corps.[Footnote 72] DOJ concluded that it would not seek criminal 
prosecution, saying that the government's investigation had concluded 
that no federal criminal law was broken nor was there an attempt to 
conceal evidence regarding a violation of any law. 

In addition to investigating whether federal law had been violated, the 
CID also investigated additional questions that were relevant to the 
case but were determined not to be violations of federal law. The CID 
noted that some of these matters appeared to have contributed to 
confusion, suspicion, and concern by retired Marines. Additionally, the 
CID commented on and criticized certain actions taken by Navy and 
Marine Corps officials. For example: 

* The CID concluded that as a technical advisory agency to Camp 
Lejeune, LANTDIV was not diligent in providing technical expertise to 
the base's environmental officials and noted that LANTDIV officials 
appeared to have been better suited by virtue of their training and 
expertise to recognize and address VOC contamination and the possible 
effects on public health than the environmental officials at Camp 
Lejeune. 

* The CID commented that former Camp Lejeune environmental officials 
failed to properly investigate the contamination and determine the 
contamination was coming from individual wells. Until 1984, the Camp 
Lejeune environmental officials never sampled individual water wells 
and the CID noted that this was arguably their most significant lapse 
in judgment. 

* Because of questions raised by Congress and former residents, the CID 
also investigated the provision of DOD funding for ATSDR's work. The 
CID concluded that funding for the current study was apparently delayed 
because of opposition characterized as a professional difference of 
opinion as to the scientific value of the study by a midlevel manager 
at the Navy Environmental Health Center, and that coupled with this 
opposition was confusion within the Navy hierarchy regarding what 
entity was responsible for the contaminated wells. 

* Regarding the provision of records and data to ATSDR by the Marine 
Corps, the CID found no instances when data or records were 
intentionally withheld or false data were provided by Marine Corps 
officials to ATSDR. The CID noted the Marine Corps appeared not to have 
recognized the complexity and degree of attention this issue required 
in 1997 and that prior to 1997, the Marine Corps admitted that it 
failed to adequately address concerns and data requests from the public 
and ATSDR. 

Experts Convened by NAS Generally Agreed That Many Parameters of 
ATSDR's Current Study Were Appropriate but Some Experts Suggested 
Potential Modifications to the Study: 

The seven members of an expert panel convened by the National Academy 
of Sciences (NAS) at our request generally agreed that specific 
parameters of ATSDR's current study were appropriate, including the 
study population, the exposure time frame, and the selected health 
effects. The expert panel members had mixed opinions on ATSDR's 
projected completion date. Some panel experts suggested modifying the 
study to use a simpler method of analysis, with alternative ways to 
define exposure categories, in order to complete the study sooner. Some 
panel experts also identified other potential modifications to the 
study, such as conducting separate analyses for those who were born on 
the base and those born off the base. (See app. VII for a more detailed 
description of ATSDR's study.) 

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

The seven panel experts concurred that ATSDR logically limited its 
study population to those individuals who were in utero while their 
mothers were pregnant and lived at Camp Lejeune during the 1968 through 
1985 time frame, and who may have been exposed to the contaminated 
drinking water.[Footnote 73] The current study follows recommendations 
from the agency's 1997 public health assessment of Camp Lejeune, which 
noted that studies of cancer among those who were exposed in utero 
should be conducted to further the understanding of the health effects 
in this susceptible population. Panel experts said that ideally a study 
would attempt to include all individuals who were potentially exposed, 
but that limited resources and data availability were practical reasons 
for limiting the study population. Additionally, panel experts agreed 
that those exposed while in utero were an appropriate study population 
because they could be considered at higher risk of adverse health 
outcomes than others, such as those exposed as children or adults. In 
addition, two panel experts said that studying only those who lived on 
base was reasonable because they likely had a higher risk of inhalation 
exposure to VOCs such as TCE and PCE, which may be more potent than 
ingestion exposure.[Footnote 74] Thus, pregnant women who lived in 
areas of base housing with contaminated water and conducted activities 
during which they could inhale water vapor--such as bathing, showering, 
or washing dishes or clothing--likely faced greater exposure than those 
who did not live on base but worked on base in areas served by the 
contaminated drinking water. 

While supporting the decision to limit the study population to 
individuals who were in utero, the panel experts did not discount the 
possibility that children and adults who lived or worked on base may 
also be at risk for adverse health effects because of their potential 
exposure to contaminated drinking water. For example, four panel 
experts pointed out that exposed children and adults might have an 
elevated risk for neurological effects, and one of the four experts 
said exposed adults might have an elevated risk for certain cancers. 
Similarly, the ATSDR scientific advisory panel convened in February 
2005 identified at least four groups of individuals at Camp Lejeune who 
might be at higher risk for adverse health effects because they could 
have been exposed to the contaminated drinking water. In addition to 
individuals who were in utero, these groups included children who lived 
on base, adults who lived on base, and adults who lived off base but 
worked on base, because they too spent time at Camp Lejeune and were 
potentially exposed to the contaminated drinking water. 

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

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

Six of the panel experts said that extending the time frame past 1985 
could help strengthen ATSDR's study by adding an additional unexposed 
population for comparison. Having an additional comparison population 
could help researchers reinforce any conclusions about whether TCE or 
PCE are associated with adverse health outcomes, panel experts said. 
For example, if the study found some association between adverse health 
outcomes and the pre-1985 exposed population, but no association with 
an additional unexposed comparison group, it would support any finding 
that TCE or PCE exposure was associated with adverse health outcomes, 
since the exposure ended in 1985. Two of the expert panel members said 
that if adverse health effects continued to be found in a comparison 
population after 1985, that finding could mean that exposure to the 
contaminated drinking water was not associated with the adverse health 
effects. However, one of the six experts also noted that extending the 
study time frame would be cost effective only if a significant 
association between TCE or PCE exposure and adverse health outcomes was 
first found among those exposed before 1985. 

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

The five panel experts who discussed health effects said that those 
selected for the study were valid for individuals who were potentially 
exposed in utero at Camp Lejeune.[Footnote 75] Based on previous ATSDR 
work and existing literature, the health effects chosen for the study 
were neural tube defects, oral cleft defects, and childhood 
hematopoietic cancers, including leukemia and non-Hodgkin's 
lymphoma.[Footnote 76] Two panel experts said that ATSDR had limited 
its study to health effects that are rare and that generally occur at 
higher levels of exposure to VOCs such as TCE and PCE than are expected 
to have occurred at Camp Lejeune. They said that this may result in 
ATSDR not identifying enough individuals with these health effects to 
determine meaningful results in the study.[Footnote 77] 

Four panel experts added that other adverse health outcomes not 
included in the study could also be related to exposure to drinking 
water contaminated with TCE or PCE, including adverse neurological or 
behavioral effects, or pregnancy loss. However, three of these four 
panel experts said that studying adverse neurological or behavioral 
health effects would likely be difficult because of limited access to 
needed records, such as school records for children, or because there 
might be few databases for researchers to use to study these effects in 
adults. 

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

ATSDR has projected a December 2007 completion date for the study, 
which would include activities such as identifying and enrolling study 
participants, conducting a parental interview, confirming each reported 
diagnosis, modeling the water system to quantify the amount and extent 
of each individual's exposure, analyzing the data, and drafting a final 
report. Panel experts had mixed opinions regarding ATSDR's completion 
date. Of the five panel experts who commented on the proposed 
completion date, three said that the date appeared reasonable, and two 
others said that based on the complexity of the water modeling the 
projected completion date might be optimistic.[Footnote 78] 

While none of the panel experts said that ATSDR's projected completion 
date should be earlier, several said that one way to provide analytical 
results sooner would be to conduct the study without using the water 
modeling analysis. Three of the experts explained that water modeling 
would be useful if it improved the classification of the study 
participants as either exposed or unexposed to contaminated water or 
provided more accurate estimates of individual exposure levels, as 
ATSDR intends. ATSDR officials said that a precise and accurate 
exposure assessment would enhance the scientific credibility of a study 
and strengthen the study's ability to identify any important exposure 
effects. But all of the panel experts raised concerns about the limited 
historical record of the amount of PCE or TCE concentration identified 
at individual Camp Lejeune wells. They said that with limited 
historical data there would be minimal potential for water modeling to 
provide accurate information about the level of concentration of the 
contamination and thus about each individual's total amount of 
exposure. As an alternative to estimating the extent of each study 
individual's exposure using the water modeling results, four panel 
experts suggested ATSDR could use simpler categories of whether and to 
what extent individuals were exposed to water contamination. These four 
experts said that analyzing the data on birth defects and childhood 
cancers by using the same exposure categories that were used in the 
1998 ATSDR study could yield an effective study sooner than December 
2007. The current ATSDR study expects to use more categories of 
exposure than were used in the 1998 study, based on data from its water 
modeling activities and from information gathered on the mothers' usage 
and consumption of the contaminated water. 

Experts Identified Additional Potential Modifications to the ATSDR 
Study: 

Panel experts identified several other possibilities for modifying the 
design of the ATSDR study. Four panel experts suggested conducting 
separate analyses for study individuals born in the county where Camp 
Lejeune is located, and for individuals who were born outside the 
county but whose mothers were pregnant with them while living in base 
housing.[Footnote 79] Word of mouth among current and former residents 
and media campaigns were the primary methods used to identify and 
recruit those individuals born outside the county as study 
participants. According to three panel experts, the methods used to 
identify these study participants raise the possibility of selection 
bias for that group. Specifically, the experts suggested that eligible 
study individuals born out of county, or their parents, who had 
concerns about potential exposure to TCE or PCE or about existing 
health problems may have been more likely to sign up for the study than 
those who did not have these concerns. Selection bias could result in a 
mistaken estimate of an exposure's effect on the risk of 
disease.[Footnote 80] 

As another potential study modification, two panel experts suggested 
conducting separate analyses for those with childhood leukemias and non-
Hodgkin's lymphoma, which they said ATSDR had inappropriately combined 
into one category of hematopoietic cancers. ATSDR study investigators 
had combined these health outcomes into one category following advice 
from the ATSDR scientific advisory panel at its meeting in February 
2005. Before the February meeting, ATSDR study investigators had 
dropped plans to separately analyze childhood non- Hodgkin's lymphoma 
because they were unable to confirm a large enough number of 
individuals with this type of cancer to further study this health 
outcome. 

Agency Comments: 

DOD, EPA, and HHS provided technical comments on a draft of this 
report, which we incorporated where appropriate. We provided the seven 
former Camp Lejeune residents who are members of the ATSDR community 
assistance panel for Camp Lejeune the opportunity to provide comments 
on our draft--three of the panel members provided technical and general 
oral comments, and four declined to review the draft report. Two of the 
panel members said that the report should address contaminants other 
than TCE and PCE with potential adverse health effects, such as 
benzene, that were identified at Camp Lejeune. Our report focused on 
TCE and PCE because ATSDR's health studies have focused on these 
chemicals and their associated health effects and ATSDR has identified 
TCE and PCE as the chemicals of primary concern at Camp Lejeune. 
However, in response to technical comments from ATSDR and the panel 
members' comments, we have added the sampling results for all other 
VOCs detected in wells that were taken out of service at Camp Lejeune 
during 1984 and 1985. Additionally, the three members expressed the 
belief that the Marine Corps had not fully disclosed information 
related to the past drinking water contamination and two of the members 
expressed disappointment that our report was not more critical of the 
Marine Corps. We believe that we have accurately described efforts to 
identify and address the past contamination and described activities 
resulting from concerns about possible adverse health effects and 
government actions related to the past contamination. Finally, the 
three members raised various other issues, such as compensation and 
health benefits for former residents and their families and the need 
for additional notification to be provided to former residents 
regarding the past drinking water contamination; however, these issues 
were beyond the scope of this report. 

We are sending copies of this report to the Secretary of Defense, the 
Administrator of EPA, the Secretary of Health and Human Services, 
appropriate congressional committees, and other interested parties. We 
will also make copies available to others upon request. In addition, 
the report is available at no charge on the GAO Web site at 
http://www.gao.gov. If you or your staff have questions about this 
report, please contact me at (202) 512-7119. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this report. GAO staff who made major contributions 
are listed in appendix VIII. 

Signed by: 

Marcia Crosse: 
Director, Health Care: 

[End of section] 

Appendix I: Scope and Methodology: 

To examine efforts to identify and address the past drinking water 
contamination at Camp Lejeune, we obtained and reviewed more than 1,600 
documents related to past and current drinking water activities at Camp 
Lejeune. We focused our review on the past trichloroethylene (TCE) and 
tetrachloroethylene (PCE) contamination at Camp Lejeune because the 
Agency for Toxic Substances and Disease Registry (ATSDR) had noted that 
these chemicals were the VOCs of primary concern. However, we also 
reviewed documentation regarding other volatile organic compounds 
(VOCs) detected at Camp Lejeune. The documents we reviewed were 
obtained from Headquarters Marine Corps and had been collected and 
organized by a contractor for the Commandant of the Marine Corps' 
Drinking Water Fact-Finding Panel for Camp Lejeune. Documents related 
to past and current drinking water activities were also obtained during 
a visit to Camp Lejeune. The authors of the documents we collected 
included officials with Camp Lejeune, Headquarters Marine Corps, the 
Department of the Navy, other federal agencies such as the 
Environmental Protection Agency (EPA), the state of North Carolina, and 
private laboratories. The types of documents that were collected 
included results of laboratory analyses of drinking water samples, e- 
mails, memorandums, letters, reports, site maps, federal and state 
regulations, press releases, and newspaper articles. 

Additionally, we reviewed a list of more than 6,000 historical 
documents collected by a contractor hired by Headquarters Marine Corps; 
this list was compiled by the contractor and included detailed 
descriptions and dates of the historical documents. We requested and 
reviewed more than 100 documents from this list that we thought might 
be relevant to the past drinking water contamination. 

We interviewed 39 current and former officials from various Department 
of Defense (DOD) entities, including Camp Lejeune, Headquarters Marine 
Corps, and the Department of the Navy, who were involved in activities 
related to or knowledgeable about historical environmental activities 
at Camp Lejeune. The former officials we interviewed were responsible 
for environmental activities at Camp Lejeune or the Department of the 
Navy during the time in which the contamination was detected. The 
current officials we interviewed are responsible for environmental 
activities at Camp Lejeune, Headquarters Marine Corps, or the 
Department of the Navy. Some of these current officials were also 
responsible for environmental activities during the time in which the 
contamination was detected. The current and former officials 
interviewed often provided information based on their memory of events 
which occurred more than 20 years ago. We attempted to corroborate 
their testimonial evidence with documentation whenever possible. We 
also met with 19 interested former residents and individuals who worked 
on the base during the 1960s, 1970s, and 1980s in order to obtain their 
perspective on historical events. A former resident who is active in 
matters related to the past drinking water contamination at Camp 
Lejeune identified most of the interested former residents; others were 
identified at an ATSDR public meeting. We also interviewed current Camp 
Lejeune housing officials in order to obtain estimated historical 
occupancy rates, including the limitations of the occupancy data that 
were provided. Additionally, we examined reports from and interviewed 
current officials from Camp Lejeune, EPA, and the North Carolina 
Department of Environment and Natural Resources who were involved with 
or knowledgeable about past and current activities and costs related to 
the cleanup of the suspected sources of contamination. Finally, we 
obtained and analyzed information from ATSDR and EPA on drinking water 
contaminated with TCE and PCE, the possible adverse health effects 
related to exposure to these chemicals, and relevant federal 
regulations for TCE and PCE. 

To describe activities resulting from concerns about the possible 
adverse health effects and government actions related to past drinking 
water contamination, including efforts to study potential health 
effects and federal inquiries into the response to the contamination, 
we reviewed documents, interviewed agency officials, and attended 
agency meetings. To examine the activities undertaken by ATSDR to study 
potential health effects related to the drinking water contamination at 
Camp Lejeune, we reviewed the agency's 1997 Public Health Assessment 
that evaluated the risks of adverse health effects from exposure to the 
contaminated drinking water, as well as released documents regarding 
ATSDR's 1998 health study of the association between exposure to TCE 
and PCE in drinking water at Camp Lejeune and a variety of adverse 
pregnancy outcomes. We did not evaluate the methodology or findings of 
the public health assessment or health study. For ATSDR's current 
study, we examined the study protocol, a progress report, and other 
documents describing ATSDR's current study examining whether birth 
defects and childhood cancers are associated with exposure to TCE or 
PCE at Camp Lejeune. We interviewed ATSDR officials involved with the 
Public Health Assessment, the 1998 study, and the current study, and 
also attended ATSDR expert panel meetings convened to evaluate and 
provide recommendations regarding the agency's work related to Camp 
Lejeune. In order to examine the sources of and issues surrounding 
funding for ATSDR's Camp Lejeune-related work, we obtained documents 
from and interviewed officials with ATSDR, the Department of the Navy, 
and the U.S. Army Center for Health Promotion and Preventive Medicine, 
which currently executes the memorandum of understanding between DOD 
and ATSDR and negotiates an annual plan of work with ATSDR. We examined 
documentation and interviewed DOD, ATSDR, and EPA officials about 
efforts to address the concerns of the former Camp Lejeune residents. 
To examine the recommendations of additional review panels convened by 
ATSDR in 2005 regarding improving the study's water modeling efforts 
and future studies of health effects, we attended two panel meetings 
and obtained and reviewed the final reports of both panels, which 
included ATSDR's response to the panels' recommendations. To determine 
the actions taken by ATSDR to address the panel recommendations, we 
interviewed relevant ATSDR officials and observed and subsequently 
reviewed transcripts of meetings of the Camp Lejeune community 
assistance panel held in 2006, where ATSDR officials reported on their 
activities. In order to describe the lawsuits and tort claims filed 
against the federal government for injuries alleged to have resulted 
from exposure to the contaminated drinking water at Camp Lejeune, we 
interviewed officials with the Department of the Navy's Judge Advocate 
General and the Department of Justice. To describe three federal 
inquiries into issues related to the drinking water contamination at 
Camp Lejeune, we reviewed the reports and statements of the Drinking 
Water Fact-Finding Panel for Camp Lejeune, the EPA Office of Inspector 
General, the EPA Criminal Investigation Division, and the Department of 
Justice. We also interviewed officials from the EPA Office of Inspector 
General and the EPA Criminal Investigation Division about their 
examinations of allegations made by former residents. We did not 
evaluate the methodology used by the officials who conducted these 
three inquiries. 

When the source of evidence we cited is from an interview, we 
identified the respondent's agency and noted whether the individual was 
a current or former official. Whenever possible, we reviewed documents 
to verify testimonial evidence from DOD and ATSDR officials. When this 
was not possible, we attempted to corroborate testimonial evidence by 
interviewing multiple individuals about the information we obtained. 

To assess the design of the current study by ATSDR on the possible 
health effects associated with the contaminated drinking water at Camp 
Lejeune, including the study population, time frame, health effects, 
and completion date, we contracted with the National Academy of 
Sciences (NAS) to convene a 1-day meeting of scientific experts in the 
areas of drinking water contamination, hydrologic modeling, and 
reproductive health. We identified for NAS the categories of expertise 
preferred at the meeting and expressed a preference that each 
participant have no conflict of interest with ATSDR, DOD, or EPA. NAS 
identified participants according to the preferred categories. Once we 
concurred with the proposed participants, NAS contacted the potential 
participants to determine interest and availability to participate in 
the meeting. In total, seven experts and one moderator participated in 
the meeting. The experts and the moderator had combined research 
expertise in environmental engineering; reproductive, environmental, 
and occupational epidemiology; statistics and modeling; public health 
investigations, risk assessment, and decision analysis; geochemistry; 
and water and wastewater treatment and water modeling. We observed the 
meeting, which took place in July 2005, and subsequently reviewed the 
written transcript of the meeting. The experts' discussion during the 
meeting was guided by a set of questions we prepared regarding the 
ATSDR study population, time frame, health effects, and completion 
date. Participants were invited as individual experts, not as 
organizational representatives, and were not asked to reach consensus 
on any topics. NAS was not asked to provide advice or produce any 
report, and the comments made during the meeting of the expert panel 
should not be interpreted to represent the views of NAS or of all 
experts regarding health studies related to drinking water 
contamination. As we requested, each of the experts also provided 
written responses to the set of questions that were discussed during 
the meeting. During the meeting and in their written responses, not all 
panel members commented individually about each of the questions 
discussed during the 1-day meeting. Additionally, some panel members 
noted that certain questions addressed subjects that were outside their 
areas of expertise. In addition to convening and attending the expert 
panel meeting, we also reviewed ATSDR documents related to the current 
study, including the study protocol and progress reports, and 
interviewed ATSDR officials involved in the study's epidemiologic and 
water modeling activities. 

We conducted our work from May 2005 through April 2007 in accordance 
with generally accepted government auditing standards. 

[End of section] 

Appendix II: Selected Events Related to Past Drinking Water 
Contamination at Camp Lejeune from 1980 through 1981: 

Date: October 1, 1980; 
Event: An official with the Naval Facilities Engineering Command, 
Atlantic Division (LANTDIV), collected samples from all eight water 
systems at Camp Lejeune to be combined into a single sample and 
analyzed in order to detect any potential contaminants in the water 
systems. 

Date: October 21 and October 24, 1980; 
Event: At the direction of LANTDIV, Camp Lejeune collected separate 
samples to be analyzed for total trihalomethanes (TTHMs)[A] at two base 
water systems, Hadnot Point and New River. LANTDIV arranged for the 
U.S. Army Environmental Hygiene Agency (USAEHA) laboratory to conduct 
the testing. 

Date: October 31, 1980; 
Event: A LANTDIV-contracted private laboratory reported results from 
the samples collected on October 1, 1980, from all eight water systems 
at Camp Lejeune. The results, sent to LANTDIV, indicated that 11 
volatile organic compounds (VOCs) were detected, including 
trichloroethylene (TCE).[B] All VOCs detected in this analysis were 
identified at their detection limits, which were the lowest level at 
which the chemicals could be reliably identified by the instruments 
being used. 

Date: October 31, 1980; 
Event: A report[C] from USAEHA of the results of the analysis of 
samples collected on October 21, 1980, contained a USAEHA official's 
handwritten notes which indicated unidentified chlorinated hydrocarbons 
were interfering with the testing for TTHMs at the Hadnot Point water 
system. 

Date: January 22, 1981; 
Event: Handwritten notes from a USAEHA official on a USAEHA report 
indicated that continued interference with the TTHM analysis of samples 
collected on December 29, 1980, for the Hadnot Point water system, and 
recommended conducting analyses for chlorinated organics. 

Date: February 9, 1981; 
Event: Handwritten notes from a USAEHA official on a USAEHA report 
indicated continued interference with the TTHM analysis of samples 
collected on January 30, 1980, for the Hadnot Point water system, and 
recommended conducting analyses for chlorinated organics. 

Date: March 9, 1981; 
Event: Handwritten notes from a USAEHA official on a USAEHA report 
indicated that water samples collected on March 9, 1981, for analysis 
for TTHMs at the Hadnot Point water system were "highly contaminated" 
with other chlorinated hydrocarbons. 

Date: April 7, 1981; 
Event: According to the private laboratory report sent to LANTDIV, an 
analysis of water samples collected on March 30, 1981, from areas 
surrounding the Camp Lejeune Rifle Range chemical dump detected VOCs. 
However, TCE and tetrachloroethylene (PCE)[D] were not among the VOCs 
detected in these samples. 

Date: April 16, 1981; 
Event: According to the private laboratory report sent to LANTDIV, an 
analysis of water samples collected on April 10, 1981, was conducted 
from the untreated water in the wells that served the Rifle Range water 
system, from treated water from the Rifle Range water system, and from 
areas surrounding the Rifle Range chemical dump. VOCs, including TCE 
and PCE, were detected in water samples from the areas surrounding the 
chemical dump. VOCs, including TCE, were also detected in the well 
samples. TCE was detected at 1.8 parts per billion[E] in one of the 
well samples. 

Date: May 8, 1981; 
Event: The Commander of LANTDIV wrote a memorandum to the Commanding 
General of Camp Lejeune that recommended resampling the Rifle Range 
area because of variation in the results from the April 7 and April 16 
analysis reports. LANTDIV noted that three contaminants were detected 
in the treated and untreated water in the Rifle Range water system. Two 
of these contaminants, methylene chloride[F] and TCE, were not 
regulated and the third chemical, a TTHM, was detected at levels within 
the new regulatory standards. The LANTDIV official noted that no 
imminent threat to human health was presented by consumption of water 
from the Rifle Range water system. 

Date: May 29, 1981; 
Event: According to the private laboratory report sent to LANTDIV, an 
analysis of water samples collected on May 20, 1981, from treated water 
in the Rifle Range water system and from areas surrounding the Rifle 
Range chemical dump detected VOCs in the treated water at the Rifle 
Range water system and also detected VOCs, including TCE, in areas 
surrounding the Rifle Range chemical dump. 

Date: July 31, 1981; 
Event: The Commander of LANTDIV wrote a memorandum to the Commanding 
General of Camp Lejeune that described the analyses of the additional 
water samples taken from the Rifle Range area. The official noted that 
of the organic contaminants detected at the Rifle Range area, only one, 
a TTHM, had an established regulation with a maximum contaminant 
level[G] though it did not apply to the Rifle Range water system 
because this system did not serve more than 10,000 people. The official 
noted that LANTDIV would add the Rifle Range water system to the TTHM 
testing that had been initiated in 1980. Additionally, he suggested no 
further action be taken until the Navy Assessment and Control of 
Installation Pollutants programh and TTHM analysis provided additional 
data. According to a handwritten note at the end of the memorandum, an 
environmental official at Camp Lejeune recommended arranging a meeting 
with the state in order to share these results. 

Date: August 26, 1981; 
Event: The Commander of LANTDIV wrote a memorandum to the Commanding 
General of Camp Lejeune noting that in accordance with Camp Lejeune's 
request, it was providing the summary of TTHM regulations and copies of 
the TTHM testing reports for the two water systems that met the 
requirement to be tested. 

Source: GAO analysis of Headquarters Marine Corps documents. 

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

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

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

[C] Generally, the USAEHA reports did not indicate to whom they were 
sent. 

[D] PCE is a VOC typically used as a dry cleaning solvent. 

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

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

[G] Maximum contaminant levels are the maximum permissible level of a 
contaminant in water delivered to a public water system. 

[H] The Navy Assessment and Control of Installation Pollutants program 
was established in 1980 to identify, assess, and control environmental 
contamination from past hazardous materials storage, transfer, 
processing, and disposal operations. 

[End of table] 

[End of section] 

Appendix III: Selected Events Related to Past Drinking Water 
Contamination at Camp Lejeune from 1982 through 1983: 

Date: April 19, 1982; 
Event: Camp Lejeune environmental officials began collecting monthly 
samples for monitoring of total trihalomethanes (TTHMs)[A] at all eight 
base water systems. 

Date: May 6, 1982; 
Event: A private laboratory contracted by Camp Lejeune to conduct the 
TTHM analysis informed Camp Lejeune by telephone that synthetic organic 
cleaning solvents, including trichloroethylene (TCE),[B] were detected 
in the samples that were collected from April 19 to April 22, 1982, 
from the Tarawa Terrace and Hadnot Point water systems. Grainger 
Laboratory stated that TCE interference with the analysis of the Hadnot 
Point samples prevented the detection of a precise reading for TTHMs. 

Date: May 27 and May 28, 1982; 
Event: Camp Lejeune environmental officials took a second set of 
monthly water samples at the base water systems because of problems 
with the collection of earlier samples taken from May 17 through May 
24, 1982. 

Date: June 9, 1982; 
Event: The private laboratory report of the results of the analysis of 
monthly samples collected May 27 and May 28, 1982, noted that an 
unknown compound was interfering with the testing for TTHMs at the 
Hadnot Point water system. 

Date: July 13, 1982; 
Event: The private laboratory report of the results of the analysis of 
monthly samples collected June 24 and June 25, 1982, did not 
specifically note interference with the testing for TTHMs at the Hadnot 
Point water system, but, as in previous reports, noted that there was 
some uncertainty in the measurements for this water system. 

Date: July 28, 1982; 
Event: Camp Lejeune environmental officials collected samples, which 
were in addition to the monthly samples, from the Hadnot Point and 
Tarawa Terrace water systems. An internal Camp Lejeune memorandum noted 
that the additional sampling was conducted because the private 
laboratory identified interference by TCE and another synthetic organic 
cleaning solvent while analyzing earlier samples from the Hadnot Point 
and Tarawa Terrace water systems for TTHMs. 

Date: August 10, 1982; 
Event: The private laboratory sent a letter to Camp Lejeune officials 
stating that the contaminants interfering with the TTHM monitoring at 
the Tarawa Terrace and Hadnot Point water systems were TCE and 
tetrachloroethylene (PCE).[C] The laboratory noted that these chemicals 
appeared to be at high levels and were thus more important from a 
health standpoint than the TTHM levels. The laboratory further noted 
that the levels of PCE detected in the Tarawa Terrace water system had 
been relatively stable over the time period examined, while levels of 
TCE and PCE detected in the Hadnot Point water system had varied, and 
the most recent Hadnot Point readings had been at significantly lower 
levels than the levels detected in May. 

Date: August 18, 1982; 
Event: Camp Lejeune officials decided to reduce monitoring for TTHMs 
from monthly to quarterly for six of the eight water systems, including 
Tarawa Terrace and Hadnot Point, beginning in September 1982. Officials 
noted in a memorandum that federal and state regulations required only 
quarterly sampling.[D]. 

Date: August 19, 1982; 
Event: A Camp Lejeune environmental official sent a memorandum to her 
supervisor that discussed the TTHM sampling and interference at the 
Tarawa Terrace and Hadnot Point water systems. She explained that the 
additional samples had been collected on July 28, 1982, to identify the 
source of the interference in the earlier TTHM testing; TCE and PCE 
were identified as the interfering chemicals. The official detailed the 
possible adverse health effects from both TCE and PCE, but further 
explained that TCE and PCE were not regulated under the Safe Drinking 
Water Act. However, she noted that the EPA had issued "suggested no 
adverse response levels"[E] and "suggested action guidance,"f which 
provided some guidance on unregulated contaminants. The official 
explained that levels of TCE and PCE detected in the Hadnot Point water 
system were presently within the limits suggested by the suggested no 
adverse response levels, but she offered no explanation for the higher 
level detected in samples taken in May 1982 and analyzed in July 1982. 
She also noted that it was possible that the levels of PCE detected in 
the Tarawa Terrace water system were the result of the use of asbestos-
coated pipe in the water lines carrying untreated water. 

Date: December 9, 1982; 
Event: The private laboratory report of the results of the analysis of 
samples collected in November from all eight water systems for 
quarterly TTHM testing was provided to Camp Lejeune officials. This 
report stated that all samples from Tarawa Terrace indicated 
contamination from PCE and all samples from Hadnot Point indicated 
contamination from TCE and PCE. 

Date: December 21, 1982; 
Event: An environmental official at Camp Lejeune wrote a memorandum to 
her supervisor about the TTHM analysis from November 1982. She noted 
that during a telephone conversation with a chemist at the private 
laboratory, the chemist had expressed concerns over the solvents that 
interfered with the Tarawa Terrace and Hadnot Point samples, 
particularly those from Hadnot Point. According to the memorandum, the 
chemist told the Camp Lejeune official that while the levels of TCE and 
PCE had dropped for a period of time, the November samples showed 
levels of TCE and PCE that were relatively high again. 

Date: September 16, 1983; 
Event: The private laboratory report of the results of the analysis of 
samples collected on August 25 and August 26, 1983, from all eight 
water systems for TTHM testing was provided to Camp Lejeune officials. 
The report stated that all samples from Tarawa Terrace exhibited 
contamination from PCE and all samples from Hadnot Point exhibited 
contamination from both TCE and PCE. 

Source: GAO analysis of Headquarters Marine Corps documents. 

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

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

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

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

[D] Amendments in 1979 to the National Interim Primary Drinking Water 
Regulations required that water systems serving more than 10,000 people 
and adding a disinfectant as part of the drinking water treatment 
process to begin mandatory water testing for TTHMs by November 1982 and 
comply with the maximum contaminant level by November 1983. Only two 
water systems at Camp Lejeune, Hadnot Point and New River, served more 
than 10,000 people when TTHM testing was initiated at Camp Lejeune. 

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

[F] EPA's suggested action guidance was a nonenforceable guidance 
suggesting that remedial action be taken when PCE exceeded specific 
levels. 

[End of table] 

[End of section] 

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

Water systems: Hadnot Point; 
Wells: 602; 
Date removed from service: Nov. 30, 1984; 
Concentrations of chemicals in parts per billion[A]: Benzene[B]: 120; 
Concentrations of chemicals in parts per billion[A]: Trans-1,2-DCE[C]: 
630; 
Concentrations of chemicals in parts per billion[A]: 1,1-DCE[D]: 2.4; 
Concentrations of chemicals in parts per billion[A]: Methylene 
chloride[E]: --; 
Concentrations of chemicals in parts per billion[A]: Toluene[F]: 5.4; 
Concentrations of chemicals in parts per billion[A]: Vinyl chloride[G]: 
18. 

Wells: 601; 
Date removed from service: Dec. 6, 1984; 
Concentrations of chemicals in parts per billion[A]: Benzene[B]: ND; 
Concentrations of chemicals in parts per billion[A]: Trans-1,2-DCE[C]: 
88; 
Concentrations of chemicals in parts per billion[A]: 1,1-DCE[D]: ND; 
Concentrations of chemicals in parts per billion[A]: Methylene 
chloride[E]: ND; 
Concentrations of chemicals in parts per billion[A]: Toluene[F]: ND; 
Concentrations of chemicals in parts per billion[A]: Vinyl chloride[G]: 
ND. 

Wells: 608; 
Date removed from service: Dec. 6, 1984; 
Concentrations of chemicals in parts per billion[A]: Benzene[B]: 3.7; 
Concentrations of chemicals in parts per billion[A]: Trans-1,2-DCE[C]: 
5.4; 
Concentrations of chemicals in parts per billion[A]: 1,1-DCE[D]: ND; 
Concentrations of chemicals in parts per billion[A]: Methylene 
chloride[E]: ND; 
Concentrations of chemicals in parts per billion[A]: Toluene[F]: ND; 
Concentrations of chemicals in parts per billion[A]: Vinyl chloride[G]: 
ND. 

Wells: 634; 
Date removed from service: Dec. 14, 1984; 
Concentrations of chemicals in parts per billion[A]: Benzene[B]: ND; 
Concentrations of chemicals in parts per billion[A]: Trans-1,2-DCE[C]: 
2.3; 
Concentrations of chemicals in parts per billion[A]: 1,1-DCE[D]: --; 
Concentrations of chemicals in parts per billion[A]: Methylene 
chloride[E]: 130; 
Concentrations of chemicals in parts per billion[A]: Toluene[F]: --; 
Concentrations of chemicals in parts per billion[A]: Vinyl chloride[G]: 
ND. 

Wells: 637; 
Date removed from service: Dec. 14, 1984; 
Concentrations of chemicals in parts per billion[A]: Benzene[B]: ND; 
Concentrations of chemicals in parts per billion[A]: Trans-1,2-DCE[C]: 
ND; 
Concentrations of chemicals in parts per billion[A]: 1,1-DCE[D]: --; 
Concentrations of chemicals in parts per billion[A]: Methylene 
chloride[E]: 270; 
Concentrations of chemicals in parts per billion[A]: Toluene[F]: --; 
Concentrations of chemicals in parts per billion[A]: Vinyl 
chloride[G]: --. 

Wells: 651; 
Date removed from service: Feb. 4, 1985; 
Concentrations of chemicals in parts per billion[A]: Benzene[B]: --; 
Concentrations of chemicals in parts per billion[A]: Trans-1,2-DCE[C]: 
3,400; 
Concentrations of chemicals in parts per billion[A]: 1,1-DCE[D]: 187; 
Concentrations of chemicals in parts per billion[A]: Methylene 
chloride[E]: --; 
Concentrations of chemicals in parts per billion[A]: Toluene[F]: --; 
Concentrations of chemicals in parts per billion[A]: Vinyl chloride[G]: 
655. 

Wells: 652; 
Date removed from service: Feb. 8, 1985; 
Concentrations of chemicals in parts per billion[A]: Benzene[B]: --; 
Concentrations of chemicals in parts per billion[A]: Trans-1,2-DCE[C]: 
ND; 
Concentrations of chemicals in parts per billion[A]: 1,1-DCE[D]: ND; 
Concentrations of chemicals in parts per billion[A]: Methylene 
chloride[E]: --; 
Concentrations of chemicals in parts per billion[A]: Toluene[F]: --; 
Concentrations of chemicals in parts per billion[A]: Vinyl chloride[G]: 
ND. 

Wells: 653; 
Date removed from service: Feb. 8, 1985; 
Concentrations of chemicals in parts per billion[A]: Benzene[B]: --; 
Concentrations of chemicals in parts per billion[A]: Trans-1,2-DCE[C]: 
ND; 
Concentrations of chemicals in parts per billion[A]: 1,1-DCE[D]: ND; 
Concentrations of chemicals in parts per billion[A]: Methylene 
chloride[E]: --; 
Concentrations of chemicals in parts per billion[A]: Toluene[F]: --; 
Concentrations of chemicals in parts per billion[A]: Vinyl 
chloride[G]:  ND. 

Water systems: Tarawa Terrace; 
Wells: TT-26; 
Date removed from service: Feb. 8, 1985; 
Concentrations of chemicals in parts per billion[A]: Benzene[B]: ND; 
Concentrations of chemicals in parts per billion[A]: Trans-1,2-DCE[C]: 
92; 
Concentrations of chemicals in parts per billion[A]: 1,1-DCE[D]: --; 
Concentrations of chemicals in parts per billion[A]: Methylene 
chloride[E]: --; 
Concentrations of chemicals in parts per billion[A]: Toluene[F]: --; 
Concentrations of chemicals in parts per billion[A]: Vinyl chloride[G]: 
27. 

Wells: TT-23[H]; 
Date removed from service: Feb. 8, 1985; 
Concentrations of chemicals in parts per billion[A]: Benzene[B]: ND; 
Concentrations of chemicals in parts per billion[A]: Trans-1,2-DCE[C]: 
11; 
Concentrations of chemicals in parts per billion[A]: 1,1-DCE[D]: --; 
Concentrations of chemicals in parts per billion[A]: Methylene 
chloride[E]: --; 
Concentrations of chemicals in parts per billion[A]: Toluene[F]: --; 
Concentrations of chemicals in parts per billion[A]: Vinyl chloride[G]: 
ND. 

Source: GAO analysis of Headquarters Marine Corps data. 

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

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

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

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

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

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

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

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

[H] Well TT-23 is also referred to as "TT-new well" in Marine Corps 
documents. 

[End of table] 

[End of section] 

Appendix V: Selected Events Related to Past Drinking Water 
Contamination at Camp Lejeune from 1984 through 1985: 

Date: July 1984; 
Event: Camp Lejeune initiated the Navy Assessment and Control of 
Installation Pollutants (NACIP)[A] confirmation study. The purpose of 
the confirmation study was to further investigate potential 
contamination at 22 priority sites at Camp Lejeune that were identified 
in an initial assessment study. As part of the confirmation study, 
sampling began at any well in the vicinity of a priority site where 
groundwater contamination was suspected. Prior water samples at Camp 
Lejeune had usually been drawn at the water treatment plants or in the 
distribution system--not from individual wells. 

Date: November 30, 1984; 
Event: Camp Lejeune officials received results from the confirmation 
study sampling which detected trichloroethylene (TCE) and 
tetrachloroethylene (PCE), among other volatile organic compounds[B] 
(VOC), at a well serving the Hadnot Point water system, one of eight 
water systems at Camp Lejeune. This well was removed from service. 

Date: December 4, 1984; 
Event: Water samples were collected from six Hadnot Point wells and 
from the untreated and treated water at the Hadnot Point water 
treatment plant. These wells were sampled because of their proximity to 
the contaminated well that was removed from service on November 30, 
1984. 

Date: December 6, 1984; 
Event: Camp Lejeune officials received results of the analysis of 
samples collected on December 4, 1984, that indicated three additional 
wells and the untreated and treated water from the Hadnot Point water 
system had levels of TCE and PCE, among other VOCs. In one of the 
wells, TCE was detected at 210 parts per billion (ppb)[C] and PCE was 
detected at 5 ppb. In the second well, TCE was detected at 110 ppb. In 
the third well, TCE was detected at 4.6 ppb. The first two wells were 
removed from service.d. 

Date: December 10, 1984; 
Event: A Camp Lejeune official contacted a North Carolina state 
environmental official by telephone to discuss suspected contamination 
found in wells, untreated water, and treated water from the Hadnot 
Point water system. The Camp Lejeune official explained Camp Lejeune 
anticipated that a resampling program would be initiated, and indicated 
that some form of information might be released to the public. 

Date: December 10, 1984; 
Event: Samples were again collected from the same seven Hadnot Point 
wells and the treated water at the Hadnot Point water treatment plant. 

Date: December 13, 1984 through December 19, 1984; 
Event: Separately, daily samples were collected from the untreated 
water at the Hadnot Point water treatment plant. 

Date: December 13, 1984; 
Event: The base newspaper published its first article about water 
testing, VOC contamination, and corrective actions taken by base 
officials, including removing wells from service. The article did not 
identify TCE or PCE as the VOC contaminants. 

Date: December 14, 1984; 
Event: Camp Lejeune officials received results of the analysis of 
samples collected on December 10, 1984, that indicated two additional 
wells in the Hadnot Point water system had significant levels of a VOC, 
methylene chloride,[E] while a third well also indicated levels of 
methylene chloride. TCE and PCE were not detected in these wells. Two 
of these three wells were removed from service.f. 

Date: December 21, 1984; 
Event: Camp Lejeune officials received the results of the analysis of 
samples that were collected from December 13 to December 19, 1984, at 
the Hadnot Point water treatment plant. TCE and PCE were not detected 
in these samples. 

Date: January 8, 1985; 
Event: The director of the NACIP program at Camp Lejeune received a 
report[G] reviewing the December 1984 sampling of wells, untreated 
water, and treated water at the Hadnot Point water system. In the 
report, sampling of all the wells and the water treatment plants at 
Camp Lejeune was proposed. 

Date: January 16, 1985; 
Event: Samples were collected at all wells serving the Hadnot Point and 
Holcomb Boulevard water systems to be tested for VOCs. 

Date: January 23, 1985; 
Event: Samples were collected at all wells serving four other water 
systems, including Tarawa Terrace, to be tested for VOCs. 

Date: January 27, 1985; 
Event: A fuel line from Holcomb Boulevard water treatment plant leaked 
fuel into the water system. The Holcomb Boulevard water treatment plant 
was subsequently shut down and water from the Hadnot Point water system 
was pumped into the Holcomb Boulevard water lines. 

Date: January 31, 1985; 
Event: Samples were collected at various locations within the Hadnot 
Point and Holcomb Boulevard water systems for analysis required by 
North Carolina prior to restarting the Holcomb Boulevard water 
treatment plant. 

Date: February 4, 1985; 
Event: Camp Lejeune officials received results of the analysis of the 
samples collected on January 16, 1985, that indicated one additional 
well in the Hadnot Point water system had significant levels of TCE and 
PCE, among other VOCs. TCE was detected at 3,200 ppb and PCE was 
detected at 386 ppb. This well was removed from service; The results 
also noted that trace amounts of TCE were detected in two other Hadnot 
Point wells. In one well, TCE was detected at 9 ppb and in the other 
well TCE was detected at 5.5 ppb. 

Date: February 4, 1985; 
Event: Camp Lejeune officials received results of the analysis of the 
samples collected on January 31, 1985, from various locations within 
the Hadnot Point and Holcomb Boulevard water systems. No gasoline was 
detected in samples from Holcomb Boulevard. However, various levels of 
TCE were detected in all of the samples; TCE was detected at levels 
ranging from 24 ppb to 1,148 ppb. 

Date: February 4, 1985; 
Event: The Holcomb Boulevard water treatment plant was restarted. 

Date: February 7, 1985; 
Event: Camp Lejeune officials received results of the analysis of the 
samples collected on January 23, 1985, that indicated that two wells in 
the Tarawa Terrace water system had levels of TCE and PCE. In one well, 
TCE was detected at 57 ppb and PCE was detected at 158 ppb. In the 
other well, TCE was detected at 5.8 ppb and PCE was detected at 132 
ppb. 

Date: February 8, 1985; 
Event: The two wells in the Tarawa Terrace water system that were found 
to be contaminated with TCE and PCE on February 7, 1985, were removed 
from service. Additionally, the two wells in the Hadnot Point water 
system that were found to be contaminated with trace levels of TCE and 
PCE on February 4, 1985, were removed from service. 

Date: March 12, 1985; 
Event: According to an internal Camp Lejeune memorandum, one of the 
wells removed from service on February 8, 1985, was restarted on March 
11, 1985, after samples were taken. After 24 hours of operation, 
additional samples were taken and the well was removed from service. 

Date: April 30, 1985; 
Event: The Commanding General of Camp Lejeune issued a notice to the 
residents of Tarawa Terrace housing area regarding problems with the 
water supply. According to the notice, two of the wells that supplied 
water to the Tarawa Terrace water system were taken off line because 
"minute (trace)" amounts of several organic chemicals were detected in 
the water. The notice stated that there were no regulations regarding 
safe levels of the organic chemicals found in these wells, but as a 
precaution the Commanding General had ordered the wells to be removed 
from service in all but emergency situations. Additionally, the notice 
provided ways for residents to reduce water usage because of concerns 
that a water shortage might result following the removal of these wells 
from service. 

Date: May 9, 1985; 
Event: An article was published in the base newspaper explaining that 
10 wells that served the Tarawa Terrace and Hadnot Point water systems 
were removed from service because of contamination. The article also 
noted the potential for water shortages in the Tarawa Terrace water 
system and included information about how to conserve water. 

Date: May 10, 1985; 
Event: An article was published in a North Carolina newspaper providing 
similar information as that included in the May 9, 1985, base newspaper 
article regarding the contamination in the Tarawa Terrace and Hadnot 
Point water systems. 

Date: May 11, 1985; 
Event: An article was published in a second North Carolina newspaper 
providing similar information as that included in the May 9, 1985, base 
newspaper article regarding the contamination in the Tarawa Terrace and 
Hadnot Point water systems. 

Date: May 31, 1985; 
Event: Camp Lejeune officials sent a memorandum to Headquarters Marine 
Corps and LANTDIV noting that all 10 contaminated wells remained out of 
service, although 1 of the contaminated wells at Tarawa Terrace had 
been used on April 22, 23, and 29 to maintain water production. 

Date: September 15, 1985; 
Event: An article was published in a third North Carolina newspaper 
that provided similar information as that included in the May 9, 1985, 
base newspaper article regarding the contamination in the Tarawa 
Terrace and Hadnot Point water systems. 

Source: GAO analysis of Headquarters Marine Corps documents. 

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

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

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

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

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

[E] Methylene chloride is a VOC used in various industrial processes 
including paint stripping, paint remover manufacturing, and metal 
cleaning and degreasing: 

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

[G] The report did not indicate from whom it was sent. 

[End of table] 

[End of section] 

Appendix VI: Agency for Toxic Substances and Disease Registry's 
Response to its 2005 Scientific Advisory Panel's Recommendations: 

Scientific advisory panel's recommendations regarding future health 
studies of past drinking water contamination at Camp Lejeune: 1. Create 
an advisory panel to oversee health studies related to Volatile Organic 
Chemical (VOC) exposures at Camp Lejeune; 
Agency for Toxic Substances and Disease Registry's (ATSDR) response: 
Agreed. ATSDR will create a community assistance panel (CAP) comparable 
to other panels it has set up for community participation at National 
Priorities List sites. ATSDR recommended that its Camp Lejeune CAP be 
comprised of five or more community members and one or two scientific 
advisers, along with ex officio members from the Navy. 

Scientific advisory panel's recommendations regarding future health 
studies of past drinking water contamination at Camp Lejeune: 2. 
Conduct future studies in full partnership with the potentially exposed 
community; 
Agency for Toxic Substances and Disease Registry's (ATSDR) response: 
Agreed. ATSDR said it considered interaction with the community an 
important aspect of its on-site work and planned to continue to work 
closely with organized community advocacy groups. It agreed to be 
responsive to recommendations from the CAP. 

Scientific advisory panel's recommendations regarding future health 
studies of past drinking water contamination at Camp Lejeune: 3. 
Establish a registry to identify groups of potentially exposed 
individuals to study, including exposed and unexposed individuals who 
had lived and/or worked at Camp Lejeune during the period of interest, 
which would serve as the population base for further studies; 
Agency for Toxic Substances and Disease Registry's (ATSDR) response: 
Agreed. In order to identify various distinct groups of individuals 
with potential exposure, ATSDR said that efforts or activities should 
be conducted to determine if potential databases exist that would 
identify these groups, such as children who lived on base and adults 
who lived or worked on base. However, the agency said that it believed 
that it had already identified as completely as possible those who may 
have been exposed while in utero for the years 1968-1985. 

Scientific advisory panel's recommendations regarding future health 
studies of past drinking water contamination at Camp Lejeune: 4. 
Conduct various types of feasibility or pilot studies--to determine 
whether study individuals can be identified and tracked and what types 
of medical records are available--before embarking on full-scale 
studies of the impact on health of exposures at Camp Lejeune; 
Agency for Toxic Substances and Disease Registry's (ATSDR) response: 
Agreed. ATSDR will conduct a feasibility assessment to determine the 
number of adults and children that could be identified through 
available data sources. 

Scientific advisory panel's recommendations regarding future health 
studies of past drinking water contamination at Camp Lejeune: 5. Study 
additional health outcomes, such as mortality and cancer incidence. 
Also, conduct feasibility studies of other adverse health outcomes, 
such as autoimmune diseases; spontaneous abortion; neurological 
effects; organ failure; adult heart disease; reproductive outcomes of 
male and female children who were born (or were in utero) at Camp 
Lejeune; birth defects beyond those considered by ATSDR; and ocular 
problems; 
Agency for Toxic Substances and Disease Registry's (ATSDR) response: 
Agreed. ATSDR agreed that mortality and cancer incidence should receive 
the highest priority and are the outcomes most feasible to study. The 
agency said that decisions concerning study period, study population, 
and study outcomes should be made in consultation with the CAP, and 
said that ATSDR would defer decisions about additional health studies 
until feasibility studies were completed and reviewed by the CAP. 

Scientific advisory panel's recommendations regarding future health 
studies of past drinking water contamination at Camp Lejeune: 6. 
Conduct future research activities in parallel with the current study 
and without awaiting completion of current ATSDR activities; 
Agency for Toxic Substances and Disease Registry's (ATSDR) response: 
Agreed. The agency said that its highest priority is to complete the 
current study. Development of a CAP and further research activities 
would likely require additional staffing and resources, which ATSDR 
said it would request from the Department of Defense (DOD). 

Scientific advisory panel's recommendations regarding future health 
studies of past drinking water contamination at Camp Lejeune: 7. Amend 
the 1997 public health assessment to include the possibility that adult 
cancers and other adverse health outcomes may be related to VOC 
exposures. Additionally, in the period since release of the original 
public health assessment, much additional information on exposures at 
Camp Lejeune and their potential risks has been developed, and this 
additional material should be incorporated into an amended document; 
Agency for Toxic Substances and Disease Registry's (ATSDR) response: 
Did not agree. ATSDR said revisions to the assessment would be needed 
only if new information changed the assessment's conclusions or 
recommendations. ATSDR noted that its assessment acknowledged that the 
science was inconclusive and did not rule out the possibility of 
cancerous health effects from low-dose exposure to VOCs. 

Scientific advisory panel's recommendations regarding future health 
studies of past drinking water contamination at Camp Lejeune: 8. Notify 
all persons potentially affected by exposure to VOCs in the drinking 
water at Camp Lejeune; 
Agency for Toxic Substances and Disease Registry's (ATSDR) response: 
Did not respond directly. ATSDR indicated that it would work with the 
CAP to determine effective ways to disseminate information about its 
current study and any future health studies. 

Scientific advisory panel's recommendations regarding future health 
studies of past drinking water contamination at Camp Lejeune: 9. Obtain 
future funding for Camp Lejeune health studies through direct 
congressional appropriation, not through DOD's budget, to avoid even 
the appearance of a conflict of interest; 
Agency for Toxic Substances and Disease Registry's (ATSDR) response: 
Did not agree. ATSDR said it recognized that the affected community had 
some distrust of ATSDR and DOD, and said that the CAP was intended to 
help mitigate this distrust. However, ATSDR suggested that DOD is the 
most likely funding source for these research activities because no 
other funds are available outside those budgeted to complete the 
current study. 

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

[End of table] 

[End of section] 

Appendix VII: Description of Current Agency for Toxic Substances and 
Disease Registry (ATSDR) Health Study: 

ATSDR is conducting a study of the potential health effects of exposure 
while in utero and as infants up to 1 year of age to trichloroethylene 
(TCE) and tetrachloroethylene (PCE)--two volatile organic chemicals 
found in drinking water at Marine Corps Base Camp Lejeune in the 1980s. 
ATSDR's study will analyze whether exposure to the TCE or PCE- 
contaminated drinking water at Camp Lejeune before birth is associated 
with increased risks of specific birth defects or childhood cancers. 
These birth defects include (1) neural tube defects, (2) oral cleft 
defects, and (3) childhood leukemias and non-Hodgkin's lymphoma, which 
have been combined into one category of hematopoietic cancers. 

ATSDR's efforts to conduct this study began in 1999 with a telephone 
survey conducted with parents of 12,598 individuals born to women who 
were pregnant with them while living in on-base housing at Camp Lejeune 
any time from 1968 through 1985. Parents were asked if their child had 
a birth defect or developed a childhood cancer, along with other 
questions such as those to confirm residency on base during the 
specific time period and questions regarding water usage. A total of 
106 potential cases of the childhood cancers or birth defects were 
reported by the interviewed parents.[Footnote 81] ATSDR reviewed health 
records in order to verify the reported health problems and had 
confirmed 57 cases of the childhood cancers or birth defects as of June 
2006. (See table 6.) The study population includes the 57 individuals 
with confirmed health problems and 548 comparison individuals chosen 
randomly from among the remaining individuals identified in the survey. 

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

Health condition: Neural tube defects; 
Reported cases of health conditions: 35; 
Confirmed cases with diagnosis of health condition: 17; 
Cases not yet confirmed: 2; 
Cases confirmed as without health condition, refused to participate, or 
ineligible: 16. 

Health condition: Oral clefts; 
Reported cases of health conditions: 42; 
Confirmed cases with diagnosis of health condition: 24; 
Cases not yet confirmed: 4; 
Cases confirmed as without health condition, refused to participate, or 
ineligible: 14. 

Health condition: Childhood cancers; 
Reported cases of health conditions: 29; 
Confirmed cases with diagnosis of health condition: 16; 
Cases not yet confirmed: 2; 
Cases confirmed as without health condition, refused to participate, or 
ineligible: 11. 

Health condition: Total; 
Reported cases of health conditions: 106; 
Confirmed cases with diagnosis of health condition: 57; 
Cases not yet confirmed: 8; 
Cases confirmed as without health condition, refused to participate, or 
ineligible: 41. 

Source: ATSDR. 

[End of table] 

As part of this study, ATSDR officials are also conducting computer 
modeling of the drinking water system at Camp Lejeune from 1968 through 
1985 in order to determine which pregnant women were probably exposed 
to the contaminated drinking water and to estimate their levels of 
exposure. ATSDR's drinking water distribution system model is based on 
current and historical information for the base water system as well as 
historical information on the sources of the contamination. The results 
of the model are intended to establish whether the mothers of the 
individuals with the birth defects or childhood cancers were more 
likely to have been exposed during their pregnancy to the drinking 
water contaminants than were the mothers of the comparison individuals. 
ATSDR officials said they did not expect to finalize exposure 
categories for the current study until February or March 2007, after 
most water modeling activities were completed, but noted that they 
would use the water modeling results to assign multiple exposure levels 
to each study participant. Additionally, data gathered from the survey 
about the mothers' drinking water and other home water use activities, 
such as dishwashing, clothes washing, and bathing, will be combined 
with the estimated exposures levels to create another exposure measure. 
ATSDR officials also said the current study will analyze results for 
individuals who were exposed to TCE separately from those exposed to 
PCE and will analyze cancer and each type of birth defect separately. 
The study is expected to be completed by December 2007. 

[End of section] 

Appendix VIII: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Marcia Crosse (202) 512-7119 or crossem@gao.gov: 

Acknowledgments: 

In addition to the contact named above, Bonnie Anderson, Assistant 
Director; Karen Doran, Assistant Director; George Bogart; Helen 
Desaulniers; Cathleen Hamann; Danielle Organek; Roseanne Price; 
Christina Ritchie; and Stuart Ryba made key contributions to this 
report. 

FOOTNOTES 

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

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

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

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

[5] Superfund Amendments and Reauthorization Act of 1986, Pub. L. No. 
99-499, §110, 100 stat. 1613, 1642 (codified at 42 U.S.C. § 9604(i). 

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

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

[8] U.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). 

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

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

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

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

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

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

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

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

[17] In 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. 

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

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

[20] At 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. 

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

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

[23] See 42 U.S.C. § 9620(e). 

[24] See 10 U.S.C. §§ 2701-2709. 

[25] See 10 U.S.C. § 2701(a)(2). 

[26] See 42 U.S.C. § 9607(a)(4)(D). 

[27] See 10 U.S.C. § 2704(c). 

[28] ATSDR 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). 

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

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

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

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

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

[34] In 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. 

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

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

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

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

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

[40] According 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. 

[41] The 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. 

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

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

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

[45] Although 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. 

[46] U.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). 

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

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

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

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

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

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

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

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

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

[56] Additionally, the EPA CID concluded that funding for the current 
study was apparently delayed because of opposition characterized as a 
professional difference of opinion as to the scientific value of the 
study by a midlevel manager at the Navy Environmental Health Center. 

[57] A 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. 

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

[59] The 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. 

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

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

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

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

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

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

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

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

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

[69] The Freedom of Information Act generally ensures public access to 
federal agency records. Upon written request, federal government 
agencies are required to disclose those records, unless they can be 
lawfully withheld from disclosure under specific exemptions in the act. 
5 U.S.C. § 552. 

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

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

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

[73] ATSDR'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. 

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

[75] The 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. 

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

[77] ATSDR'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. 

[78] One 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. 

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

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

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

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