Defense Health Care

Activities Related to Past Drinking Water Contamination at Marine Corps Base Camp Lejeune Gao ID: GAO-07-276 May 11, 2007

In the early 1980s, volatile organic compounds (VOCs) were discovered in some of the water systems serving housing areas on Marine Corps Base Camp Lejeune. Exposure to certain VOCs may cause adverse health effects, including cancer. In 1999, the Department of Health and Human Services' (HHS) Agency for Toxic Substances and Disease Registry (ATSDR) began a study to examine whether individuals who were exposed in utero to the contaminated drinking water are more likely to have developed certain childhood cancers or birth defects. ATSDR has projected a December 2007 completion date for the study. The National Defense Authorization Act of Fiscal Year 2005 required GAO to report on past drinking water contamination and related health effects at Camp Lejeune. In this report GAO describes (1) efforts to identify and address the past contamination, (2) activities resulting from concerns about possible adverse health effects and government actions related to the past contamination, and (3) the design of the current ATSDR study, including the study's population, time frame, selected health effects, and the reasonableness of the projected completion date. GAO reviewed documents, interviewed officials and former residents, and contracted with the National Academy of Sciences to convene an expert panel to assess the design of the current ATSDR study.

Efforts to identify and address the past drinking water contamination at Camp Lejeune began in the 1980s, when Navy water testing at Camp Lejeune detected VOCs in some base water systems. In 1982 and 1983, continued testing identified two VOCs--trichloroethylene (TCE), a metal degreaser, and tetrachloroethylene (PCE), a dry cleaning solvent--in two water systems that served base housing areas, Hadnot Point and Tarawa Terrace. In 1984 and 1985 a Navy environmental program identified VOCs, such as TCE and PCE, in some of the individual wells serving the Hadnot Point and Tarawa Terrace water systems. Ten wells were subsequently removed from service. Department of Defense (DOD) and North Carolina officials concluded that on- and off-base sources were likely to have caused the contamination. It has not been determined when contamination at Hadnot Point began. ATSDR has estimated that well contamination at Tarawa Terrace from an off-base dry cleaner began as early as 1957. Activities related to concerns about possible adverse health effects began in 1991, when ATSDR initiated a public health assessment evaluating the possible health risks from exposure to the contaminated drinking water. The health assessment was followed by two health studies, one of which is ongoing. While ATSDR did not always receive requested funding and experienced delays in receiving information from DOD for its Camp Lejeune-related work, ATSDR officials said this has not significantly delayed their work. Former residents and employees have filed about 750 claims against the federal government. Additionally, three federal inquiries into issues related to the contamination have been conducted--one by a Marine Corps-chartered panel and two by the Environmental Protection Agency (EPA). Members of the expert panel that the National Academy of Sciences convened generally agreed that many parameters of ATSDR's current study are appropriate, including the study population, the exposure time frame, and the selected health effects. ATSDR's study is examining whether individuals who were exposed in utero to the contaminated drinking water at Camp Lejeune between 1968 and 1985 were more likely to have specific birth defects or childhood cancers than those not exposed. DOD, EPA, and HHS provided technical comments on a draft of this report, which GAO incorporated where appropriate. Three members of an ATSDR community assistance panel for Camp Lejeune provided oral comments on issues such as other VOCs that have been detected at Camp Lejeune, and compensation, health benefits, and additional notification for former residents. GAO focused its review on TCE and PCE because they were identified by ATSDR as the chemicals of primary concern. GAO's report notes that other VOCs were detected. GAO incorporated the panel members' comments where appropriate, but some issues were beyond the scope of this report.



GAO-07-276, Defense Health Care: Activities Related to Past Drinking Water Contamination at Marine Corps Base Camp Lejeune This is the accessible text file for GAO report number GAO-07-276 entitled 'Defense Health Care: Activities Related to Past Drinking Water Contaminating at Marine Corps Base Camp Lejeune' which was released on May 11, 2007. This text file was formatted by the U.S. Government Accountability Office (GAO) to be accessible to users with visual impairments, as part of a longer term project to improve GAO products' accessibility. Every attempt has been made to maintain the structural and data integrity of the original printed product. Accessibility features, such as text descriptions of tables, consecutively numbered footnotes placed at the end of the file, and the text of agency comment letters, are provided but may not exactly duplicate the presentation or format of the printed version. 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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]:

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