Defense Health Care
Issues Related to Past Drinking Water Contamination at Marine Corps Base Camp Lejeune Gao ID: GAO-07-933T June 12, 2007In the early 1980s, volatile organic compounds (VOC) were discovered in some of the water systems serving housing areas on Marine Corps Base Camp Lejeune. Exposure to certain VOCs may cause adverse health effects, including cancer. Since 1991, the Department of Health and Human Services' Agency for Toxic Substances and Disease Registry (ATSDR) has been examining whether individuals who were exposed to the contaminated drinking water are likely to have adverse health effects. ATSDR's current study is examining whether individuals who were exposed in utero are more likely to have developed certain childhood cancers or birth defects. GAO was asked to testify on its May 11, 2007 report: Defense Health Care: Activities Related to Past Drinking Water Contamination at Marine Corps Base Camp Lejeune (GAO-07-276). This testimony summarizes findings from the report about (1) efforts to identify and address the past drinking water contamination, (2) the provision of funding and information from the Department of Defense (DOD) to ATSDR, and (3) an assessment of the design of the current ATSDR study. GAO reviewed documents, interviewed officials and former residents, and contracted with the National Academy of Sciences to convene an expert panel to assess the current ATSDR study.
Efforts to identify and address the past drinking water contamination at Camp Lejeune began in the 1980s, when Navy water testing at Camp Lejeune detected VOCs in some base water systems. In 1982 and 1983, continued testing identified two VOCs--trichloroethylene (TCE), a metal degreaser, and tetrachloroethylene (PCE), a dry cleaning solvent--in two water systems that served base housing areas, Hadnot Point and Tarawa Terrace. In 1984 and 1985 a Navy environmental program identified VOCs, such as TCE and PCE, in some of the individual wells serving the Hadnot Point and Tarawa Terrace water systems. Ten wells were subsequently removed from service. DOD and North Carolina officials concluded that on- and off-base sources were likely to have caused the contamination. It has not been determined when contamination at Hadnot Point began. ATSDR has estimated that well contamination at Tarawa Terrace from an off-base dry cleaner began as early as 1957. Since ATSDR began its Camp Lejeune-related work in 1991, the agency has not always received requested funding and has experienced delays in receiving information from DOD. However, ATSDR officials said that while funding and access to records were probably slowed down and made more expensive by DOD officials' actions, their actions did not significantly impede ATSDR's Camp Lejeune-related health study efforts. The ATSDR officials also stated that while issues such as limitations in access to DOD data had to be addressed, such situations are normal during the course of a study. Members of the expert panel that the National Academy of Sciences convened for GAO generally agreed that many parameters of ATSDR's current study are appropriate, including the study population, the exposure time frame, and the selected health effects. Regarding the study's proposed completion date of December 2007, the panel experts had mixed opinions: three of the five panel experts who commented said that the projected date appeared reasonable, while two said that the date might be optimistic. DOD, the Environmental Protection Agency, and the Department of Health and Human Services provided technical comments on a draft of the May 11, 2007 report, which GAO incorporated where appropriate. Three members of an ATSDR community assistance panel for Camp Lejeune provided oral comments on issues such as other VOCs that have been detected at Camp Lejeune, and compensation, health benefits, and additional notification for former residents. GAO focused its review on TCE and PCE because they were identified by ATSDR as the chemicals of primary concern. GAO's report notes that other VOCs were detected. GAO incorporated the panel members' comments where appropriate, but some issues were beyond the scope of the report.
GAO-07-933T, Defense Health Care: Issues Related to Past Drinking Water Contamination at Marine Corps Base Camp Lejeune
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Testimony:
Before the Subcommittee on Oversight and Investigations, Committee on
Energy and Commerce, House of Representatives:
United States Government Accountability Office:
GAO:
For Release on Delivery Expected at 10:00 a.m. EDT:
Tuesday, June 12, 2007:
Defense Health Care:
Issues Related to Past Drinking Water Contamination at Marine Corps
Base Camp Lejeune:
Statement of Marcia Crosse:
Director, Health Care:
GAO-07-933T:
GAO Highlights:
Highlights of GAO-07-933T, a testimony before the Subcommittee on
Oversight and Investigations, Committee on Energy and Commerce, House
of Representatives
Why GAO Did This Study:
In the early 1980s, volatile organic compounds (VOC) were discovered in
some of the water systems serving housing areas on Marine Corps Base
Camp Lejeune. Exposure to certain VOCs may cause adverse health
effects, including cancer. Since 1991, the Department of Health and
Human Services‘ Agency for Toxic Substances and Disease Registry
(ATSDR) has been examining whether individuals who were exposed to the
contaminated drinking water are likely to have adverse health effects.
ATSDR‘s current study is examining whether individuals who were exposed
in utero are more likely to have developed certain childhood cancers or
birth defects.
GAO was asked to testify on its May 11, 2007 report: Defense Health
Care: Activities Related to Past Drinking Water Contamination at Marine
Corps Base Camp Lejeune (GAO-07-276). This testimony summarizes
findings from the report about (1) efforts to identify and address the
past drinking water contamination, (2) the provision of funding and
information from the Department of Defense (DOD) to ATSDR, and (3) an
assessment of the design of the current ATSDR study. GAO reviewed
documents, interviewed officials and former residents, and contracted
with the National Academy of Sciences to convene an expert panel to
assess the current ATSDR study.
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. DOD and North Carolina officials concluded that
on- and off-base sources were likely to have caused the contamination.
It has not been determined when contamination at Hadnot Point began.
ATSDR has estimated that well contamination at Tarawa Terrace from an
off-base dry cleaner began as early as 1957.
Since ATSDR began its Camp Lejeune-related work in 1991, the agency has
not always received requested funding and has experienced delays in
receiving information from DOD. However, ATSDR officials said that
while funding and access to records were probably slowed down and made
more expensive by DOD officials‘ actions, their actions did not
significantly impede ATSDR‘s Camp Lejeune-related health study efforts.
The ATSDR officials also stated that while issues such as limitations
in access to DOD data had to be addressed, such situations are normal
during the course of a study.
Members of the expert panel that the National Academy of Sciences
convened for GAO generally agreed that many parameters of ATSDR‘s
current study are appropriate, including the study population, the
exposure time frame, and the selected health effects. Regarding the
study‘s proposed completion date of December 2007, the panel experts
had mixed opinions: three of the five panel experts who commented said
that the projected date appeared reasonable, while two said that the
date might be optimistic.
DOD, the Environmental Protection Agency, and the Department of Health
and Human Services provided technical comments on a draft of the May
11, 2007 report, which GAO incorporated where appropriate. Three
members of an ATSDR community assistance panel for Camp Lejeune
provided oral comments on issues such as other VOCs that have been
detected at Camp Lejeune, and compensation, health benefits, and
additional notification for former residents. GAO focused its review on
TCE and PCE because they were identified by ATSDR as the chemicals of
primary concern. GAO‘s report notes that other VOCs were detected. GAO
incorporated the panel members‘ comments where appropriate, but some
issues were beyond the scope of the report.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-933T].
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Marcia Crosse at (202)
512-7119 or crossem@gao.gov.
[End of section]
Mr. Chairman and Members of the Subcommittee:
I am pleased to be here today as you examine issues related to past
drinking water contamination at Camp Lejeune. In the early 1980s,
Department of the Navy water testing at Marine Corps Base Camp Lejeune
identified contamination in water systems that served housing areas on
the base.[Footnote 1] Further water testing revealed that some of the
individual wells serving two of the water systems were contaminated
with volatile organic compounds (VOC), such as trichloroethylene (TCE),
which is a metal degreaser and an ingredient in adhesives and paint
removers, and tetrachloroethylene (PCE), which is a solvent used in the
textile industry and a dry cleaning solvent. Although it is not known
precisely when the wells became contaminated, the Department of Health
and Human Services' (HHS) Agency for Toxic Substances and Disease
Registry (ATSDR), which is investigating the issue, has estimated that
the contamination may have begun as early as the 1950s. According to
ATSDR, the VOCs of primary concern at Camp Lejeune were TCE and PCE,
and the agency notes that exposure to these chemicals may cause adverse
health effects. For example, exposure to low levels of TCE may cause
headaches and difficulty concentrating.[Footnote 2] Exposure to high
levels of both TCE and PCE may cause dizziness, headaches, nausea,
unconsciousness, cancer, and possibly death.[Footnote 3]
Former residents of Camp Lejeune have taken legal action against the
federal government for injuries alleged to have resulted from exposure
to the contaminated water. As of June 2007, about 850 former residents
and former employees of Camp Lejeune have filed tort claims with the
Department of the Navy related to the past drinking water
contamination. Two of these claims have resulted in the filing of
lawsuits in Federal District Courts in Texas and Mississippi.[Footnote
4] In addition, some former residents have expressed concern over the
Marine Corps' handling of and response to the drinking water
contamination, noting that even though contaminants were detected as
early as 1980, the wells that were determined to be contaminated were
not removed from service until 1985. Some former residents have also
asserted that there have been delays in the provision of funding and
information from the Department of Defense (DOD) to ATSDR.[Footnote 5]
My statement is based on our May 11, 2007 report, Defense Health Care:
Activities Related to Past Drinking Water Contamination at Marine Corps
Base Camp Lejeune (GAO-07-276). For this report, the Ronald W. Reagan
National Defense Authorization Act for Fiscal Year 2005 directed that
we study and report on the past drinking water contamination and
related adverse health effects at Camp Lejeune, including identifying
the type, source, and duration of the contamination and determining the
actions taken to address the contamination, and assessing the current
ATSDR health study.[Footnote 6] My remarks today will summarize our
findings related to the history of events related to drinking water
contamination at Camp Lejeune, specifically, (1) efforts to identify
and address the past contamination; (2) the provision of funding and
information from DOD to ATSDR for its work related to the past
contamination at Camp Lejeune; and (3) an assessment by an independent
panel of experts of the design of the current ATSDR health study,
including the study's population, the exposure time frame, selected
health effects being measured, and the reasonableness of the projected
completion date.
To do this work, we reviewed more than 1,600 documents related to past
and current drinking water activities at Camp Lejeune. We focused our
review on the past TCE and PCE contamination[Footnote 7] because ATSDR
had noted that these chemicals were the VOCs of primary concern at Camp
Lejeune. However, we also reviewed documentation regarding other VOCs
detected at Camp Lejeune. For this testimony we focused on
contamination in Camp Lejeune's Hadnot Point, Tarawa Terrace, and
Holcomb Boulevard water systems, as they provided drinking water to
most of the installation's housing areas during the period of interest.
We interviewed current and former officials from various DOD entities,
including Camp Lejeune, Headquarters Marine Corps, and the Department
of the Navy, to obtain information about the history of events related
to the past drinking water contamination at Camp Lejeune, including
efforts to identify and address the contamination. The current and
former officials interviewed often provided information based on their
memory of events that occurred more than 20 years ago. We attempted to
corroborate their testimonial evidence with documentation whenever
possible. The former officials we interviewed were responsible for
environmental activities at Camp Lejeune or the Department of the Navy
during the time in which the contamination was detected. The current
officials we interviewed are responsible for environmental activities
at Camp Lejeune, Headquarters Marine Corps, or the Department of the
Navy. Some of these current officials were also responsible for
environmental activities during the time in which the contamination was
detected. We also met with 19 interested former residents and
individuals who worked on the base during the 1960s, 1970s, and 1980s,
in order to obtain their perspective on historical events and to learn
about their concerns related to the drinking water contamination. A
former resident who is active in matters related to the past drinking
water contamination at Camp Lejeune identified most of the interested
former residents; others were identified at an ATSDR public meeting.
Additionally, we examined reports from and interviewed officials with
the Environmental Protection Agency (EPA) and with the North Carolina
Department of Environment and Natural Resources who were knowledgeable
about activities and costs related to the cleanup of the suspected
sources of contamination. We also interviewed ATSDR officials and
reviewed ATSDR's Camp Lejeune-related documents and publications,
including a 1997 public health assessment and an ATSDR health study
released in 1998. We also interviewed officials with the Department of
the Navy and the U.S. Army Center for Health Promotion and Preventive
Medicine, which serves as a liaison between DOD and ATSDR. To assess
the design of the current ATSDR health study, we contracted with the
National Academy of Sciences (NAS) to convene a panel of seven subject
area experts for a 1-day meeting. The expert panel was charged with
evaluating the study's population, exposure time frame, selected health
effects, and completion date. We relied primarily on information
gleaned from the expert panel meeting and the panel experts' subsequent
written responses to the set of questions that were discussed during
the 1-day meeting. Not all panel members commented individually about
each of the questions discussed during the 1-day meeting. Additionally,
some panel members noted that certain questions addressed subjects that
were outside their areas of expertise. We also reviewed study-related
documentation furnished by officials from ATSDR, the Marine Corps, and
the Navy Environmental Health Center, and interviewed officials from
those agencies. We conducted our work from May 2005 through April 2007
in accordance with generally accepted government auditing standards.
In summary, we found that efforts to identify and address past drinking
water contamination at Camp Lejeune began in the 1980s, when the Navy
initiated water testing, and are continuing with long-term cleanup and
monitoring. In 1980, VOCs, including TCE, were first detected at Camp
Lejeune during an analysis by a Navy-contracted laboratory that
combined treated water from all base water systems. During the same
year, the Navy began monitoring Camp Lejeune's treated water for total
trihalomethanes (TTHMs), contaminants that are a by-product of the
water treatment process. The TTHM monitoring indicated interference
from unidentified chemicals. In 1982 and 1983, continued TTHM
monitoring identified TCE and another VOC, PCE, as contaminants in two
separate water systems that served base housing areas, Hadnot Point and
Tarawa Terrace. Sampling results indicated that the levels of TCE and
PCE found in the water systems varied. Former Camp Lejeune
environmental officials said that they did not take additional steps to
address the contamination after TCE and PCE were identified. The former
officials recalled that they did not act because at that time they had
little knowledge about TCE and PCE, there were no drinking water
regulations that gave enforceable limits for these chemicals, and
variation in water testing results raised questions about the tests'
validity. Also in 1982, a Navy environmental program began
investigating potentially contaminated sites at many Marine Corps and
Navy bases, including Camp Lejeune. Testing initiated under that
program in 1984 and 1985 found that individual wells in the Hadnot
Point and Tarawa Terrace water systems were contaminated with TCE, PCE,
and other VOCs. Camp Lejeune officials removed 10 contaminated wells
from service in 1984 and 1985. Camp Lejeune officials determined that
several areas on base where hazardous waste and other materials were
disposed of may have been the sources of contamination for the Hadnot
Point water system, and North Carolina environmental officials
determined that an off-base dry cleaner was the likely source of
contamination for the Tarawa Terrace water system. Efforts are ongoing
by ATSDR to determine when contamination at Hadnot Point began. In
2006, ATSDR estimated that well contamination from the off-base dry
cleaner began as early as 1957. In 1989, both Camp Lejeune and the off-
base dry cleaner were placed on EPA's National Priorities List.
Regarding the provision of funding and information from DOD to ATSDR
for its work related to the past contamination at Camp Lejeune, we
found that since ATSDR began its Camp Lejeune-related work in 1991, the
agency has not always received requested DOD funding and experienced
delays in receiving information from DOD. For example, for 3 of the 16
fiscal years during which ATSDR has conducted its Camp Lejeune-related
work (fiscal years 1998 through 2000), no funding was provided to ATSDR
by the Navy or any DOD entity. ATSDR also had difficulties getting
documents needed from Camp Lejeune while it was conducting a public
health assessment for the base. However, ATSDR officials said that
while funding and access to records were probably slowed down and their
Camp Lejeune related work made more expensive by DOD officials'
actions, their actions did not significantly impede ATSDR's Camp
Lejeune-related health study efforts. The ATSDR officials also stated
that while issues such as limitations in access to DOD data had to be
addressed, such situations are normal during the course of a study.
The experts convened by NAS to assess the design of the current ATSDR
health study generally agreed that many parameters of ATSDR's current
study are appropriate. Regarding the study population, all seven panel
experts agreed that ATSDR's study population of individuals who were
potentially exposed in utero to the contaminated drinking water at Camp
Lejeune between 1968 and 1985 was appropriate, as this population was
arguably the most vulnerable to the effects of the contamination. Panel
experts generally agreed that the 1968-1985 study time frame was
reasonable, based on limitations in data availability for the years
prior to 1968. Regarding the health effects studied, five of the seven
panel experts discussed health effects and said that the selected birth
defects and childhood cancers were relevant. Regarding the proposed
completion date, the panel experts had mixed opinions: three of the
five panel experts who commented said that the projected December 2007
date appeared reasonable, while two said that the date might be
optimistic.
DOD, EPA, and HHS provided technical comments on a draft of the May 11,
2007 report, which we incorporated where appropriate. We provided the
seven former Camp Lejeune residents who are members of an ATSDR
community assistance panel for Camp Lejeune the opportunity to provide
comments on our draft--three of the panel members provided both
technical and general oral comments, and four declined to review the
draft report. The three panel members commented generally on issues
such as VOCs other than TCE and PCE that have been detected at Camp
Lejeune, compensation and health benefits for former residents, and
additional notification for former residents. We incorporated the panel
members' technical comments where appropriate, but some issues they
discussed were beyond the scope of the report.
Background:
Drinking water can come from either groundwater sources, via wells, or
from surface water sources, such as rivers, lakes, and streams. All
sources of drinking water contain some naturally occurring
contaminants. As water flows in streams, sits in lakes, and filters
thorough layers of soil and rock in the ground, it dissolves or absorbs
the substances that it touches. Some of these contaminants are
harmless, but others can pose a threat to drinking water, such as
improperly disposed-of chemicals, pesticides, and certain naturally
occurring substances. Likewise, drinking water that is not properly
treated or disinfected, or which travels through an improperly
maintained water system, may pose a health risk. However, the presence
of contaminants does not necessarily indicate that water poses a health
risk--all drinking water may reasonably be expected to contain at least
small amounts of some contaminants. As of July 2006, EPA had set
standards for approximately 90 contaminants in drinking water that may
pose a risk to human health. According to EPA, water that contains
small amounts of these contaminants, as long as they are below EPA's
standards, is safe to drink. However, EPA notes that people with
severely compromised immune systems and children may be more vulnerable
to contaminants in drinking water than the general population.
General Information about Camp Lejeune and Its Water Systems:
Camp Lejeune covers approximately 233 square miles in Onslow County,
North Carolina, and includes training schools for infantry, engineers,
service support, and medical support, as well as a Naval Hospital and
Naval Dental Center. The base has nine family housing areas, and
families live in base housing for an average of 2 years. Base housing
at Camp Lejeune consists of enlisted family housing, officer family
housing, and bachelor housing (barracks for unmarried service
personnel). Additionally, schools, day care centers, and administrative
offices are located on the base. Approximately 54,000 people currently
live and work at Camp Lejeune, including about 43,000 active duty
personnel and 11,000 military dependents and civilian employees.
In the 1980s, Camp Lejeune obtained its drinking water from as many as
eight water systems, which were fed by more than 100 individual wells
that pumped water from a freshwater aquifer located approximately 180
feet below the ground. Each of Camp Lejeune's water systems included
wells, a water treatment plant, reservoirs, elevated storage tanks, and
distribution lines to provide the treated water to the systems'
respective service areas. Drinking water at Camp Lejeune has been
created by combining and treating groundwater from multiple individual
wells that are rotated on and off, so that not all wells are providing
water to the system at any given time. Water is treated in order to
remove minerals and particles and to protect against microbial
contamination. (See fig. 1 for a description of how a Camp Lejeune
water system operates.)
Figure 1: Conceptual Model of a Camp Lejeune Water System:
[See PDF for image]
Sources: 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, and Holcomb
Boulevard water systems provided drinking water to most of Camp
Lejeune's housing areas. The water treatment plants for the Hadnot
Point and Tarawa Terrace water systems were constructed during the
1940s and 1950s. The water treatment plant for the Holcomb Boulevard
water system began operating at Camp Lejeune in 1972; prior to this
time, the Hadnot Point water system provided water to the Holcomb
Boulevard service area. In the 1980s, each of these three systems had
between 8 and 35 wells that could provide water to their respective
service areas. In 1987 the Tarawa Terrace water treatment plant was
shut down and the Holcomb Boulevard water distribution system was
expanded to include the Tarawa Terrace water service area.
Generally, housing units served by the Tarawa Terrace and Holcomb
Boulevard water systems consisted of family housing, which included
single-and multifamily homes and housing in trailer parks. Housing
units served by the Hadnot Point water system included mainly bachelor
housing with limited family housing. Based on available housing data
for the late 1970s and the 1980s,[Footnote 8] the estimated annual
averages of the number of people living in family housing
units[Footnote 9] 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,
and:
* 71 people in units served by the Hadnot Point water system.
In addition to serving housing units, all three water systems provided
water to base administrative offices. The Tarawa Terrace, Holcomb
Boulevard, and Hadnot Point water systems also served schools and other
recreational areas. Additionally, the Hadnot Point water system also
served an industrial area and the base hospital.
Department of the Navy Environmental Functions:
Certain Navy entities provide support functions for Marine Corps bases
such as Camp Lejeune. Two entities provide support for environmental
issues:
* 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 10] For example,
LANTDIV officials work with Camp Lejeune officials to establish
environmental cleanup priorities and cost estimates and to allocate
funding to ensure compliance with state and federal environmental
regulations.
* 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.
Environmental Laws and Regulations Related to Drinking Water
Contamination and Hazardous Waste Contamination at Camp Lejeune:
Congress passed the Safe Drinking Water Act in 1974[Footnote 11] to
protect the public's health by regulating the nation's public drinking
water supply. The Safe Drinking Water Act, as amended, is the key
federal law protecting public water supplies from harmful contaminants.
For example, the act requires that all public water systems conduct
routine tests of treated water to ensure that the water is safe to
drink. Required water testing frequencies vary and range from weekly
testing for some contaminants to testing every 3 years for other
contaminants. The act also established a federal-state arrangement in
which states may be delegated primary implementation and enforcement
authority for the drinking water program. For contaminants that are
known or anticipated to occur in public water systems and that EPA
determines may have an adverse impact on health, the act requires EPA
to set a nonenforceable maximum contaminant level goal, at which no
known or anticipated adverse health effects occur and that allows an
adequate margin of safety. Once the maximum contaminant level goal is
established, EPA sets an enforceable standard for water as it leaves
the treatment plant, the maximum contaminant level. A maximum
contaminant level is the maximum permissible level of a contaminant in
water delivered to any user of a public water system. The maximum
contaminant level must be set as close to the goal as is feasible using
the best technology or other means available, taking costs into
consideration. The North Carolina Department of Environment and Natural
Resources and its predecessors[Footnote 12] have had primary
responsibility for implementation of the Safe Drinking Water Act in
North Carolina since 1980.
In 1979, EPA promulgated final regulations applicable to certain
community water systems establishing the maximum contaminant levels for
the control of TTHMs, which are a type of VOC that are formed when
disinfectants--used to control disease-causing contaminants in drinking
water--react with naturally occurring organic matter in water. The
regulations required that water systems that served more than 10,000
people and that added a disinfectant as part of the drinking water
treatment process begin mandatory water testing for TTHMs by November
1982 and comply with the maximum contaminant level by November 1983.
TCE and PCE were not among the contaminants included in these
regulations.
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 13] Suggested no adverse response levels
provided EPA's estimate of the short-and long-term exposure to TCE and
PCE in drinking water for which no adverse response would be observed
and described the known information about possible health risks for
these chemicals. Suggested action guidance recommended remedial actions
within certain time periods when concentrations of contaminants
exceeded specific levels. Suggested action guidance was issued for PCE
related to drinking water contamination from coated asbestos-cement
pipes, which were used in water distribution lines.
The initial regulation of TCE and PCE under the Safe Drinking Water Act
began in 1989 and 1992, respectively, when maximum contaminant levels
became effective for these contaminants. (See table 1 for the suggested
no adverse response levels, suggested action guidance, and maximum
contaminant level regulations for TCE and PCE.)
Table 1: EPA Guidance and Regulations for Trichloroethylene (TCE) and
Tetrachloroethylene (PCE) in Drinking Water:
Nonenforceable guidance: TCE: [Empty]; TCE: [Empty]; Enforceable
regulation: Maximum contaminant level in milligrams per liter (mg/l)
and ppb[C] effective in 1989 (TCE) and 1992 (PCE): TCE: [Empty].
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 (Jan. 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 14] established what is known as the
Superfund program to clean up highly contaminated waste sites and
address the threats that these sites pose to human health and the
environment, and assigned responsibility to EPA for administering the
program.[Footnote 15] CERCLA was amended by the Superfund Amendments
and Reauthorization Act (SARA) of 1986.[Footnote 16] Among other
things, SARA requires that federal agencies, including DOD, that own or
operate facilities on EPA's CERCLA list of seriously contaminated
sites, known as the National Priorities List, enter into an interagency
agreement with EPA.[Footnote 17] The agreement is to specify what
cleanup activities, if any, are required and to set priorities for
carrying out those activities.[Footnote 18] SARA also established the
Defense Environmental Restoration Program, through which DOD conducts
environmental cleanup activities at military installations.[Footnote
19] Under the environmental restoration program, DOD's activities
addressing hazardous substances, pollutants, or contaminants are
required to be carried out consistent with the provisions of CERCLA
governing environmental cleanups at federal facilities.[Footnote 20]
Based on environmental contamination at various areas on the base, Camp
Lejeune was designated as a National Priorities List site in 1989. EPA,
the Department of the Navy, and the state of North Carolina entered
into a Federal Facilities Agreement concerning cleanup of Camp Lejeune
with an effective date of March 1, 1991.
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 21]
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 22] Based on the memorandum
of understanding signed between ATSDR and DOD, ATSDR is required to
submit an annual plan of work to DOD, in which it must describe the
public health activities it plans to conduct at DOD sites in the
following fiscal year, as well as the amount of funding required to
conduct these activities. After the annual plan of work has been
submitted, DOD has 45 days to respond and negotiate the scope of work
to be conducted by ATSDR. The memorandum of understanding states that
DOD must seek sufficient funding through the DOD budgetary process to
carry out the work agreed upon.
From 1991 to 1997, ATSDR conducted a public health assessment at Camp
Lejeune that was required by law because of the base's listing on the
National Priorities List. The health assessment evaluated several ways
in which people on base had been exposed to hazardous substances,
including exposure to the VOC-contaminated drinking water.[Footnote 23]
In its 1997 report, ATSDR recommended that a study be carried out to
evaluate the risks of childhood cancer in those who were exposed in
utero to the contaminated drinking water and also noted that adverse
pregnancy outcomes were of concern. In 1995, while the health
assessment was being conducted, ATSDR initiated a study to determine
whether there was an association between exposure to VOCs in drinking
water and specific adverse pregnancy outcomes among women who had lived
at Camp Lejeune from 1968 through 1985.[Footnote 24] The study,
released in 1998, originally concluded that there was a statistically
significant elevated risk for several poor pregnancy outcomes,
including (1) small for gestational age among male infants born to
mothers living at Hadnot Point, (2) small for gestational age for
infants born to mothers over 35 years old living at Tarawa Terrace, and
(3) small for gestational age for infants born to mothers with two or
more prior fetal losses living at Tarawa Terrace.[Footnote 25] However,
ATSDR officials said they are reanalyzing the findings of this study
because of an error in the original assessment of exposure to VOCs in
drinking water. While the study originally assessed births from 1968 to
1972 in the Holcomb Boulevard service area as being unexposed to VOCs,
these births were exposed to contaminants from the Hadnot Point water
system. An ATSDR official said the reanalysis may alter the study's
results.
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 26] The current study began with a
survey to identify potential cases of the selected birth defects and
childhood cancers. The study is also using water modeling[Footnote 27]
to help ATSDR determine the potential sources of past contamination and
estimate when the water became contaminated and which housing units
received the contaminated water. The water modeling data will help
ATSDR identify which pregnant women may have been exposed to the
contaminated water, and will also help ATSDR estimate the amount of TCE
and PCE that may have been in the drinking water. ATSDR officials said
that the study is expected to be completed by December 2007.
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, the NACIP
program identified VOCs, including TCE and PCE, in 12 of the wells
serving the Hadnot Point and Tarawa Terrace water systems. Camp Lejeune
officials removed 10 wells from service in 1984 and 1985. Additionally,
information about the contamination was provided to residents. Upon
investigating the contamination, DOD and North Carolina officials
concluded that both on-and off-base sources were likely to have caused
the contamination in the Hadnot Point and Tarawa Terrace water systems.
Since 1989, federal, state, and Camp Lejeune officials have partnered
to take actions to clean up the sources of contamination and to monitor
and protect the base's drinking water.
Navy Water Testing Beginning in 1980 Identified VOCs in Camp Lejeune
Water Systems:
The presence of VOCs in Camp Lejeune water systems was first detected
in October 1980. On October 1, 1980, samples of water were collected
from all eight water systems at Camp Lejeune by an official from
LANTDIV, a Navy entity that provided environmental support to Camp
Lejeune. The water samples were combined into a single sample, and a
"priority pollutant scan" was conducted in order to detect possible
contaminants in the water systems. The results of this analysis,
conducted by a Navy-contracted private laboratory and sent to LANTDIV,
identified 11 VOCs, including TCE, at their detection limits, that is,
the lowest level at which the chemicals could be reliably identified by
the instruments being used.[Footnote 30]
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 31] LANTDIV arranged for an Army laboratory to
begin testing the treated water from two Camp Lejeune water systems,
Hadnot Point and New River, in October 1980. At that time, these two
water systems were the only ones that served more than 10,000 people
and therefore would be required to meet the future TTHM regulation.
From October 1980 to September 1981, eight samples were collected from
the Hadnot Point water system and analyzed for TTHMs. Results from four
of the eight samples indicated the presence of unidentified chemicals
that were interfering with the TTHM analyses.[Footnote 32] Reports for
each of the four analyses contained an Army laboratory official's
handwritten notes about the unidentified chemicals: two of the notes
classified the water as "highly contaminated" and notes for the other
two analyses recommended analyzing the water for organic compounds.
The exact date when LANTDIV officials began receiving results from TTHM
testing is not known, and LANTDIV officials told us that they had no
recollection of how or when the results were communicated from the Army
laboratory. Available Marine Corps documents indicate that Camp Lejeune
environmental officials[Footnote 33] learned in July 1981 that LANTDIV
had been receiving the results of TTHM testing and was holding the
results until all planned testing was complete. Subsequently, Camp
Lejeune environmental officials requested copies of the TTHM results
that LANTDIV had received to date, and LANTDIV provided these results
in August 1981. The next documented correspondence from LANTDIV to Camp
Lejeune regarding TTHM monitoring occurred in a February 1982
memorandum in which LANTDIV recommended that TTHM monitoring be
expanded to all of Camp Lejeune's water systems and noted that Camp
Lejeune should contract with a North Carolina state-certified
laboratory for the testing. Current and former LANTDIV officials
recalled that their agency played a limited role in providing
information or guidance regarding environmental issues at Camp Lejeune,
and that this assistance generally would have been at the request of
Camp Lejeune officials. However, former Camp Lejeune environmental
officials recalled that at that time they had little experience in
water quality issues and relied on LANTDIV to serve as their
environmental experts.
Further Tests Identified TCE and PCE in Two Camp Lejeune Water Systems
in 1982 and 1983; Camp Lejeune Officials Do Not Recall Taking Action to
Address the Contamination at That Time:
Following LANTDIV's recommendation to expand TTHM monitoring to all
base water systems, Camp Lejeune officials contracted with a private
state-certified laboratory to test samples of treated water from all
eight of their water systems. According to an August 1982 memorandum,
in May 1982 a Camp Lejeune official was informed during a telephone
conversation with a private laboratory official that organic cleaning
solvents, including TCE, were present in the water samples for TTHM
monitoring from the Hadnot Point and Tarawa Terrace water systems. In
July 1982, additional water samples from the two systems were collected
in an effort to investigate the presence of these chemicals. In August
1982 the contracted laboratory sent a letter to base officials
informing them that TCE and PCE were identified as the contaminants in
the May and July samples. According to the letter, the testing
determined that the Hadnot Point water system was contaminated with
both TCE and PCE and the Tarawa Terrace water system was contaminated
with PCE. The letter also noted that TCE and PCE "appeared to be at
high levels" and were "more important from a health standpoint" than
the TTHM monitoring. Sampling results indicated that the levels of TCE
and PCE varied. The letter noted that one sample taken in May 1982 from
the Hadnot Point water system contained TCE at 1,400 parts per billion
and two samples taken in July 1982 contained TCE at 19 and 21 parts per
billion. Four samples taken in May 1982 and July 1982 from the Tarawa
Terrace water system contained levels of PCE that ranged from 76 to 104
parts per billion. (See table 2 for the May and July 1982 sampling
results.)
Table 2: Sampling Results from Hadnot Point and Tarawa Terrace Water
Systems for May 1982 and July 1982:
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]:
